ML062210458

License Amendment 261 Limits on Main Steam Isolation Valve Leakage

ML062210458
Person / Time
Site:	Browns Ferry
Issue date:	09/27/2006
From:	Chernoff M H NRC/NRR/ADRO/DORL/LPLII-2
To:	Singer K W Tennessee Valley Authority
Chernoff M H, NRR/DORL, 415-4041
Shared Package
ML062210461	List: ML062210458 ML062710014
References
TAC MC3813
Download: ML062210458 (11)

Text

September 27, 2006Mr. Karl W. SingerChief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNIT 1 - ISSUANCE OF AMENDMENTREGARDING LIMITS ON MAIN STEAM ISOLATION VALVE LEAKAGE (TAC NO. MC3813)

Dear Mr. Singer:

The Commission has issued the enclosed Amendment No. 261 to Renewed Facility OperatingLicense No. DPR-33 for the Browns Ferry Nuclear Plant (BFN), Unit 1. This amendment is in response to your application dated July 9, 2004 (letter TVA-BFN-TS-436).The amendment revises BFN Unit 1 Technical Specifications Surveillance Requirement3.6.1.3.10 to increase the allowed main steam isolation valve (MSIV) leak rate limit from 11.5 standard cubic feet per hour (scfh) per valve, to 100 scfh for each individual MSIV with a combined leak rate of 150 scfh for all four main steam lines.A copy of the Safety Evaluation is also enclosed. Notice of Issuance will be included in theCommission's biweekly Federal Register notice.Sincerely,/RA/Margaret H. Chernoff, Project ManagerPlant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-259

Enclosures:

1. Amendment No. 261 to DPR-332. Safety Evaluationcc w/enclosures: See next page September 27, 2006Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

BROWNS FERRY NUCLEAR PLANT, UNIT 1 - ISSUANCE OF AMENDMENTREGARDING LIMITS ON MAIN STEAM ISOLATION VALVE LEAKAGE (TAC NO. MC3813)

Dear Mr. Singer:

The Commission has issued the enclosed Amendment No. 261 to Renewed Facility OperatingLicense No. DPR-33 for the Browns Ferry Nuclear Plant (BFN), Unit 1. This amendment is in response to your application dated July 9, 2004 (letter TVA-BFN-TS-436).The amendment revises BFN Unit 1 Technical Specifications Surveillance Requirement3.6.1.3.10 to increase the allowed main steam isolation valve (MSIV) leak rate limit from 11.5 standard cubic feet per hour (scfh) per valve, to 100 scfh for each individual MSIV with a combined leak rate of 150 scfh for all four main steam lines.A copy of the Safety Evaluation is also enclosed. Notice of Issuance will be included in theCommission's biweekly Federal Register notice.Sincerely,/RA/Margaret H. Chernoff, Project ManagerPlant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-259

Enclosures:

1. Amendment No. 261 to DPR-33 2. Safety Evaluationcc w/enclosures: See next pageDISTRIBUTION:PUBLICGHill, OIS (2 hard copies)JMaLPL2-2 R/FRidsRgn2MailCenter (MWidmann, LMellen)RGoelRidsNrrLACGoldsteinRidsOgcRPRidsAcrsAcnwMailCenterRidsNrrDeEgcbRidsNrrDorlLpl2-2 (LRaghavan)RidsNrrDssScvbDDuvigneaudRidsNrrDorlDprRidsNrrPMMChernoffRidsNrrDirsItsbRidsNrrPMEBrownRidsNrrLABClayton (Hard Copy)RidsNrrPMFLyonRidsNrrDssSbpb Package:ML062210461Tech Spec: ML062710014 ADAMS Accession No.: ML062210458**Memo dated 5/11/05 NRR-058OFFICELPL2-2/PELPL2-2/PMLPL2-2/LASCVB/BCEGCB/BCITSB/BCSBPB/BCOGCLPL2-2/BCNAMEFLyon forDDuvigneaudMChernoffBClayton forCGoldsteinRDenning**RKarasTKobetzJSegalaDRothLRaghavanDATE8/23/068/23/068/23/065/11/058/30/069/1/068/31/069/22/069/26/06Official Record Copy TENNESSEE VALLEY AUTHORITYDOCKET NO. 50-259BROWNS FERRY NUCLEAR PLANT UNIT 1AMENDMENT TO RENEWED FACILITY OPERATING LICENSEAmendment No. 261 Renewed License No. DPR-331.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment by Tennessee Valley Authority (the licensee)dated July 9, 2004, complies with the standards and requirements of the AtomicEnergy 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 theAct, and the rules and regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with theCommission's regulations;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied. 2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-33 is hereby amended to read as follows:(2)Technical SpecificationsThe Technical Specifications contained in Appendices A and B, as revised throughAmendment No. 261, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.3.This license amendment is effective as of its date of issuance and shall be implementedwithin 60 days from the date of issuance. FOR THE NUCLEAR REGULATORY COMMISSION/RA/

L. Raghavan, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical SpecificationsDate of Issuance: September 27, 2006 ATTACHMENT TO LICENSE AMENDMENT NO. 261TO RENEWED FACILITY OPERATING LICENSE NO. DPR-33DOCKET NO. 50-259Replace Page 3 of Renewed Operating License DPR-33 with the attached Page 3.Revise the Appendix A Technical Specifications by removing the page identified below andinserting the attached page. The revised page is identified by the captioned amendment number and contains a marginal line indicating the area of change. REMOVE INSERT3.6-16 3.6-16 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 261TO RENEWED FACILITY OPERATING LICENSE NO. DPR-33TENNESSEE VALLEY AUTHORITYBROWNS FERRY NUCLEAR PLANT, UNIT 1DOCKET NO. 50-25

91.0 INTRODUCTION

By letter dated July 9, 2004 (Agencywide Documents Access and Management System(ADAMS) Accession No. ML041980222), the Tennessee Valley Authority (TVA, the licensee) submitted to the Nuclear Regulatory Commission (NRC) a request for changes to the BrownsFerry Nuclear Plant (BFN), Unit 1, Technical Specifications (TSs). The proposed changes increase the allowable leakage limit for any one of the four main steam line (MSL) penetrations from 11.5 standard cubic feet per hour (scfh) to 100 scfh, and establish a 150-scfh limit on the maximum allowable combined leakage of all four MSL penetrations.Specifically, TS Surveillance Requirement (SR) 3.6.1.3.10 currently states:Verify leakage rate through each MSIV is 11.5 scfh when tested at 25 psig.The licensee proposes to revise TS SR 3.6.1.3.10 to state:Verify leakage rate through each MSIV is 100 scfh and that the combined leakagerate for all four main steam lines is 150 scfh when tested at 25 psig.The licensee's application also included a request for exemption from Title 10, Code of FederalRegulations (10 CFR), Part 50, Appendix J. The proposed exemption would allow the licenseeto exclude leakage from MSL penetrations from consideration in meeting the requirement thatthe total leakage of Type B and Type C containment penetrations shall not exceed 60 percent of the maximum allowable containment leakage (i.e., 0.6 La). MSL penetrations are Type C containment penetrations. The request for exemption is being reviewed by the NRC staffconcurrently as a separate licensing action.The NRC staff previously approved similar changes to the MSIV leakage rate limits for BFNUnits 2 and 3 by Amendment Nos. 263 and 223, respectively, dated March 14, 2000 (ADAMS Accession No. ML003693000). The radiological consequences of the increased MSIV leakage rate limits and the acceptability of the alternate leakage treatment (ALT) system for BFN Unit 1were previously reviewed and approved by the NRC staff, as documented in the safety evaluation for BFN Unit 1 Amendment No. 251 (Full-Scope Implementation of AlternativeSource Term), dated September 27, 2004 (ADAMS Accession No. ML042730028). 2.0EVALUATION2.1BackgroundThe main steam system transports steam from the reactor vessel to the main turbines andother steam driven auxiliary equipment. Each of the four MSLs contains two quick closing mainsteam isolation valves (MSIVs) located in the containment penetration piping. One MSIV ineach line is located inside the containment, and the other is located outside. These valvesserve to rapidly isolate the primary containment MSL penetrations in the event of an MSL breakaccident or loss-of-coolant accident. At some boiling-water reactor (BWR) facilities, the MSLsare provided with a leakage control system (LCS) to collect and process MSIV leakage;however, BFN-1 does not have an MSIV LCS. MSIVs, due to their size and service conditions, have a history of leakage in excess of theirdesign criteria. On July 16, 1982, the NRC staff iss ued NRC Information Notice 82-23, "MainSteam Isolation Valve Leakage," which discussed the high frequency at which MSIVs were failing to meet TS leak test criteria. Because of these recurring problems with excessive leakage of MSIVs, the NRC established Generic Issue C-8, "Main Steam Line Valve LeakageControl Systems." The same year, the BWR Owners' Group (BWROG) formed an MSIV Leakage Committee to address the MSIV leakage issue. In 1986, Generic Letter 86-17, "Technical Findings Related to Generic Issue C-8; Boiling Water Reactor Main Steam IsolationValve Leakage and Leakage Treatment Methods," was issued, and a follow-on MSIV Leakage Closure Committee was formed to further the effort. Based on the committee

<s work, theBWROG developed an approach for resolution of Generic Issue C-8 that proposed to remove the safety related leakage control systems on those facilities having them, and increase MSIVallowable leakage limits. The BWROG described the proposal in "BWROG Report for Increasing MSIV Leakage Rate Limits and Elimination of Leakage Control Systems,"

NEDC-31858P, Revision 1, dated October 1991. The purpose of NEDC-31858P was to define a means by which BWR licensees coulddemonstrate to regulators that alternate leakage treatment (ALT) leakage pathways using mainsteam system piping and the main condenser are capable of performing a post-accident dosemitigation function for MSIV leakage, under safe-shutdown earthquake conditions. This would provide a basis to (1) eliminate MSIV Leakage Control Systems at those facilities having themand (2) increase allowable MSIV leakage rates. The NRC staff reviewed NEDC-31858P,Revision 2, and issued its safety evaluation on March 3, 1999 (ADAMS Accession No. ML010640286), approving the report for reference in future individual plant applications.

The safety evaluation concluded that licensees demonstrating certain plant-specific attributes are eligible for amendments increasing the allowable MSIV leakage rate up to 200 scfh.

Licensees would have to demonstrate that the main steam piping from the outermost isolationvalve up to the turbine stop valve, the bypass/drain piping to the main condenser, and the main condenser, will retain structural integrity during and following a safe-shutdown earthquake(SSE). NEDC-31858P was reissued by the BWROG as NEDC-31858P-A (ADAMS Accession No. ML993440254), dated November 22, 1999. 2.2Technical Evaluation2.2.1Review of the ALT PathwayThe NRC staff previously reviewed (1) the functional design of the ALT path and capability toestablish the ALT path under post-accident conditions, and (2) structural/seismic issues related to integrity of the ALT path. Details of the NRC staff's review are documented in the safety evaluation for BFN Unit 1 Amendment No. 251, dated September 27, 2004 (ADAMS AccessionNo. ML042730028). The NRC staff's conclusion was that there is reasonable assurance thatthe BFN Unit 1 MSIV ALT system is seismically adequate for the intended purpose. The NRCstaff's conclusion was based on the fact that (1) the ALT pathway has been walked-down in accordance with the procedures in NEDC-31858P-A, which was approved by the NRC staff,(2) all the outliers have been either analytically resolved or physically modified, (3) the condenser was seismically analyzed subject to a design-basis earthquake (DBE) for its adequacy and its anchorages were evaluated to be adequate in accordance with information contained in NEDC-31858P-A, and (4) the turbine building is deemed, through the use of approximate calculations to be followed by performance of dynamic seismic analysis prior to the plant restart, to remain intact following a DBE. In approving Amendment No. 251, the NRC staff added license condition 2.C(15):The licensee is required to confirm that the conclusions made in TVA's letter datedSeptember 17, 2004 [ADAMS Accession No. ML042730342], for the turbine building remain acceptable using seismic demand accelerations based on dynamic seismic analysis prior to the restart of Unit 1.In approving this amendment, the NRC staff notes that the licensee must satisfy licensecondition 2.C(15). The basis used by the NRC staff in approving Amendment No. 251 has notchanged; therefore, the staff concludes that the ALT system continues to be adequate toperform its safety function.

2.2.2Radiological ConsequencesThe NRC staff previously reviewed the radiological consequences for increased MSIV leakagevia the ALT path. Details of the staff's review were documented in the safety evaluation forBFN Unit 1 Amendment No. 251. The NRC staff's radiological review encompassed (1) therelease pathways, (2) meteorology, and (3) control room habitability, and focused on thechanges from previous NRC-accepted analyses. The NRC staff reviewed the technicalanalyses related to the radiological consequences of DBAs that were performed by TVA in support of Amendment No. 251, which was based on the increased MSIV leakage limits. With regard to BFN, Unit 1, the inputs used in the main steam line break accident, fuel handling accident, and control rod drop accident were bounding for Units 1, 2, and 3. The inputs used in the loss-of-coolant accident were different for Unit 1 and Units 2 and 3; a separate analysis wasperformed and the bounding results for Units 1, 2, and 3 were provided. Based on its review of information provided by the licensee, the NRC staff concluded that the offsite doseconsequences of DBAs are within the acceptance criteria of 10 CFR Part 100, and the control room dose consequences are within the acceptance criteria of 10 CFR Part 50, Appendix A, General Design Criterion 19. The basis used by the NRC staff in approving AmendmentNo. 251 has not changed; therefore, the staff concludes that the offsite dose consequences ofDBAs continue to be within the acceptance criteria of 10 CFR Part 100, and the control room dose consequences are within the acceptance criteria of 10 CFR Part 50, Appendix A, GeneralDesign Criterion 19. 2.2.3TS Bases Changes The licensee proposed associated changes to the TS Bases. Since the proposed changesummarized a required action from the TSs, the NRC staff recommended that the licenseeconsider revising the proposed change to the TS Bases to more closely conform to NUREG-1433, "Standard TSs, General Electric, BWR/4," Volume 2, "Bases." The issue wasdiscussed in a telephone call on August 21, 2006, between F. Lyon (NRC) and J. McCarthy(TVA). The licensee will consider the issue when the change is processed under its TS BasesControl Program.2.2.4Conclusion Based on the information provided by TVA related to increasing the allowable MSIV leakagerate at BFN Unit 1 to 100 scfh per valve, provided the combined leakage from all four MSLs is not greater than 150 scfh, the NRC staff finds reasonable assurance that the ALT will performits safety function and that radiological consequences of DBAs at BFN, Unit 1 will be within thedose guidelines of 10 CFR Part 100 and the criteria of 10 CFR Part 50, Appendix A, General Design Criterion 19. Therefore, the proposed changes to the MSIV leakage limits are acceptable.2.3Summary of CommitmentsIn its July 9, 2004, application, the licensee made the following commitments:1. Prior to Unit 1 restart, plant operating procedures will be revised to provideprocedural requirements for the establishment of the ALT path to the condenser.2. The Unit 1 outliers [e.g., conditions that did not conform with the seismic walkdownscreening guidelines or were judged by the licensee to require further review] will beresolved prior to Unit 1 restart. This includes qualification of 1-PCV-1-147 and the addition of in-line check valves (1-CKV-1-742 and 1-CKV-1-744) for the offgas preheaters.

3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the NRC staff attempted to contact theAlabama State official concerning the proposed issuance of the amendment. There was no official response.

4.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a surveillance requirement. The NRC staff has determi ned that theamendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase inindividual or cumulative occupational radiation exposure. 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 (71 FR 29680). Accordingly, theamendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmentalassessment need be prepared in connection with the issuance of the amendment.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) thereis operation in the proposed manner, (2) such activities will be conducted in compliance with thereasonable assurance that the health and safety of the public will not be endangered by Commission's regulations, and (3) the issuance of the amendment will not be inimical to thecommon defense and security or to the health and safety of the public.Principal Contributors: J. Ma R. GoelDate: September 27, 2006 Mr. Karl W. SingerBROWNS FERRY NUCLEAR PLANTTennessee Valley Authority

cc:

Mr. Ashok S. Bhatnagar, Senior Vice President Nuclear Operations Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Larry S. Bryant, Vice PresidentNuclear Engineering & Technical Services Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801Brian O'Grady, Site Vice PresidentBrowns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609Mr. Robert J. Beecken, Vice PresidentNuclear Support Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 General CounselTennessee Valley Authority ET 11A 400 West Summit Hill DriveKnoxville, TN 37902Mr. John C. Fornicola, ManagerNuclear Assurance and Licensing Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801Mr. Bruce Aukland, Plant ManagerBrowns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609Mr. Masoud Bajestani, Vice PresidentBrowns Ferry Unit 1 Restart Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609Mr. Robert G. Jones, General ManagerBrowns Ferry Site Operations Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609Mr. Larry S. MellenBrowns Ferry Unit 1 Project Engineer Division of Reactor Projects, Branch 6 U.S. Nuclear Regulatory Commission 61 Forsyth Street, SW.

Suite 23T85 Atlanta, GA 30303-8931 Mr. Glenn W. Morris, Manager Corporate Nuclear Licensing and Industry Affairs Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801Mr. William D. Crouch, M anagerLicensing and Industry Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609Senior Resident InspectorU.S. Nuclear Regulatory Commission Browns Ferry Nuclear Plant 10833 Shaw Road Athens, AL 35611-6970State Health OfficerAlabama Dept. of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, AL 36130-3017ChairmanLimestone County Commission 310 West Washington Street Athens, AL 35611