ML26083A330
| ML26083A330 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  (DPR-077, DPR-079) |
| Issue date: | 03/24/2026 |
| From: | Kimberly Green NRC/NRR/DORL/LPL2-2 |
| To: | Taylor A Tennessee Valley Authority |
| Shared Package | |
| TS 5.5.3 | List: |
| References | |
| EPID L-2026-LLA-0006 TS 5.5.3 | |
| Download: ML26083A330 (0) | |
Text
From:
Kimberly Green To:
Taylor, Andrew Charles Cc:
Subject:
Audit Plan Related to the Review of Sequoyah Nuclear Plant, Units 1 and 2, Revision to TS 5.5.3, "Radioactive Effluent Controls Program" (EPID L-2026-LLA-0006)
Date:
Tuesday, March 24, 2026 10:33:00 AM Attachments:
Audit Plan - TS 5.5.3 LAR re KOH.pdf
Dear Mr. Taylor:
By application dated January 15, 2026 (Agencywide Documents Access and Management System Accession No. ML260015A134), pursuant to Section 50.90 of Title 10 of the Code of Federal Regulations (10CFR), the Tennessee Valley Authority (TVA) submitted a license amendment request (LAR) to amend Renewed Facility Operating Licenses Nos.
DPR-77 and DPR-79 for the Sequoyah Nuclear Plant (SQN), Units 1 and 2, respectively.
The proposed amendments would revise each units Technical Specification 5.5.3, Radioactive Effluent Controls Program, to allow the use of International Commission on Radiological Protection (ICRP) publications 72, 119, 144, along with Environmental Protection Agency Federal Guidance Report (FGR) methodologies FGR-12 and FGR-15 for the purpose of determining dose coefficients for potassium hydroxide-related radionuclides.
The U.S. Nuclear Regulatory Commission staff is reviewing the proposed changes and has determined that a regulatory audit will provide efficiency and allow the NRC staff to view supporting documents.
Attached, please find a simplified audit plan that identifies the information needs, audit team members, and logistics. The deliverable for this audit will be an audit summary report that will be issued on or before the issuance of any amendments related to this request.
If you have any questions, please let me know.
Sincerely, Kimberly Green Senior Project Manager Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 301-415-1627
OFFICE OF NUCLEAR REACTOR REGULATION AUDIT PLAN This audit is being conducted to gain an understanding, verify information, and/or identify information that should be docketed to support the NRC staffs regulatory decision. The audit will be conducted in accordance with NRR Office Instructions LIC-111, Regulatory Audits.
EPID No.
L-2026-LLA-0006 Project Name Revise TS 5.5.3 Radioactive Effluents Control Program for Potassium Hydroxide Application Date 01/15/2026 Accession No. ML26015A134 Licensee Tennessee Valley Authority Docket No(s).
50-327, 50-328 Type of Audit In Person Virtual/Remote Desktop If virtual/remote audit is selected, the audit will be conducted using a secure, online electronic portal established by the licensee or its vendor. The portal must be password protected or secured by use of multifactor authentication.
The portal must prevent NRC participants or its contractors from printing, saving, copying, downloading, and collecting any information directly from the portal. Conditions of the use of the portal should be displayed at the login screen or appropriate location and acknowledged by each NRC participant or its contractor. Login information should be provided directly to the individuals listed in the Audit Teams Member Section below.
Audit Start Date 4/20/2026 or when documents have been placed on the electronic reading room Audit End Date 4/24/2026 Audit Team Members (List Names and E-mail addresses)
Name/Position Email Kimberly Green, Project Manager Kimberly.Green@nrc.gov Bill Rautzen, ARCB Technical Reviewer William.Rautzen@nrc.gov Clint Ashley, STSB Technical Reviewer Clinton.Ashley@nrc.gov
2 Audit Documents or Questions Documents:
- 1. The procedures mentioned in section 2.1 of the license amendment request (LAR) that implement the Offsite Dose Calculation Manual (ODCM).
- 2. Any procedures or other Sequoyah Nuclear Plant (SQN) documents that support the statement from LAR section 3.0:
The SQN radiological protection program sufficiently addresses these described anticipated effects of KOH [potassium hydroxide] implementation.
Reference:
LAR section 3.0).
- 4. Any operating procedures for controlling effluents and utilizing radioactive waste systems at SQN (
Reference:
LAR section 4.0)
- 5. The following documents from LAR section 6.0:
Reference 2: Proposed Cl-K Dose Conversion Factors Considerations for Potassium Generated Radionuclides: Application of ICRP-72 and ICRP-119 Dose Conversion Factors to Support KOH Addition and the Radiological Environmental Monitoring Program Dose Calculations. EPRI, Palo Alto, CA: 2025. 3002032484.
Reference 3: PWR Argon Effluent Release Mechanisms and Impacts on Dose Rates Due to Potassium Hydroxide Injection: Proposed Argon Dose Conversion Factor Considerations. EPRI, Palo Alto, CA: 2025. 3002031977.
Reference 5: Use of Potassium Hydroxide in Western-Design Pressurized Water Reactors:
Chemistry and Radiation Safety Assessments. EPRI, Palo Alto, CA: 2019. 3002015902.
Questions:
- 1. During the pre-application meeting on August 20, 2025, the NRC staff cautioned TVA against adding effective dose values together since these values have different meaning in the system of radiation protection. The NRC 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 (ML25239A046).
The January 15, 2026, LAR (ML26015A134) does not provide a discussion of how SQN will demonstrate compliance with 10 CFR Part 20, 10 CFR Part 50, Appendix I, and 40 CFR 190 regarding the above statement. Provide a discussion of how radionuclide doses calculated with the proposed dose coefficients will be qualitatively compared to the doses currently being calculated to show compliance with 10 CFR Part 20, 10 CFR Part 50, Appendix I, and 40 CFR 190.
The NRR Project Manager will inform the licensee of the entrance and exit meeting dates when they are established. The Project Manager will coordinate with the licensee 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.