CNL-22-028, Response to Request for Additional Information Regarding License Amendment Request Regarding Criticality Safety Analysis of Spent Fuel Pool Storage of Atrium 11 Fuel (TS-534)
| ML22077A576 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/18/2022 |
| From: | Polickoski J Tennessee Valley Authority |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| CNL-22-028 | |
| Download: ML22077A576 (4) | |
Text
1101 Market Street, Chattanooga, Tennessee 37402 CNL-22-028 March 18, 2022 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Browns Ferry Nuclear Plant, Units 1, 2, and 3 Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 NRC Docket Nos. 50-259, 50-260, and 50-296
Subject:
Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3, License Amendment Request Regarding Criticality Safety Analysis of Spent Fuel Pool Storage of ATRIUM 11 Fuel (TS-534) (EPID L-2021-LLA-0097)
References:
- 1. TVA letter to NRC, CNL-21-050, Browns Ferry Nuclear Plant, Units 1, 2, and 3, License Amendment Request Regarding Criticality Safety Analysis of Spent Fuel Pool Storage of ATRIUM 11 Fuel (TS-534), dated May 29, 2021 (ML21150A022)
- 2. NRC Electronic Mail to TVA, Request for Additional Information Regarding TVAs Request to Expand the SFP Criticality Safety Analysis for Browns Ferry Nuclear Plant, Units 1, 2, and 3 (EPID L-2021-LLA-0097), dated February 16, 2022 (ML22047A161)
In Reference 1, Tennessee Valley Authority (TVA) submitted a request for an amendment to Renewed Facility Operating Licenses DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3. The proposed change expanded the applicability of the spent fuel pool criticality safety analysis of record for all three BFN units to include the ATRIUM 11'1 fuel design.
In Reference 2, the Nuclear Regulatory Commission (NRC) issued a request for additional information (RAI) and requested TVA respond by March 18, 2022. The enclosure to this letter provides the response to the RAI.
1 ATRIUM 11 is a trademark or registered trademarks of Framatome, Inc., its affiliates and/or its subsidiaries in the United States of America and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited.
Other names may be trademarks of their respective owners.
U.S. Nuclear Regulatory Commission CNL-22-028 Page 2 March 18, 2022 This letter does not change the no significant hazards considerations or the environmental considerations contained in Reference 1. Additionally, in accordance with Title 10 of the Code of Federal Regulations (10 CFR) 50.91(b)(1), TVA is sending a copy of this letter and enclosure to the Alabama Department of Public Health.
There are no new regulatory commitments contained in this letter. If you have any questions regarding this submittal, please contact Stuart L. Rymer, Senior Manager, Fleet Licensing, at slrymer@tva.gov.
I declare under penalty of perjury that the foregoing is true and correct. Executed on this 18th day of March 2022.
Respectfully, James T. Polickoski Director, Nuclear Regulatory Affairs
Enclosure:
Response to NRC Request for Additional Information cc: (Enclosure):
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant State Health Officer, Alabama Department of Public Health Digitally signed by Carla Edmondson Date: 2022.03.18 13:05:10
-04'00'
Enclosure CNL-22-028 E1 of 2 Response to NRC Request for Additional Information Introduction By letter to the U.S. Nuclear Regulatory Commission (NRC) dated May 29, 2021, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML21150A022), the Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) that proposed a revision to the criticality safety analysis for the spent fuel pools (SFPs) at Browns Ferry Nuclear Plant (Browns Ferry) Units 1, 2, and 3. The LAR proposes to expand the applicability of the spent fuel pool criticality safety analysis of record for all three Browns Ferry units to include the ATRIUM 11' fuel design. Attachments 1 and 2 to LAR contain the proprietary and non-proprietary Framatome, Inc. (Framatome) Report, ANP-3910P and NP, Revision 2, Browns Ferry Nuclear Plant Units 1, 2 and 3 Spent Fuel Storage Pool Criticality Safety Analysis for ATRIUM 11 Fuel, respectively.
Regulatory Requirements Title 10 of the Code of Federal Regulations (10 CFR), Section 50.68(b)(1) requires that, [p]lant procedures shall prohibit the handling and storage at any one time of more fuel assemblies than have been determined to be safely subcritical under the most adverse moderation conditions feasible by unborated water.
Paragraph 50.68(b)(4) of 10 CFR requires, in part, If no credit for soluble boron is taken, the k-effective of the spent fuel storage racks loaded with fuel of the maximum fuel assembly reactivity must not exceed 0.95, at a 95-percent probability, 95-percent confidence level, if flooded with unborated water.
The Browns Ferry criticality safety analysis in ANP-3910, Revision 2, does not take credit for soluble boron for normal operating conditions.
Request By letter dated September 21, 2015, (ADAMS Accession No. ML15282A152), TVA submitted a LAR for an extended power uprate (EPU) that would allow the Browns Ferry Units 1, 2, and 3 reactors to operate at 120 percent of the original licensed thermal power level. In Attachment 7 of the September 21, 2015, letter, TVA addressed the impact of EPU on the SFP nuclear criticality safety (NCS) analyses. During the acceptance review, the NRC staff determined that a review of the NCS analysis of record would be necessary. TVA provided AREVA Report ANP-3160, Revision 1, by letter dated December 15, 2015 (ADAMS Accession No. ML15351A097). AREVA Report ANP-3160, Revision 1, addressed the TVAs use of blended low enriched uranium (BLEU) fuel with the ATRIUM 10XM' fuel. However, the more recent Framatome Report, ANP-3910P, Revision 2, does not address TVAs use of BLEU fuel.
The use of BLEU fuel could impact TVAs calculation of its SFP k-effective at a 95-percent probability, 95-percent confidence level, if flooded with unborated water. Therefore, in order to complete its review of the current LAR, the NRC staff requests the following information:
Enclosure CNL-22-028 E2 of 2
RAI 1
State whether the Browns Ferry Units 1, 2, and 3, reactors currently use BLEU fuel, and if the use of BLEU fuel is planned with the proposed ATRIUM 11' fuel.
TVA Response The remaining inventory of BLEU fuel was used for the production of the reload batch for Unit 1 in the fall of 2018 (outage U1R12). Reloads of ATRIUM 10XM' fuel since that time have utilized commercial grade uranium. Each unit has some amount of legacy ATRIUM 10XM' fuel containing BLEU fuel that will be discharged prior to ATRIUM 11' introduction. TVA has no plans to utilize BLEU fuel in ATRIUM 11' fuel.
RAI 2
If TVA plans to continue to use BLEU fuel in the Browns Ferry Units 1, 2, and 3, reactors, describe how its use has been considered in the current criticality safety analysis, including whether the BLEU fuel would have the same power density during reactor operations as the limiting commercial grade uranium fuel evaluated in Framatome Report, ANP-3910P, Revision
- 2.
TVA Response As noted in the response to RAI 1, TVA has no plans to utilize BLEU fuel in future reloads, including ATRIUM 11'.