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| | issue date = 11/21/2014 | | | issue date = 11/21/2014 |
| | title = LTR-14-0426 - Response LTR to Diane Curran, Harmon, Curran, Spielberg & Eisenberg, Llp Ltr. Watts Bar Unit 2 Operating License Proceeding | | | title = LTR-14-0426 - Response LTR to Diane Curran, Harmon, Curran, Spielberg & Eisenberg, Llp Ltr. Watts Bar Unit 2 Operating License Proceeding |
| | author name = Dean W M | | | author name = Dean W |
| | author affiliation = NRC/NRR/DORL | | | author affiliation = NRC/NRR/DORL |
| | addressee name = Curran D J | | | addressee name = Curran D |
| | addressee affiliation = Harmon, Curran, Spielberg & Eisenberg, LLP, Southern Alliance for Clean Energy | | | addressee affiliation = Harmon, Curran, Spielberg & Eisenberg, LLP, Southern Alliance for Clean Energy |
| | docket = 05000391 | | | docket = 05000391 |
LTR-14-0426 - Response LTR to Diane Curran, Harmon, Curran, Spielberg & Eisenberg, Llp Ltr. Watts Bar Unit 2 Operating License ProceedingML14267A466 |
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11/21/2014 |
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Bill Dean Division of Operating Reactor Licensing |
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Curran D Harmon, Curran, Harmon, Curran, Spielberg & Eisenberg, LLP, Southern Alliance for Clean Energy |
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ML14204A785 |
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LTR-14-0426 |
Download: ML14267A466 (4) |
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Category:Letter
MONTHYEARIR 05000390/20240052024-08-28028 August 2024 Updated Inspection Plan and Assessment Follow-Up Letter for Watts Bar Nuclear Plant, Units 1 and 2 - Report 05000390-2024005 and 05000391-2024005 IR 05000390/20244022024-08-20020 August 2024 – Security Baseline Inspection Report 05000390-2024402 and 05000391/2024402 - Public CNL-24-061, Supplement to Application to Revise Function 5 of Technical Specification Table 3.3.2-1, ‘Engineered Safety Feature Actuation System Instrumentation,’ for the Sequoyah and Watts Bar (SQN-TS-23-02 and WBN-TS-23-08),”2024-08-19019 August 2024 Supplement to Application to Revise Function 5 of Technical Specification Table 3.3.2-1, ‘Engineered Safety Feature Actuation System Instrumentation,’ for the Sequoyah and Watts Bar (SQN-TS-23-02 and WBN-TS-23-08),” ML24219A0262024-08-12012 August 2024 Request for Withholding Information from Public Disclosure IR 05000390/20240022024-08-0707 August 2024 Integrated Inspection Report 05000390/2024002 and 05000391/2024002 Rev ML24204A2652024-07-25025 July 2024 Regulatory Audit Summary Related to Request to Revise Technical Specification Surveillance Requirement 3.9.5.1 to Reduce the Residual Heat Removal Flow Rate ML24199A0012024-07-22022 July 2024 Clarification and Correction to Exemption from Requirement of 10 CFR 37.11(c)(2) ML24170A8002024-07-15015 July 2024 Issuance of Amendment Nos. 168 and 74 Regarding Revision to Technical Specification Table 1.1-1 for Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Bolts ML24172A1342024-07-15015 July 2024 Exemptions from 10 CFR 37.11(C)(2) (EPID L-2023-LLE-0024) - Letter IR 05000390/20244402024-07-12012 July 2024 95001 Supplemental Inspection Supplemental Report 05000390-2024440 and 05000391-2024440 and Follow-Up Assessment Letter ML24131A0012024-07-0202 July 2024 Issuance of Amendment Nos. 167 and 73 Regarding Adoption of Technical Specification Task Force Traveler TSTF-427-A, Revision 2 CNL-24-052, Response to Request for Additional Information Regarding Application to Modify the Technical Specification Surveillance Requirement 3.9.5.1 (WBN-TS-21-14)2024-06-27027 June 2024 Response to Request for Additional Information Regarding Application to Modify the Technical Specification Surveillance Requirement 3.9.5.1 (WBN-TS-21-14) CNL-24-018, License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-276-A, Revision 2, Regarding TS 3.8.1 AC Sources – Operating to Clarify Requirements for Diesel Generator Testing (WBN-TS2024-06-25025 June 2024 License Amendment Request for Adoption of Technical Specification Task Force Traveler TSTF-276-A, Revision 2, Regarding TS 3.8.1 AC Sources – Operating to Clarify Requirements for Diesel Generator Testing (WBN-TS ML24089A1152024-06-21021 June 2024 Transmittal Letter, Environmental Assessments and Findings of No Significant Impact Related to Exemption Requests from 10 CFR 37.11(c)(2) ML24141A0482024-05-17017 May 2024 EN 56958_1 Ametek Solidstate Controls, Inc ML24100A7642024-05-16016 May 2024 Issuance of Amendment No. 166 Regarding Revision to Technical Specification 3.8.2, AC Sources-Shutdown, to Remove Reference to C-S Diesel Generator (CNL-23-062) IR 05000390/20240012024-05-14014 May 2024 Integrated Inspection Report 05000390/2024001 and 05000391/2024001 CNL-24-040, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2024-05-0808 May 2024 Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revisions IR 05000391/20240072024-04-30030 April 2024 Assessment Follow-up Letter for Watts Bar Nuclear Plant, Unit 2 – Report 05000391/2024007 ML24120A1182024-04-29029 April 2024 – Notification of NRC Supplemental Inspection (95001) and Request for Information CNL-24-037, Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Unit 1 and 2, Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 422024-04-22022 April 2024 Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Unit 1 and 2, Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 42 ML24087A1912024-04-18018 April 2024 Exemption from Select Requirements of 10 CFR Part 73, Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting CNL-24-010, License Amendment Request to Recapture Low-Power Testing Time (WBN-TS-23-19)2024-04-17017 April 2024 License Amendment Request to Recapture Low-Power Testing Time (WBN-TS-23-19) CNL-24-033, Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2024-04-17017 April 2024 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions CNL-24-024, Hydrologic Engineering Center River Analysis System Project Milestone Status Update2024-04-17017 April 2024 Hydrologic Engineering Center River Analysis System Project Milestone Status Update ML24072A0052024-04-15015 April 2024 Issuance of Amendment Nos. 165 and 72 Regarding Increase in the Maximum Number of Tritium Producing Burnable Absorber Rods and Supporting Changes, and Revision to the Updated Final Safety Analysis Report CNL-24-004, Application to Modify the Watts Bar Nuclear Plant, Unit 1 and Unit 2 Technical Specifications for Main Control Room Chiller Completion Time Extension (WBN-TS-23-13)2024-04-0404 April 2024 Application to Modify the Watts Bar Nuclear Plant, Unit 1 and Unit 2 Technical Specifications for Main Control Room Chiller Completion Time Extension (WBN-TS-23-13) IR 05000390/20244012024-04-0202 April 2024 – Security Baseline Inspection Report 05000390/2024401 and 05000391/2024401 - (Public) CNL-24-020, Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Units 1 and 2, Request for Approval of Quality Assurance Program Description and Application to Revise the Technical Specifications Associated with QAPD Requirements2024-04-0101 April 2024 Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Units 1 and 2, Request for Approval of Quality Assurance Program Description and Application to Revise the Technical Specifications Associated with QAPD Requirements CNL-24-008, Guarantee of Payment of Deferred Premiums - 2023 Annual Report2024-03-27027 March 2024 Guarantee of Payment of Deferred Premiums - 2023 Annual Report CNL-24-007, Annual Insurance Status Report2024-03-27027 March 2024 Annual Insurance Status Report CNL-24-025, Notice of Intent to Pursue License Renewal for Watts Bar Nuclear Plant, Unit 1 - Submittal Schedule2024-03-25025 March 2024 Notice of Intent to Pursue License Renewal for Watts Bar Nuclear Plant, Unit 1 - Submittal Schedule ML24081A0262024-03-21021 March 2024 Emergency Plan Implementing Procedure Revisions ML24079A0312024-03-19019 March 2024 Wb 2024-301, Corporate Notification Letter (210-day Ltr) CNL-24-031, Supplement to Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance2024-03-18018 March 2024 Supplement to Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance CNL-24-028, Response to Request for Additional Information Regarding Watts Bar Nuclear Plant, Units 1 and 2, Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2024-03-14014 March 2024 Response to Request for Additional Information Regarding Watts Bar Nuclear Plant, Units 1 and 2, Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation CNL-24-029, Response to Request for Additional Information Regarding Tennessee Valley Authority - Request for Exemption from Specific Requirements of 10 CFR Part 372024-03-14014 March 2024 Response to Request for Additional Information Regarding Tennessee Valley Authority - Request for Exemption from Specific Requirements of 10 CFR Part 37 IR 05000390/20240102024-03-0808 March 2024 Age-Related Degradation Inspection Report 05000390/2024010 and 05000391/2024010 CNL-24-012, Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance2024-02-28028 February 2024 Request for Exemption from Various Part 72 Regulations Resulting from Fuel Basket Design Control Compliance IR 05000390/20230062024-02-28028 February 2024 Annual Assessment Letter for Watts Bar Nuclear Plant Units 1 and 2 - Report 05000390/2023006 and 05000391/2023006 CNL-24-023, Central Emergency Control Center Emergency Plan Implementing Procedure Revision. Includes CECC EPIP-17, Revision 252024-02-20020 February 2024 Central Emergency Control Center Emergency Plan Implementing Procedure Revision. Includes CECC EPIP-17, Revision 25 IR 05000390/20230042024-02-13013 February 2024 Integrated Inspection Report 05000390/2023004 and 05000391/2023004 and Apparent Violation ML24038A3342024-02-0707 February 2024 Change to South Texas Project Electric Generating Station (Stepgs) Emergency Plan ML23319A2452024-01-29029 January 2024 Issuance of Amendment Nos. 366 and 360; 164 and 71 Regarding the Adoption of TSTF-567, Revision 1, Add Containment Sump TS to Address GSI-191 Issues ML24008A2462024-01-18018 January 2024 Revision to the Reactor Vessel Material Surveillance Capsule Withdrawal Schedule CNL-24-017, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure and Emergency Preparedness Department Procedure Revisions2024-01-17017 January 2024 Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure and Emergency Preparedness Department Procedure Revisions CNL-24-016, Supplement to Application to Modify the Technical Specification Surveillance Requirement 3.9.5.1 (WBN-TS-21-14)2024-01-10010 January 2024 Supplement to Application to Modify the Technical Specification Surveillance Requirement 3.9.5.1 (WBN-TS-21-14) CNL-23-052, Application to Adopt TSTF-427-A, Revision 2, Allowance for Non-Technical Specification Barrier Degradation on Supported System Operability2024-01-0909 January 2024 Application to Adopt TSTF-427-A, Revision 2, Allowance for Non-Technical Specification Barrier Degradation on Supported System Operability CNL-23-062, Application to Revise the Technical Specifications Section 3.8.2, AC Sources-Shutdown, to Remove Reference to the C-S Diesel Generator (WBN-TS-23-018)2024-01-0808 January 2024 Application to Revise the Technical Specifications Section 3.8.2, AC Sources-Shutdown, to Remove Reference to the C-S Diesel Generator (WBN-TS-23-018) ML23346A1382024-01-0303 January 2024 Regulatory Audit Summary Related to Request to Increase the Number of Tritium Producing Burnable Absorber Rods 2024-08-07
[Table view] |
Text
November 21, 2014
Ms. Diane Curran c/o Southern Alliance for Clean Energy
1726 M St., NW. Suite 600 Washington DC 20036-4523
Dear Ms. Curran:
On behalf of the U.S. Nuclear Regulatory Commission (NRC), I am responding to your letter dated June 23, 2014. In your letter, you question the adequacy of the NRC's review of the Tennessee Valley Authority's (TVA's) Watts Bar Nuclear Plant, Unit 2 operating license application. Specifically, you question the following:
- 1. NRC's review of seismic and flooding requirements in the Watts Bar Unit 2 operating license application. 2. NRC's implementation of the Japan Lessons-Learned Near-Term Task Force (NTTF) recommendation to reevaluate seismic and flooding hazards in the Watts Bar Unit 2
operating license review. 3. NRC's practices for allowing opportunity fo r public participation during the Watts Bar Unit 2 licensing process.
In your letter you express concern that the NRC's operating license review of Watts Bar Unit 2 will not adequately address flooding and seismic safety requirements. All power reactors must be designed to safely withstand a set of natural events, including earthquakes, hurricanes, tornadoes, floods, and tsunami. These are called design-basis events. The NRC is currently completing the review of the Watts Bar Unit 2 operating license application, which includes the review of the site-specific hydrological licensing basis. To maintain site-wide consistency, the NRC is considering the current design-basis hazards of record for Watts Bar Unit 1 in the Watts Bar Unit 2 review. The NRC will not issue an operating license for Watts Bar Unit 2 until there is a reasonable assurance that the licensee can operate the facility safely and meet all applicable
requirements.
In your letter, you also express concern that in its review of the Watts Bar Unit 2 operating license application, the NRC is not applying seismic and flooding recommendations from the July 12, 2011, Japan Lessons-Learned Near-Term Task Force report, "Recommendation for Enhancing Reactor Safety in the 21st Century: The Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident." To fully address your concern, it is necessary to first describe how the NRC is implementing post-Fukus hima regulatory activities. The NRC formed the Japan Lessons-Learned Near-Term Task Force shortly after the Fukushima Dai-ichi accident. The goal of the task force was to determine what lessons the NRC can learn from the accident and to identify recommendations to enhance reactor safety in the United States. The staff prioritized the task force's recommendations in a three-tiered approach and also described the appropriate regulatory mechanisms for implementation (for example, orders, rulemaking, and requests for information). The Commission approved the staff's proposed actions, schedule for completion, and prioritization approach for implementing the Near-Term Task Force recommendations. Staff requirements memoranda (SRMs) for SECY-11-0124 and SECY-11-0137 describe this approach. You can find these memoranda in the Agencywide
Documents Access and Management System (ADAMS) under Accession Nos. ML112911571 and ML113490055, respectively. Overall, the NRC determined that it is prudent for the agency to take additional regulatory action in response to the accident. However, the NRC also concluded that continued plant operation and licensing activities, including the review of the Watts Bar Unit 2 operating license application, can continue because these actions do not pose an imminent risk to public health and safety. Y ou can find more information on how the NRC is implementing lessons learned from the Fukushima Dai-ichi accident at the NRC public Web site at http://www.nrc.gov/reactors/operating/ops-experience/japan-dashboard.html.
In response to Near-Term Task Force Recommendation 2.1, the NRC requested that licensees and applicants reevaluate the seismic and flooding hazards at their sites. At the Watts Bar nuclear power plant, TVA is implementing Recommendation 2.1 by reevaluating flooding and seismic hazards at both Unit 1 and Unit 2 using present-day methodologies and information, and determining the impact of these updated hazards on their facility. The Near-Term Task Force seismic and flooding reevaluation activi ties and the associated NRC staff assessments are complex and the agency will need several years to complete these tasks. Once the NRC obtains the results of these assessments, the NRC will determine if safe operation requires additional regulatory action. Such regulatory action could include updating the licensing basis or requiring modification of the facility. The Near-Term Task Force concluded that continued licensing activities do not pose an imminent risk to the public health and safety. Given that conclusion, the NRC does not see a need to defer the issuance of the Unit 2 operating license until these reevaluations and any potential followup actions are complete. In addition TVA must implement certain near-term post-Fukushima actions for the Watts Bar site before a license can be issued. This includes the mitigating strategies under Order EA-12-049, which will provide additional protection against beyond design basis events. TVA is required to meet a schedule for Near-Term Task Force-related requests for information that is consistent with the flooding and seismic reevaluation schedule for Watts Bar Unit 1 as well as all other operating reactors.
TVA is scheduled to submit their flooding hazard reevaluation before the NRC expects to make an operating license decision for Unit 2. If the reevaluated flooding hazard is higher than the design basis, TVA will be required to provide their plans for implementing compensatory measures.
In your letter, you express concern about the opportunities for public participation given the late
stages of the Watts Bar Unit 2 operating license application review. The NRC strives to achieve its mission to protect public health and safety in a manner that is transparent and accessible to interested members of the public. The NRC staff is coordinating regular public meetings and teleconferences with TVA to address significant licensing issues. You can find the schedule for
upcoming public meetings and teleconferences at the NRC's public Web site at http://meetings.nrc.gov/pmns/mtg. Furthermore, if the licensing basis is updated by amendment after the Watts Bar Unit 2 operating license is issued as a result of the NRC's assessment of the seismic or flooding hazard reevaluations, the public will have an opportunity to comment and request a hearing.
The NRC takes reactor safety very seriously. To ensure a quality review, the NRC developed a custom-tailored approach for licensing and inspection activities at Watts Bar Unit 2. The NRC is also dedicated to ensuring that nuclear power plants implement recommendations from the Near-Term Task Force in a timely manner and take appropriate actions to enhance reactor safety as needed. You can find more information regarding the licensing review of Watts Bar
Unit 2 here: http://www.nrc.gov/info-finder/reactor/wb/watts-bar.html. The NRC welcomes your participation and feedback. Please feel free to let us know how we can enhance your awareness of ongoing regulatory activities at Watts Bar Unit 2. Justin Poole, the Watts Bar Unit 2 senior project manager, can assist you in answering questions you may have about upcoming Watts Bar Unit 2 meetings, project milestones, and licensing activities. He can be reached at justin.poole@nrc.gov or 301-415-2048.
Sincerely,
/RA/
William M. Dean, Director Office of Nuclear Reactor Regulation
Docket No. 50-391
PKG ML14204A785 Incoming ML14204A784, ML14205A016 Response LTR ML14267A466 *email concurrence OFFICE NRR/LPWB/PM LPWB LPWB/LA QTE* OGC NRR/DORL/LP WB NAME JDion JPoole BClayton CHsu CKanatas NLO JQuichocho DATE 10/15/14 10/17/14 10/15/14 10/28/14 11/04/14 10/06/14 OFFICE NRR/JLD NRR/DORL/D NRR/OD NAME JDavis MEvans WDean DATE 11/07/14 11/17/14 11/21/14