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Bell Bend_ New and Spent Fuel Storage_ Submittal of Change Summary

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					                                 R. R. Sgarro                     PPL Bell Bend, LLC            'Sa *I 1 e
              Manager-Nuclear Regulatory Affairs                38 Bomboy Lane, Suite 2            e
                                                                       Berwick, PA 18603
                                                   Tel. 570.802.8102 FAX 570,802.8119                        - -
                                                                   rrsgarro@pplweb.com
                                                                                                   I


January 3, 2011


ATTN: Document Control Desk
U.S. Nuclear Regulatory Commission
Washington, DC 20555-0001


BELL BEND NUCLEAR POWER PLANT
NEW AND SPENT FUEL STORAGE
RACKS
BNP-2011-003    Docket No. 52-039

References:     1) S. M. Sloan (AREVA NP Inc.) to U.S. Nuclear Regulatory Commission
                   (NRC), Submittal of AREVA Transnuclear Inc. Report TN-Rack.0101, "U.S.
                   EPR New and Spent Fuel Storage Rack Technical Report," dated
                   December 8, 2009

                2) S. M. Sloan (AREVA NP Inc.) to U.S. NRC, Submittal of Revision 2 of the
                   U.S. EPR Final Safety Analysis Report for Design Certification, dated
                   August 31, 2010


The purposes of this letter are to notify the NRC of PPL Bell Bend, LLC's (PPL) intent to
incorporate by reference'those portions of the revised U.S. EPR Final Safety Analysis Report
(FSAR) related to new and spent fuel storage racks and to transmit changes to the Bell Bend
Nuclear Power Plant (BBNPP) Combined License Application (COLA). The BBNPP COLA
changes related to new and spent fuel storage racks are identified in Sections 1.8, 9.1,14.3 and
15.10 of the FSAR; Technical Specifications 3.7.15 and 3.7.16, and associated Bases; and
Appendix B of the Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) and ITAAC
Closure, as submitted in Parts 2, 4 and 10 of the BBNPP COLA, Revision 2.

In Reference 1, AREVA NP, Inc., provided notification of their intent to incorporate AREVA
Transnuclear Inc. "U.S. EPR New and Spent Fuel Storage Rack Technical Report" by reference
into the U.S. EPR Final Safety Analysis Report (FSAR). This report has been incorporated into
the U.S. EPR FSAR Revision 2 and was submitted to the NRC on August 31, 2010 (Reference
2).

Page markups of the affected BBNPP COLA pages are provided in the Enclosure to this letter.
These pages identify the incorporation by reference of the changes made to the U.S. EPR
FSAR. These changes will be incorporated into the BBNPP COLA in a future revision of the
BBNPP COLA.

The future revision of the COLA to incorporate the changes identified in the Enclosure is the
only new regulatory commitment in this letter.
January 3, 2011                           BNP-2011-003                                 Page 2


Should you have questions or need additional information, please contact the undersigned at
570.802.8102.

I declare under penalty of perjury that the foregoing is true and correct.


Executed on January 3, 2011

Respectfully,



Rocco R. Sr

RRS/kw

Enclosure: As stated
January 3, 2011                       BNP-2011-003   Page 3


cc:    (w/o Enclosures)

       Mr. William Dean
       Regional Administrator
       U.S. Nuclear Regulatory Commission
       Region I
       475 Allendale Road
       King of Prussia, PA 19406-1415

       Mr. Michael Canova
       Project Manager
       U.S. Nuclear Regulatory Commission
       11545 Rockville Pike, Mail Stop T6-E55M
       Rockville, MD 20852
January 3, 2011                  BNP-2011-003                    Enclosure




                                    Enclosure

                  Change Summary and COLA Page Markups for the
                        New and Spent Fuel Storage Racks
                         I Bell Bend Nuclear Power Plant
  January 3, 2011                                BN P-2011-003                                  Enclosure


  The following change is made to FSAR Table 1.8-1:
                Table 1.8-1-FSAR Sections that Demonstrate Conformance to
                            U.S. EPR FSAR Interface Requirements
Item                                 Interface                           Interface Type            FSAR
No.                                                                                               Section
1-1    Switchgear Building                                              U.S. EPR Interface      1.2, 8.3, 8.4
1-2    Access Building                                                  U.S. EPR Interface       1.2, 3.7.2
1-3    Turbine Building                                                 U.S. EPR Interface       1.2, 3.7.2
1-4    Fire Protection Storage Tanks and Building                       U.S. EPR Interface       1.2, 3.7.2
2-1    Envelope of U.S. EPR site related design                           Site Parameter         2.0, Table
                                                                                                    2.0-1
2-2    Consequences of potential hazards from nearby industrial,          Site Parameter             2.2
       transportation and military facilities
2-3    Site-specific X/Q values based on site-specific meteorological     Site Parameter             2.3
       data at the exclusion area boundary (EAB), low population zone
       (LPZ), and control room
2-4    Site-specific seismic parameters                                   Site   Parameter        2.5, 3.7
2-5    Soil conditions and profiles                                       Site   Parameter          2.5
2-6    Bearing pressure of soil beneath the nuclear island basemat        Site   Parameter          2.5
2-7    Foundation settlements                                             Site   Parameter          2.5
3-1    Missiles generated from nearby facilities                          Site   Parameter          3.5
3-2    Missiles generated by tornadoes or extreme winds                   Site   Parameter          3.5
3-3    Aircraft hazards                                                   Site   Parameter          3.5
3-4    Site-specific loads that lie within the standard plant design      Site   Parameter          3.8
       envelope for Seismic Category I structures
3-5    Buried conduit and duct banks, and pipe and pipe ducts           U.S. EPR Interface           3.8
8-1    Off-site AC power transmission system connections to the         U.S. EPR Interface           8.2
       switchyard and the connection to the plant power distribution
       system
8-2    On-site AC power transmission system connections to the          U.S. EPR Interface           8.3
       switchyard and the connection to the plant power distribution
       system
8-3    Auxiliary power and generator transformer areas                  U.S. EPR    Interface        8.2
8-4    Lightning protection and grounding system grid                   U.S. EPR    Interface       8.3.1
9-4    Now fuol and spent fuel storage rack                               S.
                                                                        W. EPR      interfaco   9-1-1--9---
9-2    Provide support systems such as makeup water, blowdown and       U.S. EPR    Interface       9.2.5
       chemical treatment (to control biofouling) for the UHS
9-3    Raw water system                                                 U.S. EPR Interface         9.2.9
9-4    Fire water distribution system                                   U.S. EPR Interface         9.5.1
10-1   Design details for circulating water system including makeup     U.S. EPR Interface         10.4.5
       water, and water treatment
11-1   Process Control program and program aspects of process and       U.S. EPR Interface          11.5
       effluent monitoring and sampling
13-1   Site-specific information for administrative, operating,         U.S. EPR Interface          13.5
       emergency, maintenance, and other operating procedures.
13-2   Site-specific emergency plan                                     U.S. EPR Interface          13.3
13-3   Site-specific security assessment and Physical Security Plan     U.S. EPR Interface          13.6
14-1   Site-specific information for development of the initial test    U.S. EPR Interface          14.2
       program




                                                      1 OF 13
       January 3, 2011                                      BNP-2011-003                                                  Enclosure


       The following changes are made to FSAR Table 1.8-2:
                          Table 1.8-2-FSAR Sections that Address COL Items
                                             (Page 9 of 15)
    Item No.                                                   Description                                                          Section
     8.2-1     A COL applicant that references the U.S. EPR design certification will provide site specific information             8.2.1.1
               regarding the offsite transmission system and their connections to the station switchyard.
     8.2-2     A COL applicant that references the U.S. EPR design certification will provide site-specific information             8.2.1.2
               for the switchyard layout design.
     8.2-3     A COL applicant that references the U.S. EPR design certification will provide site-specific information             8.2.2.7
               that identifies actions necessary to restore offsite power and use available nearby power sources
               when offsite power is unavailable.
     8.2-4     A COL applicant that references the U.S. EPR design certification will provide a site-specific grid                  8.2.2.4
               stability analysis.
     8.2-5     A COL applicant that references the U.S. EPR design certification will provide site-specific information             8.2.1.2
               for the protective devices that control the switchyard breakers and other switchyard relay devices.
     8.2-6     A COL applicant that references the U.S. EPR design certification will provide site-specific information             8.2.2.5
               for the station switchyard equipment inspection and testing plan.
     8.2-7     A COL applicant that references the U.S. EPR design certification will provide site specific information             8.2.1.1
               regarding the communication agreements and protocols between the station and the transmission
               system operator, independent system operator, or reliability coordinator/authority. Additionally, the
               applicant will provide a description of the analysis tool used by the transmission system operator to
               determine, in real time, the impact that the loss or unavailability of various transmission system
               elements will have on the condition of the transmission system to provide post-trip voltages at the
               switchyard. The information provided will be consistent with information requested in NRC Generic
               Letter 2006-02.
     8.2-8     A COL applicant that references the U.S. EPR design certification will provide site-specific information             8.2.1.2
               regarding indication and control of switchyard components.
     8.3-1     A COL applicant that references the U.S. EPR design certification will monitor and maintain EDG                      8.3.1.1.5
               reliability during plant operations to verify the selected reliability [evel target is being achieved as
               intended by RG 1.155.
     8.3-2     A COL applicant that references the U.S. EPR design certification will describe inspection, testing and              8.3.1.1.8
               monitoring programs to detect the degradation of inaccessible or underground power cables that
               support EDGs, offsite power, ESW and other systems that are within the scope of 10 CFR 50.65.
     8.4-1     A COL applicant that references the U.S. EPR design certification will provide site-specific information              8.4.1.3
               that identifies any additional local power sources and transmission paths that could be made available
               to resupply the power plant following a LOOP.
     8.4-2     A COL applicant that references the U.S. EPR design certification will address the RG 1.155 guidance                 8.4.2.6.4
_              related to procedures and training to cope with SBO.
     9.1-1     A COL applicant that references the U.S. EPR design certification will provide site-specific information             9.1.5.2.5
               on the heavy load handling program, including a commitment to procedures for heavy load lifts in the
               vicinity of irradiated fuel or safe shutdown equipment, and crane operator training and qualification.
       .1      A2COL applicGant that references the U.S. EPR design cortificatien will demonstrFate that the design                 911.
               &atisfios tho csrfiticality analysis Fcq,• m.. ts fo.r the new and spent fuel storage r•aks, and describe
                                                  .
               the r•os us of the analyses foFnormal and credible abnormal conditions, including a description of the
               m-thods used, approximations and assumptions made, and handling of desigr tolorances and

               racks, including a dcScription Of confirmatory structural dynamic and Stres6 analyse
     9.1-4     A QOL    applieant that rcfeeRcncs the 1U.6. EPR d6esign certification will dosGribe the spent fuel StorFage         9..2.2.2
               racks;, including a deScription of confirmatory Structural dynamnic and stress analyses and thermal
               hydraulic cooling analse.
     9.2-1     A COL applicant that references the U.S. EPR design       certification will provide site specific information        9.2.5.2
               for the UHS make up.
     9.2-2     A COL applicant that references the U.S. EPR design       certification will provide site-specific details           9.2.4.2.1
               related to the sources and treatment of makeup to the     potable and sanitary water system along with a
               simplified piping and instrument diagram.
     9.2-3     The raw water supply system (RWSS) and the design         requirements of the RWSS are site specific and               9.2.9
               will be addressed by the COL applicant.                                                                          I



                                                                2 OF 13
January 3, 2011                                BNP-2011-003                                         Enclosure


The following changes are made to FSAR Section 9.1:


9.1     FUEL STORAGE AND HANDLING

        This section of the U.S. EPR FSAR is incorporated by reference with the following
        supplements.

9.1.1   CRITICALITY SAFETY OF NEW AND SPENT FUEL STORAGE AND HANDLING

        No departures or supplements.

        9.1.1.1      Design Bases

        No departurs• or surpplomoRts.

        9.1.1.2      Facilitice DeScription

        No departwues or supplomonts.

           9.1.1.3Safety Evaluationn

        The U-.S. EPR FSAR includes the foallowir g C,() L Item.. in S-ecrtin 9. !.3:
            A COL anrpli•ant that rofo.Faroncos tho US E=PR- dloiRn            •ortifiatioRn Will demonsrFate
            th-at the desigr   satisfies the cPriticrality araly6ri FequiFeme•t•    for the new. a;;nd spent
            fuol storage racks, and     describe the r•osults
                                                            of the analyses for norEmal and redible
                                                                                      h
            Tabnor--Gmal corditions, including a description of thto"rmtho•ds ud,   apphoximati•ns
            and assumptions made, and handling of design tolerances and uncertaintis
        This CO Itom is adderesed as follows:,

        (The dcsign and analyses; fo-r the newA and spent fuel storage Fracks wil eaicroae
         into Reision 1 to the; US. EPR FSAR. This; rezvision Will icuethe analyse, in nS~ta;r
        Topical Report UN TR 08 001, Spent and New Fuel Storage Analyses forF U.S. EPR
        Topical Report, dated March 2008 (UIJRStar, 2008) and incorporate additional anaye
        to- bound_ the site specific conditions at CCNPP Unit43.
        9.1.1.4      ReferePnces~

        (No departures or supplements.)

9.1.2   NEW AND SPENT FUEL STORAGE

        No departures or supplements.

        9.1..~1      DcIpan Raise-

        No departures o•r sul•lements.

           9.1.2.2Facilities Descriotion



                                                    3 OF 13
January 3, 2011                                                   BNP-2011-003                                                   Enclosure


       9.1.2.2.1              New Fuel Storage

       The U1.S. -PR FSAR inGcl-uIde.I-                       the follo-,Wrg COL Itom in Sec•tion 9.1.                      1.

            A CGLI ar•-I-'ht                                                   r)6'igc e
                                                       rtaFefereRnes the UI.S. E                     rt•-ific-Ati,- WiII ,-sc•rhioe the
                ne quetorage racks, incluIding a description Of confirm~ator' structural dynamic,
            and 6tre66 analyses.
       This C201 tem is addressed As folws:
       (The deSign and analy6se fo-r thte newQA~     and spent fuel storage Fracks will1 be icroae
       into a fu~ture reVfiSfionR, which will incorporate additional analyses to bound the site specificG
          conitinsat BBNPP).
                         ,•
            ,-,rk n,-',-Ii     o-'l,,,-   ,f               -^i~
                                                          n,, ,'l14'   .-   .- r];^-r   -   -,-r-R •,•   ,-   -÷ ,,-,,,,4        •-•   ;-

       9.1.2.2.2              Spent Fuel Storage
             S.
       The U-. E-PR F=S-A.R wp-includesr- the follIGowig COL Item inScin9.1.222
            A COL applicant that reeecsthe U.IS. E=PR de~ign certification will desrrfibeQ the
            spent fuel storage racks,, inclu1ding a description o-f confirMator,' struc~tural dynamic
            -anAdsrs analyses, and thermal hyd-raulOfic. cooling analyses.


       (The design and analyses for the neW and spent fuel storFage racks will be8 incorporated
       into A-futuire revision, which Will inco~rporate additional analyses to bounId the site specific
       conditions; a;t BBENPP 1

        .1.2...               Safety Evaluraton

       No departures or s~upplem~entS.
           9.12.4             Inspection and Testing Requirements

       1,4E EieEparRUro Or SUDEOtmenS.
       9.1.2.5                instrumentation Requirements
       No departur~es or supplements.

       9.1.26                 References-

       (W. Aenanrerureso supnneiaom sI
                   i

              --       r-      .......         rr-'-




                                                                       4 OF 13
January 3, 2011                                  BNP-2011-003                              Enclosure


The following change is made to FSAR Table 14.3-2:
                   Table 14.3-2-{Site Specific SSC ITAAC Screening Summary}
                                           Sste, o CoponntU.S.
                                      Sit Spcifc Srucur,                             EPR    Selected
                                           Sste, o CoponntInterface
                                      Sit Spcifc Srucur,                                   for ITAAC
Structure
Fire Protection Building                                                          Yes         Yes
Switchgear Building                                                               Yes         Yes
Turbine Building                                                                  Yes         Yes
Access Building                                                                   Yes         Yes
ESWEMS Pumphouse                                                                  Yes         Yes
Warehouse Building                                                                Yes         Yes
Central Gas Supply Building                                                       Yes         Yes
Grid Systems Control Building (i.e., Control House)                               Yes         Yes
Circulating Water System Cooling Tower Structures                                 Yes         Yes
Circulating Water System Pumphouse                                                Yes         Yes
Circulating Water System Makeup Water Intake Structure                            Yes         Yes
Waste Water Retention Basin                                                       No          No
Meteorological Tower                                                              Yes         Yes
Water Treatment Building                                                          Yes         Yes

Component
Buried Ductbanks                                                                  Yes         Yes
Buried Pipe                                                                       Yes         Yes
NowAn..;3d Spont Fuel Storage Racks                                               )(-a        Yocs

System
Offsite Power System                                                              Yes         Yes
Power Transmission System (Main Generator, Main Transformer, Protection &         Yes         Yes
Synchronization)
Essential Service Water Blowdown System                                           No          No
Essential Service Water Makeup System Chemical Treatment System                   No          No
Normal Essential Service Water Makeup System                                      No          No
Essential Service Water Emergency Makeup Water System                             Yes         Yes
Potable Water System                                                              No          No
Sanitary Waste Water System                                                       No          No
Water Treatment System                                                            No          No
Raw Water System                                                                  Yes         Yes
Circulating Water System, including support systems (i.e., CWS Makeup System,     No          No
Cooling Tower Blowdown System, Chemical Treatment System, and Circulating Water
System Outfall)
ESWEMS Pumphouse HVAC System                                                      No          Yes
Fire Protection Building Ventilation System                                       No          Yes
Central Gas Distribution System                                                   No          No
Fire Detection and Alarm Systems for Balance of Plant                             No           No
Fire Water Distribution System, including Fire Protection Storage Tanks           Yes         Yes
Fire Suppression Systems for ESWEMS Pumphouse and Fire Protection Building)       No          Yes
Fire Suppression Systems for Balance of Plant                                     No           No
Standpipes and Hose Stations for Balance of Plant                                 No           No




                                                      5 OF 13
   January 3, 2011                                         BNP-2011-003                                            Enclosure


   The following changes are made to FSAR Table 14.3-3:
                          Table 14.3-3-{Interface Requirements Screening Summary}
                                                             (Page 1 of 3)

 U.S. EPR
FSAR Tier I                                  Interface Requirement                                      Selected for ITAAC
 Section #
    3.1             The physical security system provides physical features to detect,                          Yes
                    delay, assist response to, and defend against the design basis threat
                    (DBT) for radiological sabotage.
    4.1             Failure ofany of the site specific structures not within the scope of the                   Yes
                    certified design shall not cause any of the Category 1 structures within
                    the scope of the certified design to fail.
    4.2             The COL Applicant will provide the design of the fire protection storage       No. The design of the fire water
                    tanks and building.                                                           storage tanks and Fire Protection
                                                                                                   Building is discussed in Section
                                                                                                    3.7.2.3.3 and Section 3.7.2.8.
    4.2             The Fire Protection Building will house the fire protection system and                        Yes
                    fire pump with the storage tanks in close proximity to the pump building.
    4.3             The COL Applicant will provide the design of the Switchgear Building.          No. The design requirements for
                                                                                                  the Switchgear Building are stated
                                                                                                            in Table 3.2-1.
    4.3             The Switchgear Building contains the power supply, the instrumentation                       Yes
                    and controls (I&C) for the Turbine Island and the balance of plant, and
                    the SBO diesel generators; it is located adjacent to and contiguous with
                    the Turbine Building and is physically separate from the NI.

    4.4             The COL Applicant will provide the design of the Turbine Building.             No. The design requirements for
                                                                                                  the Turbine Building are stated in
                                                                                                            Table 3.2-1.
    4.4             The Turbine Building houses the components of the steam condensate                          Yes
                    main feedwater cycle, including the turbine-generator.
    4.4             The Turbine Building is located in a radial position with respect to the                     Yes
                    Reactor Building, but is independent from the NI.
    4.4             The Turbine Building is oriented to minimize the effects of any potential                    Yes
                    turbine generated missiles.
    4-.             The COL Applicant will provide the design of the new fuel Gteragc racks        No. The design Of the new and
                    and the
                          .p.nt fuel         . Fa.     .etago                                        spent fuel torage Fraks i.
                                                                                                      discu•. . .d ienSe.tion 9. 1
    4-.             These rackls identified ass S-eismic Gategor' I and are dosigncd-,                             Yes
                    c~enstructed- and tested- te AS&ME co-de S-ectien 111,
                                                                         Division 1,

    4-5             Material's fo-r fue      itrgercs satisfy their intended safety
                                                shall                                                            Yes
                    funtioal rquirmentAwih regards to fuel subriiaFityG_________________
          ____________

    44-             Setferck mnaterials will be comnpatible with the pool storage                                Yes

    4-4             Spent fuel rac-k s-truc-tural materials; mus-t be corrosion resistant andYe

    4-4             The newv fuel and spent fuel storFage racks are located in the Fuel                          Yes
    4.4             The COL Applicant will also demonstrate that the design satisfies the           No. The design of the -new~and
                    criticality analysis requiremnents for the new and spent fuel storage             spent fuel storage racks is
                    racks, and desc-rib-e the results of the analyses fo-r normal and credible         discussed in Section 9.1.
                    abnremal conditions, including a descriptionR Of the Methods used,
                    approximations and assumptions mnade, and handling of design
                    tolerances and unceraiAAnties.




                                                                6 OF 13
January 3, 2011                                 BNP-2011-003                                      Enclosure



                  Table 14.3-3-{Interface Requirements Screening Summary}
                                          (Page 1 of 3)
                                                   CONTINUED

          The COL Applicant Well al69 describe-hP the noAW fuel storage racks-,    Noa. T-he d Ro-f t ho no-anA0Ad
                                                                                              esi0gn      R
          oincluding a description of confirmatory Structural dynamic and Strocs   spent fuel racks iSdiScUssed in
          analyses and the spent fuel storage racks, including a description of              Seot*GA-9.1.
          confirmatory Structural dynamic and st      analyses and thermal
          hydrauoli cooling analyses.




                                                    7 OF 13
January 3, 2011                           BNP-2011-003                                 Enclosure


The following changes are made to FSAR Section 15.10:


15.10     SPENT FUEL POOL CRITICALITY AND BORON DILUTON ANALYSIS

          This section of the U.S. EPR FSAR is incorporated by reference.

          This section of the U.S. E-PR E=S-A.R iinoprtdby rcfcrcco-with the following
          Guppemnts7 ,
           wThe spent fuel pool criticality aalys;s vIll be in   o     tA   fu•tIurrevision ot
          tho U-.S. E-PR F=SAR, which will, incr-eporato additional analyses to on the site-
                                        01
          .pecific cn..d..itns at -BBNPP}.

15.1n.1   REFERENCES

          (No departuFe6or s,
                            upplements)




                                              8 OF 13
January 3, 2011                                                     BNP-2011-003                                                              Enclosure


The following changes are made in the Generic Changes Section of COLA Part 4, Technical
Specifications (only affected portions are shown):


3      LCO 3.7.15                        SPENT FUEL STORAGE POOL BORON CONCENTRATION ^N
       EN RIC HMEN-T
       Gon..ric Tochnica. Spccific-ati.ns:

       LCO 3.7.15, "Spent Fuel Storage Pool BoFro ConcentrationR and EnRichmcnt," includcs a
                      NIofte
       Re.vieRweNe"•r'sl                      that .states;"The d.esign of the spent fue8,l torage rac... i6 to be provided
                                                                                                      kr.
       kI, fhk       rlfI          A .,rmnl;.--nf    Tha ra      , ",;ral       ,rrA     n     -ranr-nn   rt;nn   %A;II k^     rrnir;iai   n'rt   ^f tho

       spent fulel rack design." The boron concentration is,providod as, bracketed toxt
                 n   -l   •   •-;-;-      I            ÷k   ;•       •l     ,    l   r       l.f+~        ;                  I'•;-r

       Plant Specific-•Tec•Ahnical SpecificatioRnS
       A plant spccific LCO is not being developed at this time.
       jUetifatieeR-
       As disc;russed- inF=S;A.R S-ection 9.1. The desiGn and analyis69 for the newq -andseent fuel
       storage racks-Will be inopoae int a futre reviin; hc ilicroaeadtoa
       analyses to bound the site specific onRditions at BBNPI.   Reviewer's NoteS aRnd
       bracketed information in the Generic TeGhn•Ial SpecificatiOns will be addressed in a
       subsequent revision to this COLA.
4      LC        3.7.16                  SPENT FUEL STORAGE

       Gpeneri                Technical Specifications:
       TS LCO 3.7,16 incLdes a Reviewer's Note that states "The design of the spent fuel
       storage racks is to be provided by the COLA applicant. The required spent fulel storage
       configuration Will be provided as, part of the spent fu-Iel racr-k design."'
       Plant Specific Tc-hni;al Spc;if;ati;ns:•

       A plant specific LCO is not being developed at this time.



       As discussed in ESAR Section 9.1. The desmign and analysis for the new and spent fuel
       storage racks will be i    o       it  a     re revision, which Will                                                                  additional
       aralyses to bo-und the ste specific conditions At 1INIPP Revie;wer's Notes                                                          ;And

       bracketed information in the Gener.ic Technical Specifications will be addressed in a
       subseq•ue•                      revisi-r to this COLA.

5      TS 4.3                            FUEL STORAGE

       Generic Technical Spocific-ations:
       TS 4.3, "Fuel StoFage," InlIudes a Reviewer's Note that states, "The design of the spent
       fuel storage racks is to be provided by the COL applicant. The required bor
       concentration Will be provided as part of the spent fuel rack design."

       Plant Specific Technical Specifications:!


                                                                                9 OF 13
January 3, 2011                                        BNP-2011-003                                               Enclosure


       The Re vieweF, s      Note 2n Section       4.3 or, doleted.


       A Rev..we.'s Note for boron           AA   ncentrat!on is provided in TS 3.7.15. Section 4.3 does not
       contain any inform~ationR relat:      ed   te
                                                         ~..
                                                       tjFAIA   GE
                                                                 AVI IVVI
                                                                            -
                                                                            _Irl•LIVI   .




In     T    A "1 4      frDITIt     AI ITV



       Ge•nc•rv Technical Spccifiations:

       TS 4.3.1, "CrFitiality," includes a ReviewAe~r's Noto that states "Storage rack unccrtaintieS
       aro dLIscsscd in the FS~I- o UASecGtio 9.1. in addation, TS 4 2~~1 nciuacs brac~c ES
       around tho conter-to contor distances in 4 .3...,4                       an           1.•2 d.

       Plant Spccific.Tcchniral Specifications:!
       A plant spocific Design Feature is not being developed at this tie
       Justification:
       As discussed in FSAR Section 9.1. The desiqn and analysis for the- new Rand spent fuel
       peel storage racks w,-il be incorporated into a fut-re revision, which will incorporate
       additioral anal"eed bound the site s echncG con Specific ionsP. Reviwr'essdn
                           to                                        at
                -          the
       -AnR.d-brackete inomtini           Genri    Technicalpecificationms w~i be           addesdi
       subseque nt re~vmfisio to this; CL A.
7      TS 4.3.3          CAPACITY

       Generic Technical Specifications:
       TS 4.3.3, "Capacity," .n.tains bracketed requirements for the COL applicat.io to provide
       the capacity for spent fulel storage in the spent fulel storage pool-.
       Plant Specific- Tecnhnic__al Specifications:
       A plant specific Design Feature is not being developed at this tie
       Justification:
       A•   discussed   in   FSAR    SeGtio       9.1, The design and aRalysis for the-no.... And spent fuel
       pool storage racks wil              inrprated into a ftue
                                         lbe                                        rvisin       wIhwill   ncrp
       addrIfitional an;alyses to boun~d the site-specific conditionsG_ at BRNIPP. Revieweir's No~tes
       and b-rackeeted inomto nthe Generic Tec~hnical Specifications will be addressed in a
       subsequent revision to this COLA..


     21 BASES 3.7.151SETFE                             POOL BORON CONCENTRATION AND
       ENRICHMENT

       Generic. Technical Spec-ifications:
       Bases 3.7.15, "Spent Fuel POol! Boron C2pponentratio-n an.d- En=richment," contains a
       Reviee' Note stating that the design of the spent fuel storage rack(s is to be provided
       by the COLA applicant and_ tha~t the- required boronR con~entrationR Will be Provided as a

                                                           10 OF 13
January 3, 2011                                       BNP-2011-003                                       Enclosure


       pa, of the spent fue. r.desig. A second Reviewer's Note in the APPLICABLE
                         ,.l
       SAFETY ANALYSES sectiGo                   states tha;;t "A.COL    appliGcRt that referFenes the U.S. EPR
       design cc~tificatk) will demons~trate that the design satismfies the criticality analysis
       requiremnentS for the spent fuel s•torage racks." Boro                 concentrations are provided as
           brakeedtext inthe BRACKGROUND and LCOQ sections.

       Plant Specific Technical Specifications:
       A plant specific LCOn and Bases i. Rot being developed at this time.


       .AsF discussedGtt~ in F=S-A.R S-ection 9.1, the design and analysis for the- neW9 _andf spent fuel
       pool storage racks will be i                          into a future revision, which Will incorporate
                                                         -corporated
                       alyses to bo-und the site specifiGc
       ad•di;+tional a.nh,                                            Gc tions at BIMI.
                                                                       ni                     Review   r's• NoItes
       and bracketed-ifraini the Genepric Technical Specifications Will be ad-ddressiedd ina
          subequntrpeviso~n to this. COLA.


1313   1   QAC-Q 1   7   49Z       DCKI'I"rlII        Q'I'DAf/_"



       Generic T-echnical Snccificafions;
       B.as+es 2..7.16, "Spent Fuel St.oage," contains a Reviewer's Note stating that the design
       of the spent fuel storage racks Is to be provided by the COL applicant and that the
       required spent fue sorage configratioRn Will be provided as a part of the spent f, el rank
       design. The minimRum storage capacity is provided as bracketed text in the
       BACKGROUND section. The LCO section inclu-des an assumption of u-nborated water in
       bracketed text.

       A secoRnd Reviewer'• Note in the APPLICALr-DE SAF-ETY A.N.A.L-YSES sectioen
                          s                                                                            states   that
       "A COL applicant that references the U.S. EPR deign
                      .e..f.ati..                                              w..ill de.m strate that
                                                                                .
                                                                                               .-
       the design satisfies the criticality anRalysi requiremeRts fo"r the spent fu'el storageras"

       Plant Spec*•fi•         Tec=•hnical Spc•cGifatiens:
       A plant specrifc• LC          and Bases iS net being developed at this time.

            jutfratmew.
       As discu1ssed- inF=S.AR S;ection 9.1, the design and analysis for the new and spent fuei
       pool storage racks,will be incorporated_ into _A fu-ture revision, Which will incorporate
         addtioal. analyses to bounId the site specific conditions; At BBNIPP. Reviewer's Notes
       and bra•• kt•dinm                 o       tG            ric Technia   Specifications will be       s          a
       subsequet•        revisin to-th's G-•lA.




                                                           11 OF 13
Januarv 3, 2011                                        BNP-2011-003                                                   Enclosure


          The following changes are made in Appendix B of COLA Part 10, Inspections, Tests,
          Analyses, and Acceptance Criteria (ITAAC) and ITAAC Closure, Table 2.4-23:

                   Taabhle 2.4-23 (New and Spent- Fuel Stor-age Racks Inspcctions,
                                Tests, Anl1s (Pag Ar.ccptanc Critcria)
                                               n 1                |2




               Co0mmit-men-t Wording                   InspectiOn, Test, or                    Acceptancze Critcria
    4-The new and spent fuel storage                   An inspection of the          The as built new and spent fe
                              t he
      r-Ack*s a;re loc t ed i0n Fu_,El
                     ra                                as built istr--ructure anRd   storage racks are loaA;ted in the asF
      Iiompon                                                       s
                                                                 ent4• Will hA       built Fuel Bulding.
              ___Gnddutte-,
2     The n.w and spent fuel storage                   a. Inspections will be        a. The w hailt new and spent fuel
      racks are idenRtified as Seismic                     onductedef the               strage
                                                                                             reacks are installed as
      Gatege~y                                             as-buwlt                      d8Sged.e
                                                          enew     nenk              b. The as built          and spent fuel
                                                       b. Type tests, tests,             storage
                                                                                               ra       cksGan withstand
                                                          analyses,-OF-a                 design basis seismic loads
                                                          c1biRnation of        wi4hout loss of safety function.
                                                          teFStns and an-alyssr The as built equipment S nuppfh
                                                          wil  ,be pefheFoe               pcstaintS arc installed as
                                                                                         and
                                                           On the equipment.             designed.
                                                       G. Inspecti4os Will be
                                                           conducted on the
                                                           as built equipment

                                                                                         Tettn"irts-;
      The new and spent fuel storage                   Analysfis of the as           A   Fep.et csts and concludes that
      racks have been desigred to Reet                 built new and spent           the as built Rew and spent fue
      the stress limits of, and be anal-               fuel storage racks will       raks meet the stress lmit
      inR
        accordance with ASME Cede                      be conducted.                 ASME Code Section "'I,
                                                                                                          Division 1,
                Division 1, Subsection
      Section 111,                                                                   Subsection NF.

4     All applicable structural welds for the          Inspections Of te             The structural welds, for the as built
      new and spent fuel peel racks will be            strucGtural welds for         new and spent fuel pool racks- mneet.
      pcdoermed using prOcedurcs                       the as built new and          the requirements of SectionIXo
      developed and qualified in                       spent fuel pool racksG        the ASME Code
      accordance with Section IX of the                will be Pe~fGrPed.
       A&M~-ede__
    5 M at erials fo.r the. in.ew
                                v-AnA.d SpenRt fUelI   An inspectionR Of the         a. The neutFro absorber mnaterialss
      storage racks shall satisfy thei                 as built new ad                  for the as built new and spent
      inRten.de8d safe-ty functioal                    Spe~t f~el Faek                  fuel racks are cosstn ith the;
      requiernemets With regards to fuel               structural materials             materials assumed in the
      SW19G~iti~aUfiy.                                 will be conducte.                 SUbcriticality   analysis.
                                                                                     b. The neutFro absorber mnaterial is
                                                                                        Ginstalled as assumed in the
                                                                                        su1bcrfiticality analysis.
                                                                                     A. The thickness; of the neu tronn
                                                                                        absorber material in the Storage
                                                                                                  b-etwve
                                                                                         Cell iE;4s en Q.10Q and

    65The spent fuel rack materials will be            An analysis of the      The materials; for the als built spent
      compatible with the enviFronment in              as built spent     fuei fulrcs Are compatible with h
        the spentI fuel peel.                          rack structural         envirom~ent inthe spentfuel peelI
                                                                                                             -


                                                           12 OF 13
January 3, 2011                                       BNP-2011-003                                                 Enclosure


                                                      GGnduete4d-
                   T-able- 2.1-23 (New and Spent Fuel Storage Racks Inspections,
                                Tests, Analyses, and Acceptance Criteria}
                                              (-Page-2-ef-2)-

                Commitmcnt Wording                     Inspection, Tcst, Or                    Accoptance Critcria
                                                  S           ~~~~~~~~Analysis       ______________


      7-The spent fuel rack structural                An analysis of the-           The structural mnaterials of the as
        materials must be- cr-,rosion resistant       as built spent ful            built spent fuel racks are corrosion
        and compatible with the expected              rack structural               resistant and compatible with the
        water chemistry of the spen8fe                materials will be             expected water chemistry ofth
        B Tefloigparameters are                       An inspectfion o-f the-       The ýas -bu6iltspent fuel racks,meet
        signifia•nt assum.ptios in the                as built spent fuel           the-4qliewi
        criticality analysis for the spent fuel       reeks-wmilbe                  1. Center to Center Spacing-for
        aks:                                          eduted.                           RegiDjon 1 Storage Celis - 10.      4
        1. •enteFr to CenteArSpacing-for                                                0.4A iRehe
           Region I Cells     -         0.01
                                  10.9 Et                                           2. Center to Center Spacing for
           iee~he&                                                                     Region 2 Storage Cells - 9.02
        2. CGeter to Center Spacingr for                                                   0.04- iRGIe
           Region 2 Cells     -   9.028 ± 0.01                                      3. Four Region 1 Storage Racks,
            e    'hee                                                                   each with a      X   i0o matriw f
        3. Four Region I Storage Racks,                                                 Storage Cells for a total of 36
           eac; wi~*t h -A 10- mt ri o
              -,h        O9X         -f                                                 Sterage-Cel~ls,
           Storage Cells foFr a total of 3                                          4. TeR Region I Storage Racks,
           Storag Ge-Cl.e                                                              each With A lOX 10 ma;trMx Gf
        1-. -Te Regio II Storage Racks,                                                 Sorg Cells for a total o~f 1000
             each with a lO X 10 matrix of                                              Ste~ege-Cells,
           Stor)age Cells for a to÷tal oaf 1000

4-0     The followig      arametes are                An iseton            of the   The as b•6il0t new fuel raGks meet the
        significant assuimptions in the               as built new fue              fG"eWinq;
        criticality analysis for the new fuel         raeks-well-hp                 1. Center to Cen~ter Spacing for the
        Fae~k&;                                       eeadUete4,                       Storage Cells - 10.9 ± 0.01
        1. Center to CeRteFr Spai•ng for the                                            lnehee
           Storage Celis -1.•9I ±0.01                                               2. Three Storage Rac•k, each With
              hee                                                                       7x8 m atrix S•trage Cells
                                                                                                   of
        2. Three StrFage Racks, eaclh with
           7x8-mAatrix o-f Storage Cells for-a
           total of 168   StorFagef   rCells.         _________________________




                                                          13 OF 13

				
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