ML050880157

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Summary of February 2005 Conference Calls Regarding Extended Power Uprate Acceptance Review Reply
ML050880157
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 04/01/2005
From: Ellen Brown
NRC/NRR/DLPM/LPD2
To:
Tennessee Valley Authority
Brown, E, NRR-DLPM 301-415-2315
References
TAC MC3743, TAC MC3744, TAC MC3812
Download: ML050880157 (7)


Text

April 1, 2005 LICENSEE:

Tennessee Valley Authority FACILITIES:

Browns Ferry Nuclear Plant, Units 1, 2, and 3

SUBJECT:

SUMMARY

OF FEBRUARY 2005 CONFERENCE CALLS REGARDING EXTENDED POWER UPRATE ACCEPTANCE REVIEW REPLY (TAC NOS. MC3812, MC3743, AND MC3744)

On February 9, and 10, 2005, the U.S. Nuclear Regulatory Commission (NRC) staff conducted conference calls with the Tennessee Valley Authority (TVA, the licensee) representatives. The calls were conducted to clarify expectations regarding the licensees response to the extended power uprate (EPU) acceptance review results letters dated November 18, 2004. These letters outlined areas of the EPU applications which were found to require supplemental information to complete the application. Enclosure 1 is a list of attendees. Enclosures 2 and 3 contain the draft response provided by TVA.

BACKGROUND By letter date June 28, 2004, Tennessee Valley Authority (TVA), the licensee, submitted an amendment request for Browns Ferry Nuclear Plant (BFN) Unit 1. The proposed amendment would change the BFN Unit 1, operating license to increase the maximum authorized power level from 3203 megawatts thermal (MWt) to 3952 MWt. This change represents an increase of approximately 20 percent above the current maximum authorized power level. The proposed amendment would also change the BFN licensing bases and any associated technical specifications (TSs) for containment overpressure and remove the upper bound limitation on peak cladding temperature.

By letter date June 25, 2004, TVA, the licensee, submitted an amendment request for Units 2 and 3. The proposed amendment would change the Units 2 and 3, operating licenses to increase the maximum authorized power level from 3458 MWt to 3952 MWt. This change represents an increase of approximately 15 percent above the current maximum authorized power level. The proposed amendment would also change the BFN licensing bases and any associated TSs for containment overpressure, remove the upper bound limitation on peak cladding temperature and the revise the maximum ultimate heat sink temperature.

The NRC staff reviewed TVAs request and concluded that it did not provide technical information in sufficient detail to enable the NRC staff to make an independent assessment regarding the acceptability of the proposal in terms of regulatory requirements and the protection of public health and safety. On January 21, 2005, the licensee provided draft responses to the concerns raised by the NRC staff in the November 18, 2004, letters.

Subsequently, a series of conference calls were held to discuss some remaining concerns as a result of the draft comments. A copy of the draft responses is contained in Enclosures 2 and 3.

DISCUSSION February 9, 2005 - Fuels TVAs Units 2 and 3 EPU submittal contained Enclosure 8, Framatome Updated Safety Analyses Report (FUSAR) last section, Licensing Approach for use of Framatome fuels. In this section it was stated that... the remaining GE [General Electric] 14 fuel in the Unit 2 core will be a relatively small batch of twice-burnt fuel (at BOC [beginning of cycle]) located primarily on or near the periphery. The NRC staff found that there was insufficient information to establish whether GE14 fuel would be put in critical positions or would be limiting. Since, BFN Unit 2 would be operating with a mixed core, additional information was requested, such as a mixed core analyses report and a fuel transition report. Also, since the BFN Unit 3 would be the first uprated unit using a full core of ATRIUM-10 fuel, additional information, such as the assumptions, limitations, restrictions in the models, and the applications of the models, were requested to establish whether the evaluation models given in Table 1-3 of FUSAR were valid.

Consistent with the guidance provided in Mr. Ledyard B. Marshs letter to GE dated June 25, 2003, specific operating cycle information was requested to show compliance with all regulations for the proposed transition core design.

During the call, the NRC staff indicated that the draft information provided, in response to the NRC staffs November 18, 2004, letter (Enclosure 3), on the mixed core for Unit 2 was insufficient. For example, the draft response still did not demonstrate why the GE-14 fuel would be limiting or address why the GE-14 fuel would not participate in the minimum critical power ratio safety limit calculation. The NRC staff also discussed the need for the licensee, consistent with the June 25, 2003, letter, to provide the actual core design for review. The licensee questioned the need for the actual core based on their earlier submission of a representative or equilibrium core and the possibility that last minute changes to Safety Reload Limit Report. The NRC staff stated that conservatism of the equilibrium core is questionable. Additionally, it was discussed that as a result of questions regarding thermal hydraulic conditions assumed in the GE core analysis at original licensed thermal power, TVA should address why the analyses performed for the Browns Ferry cores would be still valid at uprated conditions. This discussion should include the range of values used and the associated thermal conditions. In addition, TVA should provide a discussion as to why the NRC staff should accept the use of a process approved for GE fuel, that has not been approved for other fuels.

February 10, 2005 - Large Transient Testing Draft Section 14.2.1 of NUREG-0800, Generic Guidelines for Extended Power Uprate Testing Programs, dated December 2002 provides general guidelines for reviewing proposed EPU testing programs. This review ensures that the proposed testing program adequately verifies that the plant can be operated safely at the proposed uprated power level by ensuring that the proposed EPU testing program adequately demonstrates that structures, systems, and components (SSCs) will perform satisfactorily at EPU conditions. In particular, the EPU test program provides assurance that (1) any power uprate related modifications to the facility have been adequately constructed and implemented, and (2) the facility can be operated at the proposed EPU conditions in accordance with design requirements and in a manner that will not endanger the health and safety of the public. Additionally, the EPU test program should include sufficient testing to demonstrate that EPU-related plant modifications have been adequately implemented.

Guidance was provided in RS-001, Review Standard for Extended Power Uprates, Rev. 0 and EPU Licensing Topical Reports (ELTR)-1 and ELTR-2. The EPU test program ensures that SSCs capabilities to perform specified functions are not adversely impacted by increasing the maximum allowed power level. This also ensures that deficiencies are identified and corrected, and that testing activities are conducted in a manner which minimizes operational reliance on untested safety functions. This provides a high degree of assurance of SSCs and overall plant readiness for safe operation within the bounds of the design and safety analyses, assurance against unexpected or unanalyzed plant behavior, and assurance against early safety function failures in service. TVA decided against performing large transient testing. Therefore, the NRC staff indicated that TVA needed to provide additional information describing the site-specific safety analysis results performed for each transient test for which the analysis results would have been validated by performance of large transient testing. TVA acknowledged the NRC staffs concern and indicated that a revision to the TVA response to the NRC staffs November 18, 2004, letter would be provided.

No commitments were made by the licensee and no regulatory decisions were made by the NRC staff during the proceedings of this conference call.

/RA/

Eva A. Brown, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-259, 50-260 and 50-296

Enclosures:

1. List of Attendees
2. Draft TVA Unit 1 Response
3. Draft TVA Units 2 and 3 Response w/

Enclosures:

See next page

ML050880157 : ML051030271 NRC-001 OFFICE PDII-2/PM PDII-2/PM PDII-2/LA PDII-2/SC NAME EBrown MChernoff BClayton MMarshall DATE 3/24/05 3/24/05 3/23/05 4/01/05 Participants of Conference Calls NRC TENNESSEE VALLEY AUTHORITY Frank Akstulewicz Tim Abney Michael Marshall Steve Austin Jim Tatum Ed Hartwig Bob Pettis Joe Valente Michael Bennett Denzel Housley Margaret Chernoff Henry Jones Eva Brown Tom Newton Earl Reilly

Tennessee Valley Authority BROWNS FERRY NUCLEAR PLANT cc:

Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 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, General Manager Nuclear Engineering Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Michael D. Skaggs Site Vice President Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 General Counsel Tennessee Valley Authority ET 11A 400 West Summit Hill Drive Knoxville, TN 37902 Mr. John C. Fornicola, Manager Nuclear Assurance and Licensing Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Kurt L. Krueger, Plant Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Jon R. Rupert, Vice President Browns Ferry Unit 1 Restart Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Robert G. Jones Browns Ferry Unit 1 Plant Restart Manager Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Mr. Scott M. Shaeffer Browns 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. Fredrick C. Mashburn Senior Program Manager Nuclear Licensing Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Timothy E. Abney, Manager Licensing and Industry Affairs Browns Ferry Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Decatur, AL 35609 Senior Resident Inspector U.S. Nuclear Regulatory Commission Browns Ferry Nuclear Plant 10833 Shaw Road Athens, AL 35611-6970 State Health Officer Alabama Dept. of Public Health RSA Tower - Administration Suite 1552 P.O. Box 303017 Montgomery, AL 36130-3017 Chairman Limestone County Commission 310 West Washington Street Athens, AL 35611