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#REDIRECT [[NL-16-023, Browns Ferry, Units 1, 2, and 3 - Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 4, Responses to Requests for Additional Information]]
| number = ML16049A248
| issue date = 02/16/2016
| title = Browns Ferry, Units 1, 2, and 3 - Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 4, Responses to Requests for Additional Information
| author name = Shea J W
| author affiliation = Tennessee Valley Authority
| addressee name =
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000259, 05000260, 05000296
| license number = DPR-033, DPR-052, DPR-068
| contact person =
| case reference number = CAC MF4581, CAC MF4582, CAC MF4853, CNL-16-023
| document report number = ANP-3465NP, Rev. 0
| package number = ML16049A247
| document type = Letter, Response to Request for Additional Information (RAI)
| page count = 53
| project = CAC:MF4581, CAC:MF4582, CAC:MF4853
| stage = Response to RAI
}}
 
=Text=
{{#Wiki_filter:U.S. Nuclear Regulatory Commission CNL-16-023 Page 2 February 16, 2016 Enclosure 1 provides the response to the NRC RAI SFP-RAI 1 from Reference
: 2. AREVA considers portions of the information provided in Enclosure 1 to this letter to be proprietary and , therefore, exempt from public disclosure pursuant to 10 CFR 2.390, Public inspections, exemptions, requests for withholding.
An affidavit for withholding information , executed by AREVA , is provided in Enclosure 6. A non-proprietary version of the RAI and response is provided in Enclosure
: 2. Therefore, on behalf of AREVA , TVA requests that Enclosure 1 be withheld from public disclosure in accordance with the associated AREVA affidavit and the provisions of 10 CFR 2.390. Enclosure 3 provides the response to the NRC RAI EEEB-RAI 1 from Reference 3. Enclosure 3 contains critical energy infrastructure information that is considered sensitive , unclassified (non-safeguard) information. As a result , TVA requests that Enclosure 3 be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390(d)(1
). Enclosure 4 provides a public version of the RAI and response with critical energy infrastructure information removed. Enclosure 5 provides the responses to the NRC RAls EEEB-RAI 2, EEEB-RAI 3, EEEB-RAI 4, and ESGB-RAI 1 from Reference
: 3. TVA has reviewed the informat i on supporting a finding of no significant hazards consideration and the environmental conside r ation provided to the NRC in the Reference 1 letter. The supplemental information provided in this submittal does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration.
In addition, the supplemental info r mation in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed license amendment.
Additionally, in accordance with 10 CFR 50.91 (b)(1 ), TVA is sending a copy of this letter , without the proprietary information and critical energy infrastructure information, to the Alabama State Department of Public Health. There are no new regulatory commitments associated with this submittal.
If there are any questions or if additional information is needed , please contact Mr. Edward D. Schrull at (423) 751-3850. I declare under penalty of perjury that the foregoing is true and correct. Executed on the 16th day of February 2016. President , Nuclear Licens i ng Enclosures cc: See Page 3 U.S. Nuclear Regulatory Commission CNL-16-023 Page 3 February 16, 2016
 
==Enclosures:==
 
cc: 1. Response to NRC Request for Additional Information SFP-RAI 1 (Proprietary version) 2. Response to NRC Request for Additional Information SFP-RAI 1 (Non-proprietary version) 3. Response to NRC Request for Additional Information EEEB-RAI 1 (Critical Energy Infrastructure Information)
: 4. Response to NRC Request for Additional Information EEEB-RAI 1-(without Critical Energy Infrastructure Information)
: 5. Responses to NRC Requests for Additional Information EEEB-RAI 2, EEEB-RAI 3, EEEB-RAI 4, and ESGB-RAI 1 6. AREVA Affidavit NRC Regional Administrator
-Region II NRC Senior Resident Inspector
-Browns Ferry Nuclear Plant State Health Officer, Alabama Department of Public Health (w/o Enclosures 1 and 3) 
 
ANP-3465NP Revision 0 Response to RAI for Browns Ferry Nuclear Plant EPU Submittal - SFSP Criticality Safety Analysis February 2016 AREVA Inc. (c) February 2016 AREVA Inc.
ANP-3465NP  Revision 0 Copyright © February 2016 AREVA Inc.
All Rights Reserved AREVA Inc.
Response to RAI's for Browns Ferry Nuclear Plant EPU Submittal - SFSP Criticality Safety Analysis ANP-3465NPRevision 0 Page i  Nature of Changes Item Section(s) or Page(s) Description and Justification 1  All Initial Issue
 
AREVA Inc.
Response to RAI's for Browns Ferr y Nuclear Plant EPU Submittal - SFSP Criticality Safety Analysis ANP-3465NPRevision 0 Page ii  Contents Nature of Changes .............................................................................................................
............ i Introduction ..................................................................................................................
.. 1-1 1.0 RAIs and Responses ..................................................................................................... 2-1
 
===2.0 Figure===
Figure 1.1  Overview of the Browns Ferry SFSP Criticality Safety Analysis .............................. 2-4
 
AREVA Inc.
Response to RAI's for Browns Ferry Nuclear Plant EPU Submittal - SFSP Criticality Safety Analysis ANP-3465NPRevision 0 Page iii  NOMENCLATURE Abbreviation Description BAF Bottom of Active Fuel BFN Browns Ferry Nuclear Plant CLTP Current Licensed Thermal Power (3458 MWt) CSA Criticality Safety Analysis EPU Extended Power Uprate  LAR License Amendment Request OLTP Original Licensed Thermal Power (3293 MWt) PAR Procured Analysis Review RCE Reload Core Evaluation REBOL Reactivity Equivalent Beginning Of Life (lattice design) SFSP Spent Fuel Storage Pool TAF Top of Active Fuel TS Technical Specifications TVA Tennessee Valley Authority UFSAR Updated Final Safety Analysis Report
 
AREVA Inc.
Response to RAI's for Browns Ferr y Nuclear Plant EPU Submittal - SFSP Criticality Safety Analysis ANP-3465NPRevision 0 Page 1-1  Introduction 1.0In Reference 1, the Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) to modify the operating license for the Browns Ferry Nuclear Plant (BFN) for an extended power uprate (EPU). The amendment, if approved, would allow for an increase in the licensed reactor thermal power from the current licensed thermal power (CLTP) of 3458 MWt to a new licensed thermal power of 3952 MWt, approximately 120% of the original licensed thermal power (OLTP) of 3293 MWt. During a November 10, 2015 U. S. Nuclear Regulatory Commission (NRC) public meeting with TVA, the NRC requested a copy of the current spent fuel storage pool (SFSP) criticality safety analysis (CSA) report for BFN to support review of the EPU LAR. The requested report was provided as Enclosure 1 of Reference 2. The NRC staff has determined that additional information is needed to complete their review of the EPU LAR (Reference 3). This document contains only the response to the Request for Additional Information (RAI) that contains AREVA content. The RAI response provided in this do cument is a combined response from AREVA and TVA. References 1. Letter, JW Shea (TVA) to USNRC, "Proposed Technical Specifications Change to TS-505 - Request for License Amendments - Extended Power Uprate", CNL-15-169, September 21, 2015. (Accession Number ML15282A152) 2. Letter, JW Shea (TVA) to USNRC, "Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 1, Spent Fuel Pool Criticality Safety Analysis Information", CNL-15-249, December 15, 2015. (Accession Number ML15351A097) 3. Letter, FE Saba (USNRC) to JW Shea (TVA), "Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Request for Additional Information Related to License Amendment Request Regarding Extended Power Uprate  (CAC Nos. MF4851, MF4582, and MF4853)",
January 28, 2016. (Accession Number ML16019A283) 4. ANP-3160(P) Revision 1, Browns Ferry Nuclear Plant Units 1, 2, and 3 Spent Fuel Storage Pool Criticality Safety Analysis for ATRIUMŽ 10XM Fuel , AREVA Inc., December 2015. (provided as Enclosure 1 of Supplement 1 to the EPU LAR dated December 15, 2015)
: 5. EMF-2158(P)(A) Revision 0, Siemens Power Corporation Methodology for Boiling Water Reactors: Evaluation and Validation of CASMO-4/MICROBURN-B2,  Siemens Power Corporation, October 1999.
 
AREVA Inc.
Response to RAI's for Browns Ferr y Nuclear Plant EPU Submittal - SFSP Criticality Safety Analysis ANP-3465NPRevision 0 Page 2-1  RAIs and Responses 2.0SFP-Request for Additional Information (RAI) 1 Section 50.36(c)(4) of Title 10 of the Code of Federal Regulations (10 CFR) states, in part,  that "Design features to be included [ in the technical specifications (TSs) ] are those features of the facility such as materials of construction and geometric arrangements, which, if altered or modified, would have a significant effect on safety." BFN TS 4.3.1.1(a) requires a keff (effective neutron multiplication factor (aka k-effective)) of equal or less than 0.95, consistent with 10 CFR 50.68. The NRC staff notes the calculated k eff found in the SFP nuclear criticality safety (NCS) analysis, in Section 2 of ANP-3160(NP), Revision 1 (attached as Enclosure 2 to the letter dated December 15, 2015), is determined, in part, from an upper limit on the reactivity of the fuel lattice used in the NCS analysis. In the NCS analysis, this limit is expressed as the maximum k (infinite lattice neutron multiplication factor (aka k-infinity)) calculated for fuel stored in the SFP rack geometry. The calculated keff is used to demonstrate compliance with the k eff TS requirement. Therefore, the maximum allowable reactivity of fuel that may be stored in the SFP is a key feature in ensuring that the SFP subcriticality safety requirement is met. Discuss what limits or controls the licensee is implementing to ensure that the reactivity of the fuel stored in the SFP does not exceed the bounds of the NCS analysis, ensuring that the regulatory requirement to maintain the TS value of k eff less than 0.95 continues to be met.
Response: The plant design feature important to safety in regard to storage of fuel in the BFN spent fuel storage pool (SFSP) is the rack design. This is captured in Technical Specification (TS) 4.3.1.1(b) which is based upon the high density rack design as described in Updated Final Safety Analysis Report (UFSAR) section 10.3.4. As indicated in the question above, the BFN TS 4.3.1.1(a) requirement of maintaining a k eff of    0.95 is met by setting a reactivity limit on fuel that is to be stored in the SFSP. ANP-3160(P) (Reference 4) provides a CSA for the ATRIUMŽ 1 10XM fuel design that directly addresses meeting this BFN licensing requirement. The approach taken is summarized in Figure 1.1 below, which is based upon Figure 2.1 of the Reference 4 report. Fuel being stored within the BFN SFSP must remain within the basis of the CSA. This is met if the enriched lattices meet the requirements of Table 2.1 of ANP-3160(P). AREVA performs the required checks to ensure that new ATRIUM 10XM fuel bundle designs remain bounded by the CSA as part of the bundle design process for BFN. Table 2.1 of
 
ANP-3160(P) provides two alternate sets of validation criteria for the enriched lattices:
* Enrichment and Gadolinia loading requirements, or
* Direct Reactivity Comparison (with enrichment < 5.0 wt % U-235). Meeting either of the above sets of validation criteria ensures that the fuel remains bounded by the CSA.
1  ATRIUM is a trademark of AREVA Inc.
AREVA Inc.
Response to RAI's for Browns Ferry Nuclear Plant EPU Submittal - SFSP Criticality Safety Analysis ANP-3465NPRevision 0 Page 2-2 The enrichment and gadolinia (Gd) loading criteria provided in Table 2.1 of ANP-3160(P) are reproduced below.
Above [  ]
* Maximum Lattice Average Enrichment, wt% U-235 4.70 Minimum Number of Rods containing Gd 2 O 3 8+ Minimum wt% Gd 2 O 3 in these Gd Rod 3.5  At and below [  ]
* Maximum Lattice Average Enrichment, wt% U-235 4.70 Minimum Number of Rods containing Gd 2 O 3 8+ Minimum wt% Gd 2 O 3 in these Gd Rod 3.919
* The separate axial zones are based upon the height of the fuel in the part length fuel rod and represent the change between top and bottom lattice geometries. +  These eight gadolinia rods cannot be loaded on the perimeter of the lattice or adjacent to the water channel. An equivalent 1 of two gadolinia rods must be loaded along each side. Gadolinia is not required in natural Uranium blankets and there are no restrictions on the number, concentration, or placement of any additional gadolinia rods. If each of the enriched lattices within a new ATRIUM 10XM bundle design meets the above criteria, the fuel remains bounded by the CSA and the fuel may be safely stored within the BFN SFSP. An alternate set of validation criteria is also provided in Table 2.1 of ANP-3160(P) that allows for the direct comparison of in-rack lattice k, as follows: Zone* Lattice Geometry Distance from BAF Max. in-rack k 2 10XMLCT [  ] [  ] to TAF 0.8825 1 10XMLCB [  ] 0" to [  ] 0.8825
* The separate axial zones are based upon the height of the fuel in the part length fuel rod and represent the change between top and bottom lattice geometries.
 
1  Two face adjacent gadolinia rods count as a single rod.
AREVA Inc.
Response to RAI's for Browns Ferry Nuclear Plant EPU Submittal - SFSP Criticality Safety Analysis ANP-3465NPRevision 0 Page 2-3 The in-rack k criteria in the previous table are based upon an explicit CASMO4 calculation subject to the modeling and restrictions provided in Appendix A of the ANP-3160(P) report. These calculations are performed with the NRC approved CASMO4 code described in EMF-2158(P)(A) (Reference 5). The in-rack modeling is performed consistent with the models used in the CSA, with sample inputs provided in Tables A.1 and A.2 of ANP-3160(P). AREVA provides certification to TVA that the new fuel meets the ANP-3160(P) validation criteria in two separate reports that are part of the deliverables for each cycle. Nuclear Fuel Design Report: An example is provided in section 2.4 of ANP-3343(P) provided as Attachment 22 of the EPU LAR submittal dated September 21, 2015 (ML15282A152).
 
Reload Safety Analysis Report: An example is provided in section 7.4 of ANP-3404(P) provided as Enclosure 3 of Supplement 2 to the EPU LAR dated December 15, 2015 (ML15351A113). Additionally, as part of the TVA process, an owner acceptance review is performed for any technical product received from a vendor. This review, termed a Procured Analysis Review (PAR), is required by TVA procedures. One of the requirements for a PAR is for the reviewer to document that all regulatory and design requirements pertinent to the procured technical product have been met. The PAR associated with acceptance of the final core design document includes a confirmation that the new reload fuel complies with the requirements of the criticality analysis. AREVA design documentation is utilized by TVA as part of completing that review. The TVA compliance review is similar to the AREVA compliance check, in that it confirms that the new fuel designs for the reload meet the enrichment and gadolinia loading criteria (or the alternate criteria if required) that are provided in Table 2.1 of ANP-3160(P). In addition, the TVA procedures require the preparation of an overall Reload Core Evaluation (RCE) document, the purpose of which is to document that the reload design is safe and effective and meets all design and licensing criteria. The governing procedure specifically lists SFSP criticality analysis as one of the mandatory elements to be addressed in the RCE. The TVA processes for reload review and acceptance specifically address confirmation that new fuel designs being delivered for each reload are in compliance with the assumptions of the criticality analysis of record. 
 
AREVA Inc.
Response to RAI's for Browns Ferry Nuclear Plant EPU Submittal - SFSP Criticality Safety Analysis ANP-3465NPRevision 0 Page 2-4  [    ]  Figure 1.1  Overview of the Browns Ferry SFSP Criticality Safety Analysis 
 
E4 1
 
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E5 9LoadIDDescriptionMinimumRequiredVoltage(Volts)%StartingVoltage480VBase)@DegradedVoltageReset(3983V)MOVTerminalVoltage(Volts)LoadJustification191 1E1 FCV 75 5041485.70411Evaluatedat405V281 8C2 FCV 74 4841483.82398Evaluatedat391V282 3E2 FCV 68 7941483.20399Evaluatedat378V381 12E3 FCV 74 5841485.71411Evaluatedat411V
 
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E5 22 E5 23 E5 24 E5 25 E5 26 E5 27 E5 28
 
STATE OF WASHINGTON COUNTY OF BENTON SS. AFFIDAVIT
: 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-3465P, Revision 0, "Response to RAI for Browns Ferry Nuclear Plant EPU Submittal
-SFSP Criticality Safety Analysis," dated February 2016 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 e::jAL
,2016.}}

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