POLICY ISSUE

 (Information) 

September 29, 2014 SECY-14-0102

FOR: The Commissioners 

FROM: Daniel H. Dorman, Acting Director /RA/

 Office of Nuclear Reactor Regulation 

SUBJECT: CONSTRUCTION AND LICENSING FOR WATTS BAR NUCLEAR 

PLANT, UNIT 2 

PURPOSE

The objective of this paper is to inform the Commission of the Nuclear Regulatory Commission’s 

(NRC’s) staff licensing and inspection activities in response to the request by the Tennessee 

Valley Authority (TVA) to issue an operating license (OL) for full power operation of the Watts 

Bar Nuclear Plant (WBN) Unit 2. This paper does not address any new commitments or 

resource implications. The NRC staff expects this SECY paper to be its final information paper 

to the Commission on this matter. 

SUMMARY

The licensing of WBN Unit 2 is a project that spans five decades at the NRC with the original 

construction permit (CP) granted in 1973. The NRC staff developed a regulatory framework and 

established a licensing approach specifically for the project to ensure that a thorough and 

high-quality review is complete before rendering a decision regarding issuance of the OL. The 

NRC staff developed a construction inspection program to address WBN Unit 2’s unique history 

and to provide inspection guidance that reflects current inspection practices. As construction 

nears completion, inspections are on track to support a licensing decision in 2015. The NRC 

staff is developing a Reactor Oversight Process (ROP) transition plan to ensure that safety and 

CONTACT: Justin C. Poole, NRR/DORL 

 301-415-2048 

 
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security performance is properly inspected as Unit 2 transitions to commercial operation, should 

an OL be granted. As the project nears completion, the NRC staff is coordinating the 

management and resolution of the remaining technical and licensing open items, such as 

ensuring that the National Environmental Policy Act (NEPA) requirements are met (given the 

rulemaking on Continued Storage of Spent Nuclear Fuel) and completing the licensing basis 

hydrology review for WBN Unit 2. The NRC schedule for completing its reviews to support an 

OL decision currently aligns with TVA’s schedule to start commercial operation in 

December 2015, provided that TVA maintains their construction schedule and submits timely 

and high-quality submittals to resolve the remaining open items for licensing. 

BACKGROUND

WBN consists of two Westinghouse-designed four-loop pressurized-water reactors within 

ice-condenser containments. TVA received a CP for both Units 1 and 2 in 1973 under Part 50, 

“Domestic Licensing of Production and Utilization Facilities,” of Title 10, “Energy,” of the Code of 

Federal Regulations (10 CFR). Construction on both plants proceeded until 1985, when 

significant deficiencies in the Quality Assurance Program were identified. At that time the 

majority of WBN’s Unit 1 and 2 structures were built and significant components (such as the 

reactor pressure vessel and reactor coolant system piping) were installed. In response to these 

deficiencies, TVA developed a Nuclear Performance Plan for Unit 1, which the NRC staff 

reviewed and found acceptable in 1989, as documented in Volume 4 of NUREG-1232 

(Agencywide Documents Access and Management System (ADAMS) Accession 

No. ML073512032). This plan was successfully implemented and subsequently, WBN Unit 1 

received its full-power OL in early 1996. When TVA resumed construction, they focused their 

efforts on finishing WBN Unit 1 and deferred activities on WBN Unit 2. Because of this, the 

Supplemental Safety Evaluation Reports (SSERs) published after the NRC staff resumed the 

licensing review for Unit 1 did not contain conclusions involving Unit 2. Enclosure 1 provides a 

table of all SSERs. A complete licensing history of WBN Unit 2 is given in Enclosure 2. 

LICENSING PROCESS

All operating nuclear power plants in the United States were licensed under a two-step process 

described in 10 CFR Part 50 (Part 50). The licensing process under 10 CFR Part 50 has two 

review stages. First, an application is submitted for a CP that would authorize construction of 

the proposed facility. The focus of this stage of the NRC staff’s review is on the preliminary 

design of the facility and on the suitability of the proposed site. The second stage of the staff’s 

review involves the evaluation of an OL application in which the staff reviews the final design of 

the plant, verifies its construction, and inspects the testing, operations, and emergency 

preparedness (EP) aspects of the review. The initial CP for WBN Unit 2 was granted in 1973 

under the Part 50 licensing process. When TVA informed the NRC of its plan to complete WBN 

Unit 2, they chose to proceed under the Part 50 licensing process. 

Establishment of Regulatory Framework for WBN Unit 2

On August 3, 2007, TVA informed the NRC of its plan to complete construction activities at 

WBN Unit 2 under the existing CP. In Staff Requirements Memorandum (SRM)-SECY-07-0096, 

“Staff Requirements—Possible Reactivation of Construction and Licensing Activities for the 

Watts Bar Nuclear Plant, Unit 2,” dated July 25, 2007, the Commission directed the NRC staff to 
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employ the current licensing basis for Unit 1 as the reference basis for the licensing review of 

WBN Unit 2. 

In 2008, the NRC staff developed Inspection Manual Chapter (IMC) 2517, “Watts Bar Unit 2 

Construction Inspection Program,” to provide overall inspection guidance specifically for WBN 

Unit 2. IMC 2517 provides guidance for planning, scheduling, and implementing inspections 

specified in IMC 2512, “Light Water Reactor Inspection Program - Construction Phase,” and 

IMC 2513, “Light Water Reactor Inspection Program - Preoperational Testing and Operational 

Preparedness Phase.” After the license is issued, IMC 2517 will remain in effect until 

commercial operation. This will encompass inspections of startup testing activities in 

accordance with IMC 2514, “Light Water Reactor Inspection Program Startup Testing Phase.” 

Also in 2008, the NRC staff developed a licensing process, documented in Office Instruction 

(OI) LIC-110, “Watts Bar Unit 2 License Application Review,” that describes the NRC staff’s 

approach to perform the OL review for WBN Unit 2. This licensing review process implements 

the direction given to the NRC staff by the Commission documented in SRM-SECY-07-0096. 

Since the implementation of this licensing review process, the NRC staff continued its review of 

the WBN Unit 2 OL review with SSER 21 (see Enclosure 1). The NRC staff developed an 

Action Items Table to provide a status of all the open items, confirmatory issues, and proposed 

license conditions starting in SSER 22 as Appendix HH. 

On July 10, 2009, the NRC established the WBN Unit 2 Reactivation Assessment Group 

(WRAG) and its initial charter (ADAMS Accession No. ML091250168). The charter was last 

updated in 2012 (ADAMS Accession No. ML12163A406) and identifies WRAG members, who 

are led by division-level management from Region II and the Office of Nuclear Reactor 

Regulation (NRR). The WRAG has the responsibility to oversee the project completion and 

serves as the focal point for the status of the project and for coordination between the Region 

and Offices at Headquarters. The WRAG meets periodically and, at the appropriate time, will 

inform the Office Director of NRR and the Regional Administrator for Region II that activities 

discussed in NRR OI LIC-110 and NRC IMC 2517 have been successfully completed. 

CURRENT LICENSING ACTIVITIES

The NRC staff has provided the Commission with updates of the licensing activities for WBN 

Unit 2 since 2009, as documented in Information SECY papers SECY-09-0012, SECY-10-0015, 

SECY-10-0166, SECY-11-0102, SECY-12-0020, and SECY-12-0103. Since the last 

Information Paper on July 24, 2012, the NRC staff issued SSER 26, received a letter from the 

Federal Emergency Management Agency (FEMA) documenting its reasonable assurance 

finding, held ACRS subcommittee and full committee meetings, issued Supplement 2 to the 

WBN Unit 2 Final Environmental Statement (FES), resolved the last remaining contention about 

the FES, renewed the CP, resolved Generic Safety Issue (GSI)-191, “Assessment of Debris 

Accumulation on Pressurized-Water Reactor Sump Performance,” and renewed Special 

Nuclear Material License (SNM)-2014. 

Regarding GSI-191, the NRC staff completed its review of TVA’s response to Generic 

Letter 2004-02, “Potential Impact of Debris Blockage on Emergency Recirculation during Design 

Basis Accidents at Pressurized-Water Reactors,” dated September 13, 2004, as supplemented 

on May 17, 2012, based on the “clean plant” guidelines and methodology developed by the 

Nuclear Energy Institute. The NRC staff found TVA’s results satisfactory as noted in the 
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September 18, 2014, letter, to TVA at ADAMS Accession No. ML14163A658. In 

SRM-SECY-07-0096, the Commission had provided this GSI as an example where the 

unirradiated state of WBN Unit 2 would make it easier to resolve the issue prior to plant 

operation. 

Licensing Activities Nearing Completion

The NRC staff is nearing completion of its safety review of TVA’s Final Safety Analysis Report 

(FSAR). The next SSER to be issued is SSER 27 which will document the remaining 

Appendix HH open items related to the FSAR topics that will require confirmation, inspection 

verification, receipt of final technical specification (TS) information, or submission of additional 

information for the NRC staff’s evaluation. TVA is addressing the remaining open issues as the 

construction progresses. SSER 27 will also capture specific topics of interest identified by the 

ACRS for its review. They include the NRC staff’s evaluation of the hydrology analysis; 

GSI-191; the emergency raw cooling water system as part of General Design Criterion (GDC) 5, 

“Sharing of Structures, Systems, and Components,” in Appendix A, “General Design Criteria for 

Nuclear Power Plants, to 10 CFR Part 50; use of Performance Analysis and Design Model 

(PAD) 4.0 code to model fuel thermal conductivity degradation; the as-built version of the fire 

protection report; and Eagle 21 process protection system communication tests. For both the 

hydrology and as-built fire protection report reviews, the NRC staff is waiting for information 

from TVA to complete these complex technical reviews. Timely submittals are necessary to 

allow the NRC staff to complete its safety review and to schedule upcoming ACRS meetings. 

Regarding the NRC staff’s review of the EP plan in SSER 22, the NRC staff had documented its 

review of the EP plan and concluded, subject to confirmatory items, that the EP plan provided 

an adequate basis for an acceptable state of onsite emergency preparedness and that there 

was reasonable assurance that adequate protective measures can and will be taken in a 

radiological emergency at either WBN Unit 1 or WBN Unit 2. One of these confirmatory items 

required TVA to provide the latest revision of the EP plan for the NRC staff to review any 

changes that had been made since the earlier SER was issued in February 2011. In addition, 

the final EP regulations issued in November 2011 added new regulatory requirements and 

amended others. On September 12, 2014, TVA submitted its final revision to the EP plan; the 

NRC staff will document its review of the changes in SSER 27. 

Each license authorizing operation of a utilization facility includes TSs, which are required by 

10 CFR 50.34. The Commission may include such additional TSs as the Commission finds 

appropriate. To be consistent with SRM-SECY-07-0096, the WBN Unit 2 TSs will be similar to 

the WBN Unit 1 TSs, but will take into account some design differences between the two units. 

The NRC staff is currently reviewing the latest revision to the TSs. The completion of the NRC 

staff’s review of the TSs is based on the timely resolution by TVA of any technical issues 

identified by the NRC staff. 

The NRC staff is addressing pre-1995 generic communications (i.e., bulletins, generic letters, 

and orders), including Three Mile Island Action Plan items, as part of the FSAR review. This 

effort is still in progress and includes evaluation of certain changes to the proposed TSs. With 

regard to post-1995 generic communications, the NRC staff has completed its review of TVA 

responses to all but two of the required generic communications. The first, NRC 

Bulletin 2012-01, “Design Vulnerability in Electric Power System,” dated July 27, 2012, 

requested that information be provided describing how the protection scheme for Engineered 
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Safety Feature (ESF) buses is designed to detect and automatically respond to single-phase 

open-circuit conditions. The NRC staff is performing its review of TVA’s responses to a Request 

for Additional Information, which will be documented in SSER 27. 

The second, NRC Bulletin 2011-01, “Mitigating Strategies,” dated May 11, 2011, required 

addressees to provide a comprehensive verification of their compliance with the regulatory 

requirements in 10 CFR 50.54(hh)(2) in light of the recent events at Japan’s Fukushima Dai-ichi 

facility. In a letter dated July 18, 2011, TVA stated that it will respond to the bulletin in a way 

consistent with the response taken for WBN Unit 1 prior to licensing of Unit 2. In a safety 

evaluation dated April 23, 2012, the NRC staff verified that TVA provided the information 

requested in Bulletin 2011-01 and concluded that TVA has completed all of the requirements of 

the bulletin for WBN Unit 1. The NRC staff will review TVA’s response for WBN Unit 2, which is 

expected in October 2014, and will take appropriate action should it deem that further regulatory 

action is necessary based on the ongoing evaluations of this event. 

On March 12, 2012, the NRC issued orders to OL and CP holders requiring them to take actions 

that the NRC determined would provide a substantial increase in protection to public health and 

safety based on the events that occurred at the Fukushima Dai-ichi power plant in Japan. Of 

these three orders issued on March 12, 2012, two are applicable to the design of WBN Unit 2 

(those regarding spent fuel pool instrumentation and mitigating strategies). The orders state 

that the holder of a CP must complete full implementation before issuance of an OL, and that 

the holder shall report to the Commission when full compliance is achieved. TVA is expected to 

submit its compliance letters for the two orders in October 2014. The NRC staff intends to issue 

its safety evaluation and perform inspections to document the NRC staff’s review of the actions 

taken for WBN Unit 2. 

Also on March 12, 2012, the NRC issued requests for information under 10 CFR 50.54(f) 

regarding Recommendations 2.1, 2.3, and 9.3 of the Near-Term Task Force Review of Insights 

from the Fukushima Dai-ichi Accident (ADAMS Accession No. ML112510271). The purpose of 

these 50.54(f) letters is to gather information for the NRC staff to determine whether further 

regulatory action is required. Because of the co-located nature of the site and the sharing of 

certain systems and facilities, the NRC staff intends to hold WBN Unit 2 to the same timelines 

that WBN Unit 1 has committed to in their responses. The NRC staff will review TVA’s 

response and will take appropriate action should it deem that further regulatory action is 

necessary based on the ongoing evaluations of this event. 

As part of its updated OL application, TVA submitted a supplement to its final environmental 

impact statement for the completion and operation of WBN Unit 2. The NRC staff completed its 

review and published Supplement 2 to the Final Environment Statement in May 2013 (Vols. 1 

and 2 of Supplement 2 to NUREG-0498, ADAMS Accession No. ML13144A202). The NRC 

staff’s recommendation related to environmental aspects of issuing the WBN Unit 2 OL is that 

the license should be issued as proposed. This recommendation is based on TVA’s application, 

including the NRC’s staff review of the original Final Environmental Statement (FES) OL 

from 1978; consultation with Federal, State, Tribal, and local agencies; the NRC staff’s own 

independent review of information available since the preparation and publication of the 

1978 FES OL; and assessments summarized in Supplement 2 to NUREG-0498, including 

consideration of public comments received on the draft Supplement FES. The NRC staff’s FES 

(published in May 2013) for WBN Unit 2 stated that the updated Waste Confidence (now 

Continued Storage of Spent Nuclear Fuel) rule and supporting Generic Environmental Impact 
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Statement (GEIS) will provide the necessary NEPA analyses of waste-confidence-related 

human health and environmental issues and that if the results of the GEIS identify information 

that requires a supplement to the WBN Unit 2 FES, the NRC staff would perform any 

appropriate NEPA review before making a final licensing decision. The NRC staff is currently 

evaluating the implementation of the Continued Storage of Spent Nuclear Fuel rule that was 

approved by the Commission on August 26, 2014. 

As part of its statutory responsibilities, ACRS reviews applications for CPs and facility OLs and 

advises the Commission on the hazards of proposed reactor facilities. The NRC staff presented 

the licensing and oversight status of the WBN project to the ACRS in a subcommittee meeting 

on June 4, 2013, and a full committee meeting on November 6, 2013. On November 26, 2013, 

the ACRS issued an interim letter requesting that the NRC staff prepare to discuss the following 

at the final ACRS meetings: 

• NRC staff’s evaluation of TVA’s response to addressing GSI-191 at WBN Unit 2 

• NRC staff’s evaluation of TVA’s demonstration that Model PAD 4.0 can handle thermal 

conductivity degradation 

• NRC staff’s evaluation of TVA’s testing of the Eagle 21 communication system 

• NRC staff’s evaluation of how WBN Unit 2 meets GDC 5 

• NRC staff’s evaluation of the hydrology review 

• NRC staff’s evaluation of how TVA addressed fire-protection procedures related to 

operator manual actions 

The NRC staff expects the upcoming subcommittee and full committee meetings to be the last 

ACRS meetings on the WBN Unit 2 OL application (see Enclosure 3). The NRC staff will 

request the ACRS to endorse the NRC’s review of the OL application in the form of a letter to 

the Commission. 

OVERSIGHT ACTIVITES

The NRC staff has developed customized approaches specifically for WBN Unit 2 for 

construction inspection, corrective-action programs, oversight of TVA’s refurbishment program, 

and an ROP Transition plan. These programs are tailored to ensure that the WBN Unit 2 site is 

constructed in accordance with regulations and that NRC oversight is maintained during the 

licensing process and as WBN Unit 2 transitions to commercial operation. 

Construction Inspection Program

To address the unique history of WBN Unit 2, a customized construction inspection program 

was created. New inspection guidance, IMC 2517, was developed to (1) provide the policies 

and requirements for the WBN Unit 2 construction inspection program during that unit's 

resumption of construction after an approximately 20-year suspension of construction activities, 

and (2) establish a record of the inspection activities, applicant actions, and technical issues 
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resolved to support the decision for issuing an OL. IMCs 2512, 2513, and 2514 are being used 

as written. 

In addition to the inspection procedures contained in the above IMCs, the NRC staff recognized 

that other areas needed to be considered for inspection at WBN Unit 2. These areas included 

generic communications, corrective-action programs (CAPs), special programs (SPs), cyber 

security, historical inspection open items, construction deficiency reports, items identified during 

licensing reviews, allegations, and refurbishment activities. The NRC staff screened generic 

communications, inspection open items and allegations to determine which items warranted 

further inspections. To allow tracking and monitoring of construction inspection items for WBN 

Unit 2, the NRC staff developed the Inspection Planning and Scheduling (IP&S) database. This 

database included the inspection procedures from IMC 2512 and the items from the other areas 

mentioned above. 

As of September 15, 2014, 430 IP&S items have been completed and closed. The majority of 

the remaining 120 open IP&S items have been inspected at least once and the inspectors are 

waiting on either additional information or completion of field activities before closing. 

Inspections for many of the construction-related programs (such as engineering and design 

control, corrective actions, and quality assurance) have been completed. Some of the 

inspection areas that remain open include fire protection, as-built verifications, and 

instrumentation and controls. 

The inspections of preoperational testing (IMC 2513) and startup testing (IMC 2514) are being 

performed as specified in the applicable program requirements. As part of the 

inspection-scoping process specific to WBN Unit 2, Region II identified 86 separate inspections 

from IMC 2513 and 2514. These include the operational-preparedness inspections. 

Corrective-Action Programs

The NRC staff’s corrective-action inspections include a continuing review of TVA’s 

implementation of the CAPs and SPs to resolve concerns about the quality of construction at 

WBN in the 1970s and early 1980. The NRC staff has completed inspections for 18 CAPs and 

SPs. 11 open CAPs and SPs remain to be reviewed and closed. Each of these items has 

received some level of inspection; however, TVA must complete additional activities associated 

with these items before the NRC staff can complete their inspection. 

Construction Inspection Planning Activities

Region II is maintaining the inspection schedule by using the best information available about 

the remaining construction activities and the preoperational schedule. To ensure that inspectors 

are available to observe and review construction and preoperational test activities, Region II 

conducts routine communications with TVA to discuss the schedule and ensure that inspection 

needs are supported. In addition, more of the field verification inspections have been assigned 

to the resident inspectors, who have been flexible in meeting changes to TVA’s construction 

schedule. 

Region II conducted comprehensive planning for pre-operational testing inspections and 

assigned a team leader to oversee this effort. This has resulted in sufficient inspection 

resources being applied to allow observation and review of ongoing and completed construction 
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activities, as well as witnessing of preoperational testing activities. The inspection program 

implementation has largely moved from inspection of bulk construction activities to reviewing the 

individual IP&S open items, reviewing completion of individual plant systems, and reviewing the 

preoperational testing program. 

Preoperational testing inspection, in accordance with IMC 2513, was completed for the 

open-vessel test involving verification of the emergency core-cooling system’s capability to 

inject into the reactor vessel. Remaining preoperational testing activities include cold reactor 

coolant system pressurization testing, plant hot functional testing, containment leak-rate testing, 

and reactor protection system testing. NRC inspection activities will be coordinated to observe 

and review the results of each of these tests. Planning efforts for startup testing inspections 

specified in IMC 2514 are underway. 

Refurbishment Program

The refurbishment program was created by TVA to ensure that the design and licensing basis, 

including original equipment design specifications, would be met, given that most of the 

safety-related and quality-related equipment was installed during original construction. 

The NRC staff reviewed TVA’s refurbishment program and found the following: (1) TVA was 

refurbishing or replacing most active components and instruments; (2) TVA had determined the 

potential degradation mechanism for each category of components, along with any contributing 

environmental factors; (3) the acceptance criteria were developed from the licensing basis, 

design specifications, and vendor specifications; (4) the proposed inspections and testing 

included in the program could be expected to identify degradation; and (5) refurbishment 

activities would be in accordance with applicable vendor and design specifications or 

requirements. The NRC staff also found that TVA’s proposed refurbishment plan provides 

adequate guidance and objectives for the development of implementing procedures. The NRC 

staff concluded that the TVA refurbishment program, if properly implemented, will provide 

reasonable assurance that the equipment will meet its design criteria and perform its intended 

function. 

Inspection guidance specific to the WBN Unit 2 refurbishment program was developed by the 

NRC staff and issued as Inspection Procedure (IP) 37002, “Construction Refurbishment 

Process - Watts Bar Unit 2,” on February 5, 2010. Region II has been inspecting refurbishment 

activities since the IP was issued. Both active and passive components were included in these 

inspections. One area the inspectors focused on was TVA’s inspection of piping and their 

identification of any piping degradation. Although the inspection objectives of IP 37002 were 

satisfied and the IP was closed, construction inspections to review refurbishment activities 

continue. For example, inspecting the installation of a new pressure transmitter under the 

IP 52053, “Instrument Components and Systems - Work Observation,” would also cover a 

refurbishment activity that replaced the originally installed transmitter. 

Force-on-Force (FoF) Performance Inspections

NRC-conducted Force-on-Force (FoF) performance inspections typically do not have a direct 

bearing on a licensing decision for a power reactor. In the case of WBN Unit 2 licensing, the 

security posture for WBN Unit 2 will be merged with that of WBN Unit 1, and the 

NRC-conducted FoF inspections for both units will occur during the regular inspection cycle. 
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The verification of effective integration of the site’s protective strategy to incorporate protection 

of WBN Unit 2 will be accomplished before unit operation by NRC regional inspectors observing 

and evaluating a licensee-conducted FoF exercise to demonstrate that the protective strategy 

can defend against the attributes of the design-basis threat. 

Cyber Security Implementation

In April 2011, WBN Unit 2 submitted a cyber security plan and associated implementation 

schedule which were reviewed and approved by staff and incorporated into the licensing basis. 

The licensee’s implementation schedule for WBN Unit 2 requires full cyber security program 

implementation (completion of Milestones 1 through 8) before startup, with the exception of two 

systems common to operation of WBN Unit 1 and 2. Based on insights gained during 

inspection of the WBN cyber security program for Milestones 1 through 7, staff anticipates that 

WBN Unit 2 may be challenged to fully implement cyber security controls in accordance with its 

implementation schedule, as approved. TVA plans to submit an update to its implementation 

schedule for WBN Unit 2 to revise commitments regarding timing of cyber security control full 

implementation (i.e., Milestone 8) in October 2014. The NRC staff will review any revised 

commitments to ensure compliance with 10 CFR 73.54, “Protection of Digital Computer and 

Communication Systems and Networks” and 10 CFR 73.55, “Requirements for Physical 

Protection of Licensed Activities in Nuclear Power Reactors Against Radiological Sabotage.” 

WBN Unit 1, which shares cyber security program elements with WBN Unit 2, has requested to 

delay full cyber security program implementation until June 30, 2016, which is after WBN 

Unit 2’s anticipated startup date. This request is currently under review by the NRC staff. 

Reactor Oversight Process Transition

The overall approach for transitioning WBN Unit 2 to the ROP will be in accordance with the 

guidance contained in IMC 2517. Construction inspection, assessment, and enforcement under 

IMC 2517 will apply to WBN Unit 2 through the implementation of the IMC 2514 inspection 

program. Should an OL be issued, the NRC staff will also conduct the IMC 2515 baseline 

inspection program. The successful completion of these inspection programs will provide 

reasonable assurance that each cornerstone of safety is ready to be monitored under the ROP. 

The transition of WBN Unit 2 to the ROP will be a phased approach on an individual 

cornerstone basis. It is expected that the Emergency Preparedness, Security, and Radiation 

Protection cornerstones will be transitioned to the ROP at the time the OL is issued because 

these programs are already established for WBN Unit 1 and immediately applicable to WBN 

Unit 2. The transition of the remaining three cornerstones (Mitigating Systems, Barrier Integrity, 

and Initiating Events) will occur after the startup test program is completed and commercial 

operation begins. The ROP transition plan will outline the inspection details, including the 

duration of augmented inspection required until all Performance Indicators are determined to be 

valid. 

FUTURE ACTIONS AND MILESTONES

On September 9, 2014, the Atomic Safety and Licensing Board issued an order denying the 

only pending contention and terminated the adjudicatory proceeding related to WBN Unit 2, 

noting that, in accordance with 10 CFR 2.341(b), any petition for review of its Memorandum and 

Order must be filed within twenty-five days after it was served. 
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In accordance with the Commission's regulations and policies, the NRC staff plans to request 

needed authority to issue the OL for WBN Unit 2 at the appropriate time. To do so, the NRC 

staff will submit a Commission Notation Vote Paper after TVA's construction of the plant and the 

NRC's review of the operating license application are substantially complete. The NRC staff 

estimates that the Commission Notation Vote Paper will be submitted between 30 to 60 days 

before the NRC staff forecasts that the final decision on issuance of the WBN Unit 2 OL could 

be made. 

A number of key activities will occur concurrent with or after submission of the Commission 

Notation Vote Paper. These activities include: a letter by ACRS to the Commission providing 

its views of the staff’s review of the OL application, a letter by TVA certifying its readiness for 

fuel load, and a report from the Region II Administrator to the Office Director of NRR of a status 

of construction inspection activities. The latter report will provide significant inspection insights, 

inspection items that remain open, and the Region II Administrator’s recommendations 

regarding issuance of an OL. Should the Commission grant the authority, the Office Director of 

NRR will require this final information before making a finding that the requirements of 

10 CFR 50.57 have been met and therefore issue the OL. 

Should it receive an OL, TVA plans to load fuel between April and June of 2015 to support 

commercial operation of WBN Unit 2 by December 2015. Currently, the NRC expects to make 

an OL decision between April and June of 2015, which would be consistent with TVA’s request 

for issuance. NRC’s issuance of the OL is contingent on TVA providing the NRC staff with 

sufficient detailed information required to complete the NRC staff’s review. TVA could load fuel 

immediately after receiving the OL, at which point startup testing and associated NRC 

inspections would be performed to verify all safety requirements are met before commercial 

operation. 

Enclosure 3 provides a pictorial depiction of future activities and milestones, along with the 

expected periods for accomplishment. The representation of these activities and milestones 

should not be taken as any predisposition of findings or conclusions by the NRC staff. 

OUTREACH

Since 2007, the NRC has held over 100 public meetings across various topics including the 

environmental review, technical issues in the safety review, and construction inspection 

performance assessment. In addition, the WRAG held several Category 1 and 3 public 

meetings near the site. 

At the WRAG public meetings, TVA provides the status of construction activities, and the NRC 

describes the status of the licensing and inspection program at WBN Unit 2. Current technical 

topics are also routinely discussed. The NRC staff provides the public time to ask questions 

about and comment on the WBN Unit 2 construction project. Typically about a dozen members 

of the public attend these meetings and actively participate. Members of the media have also 

attended these meetings. The last meeting took place on April 9, 2014, in Athens, TN. The 

next meeting is planned for October 1, 2014. 

In addition to public meetings, the NRC staff uses the agency’s social media tools, such as the 

NRC blog and twitter account, to enhance public participation and awareness of the WBN Unit 2 

project. 
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Information about the NRC’s licensing and oversight activities related to WBN Unit 2 is available 

to the public at http://www.nrc.gov/info-finder/reactor/wb/watts-bar.html. 

COORDINATION

The Office of the General Counsel has reviewed this paper and has no legal objection. The 

Office of the Chief Financial Officer has reviewed this paper for resource implications and has 

no objections. 

 

 

 Daniel H. Dorman, Acting Director 

 Office of Nuclear Reactor Regulation 

Enclosures: 

1. Supplemental Safety 

Evaluation Reports (SSERs) to Date 

2. Watts Bar Nuclear Plant Unit 2 History 

3. Watts Bar Nuclear Plant Unit 2 

Licensing Timeline 
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Information about the NRC’s licensing and oversight activities related to WBN Unit 2 is available 

to the public at http://www.nrc.gov/info-finder/reactor/wb/watts-bar.html. 

COORDINATION

The Office of the General Counsel has reviewed this paper and has no legal objection. The 

Office of the Chief Financial Officer has reviewed this paper for resource implications and has 

no objections. 

 

 Daniel H. Dorman, Acting Director 

 Office of Nuclear Reactor Regulation 

Enclosures: 

1. Supplemental Safety 

Evaluation Reports (SSERs) to Date 

2. Watts Bar Nuclear Plant Unit 2 History 

3. Watts Bar Nuclear Plant Unit 2 

Licensing Timeline

ADAMS Accession Nos.: SECY Paper: ML14238A672 *via email **via phone

OFFICE NRR/LPL2-2 NRR/LPL2-

2/PM NRR/LPL2-2/LA NRR/LWBP/BC NRR/DLR* NRR/DIRS* NRR/DE* NRR/JLD* NRR/DRA* 

NAME JDion JPoole BClayton JQuichocho JLubinski 

(SWeerakkody for)

SMorris 

(AHowe for) PHiland JDavis JGiitter 

DATE 8/27/14 8/28/14 8/27/14 8/28/14 9/15/14 9/15/14 9/15/14 9/11/14 9/16/17 

OFFICE NRO** NSIR* NMSS/FCSS/D* R-II/RA* TechEditor* NRR/DORL/D (A) OGC - NLO NRR/D 

NAME GTracy 

(JMonninger for) JWiggins MBailey 

(ABlamey for) VMcCree CHsu LLund DRoth DDorman 

DATE 9/15/14 9/15/14 9/15/14 9/19/14 9/17/14 9/8/14 9/22/14 9/29/14 

OFFICIAL RECORD COPY 
Enclosure 1 

Supplemental Safety Evaluation Reports (SSERs) to Date 

Supplemental 

Safety Evaluation 

Report 

(Number of the 

Supplement to 

NUREG-0847) 

Agencywide 

Documents Access and 

Management System 

Accession No. 

WBN Unit to Which the 

SSER is Primarily 

Applicable 

Publication Date 

Supplement 26 ML13205A136 Unit 2 June 2013 

Supplement 25 ML12011A024 Unit 2 December 2011 

Supplement 24 ML11277A148 Unit 2 September 2011 

Supplement 23 ML11206A499 Unit 2 July 2011 

Supplement 22 ML110390197 Unit 2 February 2011 

Supplement 21 ML090570741 Unit 2 February 2009 

Supplement 20 ML072060498 Unit 1, full power license February 1996 

Supplement 19 ML070530539 Unit 1, low power license November 1995 

Supplement 18 ML070530364 Unit 1 October 1995 

Supplement 17 ML072060496 Unit 1 October 1995 

Supplement 16 ML072060493 Unit 1 September 1995 

Supplement 15 ML072060488 Unit 1 June 1995 

Supplement 14 ML072060486 Unit 1 December 1994 

Supplement 13 ML072060484 Unit 1 April 1994 

Supplement 12 ML072060479 Unit 1 October 1993 

Supplement 11 ML072060476 Unit 1 April 1993 

Supplement 10 ML072060473 Unit 1 October 1992 

Supplement 9 ML072060469 Unit 1 June 1992 

Supplement 8 ML072060478 Unit 1 January 1992 

Supplement 7 ML072060471 Unit 1 September 1991 

Supplement 6 ML072060464 Unit 1 April 1991 

Supplement 5 ML072060527 Unit 1 November 1990 

Supplement 4 ML072060524 Unit 1 and Unit 2 March 1985 

Supplement 3 ML072060520 Unit 1 and Unit 2 January 1985 

Supplement 2 ML072060518 Unit 1 and Unit 2 January 1984 

Supplement 1 ML072060500 Unit 1 and Unit 2 September 1982 

Initial Report ML072060490 Unit 1 and Unit 2 June 1982 
Enclosure 2 

Watts Bar Nuclear Plant Unit 2 History 

Watts Bar Nuclear Plant (WBN) Units 1 and 2 have a unique licensing history and regulatory 

framework. The Tennessee Valley Authority (TVA) received a construction permit (CP) for each 

unit in 1973 under Part 50, “Domestic Licensing of Production and Utilization Facilities,” of 

Title 10, “Energy,” of the Code of Federal Regulations (10 CFR). Construction proceeded 

until 1985, when WBN Unit 1 was thought to be essentially complete and nearly ready to 

receive an operating license (OL), as documented in the initial revision of NUREG-0847, “Safety 

Evaluation Report Related to the Operation of WBN, Units 1 and 2,” and in its Supplements 1 

through 4. As a consequence of the identification of a large number of deficiencies shortly 

before the WBN Unit 1 license was expected to be issued, the U.S. Nuclear Regulatory 

Commission (NRC) sent a letter to TVA on September 17, 1985, requesting information under 

10 CFR 50.54(f) on TVA’s plans to address the deficiencies for its operating and construction 

activities at WBN and at TVA’s other nuclear facilities. In response to this letter, TVA developed 

a Nuclear Performance Plan (NPP) to address corporate and site-specific issues, establishing 

programs to address a wide variety of material, design, and programmatic deficiencies. 

TVA suspended construction of all nuclear facilities under construction in 1985 with major 

structures at WBN in place and with equipment such as reactor coolant system piping installed. 

The NRC staff reviewed components of the NPP for WBN Unit 1 and, as documented in 

NUREG-1232, Volume 4, “Safety Evaluation Report on Tennessee Valley Authority: Watts Bar 

Nuclear Performance Plan, Watts Bar Unit 1,” the NRC staff endorsed the general approaches 

of various corrective actions. The NRC staff determined that when implemented thoroughly, the 

proposed corrective actions should address the identified deficiencies for Unit 1; however, no 

conclusions were stated for WBN Unit 2. Satisfactory resolution of NPP topics for WBN Unit 1 

were documented in the later supplements to NUREG-0847, with Supplement 19 supporting 

issuance of the low-power license for WBN Unit 1 in November 1995 and Supplement 20 

supporting issuance of the full-power license for WBN Unit 1 in February 1996. 

On October 13, 1999, TVA filed a request for extension of the completion date for WBN Unit 2. 

Subsequently, by letter dated July 14, 2000, TVA informed the NRC that WBN Unit 2 meets the 

NRC’s definition for deferred nuclear plant units as described in the Commission’s Policy 

Statement on Deferred Plants, as published in the Federal Register at 52 FR 38077 (dated 

October 14, 1987). On October 24, 2000, the NRC issued an order extending the Unit 2 

construction permit (CP) to December 31, 2010, as published in the Federal Register at 

65 FR 60225. On March 6, 2008, as supplemented May 8, 2008, TVA requested an extension 

to the WBN Unit 2 CP. On July 7, 2008, the NRC issued an order extending the Unit 2 CP to 

March 31, 2013 (at 73 FR 39995, dated July 11, 2008). On May 17, 2012, TVA requested that 

the NRC extend the CP to September 30, 2016. The NRC staff reviewed the submittal and 

performed an environmental assessment, which was issued in October 2013. In 

November 2013, the NRC staff issued an order to extend the CP to 2016. 

The NRC used Inspection Manual Chapter (IMC) 2512, “Light Water Reactor Inspection 

Program - Construction Phase,” to ensure that WBN Unit 1 was constructed in accordance with 

NRC-approved design and construction standards. In 1985, the NRC had completed its initial 

IMC 2512 inspection program for the construction of WBN Unit 1. However, the initial WBN 

inspection program was found to have some weaknesses, which were identified and corrected 

after the construction inspection program was completed for Unit 1 but before the facility was 
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licensed. Because of the complexity of the rework activities under the NPP, the NRC 

implemented a “reconstitution” of the construction inspection program to verify that 

construction-related inspections conducted after 1985 met the requirements of the IMC 2512 

program. The results of this program were published in NUREG-1528, “Reconstitution of the 

Manual Chapter 2512 Construction Inspection Program for Watts Bar Unit 1” (Agencywide 

Documents Access and Management System (ADAMS) Accession No. ML073450842). The 

NRC staff had completed a substantial number of IMC 2512 inspections for WBN Unit 2 at the 

same time; however, TVA suspended WBN Unit 2 construction before the inspection program 

was completed, and the NRC staff then suspended its licensing and inspection activities. 

TVA informed the NRC in a November 14, 2006, letter of its intent to perform a study of the 

feasibility of completing WBN Unit 2, with the goal of producing power from the reactor in 2013. 

Based on the results of this study, on August 3, 2007, TVA notified the Director of the Office of 

Nuclear Reactor Regulation (NRR) of its intention to complete construction activities at WBN 

Unit 2. TVA indicated that it planned to resume unrestricted construction activities under the 

existing CP. TVA also indicated that it would align the licensing and design bases of both units 

to the fullest extent practicable and that it would complete WBN Unit 2 in compliance with 

applicable regulations promulgated before and after the issuance of the Unit 1 OL. 

In addition, the WBN Unit 2 licensing and design bases incorporated modifications made to 

WBN Unit 1, as well as those modifications captured in the WBN Unit 1 five-year plan. TVA 

believed that this alignment of the licensing and design bases for WBN Units 1 and 2 ensured 

operational fidelity between the units and demonstrated that WBN Unit 2 complied with 

applicable NRC regulatory requirements. 

TVA submitted Site Security Plan changes which have been reviewed and accepted by the 

NRC staff. In accordance with a Memorandum of Understanding (MOU) between the NRC and 

Department of Homeland Security (DHS) which establishes a process to implement the 

provisions of Section 657 of the Energy Policy Act of 2005, the NRC staff consulted with DHS 

during August 2008 concerning the potential vulnerabilities of the location of the proposed 

facility to terrorist attack. The NRC staff reviewed of the DHS Consultation Report and 

determined that there were no issues of concern. 

In accordance with an MOU between the Federal Emergency Management Agency (FEMA) and 

the NRC (Appendix A, “Memorandum of Understanding Between Federal Emergency 

Management Agency and Nuclear Regulatory Commission,” to 44 CFR Part 353, “Fee for 

Services in Support, Review, and Approval of State and Local Government or Licensee 

Radiological Emergency Plans and Preparedness”), the NRC staff also followed up with the 

FEMA to confirm that their findings and determinations regarding offsite preparedness 

documented in SSER 22 remained valid. FEMA responded by letter on August 28, 2014, 

stating their continued finding of reasonable assurance that appropriate measures can and will 

be taken to protect the health and safety of the general public in the event of a radiological 

event. FEMA identified the successful WBN Unit 1 full-participation biennial exercises 

conducted in October 2011 and October 2013 as a basis, in part, for its continued finding of 

reasonable assurance. As such, the exercise requirement for the WBN site in Appendix E, 

“Emergency Planning and Preparedness for Production and Utilization Facilities,” to 10 CFR 

Part 50 was met with the issuance of the operating license for WBN Unit 1. As such, another 
- 3 -

exercise will not be needed before WBN Unit 2 licensing and TVA will proceed with the normal 

biennial exercise schedule. 

On January 29, 2008, with the latest update being January 30, 2014, TVA submitted a 

regulatory framework document to cite key correspondence and describe open issues or 

commitments that need to be resolved to obtain an OL for WBN Unit 2. 

To be consistent with Commission direction in a Staff Requirements Memorandum dated 

July 25, 2007 (ADAMS Accession No. ML072060688), the NRC staff used the current licensing 

basis for Unit 1 as the reference basis for the review and licensing of Unit 2. Significant 

changes to this licensing approach were allowed where the existing backfit rule would be met 

or, as necessary, to support dual-unit operation. In accordance with the Commission’s 

direction, the NRC expected TVA to review any exemptions, reliefs, and other actions that were 

specifically granted for Unit 1 to determine whether the same allowances were appropriate for 

Unit 2 and to submit such requests to the NRC for review and approval as necessary. The NRC 

staff encouraged TVA to adopt updated standards for Unit 2 where doing so would not 

significantly detract from design and operational consistency between Units 1 and 2. The NRC 

also expected TVA to look for opportunities to resolve issues such as generic safety issues 

which the unirradiated state of Unit 2 makes easier to resolve before plant operation. The 

Commission also directed the NRC staff to reissue a notice about the opportunity for a hearing 

on WBN Unit 2. 

TVA submitted a Final Supplemental Environmental Impact statement supporting completion of 

WBN Unit 2 on February 15, 2008. On January 27, 2009, in response to NRC’s request for 

additional information, TVA provided the Severe Accident Management Alternatives (SAMA) 

analysis report for WBN Unit 2. On October 14, 2010, TVA submitted a new SAMA analysis 

that supersedes the previous submittals. The NRC prepared a Supplement Final Environmental 

Statement based on this submittal and other information following the process outlined in 

LIC-203, “Procedural Guidance for Preparing Environmental Assessments and Considering 

Environmental Issues.” This supplement was published as a draft for comment and announced 

with a notice in the Federal Register (at 76 FR 70169) on November 10, 2011. The NRC staff 

held a public meeting on December 8, 2011, to provide the local public the opportunity to 

provide comments. During this meeting several members of the public requested an extension 

of the period to submit written comments. The NRC staff granted an extension and moved the 

closure of the comment period from December 27, 2011, to January 24, 2012. The NRC staff 

evaluated and developed responses to the written and verbal comments received. The final 

version of Supplement 2 to NUREG-0498 (ADAMS Accession Nos. ML13144A092 

and ML13144A093) was published in May 2013. 

Early in the process, the NRC staff conducted public outreach meetings in the vicinity of the site 

on December 4, 2007, and December 11, 2008, to inform the public about NRC’s licensing and 

inspection activities, including how they can monitor and participate in the licensing process. As 

part of the assessment process, public meetings are held on an annual basis to inform the 

public of the NRC’s assessment results of TVA’s performance in completing the construction of 

WBN Unit 2. The first meeting was held April 14, 2009, with subsequent meetings held on 

April 20, 2010; April 28, 2011; April 12, 2012; April 16, 2013; and April 9, 2014. 
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TVA originally expected to complete Unit 2 by April 2012 based on its initial detailed scoping, 

estimating, and planning study completed and approved by the TVA Board of Directors in 2007. 

However, in a press release dated April 5, 2012, TVA announced the findings of a 7-month 

construction review at WBN Unit 2, detailing cost and time estimates to complete the facility. In 

this announcement, TVA stated that the emerging estimate to complete Unit 2 would require 

additional funding of $1.5 billion to $2 billion and estimated completion between September and 

December of 2015. As part of its rationale for the cost and delay, TVA management stated that 

“walk downs to support the initial estimate were not completed. Management was misaligned, 

and planning was poor.” In its revised time and cost estimates, TVA stated that it has “added 

contingency and an allowance for addressing Fukushima impacts.” As a result of the delay in 

the project schedule, on May 17, 2012, TVA submitted a request to extend the expiration date of 

the construction permit from March 31, 2012, to September 30, 2016. On August 23, 2012, 

TVA submitted their request to renew the special nuclear material license (under 10 CFR 

Part 70, “Domestic Licensing of Special Nuclear Material,” and 10 CFR 2.109, “Effect of Timely 

Renewal Application”) for 3 more years, which would allow TVA to continue storing the fresh 

fuel assemblies during the construction of (and OL application process for) WBN Unit 2. The 

NRC completed its review of this information and granted TVA’s request for both an extension 

on the expiration of the CP and a renewal of TVA’s special nuclear material license. The CP 

was extended on November 21, 2013, while the renewed special nuclear material license was 

issued on July 24, 2014.