ML15016A205

Supplemental Information Needed for Acceptance of Requested Licensing Action Spent Fuel Pool Criticality Analysis (Tac No. MF5282)

ML15016A205
Person / Time
Site:	Indian Point
Issue date:	01/21/2015
From:	Pickett D Plant Licensing Branch 1
To:	Entergy Nuclear Operations
Pickett D
References
TAC MF5282
Download: ML15016A205 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Vice President, Operations Entergy Nuclear Operations, Inc. Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 January 21, 2015

SUBJECT:

INDIAN POINT NUCLEAR GENERATING UNIT NO.2-SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION RE: SPENT FUEL POOL CRITICALITY ANALYSIS (TAC NO. MF5282)

Dear Sir or Madam:

By letter dated November 13, 2014, Entergy Nuclear Operations, Inc., Entergy, or the licensee, submitted a proprietary and non-proprietary version of NETCO Report NET-300067-01, "Criticality Safety Analysis of the Indian Point Unit 2 Spent Fuel Pool with Credit for Inserted Neutron Absorber Panels." NET-300067-01 includes NETCO's methodology for analyzing spent fuel pool criticality.

Entergy requested Nuclear Regulatory Commission (NRC) review and approval to support a future license amendment request. The NRC staff understands that Entergy plans on crediting NRC approval of NET-300067-01 in a future license amendment request that will propose technical specification changes associated with the installation of new neutron absorber panels. The purpose of this letter is to provide the results of the NRC staff's acceptance review of this request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant. The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed request in terms of regulatory requirements and the protection of public health and safety and the environment.

In order to make the application complete, the NRC staff requests that Entergy supplement the application to address the information requested in the enclosure within 13 working days or February 5, 2015. This will enable the staff to begin its detailed technical review. If the information responsive to the staff's request is not received by the above date, the application will not be accepted for review pursuant to Title 10 of the Code of Federal Regulations Section 2.101, "Filing of Application," and the staff will cease its review activities associated with the application.

If the application is subsequently accepted for review, you will be advised of any further information needed to support the staff's detailed technical review by separate correspondence. The information requested and associated time frame in this letter were discussed with Mr. Robert Walpole of your staff on January 16, 2015. If you have any questions, please contact me at 301-415-1364.

Docket No. 50-247

Enclosure:

As stated cc w/encl: Distribution via Listserv Sincerely, Douglas V. Pickett, Senior Project Manager Plant Licensing Branch 1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation SUPPLEMENTAL INFORMATION NEEDED NETCO SPENT FUEL POOL CRITICALITY ANALYSIS ENTERGY NUCLEAR OPERATIONS.

INC. INDIAN POINT NUCLEAR GENERATING UNIT NO.2 DOCKET NO. 50-247 NRC's Reactor Systems Branch is currently performing the NRR Office Instruction LIC-1 09 acceptance review for NETCO Report NET-300067-01, "Criticality Safety Analysis of the Indian Point Unit 2 Spent Fuel Pool with Credit for Inserted Neutron Absorber Panels," that was included in the licensee's application dated November 13, 2014 (Agencywide Documents Access and Management System Accession No. ML14329A194).

The staff has recommended a finding of non-accept with the opportunity to supplement.

The staff has identified concerns regarding the depletion code validation methodology.

In the application, it is stated that For the burned fuel, two approaches for validation are used: EPRI Benchmarks

[9, 1 0] and an extension of ISG-8, Rev. 3 [11 ]. The more limiting of the two approaches is used for the validation of the burned fuel. Both Reference

[9]: K. S. Smith, et al., Benchmarks for Quantifying Fuel Reactivity Depletion Uncertainty, EPRI, Palo Alto, CA, Technical Report Number 1022909 (2011) and Reference

[1 0]: D. B. Lancaster, Utilization of the EPRI Depletion Benchmarks for Burn up Credit Validation, EPRI, Palo Alto, CA, 1025203 (2012), are currently under review and are not approved for generic use. LIC-1 09 states that the NRC staff will not accept new licensing actions that rely on unapproved topical reports. While the staff review of the two referenced EPRI reports is ongoing, final resolution may involve a significant amount of time. Furthermore, the "Extended ISG-8" approach to Reference

[11]: Spent Fuel Project Office Interim Staff Guidance -8, Rev 3-Burn up Credit in the Criticality Safety Analyses of PWR Spent Fuel in Transport and Storage Casks, NRC, April 2012, does not conform to staff guidance as intended.

There are significant deviations and the methodology is not consistent with current NRR guidance provided in DSS-ISG-201 0-01 regarding depletion code validation.

The NRC staff recommends that the application be supplemented and based upon NRC-approved methodologies.

Enclosure The information requested and associated time frame in this letter were discussed with Mr. Robert Walpole of your staff on January 16, 2015. If you have any questions, please contact me at 301-415-1364.

Docket No. 50-247

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

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