CNL-15-029, License Amendment Request for the Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-535, Revision 0, Revise Shutdown Margin Definition to Address Advanced Fuel Designs (TS-502)

License Amendment Request for the Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-535, Revision 0, Revise Shutdown Margin Definition to Address Advanced Fuel Designs (TS-502)

ML15068A407
Person / Time
Site:	Browns Ferry
Issue date:	03/09/2015
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CNL-15-029, L44 150309 003
Download: ML15068A407 (18)

Text

L44 150309 003 Tennessee Valley Authority , 1101 Market Street, Chattanooga , Tennessee 37 402 CNL-15-029 March 9, 2015 10 CFR 50.90 ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington , D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facil ity Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260 , and 50-296

Subject:

License Amendment Request for the Adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-535, Revision 0, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs" (TS-502)

References:

1) Transmittal of TSTF-535 , Revision 0, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs," dated August 8, 2011 [ADAMS Accession No. ML112200436]

2) Federal Register Notice, Notice of Availability, published on February 26, 2013 (78 FR 13100)

In accordance with Title 10 of the Code of Federal Regulations (1 0 CFR) Part 50.90, "Application for amendment of license, construction permit, or early site permit," Tennessee Valley Authority (TVA) is submitting a request for an amendment to the Technical Specifications (TS) for Browns Ferry Nuclear Plant (BFN) , Units 1, 2, and 3.

The proposed amendment modifies the TS definition of "Shutdown Margin" (SDM) to require calculation of the SDM at a reactor moderator temperature of 68°F or a higher temperature that represents the most reactive state throughout the operating cycle . This change is needed to address new Boiling Water Reactor (BWR) fuel designs which may be more reactive at shutdown temperatures above 68°F.

The proposed change is in accordance with TSTF-535 , Revision 0, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs" (Reference 1). The availability of this TS improvement was announced in the Federal Reg ister (FR) published on February 26, 2013

[78 FR 131 00] (Reference 2), as part of the Consolidated Line Item Improvement Process (CLIIP) .

U. S. Nuclear Regulatory Commission CNL-15-029 Page 2 March 9, 2015 The Enclosure of this letter provides the description , proposed change, technical analysis, regulatory analysis, and a discussion of environmental considerations. The attachments to the Enclosure provide the existing facility operating license pages marked to show the proposed change (Attachment 1 for BFN Units 1, 2, and 3) , and revised (final typed) pages (Attachment 2 for BFN Units 1, 2, and 3) .

In accordance with 10 CFR 50.91 (a) (1), "Notice for Public Comment," the analysis about the issue of no significant hazards consideration using the standards in 10 CFR 50.92 is being provided to the Commission in the regulatory analysis section of the Enclosure.

In accordance with 10 CFR 50.91 (b) (1 ), "Notice for Public Comment; State Consultation ," a copy of this application and its reasoned analysis about no significant hazards considerations is being provided to the Alabama Department of Public Health.

TVA requests review and approval of the proposed license amendment by November 30, 2015 and requests the implementation date be specified as with in 60 days of the approval date.

There are no new regulatory commitments associated with this submittal. Please direct any questions concerning this matter to Mr. Edward D. Schrull at (423) 751-3850.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 9th day of March 2015.

Respectfully ,

,tn;Pf:lS)w~-q J. W. Shea Vice President, Nuclear Licensing Enclosure Evaluation of Proposed Change, Browns Ferry Nuclear Plant, Units 1, 2, and 3 Application to Adopt TSTF-535 , "Revise Shutdown Margin Definition to Address Advanced Fuel Designs" (TS-502) cc (w/Enclosure) :

NRC Regional Administrator- Region II NRR Director- NRC Headquarters NRC Senior Resident Inspector- Browns Ferry Nuclear Plant NRR Project Manager- Browns Ferry Nuclear Plant State Health Officer- Alabama Department of Public Health

Enclosure Evaluation of Proposed Change Browns Ferry Nuclear Plant, Units 1, 2, and 3 Application to Adopt TSTF-535, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs" (TS-502) 1.0

SUMMARY

DESCRIPTION 2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation 2.2 Optional Changes and Variations

3.0 REGULATORY EVALUATION

3.1 No Significant Hazards Consideration 3.2 Conclusions

5.0 REFERENCES

CNL-15-029 E 1 of 5

Enclosure Evaluation of Proposed Change Browns Ferry Nuclear Plant, Units 1, 2, and 3 Application to Adopt TSTF-535 ,

"Revise Shutdown Margin Definition to Address Advanced Fuel Designs" (TS-502) 1.0

SUMMARY

DESCRIPTION The proposed change revises the Technical Specification (TS) definition of Shutdown Margin (SDM) to require calculation of the SDM at a reactor moderator temperature of 68°F or a higher temperature corresponding to the most reactive state throughout the operating cycle. This change is consistent with U.S. Nuclear Regulatory Commission (NRC) approved Technical Specifications Task Force (TSTF) Standard Technical Specifications (STS) Change Traveler TSTF-535, Revision 0, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs" (Reference 1).

2.0 ASSESSMENT 2.1 Applicability of Published Safety Evaluation The availability of this TS improvement was announced in the Federal Register on February 26, 2013, (78 FR 131 00) (Reference 2) as part of the consolidated line item improvement process (CLIIP).

Tennessee Valley Authority (TVA) has reviewed the model safety evaluation dated February 26, 2013 as part of the Federal Register Notice of Availability. This review included a review of the NRC staff's evaluation , as well as the information provided in TSTF-535 . TVA has concluded that the justification presented in the TSTF-535 proposal and the model safety evaluation are applicable to Browns Ferry Nuclear Power Plant (BFN) , Units 1, 2, and 3, and justify this amendment for the incorporation of the changes to the BFN TS .

2.2 Optional Changes and Variations TVA is proposing no variations or deviations from the TS changes described in the TSTF-535 ,

Revision 0, or the applicable parts of the model safety evaluation dated February 26, 2013.

3.0 REGULATORY EVALUATION

3.1 No Significant Hazards Consideration Determination Tennessee Valley Authority (TVA) requests adoption of TSTF-535 , Revision 0, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs," which is an approved change to the standard technical specifications (STS), into the Browns Ferry Nuclear Plants (BFN),

Units 1, 2, and 3 Technical Specifications. The proposed amendment modifies the TS definition of Shutdown Margin (SDM) to require calculation of the SDM at a reactor moderator temperature of 68°F or a higher temperature that represents the most reactive state throughout the operating cycle.

TVA has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, Issuance of Amendment, as discussed below:

CNL-15-029 E 2 of 5

Enclosure Evaluation of Proposed Change Browns Ferry Nuclear Plant, Units 1, 2, and 3 Application to Adopt TSTF-535 ,

"Revise Shutdown Margin Definition to Address Advanced Fuel Designs" (TS-502)

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response : No.

The proposed change revises the definition of SDM. SDM is not an initiator to any accident previously evaluated . Accordingly, the proposed change to the definition of SDM has no effect on the probability of any accident previously evaluated . SDM is an assumption in the analysis of some previously evaluated accidents and inadequate SDM could lead to an increase in consequences for those accidents. However, the proposed change revises the SDM definition to ensure that the correct SDM is determined for all fuel types at all times during the fuel cycle . As a result, the proposed change does not adversely affect the consequences of any accident previously evaluated .

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated .

2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change revises the definition of SDM. The change does not involve a physical alteration of the plant (i.e. , no new or different type of equipment will be installed) or a change in the methods governing normal plant operations. The change does not alter assumptions made in the safety analysis regarding SDM .

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change revises the definition of SDM . The change does not alter the manner in which safety limits, limiting safety system settings or limiting conditions for operation are determined . The proposed change ensures that the SDM assumed in determining safety limits, limiting safety system settings, or limiting conditions for operation is correct for all BWR fuel types at all times during the fuel cycle.

Therefore , the proposed change does not involve a significant reduction in margin of safety.

Based on the above, TVA concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c) , and accordingly, a finding of "no significant hazards consideration" is justified .

E 3 of 5

Enclosure Evaluation of Proposed Change Browns Ferry Nuclear Plant, Units 1, 2, and 3 Application to Adopt TSTF-535 ,

"Revise Shutdown Margin Definition to Address Advanced Fuel Designs" (TS-502) 3.2 Conclusions In conclusion , based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

4.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area , as defined in 10 CFR 20 , or wou ld change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration , (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51 .22(c)(9) .

Therefore, pursuant to 10 CFR 51 .22(b) , no environmental impact statement or environmental assessment need be prepared in connection with the proposed change .

E 4 of 5

Enclosure Evaluation of Proposed Change Browns Ferry Nuclear Plant, Units 1, 2, and 3 Application to Adopt TSTF-535 ,

"Revise Shutdown Margin Definition to Address Advanced Fuel Designs" (TS-502)

5.0 REFERENCES

1. Technical Specifications Task Force (TSTF)-535, Revision 0, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs," dated August 8, 2011 [ADAMS Accession No . ML112200436]

2. Federal Register Notice, Notice of Availability , published on February 26 , 2013 (78 FR 13100)

E 5 of 5

Enclosure Evaluation of Proposed Change Browns Ferry Nuclear Plant, Units 1, 2, and 3 Application to Adopt TSTF-535, "Revise Shutdown Margin Definition to Address Advanced Fuel Designs" (TS-502)

ATTACHMENT 1 Marked up Proposed Technical Specification Pages

Definitions 1.1 throughout the

• 1.1 Definitions (continued) operating cycle SHUTDOWN MARGIN SDM shall be the amount of reactivity by hich the (SDM) reactor is subcritical or would be subcriti assuming that: is;?: 68 °F, corresponding to the

a. The reactor is xenon free; most reactive state

b. The moderator temperature is 68°F; and

c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.

STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems, subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

(continued)

BFN-UNIT 1 1.1-7 Amendment No. 234

-/. *'

Definitions 1.1 1.1 Definitions (continued)

PHYSICS TESTS PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation. These tests are:

a. Described in Section 13.10, Refueling Test Program; *of the FSAR;

b. Authorized under the provisions of 10 CFR 50.59; or

c. Otherwise approved by the Nuclear R t;..I.I.Jou.a.I..I.LL.:~t-..----.

Commission. throughout the operating cycle RATED THERMAL POWER RTP shall be a total reactor core heat tr ns er rate to (RTP) the reactor coolant of 3458 MWt.

SHUTDOWN MARGIN SDM shall be the amount of reactivity by (SDM) reactor is subcritical or would be subcritica assuming that:

is~ 68'F,

a. The reactor is xenon free; correspon d" . mg t 0 the most react1ve state

b. The moderator temperature is 68°F; an

c. All control rods are fully ~nserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.

(continued)

BFN-UNIT 2 1.1-6 Amendment No. 254 SEP 0 l: 1938

Definitions 1.1 1.1 Definitions (continued)

PHYSICS TESTS PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reattor core and related instrumentation. These tests are:

a. Described in Section 13.10, Refueling Test Program; of the FSAR;

b. Authorized under the provisions of 10 CFR 50.59; or

c. Otherwise approved by the Nuclear Re ~Q.L.I.........,__ ___,.----,

Commission.

RATEDTHERMALPO~R RTP shall be a total reactor core heat tra (RTP) the reactor coolant of 3458 MWt.

SHUTDOWN MARGIN SDM shall be the amount of reactivity by (SDM) reactor is subcritical or would be subcritica assuming that: is~ 68 ' F, corresponding to the

a. The reactor is xenon free; most reactive state

b. The moderator temperature

• o ; and

c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdravm. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.

(continued)

Amendment No. 214 BFN*UNIT 3 1.1-6 ~*-

Enclosure Evaluation of Proposed Change Browns Ferry Nuclear Plant, Units 1, 2, and 3 Application to Adopt TSTF-535 ,

"Revise Shutdown Margin Definition to Address Advanced Fuel Designs" (TS-502)

ATTACHMENT 2 Final Typed Technical Specification Pages

(3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70 , to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required ;

(4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30 , Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50 , and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules , regulations , and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3458 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. , are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 234 to Facility Operating License DPR-33, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 234. For SRs that existed prior to Amendment 234, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended , the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 234.

BFN-UNIT 1 Renewed License No. DPR-33 Amendment No.

Definitions 1.1 1.1 Definitions (continued)

SHUTDOWN MARGIN SDM shall be the amount of reactivity by which the (SDM) reactor is subcritical or would be subcritical throughout the operating cycle assuming that:

a. The reactor is xenon free;

b. The moderator temperature is ~ 68°F, corresponding to the most reactive state; and

c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM .

STAGGERED TEST BASIS A STAGGERED TEST BASIS shall consist of the testing of one of the systems , subsystems, channels, or other designated components during the interval specified by the Surveillance Frequency, so that all systems, subsystems, channels, or other designated components are tested during n Surveillance Frequency intervals, where n is the total number of systems, subsystems, channels, or other designated components in the associated function.

THERMAL POWER THERMAL POWER shall be the total reactor core heat transfer rate to the reactor coolant.

(continued)

BFN-UNIT 1 1.1-7 Amendment No. ~.

sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration , and as fission detectors in amounts as required ;

(4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive , possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70 , to possess but not separate , such byproduct and special nuclear materials as may be produced by the operation of the facility .

C. Th is renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20 , Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50 .54 and 50.59 of Part 50, and Section 70.32 of Part 70 ; is subject to all applicable provisions of the Act and to the rules , regulations , and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3458 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. , are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 253 to Facility Operating License DPR-52, the first performance is due at the end of the first surveillance interval that begins at implementation of Amendment 253. For SRs that existed prior to Amendment 253 , including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended , the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 253 .

(3) The licensee is authorized to relocate certain requirements included in Appendix A and the former Appendix B to licensee-controlled documents.

Implementation of this amendment shall include the relocation of these requirements to the appropriate documents, as described in the licensee's BFN-UNIT 2 Amendment No.

Renewed License No. DPR-52

Definitions 1.1 1.1 Definitions (continued)

PHYSICS TESTS PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation . These tests are:

a. Described in Section 13.1 0, Refueling Test Program; of the FSAR;

b. Authorized under the provisions of 10 CFR 50.59; or

c. Otherwise approved by the Nuclear Regulatory Commission.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to (RTP) the reactor coolant of 3458 MWt.

SHUTDOWN MARGIN SDM shall be the amount of reactivity by which the (SDM) reactor is subcritical or would be subcritical throughout the operating cycle assuming that:

a. The reactor is xenon free;

b. The moderator temperature is :2: 68°F, corresponding to the most reactive state; and

c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM.

(continued)

BFN-UNIT 2 1.1-6 Amendment No. 2-64,

(3) Pursuant to the Act and 10 CFR Parts 30 , 40 , and 70 , to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration , and as fission detectors in amounts as required ;

(4) Pursuant to the Act and 10 CFR Parts 30 , 40 , and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70 , to possess but not separate ,

such byproduct and special nuclear materials as may be produced by the operation of the facility .

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter 1:

Part 20 , Section 30 .34 of Part 30, Section 40.4 1 of Part 40, Sections 50.54 and 50.59 of Part 50 , and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules , regulations , and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3458 megawatts therma l.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. , are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 212 to Facility Operating License DPR-68 , the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 212. For SRs that existed prior to Amendment 212 , including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended , the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 212 .

BFN-UNIT 3 Amendment No.

Renewed License No. DPR-68

Definitions 1.1 1.1 Definitions (continued)

PHYSICS TESTS PHYSICS TESTS shall be those tests performed to measure the fundamental nuclear characteristics of the reactor core and related instrumentation. These tests are:

a. Described in Section 13.10, Refueling Test Program; of the FSAR;

b. Authorized under the provisions of 10 CFR 50.59; or

c. Otherwise approved by the Nuclear Regulatory Commission.

RATED THERMAL POWER RTP shall be a total reactor core heat transfer rate to (RTP) the reactor coolant of 3458 MWt.

SHUTDOWN MARGIN SDM shall be the amount of reactivity by which the (SDM) reactor is subcritical or would be subcritical throughout the operating cycle assuming that:

a. The reactor is xenon free;

b. The moderator temperature is;:: 68°F, corresponding to the most reactive state; and

c. All control rods are fully inserted except for the single control rod of highest reactivity worth, which is assumed to be fully withdrawn. With control rods not capable of being fully inserted, the reactivity worth of these control rods must be accounted for in the determination of SDM .

(continued)

BFN-UNIT 3 1.1-6 Amendment No. ~ .