CNL-15-103, Enclosure 2, ANP-3414NP Revision 0, Areva RAI Responses for Browns Ferry, Unit 3, Cycle 18 MCPR Safety Limits (Non-proprietary), and Enclosure 3, Affidavit

Enclosure 2, ANP-3414NP Revision 0, Areva RAI Responses for Browns Ferry, Unit 3, Cycle 18 MCPR Safety Limits (Non-proprietary), and Enclosure 3, Affidavit

ML15244B096
Person / Time
Site:	Browns Ferry
Issue date:	07/07/2015
From:	James Shea AREVA, Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15244B095	List: CNL-15-103, Enclosure 2, ANP-3414NP Revision 0, Areva RAI Responses for Browns Ferry, Unit 3, Cycle 18 MCPR Safety Limits (Non-proprietary), and Enclosure 3, Affidavit
References
CNL-15-103, TAC MF5818 ANP-3414NP Rev. 0
Download: ML15244B096 (16)

Text

L44 150707 001 Proprietary Information Withhold Under 10 CFR 2.390(a)(4)

This letter is decontrolled when separated from Enclosure 1 Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-15-103 July 7, 2015 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Unit 3 Renewed Facility Operating License No. DPR-68 NRC Docket No. 50-296

Subject:

Response to NRC Request for Additional Information Browns Ferry Nuclear Plant (BFN), Unit 3 - Application to Modify Technical Specification 2.1.1.2, Reactor Core Minimum Critical Power Ratio Safety Limits (TS-499) (TAC No. MF5818)

References:

1. Letter from TVA to NRC, Browns Ferry Nuclear Plant (BFN), Unit 3 -

Application to Modify Technical Specification 2.1.1.2, Reactor Core Minimum Critical Power Ratio Safety Limits (TS-499), dated March 6, 2015 (ADAMS Accession No. ML15090A436)

2. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Unit 3 - Request for Additional Information Related to License Amendment Request to Modify Technical Specification 2.1.1.2, Reactor Core Minimum Critical Power Ratio Safety Limits (TS-499) (TAC No. MF5818), dated June 22, 2015 (ADAMS Accession No. ML15162A948)

By letter dated March 6, 2015 (Reference 1), Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) for Browns Ferry Nuclear Plant (BFN), Unit 3, to modify the Technical Specification (TS) 2.1.1.2 value of the safety limit minimum critical power ratio (SLMCPR) for two-loop operation to 1.06 and the SLMCPR for single loop operation to 1.08.

By letter dated June 22, 2015 (Reference 2), the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI). The due date for the response is July 10, 2015. Enclosure 1 contains AREVA report ANP-3414P, Revision 0, that provides the responses to the Reference 2 RAI. Enclosure 1 contains information that AREVA NP considers to be proprietary in nature and subsequently, pursuant to 10 Code of Federal Regulations 2.390, Public inspections, exemptions, requests for withholding, paragraph (a)(4), it is requested that such information be withheld from public disclosure. contains the non-proprietary version of the Enclosure 1 report with the proprietary material removed, and is suitable for public disclosure. Enclosure 3 provides the affidavit supporting this request.

U.S. Nuclear Regulatory Commission CNL-15-103 Page2 July 7, 2015 There are no new regulatory commitments contained in this submittal. Please address any questions regarding this submittal to Mr. Edward D. Schrull at (423) 751-3850.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 7th day of July 2015.

Respectfully,

~

J. .~a President, Nuclear Licensing

Enclosures:

1. ANP-3414P Revision 0, "AREVA RAI Responses for Browns Ferry Unit 3 Cycle 18 MCPR Safety Limits" (Proprietary)

2. ANP-3414NP Revision 0, "AREVA RAI Responses for Browns Ferry Unit 3 Cycle 18 MCPR Safety Limits" (Non-proprietary)

3. Affidavit for Enclosure 1 cc (Enclosures):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant NRC Branch Chief - Region 11 State Health Officer, Alabama State Department of Health

ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT UNIT 3 ANP-3414NP Revision 0, AREVA RAI Responses for Browns Ferry Unit 3 Cycle 18 MCPR Safety Limits (Non-proprietary)

AREVA RAI Responses for ANP-3414NP Revision 0 Browns Ferry Unit 3 Cycle 18 MCPR Safety Limits June 2015

© 2015 AREVA Inc.

ANP-3414NP Revision 0 Copyright © 2015 AREVA Inc.

All Rights Reserved

AREVA Inc.

ANP-3414NP AREVA RAI Responses for Revision 0 Browns Ferry Unit 3 Cycle 18 MCPR Safety Limits Page i Nature of Changes Section(s)

Item or Page(s) Description and Justification 1 All Initial Issue

AREVA Inc.

ANP-3414NP AREVA RAI Responses for Revision 0 Browns Ferry Unit 3 Cycle 18 MCPR Safety Limits Page ii Contents Page

1.0 INTRODUCTION

............................................................................................... 1-1 2.0 NRC QUESTIONS AND AREVA RESPONSE .................................................. 2-1

3.0 REFERENCES

.................................................................................................. 3-1

AREVA Inc.

ANP-3414NP AREVA RAI Responses for Revision 0 Browns Ferry Unit 3 Cycle 18 MCPR Safety Limits Page iii Nomenclature Acronym Definition BFN Browns Ferry Nuclear Plant LAR Licensing Amendment Request MCPR Minimum Critical Power Ratio NRC Nuclear Regulatory Commission RAI Request for Additional Information SLMCPR Safety Limit Minimum Critical Power Ratio TS Technical Specification TVA Tennessee Valley Authority

AREVA Inc.

ANP-3414NP AREVA RAI Responses for Revision 0 Browns Ferry Unit 3 Cycle 18 MCPR Safety Limits Page 1-1

1.0 INTRODUCTION

Tennessee Valley Authority (TVA) submitted a License Amendment Request (LAR) to support a change of approved SLMCPR methodology and Technical Specification (TS)

SLMCPR value in the Browns Ferry (BFN) Unit 3 Technical Specifications. In response to the LAR, the US Nuclear Regulatory Commission (NRC) has issued an initial set of questions, in the form of Request for Additional Information (RAI), Reference 1.

Based on the information provided in this report, TVA will prepare a formal response to the NRC RAIs.

AREVA Inc.

ANP-3414NP AREVA RAI Responses for Revision 0 Browns Ferry Unit 3 Cycle 18 MCPR Safety Limits Page 2-1 2.0 NRC QUESTIONS AND AREVA RESPONSE The NRC questions (i.e., RAIs) listed below are according to Reference 1:

RAI-01: In the Engineering Information Report provided as Attachment 3/4 to the LAR, the value for the assembly flow rate uncertainty indicated in Table 1 is slightly lower than the value provided for BFN, Unit 2, in 2012 (AREVA Document No.

51-9191259-001) and the value provided for the last BFN, Unit 3 SLMCPR submittal that could be located in NRC records (Framatome Advanced Nuclear Power report included with the October 1, 2003, LAR found under ADAMS Accession No. ML032810643). Provide justification for this decrease in uncertainty.

AREVA Response:

Table 3-2 of the SAFLIM3D topical report (ANP-10307PA Revision 0, AREVA MCPR Safety Limit Methodology for Boiling Water Reactors, dated June 2011) presents the assembly flow rate uncertainty used in the MCPR Safety Limit analyses. The value of

[

]

RAI-02: ANP-3140(P), which discusses the ACE/ATRIUM-10XM critical power correlation, indicates in the text and in Table 3-1 that an additional uncertainty is imposed on the minimum critical power ratio safety limit methodology for rods with high local peaking. Confirm that no rods in the Unit 3 Cycle 18 core are expected to exceed the limit for the applicability of the critical power

AREVA Inc.

ANP-3414NP AREVA RAI Responses for Revision 0 Browns Ferry Unit 3 Cycle 18 MCPR Safety Limits Page 2-2 correlations given in Table 1. Describe how high-peaking rods are identified and, as appropriate, the additional uncertainty applied.

AREVA Response:

The SPCB and ACE/ATRIUM 10XM critical power correlation limit of applicability for local peaking factor is [ ], provided as an SER restriction when the correlations were approved by the NRC. Fuel expected to be resident in Unit 3 Cycle 18 has been designed to be below this limit. The maximum local peaking factor for the fresh ATRIUM 10XM lattice is [ ].

During each Monte Carlo trial of the SLMCPR calculation, [

]

The base additive constant uncertainty and the high pin power additive constant uncertainty values are presented in Table 3-2 of the SAFLIM3D topical report (ANP-10307PA Revision 0 AREVA MCPR Safety Limit Methodology for Boiling Water Reactors, dated June 2011).

AREVA Inc.

ANP-3414NP AREVA RAI Responses for Revision 0 Browns Ferry Unit 3 Cycle 18 MCPR Safety Limits Page 3-1

3.0 REFERENCES

1. Letter, F. E. Saba (NRC) to J. W. Shea (TVA), Browns Ferry Nuclear Plant, Unit 3 - Request For Additional Information Related to License Amendment Request To Modify Technical Specification 2.1.1.2, Reactor Core Minimum Critical Power Ratio Safety Limits (TS-499) (TAC No. MF5818), USNRC, June 22, 2015. (38-9242052-000)

ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT UNIT 3 Affidavit for ANP-3414P Revision 0