ML11269A053

Request for Additional Information Regarding the Proposed Technical Specification Changes to Allow Use of Areva Advanced W17 High Thermal Performance Fuel

ML11269A053
Person / Time
Site:	Sequoyah
Issue date:	10/14/2011
From:	Siva Lingam Plant Licensing Branch II
To:	Krich R Tennessee Valley Authority
Lingam S
References
TAC ME6538, TAC ME6539
Download: ML11269A053 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 October 14, 2011 Mr. R. M. Krich Vice President, Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOPSED TECHNICAL SPECIFICATION CHANGES TO ALLOW USE OF AREVA ADVANCED W17 HIGH THERMAL PERFORMANCE FUEL (TAC NOS. ME6538 AND ME6539)

Dear Mr. Krich:

By letter dated June 17, 2011, and supplemented by letter dated July 27, 2011, you submitted an application for license amendment to revise the Sequoyah Nuclear Plant, Units 1 and 2 Technical Specifications to allow the use of AREVA Advanced W17 High Thermal Performance Fuel to address fuel assembly distortion and its resultant fuel handling issues.

The Nuclear Regulatory Commission staff is reviewing the submittal and has determined that additional information is required to complete its evaluation. This request was discussed with Mr. Dan Green of your staff on September 26, 2011, and it was agreed that a response would be provided within 30 days from the date of this letter.

If you have any questions regarding this matter, I can be reached at 301-415-1564.

Sincerely,

~

~~~'~

Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-327 and 50-328

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION REGARDING TECHNICAL SPECIFICATION CHANGES TO ALLOW USE OF AREVA ADVANCED W17 HIGH THERMAL PERFORMANCE FUEL SEQUOYAH NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 By letter dated June 17, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML111720780), and supplemented by letter dated July 27,2011 (ADAMS Accession No. ML112101798), the Tennessee Valley Authority (the licensee),

submitted a license amendment request to revise the Sequoyah Nuclear Plant, Units 1 and 2, Technical Specifications to allow the use of AREVA Advanced W17 High Thermal Performance Fuel to address fuel assembly distortion and its resultant fuel handling issues. In order to complete its review of the above documents, the Nuclear Regulatory Commission (NRC) staff needs the following additional information:

Question 1 Title 10 of the Code of Federal Regulations (10 CFR), Section 100.11, "Determination of exclusion area, low population zone, and population center distance," and 10 CFR Part 50, Appendix A, "General Design Criteria for Nuclear Power Plants," Criterion 19, "Control room," set regulatory dose limits for offsite and control room after a design basis accident. Section 50.67, "Accident source term," of 10 CFR. states that the NRC may issue amendments only if the applicant's analysis demonstrates that certain onsite and control room dose limits are met.

Regulatory Guide (RG) 1.183, "Alternative Radiological Source Terms for Evaluating Design Basis Accidents at Nuclear Power Reactors," (ADAMS Accession No. ML003716792) provides guidance to licensees on performing evaluations and reanalyses in support of meeting the dose limits in 10 CFR 50.67. RG 1.195, "Methods and Assumptions for Evaluating Radiological Consequences of Design Basis Accidents at Nuclear Power Reactors," (ADAMS Accession No. ML031490640) provides guidance to licensees for performing evaluations and reanalysis in support of meeting 10 CFR 100.11.

Standard Review Plan 15.0.1, "Radiological Consequence Analyses Using Alternative Source Terms," (ADAMS Accession No. ML003734190) states:

The reviewer should evaluate the AST [Alternative Source Term] proposed by the licensee against the guidance in RG-1.183. Differences between the licensee's proposal and the guidance should be resolved with the licensee.

Although the licensee is allowed to propose alternatives to the guidance, large amounts of staff resources were expended in developing the revised source term (Ref. 5) from which the RG-1.183 source term was derived.

Section 2.0 of RG-1.183 provides generic guidance on what would be Enclosure

-2 expected before the staff would approve an AST with deviations from the AST in Section 3.0 of the guide.

Standard Review Plan 15.0.1 also states:

The analysis methods and assumptions used by the licensee in determining the core inventory should be reviewed to ensure that they are based on current licensing basis rated thermal power, enrichment, and burnup.

A modification to the licensing basis fuel type can have the potential to change the core isotopic distribution and inventory assumed in post accident conditions. The impacts regarding the core inventory and enrichment are not discussed in the proposed amendment. The amendment states that burnup limits are "similar" to the current fuel, but does not provide the new burnup limits.

Please verify that the core inventory, enrichment, and burnup are not changed or are bounded by the proposed amendment. If these parameters are bounded, please provide a justification for the statement that they are bounded. Please confirm that the burnup and linear heat generation rates in footnote 11, Regulatory Position 3.2 of RG 1.183 are met, or justify the source terms used.

Question 2 Regulatory Position 1.3.2, liRe-Analysis Guidance," of RG 1.183 states:

Any implementation of an AST, full or selective, and any associated facility modification should be supported by evaluations of all significant radiological and nonradiological impacts of the proposed actions. This evaluation should consider the impact of the proposed changes on the facility's compliance with the regulations and commitments listed above as well as any other facility-specific requirements. These impacts may be due to (1) the associated facility modifications or (2) the differences in the AST characteristics. The scope and extent of the re-evaluation will necessarily be a function of the specific proposed facility modification2 and whether a full or selective implementation is being pursued. The NRC staff does not expect a complete recalculation of all facility radiological analyses, but does expect licensees to evaluate all impacts of the proposed changes and to update the affected analyses and the design bases appropriately. An analysis is considered to be affected if the proposed modification changes one or more assumptions or inputs used in that analysis such that the results, or the conclusions drawn on those results, are no longer valid.

The proposed amendment states that the fuel rod and fuel pellet materials and design are "similar" to the current fuel, but does not provide any specific details regarding the impact of the proposed change on the analysis of record. For example, changes to the structure of the fuel rod could impact the assumed amount of fuel damage as a result of a fuel handling accident. In order for the NRC staff to evaluate the impact of the proposed change, please provide any changes to the parameters, assumptions, or methodologies in the radiological design-basis

-3 accident (DBA) analyses and a justification for those changes. If there are changes to the radiological DBA analyses, please provide the resulting change to the calculated radiological consequence of the DBA.

October 14, 2011 Mr. R. M. Krich Vice President, Nuclear Licensing Tennessee Valley Authority 3R Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE PROPOPSED TECHNICAL SPECIFICATION CHANGES TO ALLOW USE OF AREVA ADVANCED W17 HIGH THERMAL PERFORMANCE FUEL (TAC NOS. ME6538 AND ME6539)

Dear Mr. Krich:

By letter dated June 17, 2011, and supplemented by letter dated July 27,2011, you submitted an application for license amendment to revise the Sequoyah Nuclear Plant, Units 1 and 2 Technical Specifications to allow the use of AREVA Advanced W17 High Thermal Performance Fuel to address fuel assembly distortion and its resultant fuel handling issues.

The Nuclear Regulatory Commission staff is reviewing the submittal and has determined that additional information is required to complete its evaluation. This request was discussed with Mr. Dan Green of your staff on September 26, 2011, and it was agreed that a response would be provided within 30 days from the date of this letter.

If you have any questions regarding this matter, I can be reached at 301-415-1564.

Sincerely, IRA!

Siva P. Lingam, Project Manager Plant Licensing Branch 11-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-327 and 50-328

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION:

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