ML18249A386

Closeout of Generic Letter 2016-01, Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools (CAC Nos. MF9433 and MF9434; EPID L-2016-LRC-0001)

ML18249A386
Person / Time
Site:	Indian Point
Issue date:	09/26/2018
From:	Doug Broaddus Special Projects and Process Branch
To:	Entergy Nuclear Operations
Wall S, NRR/DORL/LPLLSPB, 415-2855
References
CAC MF9433, CAC MF9434, EPID L-2016-LRC-0001, GL-2016-001
Download: ML18249A386 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 26, 2018 0MB Control No. 3150-0231 Vice President, Operations Entergy Nuclear Operations, Inc.

Indian Point Energy Center 450 Broadway, GSB P.O. Box249 Buchanan, NY 10511-0249

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNITS 2 AND 3 - CLOSEOUT OF GENERIC LETTER 2016-01, "MONITORING OF NEUTRON-ABSORBING MATERIALS IN SPENT FUEL POOLS" (CAC NOS. MF9433 AND MF9434; EPID L-2016-LRC-0001)

Dear Sir or Madam:

On April 7, 2016, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2016-01, "Monitoring of Neutron-Absorbing Materials in Spent Fuel Pools" (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16097A169), to address the degradation of neutron-absorbing materials (NAMs) in wet storage systems for reactor fuel at power and non-power reactors.

The generic letter requested that licensees provide information to allow the NRC staff to verify continued compliance through effective monitoring to identify and mitigate any degradation or deformation of NAMs credited for criticality control in spent fuel pools (SFPs ).

By letters dated November 3, 2016 (ADAMS Accession Nos. ML16314E261 and ML16314E266), as supplemented by letter dated May 30, 2018 (ADAMS Accession No. ML18151A858), Entergy Nuclear Operations, Inc. (the licensee), responded to GL 2016-01 for Indian Point Nuclear Generating Units 2 and 3 (IP2 and IP3). The licensee credits Boral for criticality control at IP3 and has an established NAM monitoring program. The NRC staff's review determined that the provided response sufficiently addressed the five areas of information described in Appendix A of GL 2016-01 for Boral. In particular, the described monitoring program for the Boral includes the following key features:

• Neutron attenuation testing of coupons.

• Established processes to ensure that the licensee will take the appropriate corrective actions if any potentially non-conforming material is discovered.

• A testing frequency not to exceed 5 years.

• Acceptance criteria to ensure maintenance of the 5-percent subcriticality margin for the SFP.

The NRC staff found that the licensee intends to continue monitoring the condition of its NAMs as described in its response.

In the licensee's respol"!se to GL 2016-01, as supplemented, the licensee stated that some deformation has been identified as part of its Boral monitoring program. The licensee also stated that the observed deformation is bounded by the criticality studies documented in Electric Power Research Institute (EPRI) Report 3002013119, "Evaluation of the Impact of Neutron Absorber Material Blistering and Pitting on Spent Fuel Pool Reactivity," May 2018 (ADAMS Accession No. ML18226A292).

EPRI Report 3002013119 documents a series of sensitivity studies performed on representative SFP rack configurations to demonstrate that the amount of observed pitting and blistering would not be expected to have a significant reactivity impact. Preliminary conclusions are obtained based on the estimated reactivity impact from EPRI Report 3002013119 for pitting and blistering dimensions that go well beyond that observed by the licensee's monitoring program.

The NRC staff notes that the studies documented in EPRI Report 3002013119 are intended to be generic analyses and were not provided as site-specific analyses. Therefore, the results of the analyses, or any part of those analyses, have currently not been shown as directly applicable to IP3. In addition, the NRC staff did not review whether the EPRI Reports could be used to justify equipment operability, design basis changes, or licensing changes requested pursuant to Title 10 of the Code of Federal Regulations, Section 50.90, "Application for amendment of license, construction permit, or early site permit." However, the NRC staff's review determined that the EPRI report does provide the information required to satisfy the request in GL 2016-01 for Boral at this time.

In the licensee's response to GL 2016-01, as supplemented, the licensee also credits Boraflex for criticality control at IP2 and identified the Boraflex installed in the SFP at IP2 as being in a degraded condition and entered the issue in its Corrective Action Program. This resulted in the licensee implementing corrective actions to manage Boraflex degradation and maintain subcriticality in the SFP. The NRC staff acknowledges that a license amendment request is currently under review which would, if approved, remove credit for Boraflex to meet NRC subcriticality requirements. Should this occur, no further actions will be necessary to address Boraflex degradation. If necessary, the NRC staff will perform a follow-up inspection through the baseline reactor oversight process to ensure that the licensee is properly managing the degradation and maintaining the subcriticality of the SFP.

Based upon the information submitted by the licensee in response to GL 2016-01, the NRC staff has determined that the submission addresses the information requested in GL 2016-01, and no further information is requested regarding this matter. If necessary, the NRG staff will perform a Boraflex-specific follow-up inspection through the baseline reactor oversight process to ensure that the licensee is properly managing the degradation and maintaining the subcriticality of the SFP. Any safety or timeliness issues associated with the degraded condition of the Boraflex will

be addressed through NRC inspection activities consistent with Inspection Manual Chapter (IMC) 0326, "Operability Determinations & Functionality Assessments for Conditions Adverse to Quality or Safety."

Sincerely, Douglas A. Broaddus, Chief Special Projects and Process Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-247 and 50-286 cc: ListServ

ML18249A386 *via email OFFICE NRR/DORL/LSPB/PM NRR/DORL/LPL 1/PM NRR/DORL/LAiT NRR/DORL/LSPB/LA NAME $Wall RGuzman PTalukdar JBurkhardt DATE 09/25/18 09/18/18 09/11/18 09/17/18 OFFICE NRR/DMLR/MCCB/BC* NRR/DI RS/I RGB/BC* NRR/DSS/SNPB/BC* NRR/DORL/LSPB/BC NAME $Bloom BPham RLukes DBroaddus DATE 09/25/18 09/25/18 09/19/18 09/26/18