Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 2 Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-20-014 September 23, 2020 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328 Subject: Application to Modify the Sequoyah Nuclear Plant Units 1 and 2 Technical Specification to Allow for Transition to Westinghouse RFA-2 Fuel (SQN-TS-20-09) References: 1. Summary of November 14, 2018, Meeting with Tennessee Valley Authority Regarding Presubmittal Licensing Actions - Sequoyah Nuclear Plant, Units 1 and 2 (ML18344A567) 2. Summary of January 31, 2019, Meeting with Tennessee Valley Authority Regarding Presubmittal Licensing Actions - Sequoyah Nuclear Plant, Units 1 and 2 (ML19038A469) 3. Summary of February 20, 2020, Public Meeting with Tennessee Valley Authority Regarding the Future Submittal of License Amendment Requests RE: Fuel Transition and Operation with One Control Rod Removed (ML20055C231) 4. NRC Letter to TVA, “Sequoyah Nuclear Plant, Unit 1 - Issuance of Exigent Amendment No. 348 to Operate One Cycle With One Control Rod Removed (EPID L-2019-LLA-0239),” dated November 21, 2019 (ML19319C831) 5. NRC Letter to TVA, “Sequoyah Nuclear Plant, Unit 2 - Issuance of Exigent Amendment No. 342 to Operate One Cycle with One Control Rod Removed (EPID L 2020 LLA 0078),” dated April 23, 2020 (ML20108F049) Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 2 Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 2 U.S. Nuclear Regulatory Commission CNL-20-014 Page 2 September 23, 2020 In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.90, “Application for amendment of license, construction permit, or early site permit,” Tennessee Valley Authority (TVA) is submitting a request for an amendment to Renewed Facility Operating License Nos. DPR-77 and DPR-79 for the Sequoyah Nuclear Plant (SQN) Units 1 and 2. This amendment is needed to facilitate transition to Westinghouse RFA-2 fuel with Optimized ZIRLOTM 1 cladding. The proposed change revises these Technical Specifications (TSs): TS 2.0 SAFETY LIMITS (SLs) TS 2.1.1, “Reactor Core SLs” Figure 2.1.1-1, “Reactor Core Safety Limit – Four Loops in Operation” is revised and relocated to the Core Operating Limits Report (COLR), Reactor Core Safety Limit 2.1.1.1 is revised to implement the methodology in the Westinghouse WRB-2M departure from nucleate boiling (DNB) correlation, and Reactor Core Safety Limit 2.1.1.2 is revised to implement the Westinghouse Performance Analysis and Design Model (PAD5) methodology for fuel melt temperature. TS 3.1.4, “Rod Group Alignment Limits” is revised to be consistent with revised TS 3.2.1, “Heat Flux Hot Channel Factor (FQ(Z))” Surveillance Requirement numbering. TS 3.1.7, “Rod Position Indication” is revised to implement BEACONTM 2 core power distribution measurement. TS 3.2.1, “Heat Flux Hot Channel Factor (FQ(X,Y,Z))” is revised to reflect Standard Technical Specification (STS) 3.2.1 in NUREG-1431 and the methodology in WCAP-17661-P-A Revision 1, “Improved RAOC and CAOC FQ Surveillance Technical Specifications” with deviations to the Condition B Required Action Completion Times. TS 3.2.2, “Nuclear Enthalpy Rise Hot Channel Factor F∆H(X,Y),” and 3.2.4, “Quadrant Power Tilt Ratio (QPTR),” are revised to implement Westinghouse STS format and content consistent with NUREG-1431, and TS 3.2.4 is revised to implement BEACON core power distribution measurement. TS 3.3.1, “RTS Instrumentation” is revised to implement BEACON core power distribution measurement and relocation of OT∆T and OP∆T setpoint parameter values to the COLR consistent with TSTF-339-A, Rev. 2, “Relocate TS Parameters to COLR,” and WCAP-14483-A, “Generic Methodology for Expanded Core Operating Limits Report.” TS 3.4.1, “RCS Pressure, Temperature, and Flow Departure from Nucleate Boiling (DNB) Limits” is revised to reflect a lower Thermal Design Flow rate and the relocation of parameter values to the COLR consistent with TSTF-339-A and WCAP-14483-A. __________________ 1Optimized ZIRLO is a trademark or registered trademarks of Westinghouse Electric Company LLC, its affiliates and/or its subsidiaries in the United States of America and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited. Other names may be trademarks of their respective owners. 2BEACON, FULL SPECTRUM and FSLOCA are trademarks or registered trademarks of Westinghouse Electric Company LLC, its affiliates and/or its subsidiaries in the United States of America and may be registered in other countries throughout the world. All rights reserved. Unauthorized use is strictly prohibited. Other names may be trademarks of their respective owners. Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 2 Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 2 U.S. Nuclear Regulatory Commission CNL-20-014 Page 3 September 23, 2020 TS 4.2.1, “Fuel Assemblies” is revised to add Optimized ZIRLO as a fuel assembly cladding material in accordance with WCAP-12610-P-A & CENPD-404-P-A, Addendum 1-A, “Optimized ZIRLO.” TS 4.2.1, “Fuel Assemblies,” is revised to delete the reference to Framatome lead test assemblies and the corresponding BAW-2328 topical report. TS 4.2.2, “Control Rod Assemblies” is revised to reflect 52 rod cluster control assembly (RCCAs) for Units 1 and 2. TS 5.6.3, “Core Operating Limits Report” is revised to reflect Westinghouse core safety analysis methodologies and to replace the loss-of-coolant accident (LOCA) analysis evaluation model references with the FULL SPECTRUM™3 Loss-of-Coolant Accident (FSLOCA™3) Evaluation Model analysis applicable to SQN Units 1 and 2. In addition, the following Operating License (OL) License Conditions are proposed for replacement with new restrictions associated with the mixed or transition cores. Unit 1 OL, License Condition 2(C)25 Unit 2 OL, License Condition 2(C)18 In Reference 1, TVA proposed an alternative approach for a fuel transition license amendment. NRC provided feedback on this approach via public meeting in Reference 2, noting specific concerns related to the fuel transition to be included for review for the staff to independently verify the fuel transition could be implemented in conformance with NRC requirements. Therefore, in addition to the TS and OL changes discussed above, the proposed change presents the following to address the staff’s feedback: The core configurations for the transition based on the expected transition and equilibrium core designs being presented. The operating limits for the RFA-2 fuel and the Framatome HTP fuel in the transition cores. The use of the Westinghouse methods for core design and for determining core operating limits in the transition cores and subsequent equilibrium cores containing only RFA-2 fuel. The safety analyses, specifically, that these analyses satisfy the applicable conditions and limitations associated with the employed methods and that these analyses meet applicable safety analysis and regulatory acceptance criteria. Enclosure 1 provides a description of the proposed changes, technical evaluation of the proposed changes, regulatory evaluation, and a discussion of environmental considerations. Attachments 1 and 2 to the enclosure provide the existing TS pages marked-up to show the proposed changes for __________________ 3 FULL SPECTRUM and FSLOCA are trademarks of Westinghouse Electric Company LLC Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 2 Proprietary Information Withhold Under 10 CFR § 2.390 This letter is decontrolled when separated from Enclosure 2 U.S. Nuclear Regulatory Commission CNL-20-014 Page 4 September 23, 2020 SQN Unit 1 and Unit 2, respectively. Attachments 3 and 4 to the enclosure provide the SQN Unit 1 and Unit 2 TS pages retyped to show the proposed changes. Attachment 5 to the enclosure provides the existing SQN Unit 1 TS Bases pages marked-up to show the proposed changes. Only the Unit 1 TS Bases pages have been provided, as the Unit 2 changes will be nearly identical except for some editorial differences. Changes to the existing TS Bases are provided for information only and will be implemented under the TS Bases Control Program. As discussed in References 4 and 5, both units have approved temporary Technical Specification changes to allow the RCCA in core location H-08 to be removed. As a result of the timing of the fuel transition, the request for permanent removal of the RCCA has been integrated into the attached amendment request. Enclosure 1 also contains: Attachment 6 – revised Core Operating Limits Report (COLR) Template for SQN Units 1 and 2 (For Information Only) Attachment 7 – revised Technical Requirements Manual (TRM) (Mark-Ups) for SQN Unit 1 (For Information Only) Attachment 8 – Compliance with Limitations and Conditions from NRC-Approved Newly Applied Topical Reports Attachment 9 – Justification for Permanent Removal of SQN Units 1 and 2 RCCA H-08 Attachment 10 – Sequoyah Safety Analysis UFSAR Impact Summary for the WEC RFA-2 Fuel Transition Enclosure 2 to this letter provides a summary of the SQN Units 1 and 2 LOCA Analysis with the FSLOCA Evaluation Methodology. This document contains information that Westinghouse Electric Company LLC considers to be proprietary in nature and subsequently, pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Part 2.390, “Public inspections, exemptions, requests for withholding,” paragraph (a)(4), TVA requests that this proprietary information be withheld from public disclosure.