CNL-18-041, Request for Proposed Technical Specification (TS) Change TS-519 License Amendment Request - Change to License Condition 2.C(18)(a)3

Request for Proposed Technical Specification (TS) Change TS-519 License Amendment Request - Change to License Condition 2.C(18)(a)3

ML18080A171
Person / Time
Site:	Browns Ferry
Issue date:	03/16/2018
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF6742, CAC MF6743, CAC MF6741, CNL-18-041
Download: ML18080A171 (13)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-18-041 March 16, 2018 10 CFR 50.90 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Unit 1 Renewed Facility Operating License No. DPR-33 NRC Docket No. 50-259

Subject:

Request for Proposed Technical Specification (TS) Change TS-519 License Amendment Request - Change to Unit 1 License Condition 2.C(18)(a)3

Reference:

NRC Letter to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 -

Issuance of Amendments Regarding Extended Power Uprate (CAC Nos. MF6741, MF6742, and MF6743), dated August 14, 2017 (ML17032A120)

In accordance with 10 CFR 50.90, Application for amendment of license or construction permit, Tennessee Valley Authority (TVA) requests approval for a license amendment to reduce the time, from 90 days to 15 days, before the Browns Ferry Nuclear Plant (BFN) Unit 1 Extended Power Uprate (EPU) outage for the submittal of the revised analysis of the replacement steam dryer (RSD).

By the reference letter, the NRC issued License Amendment Nos. 299, 323, and 283 to the BFN Renewed Facility Operating Licenses (RFOLs) to increase the authorized maximum power level from 3458 megawatts thermal (MWt) to 3952 MWt. The amendments included specific license conditions that required certain monitoring, evaluation, and response actions to potential adverse flow effects as a result of the EPU on plant structures, systems and components (including verifying the continued structural integrity of the RSD) during the initial EPU power ascension. One aspect of the License Condition 2.C(18)(a)3 for Unit 1 requires the submittal of a revised BFN Unit 1 RSD analysis utilizing the BFN Unit 3 on-dryer strain gauge based end-to-end bias and uncertainties (B&Us) at EPU conditions at least 90 days prior to the start of the BFN Unit 1 EPU outage.

Based on the extensive review and analyses required of the BFN Unit 3 RSD power ascension test results, TVA is unable to submit the revised BFN Unit 1 RSD analysis 90 days prior to the planned October 13, 2018, start of the BFN Unit 1 EPU outage as required by the current BFN Unit 1 License Condition 2.C(18)(a)3. TVA requests review of

U.S. Nuclear Regulatory Commission CNL-18-041 Page 2 March 16, 2018 the attached License Amendment Request (LAR) to revise the BFN Unit 1 License Condition 2.C(18)(a)3 to reduce the time, from 90 days to 15 days, prior to the EPU outage for submittal of the revised BFN Unit 1 RSD analysis. An evaluation of the proposed change is provided in the Enclosure to this letter. Attachment 1 provides a markup of the affected renewed facility operating license page indicating the proposed change. Attachment 2 provides a retype of the affected renewed facility operating license page with the proposed change incorporated.

The need for the proposed change is based on the extensive review and analyses required of the BFN Unit 3 RSD power ascension test results prior to being able to revise the BFN Unit 1 RSD analysis. As discussed with NRG staff, review of this LAR is needed to ensure continued compliance with operating license requirements. This request is purely administrative in nature, in that it will only change the length of the required period prior to the EPU outage for the BFN Unit 1 submittal.

TVA has determined that there are no significant hazards considerations associated with the proposed changes and that the Technical Specification changes qualify for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51 .22(c)(9).

Additionally, in accordance with 10 CFR 50.91 (b)(1 ), TVA is sending a copy of this letter and the enclosure to the Alabama State Department of Public Health.

The BFN Plant Operations Review Committee has reviewed this proposed change and determined that operation of BFN in accordance with the proposed change will not endanger the health and safety of the public.

TVA requests approval of the proposed amendment by July 15, 2018, which is 90 days prior to the start of the BFN Unit 1 refueling outage, i.e., October 13, 2018.

There are no new regulatory commitments associated with this submittal. If there are any questions or if additional information is needed, please contact Edward Schrull at (423) 751-3850.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 16th day of March 2018.

Respectfully,

~~ /iv J. W. Shea Vice President, Nuclear Regulatory Affairs and Support Services

Enclosure:

Evaluation of Proposed Change cc: See page 3

U.S. Nuclear Regulatory Commission CNL-18-041 Page 3 March 16, 2018 cc (Enclosure):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant State Health Officer, Alabama State Department of Public Health

Enclosure Browns Ferry Nuclear Plant Unit 1 Renewed Facility Operating License No. DPR-33 NRC Docket No. 50-259 License Amendment Request TS-519 EVALUATION OF PROPOSED CHANGE

Evaluation of Proposed Change Enclosure Page 1 TABLE OF CONTENTS

SUBJECT:

Reduction of Time Prior to the Outage Required for Submittal of the Revised Browns Ferry Nuclear Plant Unit 1 Replacement Steam Dryer Analysis 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA 4.2 PRECEDENT 4.3 NO SIGNIFICANT HAZARDS CONSIDERATION

4.4 CONCLUSION

S

6.0 REFERENCES

Attachments:

1. Proposed Renewed Facility Operating License Change (Markup)

2. Retyped Proposed Renewed Facility Operating License Change

Evaluation of Proposed Change Enclosure Page 2 1.0

SUMMARY

DESCRIPTION Tennessee Valley Authority (TVA) requests a license amendment to reduce the time, from 90 days to 15 days, before the outage that the revised Browns Ferry Nuclear Plant (BFN)

Unit 1 replacement steam dryer analysis must be submitted. The BFN Unit 1 Extended Power Uprate (EPU) outage is scheduled to start on October 13, 2018.

By the Reference 1 letter dated August 14, 2017, the NRC issued License Amendment Nos. 299, 323, and 283 to the BFN Renewed Facility Operating Licenses to increase the authorized maximum power level from 3458 megawatts thermal (MWt) to 3952 MWt. The amendments included specific license conditions that required certain monitoring, evaluation, and response actions to potential adverse flow effects as a result of the EPU on plant structures, systems and components (including verifying the continued structural integrity of the replacement steam dryer (RSD)) during the initial EPU power ascension.

One aspect of the new License Condition 2.C(18)(a)3 for BFN Unit 1 requires the submittal of a revised BFN Unit 1 RSD analysis utilizing the Unit 3 on-dryer strain gauge based end-to-end bias and uncertainties (B&Us) at EPU conditions "at least 90 days prior to the start of the BFN Unit 1 EPU outage."

Based on the extensive review and analyses required of the BFN Unit 3 RSD power ascension test results, TVA is unable to submit the revised BFN Unit 1 RSD analysis 90 days prior to the planned October 13, 2018, start of the BFN Unit 1 EPU outage as required by the current BFN Unit 1 License Condition 2.C(18)(a)3.

TVA requests an administrative revision to BFN Unit 1 Renewed Facility Operating License Condition 2.C(18)(a)3 to reduce the time, from 90 days to 15 days, prior to the outage for submittal of the revised analysis.

2.0 DETAILED DESCRIPTION The BFN Unit 1 License Condition 2.C(18)(a)3 currently states:

At least 90 days prior to the start of the BFN Unit 1 EPU outage, TVA shall revise the BFN Unit 1 replacement steam dryer (RSD) analysis utilizing the Unit 3 on-dryer strain gauge based end-to-end bias and uncertainties (B&Us) at EPU conditions, and submit the information including the updated limit curves and a list of dominant frequencies for BFN Unit 1, to the NRC as a report in accordance with 10 CFR 50.4.

The proposed change is to change the '90 days' to '15 days' and the revised statement of the license condition would read:

At least 15 days prior to the start of the BFN Unit 1 EPU outage, TVA shall revise the BFN Unit 1 replacement steam dryer (RSD) analysis utilizing the Unit 3 on-dryer strain gauge based end-to-end bias and uncertainties (B&Us) at EPU conditions, and submit the information including the updated limit curves and a list of dominant frequencies for BFN Unit 1, to the NRC as a report in accordance with 10 CFR 50.4.

Evaluation of Proposed Change Enclosure Page 3

3.0 TECHNICAL EVALUATION

The request for reducing the time, from 90 days to 15 days, before the outage at which the revised analysis must be submitted is not a technical or safety issue. The proposed change is purely an administrative change. When proposing the current license condition, TVA had anticipated a more compact power ascension schedule, even considering time for the required NRC reviews of the interim stress data.

Based on the current BFN Unit 3 refueling outage and power ascension test schedule, BFN Unit 3 will not reach full EPU power until June 14, 2018. The BFN Unit 3 on-dryer and main steam line (MSL) measurements will be available shortly after this time. Using this measured MSL data from BFN Unit 3, General Electric - Hitachi Nuclear Energy (GEH) will develop PBLE02 load definitions and re-perform the stress analysis for BFN Unit 3 RSD using the BFN-specific bias and uncertainty and transfer function at EPU conditions. The required duration for performance of the BFN Unit 3 PBLE02 analysis of the RSD by GEH is from June 14, 2018, to September 1, 2018. Once available, the Minimum Alternating Stress Ratio from BFN Unit 3 PBLE02 analysis and the on-dryer pressure loads developed from BFN Unit 3 MSL EPU measurements will be used by GEH for revising the BFN Unit 1 RSD analysis and developing updated BFN Unit 1 RSD limit curves. GEH will develop and provide a report including the revised BFN Unit 1 RSD analysis, including updated limit curves and a list of dominant frequencies, to TVA by September 13, 2018. Upon receipt of the report from GEH, TVA will develop, review, and process the NRC submittal in accordance with TVA procedures. This report will be submitted to NRC in accordance with 10 CFR 50.4, Written communications, by September 28, 2018 (i.e., 15 days prior to the start of the BFN Unit 1 EPU outage).

The timing for submittal of the revised analysis is a requirement of a license condition included in the Renewed Facility Operating License. As such, a change to the timing for submittal of the revised analysis is a change to the operating license for the unit.

4.0 REGULATORY EVALUATION

4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met. TVA has determined that the proposed change does not require any exemptions or relief from regulatory requirements other than the operating license. The following applicable regulations and regulatory requirements were reviewed in making this determination:

• 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit

• 10 CFR 50.91, Notice for public comment; State consultation

• 10 CFR 50.92, Issuance of amendment

Evaluation of Proposed Change Enclosure Page 4 4.2 PRECEDENT License Amendment No. 305 to Renewed Facility Operating License No. DPR-56 for the Peach Bottom Atomic Power Station Unit 3, approved by the NRC on August 11, 2015 (ML15189A185), involves a reduction I relaxation of a required submittal schedule for the revised replacement steam dryer analysis from at least 90 days prior to the start of the Peach Bottom Unit 3 EPU outage to at least 30 days prior to the start of the Peach Bottom Unit 3 EPU outage...

4.3 NO SIGNIFICANT HAZARDS CONSIDERATION Tennessee Valley Authority (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:

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

Response: No.

The proposed license amendment reduces the length of time, from 90 days to 15 days, prior to the outage by which a revised analysis of the Browns Ferry Nuclear Plant (BFN)

Unit 1 replacement steam dryer (RSD), performed using an NRC-approved methodology benchmarked on the BFN Unit 3 RSD, must be submitted to the NRC for information.

There is no required review or approval of the revised analysis needed to satisfy the license condition. The proposed change is an administrative change to the period before the outage and does not impact any system, structure or component in such a way as to affect the probability or consequences of an accident previously evaluated. The proposed amendment is purely administrative and has no technical or safety aspects.

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

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

Response: No.

The proposed license amendment reduces the length of time, from 90 days to 15 days, prior to the outage by which a revised analysis of the BFN Unit 1 RSD must be submitted to the NRC for information. The proposed amendment is purely administrative and has no technical or safety aspects. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Evaluation of Proposed Change Enclosure Page 5

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

Response: No.

The proposed license amendment reduces the length of time, from 90 days to 15 days, prior to the outage by which a revised analysis of the BFN Unit 1 RSD must be submitted to the NRC for information. The proposed amendment is purely administrative and has no technical or safety aspects. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, TVA concludes that the proposed amendment does not involve a 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.

4.4 CONCLUSION

S 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.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment does not change any technical requirement with respect to the installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, and does not change any inspection or surveillance requirement. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCE

1. Letter from NRC to TVA, Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Issuance of Amendments Regarding Extended Power Uprate (CAC Nos. MF6741, MF6742, and MF6743), dated August 14, 2017 (ML17032A120).

ATTACHMENT 1 Proposed Renewed Facility Operating License Change (Markup)

-6a-active MSL strain gauges is less than two strain gauges (180 degrees apart) at any of the eight MSL locations, TVA will stop power ascension and repair/replace the damaged strain gauges and only then resume 15 power ascension.

3. At least 90 days prior to the start of the BFN Unit 1 EPU outage, TVA shall revise the BFN Unit 1 replacement steam dryer (RSD) analysis utilizing the BFN Unit 3 on-dryer strain gauge based end-to-end bias and uncertainties (B&Us) at EPU conditions, and submit the information including the updated limit curves and a list of dominant frequencies for BFN Unit 1, to the NRC as a report in accordance with 10 CFR 50.4.

a. If the on-dryer instrumentation was not available when BFN Unit 3 reached a power level of 3458 MWt and the BFN-specific bias and uncertainty data and transfer function could not be developed, the predicted dryer loads during the BFN Unit 1 power ascension will be calculated with the Plant Based Load Evaluation Method 2 transfer function used in the steam dryer design analyses for EPU. The acceptance limits will be based on BFN Unit 3 steam dryer confirmatory stress analysis results using the MSL strain gauge data collected at EPU conditions. The acceptance limits will ensure the steam dryer stress margins remain above the minimum alternating stress ratio (MASR) determined in the BFN Unit 3 steam dryer EPU confirmatory analyses.

4. TVA shall evaluate the BFN Unit 1 limit curves prepared in item (a)3 above based on new MSL strain gauge data collected following the BFN Unit 1 EPU outage at or near 3458 MWt. If the limit curves change, the new post-EPU outage limit curves shall be provided to the NRC Project Manager. TVA shall not increase power above 3458 MWt for at least 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after the NRC Project Manager confirms receipt of the reports unless, prior to expiration of the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> period, the NRC Project Manager advises that the NRC staff has no objections to the continuation of power ascension.

5. TVA shall monitor the MSL strain gauges during power ascension above 3458 MWt for increasing pressure fluctuations in the steam lines. Upon the initial increase of power above 3458 MWt until reaching 3952 MWt, TVA shall collect data from the MSL strain gauges at nominal 2.5 percent of 3458 MWt (approximately 86 MWt) increments and evaluate steam dryer performance based on this data.

6. During power ascension at each nominal 2.5 percent power level above 3458 MWt (approximately 86 MWt), TVA shall compare the MSL data to the approved limit curves based on end-to-end B&Us from the BFN Unit 3 benchmarking at EPU conditions and determine the MASR.

BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 299

ATTACHMENT 2 Retyped Proposed Renewed Facility Operating License Change

-6a-active MSL strain gauges is less than two strain gauges (180 degrees apart) at any of the eight MSL locations, TVA will stop power ascension and repair/replace the damaged strain gauges and only then resume power ascension.

3. At least 15 days prior to the start of the BFN Unit 1 EPU outage, TVA shall revise the BFN Unit 1 replacement steam dryer (RSD) analysis utilizing the BFN Unit 3 on-dryer strain gauge based end-to-end bias and uncertainties (B&Us) at EPU conditions, and submit the information including the updated limit curves and a list of dominant frequencies for BFN Unit 1, to the NRC as a report in accordance with 10 CFR 50.4.

a. If the on-dryer instrumentation was not available when BFN Unit 3 reached a power level of 3458 MWt and the BFN-specific bias and uncertainty data and transfer function could not be developed, the predicted dryer loads during the BFN Unit 1 power ascension will be calculated with the Plant Based Load Evaluation Method 2 transfer function used in the steam dryer design analyses for EPU. The acceptance limits will be based on BFN Unit 3 steam dryer confirmatory stress analysis results using the MSL strain gauge data collected at EPU conditions. The acceptance limits will ensure the steam dryer stress margins remain above the minimum alternating stress ratio (MASR) determined in the BFN Unit 3 steam dryer EPU confirmatory analyses.

4. TVA shall evaluate the BFN Unit 1 limit curves prepared in item (a)3 above based on new MSL strain gauge data collected following the BFN Unit 1 EPU outage at or near 3458 MWt. If the limit curves change, the new post-EPU outage limit curves shall be provided to the NRC Project Manager. TV A shall not increase power above 3458 MWt for at least 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> after the NRC Project Manager confirms receipt of the reports unless, prior to expiration of the 96 hour0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> period, the NRC Project Manager advises that the NRC staff has no objections to the continuation of power ascension.

5. TVA shall monitor the MSL strain gauges during power ascension above 3458 MWt for increasing pressure fluctuations in the steam lines. Upon the initial increase of power above 3458 MWt until reaching 3952 MWt, TVA shall collect data from the MSL strain gauges at nominal 2.5 percent of 3458 MWt (approximately 86 MWt) increments and evaluate steam dryer performance based on this data.

6. During power ascension at each nominal 2.5 percent power level above 3458 MWt (approximately 86 MWt), TVA shall compare the MSL data to the approved limit curves based on end-to-end B&Us from the BFN Unit 3 benchmarking at EPU conditions and determine the MASR.

BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 299