ML023290365
| ML023290365 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/21/2002 |
| From: | Bhatnagar A Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| R08 021121 702 | |
| Download: ML023290365 (6) | |
Text
R08 021121 702 November 21, 2002 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Stop: OWFN, P1-35 Washington, D.C. 20555-0001 Gentlemen:
In the Matter of
)
Docket Nos. 50-260 Tennessee Valley Authority
)
50-296 BROWNS FERRY NUCLEAR PLANT (BFN) - UNITS 2 AND 3 - OPTIONS FOR EXTENDED POWER UPRATE (EPU) AND FUEL VENDOR CHANGE The purpose of this letter is to notify the NRC Staff of TVAs plans for licensing and implementation of Extended Power Uprate (EPU), Maximum Extended Load Line Limit Analyses Plus (MELLLA+) and a fuel vendor change.
In a meeting between TVA, General Electric, and the staff on July 10, 2002, the staff told TVA that concurrent EPU and a fuel vendor change may not be possible using the EPU process proposed by TVA. Subsequent phone calls and meetings confirmed this direction.
On October 10, 2002, a telephone conference between Tim Abney and Tony Langley of my staff and Herb Berkow, Jerod Wermiel, Kahtan Jabbour, et. al., of NRC was conducted to discuss options available to TVA for EPU and fuel vendor change license amendments. On October 16, 2002, a meeting was held between Framatome ANP, NRC, and TVA to discuss TVAs planned transition to Framatome fuel, including Framatome transition methodology, and requirements to support a fuel vendor transition at EPU conditions. As a result of the telephone call and the meeting, two options appear viable. The following describes TVAs understanding of the two options and the implications associated with each:
U.S. Nuclear Regulatory Commission Page 2 November 22, 2002 Constant Pressure Power Uprate License Topical Report (CLTR) Process Even though there is not an approved safety evaluation report (SER) for the Constant Pressure Power Uprate License Topical Report NEDC-33004P, TVA could submit a license amendment for Units 2 and 3 in accordance with this process under the following conditions:
With the CLTR process, only Global Nuclear Fuel-LLC (GNF) fuel can be loaded into the first unit implementing the EPU project. No fuel vendor change could occur concurrent with implementing EPU on the first unit.
After the first cycle of operation with GNF fuel, a fuel vendor change can be achieved using Framatome ANPs normal licensing process. In addition, this amendment would address any underlying assumptions of the CLTR process regarding the fuel vendor.
Since the BFN units are identical in features that affect fuel-related analyses, after the first unit is operated at EPU conditions with GNF fuel, there will be no requirement for GNF fuel on the second unit. The second unit could implement EPU and change fuel vendors concurrently. In this case, Framatome ANPs normal licensing process would be followed addressing any underlying assumptions of the CLTR process regarding the fuel vendor.
A MELLLA+ License Amendment cannot be submitted for NRC review until after NRC approval of the Safety Evaluation Report for the EPU License Amendment.
The MELLLA+ license amendment would then follow the normal license amendment process.
If only GNF fuel is in the reactor at the time of EPU approval, there would be no limits on increasing reactor power at the time of approval.
U.S. Nuclear Regulatory Commission Page 3 November 22, 2002 Extended Power Uprate License Topical Report (ELTR) Process The Extended Power Uprate License Topical Report process, NEDC 32424P-A and NEDC 32523P-A, has been approved by the NRC and used by several utilities for licensing and implementing EPU projects. TVA could use the ELTR process for BFN as follows:
TVA would verify that the constraints and limitations of the ELTR (and associated SERs) do not limit its use in this application or justify its use by identifying and dispositioning any exceptions.
With the ELTR process a fuel vendor change could be approved and implemented concurrent with the EPU project provided the supporting transient and accident analyses for Framatome ANP fuel are included and acceptable. Framatome will provide the scope of transient and accident analyses consistent with Framatome ANPs normal transition methodology as well as additional transient analyses applicable to the uprated condition.
With the ELTR process, it is acceptable to implement a fuel vendor change prior to submitting the EPU license amendment. The EPU submittal would contain the supporting transient and accident analyses for Framatome ANP fuel.
It would be acceptable to submit an ELTR license amendment request in two phases. The submittal containing all the analyses except for the fuel-related analyses could be submitted and the fuel-related analyses (provided by Framatome ANP) could be submitted at a later date.
U.S. Nuclear Regulatory Commission Page 4 November 21, 2002 With the ELTR process, the MELLLA+ license amendment can be submitted and approved prior to, concurrent with, or subsequent to the EPU license amendment.
Reactor power could not be increased until the new vendors fuel is loaded into the core. This would effectively eliminate the possibility of a small power increase if the EPU amendment is approved mid-cycle.
The staff will require at least one year to review the ELTR submitted with a fuel vendor change.
With this understanding, TVA plans to proceed as follows:
TVA will request a license amendment for a fuel vendor change in spring 2003 and assuming NRC approval, Framatome fuel will be loaded during the Unit 3 refueling outage scheduled in the spring of 2004. An EPU license amendment for Units 2 and 3 would be submitted in mid-2003 with requested NRC approval of summer 2004. Concurrent with this, TVA would also submit a MELLLA+ license amendment for Units 2 and 3 in mid-2003 with requested NRC approval of mid-2004. Assuming NRC approval, the EPU, MELLLA+ and fuel vendor change projects would then be implemented concurrently during the refueling outage for Unit 2 scheduled in the spring of 2005. EPU and MELLLA+ projects would be implemented for Unit 3 during the outage scheduled in the spring of 2006.
TVA requests that the staff expeditiously review the options described above and TVAs plan for implementation to ensure that the options available and the plan are consistent with staff positions. TVA also requests that NRC formally provide concurrence with the options and TVAs plans.
U.S. Nuclear Regulatory Commission Page 5 November 21, 2002 There are no new commitments contained in this letter. If you have any questions, please contact Tim Abney at (256) 729-2636.
Sincerely, original signed by:
Ashok S. Bhatnagar (Via NRC Electronic Distribution) cc:
Mr. Paul E. Fredrickson, Branch Chief U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth Street, SW, Suite 23T85 Atlanta, Georgia 30303-8931 NRC Resident Inspector Browns Ferry Nuclear Plant 10833 Shaw Road Athens, Alabama 35611 Mr. Kahtan N. Jabbour, Senior Project Manager U.S. Nuclear Regulatory Commission One White Flint, North (MS 08G9) 11555 Rockville Pike Rockville, Maryland 20852-2739
U.S. Nuclear Regulatory Commission Page 6 TEA:DTL:BAB cc: A. S. Bhatnagar, PAB 1E-BFN M. J. Burzynski, BR 4X-C R. G. Jones, POB 2C-BFN J. E. Maddox, LP 6A-C R. F. Marks, PAB 1A-BFN T. J. Niessen, PAB 1A-BFN D. C. Olcsvary, LP 6A-C C. M. Root, PAB 1G-BFN J. R. Rupert, LP 6A-C K. W. Singer, LP 6A-C E. J. Vigluicci, ET 11A-K R. E. Wiggall, PEC 2A-BFN NSRB Support, LP 5M-C EDMS-K s:lic/submit/subs/NRC EPU Letter A.doc