Text

TVA Fleet License Amendment Request to Adopt TSTF-596-A and TSTF-600-A, Revision 2, Meeting Slides
	ML25325A153
Person / Time
Site:	Browns Ferry, Watts Bar, Sequoyah
Issue date:	12/01/2025
From:	Kimberly Green; Plant Licensing Branch II
To:	Jim Barstow; Tennessee Valley Authority
	Green K
References
	TSTF-596-A, TSTF-600-A
	Download: ML25325A153 (1)
	v • d • e

TVA Fleet License Amendment Request to Adopt TSTF-596-A, Revision 2, "Expand the Applicability of the Surveillance Frequency Control Program (SFCP)," and TSTF-600-A, Revision 2, Revise the Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) Leakage Testing Frequency December 01, 2025

Agenda Introduction

Background

TSTF-596 and Key Variations TSTF-600 (WBN Only)

TSTF-374-A and TSTF-118-A (WBN only)

No Significant Hazards Considerations Analysis Schedule for Submittal l 2

Introduction Tennessee Valley Authority (TVA) is submitting a license amendment request (LAR) for the Renewed Facility Operating License Nos. DPR-33, DPR-52, and DPR-68 for the Browns Ferry Nuclear Plant (BFN), Units 1, 2, and 3, Renewed Facility Operating License Nos. DPR-77 and DPR-79 for the Sequoyah Nuclear Plant (SQN), Units 1 and 2 and Facility Operating License Nos. NPF-90 and NPF-96 for the Watts Bar Nuclear Plant (WBN), Units 1 and 2, respectively.

TVA requests adoption of TSTF-596-A, Revision 2, "Expand the Applicability of the Surveillance Frequency Control Program (SFCP)," for the BFN Units 1, 2, and 3 Technical Specifications (TS), SQN Units 1 and 2 TS, and the WBN Units 1 and 2 TS. TSTF-596-A expands the applicability of the Surveillance Frequency Control Program (SFCP) to include other periodic testing frequencies in the Technical Specifications (TS).

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Introduction TSTF-596-A also revises the SFCP to reference additional regulatory mechanisms that may be used to control Surveillance Frequencies, such as 10 CFR 50.55a and 10 CFR 50.69. The proposed change revises Surveillance Requirements (SRs) that reference the Inservice Testing (IST)

Program to instead reference the SFCP for BFN, SQN, and WBN.

The proposed change also incorporates TSTF-374-A, Revision 0, Revision to TS 5.5.13 and associated TS Bases for Diesel Fuel Oil, TSTF-118-A, Revision 0, Administrative Controls Program Exceptions, and TSTF-600-A, Revision 2, Revise the Reactor Coolant System (RCS) Pressure Isolation Valve (PIV) Leakage Testing Frequency, for the WBN Units 1 and 2 TS.

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Background===

TSTF-596-A was approved by the Nuclear Regulatory Commission (NRC) on December 30, 2024 (ML24362A054)

TSTF-600-A was approved by the NRC on September 8, 2025 (ML25247A238)

TSTFs 118 and 374 revise Westinghouse Standard TS (STS) 5.5.13, which is equivalent to WBN Units 1 and 2 TS 5.7.2.16.

TSTF-118-A was approved by the NRC on March 13, 1997. The NRC did not issue a letter approving TSTF-118-A, however it was incorporated by the NRC into Revision 2 of the ISTS NUREGs.

TSTF 374-A was approved by the NRC on May 17, 2006 (ML061040356),

which included a model Safety Evaluation (SE) and a model application and noted that applications would be reviewed under the Consolidated Line Item Improvement Process (CLIIP).

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TSTF-596 Key Variations Common to SQN and WBN

TVA is proposing to revise SQN Units 1 and 2 and WBN Units 1 and 2 SR 3.4.14.1 Frequency from In accordance with the Inservice Testing Program to In accordance with the Surveillance Frequency Control Program.

NRC License Amendments 370 and 364 for SQN Units 1 and 2, respectively (ML25027A314 dated March 6, 2025), revised the Frequency of SQN Units 1 and 2 SR 3.4.14.1 to be solely in accordance with the Inservice Testing Program and deleted the condition based frequencies and reference to the SFCP. This is consistent with TSTF-600-A, Revision 2, which revises Westinghouse STS SR 3.4.14.1 to be solely in accordance with the Inservice Testing Program.

TSTF-596-A revises Westinghouse STS SR 3.4.14.1 to eliminate the reference to the IST Program and retain the reference to the SFCP and the other condition based frequencies.

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TSTF-596 Key Variations Common to SQN and WBN

As noted in TSTF-600-A Section 2.4, Description of the Proposed Change:

Plants that have adopted TSTF-596, Revision 2, "Expand the Applicability of the Surveillance Frequency Control Program (SFCP)," (ADAMS Accession No. ML24362A054) will use a Frequency of "In accordance with the Surveillance Frequency Control Program." Under TSTF-596, references to the Inservice Testing Program are replaced with references to the SFCP. The TS Section 5.5, "Surveillance Frequency Control Program," references 10 CFR 50.55a(f) (the Inservice Testing Program) for the applicable SRs, such as the RCS PIV SR. This is an administrative difference that does not affect the justification for TSTF-600.

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SQN SR 3.4.14.1 l 8

WBN SR 3.4.14.1 l 9

TSTF-596 Key Variations Common to SQN and WBN

The SQN and WBN TS do not include the changes in TSTF-545. As a result, the SQN and WBN TS include a TS Section 5.5.6 (SQN) and 5.7.2.11 (WBN),

"Inservice Testing Program," and do not include a defined term, "INSERVICE TESTING PROGRAM." As discussed in TSTF-596-A, the proposed change removes TS Section 5.5, "Inservice Testing Program," in addition to making the other changes described in the traveler. Furthermore, Section 3.6 of TSTF-596-A states Licensees that have not adopted TSTF-545 may adopt the proposed traveler and delete the TS Section 5.5, Inservice Testing Program without adding the defined term, INSERVICE TESTING PROGRAM, that is eliminated by this traveler.

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Therefore, SQN TS 5.5.6 and WBN TS 5.7.2.11, Inservice Testing Program, are being deleted consistent with the Westinghouse STS and TSTF-545, Revision 3. However, the titles of SQN TS 5.5.6 and WBN TS 5.7.2.11 are being revised to state Inservice Testing Program (see Section 5.5.17), and Inservice Testing Program (see Section 5.7.2.23), respectively, in order to avoid the numerous procedure changes with the STS revision. Additionally, the definition of the IST program is being added to SQN Units 1 and 2 TS 5.5.6 and WBN Units 1 and 2 TS 5.7.2.11 for consistency with BFN TS 1.1. Furthermore, the verbiage that SR 3.0.3 is applicable to inservice testing activities is being retained in SQN Units 1 and 2 TS 5.5.6 and WBN Units 1 and 2 TS 5.7.2.11.

l 11 TSTF-596 Key Variations Common to SQN and WBN

SQN TS 5.5.6 l 12 WBN TS 5.7.2.11

TSTF-596-A revises TS 5.5.16, Surveillance Frequency Control Program, of the BWR/4 STS, which is numbered as TS 5.5.15 in the BFN TS. TSTF-596-A also revises Westinghouse STS 5.5.19, Surveillance Frequency Control Program, which is numbered as TS 5.5.17 in the SQN Units 1 and 2 TS and TS 5.7.2.23 in the WBN Units 1 and 2 TS.

These are non-technical variations to the traveler. TVA is also revising BFN TS 5.5.15, SQN Units 1 and 2 TS 5.5.17, and WBN Units 1 and 2 TS 5.7.2.23 as follows:

The verbiage in BFN TS 5.5.15.a, SQN Units 1 and 2 TS 5.5.17.a, and WBN Units 1 and 2 TS 5.7.2.23.a is revised as follows (changes indicated in bold italics):

The Surveillance Frequency Control Program shall contain a list of Frequencies controlled by the programs that govern the activities listed in items b.1, b.2, and b.3.

Item b.1 refers to the IST program by 10 CFR 50.55a(f), item b.2 refers to 10 CFR 50.69(d)(2) for testing permitted under 10 CFR 50.69(b)(1)(v); and item b.3 refers to the SFCP frequencies that are in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

l 13 TSTF-596 Key Variations Common to BFN, SQN and WBN

l 14 TSTF-596 Key Variations Common to BFN, SQN and WBN (BFN TS 5.5.15.a, SQN TS 5.5.17.a, WBN TS 5.7.2.23.a)

The proposed change to BFN TS 5.5.15.a, SQN Units 1 and 2 TS 5.5.17.a, and WBN Units 1 and 2 TS 5.7.2.23.a, as shown on the previous page, is to ensure that the SFCP program is not required to include a list of the IST program frequencies that are TS related. The implementing SFCP procedures will have to list each SR that references the SFCP, but for those SRs that are in scope of the IST program, the implementing SFCP procedures can simply reference the IST Program procedure number and not list all of the associated IST Program frequencies. The same rationale applies to the SFCP frequencies that are controlled by 10 CFR 50.69(d)(2) for testing permitted under 10 CFR 50.69(b)(1)(v) (i.e., the SFCP would refer to the implementing program for those activities).

l 15 TSTF-596 Key Variations Common to BFN, SQN and WBN

BFN TS 5.5.15.b.1, SQN Units 1 and 2 TS 5.5.17.b.1, and WBN Units 1 and 2 TS 5.7.2.23.b.1 are being slightly revised to state (as shown in bold italics): In accordance with the requirements for the inservice testing program required by 10 CFR 50.55a(f). This change is to clearly identify that this TS requirement applies to the IST program governed by 10 CFR 50.55a(f).

BFN TS 5.5.15.b.2, SQN Units 1 and 2 TS 5.5.17.b.2, and WBN Units 1 and 2 TS 5.7.2.23.b.2 are being slightly revised to remove the reference to the inservice testing program required by 10 CFR 50.55a(f), because the changes to the SFCP, in accordance with 10 CFR 50.55a(f), is addressed in the above proposed revision to BFN TS 5.5.15.b.1, SQN Units 1 and 2 TS 5.5.17.b.1, and WBN Units 1 and 2 TS 5.7.2.23.b.1.

l 16 TSTF-596 Key Variations Common to BFN, SQN and WBN

l 17 TSTF-596 Key Variations Common to BFN, SQN and WBN (BFN TS 5.5.15.b, SQN TS 5.5.17.b, WBN TS 5.7.2.23.b)

TSTF-596-A adds new BWR/4 STS 5.5.16.c.1 and Westinghouse STS 5.5.19.c.1, which states: For testing required by 10 CFR 50.55a(f), Surveillance Requirement 3.0.2 is only applicable as permitted by that regulation.

The regulations in 10 CFR 50.55a(f) require that inservice testing be performed in accordance with American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants (OM Code). OM Code Section ISTA-3170, Inservice Examination and Test Frequency Grace, allows test frequencies to be extended similar to the requirements of SR 3.0.2.

Therefore, because the ASME OM Code reflects the requirements of BWR/4 STS 5.5.16.c.1 and Westinghouse STS 5.5.19.c.1, TVA is not incorporating this change in BFN TS 5.5.15, SQN Units 1 and 2 TS 5.5.17, and WBN Units 1 and 2 TS 5.7.2.23.

Accordingly, proposed BWR/4 STS 5.5.16.c.2 and Westinghouse STS 5.5.19.c.2, which addresses SR 3.0.3, are being merged with the text of BFN TS 5.5.15.c, SQN Units 1 and 2 TS 5.5.17.c, and WBN Units 1 and 2 TS 5.7.2.23.c.

l 18 TSTF-596 Key Variations Common to BFN, SQN and WBN

l 19 TSTF-596 Key Variations Common to BFN, SQN and WBN (BFN TS 5.5.15.c, SQN TS 5.5.17.c, WBN TS 5.7.2.23.c)

l 20 Revised BFN TS 5.5.15.d

BFN TS 5.5.15.d is being added to state: The provisions of SR 3.0.3 are applicable to inservice testing activities. These provisions were previously in the BWR/4 STS Chapter 5 for the Inservice Testing Program that was deleted in TSTF-545. The proposed changes provide assurance that the provisions of SRs 3.0.2 and 3.0.3 will remain applicable to the BFN IST program. Similar changes are not needed to SQN Units 1 and 2 TS 5.5.17, and WBN Units 1 and 2 TS 5.7.2.23 because TVA is retaining similar verbiage regarding SR 3.0.3 in the SQN and WBN Chapter 5 TS for the IST program (i.e., SQN Units 1 and 2 TS 5.5.6 and WBN Units 1 and 2 TS 5.7.2.11).

l 21 Revised BFN TS 5.5.15, SQN TS 5.5.17, and WBN TS 5.7.2.23 (variations highlighted in yellow)