ML18037A704

Response to Request for Additional Information Regarding Proposed License Amendment Request for Spent Fuel Storage and New Fuel Storage

ML18037A704
Person / Time
Site:	North Anna
Issue date:	01/31/2018
From:	Bischof G T Virginia Electric & Power Co (VEPCO)
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
16-383B, CAC MF9712, CAC MF9713
Download: ML18037A704 (9)

Text

.. VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 23261 U.S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, DC 20555 January 31, 2018 Serial No.: NRA/DEA Docket Nos.: License Nos.: 10 CFR 50.90 16-383B RO 50-338/339 NPF-4/7 VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION ENERGY VIRGINIA)

NORTH ANNA POWER STATION UNITS 1 AND 2 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION PROPOSED LICENSE AMENDMENT REQUEST FOR SPENT FUEL STORAGE AND NEW FUEL STORAGE (CAC Nos. MF9712 AND MF9713) By letter dated May 2, 2017, Dominion submitted a license amendment request (LAR) to revise Technical Specifications

{TS) 3.7.18, "Spent Fuel Pool Storage" and TS 4.3.1 "Criticality." Conforming changes were proposed to Technical Specifications Bases (TSB) 83.7.18. In an email dated December 21, 2017, the NRC transmitted a request for additional information (RAI) related to the LAR. A January 31, 2018 response date was requested.

The response to the RAI is provided in Attachment

1. Attachment 2 provides a revised marked-up change to TS 4.3.1.1 and Attachment 3 provides the proposed change page forTS4.3.1.1.

Should you have any questions in regard to this submittal, please contact Diane E. Aitken at (804) 273-2694.

Sincerely, Vice President

-Nuclear Operations and Fleet Performance COMMONWEAL TH OF VIRGINIA COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President

-Nuclear Operations and Fleet Performance of Virginia Electric and Power Company. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behaW of that Company, and that the statements in the dM true to the best of his knowledge and belief Acknowledged before me this 3...1!£..

day of , 2018. ftp O I My Commission Expires: S -3 J -/8 . . z /J /

• p._ i, . <..AldL_,, r. If,. Notary Public f V Commitments made in this letter: None Attachments:

1. Response to Request for Additional Information

2. Marked-up Technical Specification page 3. Proposed Technical Specification change page Serial No. 16-3838 Docket Nos.: 50-338/339 Page 2 of 3

., cc: U.S. Nuclear Regulatory Commission

-Region II Marquis One Tower 245 Peachtree Center Avenue, NE Suite 1200 Atlanta, GA 30303-1257 State Health Commissioner Virginia Department of Health James Madison Building -7th floor 109 Governor Street Suite 730 Richmond, VA 23219 Mr. James R. Hall NRC Senior Project Manager -North Anna U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 Ms. Karen Cotton-Gross NRC Project Manager U.S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 G-9A 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector North Anna Power Station Mr. J. E. Reasor, Jr. Old Dominion Electric Cooperative Innsbrook Corporate Center 4201 Dominion Blvd. Suite 300 Glen Allen, VA 23060 Serial No. 16-3838 Docket Nos.: 50-338/339 Page 3 of 3 Attachment 1 RESPONSE TO Serial No. 16-3838 Docket Nos.: 50-338/339 REQUEST FOR ADDITIONAL INFORMATION VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION ENERGY VIRGINIA)

NORTH ANNA POWER STATION UNITS 1 AND 2 Technical Basis for the Request Serial No. 16-3838 Docket Nos.: 50-338/339 Attachment 1 Page 1 of 1 Section 2.2 of Attachment 1 of the LAR provides a description of the changes to TS 4.3.1.1. Attachment 2 of the LAR provides marked up technical specification pages showing the proposed changes, including TS page 4.0-2, which shows the proposed deletion of the text identifying a specific document providing the methodology used to calculate uncertainties in keff, in both TS 4.3.1.1.b.

and c. Section 2.2 of Attachment 1 does not describe the basis for the proposed deletions of text. NUREG-1431 contains the staff's guidance on one manner of format and content for TSs that would meet the regulatory requirements of 10 CFR 50.36. The current NAPS TS 4.3.1.1 and NUREG-1431 both cite the location of the methodologies used to calculate uncertainties in keff* It appears the LAR is proposing deletion of the location of the methodologies used to calculate uncertainties in keff in TS 4.3.1.1 without fully describing why the deletion is appropriate for NAPS. RAI Please provide a full description and justification for the proposed deletion of the location of the methodology used to calculate uncertainties in keff in TS 4.3.1.1, or, alternatively, provide a revised change to TS 4.3.1.1 that retains the citation of the location of the methodology used to calculate uncertainties in keff* RAI Response As indicated in the request for additional information (RAI), the license amendment request (LAR) submitted May 2, 2017, proposed the deletion of text identifying a specific document providing the methodology used to calculate uncertainties in keff, in both Technical Specification (TS) 4.3.1.1.b.

and c without describing why the change was appropriate.

The specific document cited in the current TS 4.3.1.1 as providing the methodology used to calculate uncertainties in keff is the LAR letter describing the analysis that was reviewed by the NRC prior to approval of the current TS 4.3.1.1. Deletion of this text was appropriate since the cited LAR letter was obsolete (superseded by the methodology provided in the LAR submittal dated May 2, 2017). Guidance in NUREG-1431, Standard Technical Specifications

-Westinghouse Plants, Volume 1, Specifications, indicates it is appropriate to include a reference to the Final Safety Analysis Report (FSAR) as the location of the methodology used to calculate uncertainties in keff in TS 4.3.1.1. Updated Final Safety Analysis Report (UFSAR) Section 9.1 will be revised to include the methodology used to calculate uncertainties in keff during implementation of the approved LAR. Therefore, a mark-up of Technical Specification 4.3.1.1 that adds UFSAR Section 9.1 as the location of the methodology used to calculate uncertainties in keff is provided in Attachment

2. The associated proposed change to Technical Specification 4.3.1.1 is provided in Attachment

3.

Attachment 2 Serial No. 16-383B Docket Nos.: 50-338/339 MARKED-UP TECHNICAL SPECIFICATION PAGE VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION ENERGY VIRGINIA)

NORTH ANNA POWER STATION UNITS 1 AND 2

4.0 DESIGN

FEATURES 4.3.1.1 (continued)

UFSARSection

9.1 Design

Features 4.0 b. keff < 1.0 if full flooded with unborated water,_.............

which includes allowance for uncertainties~

calculated in ccordance with the methodology described in *

• letter dated Septe111ber

27. 2000 (Serial No.00-491); and biases c. keff 0.95 if fu~flooded with water borated to 900 ~~)-'35fr ppm, which~cl~des an allowance for uncertainties calculated in accordance with the methodology described in w~~t.5:tr

!c ctr.id flower eu111par1y 1 e L Ler* da Led 3ep L"e!mJ' , OM C3er I al No. 00 ~91); and UFSARSection9.1

d. A nominal 10 9/16 inch center to center distance between fuel assemblies placed in the fuel storage racks. 4.3.1.2 The new fuel storage racks are designed and shall be maintained with: 5.0 a. Fuel assemblies having a maximum U-235 enrichment of weight percent; 4.3.2 Drainage b. keff 0.95 if fully flooded with unborated water, which includes an allowance for uncertain~

and biases ----'

• c. keff 0.98 if moderated by aqueou~~m, which includes an allowance for uncertai"'nti~

and d. A nominal 21 inch center to center distance between fuel assemblies placed in the storage racks. The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 285 feet, 9 inches, Mean Sea Level, USGS datum. 4.3.3 Capacity The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 1737 fuel assemblies.

North Anna Units 1 and 2 4.0-2 Amendme~ts 231/212 and biases Attachment 3 Serial No. 16-3838 Docket Nos.: 50-338/339 PROPOSED TECHNICAL SPECIFICATION CHANGE PAGE VIRGINIA ELECTRIC AND POWER COMPANY (DOMINION ENERGY VIRGINIA)

NORTH ANNA POWER STATION UNITS 1 AND 2

4.0 DESIGN

FEATURES Design Features 4.0 4.3.1.1 (continued)

b. keff < 1.0 if fully flooded with unborated water, which includes an allowance for uncertainties and biases calculated in accordance with the methodology described in UFSAR Section 9.1; c. keff 0.95 if fully flooded with water borated to 900 pp~, which includes an allowance for uncertainties and biases calculated in accordance with the methodology described in UFSAR Section 9.1; and d. A nominal 10 9/16 inch center to center distance between fuel assemblies placed in the fuel storage racks. 4.3.1.2 The new fuel storage racks are designed and shall be maintained with: 4.3.2 Drainage a. Fuel assemblies having a maximum U-235 enrichment of 5.0 weight percent; b. keff 0.95 if fully flooded with unborated water, which includes an allowance for uncertainties and biases; c. keff 0.98 if moderated by aqueous foam, which includes an allowance for uncertainties and biases; and d. A nominal 21 inch center to center distance between fuel assemblies placed in the storage racks. The spent fuel storage pool is designed and shall be maintained to prevent inadvertent draining of the pool below elevation 285 feet, 9 inches, Mean Sea Level, USGS datum. 4.3.3 Capacity The spent fuel storage pool is designed and shall be maintained with a storage capacity limited to no more than 1737 fuel assemblies.

North Anna Units 1 and 2 4.0-2 Amendments