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| | issue date = 02/09/2010 | | | issue date = 02/09/2010 |
| | title = Clarification Regarding the Number of Tritium Producing Burnable Absorber Rods in Operating Cycle 10 and Program Update | | | title = Clarification Regarding the Number of Tritium Producing Burnable Absorber Rods in Operating Cycle 10 and Program Update |
| | author name = Krich R M | | | author name = Krich R |
| | author affiliation = Tennessee Valley Authority | | | author affiliation = Tennessee Valley Authority |
| | addressee name = | | | addressee name = |
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| {{#Wiki_filter:Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402-2801 February 9, 2010 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Watts Bar Nuclear Plant, Unit 1 Facility Operating License No. NPF-90 NRC Docket No. 50-390 | | {{#Wiki_filter:Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402-2801 February 9, 2010 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Watts Bar Nuclear Plant, Unit 1 Facility Operating License No. NPF-90 NRC Docket No. 50-390 |
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| ==Subject:== | | ==Subject:== |
| | Clarification Regarding the Number of Tritium Producing Burnable Absorber Rods in Operating Cycle 10 and Program Update |
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| ==References:== | | ==References:== |
| | : 1. NRC letter to TVA, "Watts Bar Nuclear Plant, Unit 1 - Issuance of Amendment Regarding the Maximum Number of Tritium Producing Burnable Assembly Rods in the Reactor Core (TAC No. MD5430)," |
| | dated January 18, 2008. |
| | : 2. TVA letter to NRC, "Watts Bar Nuclear Plant (WBN) Unit 1 - |
| | Revised Technical Specifications Change WBN-TS-08 Revision to the Maximum Number of TPBARS that can be Irradiated in the Reactor Core Per Cycle (TAC No. MD9396)," |
| | dated December 31, 2008. |
| | : 3. NRC letter to TVA, "Watts Bar Nuclear Plant, Unit 1 - Issuance of Amendment Regarding the Maximum Number of Tritium Producing Burnable Assembly Rods in the Reactor Core (TAC No. MD9396)," dated May 4, 2009. |
| | : 4. NRC letter to TVA, "Watts Bar Nuclear Plant, Unit 1 - Tritium Producing Burnable Absorber Rods (TAC No. ME2775)," dated January 5, 2010. |
| | The purpose of this letter is twofold: (1) to provide clarification regarding the number of Tritium Producing Burnable Absorber Rods (TPBARs) loaded in the Cycle 10 core relative to the number approved by the Nuclear Regulatory Commission (NRC) in Amendment No. 77 to the Watts Bar Nuclear Plant, Unit 1, facility operating license; and, (2) to provide a description of planned future licensing actions. |
| | LoC>o Printed on recycled paper |
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| Clarification Regarding the Number of Tritium Producing Burnable Absorber Rods in Operating Cycle 10 and Program Update 1. NRC letter to TVA, "Watts Bar Nuclear Plant, Unit 1 -Issuance of Amendment Regarding the Maximum Number of Tritium Producing Burnable Assembly Rods in the Reactor Core (TAC No. MD5430)," dated January 18, 2008.2. TVA letter to NRC, "Watts Bar Nuclear Plant (WBN) Unit 1 -Revised Technical Specifications Change WBN-TS-08-04
| | Nuclear Regulatory Commission Page 2 February 9, 2010 The Tennessee Valley Authority (TVA) irradiated 368 TPBARs for the U.S. |
| -Revision to the Maximum Number of TPBARS that can be Irradiated in the Reactor Core Per Cycle (TAC No. MD9396)," dated December 31, 2008.3. NRC letter to TVA, "Watts Bar Nuclear Plant, Unit 1 -Issuance of Amendment Regarding the Maximum Number of Tritium Producing Burnable Assembly Rods in the Reactor Core (TAC No. MD9396)," dated May 4, 2009.4. NRC letter to TVA, "Watts Bar Nuclear Plant, Unit 1 -Tritium Producing Burnable Absorber Rods (TAC No. ME2775)," dated January 5, 2010.The purpose of this letter is twofold: (1) to provide clarification regarding the number of Tritium Producing Burnable Absorber Rods (TPBARs) loaded in the Cycle 10 core relative to the number approved by the Nuclear Regulatory Commission (NRC) in Amendment No. 77 to the Watts Bar Nuclear Plant, Unit 1, facility operating license;and, (2) to provide a description of planned future licensing actions.LoC>o Printed on recycled paper Nuclear Regulatory Commission Page 2 February 9, 2010 The Tennessee Valley Authority (TVA) irradiated 368 TPBARs for the U.S.Department of Energy (DOE) during Watts Bar Nuclear Plant, Unit 1, Cycle 9, which ran from March 25, 2008 to September 20, 2009, as authorized by License Amendment No. 67 issued January 18, 2008 (Reference 1). This Amendment also approved the use of the new Mark 9.2 design TPBAR which was expected to exhibit a tritium permeation rate that was less than the rate in previous cycles. In response to increased DOE tritium production goals, TVA submitted a revised License Amendment Request (LAR) dated December 31, 2008 for Cycle 10, requesting to increase the number of TPBARs from 400 to 704 (Reference 2). This request was based in part on a lower expected tritium permeation rate and also stated the planned number of TPBARs to be loaded was to be 576. The December 31, 2008 request was approved by License Amendment No. 77 transmitted by NRC letter dated May 4, 2009 (Reference 3).During the course of Cycle 9 operation, it became apparent by February 2009 that the new Mark 9.2 design TPBARs had permeation rates higher than expected and possibly higher than that in the previous cycles, resulting in more tritium passing through the TPBARs into the reactor coolant system. Based on this information, in March 2009 TVA conservatively chose to limit the number of TPBARs to 240, instead of 576, to be irradiated in Cycle 10, which was scheduled to begin in October 2009.This decision allowed TVA to gather data from an additional cycle with the new Mark 9.2 design TPBARs and to provide additional margin to ensure TVA would stay below its regulatory limits for tritium level. DOE's contractor, Pacific Northwest National Laboratory confirmed after completion of Cycle 9 in November 2009 that calculated tritium levels, when using the latest adjusted methodology for TPBAR calculation, were essentially the same as previous cycles in which TPBARs were irradiated.
| | Department of Energy (DOE) during Watts Bar Nuclear Plant, Unit 1, Cycle 9, which ran from March 25, 2008 to September 20, 2009, as authorized by License Amendment No. 67 issued January 18, 2008 (Reference 1). This Amendment also approved the use of the new Mark 9.2 design TPBAR which was expected to exhibit a tritium permeation rate that was less than the rate in previous cycles. In response to increased DOE tritium production goals, TVA submitted a revised License Amendment Request (LAR) dated December 31, 2008 for Cycle 10, requesting to increase the number of TPBARs from 400 to 704 (Reference 2). This request was based in part on a lower expected tritium permeation rate and also stated the planned number of TPBARs to be loaded was to be 576. The December 31, 2008 request was approved by License Amendment No. 77 transmitted by NRC letter dated May 4, 2009 (Reference 3). |
| Neither the decision to irradiate only 240 versus the 576 TPBARs during Cycle 10 nor the apparent change to the calculated permeation rate observed during Cycle 9 were communicated to the NRC. TVA did enter this issue into its Corrective Action Program. The resulting evaluation has determined that while TVA made a conservative decision and reduced the number of TPBARs to 240, the NRC was not notified of these changes. This is considered inappropriate for two reasons.1. TVA had requested that the license amendment allowing the loading of up to 704 TPBARs be approved by August of 2009 to support Cycle 10. However, before the amendment was approved by the NRC, TVA revised the number of TPBARs to be placed in the Cycle 10 reactor core to less than that which was previously approved by the NRC for the Cycle 9 core. As a result, even though TVA determined that only 240 TPBARs would be loaded into the Cycle 10 reactor core, TVA did not inform the NRC that the amendment would no longer be needed to support Cycle 10. | | During the course of Cycle 9 operation, it became apparent by February 2009 that the new Mark 9.2 design TPBARs had permeation rates higher than expected and possibly higher than that in the previous cycles, resulting in more tritium passing through the TPBARs into the reactor coolant system. Based on this information, in March 2009 TVA conservatively chose to limit the number of TPBARs to 240, instead of 576, to be irradiated in Cycle 10, which was scheduled to begin in October 2009. |
| Nuclear Regulatory Commission Page 3 February 9, 2010 2. TVA based a portion of its LAR on the TPBAR performance data from Cycles 6, 7, and 8, and stated that the increase to 704 TPBARs could be accomplished even if the tritium permeation did not decrease from Cycles 6, 7, and 8. However, TVA did not inform the NRC after performance data during Cycle 9 indicated that tritium permeation values were observed to be higher than expected and possibly higher than those in Cycles 6, 7, and 8. TVA became aware of increased permeation values prior to the NRC issuing Amendment No. 77.The decision to irradiate only 240 versus the 576 TPBARs during Cycle 10 due to the apparent change to the calculated permeation rate observed during Cycle 9 was communicated to the NRC on December 7, 2009 (Reference 4).Accordingly, TVA has concluded that in accordance with 10 CFR 50.9, "Completeness and accuracy of information," paragraph (a), it should have notified the NRC of these changes in March 2009 when TVA determined that only 240 TPBARs would be loaded in the Cycle 10 reactor core in order to account for apparently higher than expected permeation. | | This decision allowed TVA to gather data from an additional cycle with the new Mark 9.2 design TPBARs and to provide additional margin to ensure TVA would stay below its regulatory limits for tritium level. DOE's contractor, Pacific Northwest National Laboratory confirmed after completion of Cycle 9 in November 2009 that calculated tritium levels, when using the latest adjusted methodology for TPBAR calculation, were essentially the same as previous cycles in which TPBARs were irradiated. |
| The reason for this lack of proper notification was that the TVA TPBAR team was focused on ensuring regulatory limits would not be exceeded during Cycle .10 to the exclusion of recognizing the requirement for the NRC to have complete and accurate information. | | Neither the decision to irradiate only 240 versus the 576 TPBARs during Cycle 10 nor the apparent change to the calculated permeation rate observed during Cycle 9 were communicated to the NRC. TVA did enter this issue into its Corrective Action Program. The resulting evaluation has determined that while TVA made a conservative decision and reduced the number of TPBARs to 240, the NRC was not notified of these changes. This is considered inappropriate for two reasons. |
| This letter therefore constitutes TVA's notification to the NRC of changes to the TPBAR program. TVA is now evaluating if any conforming changes need to be made to the Watts Bar Nuclear Plant, Unit 1 license. TVA has evaluated the current Watts Bar Nuclear Plant, Unit 1 Technical Specifications (TS)relative to NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Ensure Plant Safety," and has concluded that with regard to the TPBARs the TS do not contain non-conservative values or specify incorrect actions.TVA will inform NRC of the number of TPBARs planned for irradiation in Cycle 11 by no later than September 30, 2010. TVA is working with DOE to evaluate options to increase tritium production to meet Department of Defense requirements, by increasing the number of TPBARs. TVA anticipates the need to submit a License Amendment Request in late 2011 in support of Cycle 12 which is scheduled to begin in the fall of 2012.As this information is provided for NRC information only, no NRC action is being requested at this time. | | : 1. TVA had requested that the license amendment allowing the loading of up to 704 TPBARs be approved by August of 2009 to support Cycle 10. However, before the amendment was approved by the NRC, TVA revised the number of TPBARs to be placed in the Cycle 10 reactor core to less than that which was previously approved by the NRC for the Cycle 9 core. As a result, even though TVA determined that only 240 TPBARs would be loaded into the Cycle 10 reactor core, TVA did not inform the NRC that the amendment would no longer be needed to support Cycle 10. |
| Nuclear Regulatory Commission Page 4 February 9, 2010 The Enclosure provides a regulatory commitment associated with this submittal. | | |
| If you have any questions about this letter, please contact Kevin Casey at (423) 751-8523.Respectfully, R. M. Kric Vice President Nuclear Licensing ENCLOSURE cc (w/ Enclosure): | | Nuclear Regulatory Commission Page 3 February 9, 2010 |
| NRC Regional Administrator | | : 2. TVA based a portion of its LAR on the TPBAR performance data from Cycles 6, 7, and 8, and stated that the increase to 704 TPBARs could be accomplished even if the tritium permeation did not decrease from Cycles 6, 7, and 8. However, TVA did not inform the NRC after performance data during Cycle 9 indicated that tritium permeation values were observed to be higher than expected and possibly higher than those in Cycles 6, 7, and 8. TVA became aware of increased permeation values prior to the NRC issuing Amendment No. 77. |
| -Region II NRC Senior Resident Inspector-Watts Bar Nuclear Plant ENCLOSURE COMMITMENT | | The decision to irradiate only 240 versus the 576 TPBARs during Cycle 10 due to the apparent change to the calculated permeation rate observed during Cycle 9 was communicated to the NRC on December 7, 2009 (Reference 4). |
| | Accordingly, TVA has concluded that in accordance with 10 CFR 50.9, "Completeness and accuracy of information," paragraph (a), it should have notified the NRC of these changes in March 2009 when TVA determined that only 240 TPBARs would be loaded in the Cycle 10 reactor core in order to account for apparently higher than expected permeation. The reason for this lack of proper notification was that the TVA TPBAR team was focused on ensuring regulatory limits would not be exceeded during Cycle .10 to the exclusion of recognizing the requirement for the NRC to have complete and accurate information. This letter therefore constitutes TVA's notification to the NRC of changes to the TPBAR program. TVA is now evaluating ifany conforming changes need to be made to the Watts Bar Nuclear Plant, Unit 1 license. TVA has evaluated the current Watts Bar Nuclear Plant, Unit 1 Technical Specifications (TS) relative to NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Ensure Plant Safety," and has concluded that with regard to the TPBARs the TS do not contain non-conservative values or specify incorrect actions. |
| | TVA will inform NRC of the number of TPBARs planned for irradiation in Cycle 11 by no later than September 30, 2010. TVA is working with DOE to evaluate options to increase tritium production to meet Department of Defense requirements, by increasing the number of TPBARs. TVA anticipates the need to submit a License Amendment Request in late 2011 in support of Cycle 12 which is scheduled to begin in the fall of 2012. |
| | As this information is provided for NRC information only, no NRC action is being requested at this time. |
| | |
| | Nuclear Regulatory Commission Page 4 February 9, 2010 The Enclosure provides a regulatory commitment associated with this submittal. If you have any questions about this letter, please contact Kevin Casey at (423) 751-8523. |
| | Respectfully, R. M. Kric Vice President Nuclear Licensing ENCLOSURE cc (w/ Enclosure): |
| | NRC Regional Administrator - Region II NRC Senior Resident Inspector- Watts Bar Nuclear Plant |
| | |
| | ENCLOSURE COMMITMENT |
| : 1. TVA will inform the NRC of the number of TPBARs planned for irradiation in Cycle 11 by no later than September 30, 2010.}} | | : 1. TVA will inform the NRC of the number of TPBARs planned for irradiation in Cycle 11 by no later than September 30, 2010.}} |
Letter Sequence Other |
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MONTHYEARML0204507012002-02-11011 February 2002 Unit - Request for Additional Information Re Tritium Production Program Interface Issue 7 Project stage: RAI ML0205800822002-02-19019 February 2002 Response to Request for Additional Information Re Tritium Production - Holtec Analysis. Submits New non-proprietary Version (Revision 3) of Holtec International Report HI-2012620 Project stage: Response to RAI ML0205806122002-02-21021 February 2002 License Amendment, FSAR Change for Revised Spent Fuel Cooling Analysis Methodology - TAC Nos. MB1807 and MB1884 Project stage: Other ML0205800052002-02-21021 February 2002 Responses to RAI Regarding Tritium Producing Burnable Absorber Rods (TPBARS) Project stage: Response to RAI ML0205804302002-02-21021 February 2002 Tennessee Valley Authority Response to NRC Request for Additional Information Re Tritium Producing Burnable Absorber Rods (TPBARS) at Watts Bar Nuclear Plant Project stage: Response to RAI ML0210003612002-04-0505 April 2002 Response to Request for Additional Information Re Tritium Production - Interface Issue Number 2 - Procurement and Fabrication Issues Project stage: Response to RAI ML0211905572002-04-25025 April 2002 Second Request for Additional Information Tritium Production Program Interface Issue 7 Project stage: RAI ML0212806302002-05-0808 May 2002 Request for Additional Information Re Tritium Production Program Interface Issue 5 Project stage: RAI ML0214401522002-05-21021 May 2002 Request for Additional Information Regarding Tritium Production - Interface Issue Number 7 Light Load Handling Systems Project stage: Request ML0214401422002-05-21021 May 2002 Request for Additional Information Re Tritium Production - Interface Issue Number 7 - Light Load Handling Systems Project stage: Request ML0214401352002-05-21021 May 2002 Request for Additional Information Re Tritium Production - Interface Issue Number 5 - Control Room Habitability Systems Project stage: Request ML0214901392002-05-23023 May 2002 Response to Request for Additional Information Re Radiological Impact Project stage: Response to RAI ML0221004492002-07-29029 July 2002 Request for Additional Information Tritium Production Program Project stage: RAI ML0221401972002-07-30030 July 2002 Tritium Production -- Post-LOCA Hot Leg Emergency Core Cooling System (ECCS) Recirculation Time -- Supplemental Information Project stage: Supplement ML0222601522002-08-0909 August 2002 Request for Risk-Informed Information Tritium Production Program Project stage: Request ML0831800942002-08-0909 August 2002 Plants - Request for Risk-Informed Information Tritium Production Program Project stage: Request ML0223209052002-08-20020 August 2002 Environmental Assessment and Finding of No Significant Impact for Incore Irradiation Services for the U. S. Department of Energy'S Tritium Production Program Project stage: Other ML0225409252002-09-23023 September 2002 Amendment No. 40, Irridiate Up to 2304 Tritium-Producing Burnable Absorber Rods in the Reactor Core Project stage: Acceptance Review ML0227502952002-09-23023 September 2002 Technical Specification Pages for Amendment No. 40, Irradiated Up to 2304 Tritium Producing Burnable Absborber Rods in the Reactor Core Project stage: Other ML0735205462008-01-18018 January 2008 Issuance of License Amendment 67 Regarding the Maximum Number of Tritium Producing Burnable Assembly Rods in the Reactor Core Project stage: Approval ML0802203782008-01-18018 January 2008 Tech Spec Pages for Amendment 67 Regarding the Maximum Number of Tritium Producing Burnable Assembly Rods in the Reactor Core Project stage: Other ML0821800942008-07-31031 July 2008 WCAP-16932-NP, Rev. 1, Control Rod Insertion Following a Cold Leg LOCA for Watts Bar Unit 1. Project stage: Request ML0821800932008-08-0101 August 2008 Watt'S Bar, Unit 1, Technical Specifications Change - Revision of Boron Requirements for Cold Leg Accumulators and Refueling Water Storage Tank. Project stage: Request ML0827502132008-10-0606 October 2008 Request for Withholding Information from Public Disclosure for Watts Bar Nuclear Plant, Unit 1 (Tac No. MD9396) Project stage: Withholding Request Acceptance ML0828314472008-10-14014 October 2008 Request for Additional Information Regarding Analysis in Support of Control Rod Insertion Following a Cold Leg Loss-of -Coolant Accident (Tac MD9396) Project stage: RAI ML0829401702008-10-28028 October 2008 Request for Additional Information - Watts Bar Emergency Core Cooling System Boron Requirements Project stage: RAI ML0830401042008-11-0707 November 2008 Request for Additional Information - Watts Bar Emergency Core Cooling System Boron Requirements Project stage: RAI ML0833601912008-11-25025 November 2008 Response to Request for Additional Information Analysis in Support of Control Rod Insertion Following a Cold Leg Loss-of-Coolant Accident Project stage: Response to RAI ML0834303042008-12-0909 December 2008 Potential Schedule Impact Regarding Revision of Technical Specifications, Revision of Boron Requirements for Cold Leg Accumulators and Refueling Water Storage Tank. Project stage: Other ML0835101022008-12-19019 December 2008 Withdrawal of Questions Number 6 from Letter Dated October 28, 2008, Regarding Proposed Amendment to Revise Technical Specifications for Boron Requirements for the Cold Leg Accumulations and Refueling Water Storage Tank Project stage: Withdrawal ML0902202552008-12-31031 December 2008 Response to Request for Additional Information Emergency Core Cooling System Boron Requirements Project stage: Response to RAI ML0900900442008-12-31031 December 2008 Revised Technical Specifications Change WBN-TS-08-04 - Revision to the Maximum Number of TPBARS That Can Be Irradiated in the Reactor Core Per Cycle Project stage: Other ML0933507402009-01-0505 January 2009 Request for Information Regarding the Tritium Producing Burnable Absorber Rods (Tac No. ME2775) Project stage: RAI ML0900600402009-01-26026 January 2009 Request for Withholding Information from Public Disclosure for Watts Bar Nuclear Plant, Unit 1 Project stage: Withholding Request Acceptance ML0909205062009-05-0404 May 2009 Issuance of Amendment Regarding the Maximum Number of Tritium Producing Burnable Assembly Rods in the Reactor Core Project stage: Approval ML1004703202010-02-0909 February 2010 Clarification Regarding the Number of Tritium Producing Burnable Absorber Rods in Operating Cycle 10 and Program Update Project stage: Other CNL-14-053, Notification of the Number of Tritium Producing Burnable Absorber Rods for the Operating Cycle 13 Reactor Core2014-04-0808 April 2014 Notification of the Number of Tritium Producing Burnable Absorber Rods for the Operating Cycle 13 Reactor Core Project stage: Other ML15030A5082015-01-30030 January 2015 Tritium Production Program, Updated Plans for Cycle 13 Operation and Updated Evaluation of the Radiological Impacts of Tritium Permeation Into the Reactor Coolant System Project stage: Other 2008-10-14
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Category:Letter
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Includes CECC-EPIP-1, Revision 76 and CECC-EPIP-9, Revision 642023-09-0505 September 2023 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions. Includes CECC-EPIP-1, Revision 76 and CECC-EPIP-9, Revision 64 IR 05000390/20230052023-08-30030 August 2023 Updated Inspection Plan for Watts Bar Nuclear Plant, Units 1 and 2 - Report 05000390/2023005 and 05000391/2023005 ML23233A0042023-08-28028 August 2023 Proposed Alternative to the Requirements of the ASME Boiler and Pressure Vessel Code for Upper Head Injection Dissimilar Metal Butt Welds IR 05000390/20230022023-08-16016 August 2023 Reissue - Watts Bar Nuclear Plant - Integrated Inspection Report 05000390/2023002 and 05000391/2023002 ML23220A1582023-08-0909 August 2023 Integrated Inspection Report 05000390/2023002 and 05000391/2023002 CNL-23-045, License Amendment Request to Revise Technical Specification Table 1.1-1 Regarding the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Bolts (WBN-TS-23-010)2023-08-0707 August 2023 License Amendment Request to Revise Technical Specification Table 1.1-1 Regarding the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Bolts (WBN-TS-23-010) CNL-23-028, Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-03 and WBN-TS-23-06)2023-08-0202 August 2023 Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-03 and WBN-TS-23-06) ML23192A4472023-07-31031 July 2023 Staff Assessment of Updated Seismic Hazards at TVA Sites Following the NRC Process for the Ongoing Assessment of Natural Hazards Information CNL-23-055, Tennessee Valley Authority - Emergency Preparedness Department Procedure Revision. Includes EPDP-3, Revision 3, Emergency Plan Exercises and Preparedness Drills2023-07-25025 July 2023 Tennessee Valley Authority - Emergency Preparedness Department Procedure Revision. Includes EPDP-3, Revision 3, Emergency Plan Exercises and Preparedness Drills IR 05000390/20230112023-07-24024 July 2023 Quadrennial Focused Engineering Inspection (FEI) Commercial Grade Dedication Report 05000390 2023011 and 05000391 2023011 CNL-23-053, Tennessee Valley Authority - Radiological Emergency Plan Revisions2023-07-18018 July 2023 Tennessee Valley Authority - Radiological Emergency Plan Revisions CNL-23-020, Application to Revise Technical Specifications to Adopt TSTF-501-A, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control (WBN-TS-22-06)2023-06-28028 June 2023 Application to Revise Technical Specifications to Adopt TSTF-501-A, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control (WBN-TS-22-06) CNL-23-049, Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan .2023-06-26026 June 2023 Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan . ML23122A2322023-06-0707 June 2023 Issuance of Amendment Nos. 162 and 69 Regarding Change to Date in Footnotes for Technical Specification 3.7.11, Control Room Emergency Air Temperature Control System (Creatcs) CNL-23-044, Transmittal of Revision 3 to WCAP-18774-P and WCAP-18774-NP, Addendum to the Rotterdam Dockyard Company Final Stress Report for 173 P.W.R. Vessels TVA III & IV (Report No. 30749-B-030, Rev. 3) - Evaluation of One Closure Stud Out2023-06-0101 June 2023 Transmittal of Revision 3 to WCAP-18774-P and WCAP-18774-NP, Addendum to the Rotterdam Dockyard Company Final Stress Report for 173 P.W.R. Vessels TVA III & IV (Report No. 30749-B-030, Rev. 3) - Evaluation of One Closure Stud Out IR 05000390/20234032023-05-30030 May 2023 Cyber Security Inspection Report 05000390/2023403 and 05000391/2023403 ML23131A1812023-05-23023 May 2023 Correction to Amendment No. 161 to Facility Operating License No. NPF-90 CNL-23-042, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-05-16016 May 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions IR 05000390/20220032023-05-0909 May 2023 Reissue Watts Bar Nuclear Plant - Integrated Inspection Report 05000390/2022003 and 05000391/2022003 ML23125A2202023-05-0505 May 2023 Issuance of Amendment No. 161 Regarding a Change to Footnotes for Technical Specification Table 1.1-1 Modes (Emergency Circumstances) IR 05000390/20230012023-05-0404 May 2023 Integrated Inspection Report 05000390/2023001 and 05000391/2023001 CNL-23-043, Emergency License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 1.1-1, Modes (WBN-TS-23-09)2023-05-0404 May 2023 Emergency License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 1.1-1, Modes (WBN-TS-23-09) CNL-23-032, Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Unit 1 and 2, Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 412023-04-27027 April 2023 Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Unit 1 and 2, Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 41 CNL-23-030, Tennessee Valley Authority - Hydrologic Engineering Center River Analysis System Project Milestone Status Update2023-04-27027 April 2023 Tennessee Valley Authority - Hydrologic Engineering Center River Analysis System Project Milestone Status Update CNL-23-033, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revision2023-04-24024 April 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revision CNL-23-029, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-04-11011 April 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions ML23072A0652023-04-0505 April 2023 Units 1 and 2 Issuance of Amendment Nos. 364 and 358; 160 and 68 Regarding a Revision to Technical Specification 3.4.12 ML23073A2762023-04-0303 April 2023 Individual Notice of Consideration of Issuance of Amendments to Facility Operating Licenses, Proposed No Significant Hazards Consideration Determination, and Opportunity for a Hearing (EPID L-2023-LLA-0029) (Letter) CNL-23-023, Annual Insurance Status Report2023-03-30030 March 2023 Annual Insurance Status Report CNL-23-024, TVA Guarantee of Payment of Deferred Premiums - 2022 Annual Report2023-03-29029 March 2023 TVA Guarantee of Payment of Deferred Premiums - 2022 Annual Report 2024-01-09
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Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402-2801 February 9, 2010 10 CFR 50.4 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Watts Bar Nuclear Plant, Unit 1 Facility Operating License No. NPF-90 NRC Docket No. 50-390
Subject:
Clarification Regarding the Number of Tritium Producing Burnable Absorber Rods in Operating Cycle 10 and Program Update
References:
- 1. NRC letter to TVA, "Watts Bar Nuclear Plant, Unit 1 - Issuance of Amendment Regarding the Maximum Number of Tritium Producing Burnable Assembly Rods in the Reactor Core (TAC No. MD5430),"
dated January 18, 2008.
- 2. TVA letter to NRC, "Watts Bar Nuclear Plant (WBN) Unit 1 -
Revised Technical Specifications Change WBN-TS-08 Revision to the Maximum Number of TPBARS that can be Irradiated in the Reactor Core Per Cycle (TAC No. MD9396),"
dated December 31, 2008.
- 3. NRC letter to TVA, "Watts Bar Nuclear Plant, Unit 1 - Issuance of Amendment Regarding the Maximum Number of Tritium Producing Burnable Assembly Rods in the Reactor Core (TAC No. MD9396)," dated May 4, 2009.
- 4. NRC letter to TVA, "Watts Bar Nuclear Plant, Unit 1 - Tritium Producing Burnable Absorber Rods (TAC No. ME2775)," dated January 5, 2010.
The purpose of this letter is twofold: (1) to provide clarification regarding the number of Tritium Producing Burnable Absorber Rods (TPBARs) loaded in the Cycle 10 core relative to the number approved by the Nuclear Regulatory Commission (NRC) in Amendment No. 77 to the Watts Bar Nuclear Plant, Unit 1, facility operating license; and, (2) to provide a description of planned future licensing actions.
LoC>o Printed on recycled paper
Nuclear Regulatory Commission Page 2 February 9, 2010 The Tennessee Valley Authority (TVA) irradiated 368 TPBARs for the U.S.
Department of Energy (DOE) during Watts Bar Nuclear Plant, Unit 1, Cycle 9, which ran from March 25, 2008 to September 20, 2009, as authorized by License Amendment No. 67 issued January 18, 2008 (Reference 1). This Amendment also approved the use of the new Mark 9.2 design TPBAR which was expected to exhibit a tritium permeation rate that was less than the rate in previous cycles. In response to increased DOE tritium production goals, TVA submitted a revised License Amendment Request (LAR) dated December 31, 2008 for Cycle 10, requesting to increase the number of TPBARs from 400 to 704 (Reference 2). This request was based in part on a lower expected tritium permeation rate and also stated the planned number of TPBARs to be loaded was to be 576. The December 31, 2008 request was approved by License Amendment No. 77 transmitted by NRC letter dated May 4, 2009 (Reference 3).
During the course of Cycle 9 operation, it became apparent by February 2009 that the new Mark 9.2 design TPBARs had permeation rates higher than expected and possibly higher than that in the previous cycles, resulting in more tritium passing through the TPBARs into the reactor coolant system. Based on this information, in March 2009 TVA conservatively chose to limit the number of TPBARs to 240, instead of 576, to be irradiated in Cycle 10, which was scheduled to begin in October 2009.
This decision allowed TVA to gather data from an additional cycle with the new Mark 9.2 design TPBARs and to provide additional margin to ensure TVA would stay below its regulatory limits for tritium level. DOE's contractor, Pacific Northwest National Laboratory confirmed after completion of Cycle 9 in November 2009 that calculated tritium levels, when using the latest adjusted methodology for TPBAR calculation, were essentially the same as previous cycles in which TPBARs were irradiated.
Neither the decision to irradiate only 240 versus the 576 TPBARs during Cycle 10 nor the apparent change to the calculated permeation rate observed during Cycle 9 were communicated to the NRC. TVA did enter this issue into its Corrective Action Program. The resulting evaluation has determined that while TVA made a conservative decision and reduced the number of TPBARs to 240, the NRC was not notified of these changes. This is considered inappropriate for two reasons.
- 1. TVA had requested that the license amendment allowing the loading of up to 704 TPBARs be approved by August of 2009 to support Cycle 10. However, before the amendment was approved by the NRC, TVA revised the number of TPBARs to be placed in the Cycle 10 reactor core to less than that which was previously approved by the NRC for the Cycle 9 core. As a result, even though TVA determined that only 240 TPBARs would be loaded into the Cycle 10 reactor core, TVA did not inform the NRC that the amendment would no longer be needed to support Cycle 10.
Nuclear Regulatory Commission Page 3 February 9, 2010
- 2. TVA based a portion of its LAR on the TPBAR performance data from Cycles 6, 7, and 8, and stated that the increase to 704 TPBARs could be accomplished even if the tritium permeation did not decrease from Cycles 6, 7, and 8. However, TVA did not inform the NRC after performance data during Cycle 9 indicated that tritium permeation values were observed to be higher than expected and possibly higher than those in Cycles 6, 7, and 8. TVA became aware of increased permeation values prior to the NRC issuing Amendment No. 77.
The decision to irradiate only 240 versus the 576 TPBARs during Cycle 10 due to the apparent change to the calculated permeation rate observed during Cycle 9 was communicated to the NRC on December 7, 2009 (Reference 4).
Accordingly, TVA has concluded that in accordance with 10 CFR 50.9, "Completeness and accuracy of information," paragraph (a), it should have notified the NRC of these changes in March 2009 when TVA determined that only 240 TPBARs would be loaded in the Cycle 10 reactor core in order to account for apparently higher than expected permeation. The reason for this lack of proper notification was that the TVA TPBAR team was focused on ensuring regulatory limits would not be exceeded during Cycle .10 to the exclusion of recognizing the requirement for the NRC to have complete and accurate information. This letter therefore constitutes TVA's notification to the NRC of changes to the TPBAR program. TVA is now evaluating ifany conforming changes need to be made to the Watts Bar Nuclear Plant, Unit 1 license. TVA has evaluated the current Watts Bar Nuclear Plant, Unit 1 Technical Specifications (TS) relative to NRC Administrative Letter 98-10, "Dispositioning of Technical Specifications that are Insufficient to Ensure Plant Safety," and has concluded that with regard to the TPBARs the TS do not contain non-conservative values or specify incorrect actions.
TVA will inform NRC of the number of TPBARs planned for irradiation in Cycle 11 by no later than September 30, 2010. TVA is working with DOE to evaluate options to increase tritium production to meet Department of Defense requirements, by increasing the number of TPBARs. TVA anticipates the need to submit a License Amendment Request in late 2011 in support of Cycle 12 which is scheduled to begin in the fall of 2012.
As this information is provided for NRC information only, no NRC action is being requested at this time.
Nuclear Regulatory Commission Page 4 February 9, 2010 The Enclosure provides a regulatory commitment associated with this submittal. If you have any questions about this letter, please contact Kevin Casey at (423) 751-8523.
Respectfully, R. M. Kric Vice President Nuclear Licensing ENCLOSURE cc (w/ Enclosure):
NRC Regional Administrator - Region II NRC Senior Resident Inspector- Watts Bar Nuclear Plant
ENCLOSURE COMMITMENT
- 1. TVA will inform the NRC of the number of TPBARs planned for irradiation in Cycle 11 by no later than September 30, 2010.