ML11207A069

Nine Mile Point Nuclear Station - Revised Response to Request for Additional Information Regarding the License Amendment Request for Extended Power Uprate Operation - Boral Monitoring

ML11207A069
Person / Time
Site:	Nine Mile Point
Issue date:	07/15/2011
From:	Belcher S Constellation Energy Group, EDF Group, Nine Mile Point
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME1476
Download: ML11207A069 (6)

Text

Sam Belcher P.O. Box 63Vice President-Nine Mile Point Lycoming, New York 13093315.349.5200315.349.1321 FaxCENGa joint venture ofConstellation eDFEnwe-gyNINE MILE POINTNUCLEAR STATIONJuly 15, 2011U.S. Nuclear Regulatory CommissionWashington, DC 20555-0001ATTENTION: Document Control Desk

SUBJECT:

Nine Mile Point Nuclear StationUnit No. 2; Docket No. 50-410Revised Response to Request for Additional Information Regarding Nine Mile PointNuclear Station, Unit No. 2 -Re: The License Amendment Request for ExtendedPower Uprate Operation (TAC No. ME 1476) -BORAL Monitoring Program

REFERENCES:

(a) Letter from K. J. Poison (NMPNS) to Document Control Desk (NRC), datedMay 27, 2009, License Amendment Request (LAR) Pursuant to 10 CFR 50.90:Extended Power Uprate(b) E-mail from R. Guzman (NRC) to J. J. Dosa (NMPNS), dated June 23, 2011,Supplemental Information Needed for RAI-3(c) Letter from M. A. Philippon (NMPNS) to Document Control Desk (NRC) datedJune 13, 2011', Response to Request for Additional Information Regarding NineMile Point Nuclear Station, Unit No. 2 -Re: The License Amendment Requestfor Extended Power Uprate Operation (TAC No. ME1476) -Steam Dryer andBORAL Monitoring ProgramNine Mile Point Nuclear Station, LLC (NMPNS) hereby transmits revised and supplemental informationin support of a previously submitted request for amendment to Nine Mile Point Unit 2 (NMP2) RenewedOperating License (OL) NPF-69. The request, dated May 27, 2009 (Reference a), proposed anamendment to increase the power level authorized by OL Section 2.C.(1), Maximum Power Level, from3467 megawatts-thermal (MWt) to 3988 MWt.

Document Control DeskJuly 15, 2011Page 2By e-mail dated June 23, 2011 (Reference b), the NRC staff requested supplemental informationregarding the response to a request for additional information (RAI) submitted on June 13, 2011(Reference c) regarding the BORAL Monitoring Program. The Attachment to this letter provides thesupplemental information in the form of a revised response to CSGB-RAI-3.a.There are no regulatory commitments in this submittal.Should you have any questions regarding the information in this submittal, please contact John J. Dosa,Director Licensing, at (315) 349-5219.Very truly yours,STATE OF NEW YORKTO WIT:COUNTY OF OSWEGOI, Sam Belcher, being duly sworn, state that I am Vice President -Nine Mile Point, and that I am dulyauthorized to execute and file this response on behalf of Nine Mile Point Nuclear Station, LLC. To thebest of my knowledge and belief, the statements contained in this document are true and correct. To theextent that these statements are not based on my personal knowledge, they are based upon informationprovided by other Nine Mile Point employees and/or consultants. Such information has been reviewed inaccordance with company practice and I believe it to be reliable.Subscribed and sworn before me, a Notary Public in and for the State of New York and County of,this 15 dayof ,2011.d _JWITNESS my Hand and Notarial Seal: '-4 4 Notary PublicMy Commission Expires:Date 196/_3 U"_ K DomDate !Y U SEb~ Sgswqsywft all!~ O6UIISB/STD w -- .., WM

Attachment:

Revised Response to Request for Additional Information Regarding License AmendmentRequest for Extended Power Uprate Operationcc: NRC Regional Administrator, Region INRC Resident InspectorNRC Project ManagerA. L. Peterson, NYSERDA ATTACHMENTREVISED RESPONSE TO REQUEST FOR ADDITIONALINFORMATION REGARDING LICENSE AMENDMENT REQUEST FOREXTENDED POWER UPRATE OPERATIONNine Mile Point Nuclear Station, LLCJuly 15, 2011 ATTACHMENTREVISED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDINGLICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATIONBy letter dated May 27, 2009, as supplemented on August 28, 2009, December 23, 2009, February 19,2010, April 16, 2010, May 7, 2010, June 3, 2010, June 30, 2010, July 9, 2010, July 30, 2010, October 8,2010, October 28, 2010, November 5, 2010, December 10, 2010, December 13, 2010, January 19, 2011,January 31, 2011, February 4, 2011, March 23, 2011, May 9, 2011, and June 13, 2011, Nine Mile PointNuclear Station, LLC (NMPNS) submitted for Nuclear Regulatory Commission (NRC) review andapproval, a proposed license amendment requesting an increase in the maximum steady-state power levelfrom 3467 megawatts thermal (MWt) to 3988 MWt for Nine Mile Point Unit 2 (NMP2).By e-mail dated June 23, 2011, the NRC staff requested supplemental information regarding the responseto a request for additional information (RAI) submitted on June 13, 2011, regarding the BORALMonitoring Program. This attachment provides the supplemental information in the form of a revisedresponse to CSGB-RAI-3.a.The NRC request is repeated (in italics), followed by the NMPNS response.1 of 3 ATTACHMENTREVISED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDINGLICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATIONRAI#1 from NRC E-mail dated April 14, 2011Supplemental CSGB-RAI-3.aOn page 6 of Attachment 1 of its letter dated March 23, 2011, the licensee states that, "NMPNS does notintend to utilize these coupons [for the initial 10 [BORAL] spent fuel racks] since the coupon tree wasnot installed at the same time as the associated racks." The NRC staff is uncertain whether the[BORAL] material installed in 2001 has an effective surveillance monitoring program. Please providethe surveillance approach and testing for these 10 [BORAL] spent fuel racks.Revised NMPNS ResponseIn an e-mail dated May 12, 2011, the NRC provided the following feedback regarding the response toCSGB-RAI-3.a:Specifically, after review of the response to RAI-3.a, the staff understands that NMPNS would like touse the inspection and testing of coupons installed in 2007 to monitor [BORAL] spent fuel racksinstalled in 2001. However, the staff does not think that using coupons (installed 6 years after the[BORAL] material it's supposed to monitor) is an appropriate surveillance monitoringapproach/program because the racks have had more exposure to spent fuel pool conditions than thecoupons. The NMPNS response appears to be inconsistent with what the staff understood was thelicensee's intended approach for answering the question (when presented in the previous phone call).If a new analysis has been performed to justify using the 2007 coupons to represent the 2001[BORAL] , the staff requests the licensee to provide it as additional explanation to support the RAI-3. a supplemental response.On May, 18, 2011, NMPNS and the NRC discussed the NMP2 monitoring program regarding theBORAL spent fuel racks, and the NRC feedback provided in an e-mail dated May 12, 2011. NMPNSunderstands that the coupon tree installed in 2007, comprised of the same lot of material as our Phase 1BORAL spent fuel racks installed at NMP2 in 2001, does not have as much exposure to the NMP2 spentfuel pool conditions as the spent fuel racks installed in 2001. As such, NMPNS will conduct in-situBoron-10 Areal Density Gauge for Evaluating Racks (BADGER) testing on the Phase 1 BORAL spentfuel racks installed at NMP2 in 2001 on a 10-year frequency, beginning in 2012. The BADGER testingprogram will be the surveillance program for the Phase 1 BORAL spent fuel racks installed at NMP2 in2001.In an e-mail dated June 23, 2011, the NRC requested supplemental information regarding the response toCSGB-RAI-3.a. The NRC e-mail states:In its response dated June 13, 2011, the licensee states that, "NMPNS will conduct in-situ Boron -10Areal Density Gauge for Evaluating Racks (BADGER) testing on the Phase 1 Boral Spent fuel racksinstalled at NMP2 in 2001 on a 1 0-year frequency, beginning in 2012."Based on this response, the NRC staff understands that the licensee plans to perform in-situ testing oftheir Boral spent fuel pool racks installed in 2001; however, the staff notes that NMPNS did notprovide information regarding the acceptance criteria for the in-situ test. While the NRC staff viewsthe licensee's proposed plan to conduct in-situ testing as acceptable, the staff has determined that theacceptance criteria information is needed to complete its safety evaluation for the Boral monitoring2 of 3 ATTACHMENTREVISED RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDINGLICENSE AMENDMENT REQUEST FOR EXTENDED POWER UPRATE OPERATIONprogram. Please note that the original RAI-3 in NRC letter dated February 3, 2011, requested thelicensee to provide the acceptance criteria for its surveillance/monitoring program. Accordingly, thestaff requests NMPNS to provide the acceptance criteria for the in-situ test, including the correctiveactions taken if the acceptance [criterion] is not met.For the Phase 1 BORAL spent fuel racks installed at NMP2 in 2001, the BADGER tests will confirmthat the minimum Boron-10 areal density assumed in the spent fuel pool criticality analyses is met.Currently, the spent fuel pool criticality analyses assume a minimum Boron-10 areal density of 20 mgBoron-10/cm2.Thus, the acceptance criterion for the BADGER tests will be to ensure a Boron-10 arealdensity > 20 mg Boron- 10/cm2.If the acceptance criterion is not met, the following actions would be taken:1. The condition would be entered into the site's Corrective Action Program.2. Administrative controls would be implemented to ensure that fuel is not stored within the impactedlocation(s) until the condition is resolved.3. An evaluation would be conducted to determine if more frequent and expanded surveillance of thespent fuel storage racks is needed.3 of 3