ML25052A088
| ML25052A088 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah, Watts Bar  |
| Issue date: | 02/27/2025 |
| From: | Kimberly Green Plant Licensing Branch II |
| To: | Hulvey K Tennessee Valley Authority |
| References | |
| EPID L-2024-LLA-0147 | |
| Download: ML25052A088 (1) | |
Text
February 27, 2025 Kimberly D. Hulvey General Manager, Nuclear Regulatory Affairs
& Emergency Preparedness Tennessee Valley Authority 1101 Market Street, LP 4B-C Chattanooga, TN 37402-2801
SUBJECT:
SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2; WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2 - REGULATORY AUDIT PLAN IN SUPPORT OF LICENSE AMENDMENT REQUEST TO USE ONLINE MONITORING METHODOLOGY (EPID L-2024-LLA-0147)
Dear Kimberly Hulvey:
By letter dated November 4, 2024, the Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) for Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2. The proposed LAR would revise each units Technical Specification (TS) 1.1, Use and Application Definitions, and add new Sequoyah, Units 1 and 2, TS 5.5.19, Online Monitoring Program, and new Watts Bar, Units 1 and 2, TS 5.7.2.24, Online Monitoring Program.
The U.S. Nuclear Regulatory Commission (NRC) staff has identified the need for a regulatory audit to examine TVAs non-docketed information with the intent to gain understanding, to verify information, and to identify information that will require docketing to support the basis of the licensing or regulatory decision.
The NRC staff will conduct the audit virtually via Teams using an electronic portal established by TVA available to NRC staff from approximately March 17 through May 31, 2023, with formal audit meetings to be scheduled during this period as needed. The NRC staff reserves the right to extend the audit, if necessary. The detailed audit plan is enclosed with this letter.
If you have any questions, please contact me at 301-415-1627 or by e-mail at Kimberly.Green@nrc.gov.
Sincerely,
/RA/
Kimberly J. Green, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-327, 50-328, 50-390 and 50-391
Enclosure:
Audit Plan cc: Listserv
Enclosure REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF LICENSE AMENDMENT REQUEST TO USE ONLINE MONITORING METHODOLOGY TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 WATTS BAR NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-390 AND 50-391
1.0 BACKGROUND
By letter dated November 4, 2024, the Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) for Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2 (Agencywide Documents Access and Management System Accession No. ML24309A061). The proposed LAR would revise each units Technical Specification (TS) 1.1, Use and Application Definitions, and add new Sequoyah, Units 1 and 2, TS 5.5.19, Online Monitoring Program, and new Watts Bar, Units 1 and 2, TS 5.7.2.24, Online Monitoring Program.
TVA proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The proposed LAR is based on the U.S. Nuclear Regulatory Commission (NRC)-approved Analysis and Measurement Services Corporation (AMS) topical report (TR) AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (ML21235A493).
Staff from the NRCs Office of Nuclear Reactor Regulation (NRR) has initiated its review of the LAR in accordance with office instruction LIC-101, License Amendment Review Procedures (ML19248C539).
2.0 REGULATORY AUDIT BASIS A regulatory audit is a planned license-or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with the LAR. An audit is conducted to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. An audit will assist the NRC staff in efficiently conducting its review and gaining insights to TVAs processes and procedures. Information identified during the audit that the NRC staff relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits (ML19226A274), with exceptions noted within this audit plan.
The NRC staff will perform the audit to support its evaluation of whether TVAs LAR can be approved per Title 10 of the Code of Federal Regulations (10 CFR), Section 50.90, Application for amendment of license, construction permit, or early site permit. The staffs review of the LAR will be informed by NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants. The audit will assist the staff with understanding TVAs proposed OLM program.
3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY The scope of the NRC staffs audit will focus on the following subjects:
Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the NRC staffs understanding of the LAR.
Gain a better understanding of plant design features and their implications for the LAR.
Identify any information needed to enable the NRC staffs evaluation of the technical basis used for this application.
Identify any information needed to enable the NRC staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis functions.
Identify questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information (ML21141A238).
The NRC staff will audit the technical information and methods that the licensee used to determine the impact on the plant, and the licensees evaluation of defense-in-depth.
4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT The NRC staff will request information and audit meetings throughout the audit period. The NRC staff will use an audit items list to identify the information to be audited (e.g., methodology, process information, and calculations) to be audited. The NRC staff will document the final audit items list as an enclosure to the audit summary report, which will be publicly available. The attachment to this audit plan includes the initial audit items list. Throughout the audit period, the NRC staff will provide TVA with audit questions and audit-related requests so that it can better prepare for audit discussions with NRC staff.
The NRC staff requests that TVA have the information referenced in the attachment of this audit plan available and accessible for staffs viewing via a Web-based portal within 2 weeks of the date of this audit plan. The staff requests that any supplemental information requested be available and accessible for the staffs viewing within 1 week of the date of the NRCs notification to TVA of the new request.
5.0 TEAM ASSIGNMENTS The following table identifies the NRC audit team members, including contractors, and their respective focus areas:
Name Email Organization Kimberly Green Kimberly.Green@nrc.gov Plant Licensing Branch LPL II-2 (LPL2-2)
Gilberto Blas Gilberto.BlasRodriguez@nrc.gov Instrumentation and Controls Branch (EICB)
Fredrick OBrien Fredrick.OBrien@nrc.gov Instrumentation and Controls Branch (EICB)
Aaron Armstrong Aaron.Armstrong@nrc.gov Quality Assurance and Vendor Inspection Branch (IQVB)
Tarico Sweat Tarico.Sweat@nrc.gov Technical Specifications Branch (STSB) 6.0 LOGISTICS To support the review schedule communicated to TVA when the NRC staff accepted the LAR for technical review, audit activities will be performed remotely and virtually using Microsoft Teams, teleconference, and an online Web-based portal or other virtual meeting space created by TVA. The NRC staff information requests and communications with licensee staff will be coordinated through the NRCs licensing project manager.
A desktop audit will take place between March 17 and May 30, 2025. The NRCs licensing project manager will inform the licensee of the entrance and exit meeting dates when they are established. The NRC project manager will coordinate with TVA to set dates and times to discuss information needs and questions arising from the NRCs audit of the information. The NRC staff may change and/or add audit dates and times when deemed necessary. Audit meeting agenda and questions, if needed, will be sent in advance of the audit meeting.
7.0 SPECIAL REQUESTS The NRC requests access to requested documents and information through an online Web-based portal that allows the NRC staff to access documents. The following conditions associated with the portal should be maintained while the NRC staff and contractors have access to the portal:
The portal will be password-protected. A separate password will be assigned to each member of the NRC staff and NRC contractors participating in the audit.
The portal should prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.
Conditions of use of the portal will be displayed on the login screen and will require acknowledgment by each user.
TVA should provide the username, password, and other portal access information directly to members of the NRC audit team. The names and contact information of the NRC staff participating in the audit are provided in the table in section 5 above. All other communications should be coordinated through the NRC project manager. The NRC project manager will inform TVA via routine communications when the NRC staff no longer needs access to the electronic portal.
8.0 DELIVERABLES The NRC staff will issue an audit summary report within approximately 90 days after the end of the audit and prior to completing its safety evaluation of the LAR. The staff may request additional information needed to complete the review of the LAR but will issue any such RAIs separately from audit-related correspondence in accordance with NRR Office Instruction LIC-115.
Attachment:
OLM Audit Items List
Attachment OLM AUDIT ITEMS LIST Item #
Audit Item 1
AMS Report SYA2307R0, OLM Amenable Transmitters Report for Sequoyah Units 1 and 2 2
AMS Report WBR2302R0, OLM Amenable Transmitters Report for Watts Bar Units 1 and 2 3
AMS Report SYA2308R0, OLM Analysis Methods and Limits Report for Sequoyah Units 1 and 2 4
AMS Report WBR2303R0, OLM Analysis Methods and Limits Report for Watts Bar Units 1 and 2 5
AMS Report SYA2309R0, OLM Drift Monitoring Program Report for Sequoyah Units 1 and 2 6
AMS Report WBR2304R0, OLM Drift Monitoring Program Report for Watts Bar Units 1 and 2 7
AMS Procedure OLM2201R0, Procedure for Online Monitoring Data Retrieval, December 2022 8
AMS Procedure OLM2202R1, Procedure for Performing Online Monitoring Data Qualification and Analysis, August 2024 9
AMS Report SYA2310R0, OLM Noise Analysis Program Report for Sequoyah Units 1 and 2 10 AMS Report WBR2305R0, OLM Noise Analysis Program Report for Watts Bar Units 1 and 2 11 AMS Procedure NPS1501R0, Procedure for Noise Data Collection from Plant Sensors, March 2015 12 AMS Procedure NAR2201R1, Procedure for Performing Dynamic Failure Mode Assessment Using Noise Analysis, August 2024
ML25052A088 OFFICE NRR/DORL/LPLII-2 NRR/DORL/LPLII-2/LA NRR/DEX/EICB/BC NRR/DRO/IQVB/BC NAME KGreen ABaxter (SLent for)
FSacko KKavanagh DATE 02/19/2025 02/24/2025 02/26/2025 02/25/2025 OFFICE NRR/DSS/STSB/BC NRR/DORL/LPLII-2/BC NRR/DORL/LPLII-2/PM NAME SMehta DWrona KGreen DATE 02/25/2025 02/26/2025 02/27/2025