ML20203M229

July 16, 2020, Summary of Partially Closed Meeting with Tennessee Valley Authority to Discuss Responses to Requests for Additional Information Regarding Updated Final Safety Analysis Report Hydrologic Analysis License Amendment Request

ML20203M229
Person / Time
Site:	Sequoyah
Issue date:	08/11/2020
From:	Michael Wentzel Plant Licensing Branch II
To:
Wentzel M
Shared Package
ML20203M239	List: ML20203M229
References
EPID L-2020-LLA-0004
Download: ML20203M229 (4)

Text

August 11, 2020 LICENSEE:

Tennessee Valley Authority FACILITY:

Sequoyah Nuclear Plant, Units 1 and 2

SUMMARY

OF JULY 16, 2020, PARTIALLY CLOSED MEETING WITH TENNESSEE VALLEY AUTHORITY TO DISCUSS RESPONSES TO REQUESTS FOR ADDITIONAL INFORMATION REGARDING UPDATED FINAL SAFETY ANALYSIS REPORT HYDROLOGIC ANALYSIS LICENSE AMENDMENT REQUEST (EPID L-2020-LLA-0004)

On July 16, 2020, the U.S. Nuclear Regulatory Commission (NRC) staff held a partially closed meeting with representatives of Tennessee Valley Authority (the licensee) to discuss the licensees plan for responding to the staffs July 1, 2020, request for additional information (RAI); Agencywide Documents Access and Management System (ADAMS) Accession No. ML20189A211) issued in response to the licensees request to modify the Sequoyah Nuclear Plant, Units 1 and 2 (Sequoyah), Updated Final Safety Analysis Report hydrologic analysis. The meeting was partially closed to allow for the discussion of proprietary information.

The meeting notice and agenda for this meeting, dated July 6, 2020, are available at ADAMS Accession No. ML20188A366. The licensees non-proprietary slides for the meeting are available at ADAMS Accession No. ML20203M057. A list of attendees is enclosed. No regulatory decisions were made at this meeting.

During the open portion of the meeting, the licensee described its approach to responding to Question 1 of the NRC staffs RAI, as outlined in its meeting slides. The NRC staff had no questions or comments on the licensees presentation. The meeting then transitioned to the closed session to discuss the NRC staff questions that contained proprietary information. The discussion during this part of the meeting primarily focused on the NRC staffs questions related to the use of Microsoft Excel Visual Basic for Applications (VBA) macros to verify the output of the Probable Maximum Precipitation (PMP) Evaluation Tool as part of the commercial grade dedication of this tool. The software dedication report (SDR) for the PMP Evaluation Tool indicated that the Excel VBA macros were created under the third-party (Barge Design Solutions) dedicating entitys Appendix B to Title 10 of the Code of Federal Regulations, Part 50-compliant quality assurance (QA) program. During the public meeting, the NRC staff requested the licensee and its contractor, Barge Design Solutions, to clarify whether the functionality of the Excel VBA macros were derived from the licensees technical requirements for the procurement of the required software tool. Barge Design Solutions stated that these VBA macros were developed based on its review of the software code for the PMP Evaluation Tool and not based on the technical requirements specified for the required tool. The NRC staff stated that because the Excel VBA macros were developed based on reviewing the software code of the PMP Evaluation Tool, any errors in the translation of the technical requirements to the tools software code could also exist in the Excel VBA macros. Therefore, the ability of the Excel VBA macros to verify the output of the PMP Evaluation Tool is limited. In addition, the NRC staff asked whether the documentation to demonstrate that these Excel VBA macros were developed under Barge Design Solutions Appendix B compliant QA program was available for NRC staff to review. Barge Design Solutions stated that although the SDR for the PMP Evaluation Tool indicated that these Excel VBA macros were developed under Barge Design Solutions Appendix B compliant QA program, these macros were not developed in accordance with the processes and procedures of Barge Design Solutions QA program. Barge Design Solutions stated that its rationale was that these macros do not perform a safety function and are only intended to be used as an alternate method for verifying the output of the PMP Evaluation Tool. The NRC staff informed Barge Design Solutions and the licensee that because the Excel VBA macros were not developed in accordance with the processes and procedures of Barge Design Solutions QA program, the quality of these macros cannot be verified by the NRC staff. In addition, this information appears to directly contradict statements in the SDR regarding the development of these macros under Barge Design Solutions Appendix B-compliant QA program.

Due to the complexity of this issue, the NRC staff and the licensee agreed that a separate closed meeting would be necessary to continue the discussion of this particular issue.

Regarding the plan for responding to the RAIs, the NRC staff and the licensee agreed that an acceptable approach would be for the licensee respond to Question 1 of the staffs RAI, but defer the response to Question 2 until after the follow-on meeting.

No members of the public were in attendance and no comments or public meeting feedback forms were received.

Please direct any inquiries to me at 301-415-6459 or Michael.Wentzel@nrc.gov.

/RA/

Michael J. Wentzel, Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosure:

List of Attendees cc: Listserv

Enclosure LIST OF ATTENDEES JULY 16, 2020, PARTIALLY CLOSED MEETING WITH TENNESSEE VALLEY AUTHORITY REGARDING THE UPDATED FINAL SAFETY ANALYSIS REPORT HYDORLOGIC ANALYSIS LICENSE AMENDMENT REQUEST FOR SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 Name Organization K. Quinlan U.S. Nuclear Regulatory Commission (NRC)

M. Wentzel NRC D. Zhang NRC S. DeNeale Oak Ridge National Laboratory S. Kao Oak Ridge National Laboratory D. Lundy Tennessee Valley Authority (TVA)

W. Nesmith TVA P. Selman TVA B. Simril TVA T. Spink TVA A. Taylor TVA R. Wells TVA G. Williams TVA H. Smith-Sawyer Barge Design Solutions S. Henry Barge Design Solutions T. Cropp Barge Design Solutions R. Blackwell Barge Design Solutions

ML20203M229

• via e-mail OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA* NRR/DORL/LPL2-2/BC* NRR/DORL/LPL2-2/PM NAME MWentzel BAbeywickrama UShoop MWentzel DATE 07/24/2020 07/23/2020 08/10/2020 08/11/2020