ML18171A337

Issuance of Amendment to Revise License Condition 2.C(18)(a)3

ML18171A337
Person / Time
Site:	Browns Ferry
Issue date:	07/10/2018
From:	Farideh Saba Plant Licensing Branch II
To:	James Shea Tennessee Valley Authority
Saba F DORL/LPL2-2 301-415-1447
References
EPID L-2018-LLA-0061
Download: ML18171A337 (11)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 10, 2018 Mr. Joseph W. Shea, Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A Chattanooga, Tennessee 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNIT 1 - ISSUANCE OF AMENDMENT TO REVISE LICENSE CONDITION 2.C(18)(a)3 (EPID L-2018-LLA-0061)

Dear Mr. Shea:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 304 to Renewed Facility Operating License No. DPR-33 for the Browns Ferry Nuclear Plant, Unit 1. This amendment is in response to Tennessee Valley Authority's license amendment request dated March 16, 2018, as supplemented by letter dated April 19, 2018. The amendment revises License Condition 2.C(18)(a)3 for Unit 1 that required submittal of a revised replacement steam dryer analysis from at least 90 days prior to the start of the Browns Ferry Unit 1 extended power uprate outage to 60 days prior to exceeding 3458 megawatt thermal after the outage.

Copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely, Farideh E. Saba, Senior Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-259

Enclosures:

1. Amendment No. 304 to DPR-33

2. Safety Evaluation cc: Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-259 BROWNS FERRY NUCLEAR PLANT. UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 304 Renewed License No. DPR-33

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated March 16, 2018, as supplemented by letter April 19, 2018, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the renewed license is amended by changes as indicated in the attachment to this license amendment and to the following paragraphs:

Paragraph 2.C.(2) of Renewed Facility Operating License (RFOL) No. DPR-33 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 304, are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

Paragraph 2.C(18)(a)3 of RFOL No. DPR-33 is hereby amended to read as follows:

3. At least 60 days prior to exceeding 3458 MWt after 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.

4. The license amendment is effective as of its date of issuance and shall be implemented immediately.

FOR THE NUCLEAR REGULATORY COMMISSION

~.~~

Booma Venkataraman, Acting Chief Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Operating License Date of Issuance: July 10, 2018

ATTACHMENT TO LICENSE AMENDMENT NO. 304 BROWNS FERRY NUCLEAR PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-33 DOCKET NO. 50-259 Replace the following pages of Renewed Facility Operating License DPR-33 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

REMOVE INSERT 3 3 6a 6a

(3) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use at any time any byproduct, source, and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4) Pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or equipment and instrument calibration or associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C. This renewed operating license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I:

Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at steady state reactor core power levels not in excess of 3952 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 304 are hereby incorporated in the renewed operating license. The licensee shall operate the facility in accordance with the Technical Specifications.

For Surveillance Requirements (SRs) that are new in Amendment 234 to Facility Operating License DPR-33, the first performance is due at the end of the first surveillance interval that begins at implementation of the Amendment 234. For SRs that existed prior to Amendment 234, including SRs with modified acceptance criteria and SRs whose frequency of performance is being extended, the first performance is due at the end of the first surveillance interval that begins on the date the surveillance was last performed prior to implementation of Amendment 234.

BFN-UNIT 1 Renewed License No. DPR-33 Amendment No. 304

-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 60 days prior to exceeding 3458 MWt after 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 the 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 analysis.

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. 304

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 304 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-33, TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNIT 1 DOCKET NO. 50-259

1.0 INTRODUCTION

By letter dated March 16, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18080A171 ), as supplemented by letter dated April 19, 2018 (ADAMS Accession No. ML18109A573, Tennessee Valley Authority (TVA, the licensee),

submitted a license amendment request (LAR) regarding the Browns Ferry Nuclear Plant (BFN)

Unit 1. The amendment revises License Condition 2.C(18)(a)3 for Unit 1 that to alter the time for submittal of a revised replacement steam dryer (RSD) analysis from at least 90 days prior to the start of the BFN Unit 1 extended power uprate outage to 60 days prior to exceeding 3458 megawatt thermal (MWt) after the outage.

The LAR was originally noticed in the Federal Register on April 10, 2018 (83 FR 15418). The renotice, which superseded the original notice in its entirety, was published on May 8, 2018 (83 FR 20862).

2.0 REGULATORY EVALUATION

2.1 Background By letter dated August 14, 2017, the Nuclear Regulatory Commission (NRC) issued Amendment Nos. 299, 323, and 283 to the BFN Renewed Facility Operating Licenses (RFOLs) to increase the authorized maximum power level from 3458 MWt to 3952 MWt (ADAMS Accession No.ML17032A120). The amendments included specific license conditions that required certain monitoring, evaluation, and response actions to potential adverse flow effects as a result of the extended power uprate (EPU) on plant structures, systems and components (including verifying the continued structural integrity of the RSD) during the initial EPU power ascension. The licensee planned to implement the EPU in accordance with the following schedule:

Unit 1: Prior to startup from the refueling outage in the fall of 2018.

Unit 2: Prior to startup from the refueling outage in the spring of 2019.

Unit 3: Prior to startup from the refueling outage in the spring of 2018.

Enclosure 2

The NRC staff approval of the EPU was based, in part, on the capability of the licensee to monitor, evaluate, and take prompt action in response to potential adverse flow effects as a result of EPU operation on plant structures, systems, and components (including verifying the continued structural integrity of the RSD). License condition 2.C{18)(a)3 was added to the RFOL for BFN Unit 1, as part of the EPU amendment, to provide the necessary requirements associated with potential adverse flow effects. 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.

Consistent with the above license condition, the licensee is required to revise the BFN, Unit 3, RSD analysis, based on the revised Unit 3 RSD analysis at EPU conditions. The license condition requires that the revised Unit 1 RSD analysis be submitted as a report at least 90 days prior to the start of the current estimated Unit 1 EPU outage of October 13, 2018.

2.2 Proposed Amendment TVA, in its submittal dated April 19, 2018, stated that based on delays associated with the BFN Unit 3 power ascension and 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.

Further TVA explained that based on the current BFN Unit 3 power ascension test schedule, Unit 3 will not reach full EPU power until late July 2018, and that the Unit 3 on-dryer and main steam line (MSL) measurements will be available shortly after. Using the measured MSL data from Un.it 3, General Electric - Hitachi Nuclear Energy (GEH) will develop plant based load evaluation (PBLE)02 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. Once available, the Minimum Alternating Stress Ratio from the 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. Subsequently, 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. Upon receipt of the report from GEH, TVA will develop, review, and process the NRC submittal in accordance with TVA procedures.

Therefore, the licensee's LAR requested to change the "At least 90 days prior to the start of the BFN Unit 1 EPU outage," requirement in the license condition to "60 days prior to exceeding 3458 MWt after the BFN Unit 1 EPU outage." The revised BFN, Unit 1, license condition 2.C(18)(a)3 would read as follows:

At least 60 days prior to exceeding 3458 MWt after 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.

3.0 TECHNICAL EVALUATION

The original steam dryers at BFN, Units 1, 2, and 3, were GE BWR/4, parallel vane bank slanted hood design steam dryers with perforated plates at the inlet and outlet sides of the vane banks. As part of the EPU implementation, the licensee planned to replace the original GE dryers with parallel vane bank curved hood design dryers for all three Browns Ferry units. For BFN, Unit 3, the licensee replaced the original steam dryer during the spring of 2018 refueling outage.

Section 2.2.6, "Additional Review Area - Replacement Steam Dryer Structural Integrity," and Section 2.12, "Power Ascension and Testing Plan," of the NRC staff's safety evaluation in the EPU amendments for BFN units (Amendment Nos. 299,323, and 283, dated August 14, 2017) discusses the staff's review regarding the RSDs' structural integrity and test plans. The NRC staff's review focused on potential adverse flow effects due to increased flow at EPU conditions in order to assure the RSDs' structural integrity and the licensee's power ascension test plan (PATP). The three main elements of the PATP are as follows: ( 1) a slow and deliberate power ascension with defined hold points and durations allowing time for monitoring and analysis; (2) a detailed power ascension monitoring and analysis program to trend RSD performance; and (3) an inspection and analysis program to verify RSD and piping system performance. In accordance with the appropriate license condition for each unit, relevant information is transmitted to the NRC staff prior to and during the power ascension, and following the EPU implementation.

TVA requested license condition 2.C(18)(a)3, the Unit 1 RSD analysis is to be revised from "At least 90 days prior to the start of the BFN Unit 1 EPU outage" to "At least 60 days prior to exceeding 3458 MWt after the BFN Unit 1 EPU outage" based on the revised Unit 3 RSD analysis at EPU conditions. The information to be submitted to the NRC in accordance with this license condition provides a baseline of the expected performance of the RSD during power ascension. The information to be submitted also provides acceptance criteria that is used to assess actual performance of the Unit 1 RSD during the power ascension process from the previous thermal power of 3458 MWt to the EPU approved thermal power of 3952 MWt. There is no formal NRC staff review and approval associated with the information to be submitted in accordance with BFN Unit 1 license condition 2. C( 18 )( a )3.

Based on the above discussion and given the delays associated with completing the revised RSD analysis for BFN Unit 3, the NRC staff finds that the proposed change from "90 days prior to the start of the BFN Unit 1 EPU outage" to "60 days prior to exceeding 3458 MWt after the BFN Unit 1 EPU outage" in BFN Unit 1, in license condition 2.C(18)(a)(3) will provide the licensee with a reasonable time to submit the revised RSD analysis for BFN Unit 1. It also provides the NRC staff with reasonable amount of time to complete its review of this analysis prior to Unit 1 exceeding its previous power level of 3458 MWt. Therefore, the NRC staff concludes that the proposed amendment is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Tennessee State official was notified of the proposed issuance of the amendment on June 26, 2018. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment relates to changes in recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on May 8, 2018 (83 FR 20862).

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Farideh Saba Chakrapani Basavaraju Date: July 10, 2018

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNIT 1 - ISSUANCE OF AMENDMENT TO REVISE LICENSE CONDITION 2.C(18)(a)3 (EPID L-2018-LLA-0061)

DATED JULY 10, 2018 DISTRIBUTION:

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DATE 06/26/18 06/26/18 06/26/18 OFFICE OGC-NLO DORL/LPL2-2/BC DORL/LPL2-2/PM NAME SSpicer BVenkataraman FSaba DATE 06/29/18 07/05/18 07/10/18 OFFICIAL RECORD COPY