ML121850009

Response to NRC Sixth Request for Additional Information Regarding Application to Modify Technical Specifications for Use of Areva Advanced W17 Htp Fuel (TS-SQN-2011-07)

ML121850009
Person / Time
Site:	Sequoyah
Issue date:	06/26/2012
From:	James Shea Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME6538, TAC ME6539, TS-SQN-2011-07
Download: ML121850009 (5)

Text

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 June 26, 2012 10 CFR 50.4 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328

Subject:

Response to NRC Sixth Request for Additional Information Regarding Application to Modify Technical Specifications for Use of AREVA Advanced W17 HTP Fuel (TS-SQN-2011-07) (TAC Nos.

ME6538 and ME6539)

References:

1. Letter from TVA to NRC, "Application to Modify Technical Specifications for Use of AREVA Advanced W1 7 HTP Fuel (TS-SQN-2011-07)," dated June 17, 2011

2. Letter from TVA to NRC, "Response to NRC Request for Supplemental Information Regarding Application to Modify Technical Specifications for Use of AREVA Advanced W1 7 HTP Fuel (TS-SQN-2011-07)," dated July 27, 2011

3. Letter from NRC to TVA, "Sequoyah Nuclear Plant, Units 1 and 2 -

Request for Additional Information Regarding the Propopsed [sic]

Technical Specification Changes to Allow Use of AREVA Advanced W17 High Thermal Performance Fuel (TAC Nos. ME6538 and ME6539)," dated October 14, 2011

4. Letter from TVA to NRC, "Response to NRC Request for Additional Information Regarding Application to Modify Technical Specifications for Use of AREVA Advanced W1 7 HTP Fuel (TS-SQN-2011-07)," dated November 14, 2011 Printed on recycled paper 7Ibc *&

U.S. Nuclear Regulatory Commission Page 2 June 26, 2012

5. Letter from NRC to TVA, "Sequoyah Nuclear Plant, Units 1 and 2 -

Request for Additional Information Regarding the Propopsed [sic]

Technical Specification Changes to Allow Use of AREVA Advanced W17 High Thermal Performance Fuel (TAC Nos. ME6538 and ME6539), dated February 8, 2012

6. Letter from TVA to NRC, "Response to NRC Second Request for Additional Information Regarding Application to Modify Technical Specifications for Use of AREVA Advanced W1 7 HTP Fuel (TS-SQN-2011-07)," dated March 23, 2012

7. Electronic Mail from NRC to TVA, "LAR for TAC ME6538/6539 (Sequoyah 1 & 2 - Use of AREVA Advanced W17 HTP Fuel)," dated April 4, 2012

8. Letter from TVA to NRC, "Response to NRC Third Request for Additional Information Regarding Application to Modify Technical Specifications for Use of AREVA Advanced W1 7 HTP Fuel (TS-SQN-2011-07) (TAC Nos. ME6538 and ME6539)," dated April 26, 2012

9. Electronic Mail from NRC to TVA, "Sequoyah, Units 1 & 2 - AREVA W17 HTP Fuel Transition (TAC Nos. ME6538 and ME6539)," dated May 2, 2012

10. Letter from TVA to NRC, "Response to NRC Fourth Request for Additional Information Regarding Application to Modify Technical Specifications for Use of AREVA Advanced W1 7 HTP Fuel (TS-SQN-2011-07) (TAC Nos. ME6538 and ME6539)," dated May 15, 2012

11. Electronic Mail from NRC to TVA, "TCD Issue," dated May 15, 2012

12. Letter from TVA to NRC, "Response to NRC Fifth Request for Additional Information Regarding Application to Modify Technical Specifications for Use of AREVA Advanced W1 7 HTP Fuel (TS-SQN-2011-07) (TAC Nos. ME6538 and ME6539)," dated May 24, 2012

13. Electronic Mail from NRC to TVA, "Sequoyah 1 and 2 - AREVA Advanced W1 7 HTP Fuel Transition LAR (TAC Nos. ME6538 and ME6539)," dated June 5, 2012 The purpose of this letter is to provide a response to the Nuclear Regulatory Commission (NRC) request for additional information (RAI) transmitted to the Tennessee Valley Authority (TVA) by electronic mail (email) on June 5, 2012 (Reference 13), regarding the proposed Technical Specification (TS) changes for

U.S. Nuclear Regulatory Commission Page 3 June 26, 2012 Sequoyah Nuclear Plant (SQN), Units 1 and 2, allowing use of AREVA Advanced W1 7 High Thermal Performance (HTP) fuel.

On June 17, 2011, TVA submitted a request for amendment to the TSs for SQN, Units 1 and 2 (Reference 1). The amendment request proposed to allow use of AREVA Advanced W17 High Thermal Performance (HTP) fuel at SQN. In a letter dated July 27, 2011 (Reference 2), TVA provided supplemental information requested by the NRC on July 21, 2011, in a telephone call between TVA and NRC representatives. By letter dated October 14, 2011 (Reference 3), the NRC forwarded an RAI regarding the proposed changes to the TSs. TVA provided the response to this RAI in a letter dated November 14, 2011 (Reference 4). A second RAI regarding the proposed TS changes was forwarded to TVA by letter dated February 8, 2012 (Reference 5). TVA provided the response to the second RAI in a letter dated March 23, 2012 (Reference 6).

On April 4, 2012, the NRC transmitted a third RAI by email (Reference 7) involving the Loss of Coolant Accident (LOCA) analyses supporting the proposed use of AREVA Advanced W17 HTP fuel at SQN. Following a telephone conference call between TVA and NRC representatives held on April 9, 2012, TVA agreed to provide an analysis of the effects of fuel clad swelling, rupture, and relocation, and also to provide a discussion of the cause of the apparent negative trend of the post-LOCA reactor vessel downcomer liquid level transient, with confirmation that this trend does not continue. TVA provided the requested analysis and confirmation in a letter dated April 26, 2012 (Reference 8).

By email dated May 2, 2012 (Reference 9), the NRC transmitted a fourth RAI regarding the proposed use of AREVA Advanced W17 HTP fuel at SQN. TVA provided the response to this fourth RAI in a letter dated May 15, 2012 (Reference 10).

Also on May 15, 2012, the NRC transmitted a fifth RAI by email (Reference 11) regarding a thermal conductivity degradation (TCD) issue and its effect on HTP fuel performance. A telephone conference call was held with the NRC reviewers on May 16, 2012, to discuss the TCD issue, and also to discuss the response to a previous RAI question. Upon conclusion of the conference call, it was TVA's understanding that the discussions during the conference call adequately addressed the NRC reviewers' questions regarding the previous RAI response. As such, only the questions pertaining to the TCD issue as documented in the fifth NRC RAI (Reference 11) would require docketed responses. TVA provided the response to the fifth RAI in a letter dated May 24, 2012 (Reference 12).

A telephone conference call was held on June 4, 2012 between TVA and NRC representatives concerning the status of the NRC's review of the proposed TS amendment to allow use of AREVA Advanced W17 HTP fuel at SQN. During the conference call, the participating NRC reviewers introduced additional questions that TVA requested to have documented in an RAI. The NRC agreed, and transmitted a sixth RAI containing the additional questions by email dated June 5, 2012 (Reference 13).

U.S. Nuclear Regulatory Commission Page 4 June 26, 2012 to this letter contains TVA's responses to the Reference 13 RAI, and the responses to the first, second, and fifth NRC RAIs (References 4, 6 and 12). These RAI responses include information provided by AREVA NP Inc. (AREVA NP) which they consider to be proprietary in nature, pursuant to 10 CFR 2.390, "Public inspections, exemptions, requests for withholding," paragraph (a)(4). It is, therefore, requested that this information be withheld from public disclosure. Enclosure 2 provides a redacted version of Enclosure 1 that is suitable for public disclosure. to this letter contains the affidavit supporting the request for withholding the information from public disclosure. No other changes have been made to the previous submittals regarding the proposed TS amendment to allow use of AREVA Advanced W17 HTP fuel at SQN.

Note that Sections 3, 4, and 5 of Enclosures 1 and 2 include the previously submitted responses to the NRC's first, second, and fifth RAIs (References 4, 6, and 12),

respectively, regarding the proposed use of AREVA Advanced W1 7 HTP fuel. Section 6 of Enclosures 1 and 2 provides the responses to this sixth NRC RAI (Reference 13).

There are no regulatory commitments associated with this submittal. Please address any questions regarding this request to Clyde Mackaman at 423-751-2834.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2 6 th day of June, 2012.

Respcully, M Vere Corporate Nuclear Licensing

Enclosures:

1. ANP-3053(P), Revision 4, Sequoyah HTP Fuel Transition - NRC RAIs and Responses, June 2012 (Proprietary Version)

2. ANP-3053(NP), Revision 4, Sequoyah HTP Fuel Transition - NRC RAIs and Responses, June 2012 (Non-Proprietary Version)

3. AREVA NP Affidavit cc (Enclosures):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Sequoyah Nuclear Plant Director, Division of Radiological Health - Tennessee State Department of Environment and Conservation

ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT UNITS I AND 2 ANP-3053(P), Revision 4, Sequoyah HTP Fuel Transition -

NRC RAIs and Responses, June 2012 (Proprietary Version)