ML23285A224

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Letter to Tennessee Valley Authority - Pre-application Readiness Assessment Plan (Clinch River CP Application)
ML23285A224
Person / Time
Site: 99902056
Issue date: 10/13/2023
From: Allen Fetter, Hayes M
NRC/NRR/DNRL/NLIB
To: Brian Mcdermott
Tennessee Valley Authority
References
Download: ML23285A224 (10)


Text

October 13, 2023 Mr. Brian McDermott, Director Licensing and Planning New Nuclear Program Tennessee Valley Authority 1101 Market Street LP 1G-C Chattanooga, TN 37402

SUBJECT:

PREAPPLICATION READINESS ASSESSMENT PLAN FOR THE TENNESSEE VALLEY AUTHORITY DRAFT CONSTRUCTION PERMIT APPLICATION, CLINCH RIVER NUCLEAR SITE

Dear Mr. McDermott:

As part of pre-application activities related to the development of Tennessee Valley Authoritys (TVAs) construction permit (CP) application for the Clinch River Nuclear (CRN) Site, TVA plans to make draft versions of preliminary safety analysis (PSAR) chapters available to U.S. Nuclear Regulatory Commission (NRC) staff. TVA initiated pre-application interactions with the NRC by letter dated February 23, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22055A738). NRC responded to TVA by letter dated October 27, 2022 (ML22285A027), outlining a plan for pre-application activities associated with the development of a CP application for the CRN Site. Consistent with this correspondence, TVA verbally requested that NRC staff conduct a pre-application readiness assessment of the draft CP application prior to its potential submittal in calendar year 2024.

The readiness assessment is not part of the NRCs official acceptance review process. The readiness assessment of the CRN Site draft CP application will allow the NRC staff to understand the level of detail in the draft application and identify any major issues or information gaps between the draft application and the technical content required to be included in the application submitted to the NRC. Therefore, the observations from the readiness assessment do not predetermine whether the application will be accepted and docketed for detailed review.

The attached readiness assessment plan provides the details and logistics of the readiness assessment activities.

B. McDermott If you have any questions regarding this matter, please contact Mr. Allen Fetter, Senior Project Manager, at (301) 415-8556 or by email at allen.fetter@nrc.gov.

Sincerely,

/RA/

Michelle W. Hayes, Chief New Reactor Licensing and Infrastructure Branch Division of New and Renewed Licenses Office of Nuclear Reactor Regulation Docket No.: 99902056

Enclosure:

Readiness Assessment Plan

ML23285A224

  • via email NRR-106 OFFICE DNRL/NLIB: PM DNRL/NLIB: LA DNRL/NLIB: BC NAME AFetter SGreen*

MHayes*

DATE 10/03/2023 10/12/2023 10/13/2023

Enclosure PREAPPLICATION READINESS ASSESSMENT PLAN OF THE TENNESSEE VALLEY AUTHORITY DRAFT CONSTRUCTION PERMIT APPLICATION October 2023 Docket No. 99902056 LOCATION TVA Electronic Reading Room (eRR)

PURPOSE Tennessee Valley Authority (TVA) has voluntarily agreed to engage with the U.S. Nuclear Regulatory Commission (NRC) staff in a preapplication readiness assessment (hereinafter readiness assessment) of the draft construction permit (CP) application before the application is submitted for a formal NRC review.

The readiness assessment will allow the NRC staff to:

Identify information gaps between the draft application and the technical content required in the application submitted to the NRC Identify major technical or policy issues that may adversely impact the docketing or technical review of the application Become familiar with the application, particularly in areas where TVA is proposing new concepts or novel regulatory approaches The observations from the readiness assessment will inform TVA in finalizing the CP application and will assist the NRC staff in planning NRC resources in preparation for the application review once the application is formally submitted.

BACKGROUND The safety-related chapters and sections of TVAs draft CP application (Preliminary Safety Analysis Report (PSAR)) will be located in TVAs electronic reading room (eRR), which has read only access. As part of established and ongoing pre-application engagement activities with NRC (see ML22055A738 and ML22285A027), TVA verbally requested that NRC staff conduct a pre-application readiness assessment of the draft CP application prior to its potential submittal in calendar year 2024.

The NRC plans to conduct the readiness assessment from October 2023 through January 2024.

SCOPE OF THE READINESS ASSESSMENT The readiness assessment of TVAs draft application will cover the draft CP PSAR Chapters 2 through 17. Chapter 1 will not be included.

INFORMATION AND OTHER MATERIAL NECESSARY FOR THE READINESS ASSESSMENT TVA will provide the full text of draft PSAR Chapters 2 through 17 in the eRR. If the NRC staff requests to see other supporting materials related to the readiness assessment, the NRC staff will coordinate such needs with TVA.

READINESS ASSESSMENT TEAM AND SCHEDULES The readiness assessment will be conducted in six phases. A breakdown of planned readiness assessment schedules1 and tables showing the associated chapters/sections and technical review areas and the responsible divisions/branches for each phase are shown below.

Readiness Assessment, Phase 1 October 16 - 31, 2023 Chapter/Section Division(s) - Branch(es) [NRR unless indicated otherwise]

13 - Conduct of Operations See below 13.1 - Organizational Structure DRO-IOLB 13.2 - Training DRO-IOLB 13.3 - Emergency Planning DPR-RLB [NSIR]

13.4 - Operational Programs DRO-IOLB 13.5 - Plant Procedures DRO-IOLB 13.6 - Security DPCP-RSB [NSIR]

13.7 - Fitness for Duty DPCP-RSB [NSIR]

14 - Initial Test Program DRO-IOLB; DEX-EMIB/EICB/ELTB 16 - Technical Specifications DSS-STSB; DEX-EEEB/EICB/ELTB 17 - Quality Assurance DRO-IQVB 1 Planned schedules may vary based on NRC staff availability and other resource factors.

Readiness Assessment, Phase 2 November 1 - December 1, 2023 Chapter/Section Division(s) - Branch(es) [NRR unless indicated otherwise]

3.3 - Wind and Tornado Loadings DEX-ESEB/EMIB/EXHB; DRA-APLC 3.4 - Water Level (Flood) Design DEX-EXHB/ESEB 3.7 - Seismic Design DEX-ESEB 3.8 - Design of Category I Structures DEX-ESEB 4 - Reactor Design DSS-SNRB 7 - Instrumentation and Controls DEX-EEEB/EICB/ELTB; DRO-IOLB 8 - Electric Power DEX-EEEB 10 - Steam and Power Conversion System DSS-SCPB 11 - Radioactive Waste Management DRA-ARCB

Readiness Assessment, Phase 3 November 13 - December 8, 2023 Chapter/Section Division(s) - Branch(es) [NRR unless indicated otherwise]

3.5 - Missile Protection DSS-SCPB 3.6 - Protection Against Dynamic Effects Associated with the Postulated Rupture of Piping DSS-SCPB 9.1 - Fuel Storage and Handling DSS-SCPB 9.2 - Water Systems DSS-SCPB Readiness Assessment, Phase 4 November 20 - December 15, 2023 Chapter/Section Division(s) - Branch(es) [NRR unless indicated otherwise]

3.9 - Mechanical Systems and Components DEX-EMIB/ELTB/EEEB 3.10 - Seismic and Dynamic Qualification of Mechanical and Electrical Equipment DEX-EMIB/ELTB/EEEB 3.11 - Environmental Qualification of Mechanical and Electrical Equipment DEX-EEEB/ELTB/EICB/EMIB; DRA-ARCB 3.12 - ASME BPV Code Class 1, 2, and 3 Piping Systems and Associated Support Design DEX-EMIB/ESEB 3.13 - Threaded FastenersASME BPV Code Class 1, 2, and 3 DNRL-NVIB; DEX-EMIB

Readiness Assessment, Phase 5 December 4, 2023 - January 14, 2024 Chapter/Section Division(s) - Branch(es) [NRR unless indicated otherwise]

3.1 - Conformance with US NRC General Design Criteria NLIB PM 3.2 - Classification of Structures, Systems, and Components DEX-EMIB/EXHB/ESEB/EEEB; DRA-APLC; DNRL-NPHP; DSS-SCPB 5 - Reactor Coolant System and Connected Systems DEX-EMIB; DSS-SNRB/SCPB; DNRL-NPHP/NCSG/NVIB 6 - Engineered Safety Features DNRL/NPHP/NVIB/NCSG; DSS-SCPB, SNSB; DRA-APLC 9.3 - Process Auxiliaries DSS-SCPB 9.4 - Air Conditioning, Heating, Cooling and Ventilation Systems DSS-SCPB 9.5 - Other Auxiliary Systems DRA-APLB; DEX-ELTB/EICB 9A - Fire Hazards Analysis DRA/APLB 15.1 - Increase in heat Removal Events DSS-SNSB/SNRB 15.2 - Decrease in Heat Removal Events DSS-SNSB/SNRB 15.4 - Reactivity and Power Distribution Anomalies DSS-SNSB/SNRB 15.6 - Decrease in Reactor Coolant Inventory DSS-SNSB/SNRB 15.7 - Radioactive Release from a Subsystem or Component (See SRP 15.0.3 and BTP 11.6)

DEX-EXHB; DRA-ARCB

Readiness Assessment, Phase 6 January 07 - 20, 2024 Chapter/Section Division(s) - Branch(es) [NRR unless indicated otherwise]

2.1 - Geography and Demography DEX-EXHB 2.3 - Meteorology DEX-EXHB 2.4 - Hydrologic Engineering DEX-EXHB 2.5 - Geology, Seismology and Geotechnical Engineering DEX-EXHB 12 - Radiation Protection DEX-EXHB LOGISTICS The readiness assessment will employ TVAs eRR and will be conducted in six phases (see tables above). Phase 1 of the readiness assessment is planned to begin the week of October 16, 2023. Each readiness assessment phase will begin with virtual entrance/orientation meeting and at the conclusion of Phase 6, there will be a virtual exit meeting to formally end the readiness assessment (currently scheduled to end in January 2024). The planned schedules for each phase are shown in the tables above.

NRC Review Approach NRC staff will focus on identifying and documenting technical and regulatory gaps in the draft CP PSAR chapter/sections. These gaps, and other observations relevant to application quality and completeness, will be shared with TVA at the end of each phase and will be compiled into a final readiness assessment letter to TVA after all the phases have been completed.

The NRC will conduct a streamlined readiness assessment that includes the following aspects:

This assessment will be conducted in accordance with NRR Office Instruction LIC-116, Preapplication Readiness Assessment (ML20104B698).

The content of a CP application will be informed by RG 1.70, Standard Format and Content of Safety Analysis Reports for Nuclear Power Plants, Revision 3 (ML011340122) and DNRL-ISG-2022-01, Safety Review of Light-Water Power Reactor Construction Permit Applications Interim Staff Guidance, October 2022 (ML22189A099).

The assessment of each phase is expected to be conducted in approximately two

weeks.

For each phase, the NRC will limit participation to targeted technical reviewers and will provide them specific charging codes.

At the start of each phase, TVA will provide a presentation to technical staff tailored to the specific Phase, Chapter, or Section.

During each phase, if the NRC is seeking additional clarity on the PSAR content, or would like to see additional material or provide immediate feedback, additional meetings with TVA may be requested.

At the end of each phase, the NRC will share assessment feedback with TVA.

NRC PMs will provide regular status updates to NRC management and TVA.

NRC will target to complete all phases of the readiness assessment by late January 2024.

READINESS ASSESSMENT OBSERVATIONS The NRC will send the readiness assessment observations, including any identified technical concerns or major information gaps, to TVA in a publicly available report that will also summarize the scope of the readiness assessment. NRC Office Instruction LIC-116 delineates the timeline for the final report which is to be completed within 45 calendar days of completion of the readiness assessment. The Readiness Assessment Team will endeavor to complete the final report as quickly as possible (in less than 45 days) using the streamlined process described above. To protect the applicants proprietary information, if needed, the staff will issue a proprietary version of the readiness assessment report. The staffs expectation is that TVA will consider the observations from the readiness assessment while finalizing the application and will reevaluate the application submission date based on its evaluation of the time to address the readiness assessment observations.

The NRC estimates that this readiness assessment will require approximately 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br /> by the staff to complete.