ML25239A046
| ML25239A046 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/27/2025 |
| From: | Kimberly Green NRC/NRR/DORL/LPL2-2 |
| To: | |
| Shared Package | |
| ML25239A041 | List: |
| References | |
| EPID L-2025-LRM-0106 | |
| Download: ML25239A046 (1) | |
Text
August 27, 2025 LICENSEE:
Tennessee Valley Authority FACILITY:
Sequoyah Nuclear Plant, Units 1 and 2
SUBJECT:
SUMMARY
OF AUGUST 20, 2025, PUBLIC TELECONFERENCE WITH TENNESSEE VALLEY AUTHORITY TO DISCUSS A PROPOSED LICENSE AMENDMENT REQUEST REGARDING REVISION TO TECHNICAL SPECIFICATION 5.5.3 FOR USE OF POTASSIUM HYDROXIDE (EPID L-2025-LRM-0106)
On August 20, 2025, the U.S. Nuclear Regulatory Commission (NRC) staff held a public meeting via teleconference with representatives of the Tennessee Valley Authority (TVA) to discuss a proposed license amendment request (LAR) for Sequoyah Nuclear Plant (SQN),
Units 1 and 2. The meeting notice and agenda for this meeting, dated August 1, 2025, are available at Agencywide Documents Access and Management System (ADAMS) Accession No. ML25218A171. The licensees slides for the meeting are available at ADAMS Accession No. ML25231A030. A list of the meeting attendees is enclosed.
TVA stated that it plans to submit an LAR for SQN, Units 1 and 2, that would revise Technical Specification (TS) 5.5.3, Radioactive Effluent Controls Program. The first-of-a-kind LAR for a North American pressurized-water reactor would allow for the application of specific International Commission on Radiological Protection (ICPR) publications and Federal Guidance Reports (FGRs) for the determination of dose coefficients to accommodate the use of potassium hydroxide (KOH) as a chemistry control additive to the reactor coolant system. The dose coefficients are required to evaluate compliance with the requirements of Title 10 of the Code of Federal Regulations, Part 20, Standards for Protection Against Radiation, and plant TSs that are required by 10 CFR 50.36a, and that apply design objectives for radiological effluents as described in Part 50, Domestic Licensing of Production and Utilization Facilities, Appendix I, Numerical Guides for Design Objectives and Limiting Conditions for Operation to Meet the Criterion As Low as is Reasonably Achievable for Radioactive Material in Light-Water-Cooled Nuclear Power Reactor Effluents.
TVA explained that the proposed LAR would support a revision of the SQN Offsite Dose Calculation Manual (ODCM) to account for the additional radionuclides that would be generated when using KOH. TVA noted that the proposed LAR would not change any of the existing requirements in SQN TS 5.5.1, Offsite Dose Calculation Manual (ODCM), nor would the proposed LAR apply to the determination of dose coefficients for any other radionuclides. The NRC staff inquired if TVA planned to provide a copy of the ODCM for information. TVA replied that it plans to submit only the pages that are affected by the LAR for information purposes only.
The proposed revision to TS 5.5.3 would be a paragraph at the end of the TS that states ICRP publications 72, 119, 144, and 151 and FRGs 12 and 15 may be used to determine dose coefficients for KOH-related radionuclides when evaluating compliance with 10 CFR Part 20 and 10 CFR Part 50, Appendix I. The NRC staff asked if TVA has considered listing the specific radionuclides in TS 5.5.3. TVA said that it does not see an issue with adding them to its proposed language updating TS 5.5.3. The NRC staff suggested that TVA consider using the statements that apply to licensee initiated changes to the ODCM from TS 5.5.1 as a template for the level of information to provide as a technical basis for the LAR. Additionally, the NRC staff cautioned TVA against adding effective dose values and whole body dose values together since these values have different meaning in the system of radiation protection. The staff further suggested that in the ODCM when demonstrating compliance with 10 CFR Part 50, Appendix I to keep the doses separate and draw qualitative comparisons with dose objectives instead of quantitative comparisons. The NRC staff also suggested that TVA consider using the phrasing in other paragraphs in TS 5.5.3, e.g., conforming to 10 CFR 50, Appendix I. The NRC staff noted that since the LAR is a first-of-a-kind, industry groups such as the Technical Specification Task Force or the Pressurized Water Reactor Owners Group may be helpful in crafting the proposed TS language.
During a previous public pre-submittal meeting on this subject (ML25139A516), the NRC staff asked a few questions of TVA. During the August 20th meeting, TVA provided responses as described in the meeting slides (ML25231A030). The NRC staff noted that it would be helpful to the staff if TVA included much of the information in the responses as supporting information in the LARthis will minimize the need for requests for additional information. The NRC staff informed TVA that the staff may need to conduct an audit of the analyses referenced in TVAs presentation that the Electric Power Research Institute (EPRI) performed.
TVA asked if the NRCs inspection procedures need to be updated for the use of KOH. The NRC staff said that the procedures themselves are written at a level of detail that can accommodate the licensees proposed change but that additional guidance may need to be provided for inspection staff.
TVA plans to submit the LAR by September 30, 2025.
No regulatory decisions were made at this meeting.
No comments or public meeting feedback forms were received.
Please direct any inquiries to me at 301-415-1627 or Kimberly.Green@nrc.gov.
/RA/
Kimberly J. Green, 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 AUGUST 20, 2025, TELECONFERENCE WITH TENNESSEE VALLEY AUTHORITY PROPOSED LICENSE AMENDMENT REQUEST REGARDING REVISION TO TS 5.5.3 FOR USE OF POTASSIUM HYDROXIDE SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 Name Organization Kim Green U.S. Nuclear Regulatory Commission (NRC)
David Wrona NRC Kevin Hsueh NRC David Garmon NRC Bill Rautzen NRC Clint Ashley NRC Matt Yoder NRC Andrea Russell NRC Adam Nielsen NRC Andy Rosebrook NRC Jesse Baron Tennessee Valley Authority (TVA)
Amber Aboulfaida TVA Andy Taylor TVA Andy McNeil TVA Travis Markum TVA Jeff Sowa TVA Chad Dozier TVA Austin Miller TVA Marsha Johnson TVA Kyle Cothran TVA Amy Stubblefield TVA William Trexler TVA Zachary Kitts TVA Karina Nigmatullina TVA Keith Fruzzetti Electric Power Research Institute(EPRI)
David Perkins EPRI Ed Everett American Nuclear Insurers
ML25239A041 (Package)
ML25231A030 (Slides)
ML25218A171. (Meeting Notice)
ML25239A046 (Meeting Summary)
- via eConcurrence NRC-001 OFFICE NRR/DORL/LPL2-2/PM NRR/DORL/LPL2-2/LA NRR/DORL/LPL2-2/BC NRR/DORL/LPL2-2/PM NAME KGreen ABaxter DWrona KGreen DATE 8/26/2025 8/27/2025 8/27/2025 8/27/2025