ML12283A350

Summary of 9/13/12 Meeting with Luminant Generation Company LLC to Discuss Proposed License Request for Approval of Revised Spent Fuel Criticality Analysis to Update Comanche Peak, Units 1 and 2, Technical Specifications (TAC Nos. ME8896 an

ML12283A350
Person / Time
Site:	Comanche Peak
Issue date:	10/25/2012
From:	Balwant Singal Plant Licensing Branch IV
To:	Plant Licensing Branch IV
Singal B
References
TAC ME8896, TAC ME8897
Download: ML12283A350 (5)

Text

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01' NUCLEAR REGULATORY

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Luminant Generation Company LLC Comanche Peak Nuclear Power Plant, Units 1 and 2

SUMMARY

OF SEPTEMBER 13, 2012, PRE-LICENSING PUBLIC MEETING WITH LUMINANT GENERATION COMPANY LLC TO DISCUSS THE PROPOSED LICENSE AMENDMENT REQUEST FOR APPROVAL OF THE REVISED SPENT FUEL POOL CRITICALITY ANALYSIS (TAC NOS. ME8896 AND ME8897) On September 13, 2012, a public meeting was held between the U.S. Nuclear Regulatory Commission (NRC), and representatives of Luminant Generation Company LLC (Luminant, the licensee), at NRC Headquarters, Rockville, Maryland.

The meeting notice and agenda, dated August 27,2012, is located in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML12216A299.

The purpose of the meeting was to discuss the proposed license amendment request (LAR) for approval of the revised spent fuel pool criticality analysis (SFPCA) and associated spent fuel storage configurations at Comanche Peak Nuclear Power Plant (CPNPP), Units 1 and 2. A list of meeting attendees is provided as an Enclosure to this meeting summary. Meeting Summary The discussion included an overview of the proposed SFPCA LAR for CPNPP, Units 1 and 2, as follows:

• Purpose

• SFPCA background and status

• Fuel assembly configuration control program overview

• SFPCA methodology

• Meeting summary and conclusions with proposed submittal schedule A copy of the non-proprietary version of the meeting materials/handouts is located at ADAMS Accession No. ML12236A332.

Results of Discussions The NRC staff expressed concern about the complex spent fuel storage configurations proposed by the licensee as part of the revised SFPCA, which could potentially result in the spent fuel assembly (SFA) being loaded at the wrong location.

The licensee indicated that it plans to implement detailed procedures and updated/new software for developing surveillance reports to document acceptability of each configuration, graphical output to assist in review process, verification of planned fuel move sequences

-and configurations, and color codes visual aid maps for review and fuel move planning purposes to account for the complexity.

The NRC staff suggested that the licensee consider the complexity of the spent fuel storage configurations versus the overall benefits.

The NRC staff also indicated that preparation of no significant hazards consideration in support of the proposed LAR may be a challenge and suggested a robust justification in support of no significant hazards consideration. The licensee stated that the updated software mentioned in item 1 will meet the quality assurance criteria specified by Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants," of the Title 10 of the Code of Federal Regulations (10 CFR). Part 50. The NRC staff and the licensee discussed the need to address misloading of SFAs. The licensee made several references to Westinghouse Electric Company, llC (Westinghouse)

Topical Report WCAP-17483-P.

Revision 0, "Westinghouse Methodology for Spent Fuel Pool and New Fuel Rack Criticality Safety Analysis," December 2011. submitted to the NRC staff for review and approval on December 20, 2011 (ADAMS Accession No. Ml113640206).

The NRC staff suggested that for sake of schedule, the proposed CPNPP submittal should be standalone document and should not be based on the results of the unapproved Westinghouse WCAP. The NRC staff stated that because the Westinghouse document is generic in nature. it is likely to take more review time and the results of the NRC staff review of the WCAP may not be available for use for the CPNPP submittal.

The licensee confirmed that the CPNPP document will be a standalone document and its purpose in referencing the WCAP in the CPNPP LAR is only for future use by other licensees. The licensee stated that it intends to use the Electric Power Research Institute (EPRI) depletion uncertainty methodology to either develop an appropriate depletion uncertainty by benchmarking PARAGON with the EPRI methodology or support the 5 percent depletion uncertainty as per guidance provided in Interim Staff Guidance DSS-ISG-201 0-01, Revision 0, "Staff Guidance Regarding the Nuclear Criticality Safety Analysis for Spent Fuel Pools" (ADAMS Accession No. Ml11 0620086).

The NRC staff stated that the EPRI document has not been reviewed or endorsed by the NRC staff for use and the analysis provided should be standalone without any dependence on the results of the EPRI document not reviewed and approved by the NRC satff. The CPNPP spent fuel pool (SFP) utilizes BORAl neutron absorbing material in Region 1 storage racks. The licensee presented plans to utilize guidance from the 2012 EPRI Report "Strategy for Managing long Term Use of BORAl in Spent Fuel Storage Racks". Specifically, the monitoring program described would rely on (1) conservative assumptions related to degradation related geometry changes within the Criticality Analysis, and (2) monitoring industry operating experience related to BORAl degradation.

The NRC stated that the EPRI report has not been reviewed or endorsed by the NRC staff. Furthermore, the NRC acknowledged that a program which does not monitor the actual BORAl material in the CPNPP SFP would be difficult to justify. More favorable approaches discussed included the use of test coupons (which would monitor for adverse reactions between the material and the SFP water chemistry environment), or an in-situ testing program of the installed panels.

-3 The licensee clarified that in addition to Region 2 of CPNPP, Units 1 and 2, the licensee plans to revise the SFPCA for Region 1 also. Based on the discussions during the meeting, the NRC staff believes that the licensee plans to address only the final SFA storage configurations resulting in the revised SFPCA. The NRC staff asked the licensee also to address the existing interim condition to provide justification for use of the NRC Administrative Letter (AL) 98-10, "Dispositioning of Technical Specifications That are Insufficient to Assure Plant Safety," dated December 29, 1998 (ADAMS Accession No. ML031110108).

The NRC staff expressed the concern that the current spent fuel storage practice with regard to the uprated fuel at CPNPP, Units 1 and 2 may not meet the current TS 3.7.17, "Spent Fuel Assembly Storage,>>

requirements for the uprated fuel. The licensee indicated that based on the current status of the project, it plans to submit the LAR to the NRC staff for review by the end of March 2013. For the purposes of resource planning, the NRC staff wanted to know how firm the schedule was, The licensee informed the NRC staff that its management is committed to the proposed schedule and the schedule should be very firm. No Public Meeting Feedback Forms were received for this meeting. Please direct any inquiries to me at (301) 415-3016, or balwant.singal@nrc.gov.

Sincerely, R' \/1 0 !. () \ ' ",,-t Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and 50-446

Enclosures:

list of Attendees cc w/encl: Distribution via Listserv LIST OF SEPTEMBER 13, 2012, MEETING WITH LUMINANT GENERATION COMPANY REGARDING PROPOSED LICENSE AMENDMENT FOR APPROVAL OF REVISED SPENT FUEL POOL CRITICALITY ANALYSIS ASSOCIATED TECHNICAL SPECIFICATION COMANCHE PEAK NUCLEAR POWER PLANT, UNITS 1 AND DOCKET NOS. 50-445 AND NAME TITLE ORGANIZATION KentWood Team Leader U.S. Nuclear Regulatory Commission (NRC) GerryWaig*

Senior Reactor Systems Engineer NRC David Proulx* Senior Project Engineer NRC (Region IV) : Wayne Walker* Branch Chief NRC (Region IV) 'Emma Wong Chemical Engineer NRC Balwant K. Singal Senior Project Manager NRC Michael Markley**

Branch Chief NRC Tim Hope Manager, Nuclear Licensing Luminant Generation Company LLC (Luminant)

Jimmy Seawright Consulting Engineer, Regulatory Luminant Affairs Matthew Weeks Core Performance, Engineering Luminant Manager Cody Lemons Core Performance Engineer Luminant Dave Goodwin Director, Engineering Projects Luminant Darren Smith . Project Manager Westinghouse Electric i (Westinghousef Kris Cummings , Manager, Fuel Engineering Westinghouse

+

• Licensing Blanco Andrew Criticality Analyst Westinghouse

+ Keith Waldrop Senior Project Manager Electric Power Research Institute

+

• Participated via phone ** Attended the meeting part time + Represented Luminant Enclosure

-The licensee clarified that in addition to Region 2 of CPNPP, Units 1 and 2, the licensee plans to revise the SFPCA for Region 1 also. Based on the discussions during the meeting, the NRC staff believes that the licensee plans to address only the final SFA storage configurations resulting in the revised SFPCA. The NRC staff asked the licensee also to address the existing interim condition to provide justification for use of the NRC Administrative Letter (AL) 98-10, "Dispositioning of Technical Specifications That are Insufficient to Assure Plant Safety," dated December 29, 1998 (ADAMS Accession No. ML031110108).

The NRC staff expressed the concern that the current spent fuel storage practice with regard to the uprated fuel at CPNPP, Units 1 and 2 may not meet the current TS 3.7.17, "Spent Fuel Assembly Storage," requirements for the uprated fuel. The licensee indicated that based on the current status of the project, it plans to submit the LAR to the NRC staff for review by the end of March 2013. For the purposes of resource planning, the NRC staff wanted to know how firm the schedule was. The licensee informed the NRC staff that its management is committed to the proposed schedule and the schedule should be very firm. No Public Meeting Feedback Forms were received for this meeting. Please direct any inquiries to me at (301) 415-3016, or balwant.singal@nrc.gov.

Sincerely, IRA! Balwant K. Singal, Senior Project Manager Plant Licensing Branch IV Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-445 and List of cc w/encl: Distribution via DISTRIBUTION:

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