ML15023A280
| ML15023A280 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 02/13/2015 |
| From: | Farideh Saba Plant Licensing Branch II |
| To: | Tennessee Valley Authority |
| Saba F DORL/LPL2-2 301-415-1447 | |
| References | |
| TAC MF4851, TAC MF4852, TAC MF4853 | |
| Download: ML15023A280 (4) | |
Text
LICENSEE:
Tennessee Valley Authority FACILITY:
Browns Ferry Nuclear Plant, Units 1, 2, and 3
SUBJECT:
SUMMARY
OF JANUARY 15, 2015, MEETING WITH TENNESSEE VALLEY AUTHORITY ON PRE-SUBMITTAL OF EXTENDED POWER UPRATE LICENSE AMENDMENT REQUEST - APPROACH TO TREATMENT OF HYDROGEN EMBRITTLEMENT ISSUES (TAC NOS. MF4851, MF4852, AND MF4853)
On January 15, 2015, 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 for TVA to present and discuss its plans for addressing hydrogen embrittlement issues, in order to preclude impact to the forthcoming extended power uprate (EPU) license amendment request (LAR) for Browns Ferry Nuclear Plant, Units 1, 2, and 3. Its presentation included proposed Title 10 of the Code of Federal Regulations (10 CFR) Section 50.46c rulemaking and reactivity initiated accident (RIA) guidance revisions. The meeting notice and agenda, dated December 15, 2014, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML15008A211. The licensee's presentation material is available in ADAMS at Accession No. ML15008A184. A list of attendees is enclosed.
The licensee presented an overview of its plans for the 10 CFR 50.46c rule implementation and upcoming changes for compliance with this new rule. TVA showed a timeline of its EPU LAR, plant modifications, and implementation dates. TVA stated that some plant modifications were previously completed and others are still in the process of being completed. TVA's planned approach for the EPU LAR submittal scheduled for October 2015 is to demonstrate compliance with the current regulations, while also taking an approach, similar to the Boiling Water Reactor Owners Group Margin Assessment, based on the draft 1 O CFR 50.46c rule, with updated information for EPU conditions and new fuel. TVA believes it will gain margin on various acceptance criteria by credit gained with automatic depressurization system (ADS) initiation logic now becoming single failure proof. Some modifications were performed to ensure not all ADS logic came from one single battery. TVA believes it will lose some margin due to the recent newer Core Spray licensing basis requirements.
TVA plans to submit its new, revised request for a 15 percent power uprate (20 percent from original licensed thermal power) for all units in October 2015. with target implementation in March 2018 for Unit 3, October 2018 for Unit 1, and March 2019 for Unit 2. TVA is preparing for an 18-24 month NRC review period to reach the first implementation date, but it is unclear if this will be enough time.
Based on the currently proposed 10 CFR 50.46c, TVA is planning to develop a fuel rod thermal mechanical method, emergency core cooling system performance method, long-term cooling method, vendor breakaway oxidation program, and change its Technical Specification 5.6.5, "Core Operating Limits Report," to satisfy the requirements of this rule. TVA presented a timeline for its plans to comply with the 10 CFR 50.46c rule, which lists all of its potential changes that will need NRC approval. While discussing the timeline, AREVA mentioned a potential topical report that will be submitted in a comment package on the 1 O CFR 50.46c rule.
TVA expressed concern with the scheduling challenge of being in compliance with long-term cooling (e.g., Generic Safety lssue-191 ), if the rule is published in March 2016 with a 24-month implementation schedule. TVA reiterated its view that legacy fuel should be grandfathered for the new aspects of the proposed 50.46c rule (e.g., testing for breakaway oxidation), because of the practical challenges of meeting the requirements with legacy fuel.
Additionally, TVA mentioned that more assessments will be performed on hydrogen pickup effects, maximum equivalent cladding reacted results, and relevant breakaway oxidation time information.
The NRC staff queried the licensee about its familiarity with timelines and processes for an EPU submittal. NRC staff suggested that TVA start this process for an EPU a year later, so the 10 CFR 50.46c rule would be implemented, and there would be more time for TV A's understanding of compliance. The staff recommended that TVA follow-up on how to comply with upcoming rulemaking by attending future public meetings.
TVA responded it was familiar with timelines for EPU submittals and created timelines to reflect them, although TVA is certain situations will arise that could disrupt the timeline. TVA responded to the NRC staff that if the EPU submittal was pushed back a year later, Unit 3 dryer outage work would have to be shifted to Unit 1, as a delay for Unit 3, without shifting dryer outage work (instrumenting the replacement steam dryer) to Unit 1, would essentially delay implementation of EPU by 6 years. TVA agreed to follow-up on upcoming rulemaking by attending public meetings.
The licensee also presented an overview of plans to address proposed changes to the reactivity initiated accidents (RIA) acceptance criteria in the EPU LAR submittal. The NRC staff indicated that the approach was reasonable, but suggested TVA also consider addressing fuel melt criteria and pellet-to-cladding mechanical interaction failure threshold in the submittal.
The meeting concluded with a summary of TVA and NRC follow-up items related to preparation for the forthcoming EPU LAR submittal. With respect to RIA acceptance criteria (i.e., Control Rod Drop Accident (CRDA) acceptance criteria), TVA is considering addressing fuel melt criteria and pellet-to-cladding mechanical interaction failure threshold in the submittal. Since PCMI failure threshold acceptance criteria impacts the number of fuel rods that would be postulated to fail in a CRDA, a margin discussion relative to resulting dose consequence changes for the CRDA could be provided.
Members of the public were in attendance. Public Meeting Feedback forms were not received.
Please direct any inquiries to me at 301-415-1447 or Farideh.Saba@nrc.gov.
Docket Nos. 50-259, 50-260, and 50-296
Enclosure:
List of Attendees cc w/enclosures: Distribution via Listserv Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
LIST OF ATTENDEES JANUARY 15. 2015. MEETING WITH TENNESSEE VALLEY AUTHORITY PRE-SUBMITTAL OF EXTENDED POWER UPRATE LICENSE AMENDMENT REQUEST -
APPROACH TO TREATMENT OF HYDROGEN EMBRITTLEMENT ISSUES NUCLEAR REGULATORY COMMISSION STAFF AND CONTRACTORS Benjamin Parks
- Diane Render Eliza Mitchell Jeremy Dean Diego Saenz Paul Clifford Mathew Panicker Margaret Watford Reed Anzalone Shana Helton Candace Pfefferkorn Alysia Bone Farideh Saba David Dumbacher
- TENNESSEE VALLEY AUTHORITY STAFF AND CONTRACTORS Daniel Green Ed Schrull Tom Eichenberg Greg Storey Gerard Doyle George Rorke Peter Donahue
- By phone AREVA STAFF AND CONTRACTORS Robert Schnepp
- David McBurney Alan Meginnis Lisa Gerken Scott Tylinski
- PUBLIC Gordon Clefton William Freebairn
- Enclosure
ML15023A280 IRA/
Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation TWertz, NRR MWatford, NRR RAnzalone, NRR CPfefferkorn, NRR DRender, NRR ABone, NRR DDumbacher, R-11 BParks, NRR PClifford, NRR LRonewicz, NRR DSaenz, NRR OFFICE DORL/LPL 1-1/PM DORL/LPL2-2/PM DORL/LPL2-2/LAiT DORL/LPL2-2/LA NAME DRender FSaba LRonewicz BClayton DATE 2/06/15 2/13/15 2/9/15 2/1315 OFFICE DSS/SNPB/BC DORL/LPL2-2/BC DORL/LPL2-2/PM NAME JDean Shelton (AKlett for)
FSaba DATE 2/10/15 2/13/15 2/13/15