ML16189A343

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Summary Report for the May 10 - 11, 2016 Audit in Support of Spent Fuel Pool Criticality and Boral Plate Testing Reviews Associated with Extended Power Uprate License Amendment Request (CAC Nos. MF6741, MF6742 & MF6743)
ML16189A343
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 07/14/2016
From: Farideh Saba
Plant Licensing Branch II
To: James Shea
Tennessee Valley Authority
Saba F DORL/LPL2-2 301-415-1447
References
CAC MF6741, CAC MF6742, CAC MF6743
Download: ML16189A343 (7)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Joseph W. Shea Vice President, Nuclear Licensing Tennessee Valley Authority 1101 Market Street, LP 3R-C Chattanooga, TN 37402-2801 July 14, 2016

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 -

SUMMARY

REPORT FOR THE MAY 10 TO MAY 11, 2016 AUDIT IN SUPPORT OF SPENT FUEL POOL CRITICALITY AND BORAL MONITORING PROGRAM REVIEWS ASSOCIATED WITH EXTENDED POWER UPRATE LICENSE AMENDMENT REQUEST (CAC NOS. MF6741, MF6742, AND MF6743)

Dear Mr. Shea:

By letter dated September 21, 2015, as supplemented by letters dated November 13, December 15 (2 letters), and December 18, 2015, Tennessee Valley Authority (TVA, the licensee) submitted a license amendment request (LAR) for the Browns Ferry Nuclear Plant, Units 1, 2, and 3. The proposed amendment would increase the authorized maximum steady-state reactor core power level for each unit from 3,458 megawatts thermal (MWt) to 3,952 MWt. This LAR represents an increase of approximately 20 percent above the original licensed thermal power level of 3,293 MWt, and an increase of approximately 14.3 percent above the current licensed thermal power level of 3,458 MWt.

In addition, by letters dated January 28 and January 29, 2016, the U.S. Nuclear Regulatory Commission (NRC) issued requests for additional information (RAls) associated with spent fuel pool criticality and the Boral monitoring program at Browns Ferry. The licensee, by letters dated February 16, 2016 and March 8, 2016, responded to the NRC staff's requested information.

On March 22, 2016, the NRC staff forwarded, by electronic mail (email), draft RAls to TVA. On April 7, 2016, the NRC staff held a conference call to provide the licensee with an opportunity to clarify any portion of the draft RAls and discuss the timeframe for which TVA could provide the requested information. Subsequently, the NRC staff determined that an audit would be the most effective approach to enable the NRC staff to develop focused RAls in order for the licensee to provide quality and timely responses.

The audit was held at the EXCEL Services Corporation facility in Rockville, Maryland, from May 10 to May 11, 2016. The audit plan dated April 27, 2016, is available in Agencywide Documents Access and Management System under Accession No. ML16105A441. A list of audit attendees is provided in Enclosure 1.

During the audit, the licensee provided to the NRC staff a documentation package that included the NRC staff's draft RAls that were emailed to TVA on March 22, 2016, TVA's draft responses, and the supplemental information that would support completion of the NRC staff's review. The

NRC staff reviewed the information provided in the package and discussed it with the TVA staff and the AREVA (TVA contractor) staff.

As the result of this audit, the NRC staff was able to finalize the draft RAls. The NRC's letter dated June 21, 2016, documents the finalized RAls associated with associated with the Boral monitoring program and spent fuel pool criticality. The licensee was able to identify draft responses that would need to be revised to provide additional clarifications. As agreed to by the NRC and TVA staffs, TVA will respond to the staff RAls by July 29, 2016. Enclosure 2 to this letter provides the audit summary report.

If you have any questions, please contact me at (301) 415-1447 or Farideh.Saba@nrc.gov.

Docket Nos. 50-259, 50-260, and 50-296

Enclosures:

1. List of Attendees
2. Summary Report for Audit cc w/encls: Distribution via Listserv Sincerely, Farideh E. Saba, Senior Project Manager Plant Licensing 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

LIST OF ATTENDEES MAY 10 - 11, 2016, AUDIT OF TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 SPENT FUEL POOL CRITICALITY AND BORAL MONITORING PROGRAM REVIEW ASSOCIATED TO EXTENDED POWER UPRATE LICENSE AMENDMENT REQUEST Name Affiliation Entrance 05/10 05/11 Exit (05/10)

(05/11)

Ben Beasley NRC x

x Scott Krepel NRC x

x x

x Kent Wood NRC x

x x

Mathew Yoder NRC x

x Farideh Saba NRC x

x x

x Gloria Kulesa NRC x

x Ed Schrull TVA In PM x

x Gerard Doyle TVA x

x x

x Dan Green TVA x

x x

x Pete Donahue TVA x

x x

x Jeff Kimberlin TVA x

x x

x Tom Eichenberg TVA x

x x

x Zita Martin TVA x

x x

x Earl Riley AREVA x

x x

x Ed Fowles AREVA x

x x

x Alan Meginnis AREVA x

x x

x David McBurney AREVA x

x x

x

SUMMARY

REPORT FOR MAY 10 - 11, 2016, AUDIT AT EXCEL FACILITY IN ROCKVILLE, MARYLAND REVIEW OF EXTENDED POWER UPRATE LICENSE AMENDMENT REQUEST TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3 DOCKET NOS. 50-259, 50-260, AND 50-296 By letter dated September 21, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15282A152), as supplemented by letters dated November 13, December 15 (2 letters), and December 18, 2015 (ADAMS Accession Nos. ML15317A361, ML15351A097, ML15351A113, and ML15355A413, respectively), Tennessee Valley Authority (TVA, the licensee) submitted a license amendment request (LAR) for Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3 (Browns Ferry). The proposed amendment would increase the authorized maximum steady-state reactor core power level for each unit from current licensed thermal power of 3,458 megawatt thermal (MWt) to extended power update (EPU) level of 3,952 MWt. This LAR represents an increase of approximately 20 percent above the original licensed thermal power level of 3,293 MWt, and an increase of approximately 14.3 percent above the CLTP.

In addition, by letters dated January 28 and January 29, 2016, the U.S. Nuclear Regulatory Commission (NRC) issued requests for additional information (RAls) associated with spent fuel pool (SFP) criticality and The Boral monitoring program at Browns Ferry (ADAMS Accession Nos. ML16019A2831 and ML16020A111, 2 respectively). The licensee, by letters dated February 16, 2016 (ADAMS Accession No. ML16049A2483) and March 8, 2016 (ADAMS Accession No. ML16069A1424), responded to the NRC staff's requested information.

On March 22, 2016, the NRC staff forwarded, by electronic mail (email), two separate draft RAls to TVA. On April 7, 2016, the NRC staff held a conference call to provide the licensee with an opportunity to obtain clarification on any portion of the draft RAls and discuss the timeframe for which TVA could provide the requested information. Subsequently, the NRC staff determined that an audit would be the most effective approach to enable the NRC staff to develop focused RAls in order for the licensee to provide quality and timely responses.

The audit was held at the EXCEL Services Corporation facility in Rockville, Maryland, from May 10 to May 11, 2016. The audit plan dated April 27, 2016, is available in ADAMS under Accession No. ML16105A297. A list of attendees in the entrance meeting, audit days, and exit meeting was shown in Enclosure 1. The following NRC staff participated in the audit 1 It contains SFP-RAI 1 and SFP-RAI 2.

2 It contains ESGB [Steam Generator Tube Integrity and Chemical Engineering Branch]-RAI 1.

3 It contains TVA responses to SFP-RAI 1 and ESGB-RAI 1.

4 It contains TVA response to SFP-RAI 2.

discussions: Kent Wood, senior criticality engineer; Scott Krepel, lead spent fuel pool criticality reviewer; Matthew Yoder, lead Boral monitoring program reviewer; and Farideh Saba, project manager.

The audit team held an entrance meeting on May 10, 2016. At this meeting, following the introduction, TVA and its contractor, AREVA, provided a short discussion about SFP criticality analyses associated with each fuel transitioning, and manufacturing and installation of the Boral-containing racks at the Browns Ferry plant.

During the audit, the licensee presented to the NRC staff, a documentation package that included the NRC staff's nine draft RAls regarding SFP criticality and two draft RAls associated with the Boral monitoring program that were emailed to TVA on March 22; TVA draft responses to all draft RAls; and the supplemental information that would support the NRC staff's review.

The documents in the package presented by TVA are listed below:

1.

Letter from NRC to TVA, "Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Regulatory Audit Plan for May 10 - 11, 2016, Audit at EXCEL Facility in Rockville, Maryland, in Support of Extended Power Uprate License Amendment Request (CAC Nos. MF6741, MF6742, and MF6743), dated April 27, 2016(ML16105A441).

2.

Draft NRC SFP RAls, "MF6741-3 BFN EPU LAR Draft RAI SFP, dated March 22, 2016.

(transmitted RAls Additional SFP-RAI 2.1 through SFP RAl-10).

3.

AREVA Draft Response to SFP-RAls 3b, 4, 6, 7, 8, 9, and 10.

4.

TVA Draft Response to SFP-RAls 2-1, 3a, and 5.

5.

Draft NRC ESGB RAls, "MF6741-3 BFN EPU LAR Draft RAI ESGB, dated March 22, 2016. (transmitted Round 2 for RAls ESGB-RAI 1 through ESGB-RAI 2).

6.

TVA Draft Response to ESGB Round 2 RAls 1 and 2.

7.

AREVA Final Response to SFP Round 1 RAI 1.

8.

TVA Final Response to SFP Round 1 RAI 2.

9.

TVA Final Response to ESGB Round 1 RAI 1.

During the audit, the NRC staff reviewed the information provided in the package and discussed it with the TVA and AREVA staffs. There was open communication throughout the audit and it was conducted in accordance with the audit plan with no known deviation. Discussions on May 10, 2016, were focused on the responses associated with the RAls for SFP criticality and discussions on May 11, 2016, were mainly focused on the Boral monitoring program RAls and issues. From the 11 draft RAls (9 from SFP and 2 from ESGB) that were discussed during the audit the TVA staff determined that the additional clarification or additional work was necessary to provide appropriate responses to 7 RAls. The NRC staff also determined the necessity of adding one more RAI, as a followup to SFP-RAI 1, asking the licensee to propose means to ensure that the maximum reactivity of fuel assemblies loaded in SFP is limited for future fuel assemblies loaded in the SFP, consistent with the k-infinity limit specified in the standard technical specifications.

During the audit, the NRC staff noted that the NRC Generic Letter (GL) 2016-01, "Monitoring of Neutron-Absorbing Material in Spent Fuel Pools," dated April 7, 2016, requested, the licensees submit information that demonstrates that credited neutron absorbing materials in the SFP are in compliance with NRC regulatory requirements for subcriticality. The staff also pointed out that Nuclear Energy Institute (NEI) document NEI 16-03, "Guidance for Monitoring of Fixed Neutron Absorbers in Spent Fuel Pools," was submitted to the NRC on May 10, 2016.

However, both the NRC staff and the TVA staff had a mutual understanding that the NRC staff's concerns regarding the Baral monitoring program would need to be resolved prior to completion of the staff review of TVA's response to GL 16-01 and NEI document. Therefore, the NRC staff and the TVA staff agreed that TVA, in its response to the staff's RAI, would propose a license condition associated with the Baral monitoring program.

At the conclusion of the audit, the NRC staff conducted an exit meeting on May 11, 2016. At that meeting, the staff provided a summary of the audit results in each subject area defined in the audit scope. In addition, the NRC staff and TVA staff agreed to renumber the draft followup SFP-RAI 2 (renumbered as SFP-RAI 125) and round 2 ESGB-RAls 1 and 2 (renumbered as ESGB-RAI 2 and 3). The NRC staff and TVA staff both agreed that the audit helped the licensee to better focus on the scope of NRC's draft RAls. The audit also provided the NRC staff with a better understanding of TVA's submittals and approach for responding to the NRC staff's RAls. Additionally, the NRC staff utilized results of the audit to finalize and issue the RAls, which are documented in the NRC letter dated June 21, 2016 (ADAMS Accession No. ML16154A635).

Subsequent to the audit, on May 12, 2016, the NRC staff emailed a draft RAI associated with in-rack k-infinity and sent another email on May 26, 2016, that contained a revised SFP-RAI 12 (followup RAI to SFP-RAI 2) to add clarifications to the requested information. These changes are captured in the finalized RAls in the NRC letter dated June 21, 2016. Currently, TVA is planning to submit its responses to the staff RAls by July 29, 2016.

5 The followup RAI to SFP-RAI 1 is numbered as SFP-RAI 11.

NRC staff reviewed the information provided in the package and discussed it with the TVA staff and the AREVA (TV A contractor) staff.

As the result of this audit, the NRC staff was able to finalize the draft RAls. The NRC's letter dated June 21, 2016, documents the finalized RAls associated with associated with The Baral monitoring program and spent fuel pool criticality. The licensee was able to identify draft responses that would need to be revised to provide additional clarifications. As agreed to by the NRC and TVA staffs, TVA will respond to the staff RAls by July 29, 2016. Enclosure 2 to this letter provides the audit summary report.

If you have any questions, please contact me at (301) 415-1447 or Farideh.Saba@nrc.gov.

Sincerely,

/RAJ Farideh E. Saba, Senior Project Manager Plant Licensing 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260, and 50-296

Enclosures:

1. List of Attendees

2. Summary Report for Audit cc w/encls: Distribution via Listserv DISTRIBUTION:

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NAME FSaba BClayton JDean (for, YOrechwa)

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