ML22243A032

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Presentation Material for 9/7/22 Pre-Submittal Meeting Supplement to the Spent Fuel Pool Criticality Safety Analysis
ML22243A032
Person / Time
Site: Millstone Dominion icon.png
Issue date: 09/07/2022
From:
Dominion Energy Nuclear Connecticut
To:
NRC/NRR/DORL/LPL1
Guzman R
References
EPID L-2022-LRM-0058
Download: ML22243A032 (15)
v • d • e


Text

Millstone Power Station Unit 3 (MPS3)

Supplement to the Spent Fuel Pool (SFP) Criticality Safety Analysis (CSA)

September 7, 2022 1

MPS3 - Supplement to the SFP CSA Agenda

  • Background
  • Reason for Request
  • Proposed Resolution
  • Proposed Justification for Submittal
  • Submittal Conclusion
  • Schedule 2 September 7, 2022

MPS3 - Supplement to the SFP CSA

Background

  • Three different SFP rack types at MPS3:
  • Region 1 - Boral poisoned, flux trap design
  • Region 1B: Two rows closest to SFP wall
  • Region 1A: Remaining rows of Region 1
  • Region 2 - Boral poisoned, non-flux trap design
  • Region 3 - Uncredited Boraflex, flux trap design 3 September 7, 2022

MPS3 - Supplement to the SFP CSA Background (cont.)

  • Current CSA was submitted in 2018 and approved in 2019
  • Analysis has a modern CSA methodology based on NEI 12-16, Revision 3 (current Revision at the time of approval)
  • Current CSA takes credit for burnup
  • CSA demonstrated that the burnable poison (BP) WABA bounds IFBA during depletion
  • Technical Specification burnup curves assume assemblies contain maximum WABA during depletion 4 September 7, 2022

MPS3 - Supplement to the SFP CSA Background (cont.)

  • Current CSA did not have any discussion on the use of gadolinia as a burnable poison
  • The SE, accordingly, did not have any discussion on the use of gadolinia
  • Citing NEI 12-16 alone is not sufficient for including gadolinia, the applicability of previous work must be demonstrated
  • This is stated in the RG 1.240, C.1.p clarification
  • This is also stated in the 2018 North Anna CSA SE 5 September 7, 2022

MPS3 - Supplement to the SFP CSA

Reason for Request

  • New fuel assembly design will be used at MPS3
  • Gadolinia will be used as the burnable poison
  • Depletion credit in the CSA assumes a different burnable poison type
  • CSA does not justify that gadolinia is bounded 6 September 7, 2022

MPS3 - Supplement to the SFP CSA Proposed Resolution

  • Submit a supplement to the current MPS3 CSA to the NRC
  • Justify through previous work that the use of gadolinia BP is bounded by the current CSAs burnup credit analysis
  • Demonstrate the previous works applicability to MPS3
  • Scope:
  • No Technical Specifications are being changed
  • No credit is being taken for gadolinia in fresh fuel
  • No calculations are being updated or added to the current CSA
  • Only change is to extend the burnup credits bounds of applicability 7 September 7, 2022

MPS3 - Supplement to the SFP CSA Proposed Justification for Submittal

  • Discussion of the NRC endorsed guidance in RG 1.240
  • NEI 12-16 states modeling no gadolinia is conservative during depletion
  • These reports investigated the effects of gadolinia on burnup credit and determined its use to be conservative
  • DENC will demonstrate that these findings are applicable to MPS3 (Satisfying the RG 1.240, C.1.p clarification) 8 September 7, 2022

MPS3 - Supplement to the SFP CSA Proposed Justification for Submittal (cont.)

  • Discussion of previous utility submittals with gadolinia work
  • Prairie Island (2013) and Millstone Unit 2 (2016) submittals investigated the effects of gadolinia on burnup credit and determined its use to be conservative
  • DENC will demonstrate that these findings are applicable to MPS3
  • The CSA normal and accident scenarios will remain conservative 9 September 7, 2022

MPS3 - Supplement to the SFP CSA Proposed Justification for Submittal (cont.)

  • No changes to current Technical Specifications
  • New Fuel Storage Area takes no BP credit
  • Region 1A - high enrichment, low burnup, gadolinia cannot be used
  • SFP burnup credit applicability extended to include gadolinia BP Unused with gadolinia fuel Burnup requirements apply to gadolinia fuel 10 September 7, 2022

MPS3 - Supplement to the SFP CSA Submittal Conclusion

  • Industry guidance reports demonstrated that gadolinia can conservatively be unmodeled in the depletion analysis
  • Supplement will demonstrate applicability to MPS3
  • Utility submittals demonstrated that gadolinia can conservatively be unmodeled in the depletion analysis
  • Supplement will demonstrate applicability to MPS3
  • Therefore, the depletion analysis in the current MPS3 SFP CSA bounds the effects associated with the use of gadolinia BP 11 September 7, 2022

MPS3 - Supplement to the SFP CSA Schedule

  • Submittal date is targeted for 4Q2022
  • NRC approval will be requested 12 months after submittal
  • Supports implementation by 3R23 (spring 2025) outage
  • If this supplement is approved, DENC would consider these items as the licensing basis for MPS3 SFP criticality:
  • Approved SFP CSA in 2019, including RAIs and SE
  • Approved 2022 CSA Supplement 12 September 7, 2022

MPS3 - Supplement to the SFP CSA Questions?

13 September 7, 2022

MPS3 - Supplement to the SFP CSA References MPS3 Licensing Basis

  • Letter to NRC, Millstone, Unit 3, License Amendment Request Regarding Proposed Technical Specifications Changes for Spent Fuel Storage and New Fuel Storage, 05/03/2018 (NRC ADAMS Accession Number ML18128A049).
  • Letter from NRC to DENC, Millstone Power Station, Unit No. 3 - Issuance of Amendment No. 273 Regarding Technical Specification Changes for Spent Fuel Storage and New Fuel Storage (EPID L-2018-LLA-0126), 05/28/2019 (NRC ADAMS Accession Number ML19126A000).

Industry Guidance

  • NEI 12-16, Revision 3, "Guidance for Performing Criticality Analyses of Fuel Storage at Light-Water Reactor Power Plants, 03/31/2018 (NRC ADAMS Accession Number ML18088B400).
  • NEI 12-16, Revision 4, Guidance for Performing Criticality Analyses of Fuel Storage at Light-Water Reactor Power Plants, 09/30/2019 (NRC ADAMS Accession Number ML19269E069).
  • Regulatory Guide RG 1.240, Fresh and Spent Fuel Pool Criticality Analyses, 03/31/2021 (NRC ADAMS Accession Number ML20356A127).

Utility SEs

  • Letter from NRC to Prairie Island, Prairie Island Nuclear Generating Plant, Units 1 and 2 - Issuance of Amendments re: Spent Fuel Pool Criticality Changes, 08/29/2013 (NRC ADAMS Accession Number ML13241A383).
  • Letter from NRC to DENC, Millstone Power Station, Unit 2 - Issuance of Amendment No. 327 Re: Proposed Technical Specification Changes for Spent Fuel Storage (CAC No. MF0435), 06/23/2016 (NRC ADAMS Accession Number ML16003A008).

14 September 7, 2022

MPS3 - Supplement to the SFP CSA Acronyms

  • BP - Burnable Poison
  • CFR - Code of Federal Regulations
  • CSA - Criticality Safety Analysis
  • EPRI - Electric Power Research Institute
  • IFBA - Integral Fuel Burnable Absorber
  • MPS3 - Millstone Power Station Unit 3
  • NEI - Nuclear Energy Institute
  • NRC - Nuclear Regulatory Commission
  • RAI - Request for Addition Information
  • RG - Regulatory Guide
  • SE - Safety Evaluation
  • SFP - Spent Fuel Pool
  • WABA - Wet Annular Burnable Absorber 15 September 7, 2022
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