View source for CNL-15-247, Brown Ferry Unit 1, Submittal of Response to NRC Request for Additional Information Re Application to Modify Technical Specification 2.1.1.2, Reactor Core Minimum Critical Power Ratio Safety Limits (TS-506). Enclosure 2 ANP-3458NP Enclose

{{Adams
| number = ML15363A426
| issue date = 12/28/2015
| title = Brown Ferry Unit 1, Submittal of Response to NRC Request for Additional Information Re Application to Modify Technical Specification 2.1.1.2, Reactor Core Minimum Critical Power Ratio Safety Limits (TS-506). Enclosure 2 ANP-3458NP Enclosed
| author name = Shea J
| author affiliation = Tennessee Valley Authority
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000259
| license number = DPR-033
| contact person = 
| case reference number = CAC MF6760, CNL-15-247
| document report number = ANP-3458NP, Rev. 0
| package number = ML15363A425
| document type = Legal-Affidavit, Letter type:CNL, Response to Request for Additional Information (RAI), Topical Report
| page count = 17
| project = CAC:MF6760
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Proprietary Information Withhold Under 10 CFR 2.390(a)(4)
This letter is decontrolled when separated from Enclosure 1 Tennessee Valley Authority, 1101 Market Street, Chattanooga , Tennessee 37402 CNL-15-247 December 28, 2015 10 CFR 50.90 ATTN : Document Control Desk U.S. Nuclear Regulatory Commission Washington , D.C. 20555-0001 Browns Ferry Nuclear Plant, Unit 1 Renewed Facility Operating License No. DPR-33 NRC Docket No. 50-259

==Subject:==
Response to NRC Request for Additional Information Browns Ferry Nuclear Plant (BFN), Unit 1 - Application to Modify Technical Specification 2.1.1.2, Reactor Core Minimum Critical Power Ratio Safety Limits (TS-506) (CAC No. MF6760)

==References:==
: 1. Letter from TVA to NRC , CNL-15-056, "Browns Ferry Nuclear Plant (BFN) , Unit 1 - Application to Modify Technical Specification 2.1.1.2, Reactor Core Minimum Critical Power Ratio Safety Limits (TS-506) ,"
dated September 25, 2015 (ML15268A566)
: 2. Letter from NRC to TVA, "Browns Ferry Nuclear Plant, Unit 1 - Request for Additional Information Regarding License Amendment Request For Safety Limit Minimum Critical Power Ratio (CAC No. MF6760) ," dated December 3, 2015 (ML15336A726)
By letter dated September 25, 2015 (Reference 1), Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) for Browns Ferry Nuclear Plant (BFN),
Unit 1, to modify the Technical Specification (TS) 2.1.1.2 value of the safety limit minimum critical power ratio (SLMCPR) for two-loop operation to 1.06 and the SLMCPR for single loop operation to 1.08.
By letter dated December 3, 2015 (Reference 2) , the Nuclear Regulatory Commission transmitted a request for additional information (RAI) . The due date for the response is December 31 , 2015. Enclosure 1 contains AREVA report ANP-3458P , Revision 0, that provides the responses to the Reference 2 RAI . Enclosure 1 contains information that AREVA NP considers to be proprietary in nature and subsequently , pursuant to 10 Code of Federal Regulations 2.390, "Public inspections, exemptions, requests for withholding ," paragraph (a)(4), it is requested that such information be withheld from public disclosure. Enclosure 2 contains the non-proprietary version of the Enclosure 1 report with the proprietary material removed , and is suitable for public disclosure. Enclosure 3 provides the affidavit supporting this request.

U.S. Nuclear Regulatory Commission CNL-15-247 Page 2 December 28, 2015 There are no new regulatory commitments contained in this submittal. Please address any questions regarding this submittal to Mr. Edward D. Schrull at (423) 751-3850.
I declare under penalty of perjury that the foregoing is true and correct. Executed on this 28th day of December 2015.
Respectfully, 1.~:
Vice President, Nuclear Licensing

==Enclosures:==
: 1. ANP-3458P Revision 0, "AREVA RAI Responses for Browns Ferry Unit 1 Cycle 12 MCPR Safety Limits" (Proprietary)
: 2. ANP-3458NP Revision 0, "AREVA RAI Responses for Browns Ferry Unit 1 Cycle 12 MCPR Safety Limits" (Non-proprietary)
: 3. Affidavit for ANP-3458P Revision 0 (Enclosure 1) cc (Enclosures):
NRC Regional Administrator- Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant NRC Project Manager - Browns Ferry Nuclear Plant NRC Branch Chief - Region II State Health Officer, Alabama State Department of Health

Proprietary Information Withhold Under 10 CFR 2.390(a)(4)
ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT UNIT 1 ANP-3458P Revision 0, AREVA RAI Responses for Browns Ferry Unit 1 Cycle 12 MCPR Safety Limits (Proprietary)

ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT UNIT 1 ANP-3458NP Revision 0, AREVA RAI Responses for Browns Ferry Unit 1 Cycle 12 MCPR Safety Limits (Non-proprietary)

AREVA RAI Responses for          ANP-3458NP Revision 0 Browns Ferry Unit 1 Cycle 12 MCPR Safety Limits December 2015
               &#xa9; 2015 AREVA Inc.

ANP-3458NP Revision 0 Copyright &#xa9; 2015 AREVA Inc.
All Rights Reserved

AREVA Inc.
ANP-3458NP AREVA RAI Responses for                                      Revision 0 Browns Ferry Unit 1 Cycle 12 MCPR Safety Limits                                              Page i Nature of Changes Section(s)
Item           or Page(s)    Description and Justification 1              All           Initial Issue

AREVA Inc.
ANP-3458NP AREVA RAI Responses for                                                                                     Revision 0 Browns Ferry Unit 1 Cycle 12 MCPR Safety Limits                                                                                               Page ii Contents Page

==1.0    INTRODUCTION==
 ............................................................................................... 1-1 2.0    NRC QUESTIONS AND AREVA RESPONSE .................................................. 2-1

==3.0    REFERENCES==
 .................................................................................................. 3-1

AREVA Inc.
ANP-3458NP AREVA RAI Responses for                                                Revision 0 Browns Ferry Unit 1 Cycle 12 MCPR Safety Limits                                                        Page iii Nomenclature Acronym                    Definition BFN                        Browns Ferry Nuclear Plant LAR                        Licensing Amendment Request MCPR                       Minimum Critical Power Ratio NRC                        Nuclear Regulatory Commission RAI                        Request for Additional Information SLMCPR                     Safety Limit Minimum Critical Power Ratio TS                         Technical Specification TVA                        Tennessee Valley Authority

AREVA Inc.
ANP-3458NP AREVA RAI Responses for                                                          Revision 0 Browns Ferry Unit 1 Cycle 12 MCPR Safety Limits                                                                Page 1-1

==1.0       INTRODUCTION==

Tennessee Valley Authority (TVA) submitted a License Amendment Request (LAR) to support a change of approved SLMCPR methodology and Technical Specification (TS)
SLMCPR value in the Browns Ferry (BFN) Unit 1 Technical Specifications. In response to the LAR, the US Nuclear Regulatory Commission (NRC) has issued an initial set of questions, in the form of Request for Additional Information (RAI), Reference 1.
Based on the information provided in this report, TVA will prepare a formal response to the NRC RAIs.

AREVA Inc.
ANP-3458NP AREVA RAI Responses for                                                             Revision 0 Browns Ferry Unit 1 Cycle 12 MCPR Safety Limits                                                                    Page 2-1 2.0       NRC QUESTIONS AND AREVA RESPONSE The NRC questions (i.e., RAIs) listed below are according to Reference 1:
RAI-01: In the critical power ratio correlations referenced in the submittal (ANP-10298P-A, Rev. 0 ACE/ATRIUM 10XM Critical Power Correlation and EMF-2209(P)(A) Rev. 3 SPCB Critical Power Correlation), there is a Safety Evaluation restriction for local peaking factors. Confirm that no rods in the Unit 1 Cycle 12 core are expected to exceed the local peaking factor limit for the range of applicability of the critical power correlations given in Table 2-1 of ANP-10298P. Describe how high-peaking rods are identified.
AREVA Response:
The SPCB and ACE/ATRIUM 10XM critical power correlation limit of applicability for local peaking factor is [      ], provided as an SER restriction when the correlations were approved by the NRC. Fuel expected to be resident in Unit 1 Cycle 12 has been designed to be below this limit. The maximum local peaking factor for the fresh ATRIUM 10XM lattice is [           ].
During each Monte Carlo trial of the SLMCPR calculation, [
                         ]
The base additive constant uncertainty and the high pin power additive constant uncertainty values are presented in Table 3-2 of the SAFLIM3D topical report

AREVA Inc.
ANP-3458NP AREVA RAI Responses for                                                 Revision 0 Browns Ferry Unit 1 Cycle 12 MCPR Safety Limits                                                       Page 2-2 (ANP-10307PA Revision 0 AREVA MCPR Safety Limit Methodology for Boiling Water Reactors, dated June 2011).

AREVA Inc.
ANP-3458NP AREVA RAI Responses for                                                      Revision 0 Browns Ferry Unit 1 Cycle 12 MCPR Safety Limits                                                            Page 3-1

==3.0       REFERENCES==
: 1. Letter, F. E. Saba (NRC) to J. W. Shea (TVA), Browns Ferry Nuclear Plant, Unit 1 - Request For Additional Information Regarding License Amendment Request for Safety Limit Minimum Critical Power Ratio(CAC No. MF6760),
USNRC, December 3, 2015. (38-9250372-000)

ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT UNIT 1 Affidavit for ANP-3458P Revision 0 (Enclosure 1)

AFFIDAVIT STATE OF WASHINGTON SS.
COUNTY OF BENTON
: 1.      My name is Alan B. Meginnis. I am Manager, Product Licensing, for AREVA Inc. and as such I am authorized to execute this Affidavit.
: 2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
: 3. I am familiar with the AREVA information contained in the report ANP-3458P, Revision 0, "AREVA RAI Responses for Browns Ferry Unit 1 Cycle 12 MCPR Safety Limits," dated December 2015 and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA for the control and protection of proprietary and confidential information.
: 4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.
: 5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is

requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."
: 6.       The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:
(a)      The information reveals details of AREVA's research and development plans and programs or their results.
(b)      Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.
(c)      The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA (d)      The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.
(e)      The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA The information in the Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(d) and 6(e) above.
: 7.       In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document have been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
: 8.       AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
: 9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.
SUBSCRIBED before me this - - - -
day of 0 ~sf, 2015.
Susan K. McCoy NOTARY PUBLIC, STATE OF WASHINGTON MY COMMISSION EXPIRES: 1/14/2016}}