ML18344A567

November 14, 2018, Summary of Public Meeting with Tennessee Valley Authority Regarding Presubmittal Licensing Actions - Sequoyah Nuclear Plant, Units 1 and 2

ML18344A567
Person / Time
Site:	Sequoyah
Issue date:	01/15/2019
From:	Andrew Hon Plant Licensing Branch II
To:
Hon A, NRR/DORL/LPLII-2, 415-8480
References
EPID L-2018-LRM-0085
Download: ML18344A567 (5)

Text

January 15, 2019 LICENSEE: Tennessee Valley Authority FACILITY: Sequoyah Nuclear Plant, Units 1 and 2

SUMMARY

OF NOVEMBER 14, 2018, MEETING WITH TENNESSEE VALLEY AUTHORITY REGARDING PRESUBMITTAL LICENSING ACTIONS -

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 (EPID L-2018-LRM-0085)

On November 14, 2018, a public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Tennessee Valley Authority (TVA) at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of this meeting was for the TVA to discuss an approach to submit a license amendment request (LAR) for a fuel transition. The meeting notice and agenda, dated October 26, 2018, are available in Agencywide Documents Access and Management System (ADAMS) at Accession No. ML18313A184.

Using the presentation slides (see ADAMS Accession No. ML18312A350), TVA summarized the proposed approach for an LAR to transition from the current Framatome HTPTM fuel to Westinghouse RFA-2 fuel at Sequoyah Nuclear Plant (SQN) Units 1 and 2. TVA believes its proposed approach is a more efficient alternative than what has been used in previous fuel transition LARs. The essence of this proposed approach is for the NRC staffs review to focus only on the SQN Technical Specification (TS) changes. This includes adding the reference to the new Westinghouse methodology topical reports (TRs) in the Core Operating Limits Report (COLR) and moving the Reactor Core Safety Limits from Section 2.0 of the TS to the COLR. As for the fuel transition related safety analyses, TVA believed that they could be performed using approved methods and will meet applicable acceptance criteria consistent with the current SQN licensing bases under the provisions in Title 10 of the Code of Federal Regulations, Section 50.59, Changes, tests, and experiments, without prior NRC approval in the LAR.

The NRC staff informed TVA that because the actual draft LAR was not available in the discussion, the likelihood of finding the LAR acceptable for review cannot be determined at this time. The following are examples of the initial challenges observed by the NRC staff with TVAs proposed approach:

• Even though TVA intended for the NRC staff to review only the proposed TS changes, the NRC staff indicated most TS-change LARs involve more in-depth review of the analytical bases supporting these proposed changes. Thus, multiple rounds of requests for additional information (RAIs) may be needed and TVAs efforts to submit the responses necessary for the NRC staff to make a reasonable assurance determination may offset the perceived efficiency of not submitting the information in the initial application.

• The NRC staff asked about TVAs proposed removal of numerical limits for the departure from nucleate boiling ratio (DNBR) and fuel temperature centerline melt safety limits from the TSs. TVA responded that no DNBR or fuel temperature values will be listed in the TSs, because they are not subject to surveillances. These parameters are important for fuel transitions and are typically reviewed by the NRC staff. Furthermore, the NRC staff noted that TVAs request to relocate safety limits to the COLR is contrary to the Standard Technical Specifications (STSs) and requested that TVA identify and justify any proposed changes that are not consistent with the STSs.

• The NRC staff asked about the justification for moving existing TS Figure 2.1.1-1 to the COLR. TVA responded that the approach is consistent with the STSs per Technical Specification Task Force Traveler TSTF 339, Revision 2.

• The NRC staff indicated when LARs usually reference NRC-approved topical reports (TRs),

the limitations and conditions (L&Cs) are typically the focus areas of the NRC staff review for plant-specific implementation. It is unclear how the NRC staff could reach a regulatory decision that plant-specific implementation of the methodology is acceptable without reviewing how the L&Cs are addressed for SQN-specific implementation.

• The NRC staff was concerned with TVA submitting the LAR in April 2019 without the associated analysis of a representative core design, which would not be available for NRC review until October 2019. NRC staff indicated that not having this analysis at the time of TVAs submittal may pose a challenge to the NRC in performing its acceptance review and in drafting the safety evaluation and RAIs. Without seeing the results of analyses, the NRC staff would not be able to assess compliance with regulations.

• In response to the need for an exemption for Optimized Zirlo, TVA replied that the exemption will be included in the LAR similar to the one for Watts Bar Nuclear Plant.

• The NRC staff asked if TVA intended to request the approval of Westinghouse methodologies for Framatome fuel (e.g., with respect to structural strength of spacer grids).

TVA responded that it will continue to credit the Framatome methodologies and is seeking additional approval to use the Westinghouse methodologies.

• TVA stated that it would not remove the Framatome methodologies from the SQN COLR, but would augment them with Westinghouse methodologies until all of the Framatome fuel has been discharged from the reactors. TVA may also submit a tiered change to the TS core operating limits methodology list that removes the Framatome methods following discharge of the remaining Framatome fuel.

• The NRC staff asked if TVA would be implementing older or newer methodologies. TVA responded that it will be using the full spectrum loss of coolant accident (FSLOCA) methodology and the latest fuel performance and design software (PAD5), which fully accounts for fuel thermal conductivity degradation. The NRC staff expected the FSLOCA analysis results be included in the LAR.

• The NRC staff asked what the reference to the SQN licensing basis was in the presentation. TVA responded that it refers to the Final Safety Analysis Report, Chapter 15 acceptance criteria. The NRC staff stated that review of licensing basis acceptance criteria (e.g., enthalpy limit for reactivity insertion accidents) is germane to the acceptability of methods implementation on a plant-specific basis.

The NRC staff indicated the above issues were only the initial thought to TVAs presentation and not exhaustive (i.e., other challenges may be identified when the LAR is submitted for acceptance review). TVA acknowledged that the NRC staffs concerns were understood, but believed that they could be addressed in the LAR. TVA will engage the NRC staff to continue the discussion at a later date. A list of attendees is enclosed.

No regulatory decisions were made at the meeting. No Public Meeting Feedback forms were received.

Please direct any inquiries to me at 301-415-8480 or Andrew.Hon@nrc.gov.

/RA/

Andrew Hon, 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

Summary: ML18344A567 Notice: ML18313A184 Presentation: ML18312A350 OFFICE DORL/LPL2-2/PM DORL/LPL2-2/LA DSS/SRXB/BC DORL/LPL2-2/BC DORL/LPL2-2/PM NAME AHon BClayton JWhitman UShoop AHon DATE 1 / 9 / 2019 1 / 7 / 2019 1 / 9 / 2019 1 / 14 / 2019 1 / 15 / 2019 LIST OF ATTENDEES NOVEMBER 14, 2018, MEETING WITH TENNESSEE VALLEY AUTHORITY REGARDING PRESUBMITTAL LICENSING ACTIONS FOR SEQUOYAH NUCLEAR PLANT NRC Andy Hon Bob Schaaf Kevin Heller Ravi Grover Jen Whitman Terrance Brimfield John Lehning Robert Beaton Robert Lukes Ahsan Salman Paul Clifford Ben Parks Kayla Gamin David Beaulieu Philip McKenna TVA Russ Wells Chris Carey David Brown Westinghouse James Smith Brian Beebe Jim Laird Arielle Konig Jesse Fisher Yixing Sung Kyle Shelton Andy Detar Mike Shockling Carmen Teolis Tom Gerlowsk Member of the public observed the meeting by telephone Bob Clarke Enclosure