ML11264A011

9/15/11 Summary of Meeting with Tennessee Valley Authority on Extended Power Uprate

ML11264A011
Person / Time
Site:	Browns Ferry
Issue date:	12/07/2011
From:	Gratton C Plant Licensing Branch II
To:
Gratton, Christopher
Shared Package
ML11264A010	List: ML11264A011
References
TAC MD5262, TAC MD5263, TAC MD5264
Download: ML11264A011 (5)

Text

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0 WASHINGTON, D.C. 20555-0001 Iii E

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LICENSEE: Tennessee Valley Authority FACILITY: Browns Ferry Nuclear Plant, Units 1, 2, and 3 SUB,JECT:

SUMMARY

OF SEPTEMBER 15, 2011, MEETING WITH TENNESSEE VALLEY AUTHORITY ON EXTENDED POWER UPRATE (TAC NOS. MD5262, MD5263, AND MD5264)

On September 15, 2011, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Tennessee Valley Authority (TVA, the licensee) at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to discuss the schedule for the resolution of technical issues related to the extended power uprate (EPU) application currently under review by the NRC and the status of the transition to National Fire Protection Association (NFPA)

Standard 805 for the Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3. A list of attendees is enclosed.

The licensee's presentation covered the background of the containment accident pressure credit issue and summarized the licensee's plans for eliminating the credit for the EPU application (See Agencywide Documents Access and Management System Accession No. ML11257A034). The licensee expects to eliminate credit for containment accident pressure (CAP) in all limiting events with the exception of the short term (less than 10 minutes) loss-of-coolant accident (LOCA). The licensee plans to use the Boiling Water Reactor Owners Group (BWROG) generic guidance, which is currently under development, to address the net positive suction head (NPSH) uncertainty adder for the short-term LOCA. Methods for eliminating CAP credit in other limiting events include improved residual heat removal (RHR) heat exchanger (HX) performance and increased suppression pool inventory for fire events and improved RHR HX performance for the long-term (greater than 10 minutes) LOCA event. CAP credit was not required in the licensee's analysis of the station blackout (SBO) and anticipated transient without scram (ATWS) events.

The licensee also discussed the status and schedule for the replacement steam dryers (RSDs).

The licensee is currently negotiating for the design, analysis, fabrication, and installation of the RSDs, and plans to begin the analysis and design following the NRC staffs acceptance of the CAP analysis. The licensee would begin fabrication of the RSDs following approval of the EPU amendment for each unit.

The licensee reviewed its schedule for the remaining milestones for the EPU amendment. The licensee expects to submit the CAP analysis in May 2012, assuming that the BWROG generic guidance is available in March 2012. The licensee plans to request written NRC staff approval of the CAP credit for the short-term LOCA analysis. The licensee will then submit the RSD analysis in spring 2014, following the successful review of the CAP analysis. The licensee will be expecting a 12-month review of the CAP analysis by the NRC staff, and 12 months to develop its RSD analysis report, also for the NRC staff's review, assuming the staff accepts the CAP analysis.

- 2 Finally, the licensee discussed its plans to transition BFN to NFPA-805. The licensee noted the milestones it has achieved and the milestones that are upcoming to complete the transition.

The licensee noted that the elimination of CAP credit is no longer dependent upon the transition to NFPA-805, and that it is currently on schedule to submit the transition amendment in March 2012, though a significant amount of work remains to make that date. The licensee is considering requesting an extension to the enforcement discretion that is currently in place. The staff stated that the current enforcement discretion expires on March 4, 2012.

During the presentation, the NRC staff asked the licensee about the following topics:

• The licensee stated during its presentation that it would request staff acceptance of the NPSH analyses for the RHR and core spray pumps, including the use of CAP for the short-term LOCA analysis. The licensee did not specify the form of the submittal of this information. Several options are available including submitting the analysis as a plant-specific topical report, and the licensee stated that it would work with the NRC staff to identify the review method that is most appropriate. The staff prefers a stand-alone document that would address the use of CAP credit and explain why CAP credit is not needed for certain events that previously credited CAP. The document should include, as attachments, the actual NPSH calculations for the core spray and RHR pumps for the LOCA, SBO, ATWS, and safe shutdown analysis in accordance with Appendix R of Title 10 of the Code of Federal Regulations, Part 50.

By a letter dated March 1, 2010, the staff transmitted guidelines to the BWROG on analyses necessary when proposing the use of CAP. The staff was subsequently directed by the Commission in Staff Requirements Memorandum SECY 11-0014 to apply this guidance in EPU reviews. The TVA submittal should address how TVA proposes to implement this staff guidance as part of the Browns Ferry EPU application.

The guidance includes the uncertainty in NPSH values and the staff guidance to ensure adequate pump performance while operating under cavitation conditions. The BWROG is currently working with the manufacturer, Sulzer Pumps, to develop information needed to implement the staff guidance. Since the guidance is still in draft form, final implementation of this guidance by TVA for BFN will entail further discussion between the NRC staff and the licensee.

• The staff clarified that, due to the evolving nature of the CAP issue, the NRC's CAP guidelines that were endorsed by the Commission in March 2011 are considered draft.

Interactions with other licensees applying the guidelines have resulted in modifications to the guidance. Ultimately, these and future modifications will result in revisions to the CAP guidelines; but for now, the NRC staff recommends that licensees preparing to apply the guidelines should schedule a conference call with the NRC staff prior to developing their written documentation so that the most current information regarding the staff's position on the guidelines can be incorporated. The licensee acknowledged that the guidance has changed and that they need to work with the NRC staff to ensure their application reflects the most current staff position.

- 3

• The staff expressed concerns about the age and complexity of the BFN EPU applications. The applications are currently 7-years old and will be more than 10-years old at the time the dryer analysis is proposed to be submitted. The NRC staff informed the licensee that it plans to re-review the entire application following the completion of the CAP analysis review. To aid in the re-review, the staff will likely request that the licensee supplement EPU applications in their entirety to remove outdated information, and incorporate the resolution of NRC information requests. The licensee indicated that they would work with the staff to ensure the application was complete and accurate.

• The staff asked whether the new steam dryers would be instrumented prior to installation, and whether the licensee planned to incorporate lessons learned from prior dryer problems. The licensee stated that it plans to instrument one RSD, and, based on lessons learned, it is making improvements in the RSD design and taking precautions not to introduce any cold work during the fabrication and installation of the RSDs.

Members of the public were in attendance. Public Meeting Feedback forms were not received.

Please direct any inquiries to me at 301-41?!ro*,gr on@nrc:gov, lloPher Gratton, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296

Enclosure:

List of Attendees cc w/encl: Distribution via Listserv

LIST OF ATTENDEES MEETING WITH TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT EXTENDED POWER UPRATE Thursday, September 15, 2011 Time 1:00 p.m. - 3:00 p.m.

NAME ORGANIZATION Christopher Gratton NRRlDORL Doug Broaddus NRRlDORL Allen Howe NRRlDORL Mike Snodderly NRC/NRRlAPLA Richard Lobel NRC/NRRISCVB Nageswara Karipineni NRC/NRRISCVB William Bentley TVA R. M. Krich TVA

• T. C. Matthews TVA i Brenda Simril TVA Harry Barrett NRC/NRRlAFPB Naeem Iqbal NRC/NRRlAFPB I Mohammad Molaei Exelon Benjamin Parks NRC/NRRlSRXB Doug Pickett NRC/NRR/DORL Chakrapani Basavaraju NRC/NRRlEMCB Jana Bergman Scientech i Jason Paige NRC/NRRlDORL

. Muhammad Razzaque NRC/NRRlSRXB Greg Casto NRC/NRRlSBPB Lynne Gunderson* Exelon  !

David Malear* Exelon Ron Janowiak* Exelon John Fields* Xcel Energy Miroslav Trubelja* Structurallnte~rity Inc.

Bill Freebairn* Platts Luke Jen* Westinghouse Vujay Kumar* Westinghouse Hassan T afarrodi* Westinghouse Denise Anderson* Westinghouse Ray Dennis* Westinghouse

• Per telecon Enclosure

PKG ML11264A010 Meeting Notice ML11236A155 Handouts ML11257A034 Summary ML11264A011 OFFICE DORULPL2-2/PM DORULPL2-2/LA DORULPL2-2IBC DORULPL2-2/PM NAME CGratton BClayton DBroaddus CGratton iDATE 09/21/11 09/21/11 12/07111 12/07111