ML101241260
| ML101241260 | |
| Person / Time | |
|---|---|
| Site: | Watts Bar, 07007018  |
| Issue date: | 05/10/2010 |
| From: | Reinaldo Rodriguez NRC/NMSS/FCSS/FCLD/FMB |
| To: | Arent G Tennessee Valley Authority |
| Santiago Aguilar - SRA1 - NMSS-492-3569 | |
| Shared Package | |
| ML101241248 | List: |
| References | |
| TAC L32918 | |
| Download: ML101241260 (2) | |
Text
Enclosure REQUEST FOR ADDITIONAL INFORMATION IN SUPPORT OF THE REVIEW OF A PART 70 LICENSE APPLICATION FOR WATTS BAR NUCLEAR PLANT, UNIT 2 A) Radiation Protection
- 1. Sections 2.2.4 and 4.3 of the license application commit to Regulatory Guide (RG) 1.8 Revisions 1 and 2 (although this isnt stated consistently in these sections). Revision 3 of this guidance is the most recent version of the document. Consistent with Title 10 of the Code of Federal Regulations (10 CFR) 70.22(a)(6) and 10 CFR 70.23(a)(2), justify why Tennessee Valley Authority (TVA) is not committing to the most recent revision of Regulatory Guide 1.8.
- 2. Section 4.5 of the license application states that: A radiation protection training program shall be developed, documented, and administered consistent with expectations as outlined in NEI 95-04, Guideline for General Access Training. This document was not submitted as part of the license application, and was not readily available by the reviewer. Consistent with 10 CFR 70.9, provide a copy of this document so this commitment can be adequately assessed.
Alternatively, describe how TVAs radiation protection training program meets the expectations in Nuclear Energy Institute (NEI) 95-04.
- 3. In Section 4.7 of the license application, commitments are made to American Standards Institute (ANSI) N13.11 - 1983 and ANSI N13.30 - 1989. ANSI N13.11-1983 is not the most recent revision of this guidance; ANSI N13.30-1989 is a draft version of the guidance.
Consistent with 10 CFR 70.22(a)(7) and 10 CFR 70.23 (a)(3), justify why the most recent and final versions, respectively, of these guidance documents are not used.
Consistent with 10 CFR 70.9, remove the reference and replace it with a current RG that is equivalent to RG 1.88. Alternatively, describe it in sufficient detail so this commitment can be adequately assessed.
- 5. Section 4.7.7 of the license application commits to U.S. Nuclear Regulatory Commission (NRC) Technical Communication, Radiation Records Data Collection and Analysis to TVA, dated January 4, 1994. This document was not submitted as part of the license application, and was not readily available by the reviewer. Consistent with 10 CFR 70.9, provide a copy of this document or describe it in sufficient detail so this commitment can be adequately assessed.
B) Nuclear Criticality Safety
- 1. Chapter 5 of the license application does not make any reference to the use of ANSI/ANS-8.23, Nuclear Criticality Accident Emergency Planning and Response, as part of the nuclear criticality safety program. ANSI/American Nuclear Society (ANS)-8.23 is endorsed in RG 3.71, but is not discussed in the license application. Consistent with 10 CFR 70.22(a)(8) and 10 CFR 70.23(a)(4), clarify if TVA is committing to using ANSI/ANS-8.23 for the purpose of the license application and indicate what version (i.e., year) TVA is committing to. Alternatively, justify the use of alternative approaches that meet the intent of ANSI/ANS-8.23.
- 2. Chapter 5 of the license application did not describe any compensatory measures while the criticality accident alarm system (CAAS) is out of service, and did not define any criteria for establishing when it is not safe to shut down fissile material movement. Since the CAAS is the primary means to identify a criticality accident and mitigate its effects, TVA needs to provide
2 further justification for allowing fissile material movement to continue if the CAAS is out of service for an extended time. Consistent with 10 CFR 70.24:
A) Revise the license application to include a statement indicating that all movement of special nuclear material (SNM) must cease until the alarm service has been restored, should the CAAS be out of service for any amount of time; however, routine testing, calibration, and/or maintenance of the system is permitted without suspension of fissile material movement.
B) Revise the license application to include a statement indicating that in the event that suspension of fissile material movement, even to make this activity safe, carries a larger risk than being without a CAAS for a short period of time, TVA commits to implementing compensatory measures (e.g., limiting access, providing continuously attended portable monitoring, etc.), approved by the nuclear criticality safety function, for the time needed to either restore complete functionality of the CAAS or to safely shut fissile material movement.
C) Define the criteria that will be used at Watts Bar, Unit 2 to determine when it is not safe to shut down fissile material movement such that compensatory measures will be used. In addition, justify the time period required to safely shut down fissile material movement on a risk basis.
- 3. Chapter 5 of the license application does not describe the basis for determining that double contingency protection is ensured when only using administrative controls, especially in those instances when only two administrative controls are used. Consistent with 10 CFR 70.61, provide such information and describe how these administrative controls are unlikely to fail for those instances, if any. The double contingency principle states that process designs should incorporate sufficient factors of safety to require at least two unlikely, independent, and concurrent changes in process conditions before a criticality accident is possible.
C) Material Control and Accounting
- 1. Enclosure 3 of the license application does not state if a Fundamental Nuclear Material Control Plan (FNMCP) will be required in support of the license application. Consistent with 10 CFR 70.22(b), revise the enclosure to clearly state the exception from the requirements for an FNMCP in support of a license application.
- 2. Enclosure 3 of the license application does not describe in sufficient detail how TVA will meet the requirements in 10 CFR 74 Subpart B, General Reporting and Recordkeeping Requirements for Watts Bar, Unit 2. Since TVA is relying on shared systems, structures, components, and administrative controls currently in place for Watts Bar Unit 1, provide a copy of such procedures, updated specifically to reflect its applicability to Unit 2, to demonstrate how the requirements of 10 CFR 74 Subpart B are met. Alternatively, describe each one of the nine elements in Enclosure 3 in sufficient detail to enable NRC to assess TVAs regulatory compliance for WB-2.