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| #REDIRECT [[CNL-16-035, Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 5, Response to Request for Additional Information]] | | {{Adams |
| | | number = ML16069A142 |
| | | issue date = 03/08/2016 |
| | | title = Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 5, Response to Request 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 MF4582, CAC MF4851, CAC MF4853, CNL-16-035 |
| | | document type = Letter, Response to Request for Additional Information (RAI) |
| | | page count = 5 |
| | | project = CAC:MF4582, CAC:MF4851, CAC:MF4853 |
| | | stage = Response to RAI |
| | }} |
| | |
| | =Text= |
| | {{#Wiki_filter:Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 |
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| | CNL-16-035 March 8, 2016 |
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| | 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:== |
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| | Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 5, Response to Request for Additional Information |
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| | ==References:== |
| | : 1. Letter from TVA to NRC, CNL-15-169, "Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU)," dated September 21, 2015 (ML15282A152) |
| | : 2. Letter from NRC to 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)," dated January 28, 2016 (ML16019A283) |
| | : 3. Letter from TVA to NRC, CNL-16-023, "Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 4," dated February 16, 2016 |
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| | By the Reference 1 letter, Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) for the Extended Power Uprate (EPU) of Browns Ferry Nuclear Plant (BFN) Units 1, 2 and 3. The proposed LAR modifies the renewed operating licenses to increase the maximum authorized core thermal power level from the current licensed thermal power of 3458 megawatts to 3952 megawatts. During the technical review of the LAR, the NRC identified the need for additional information. The Reference 2 letter provided NRC Requests for Additional Information (RAIs) related to the Spent Fuel Pool U.S. Nuclear Regulatory Commission CNL-16-035 |
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| | Page 2 March 8, 2016 |
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| | criticality safety analysis. The due date for the responses to these NRC RAIs was February 16, 2016. The Reference 3 letter provided the response to the Reference 2 letter RAIs with the exception of NRC RAI SFP-RAI 2. For the response to NRC RAI SFP-RAI 2, due to the time required to locate test records to support the development of the response and the subsequent review of documentation indicating that, in some cases, testing was inconclusive, the submittal date for this response was extended to March 11, 2016, per communications with the NRC Project Manager. The enclosure to this letter provides the response to the NRC RAI SFP-RAI 2. |
| | TVA has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration 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 information 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 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 |
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| | (423) 751-3850. |
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| | I declare under penalty of perjury that the foregoing is true and correct. Executed on the 8th day of March 2016. |
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| | Respectfully, |
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| | J. W. Shea Vice President, Nuclear Licensing |
| | |
| | ==Enclosure:== |
| | Response to NRC Request for Additional Information SFP-RAI 2 |
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| | cc: |
| | NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant State Health Officer, Alabama Department of Public Health J. W. Shea Digitally signed by J. W. Shea DN: cn=J. W. Shea, o=Tennessee Valley |
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| | Authority, ou=Nuclear Licensing, email=jwshea@tva.gov, c=US Date: 2016.03.08 19:44:43 -05'00' ENCLOSURE Response to NRC Request for Additional Information SFP-RAI 2 ENCLOSURE E-1 SFP-RAI 2 The NCS analyses submitted by the licensee are used to demonstrate the regulatory requirement of 10 CFR 50.68(b)(4), which states, in part, that, "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 borated water, and the k-effective must remain below 1.0 (subcritical), at a 95 percent probability, 95 percent confidence level, if flooded with unborated water." This requirement is evaluated against both normal conditions and postulated accident conditions. In the NCS analysis, the limiting accident condition is one in which a single Boral plate is missing. In the previous SFP LAR dated September 21, 1978 (ADAMS Accession No. |
| | ML020040269), which the NRC staff reviewed and approved in 1978, the licensee evaluated an accident condition where up to four Boral plates were missing. As part of this LAR, the licensee stated that, "the presence of the neutron absorber material in the fabricated fuel storage module will be verified at the reactor storage-pool site by use of a neutron source and neutron detectors." The licensee states there will be a permanent record of all test results and that, "a module will be accepted unless measurements indicate that five or more Boral sheets are not present." Section 10.3.6 of the BFN Updated Final Safety Analysis Report states that each rack was tested prior to installation to check for missing Boral plates. |
| | However, the information available to the NRC does not provide clear assurance that the testing results showed that no Boral plates were found to be missing. Given that the limiting accident condition assumes fewer missing Boral plates than allowed by the acceptance criteria associated with initial receipt of the rack modules, the possibility exists for an unanalyzed condition that challenges the calculated margin to the regulatory limit. Provide information that demonstrates that the testing of the neutron attenuation of each tube in each rack prior to installation showed that no more than one Boral plate was missing from any of the prescribed locations in the fabricated fuel storage modules, even though the criteria for acceptance of each rack modules would have allowed for some missing plates. |
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| | TVA Response: Neutron attenuation testing to verify the presence of the Boral plates in each tube of the high density spent fuel pool (SFP) storage modules was performed at the Browns Ferry Nuclear Plant (BFN) site by General Electric (GE) using a neutron source and four proportional counters. Documentation of the Boral verification testing include: 1) Strip chart records of the four proportional counters; 2) Product Quality Certifications (PQC) provided by GE for each storage module documenting the completion of Boral verification testing; and 3) Work plan documentation that include sign offs for the completion of Boral verification testing. Permanent records of all test results (i.e., strip charts) could not be found. The available documentation reviewed consists of strip chart records, PQCs, and work plans. Based on the review of this documentation, Tennessee Valley Authority (TVA) is confident that all 57 SFP storage modules have been Boral verification tested. Additionally, no documentation has been identified that indicates the existence of missing Boral plates in any storage module. |
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| | ENCLOSURE E-2 For BFN Unit 1, PQCs or work plans for the SFP storage modules show that all testing was completed with no anomalies, with the exception of some cell locations on five storage modules. For these cell locations, it was identified that testing results were inconclusive due to their proximity to irradiated fuel in adjacent storage modules. A statistical analysis was performed that determined the confidence of missing no more than one Boral plate per module was greater than 99.9%. Based on the review of available documentation, there is reasonable expectation that the BFN Unit 1 SFP storage modules are missing no more than |
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| | one Boral plate per module. For BFN Unit 2, PQCs show that all testing was completed with no anomalies, and, therefore, there is reasonable expectation that the BFN Unit 2 SFP storage modules are missing no more than one Boral plate per module. For BFN Unit 3, PQCs or work plans for the SFP storage modules show that all testing was completed with no anomalies, with the exception of some cell locations of one storage module. For these cell locations, it was identified that testing results were inconclusive due to the proximity of irradiated fuel in adjacent storage modules. A statistical analysis was performed that determined the confidence of missing no more than one Boral plate per module was greater than 99.9%. Therefore, there is reasonable expectation that the BFN Unit 3 SFP storage modules are missing no more than one Boral plate per module. The failure to maintain complete permanent records of the Boral verification testing and the inconclusive testing of tubes in the storage modules has been entered into the TVA Corrective Action Program. Actions will be taken to resolve these issues associated with the SFP storage module Boral plate configuration in accordance with the Corrective Action Program.}} |
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Category:Letter
MONTHYEARML24032A4762024-02-0101 February 2024 Final Report of a Part 21 Evaluation Associated with Starter Contactors for the BFN Unit 1 High Pressure Coolant Injection Suppression Pool Inboard Suction Valve ML24023A2802024-01-23023 January 2024 Final Report of a Deviation or Failure to Comply Associated with a Relay in the Reactor Core Isolation Cooling Condensate Pump CNL-24-017, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure and Emergency Preparedness Department Procedure Revisions2024-01-17017 January 2024 Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure and Emergency Preparedness Department Procedure Revisions ML24016A3042024-01-16016 January 2024 Final Report of a Part 21 Evaluation Associated with Check Valve 0-CKV-023-0565 for D1 Residual Heat Removal Service Water Pump CNL-23-071, Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3, Inservice Inspection and Augmented Program Interval Revised Request for Alternative 0-ISI-472024-01-11011 January 2024 Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3, Inservice Inspection and Augmented Program Interval Revised Request for Alternative 0-ISI-47 ML24022A1732024-01-0303 January 2024 Receipt and Availability of the Subsequent License Renewal Application ML23319A1992024-01-0303 January 2024 Issuance of Amendment Nos. 333, 356, and 316 Regarding the Technical Specification Surveillance Requirements 3.4.3.2 and 3.5.1.11 Regarding Safety Relief Valves ML23355A2062023-12-21021 December 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23348A3942023-12-14014 December 2023 Interim Part 21 Report of a Potential Deviation or Failure to Comply Associated with Starter Contactors for the High Pressure Coolant Injection Suppression Pool Inboard Suction Valve IR 05000259/20230102023-12-11011 December 2023 Commercial Grade Dedication Inspection Report 05000259/2023010 and 05000260/2023010 and 05000296/2023010 ML23335A0722023-12-0101 December 2023 Interim Report of a Deviation or Failure to Comply Associated with a Relay in the Unit 2 Reactor Core Isolation Cooling Condensate Pump ML23334A2492023-11-30030 November 2023 Site Emergency Plan Implementing Procedure Revision CNL-23-070, Submittal of Fifth 10-Year Interval Inservice Testing Program Plan2023-11-29029 November 2023 Submittal of Fifth 10-Year Interval Inservice Testing Program Plan ML23331A2532023-11-27027 November 2023 Summary Report for 10 CFR 50.9 Evaluations, Technical Specifications Bases Changes, Technical Requirement Manual Changes, and NRC Commitment Revisions CNL-23-067, Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-11-27027 November 2023 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions ML23325A1102023-11-21021 November 2023 Anchor Darling Double Disc Gate Valve Commitment Revision ML23320A2542023-11-16016 November 2023 Interim Part 21 Report of a Deviation or Failure to Comply Associated with Check Valve 0-CKV-023-0565 for D1 Residual Heat Removal Service Water Pump IR 05000259/20230032023-11-13013 November 2023 Integrated Inspection Report 05000259/2023003, 05000260/2023003 and 05000296/2023003 IR 05000259/20230402023-11-0202 November 2023 Supplemental Inspection Supplemental Report 05000259 2023040 and Follow-Up Assessment Letter ML23292A2532023-10-18018 October 2023 BFN 2024-301, Corporate Notification Letter (210-day Ltr) ML23282A0022023-10-0606 October 2023 Interim Part 21 Report of a Deviation or Failure to Comply Associated with Check Valve 0-CKV-023-0565 for D1 Residual Heat Removal Service Water Pump ML23278A0122023-10-0505 October 2023 Updated Final Safety Analysis Report, Amendment 30 ML23271A1702023-09-28028 September 2023 Site Emergency Plan Implementing Procedure Revision ML23270A0702023-09-26026 September 2023 SLRA Pre-Application Meeting Summary 09-13-2023 ML23257A1232023-09-22022 September 2023 Administrative Changes to Technical Specification Pages Issued for License Amendment Nos. 332, 355, and 315 CNL-23-061, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revision2023-09-20020 September 2023 Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revision ML23263B1042023-09-20020 September 2023 Special Report 260/2023-001 for Inoperable Post Accident Monitoring (PAM) Instrumentation ML23205A2132023-09-0808 September 2023 Issuance of Amendment Nos. 332, 355, and 315 Regarding the Revision of Technical Specifications to Adopt TSTF-566-A and TSTF-580-A, Rev. 1 CNL-23-057, Central Emergency Control Center Emergency Plan Implementing Procedure Revisions. Includes CECC-EPIP-1, Revision 76 and CECC-EPIP-9, Revision 642023-09-0505 September 2023 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions. Includes CECC-EPIP-1, Revision 76 and CECC-EPIP-9, Revision 64 IR 05000259/20230052023-08-29029 August 2023 Updated Inspection Plan for Browns Ferry Nuclear Plant, Units 1, 2 and 3 - Report 05000259/2023005, 05000260/2023005 and 05000296/2023005 ML23233A0432023-08-18018 August 2023 Enforcement Action EA-22-122 Inspection Readiness Notification ML23219A1542023-08-17017 August 2023 Request to Use Later Edition of ASME Code for Operation and Maintenance and Alternative Requests BFN-IST-01 Through 05 for the Fifth 10-Year Interval Inservice Testing Program ML23228A1642023-08-16016 August 2023 Site Emergency Plan Implementing Procedure Revision ML23228A0202023-08-15015 August 2023 (BFN) Unit 1 - Special Report 259/2023-001 for Inoperable Post Accident Monitoring (PAM) Instrumentation IR 05000259/20230022023-08-10010 August 2023 Integrated Inspection Report 05000259/2023002, 05000260/2023002, 05000296/2023002 and 07200052/2023001 ML23192A4472023-07-31031 July 2023 Staff Assessment of Updated Seismic Hazards at TVA Sites Following the NRC Process for the Ongoing Assessment of Natural Hazards Information CNL-23-055, Tennessee Valley Authority - Emergency Preparedness Department Procedure Revision. Includes EPDP-3, Revision 3, Emergency Plan Exercises and Preparedness Drills2023-07-25025 July 2023 Tennessee Valley Authority - Emergency Preparedness Department Procedure Revision. Includes EPDP-3, Revision 3, Emergency Plan Exercises and Preparedness Drills ML23171A8862023-07-24024 July 2023 Issuance of Amend. Nos. 331, 354, and 314; 365 and 359 Regarding Adoption of TSTF-541-A, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position ML23201A2182023-07-20020 July 2023 Registration of Use of Cask to Store Spent Fuel (MPC-298 and -299) ML23159A2552023-07-20020 July 2023 Proposed Alternative to the Requirements of the ASME Code Regarding Volumetric Inspection of Standby Liquid Control Nozzles ML23199A3072023-07-18018 July 2023 Site Emergency Plan Implementing Procedure Revision CNL-23-053, Tennessee Valley Authority - Radiological Emergency Plan Revisions2023-07-18018 July 2023 Tennessee Valley Authority - Radiological Emergency Plan Revisions IR 05000259/20233012023-07-18018 July 2023 NRC Operator License Examination Report Nos. 05000259/2023301, 05000260/2023301, and 05000296/2023301 2024-02-01
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARCNL-23-071, Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3, Inservice Inspection and Augmented Program Interval Revised Request for Alternative 0-ISI-472024-01-11011 January 2024 Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3, Inservice Inspection and Augmented Program Interval Revised Request for Alternative 0-ISI-47 CNL-23-037, Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Request to Use a Later Edition of the American Society of Mechanical Engineers Operation and Maintenance Code and Alternative Request2023-06-0101 June 2023 Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3 - Request to Use a Later Edition of the American Society of Mechanical Engineers Operation and Maintenance Code and Alternative Requests CNL-23-019, Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3, American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Request for Alternative BFN-0-ISI-322023-03-11011 March 2023 Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Units 1, 2, and 3, American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Request for Alternative BFN-0-ISI-32 CNL-22-097, Response to Request for Additional Information and Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide .2022-12-0101 December 2022 Response to Request for Additional Information and Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, Provide . CNL-22-075, Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Unit 2, Request for Alternative, BFN-21-ISI-02, Alternative to American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section Xi,.2022-09-12012 September 2022 Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant, Unit 2, Request for Alternative, BFN-21-ISI-02, Alternative to American Society of Mechanical Engineers, Boiler and Pressure Vessel Code, Section Xi,. CNL-22-065, Response to Request for Confirmation of Information and Additional Information and Second Supplement Regarding Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie.2022-08-0101 August 2022 Response to Request for Confirmation of Information and Additional Information and Second Supplement Regarding Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie. CNL-22-066, Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for in Support of Atrium 11 Fuel Use Supplement 3, Response to Request for Additional Information2022-07-18018 July 2022 Request for License Amendment Regarding Application of Advanced Framatome Methodologies, and Adoption of TSTF-564 Revision 2 for in Support of Atrium 11 Fuel Use Supplement 3, Response to Request for Additional Information CNL-22-064, Response to Request for Additional Information Regarding Tennessee Valley Authority License Amendment Request to Revise Emergency Plan Implementing Procedure Regarding Seismic Event Emergency Action Level Change2022-06-0909 June 2022 Response to Request for Additional Information Regarding Tennessee Valley Authority License Amendment Request to Revise Emergency Plan Implementing Procedure Regarding Seismic Event Emergency Action Level Change CNL-22-007, Supplement to Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie Modification to Support System Operability (BFN-TS-518)2022-04-0606 April 2022 Supplement to Application Requesting NRC Prior Approval of a Proposed Chilled-Water Cross-tie Modification to Support System Operability (BFN-TS-518) 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)2022-03-18018 March 2022 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) CNL-21-052, Response to Request for Additional Information Regarding License Amendment Request to Modify Technical Specification 3.8.6, Battery Cell Parameters (TS-531)2021-07-21021 July 2021 Response to Request for Additional Information Regarding License Amendment Request to Modify Technical Specification 3.8.6, Battery Cell Parameters (TS-531) CNL-21-033, Response to Request for Additional Information Regarding License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components2021-04-28028 April 2021 Response to Request for Additional Information Regarding License Amendment Request to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components CNL-21-017, Response to Request for Additional Information Regarding License Amendment Request to Incorporate Tornado Missile Risk Evaluator Into the Licensing Basis, (L-2020-LLA-0099)2020-12-29029 December 2020 Response to Request for Additional Information Regarding License Amendment Request to Incorporate Tornado Missile Risk Evaluator Into the Licensing Basis, (L-2020-LLA-0099) CNL-20-089, Response to RAI Re Application for Tech. Specification Change Re Risk-Informed Justification for Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (BFN-TS-518)2020-12-21021 December 2020 Response to RAI Re Application for Tech. Specification Change Re Risk-Informed Justification for Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (BFN-TS-518) CNL-20-059, Response to Request for Additional Information Regarding Proposed Alternative Request No. 0-ISI-47 for the Third, Fifth, and Fourth 10-Year Inservice Inspection Intervals2020-08-10010 August 2020 Response to Request for Additional Information Regarding Proposed Alternative Request No. 0-ISI-47 for the Third, Fifth, and Fourth 10-Year Inservice Inspection Intervals CNL-19-122, Seismic Probabilistic Risk Assessment Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights2019-12-17017 December 2019 Seismic Probabilistic Risk Assessment Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights CNL-19-064, Response to NRC Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF)-542, Reactor Pressure Vessel Water...2019-08-0808 August 2019 Response to NRC Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt Technical Specifications Task Force (TSTF)-542, Reactor Pressure Vessel Water... CNL-19-052, Response to NRC Request for Additional Information Regarding Re-Submittal of American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Inservice Inspection (ISI) Program and Augmented Program, Second2019-07-19019 July 2019 Response to NRC Request for Additional Information Regarding Re-Submittal of American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Inservice Inspection (ISI) Program and Augmented Program, Second CNL-19-017, Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 7, Response to Requests for Additional Information2019-01-25025 January 2019 Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 7, Response to Requests for Additional Information CNL-19-007, Supplement 5, Response to Requests for Additional Information Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus2019-01-16016 January 2019 Supplement 5, Response to Requests for Additional Information Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus CNL-19-011, Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 6, Additional Operator Training Results2019-01-16016 January 2019 Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 6, Additional Operator Training Results CNL-18-139, Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Information2018-12-14014 December 2018 Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Information CNL-18-140, Response to Request for Additional Information Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 42018-12-13013 December 2018 Response to Request for Additional Information Proposed Technical Specifications (TS) Change TS-510 - Request for License Amendments - Maximum Extended Load Line Limit Analysis Plus - Supplement 4 CNL-18-117, Response to Request for Additional Information Regarding Browns Ferry Units 1, 2, and 3: Code Case N-702 for Alternative Request ISI-462018-10-17017 October 2018 Response to Request for Additional Information Regarding Browns Ferry Units 1, 2, and 3: Code Case N-702 for Alternative Request ISI-46 CNL-18-120, Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant Unit 1, American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Inservice Inspection (ISI) Program, Unit 1 Second Ten-year ..2018-10-11011 October 2018 Response to Request for Additional Information Regarding Browns Ferry Nuclear Plant Unit 1, American Society of Mechanical Engineers Boiler and Pressure Vessel Code Section XI, Inservice Inspection (ISI) Program, Unit 1 Second Ten-year ... ML18283A8972018-10-10010 October 2018 Enclosure 1: Proposed Changes to Browns Ferry Nuclear Plant Unit 1 Technical Specifications, Attachments 1, 2, & 3 CNL-18-089, Response to Request for Additional Information Regarding Decommissioning Funding Plan Update for Browns Ferry Nuclear Plant and Sequoyah Nuclear Plant Independent Spent Fuel Storage Installations, Docket Nos. 72-052 and 72-0342018-07-23023 July 2018 Response to Request for Additional Information Regarding Decommissioning Funding Plan Update for Browns Ferry Nuclear Plant and Sequoyah Nuclear Plant Independent Spent Fuel Storage Installations, Docket Nos. 72-052 and 72-034 CNL-18-044, Tennessee Valley Authority Response to NRC Request for Additional Information Related to Topical Report TVA-NPG-AWA16, TVA Overall Basin Probable Maximum Precipitation.2018-04-19019 April 2018 Tennessee Valley Authority Response to NRC Request for Additional Information Related to Topical Report TVA-NPG-AWA16, TVA Overall Basin Probable Maximum Precipitation. 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Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402
CNL-16-035 March 8, 2016
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:
Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 5, Response to Request for Additional Information
References:
- 1. Letter from TVA to NRC, CNL-15-169, "Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU)," dated September 21, 2015 (ML15282A152)
- 2. Letter from NRC to 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)," dated January 28, 2016 (ML16019A283)
- 3. Letter from TVA to NRC, CNL-16-023, "Proposed Technical Specifications (TS) Change TS-505 - Request for License Amendments - Extended Power Uprate (EPU) - Supplement 4," dated February 16, 2016
By the Reference 1 letter, Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) for the Extended Power Uprate (EPU) of Browns Ferry Nuclear Plant (BFN) Units 1, 2 and 3. The proposed LAR modifies the renewed operating licenses to increase the maximum authorized core thermal power level from the current licensed thermal power of 3458 megawatts to 3952 megawatts. During the technical review of the LAR, the NRC identified the need for additional information. The Reference 2 letter provided NRC Requests for Additional Information (RAIs) related to the Spent Fuel Pool U.S. Nuclear Regulatory Commission CNL-16-035
Page 2 March 8, 2016
criticality safety analysis. The due date for the responses to these NRC RAIs was February 16, 2016. The Reference 3 letter provided the response to the Reference 2 letter RAIs with the exception of NRC RAI SFP-RAI 2. For the response to NRC RAI SFP-RAI 2, due to the time required to locate test records to support the development of the response and the subsequent review of documentation indicating that, in some cases, testing was inconclusive, the submittal date for this response was extended to March 11, 2016, per communications with the NRC Project Manager. The enclosure to this letter provides the response to the NRC RAI SFP-RAI 2.
TVA has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration 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 information 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 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 8th day of March 2016.
Respectfully,
J. W. Shea Vice President, Nuclear Licensing
Enclosure:
Response to NRC Request for Additional Information SFP-RAI 2
cc:
NRC Regional Administrator - Region II NRC Senior Resident Inspector - Browns Ferry Nuclear Plant State Health Officer, Alabama Department of Public Health J. W. Shea Digitally signed by J. W. Shea DN: cn=J. W. Shea, o=Tennessee Valley
Authority, ou=Nuclear Licensing, email=jwshea@tva.gov, c=US Date: 2016.03.08 19:44:43 -05'00' ENCLOSURE Response to NRC Request for Additional Information SFP-RAI 2 ENCLOSURE E-1 SFP-RAI 2 The NCS analyses submitted by the licensee are used to demonstrate the regulatory requirement of 10 CFR 50.68(b)(4), which states, in part, that, "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 borated water, and the k-effective must remain below 1.0 (subcritical), at a 95 percent probability, 95 percent confidence level, if flooded with unborated water." This requirement is evaluated against both normal conditions and postulated accident conditions. In the NCS analysis, the limiting accident condition is one in which a single Boral plate is missing. In the previous SFP LAR dated September 21, 1978 (ADAMS Accession No.
ML020040269), which the NRC staff reviewed and approved in 1978, the licensee evaluated an accident condition where up to four Boral plates were missing. As part of this LAR, the licensee stated that, "the presence of the neutron absorber material in the fabricated fuel storage module will be verified at the reactor storage-pool site by use of a neutron source and neutron detectors." The licensee states there will be a permanent record of all test results and that, "a module will be accepted unless measurements indicate that five or more Boral sheets are not present." Section 10.3.6 of the BFN Updated Final Safety Analysis Report states that each rack was tested prior to installation to check for missing Boral plates.
However, the information available to the NRC does not provide clear assurance that the testing results showed that no Boral plates were found to be missing. Given that the limiting accident condition assumes fewer missing Boral plates than allowed by the acceptance criteria associated with initial receipt of the rack modules, the possibility exists for an unanalyzed condition that challenges the calculated margin to the regulatory limit. Provide information that demonstrates that the testing of the neutron attenuation of each tube in each rack prior to installation showed that no more than one Boral plate was missing from any of the prescribed locations in the fabricated fuel storage modules, even though the criteria for acceptance of each rack modules would have allowed for some missing plates.
TVA Response: Neutron attenuation testing to verify the presence of the Boral plates in each tube of the high density spent fuel pool (SFP) storage modules was performed at the Browns Ferry Nuclear Plant (BFN) site by General Electric (GE) using a neutron source and four proportional counters. Documentation of the Boral verification testing include: 1) Strip chart records of the four proportional counters; 2) Product Quality Certifications (PQC) provided by GE for each storage module documenting the completion of Boral verification testing; and 3) Work plan documentation that include sign offs for the completion of Boral verification testing. Permanent records of all test results (i.e., strip charts) could not be found. The available documentation reviewed consists of strip chart records, PQCs, and work plans. Based on the review of this documentation, Tennessee Valley Authority (TVA) is confident that all 57 SFP storage modules have been Boral verification tested. Additionally, no documentation has been identified that indicates the existence of missing Boral plates in any storage module.
ENCLOSURE E-2 For BFN Unit 1, PQCs or work plans for the SFP storage modules show that all testing was completed with no anomalies, with the exception of some cell locations on five storage modules. For these cell locations, it was identified that testing results were inconclusive due to their proximity to irradiated fuel in adjacent storage modules. A statistical analysis was performed that determined the confidence of missing no more than one Boral plate per module was greater than 99.9%. Based on the review of available documentation, there is reasonable expectation that the BFN Unit 1 SFP storage modules are missing no more than
one Boral plate per module. For BFN Unit 2, PQCs show that all testing was completed with no anomalies, and, therefore, there is reasonable expectation that the BFN Unit 2 SFP storage modules are missing no more than one Boral plate per module. For BFN Unit 3, PQCs or work plans for the SFP storage modules show that all testing was completed with no anomalies, with the exception of some cell locations of one storage module. For these cell locations, it was identified that testing results were inconclusive due to the proximity of irradiated fuel in adjacent storage modules. A statistical analysis was performed that determined the confidence of missing no more than one Boral plate per module was greater than 99.9%. Therefore, there is reasonable expectation that the BFN Unit 3 SFP storage modules are missing no more than one Boral plate per module. The failure to maintain complete permanent records of the Boral verification testing and the inconclusive testing of tubes in the storage modules has been entered into the TVA Corrective Action Program. Actions will be taken to resolve these issues associated with the SFP storage module Boral plate configuration in accordance with the Corrective Action Program.