ML21250A301

TVA Slides for September 7, 2021, Presubmittal Meeting to Discuss Planned Browns Ferry TSTF-505 License Amendment Request

ML21250A301
Person / Time
Site:	Browns Ferry
Issue date:	09/07/2021
From:	Tennessee Valley Authority
To:	Office of Nuclear Reactor Regulation
References
Download: ML21250A301 (13)

Text

License Amendment Request Revise Browns Ferry Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b September 7, 2021

Agenda

• Describe future license amendment request (LAR)

- Scope of the Request

- Variations from TSTF-505

- PRA Models and CRMP Summary

• LAR Schedule

• Summary

• Questions/Comments?

2

Scope of the

• LAR is based on TSTF-505, Revision 2, and NEI 06-09, Risk-Informed Technical Specifications Initiative 4b, Request Risk-Managed Technical Specifications (RMTS)

Guidelines

• RICTs apply to approximately 20 BFN LCOs

- Applicable in Modes 1 and 2

- No loss of function consistent with template

• New TS 5.5 program called the Risk Informed Completion Time Program

• LAR informed by approved precedent and those currently under review

• Includes adoption of TSTF-439, Revision 2, Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO 3

TSTF-505 Several types of administrative variations are taken Variations

• Required Actions (RAs) with different numbering and slightly different wording with same intent

• TSTF-505 RAs that BFN TS do not have

• Instrumentation RAs invoked for different Functions or wording that a RICT applies to

• RICTs not applied since Additional Justifications werent met (e.g., not having a Shutdown PRA), or loss of function could not be confirmed

• Corrections to obvious minor traveler errors 4

TSTF-505 Four technical variations are being taken Variations

• BFN Instrumentation RAs that are not in STS meet the criteria for applying a RICT (continued)

• BFN RHR suppression pool cooling system differs from STS reference plant

• BFN RHR Service Water system differs from STS reference plant

• Site-specific Electrical Distribution RAs that are not in STS due to shared system capability which meet the criteria for applying a RICT 5

Other TSTF-439 is included changes

• Traveler is cited as prerequisite for applying RICT to RAs with second completion times.

• Technical justification is incorporated as a different stand-alone section of the LAR

• Affects 4 RAs that will allow an RICT to be applied to

• Six administrative variations

• Consistent approach proposed by Callaway Deletion of one-time historical change to BFN Unit 2 TS 3.5.1 6

Internal Events including Internal Flooding PRA

• Peer Reviewed Using NEI 05-04 Process Against Technical ASME/ANS RA-Sa-2009 with RG 1.200 Rev 2 Exceptions Acceptability

• Finding Closure Review Performed Using Appendix X Process

• No Open Internal Events/Internal Flooding Finding Level F&Os Fire

• Peer Reviewed Using NEI 07-12 Process Against ASME/ANS RA-Sa-2009 with RG 1.200 Rev 2 Exceptions

• Finding Closure Review Performed Using Appendix X Process

• No Open Fire PRA Finding Level F&Os 7

Seismic PRA

• Peer Reviewed Using NEI 12-13 Process Against Technical ASME/ANS RA-Sb-2013 (Code Case 1) with NRC Acceptability Conditions (ML18017A963)

(continued)

• Finding Closure Review Performed Using Appendix X Process

• No Open Seismic PRA Finding Level F&Os Other External Hazards

• All Other External Hazards Screened Out in accordance with ASME/ANS RA-Sa-2009

• Screening performed based on approved BFN 10 CFR 50.69 LAR (as updated for the as-built, as-operated plant) 8

RICT Program A Real-Time Risk Model similar to existing Real-Time Maintenance Rule a(4) Configuration Risk Model Management Program

• Incorporates Internal Events, Internal Flooding, Fire and Seismic into a One-Top Multi-Hazard Model

• Uses EPRI Phoenix Risk Analysis Software

• Incorporates RICT Calculation Based on CDF and LERF for Units 1, 2, and 3 with maximum 30-day backstop 9

Schedule

• Projected submittal in November 2021 with a requested approval within one year

• A 180-day implementation period is proposed 10

Summary

• TSTF-505 LAR is scheduled to be submitted in November 2021 with approval requested in one year

• LAR is consistent with TSTF-505 Model Application

• RICT process will follow NEI 06-09-A

• PRA is technically acceptable for the RICT Application 11

Questions/

Comments  ???

12