Safety Evaluation Report

Related to the Operation of 

Watts Bar Nuclear Plant, Unit 2

Docket Number 50-391

Tennessee Valley Authority

Office of Nuclear Reactor Regulation

NUREG-0847

Supplement 28
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Commission.
Safety Evaluation Report

Related to the Operation of 

Watts Bar Nuclear Plant, Unit 2

Docket Number 50-391

Tennessee Valley Authority

Manuscript Completed: August 2015

Date Published: August 2015

Office of Nuclear Reactor Regulation

NUREG-0847

Supplement 28

ABSTRACT

This report supplements the safety evaluation report (SER), NUREG-0847 (June 1982), with 

respect to the application filed by the Tennessee Valley Authority (TVA), as applicant and 

owner, for a license to operate Watts Bar Nuclear Plant (WBN), Unit 2 (Docket No. 50-391). 

In its SER and Supplemental SERs (SSERs) 1 through 20, issued by the Office of Nuclear 

Reactor Regulation (NRR) of the U.S. Nuclear Regulatory Commission (NRC), the NRC staff

documented its safety evaluation (SE) and determination that WBN, Unit 1, met all applicable 

regulations and regulatory guidance. Based on satisfactory findings from all applicable 

inspections, on February 7, 1996, the NRC issued a full-power operating license (OL) to WBN,

Unit 1, authorizing operation up to 100-percent power.

In SSER 21, the NRC staff addressed TVA’s application for a license to operate WBN, Unit 2,

and gave information on the status of the items remaining to be resolved that were outstanding 

at the time that TVA deferred construction of WBN, Unit 2, and were not evaluated and resolved 

as part of the licensing of WBN, Unit 1. SSERs 22 to 27 documented the NRC staff’s ongoing 

evaluation and closure of open items in support of TVA’s application for a license to operate 

WBN, Unit 2. 

In this and future SSERs, the NRC staff continues its documentation of its review of open items 

in support of TVA’s application for an OL for WBN, Unit 2. 

iii

TABLE OF CONTENTS

Page

ABSTRACT iii

TABLE OF CONTENTS v

ABBREVIATIONS vii

1 INTRODUCTION AND DISCUSSION 1-1

1.1 Introduction 1-1

1.7 Summary of Outstanding Issues 1-2

1.8 Confirmatory Issues 1-26

1.9 License Conditions 1-26

1.9.1 Flooding License Condition 1-26

1.9.2 Cyber security License Condition 1-26

1.9.3 Core Operating Limits License Condition 1-27

1.9.4 Electrical Design License Condition 1-27

1.13 Implementation of Corrective Action Programs and Special Programs 1-27

1.13.1 Corrective Action Programs 1-27

1.13.2 Special Programs 1-29

1.14 Implementation of Applicable Bulletin and Generic Letter Requirements 1-29

2 SITE CHARACTERISTICS 2-1

2.4 Hydrologic Engineering 2-1

2.4.10 Flooding Protection Requirements 2-1

8 ELECTRICAL POWER SYSTEM 8-1

8.3 Onsite (Standby) Power System 8-1

8.3.1 Alternating Current Power System 8-1

13 CONDUCT OF OPERATIONS 13-1

13.3 Emergency Preparedness 13-1

13.3.1 Introduction 13-1

13.3.2 Evaluation of the Emergency Plan 13-4

13.3.3 Conclusion 13-15

13.6 Physical Security 13-16

13.6.6 Cyber security Plan 13-16

19 REPORT OF THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 19-1

APPENDIX A CHRONOLOGY OF RADIOLOGICAL REVIEW OF WATTS BAR 

NUCLEAR PLANT, UNIT 2, OPERATING LICENSE REVIEW A-1

APPENDIX E PRINCIPAL CONTRIBUTORS TO SSER 28 E-1

APPENDIX F REPORT OF THE ADVISORY COMMITTEE ON REACTOR 

SAFEGUARDS F-1

APPENDIX HH WATTS BAR, UNIT 2, ACTION ITEMS TABLE HH-1

APPENDIX II COMPLIANCE WITH 10 CFR (hh)(2) II-1

APPENDIX JJ FUKUSHIMA ACTIVITIES JJ-1

v

ABBREVIATIONS

AC alternating current

ACR auxiliary control room

ACRS Advisory Committee for Reactor Safeguards

ADAMS Agencywide Documents Access and Management System

ALARA as low as is reasonably achievable

ANSI American National Standards Institute

ANS American Nuclear Society

ASME American Society of Mechanical Engineers

BEACON Westinghouse Best Estimate Analyzer for Core Operations—Nuclear

BL bulletin

BOP balance of plant

BTP Branch Technical Position

CAP corrective action program

CCS component cooling system

CECC Central Emergency Control Center

CFR Code of Federal Regulations

CI confirmatory issue

CRDR control room design review

CSST common station service transformer

CP construction permit

CSP cyber security plan

DBA design-basis accident

DCN design change notice

DVR degraded voltage relay

EA Environmental Assessment

EAL emergency action level

ECCS emergency core cooling system

EDG emergency diesel generator

EMC electromagnetic compatibility

EOF emergency operations facility

EOP emergency operating procedure

EP emergency preparedness

EPA electrical penetration assemblies

EPIP emergency preparedness implementation procedure

EPZ emergency planning zone

EQ environmental qualification

ERCW essential raw cooling water

ERDS emergency response data system

ERO Emergency Response Organization

ESF engineered safety feature

ETE evacuation time estimate

FEMA Federal Emergency Management Agency

FSAR final safety analysis report

GDC general design criterion/criteria

GL generic letter

HAB hostile action based

HRCAR high range containment air radiation

vii
ICM interim compensatory measures

IE Office of Inspection and Enforcement

IEB Office of Inspection and Enforcement Bulletin

IEEE Institute of Electrical and Electronics Engineers

IFR Interim Finding Report

IITA in-core instrumentation thimble assembly

IPEEE individual plant examination of external events

ISG interim staff guidance

JLD Japan Lessons-learned Directorate

kV kilovolt

kVA kilovolt ampere

LAR license amendment request

LOCA loss-of-coolant accident

LOOP loss-of-offsite power

LTOP low-temperature overpressure protection

LVR low voltage relay

MOV motor-operated valve

MSIV main steam isolation valve

NEI Nuclear Energy Institute

NPG Nuclear Power Group

NPP nuclear performance plan

NRC U.S. Nuclear Regulatory Commission

NRR Office of Nuclear Reactor Regulation

NTTF Near-Term Task Force

NUREG report prepared by NRC staff

OBE operating-basis earthquake

ODCM Offsite Dose Calculation Manual

ODS Operations Duty Specialist

OL operating license

OSA on-shift staffing analysis

PAD performance analysis and design

PAMS post-accident monitoring system

PARS publicly available records system

PDR public document room

PORV power-operated relief valve

PTLR Pressure and Temperature Limits Report

PWR pressurized-water reactor

RAI request for additional information

RCS reactor coolant system

REP Radiological Emergency Plan

RES Office of Nuclear Regulatory Research 

RG Regulatory Guide

RPV reactor pressure vessel

SE safety evaluation

SER safety evaluation report, NUREG-0847, dated June 1982

SFP spent fuel pool

SG steam generator

SIAS Safety Injection Actuation Signal

SP special program

SPND self-powered neutron detector

viii
SRM Staff Requirements Memorandum

SRS software requirements specification

SPS signal processing system

SRP Standard Review Plan, NUREG-0800

SSC structure, system, and component

SSE safe shutdown earthquake

SSEP safety, security, and emergency preparedness

SSER Supplemental SER

Std. Standard

TCD thermal conductivity degradation

TI Technical Instruction

TMI Three Mile Island

TPS Transmission and Power Supply

TS technical specification

TSO transmission system operator

TSTF Technical Specification Task Force

TVA Tennessee Valley Authority

UFSAR Updated Final Safety Analysis Report

V volt

VAC volt alternating current

VDC volt direct current

V&V verification and validation

WBA Web-based ADAMS

WBN Watts Bar Nuclear Plant

χ/Q atmospheric dispersion estimate

ix

1 INTRODUCTION AND DISCUSSION

1.1 Introduction

The Watts Bar Nuclear Plant (WBN or Watts Bar) is owned by the Tennessee Valley Authority 

(TVA) and is located in southeastern Tennessee, approximately 50 miles (80 kilometers) 

northeast of Chattanooga. The facility consists of two Westinghouse-designed four-loop 

pressurized-water reactors (PWRs) within ice condenser containments.

In June 1982, the U.S. Nuclear Regulatory Commission (NRC) staff issued safety evaluation 

report (SER), NUREG-0847, “Safety Evaluation Report Related to the Operation of Watts Bar 

Nuclear Plant Units 1 and 2,” on TVA’s application for licenses to operate WBN, Units 1 and 2. 

In SER Supplements (SSERs) 1 through 20, the NRC staff concluded that WBN, Unit 1, met all 

applicable regulations and regulatory guidance, and on February 7, 1996, the NRC issued an 

operating license (OL) to Unit 1. TVA did not complete WBN, Unit 2, and the NRC did not make 

conclusions about it. 

On March 4, 2009, TVA submitted an updated application in support of its request for an OL for 

WBN, Unit 2, pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, 

“Domestic Licensing of Production and Utilization Facilities.”

In SSER 21, the NRC staff reported on the WBN, Unit 2, items remaining to be resolved, which 

were outstanding at the time that TVA deferred construction of Unit 2, and which were not 

evaluated and resolved as part of the licensing of WBN, Unit 1. In SSERs 22, 23, 24, 25, 26, 

and 27, the NRC staff documented its evaluation and closure of open items in support of TVA’s 

application for a license to operate WBN, Unit 2.

In this and future SSERs, the NRC staff will continue the documentation of its evaluation and 

closure of open items in support of TVA’s application.

The format of this document is consistent with the format and scope outlined in the “Standard 

Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR 

[Light-Water Reactor] Edition (NUREG-0800),” dated July 1981 (SRP, NUREG-0800). The 

NRC staff added additional chapters to address the overall assessment of the facility, nuclear 

performance plan (NPP) issues, and other generic regulatory topics.

Each of the sections and appendices of this supplement is numbered the same as the SER 

section that is being updated, and the discussions are supplementary to, and not in lieu of, the 

discussion in the SER, unless otherwise noted. For example, Appendix E continues to list the 

principal contributors to the SSER. However, the chronology of the safety review 

correspondence previously given in Appendix A has been discontinued, and a reference is 

supplied instead to the NRC’s Agencywide Documents Access and Management System 

(ADAMS) or the Public Document Room (PDR). Public correspondence exchanged between 

the NRC and TVA is available through ADAMS or the PDR. References listed as “not publicly 

available” in the SSER contain proprietary information and have been withheld from public 

disclosure in accordance with 10 CFR 2.390, “Public inspections, exemptions, requests for 

withholding.”

Appendix HH includes an action items table. This table gives the status of all the open items, 

confirmatory issues, and proposed license conditions that must be resolved before completion 

1-1
of an NRC finding of reasonable assurance on the OL application for WBN, Unit 2. The NRC 

staff will maintain the action items table and revise Appendix HH in future SSERs, and add new 

appendices, as necessary. 

The NRC’s ADAMS is the agency’s official recordkeeping system. ADAMS has the full text of 

regulatory and technical documents and reports written by the NRC, NRC contractors, or NRC 

licensees. Documents include NRC regulatory guides, NUREG-series reports, correspondence, 

inspection reports, and other materials. These documents are assigned accession numbers

and are searchable and accessible in ADAMS. Documents are released periodically during the 

day in the ADAMS PUBLIC/Legacy Interface Combined (ADAMS PUBLIC) and Web-based 

ADAMS (WBA) interfaces; they are released once a day in Web-based Publicly Available 

Records System (PARS). These documents in full text can be searched using ADAMS 

accession numbers or specific fields and parameters such as docket number and document 

dates. 

More information on ADAMS and help for accessing documents may be obtained on the NRC 

Public Website at http://www.nrc.gov/reading-rm/adams/faq.html#1.

All WBN documents may be accessed using WBN Docket Nos. 05000390 and 05000391 for 

Units 1 and 2, respectively.

The WBN, Unit 2, Project Manager is Justin C. Poole, who may be contacted by calling 

(301) 415-2048, by email to Justin.Poole@nrc.gov, or by writing to the following address:

Mr. Justin Poole

Mail Stop O-8G9A

U.S. Nuclear Regulatory Commission

Washington, DC 20555-0001

1.7 Summary of Outstanding Issues

The NRC staff documented its previous review and conclusions on the OL application for WBN, 

Unit 1, in the SER (NUREG-0847, dated June 1982) and its Supplements 1 through 20. Based 

on these reviews, the NRC staff issued an OL for WBN, Unit 1, in 1996. In the SER and SSERs 

1 through 20, the NRC staff also reviewed and approved certain topics for WBN, Unit 2, though 

no final conclusions were made about an OL for WBN, Unit 2. To establish the remaining scope 

and the regulatory framework for the NRC staff’s review of an OL for WBN, Unit 2, the NRC staff 

reviewed the SER and SSERs 1 through 20. Based on this review, the NRC staff identified 

“resolved” topics (i.e., out of scope for review) and “open” topics (i.e., in scope for NRC staff 

review) for WBN, Unit 2. Where it was not clear whether the SER topic applied to Unit 2, or not, 

the NRC staff conservatively identified it as “open” pending further evaluation. It should be 

noted that these were not technical evaluations of each topic; rather, it was a status review to 

determine whether the topic was “open” or “resolved.” The NRC staff documented this 

evaluation in SSER 21 as the baseline for resumption of the review of the OL application for 

Unit 2. Thus, SSER 21 reflects the status of the NRC staff’s review of WBN, Unit 2, up to 1995. 

The NRC staff notes that a subsequent, more detailed assessment may find some topics 

conservatively identified in the initial assessment as “open” should be redefined as “closed.” 

Conversely, the NRC staff notes that there may be circumstances that could result in the need 

to reopen some previously closed topic areas that may have been adequately documented and 

that are considered closed in SSER 21. Such cases will be identified by a footnote in future 

1-2
SSERs to document that previous “open” topics have been recategorized as “closed” without 

requiring further review, or vice versa. 

The SER and SSERs 1 through 20 evaluated the changes to the final safety analysis report 

(FSAR) until Amendment No. 91. FSAR Amendment No. 91 was the initial licensing basis for 

WBN, Unit 1. At this time, the FSAR was applicable to both Units 1 and 2. As part of its 

updated OL application for WBN, Unit 2, TVA split FSAR Amendment No. 91 into two separate 

FSARs for WBN, Units 1 and 2. TVA has submitted WBN, Unit 2, FSAR Amendment Nos. 92 

through 113 to address the “open” topics in support of its OL application for WBN, Unit 2. 

These FSAR amendments reflect changes that have occurred since 1995. Some changes in 

these FSAR amendments are currently under NRC staff review. Reviews of FSAR changes 

that have been completed by the NRC staff were documented in SSERs 22, 23, 24, 25, 26, and 

27.

Additional general topics (e.g., financial qualifications that were not included in SSER 21, but 

that should be resolved before issuance of an OL) are also identified in SSER 22 and 

subsequent supplements.

SSER 21 initially contained the table below documenting the status of each SER topic. The 

relevant document in which the topic was last addressed is shown in parentheses. This table 

will be maintained in this and future supplements to reflect the updated status of review for each 

topic.

ISSUE STATUS TABLE

Issue Status Section Note

(1) Site Envelope 2

(2) Geography and Demography Resolved (SSER 22) 2.1

(3) Site Location and Description Resolved (SER)

(SSER 22)

2.1.1 3

(4) Exclusion Area Authority and 

Control

Resolved (SER)

(SSER 22)

2.1.2 3

(5) Population Distribution Resolved (SER)

(SSER 22)

2.1.3

(6) Conclusions Resolved (SER)

(SSER 22)

2.1.4

(7) Nearby Industrial, Transportation, 

and Military Facilities

Resolved (SSER 22) 2.2

(8) Transportation Routes Resolved (SER)

(SSER 22)

2.2.1

(9) Nearby Facilities Resolved (SER)

(SSER 22)

2.2.2

(10) Conclusions Resolved (SER)

(SSER 22)

2.2.3

(11) Meteorology Resolved (SER)

(SSER 22)

2.3

(12) Regional Climatology Resolved (SER)

(SSER 22)

2.3.1

(13) Local Meteorology Resolved (SER)

(SSER 22)

2.3.2

1-3
Issue Status Section Note

(14) Onsite Meteorological 

Measurements Program

Resolved (SER)

(SSER 22)

(SSER 25)

2.3.3

(15) Short-Term (Accident) Atmospheric 

Diffusion Estimates

Resolved (SER)

(SSER 14)

(SSER 22)

2.3.4

(16) Long-Term (Routine) Diffusion 

Estimates

Resolved (SER)

(SSER 14)

(SSER 22)

2.3.5

(17) Hydrologic Engineering Resolved (SSER 27)

(SSER 28)

2.4

(18) Introduction Resolved (SER) 2.4.1

(19) Hydrologic Description Resolved (SER) 2.4.2

(20) Flood Potential Resolved (SER) 2.4.3

(21) Local Intense Precipitation in Plant 

Area

Resolved (SER) 2.4.4 1

(22) Roof Drainage Resolved (SER) 2.4.5 1

(23) Ultimate Heat Sink Resolved (SER) 2.4.6

(24) Groundwater Resolved (SER) 2.4.7 1

(25) Design Basis for Subsurface 

Hydrostatic Loading

Resolved (SER)

(SSER 3)

2.4.8

(26) Transport of Liquid Releases Resolved (SER)

(SSER 22)

2.4.9 2

(27) Flooding Protection Requirements Resolved (SER)

(SSER 24)

(SSER 27)

(SSER 28)

2.4.10

(28) Geological, Seismological, and 

Geotechnical Engineering

Resolved (SER)

(SSER 24)

2.5

(29) Geology Resolved (SER) 2.5.1

(30) Seismology Resolved (SER) 2.5.2

(31) Surface Faulting Resolved (SER) 2.5.3

(32) Stability of Subsurface Materials 

and Foundations

Resolved (SER)

(SSER 3)

(SSER 9)

(SSER 11)

2.5.4

(33) Stability of Slopes Resolved (SER) 2.5.5

(34) Embankments and Dams Resolved (SER)

(SSER 22)

2.5.6

(35) References (SER)

(SSER 22)

2.6

(36) Design Criteria - Structures, 

Components, Equipment, and 

Systems

3

(37) Introduction 3.1

(38) Conformance With General Design 

Criteria 

Resolved (SER) 3.1.1

1-4
Issue Status Section Note

(39) Conformance With Industry Codes 

and Standards

Resolved (SER) 3.1.2

(40) Classification of Structures, 

Systems and Components

Resolved (SSER 14)

(SSER 22)

3.2

(41) Seismic Classifications Resolved (SER)

(SSER 3)

(SSER 5)

(SSER 6)

(SSER 8)

3.2.1

(42) System Quality Group Classification Resolved (SER)

(SSER 3)

(SSER 6)

(SSER 7)

(SSER 9)

(SSER 22)

3.2.2

(43) Wind and Tornado Loadings 3.3

(44) Wind Loading Resolved (SER) 3.3.1

(45) Tornado Loading Resolved (SER) 3.3.2

(46) Flood Level (Flood) Design 3.4

(47) Flood Protection Resolved (SER) 3.4.1

(48) Missile Protection 3.5

(49) Missile Selection and Description Resolved (SER)

(SSER 9)

(SSER 14)

(SSER 22)

3.5.1

(50) Structures, Systems, and 

Components to be Protected from 

Externally Generated Missiles

Resolved (SER)

(SSER 2)

(SSER 22)

3.5.2

(51) Barrier Design Procedures Resolved (SER) 3.5.3

(52) Protection Against the Dynamic 

Effects Associated with the 

Postulated Rupture of Piping

Resolved (SER)

(SSER 6)

(SSER 11)

3.6

(53) Plant Design for Protection Against 

Postulated Piping Failures in Fluid 

System Outside Containment

Resolved (SER)

(SSER 14)

(SSER 22)

3.6.1

(54) Determination of Break Locations 

and Dynamic Effects Associated 

with the Postulated Rupture of 

Piping

Resolved (SER)

(SSER 14)

(SSER 22)

3.6.2 3

(55) Leak-Before-Break Evaluation 

Procedures

Resolved (SSER 5)

(SSER 12)

(SSER 22)

(SSER 24)

3.6.3

(56) Seismic Design Resolved (SER)

(SSER 6)

3.7 2

(57) Seismic Input Resolved (SER)

(SSER 6)

(SSER 9)

(SSER 16)

3.7.1 2

1-5
Issue Status Section Note

(58) Seismic Analysis Resolved (SER)

(SSER 6)

(SSER 8)

(SSER 11)

(SSER 16)

3.7.2 2

(59) Seismic Subsystem Analysis Resolved (SER)

(SSER 6)

(SSER 7)

(SSER 8)

(SSER 9)

(SSER 12)

(SSER 22)

3.7.3

(60) Seismic Instrumentation Resolved (SER) 3.7.4 1

(61) Design of Seismic Category I 

Structures

Resolved (SER)

(SSER 9)

3.8 2

(62) Steel Containment Resolved (SER)

(SSER 3)

3.8.1

(63) Concrete and Structural Steel 

Internal Structures

Resolved (SER)

(SSER 7)

3.8.2

(64) Other Seismic Category I Structures Open (NRR) (SER)

(SSER 14)

(SSER 16)

3.8.3

(65) Foundations Resolved (SER) 3.8.4

(66) Mechanical Systems and 

Components

Resolved (SER) 3.9

(67) Special Topics for Mechanical 

Components

Resolved (SER)

(SSER 6)

(SSER 13)

(SSER 22)

3.9.1

(68) Dynamic Testing and Analysis of 

Systems, Components, and 

Equipment

Resolved (SER)

(SSER 14)

(SSER 22)

3.9.2

(69) ASME Code Class 1, 2, and 3 

Components, Component 

Structures, and Core Support 

Structures

Resolved (SER)

(SSER 3)

(SSER 4)

(SSER 6)

(SSER 7)

(SSER 8)

(SSER 15)

(SSER 22)

3.9.3

(70) Control Rod Drive Systems Resolved (SER) 3.9.4

(71) Reactor Pressure Vessel Internals Resolved (SER)

(SSER 23)

(SSER 26)

3.9.5

1-6
Issue Status Section Note

(72) Inservice Testing of Pumps and 

Valves

Resolved (SER)

(SSER 5)

(SSER 12)

(SSER 14)

(SSER 18)

(SSER 20)

(SSER 22)

(SSER 27)

3.9.6

(73) Seismic and Dynamic Qualification 

of Seismic Category I Mechanical 

and Electrical Equipment

Resolved (SER)

(SSER 1)

(SSER 3)

(SSER 4)

(SSER 5)

(SSER 6)

(SSER 8)

(SSER 9)

(SSER 23)

3.10

(74) Environmental Qualification of 

Mechanical and Electrical 

Equipment

Resolved (SSER 15)

(SSER 22)

(SSER 27)

3.11

(75) Threaded Fasteners — ASME Code 

Class 1, 2, and 3

Resolved (SSER 22) 3.13

(76) Reactor 4

(77) Introduction (SER)

(SSER 23)

4.1

(78) Fuel System Design Resolved (SSER 23)

(SSER 27)

4.2

(79) Description Resolved (SER)

(SSER 13)

(SSER 23)

4.2.1

(80) Thermal Performance Resolved (SER)

(SSER 2)

(SSER 23)

(SSER 27)

4.2.2

(81) Mechanical Performance Resolved (SER)

(SSER 2)

(SSER 10)

(SSER 13)

(SSER 23)

4.2.3

(82) Surveillance Resolved (SER)

(SSER 2)

(SSER 23)

4.2.4

(83) Fuel Design Considerations Resolved (SER)

(SSER 23)

4.2.5

(84) Nuclear Design Resolved (SSER 23) 4.3

(85) Design Basis Resolved (SER)

(SSER 13)

(SSER 23)

4.3.1

1-7
Issue Status Section Note

(86) Design Description Resolved (SER)

(SSER 13)

(SSER 15)

(SSER 23)

4.3.2

(87) Analytical Methods Resolved (SER)

(SSER 23)

4.3.3

(88) Summary of Evaluation Findings Resolved (SER)

(SSER 23)

4.3.4

(89) Thermal-Hydraulic Design Resolved (SSER 23) 4.4

(90) Performance in Safety Criteria Resolved (SER)

(SSER 23)

4.4.1

(91) Design Bases Resolved (SER)

(SSER 12)

(SSER 23)

4.4.2

(92) Thermal-Hydraulic Design 

Methodology

Resolved (SER)

(SSER 6)

(SSER 8)

(SSER 12)

(SSER 13)

(SSER 16)

SE dated 

6/13/89

(SSER 23)

4.4.3

(93) Operating Abnormalities Resolved (SER)

(SSER 13)

(SSER 23)

4.4.4

(94) Loose Parts Monitoring System Resolved (SER)

(SSER 3)

(SSER 5)

(SSER 16)

(SSER 23)

4.4.5

(95) Thermal-Hydraulic Comparison Resolved (SER)

(SSER 23)

4.4.6

(96) N-1 Loop Operation Resolved (SER)

(SSER 23)

4.4.7

(97) Instrumentation for Inadequate Core 

Cooling Detection (Three Mile Island 

((TMI) Action Item II.F.2)

Resolved (SER)

(SSER 10)

(SSER 23)

(SSER 27)

4.4.8

(98) Summary and Conclusion Resolved (SER)

(SSER 23)

(SSER 25)

4.4.9

(99) Reactor Materials 4.5

(100) Control Rod Drive Structural 

Materials

Resolved (SER) 4.5.1 1

(101) Reactor Internals and Core Support 

Materials

Resolved (SER) 4.5.2

(102) Functional Design of Reactivity 

Control Systems

Resolved (SER)

(SSER 23)

4.6

1-8
Issue Status Section Note

(103) Reactor Coolant System and 

Connected Systems

5

(104) Summary Description Resolved (SER)

(SSER 5)

(SSER 6)

5.1 2

(105) Integrity of Reactor Coolant 

Pressure Boundary

5.2

(106) Compliance with Codes and Code 

Cases

Resolved (SER)

(SSER 22)

5.2.1

(107) Overpressurization Protection Resolved (SER)

(SSER 2)

(SSER 15)

(SSER 24)

5.2.2

(108) Reactor Coolant Pressure Boundary 

Materials

Resolved (SER)

(SSER 22)

5.2.3

(109) Reactor Coolant System Pressure 

Boundary Inservice Inspection and 

Testing

Resolved (SER)

(SSER 10)

(SSER 12)

(SSER 15)

(SSER 16)

(SSER 23)

5.2.4

(110) Reactor Coolant Pressure Boundary 

Leakage Detection

Resolved (SER)

(SSER 9)

(SSER 11)

(SSER 12)

(SSER 22)

5.2.5

(111) Reactor Vessel 5.3

(112) Reactor Vessel Materials Resolved (SER)

(SSER 11)

(SSER 14)

(SSER 22)

(SSER 25)

5.3.1

(113) Pressure-Temperature Limits Resolved (SER)

(SSER 16)

(SSER 22)

(SSER 25)

5.3.2

(114) Reactor Vessel Integrity Resolved (SER)

(SSER 22)

5.3.3

(115) Component and Subsystem Design 5.4

(116) Reactor Coolant Pumps Resolved (SER)

(SSER 22)

5.4.1 2

(117) Steam Generators Resolved (SER)

(SSER 1)

(SSER 4)

(SSER 22)

5.4.2

1-9
Issue Status Section Note

(118) Residual Heat Removal System Resolved (SER)

(SSER 2)

(SSER 5)

(SSER 10)

(SSER 11)

(SSER 23)

5.4.3

(119) Pressurizer Relief Tank Resolved (SER)

(SSER 22)

5.4.4

(120) Reactor Coolant System Vents 

(TMI Action Item II.B.1)

Resolved (SER)

(SSER 2)

(SSER 5)

(SSER 12)

(SSER 23)

5.4.5

(121) Engineered Safety Features 6

(122) Engineered Safety Feature 

Materials

6.1

(123) Metallic Materials Resolved (SER)

(SSER 23)

(SSER 27)

6.1.1

(124) Organic Materials Resolved (SER)

(SSER 22)

6.1.2

(125) Postaccident Emergency Cooling 

Water Chemistry

Resolved (SER)

(SSER 22)

6.1.3

(126) Containment Systems 6.2

(127) Containment Functional Design Resolved (SER)

(SSER 3)

(SSER 5)

(SSER 7)

(SSER 12)

(SSER 14)

(SSER 15)

(SSER 22)

6.2.1

(128) Containment Heat Removal 

Systems

Resolved (SER)

(SSER 7)

(SSER 22)

6.2.2

(129) Secondary Containment Functional 

Design

Resolved (SER)

(SSER 18)

(SSER 22)

6.2.3

(130) Containment Isolation Systems Resolved (SER)

(SSER 3)

(SSER 5)

(SSER 7)

(SSER 12)

(SSER 22)

6.2.4

(131) Combustible Gas Control Systems Resolved (SER)

(SSER 4)

(SSER 5)

(SSER 8)

(SSER 22)

6.2.5

1-10
Issue Status Section Note

(132) Containment Leakage Testing Resolved (SER)

(SSER 4)

(SSER 5)

(SSER 19)

(SSER 22)

(SSER 26)

6.2.6

(133) Fracture Prevention of Containment 

Pressure Boundary

Resolved (SER)

(SSER 4)

(SSER 23)

6.2.7 1

(134) Emergency Core Cooling System Resolved (SER) 6.3 1

(135) System Design Open (NRR) (SER)

(SSER 6)

(SSER 7)

(SSER 11)

6.3.1

(136) Evaluation Resolved (SER)

(SSER 5)

6.3.2 1

(137) Testing Open (NRR) (SER)

(SSER 2)

(SSER 9)

6.3.3

(138) Performance Evaluation Resolved (SER) 6.3.4

(139) Conclusions Open (NRR) (SER) 6.3.5

(140) Control Room Habitability Resolved (SER)

(SSER 5)

(SSER 11)

(SSER 16)

(SSER 18

(SSER 22)

6.4

(141) Engineered Safety Feature (ESF) 

Filter Systems

6.5

(142) ESF Atmosphere Cleanup System Resolved (SER)

(SSER 5)

(SSER 22)

6.5.1

(143) Fission Product Cleanup System Resolved (SER) 6.5.2 1

(144) Fission Product Control System Resolved (SER)

(SSER 22)

(SSER 26)

6.5.3

(145) Ice Condenser as a Fission Product 

Cleanup System

Resolved (SER) 6.5.4 1

(146) Inservice Inspection of Class 2 and 

3 Components

Resolved (SER)

(SSER 10)

(SSER 12)

(SSER 15)

(SSER 23)

6.6

(147) Instrumentation and Controls 7

(148) Introduction 7.1

(149) General Resolved (SER)

(SSER 13)

(SSER 16)

(SSER 23)

7.1.1

1-11
Issue Status Section Note

(150) Comparison with Other Plants Resolved (SER)

(SSER 23)

7.1.2 1

(151) Design Criteria Resolved (SER)

(SSER 4)

(SSER 15)

(SSER 23)

7.1.3

(152) Reactor Trip System Resolved (SER) 7.2

(153) System Description Resolved (SER)

(SSER 13)

(SSER 15)

(SSER 23)

(SSER 27)

7.2.1

(154) Manual Trip Switches Resolved (SER)

(SSER 23)

7.2.2 1

(155) Testing of Reactor Trip Breaker 

Shunt Coils

Resolved (SER)

(SSER 23)

7.2.3 1

(156) Anticipatory Trips Resolved (SER)

(SSER 23)

7.2.4

(157) Steam Generator Water Level Trip Resolved (SER)

(SSER 2)

(SSER 14)

(SSER 23)

7.2.5

(158) Conclusions Resolved (SER)

(SSER 13)

(SSER 23)

7.2.6

(159) Engineered Safety Features System Resolved (SER)

(SSER 13)

7.3

(160) System Description Resolved (SER)

(SSER 13)

(SSER 14)

(SSER 23)

7.3.1

(161) Containment Sump Level 

Measurement

Resolved (SER)

(SSER 2)

(SSER 23)

7.3.2

(162) Auxiliary Feedwater Initiation and 

Control

Resolved (SER)

(SSER 23)

7.3.3 1

(163) Failure Modes and Effects Analysis Resolved (SER)

(SSER 23)

7.3.4

(164) Office of Inspection and 

Enforcement (IE) Bulletin 80-06

Resolved (SER)

(SSER 3)

(SSER 23)

7.3.5

(165) Conclusions Resolved (SER)

(SSER 13)

(SSER 23)

7.3.6

(166) Systems Required for Safe 

Shutdown

7.4

(167) System Description Resolved (SER)

(SSER 23)

7.4.1

1-12
Issue Status Section Note

(168) Safe Shutdown from Auxiliary 

Control Room

Resolved (SER)

(SSER 7)

(SSER 23)

7.4.2

(169) Conclusions Resolved (SER)

(SSER 23)

7.4.3

(170) Safety-Related Display 

Instrumentation

7.5

(171) Display Systems Resolved (SER)

(SSER 23)

7.5.1

(172) Postaccident Monitoring System Open 

(Inspection)

(SER)

(SSER 7)

(SSER 9)

(SSER 14)

(SSER 15)

(SSER 23)

(SSER 25)

(SSER 27)

7.5.2

(173) IE Bulletin 79-27 Resolved (SER)

(SSER 23)

(SSER 27)

7.5.3

(174) Conclusions Open 

(Inspection)

(SER) 7.5.4

(175) All Other Systems Required for 

Safety

7.6

(176) Loose Part Monitoring System Resolved (SER)

(SSER 23)

(SSER 24)

7.6.1

(177) Residual Heat Removal System 

Bypass Valves

Resolved (SER)

(SSER 23)

7.6.2

(178) Upper Head Injection Manual 

Control

Resolved (SER)

(SSER 23)

7.6.3

(179) Protection Against Spurious 

Actuation of Motor-Operated Valves

Resolved (SER)

(SSER 23)

7.6.4

(180) Overpressure Protection during Low 

Temperature Operation

Resolved (SER)

(SSER 4)

(SSER 23)

7.6.5

(181) Valve Power Lockout Resolved (SER)

(SSER 23)

7.6.6

(182) Cold Leg Accumulator Valve 

Interlocks and Position Indication

Resolved (SER)

(SSER 23)

7.6.7

(183) Automatic Switchover From 

Injection to Recirculation Mode

Resolved (SER)

(SSER 23)

7.6.8

(184) Conclusions Resolved (SER)

(SSER 4)

7.6.9

(185) Control Systems Not Required for 

Safety

7.7

1-13
Issue Status Section Note

(186) System Description Open (NRR) (SER)

(SSER 23)

(SSER 24)

(SSER 25)

(SSER 27)

7.7.1

(187) Safety System Status Monitoring 

System

Resolved (SER)

(SSER 7)

(SSER 13)

(SSER 23)

7.7.2

(188) Volume Control Tank Level Control 

System

Resolved (SER)

(SSER 23)

7.7.3

(189) Pressurizer and Steam Generator 

Overfill

Resolved (SER)

(SSER 23)

7.7.4

(190) IE Information Notice 79-22 Resolved (SER)

(SSER 23)

7.7.5

(191) Multiple Control System Failures Resolved (SER)

(SSER 23)

7.7.6

(192) Conclusions Resolved (SER) 7.7.7

(193) Anticipated Transient Without 

Scram Mitigation System Actuation 

Circuitry (AMSAC)

Resolved (SSER 9)

(SSER 14)

(SSER 23)

7.7.8

(194) NUREG-0737 Items Resolved (SER)

(SSER 23)

7.8

(195) Relief and Safety Valve Position 

Indication (TMI Action Item II.D.3)

Resolved (SER)

(SSER 5)

(SSER 14)

(SSER 23)

7.8.1

(196) Auxiliary Feedwater System 

Initiation and Flow Indication (TMI 

Action Item II.E.1.2)

Open 

(Inspection)

(SER)

(SSER 23)

7.8.2

(197) Proportional Integral Derivative 

Control Modification (TMI Action 

Item II.K.3.9)

Resolved (SER)

(SSER 23)

7.8.3

(198) Proposed Anticipatory Trip 

Modification (TMI Action Item 

II.K.3.10)

Resolved (SER)

(SSER 4)

(SSER 23)

7.8.4

(199) Confirm Existence of Anticipatory 

Reactor Trip Upon Turbine Trip (TMI 

Action Item II.K.3.12)

Resolved (SER)

(SSER 23)

7.8.5

(200) Data Communication Systems (SSER 23) 7.9

(201) Electric Power Systems 8

(202) General Resolved (SER)

(SSER 22)

(SSER 24)

(SSER 27)

8.1

(203) Offsite Power System Resolved (SER)

(SSER 22)

8.2

1-14
Issue Status Section Note

(204) Compliance with GDC 5 Resolved (SER)

(SSER 13)

(SSER 22)

8.2.1

(205) Compliance with GDC 17 Resolved (SER)

(SSER 2)

(SSER 3)

(SSER 13)

(SSER 14)

(SSER 15

(SSER 22)

(SSER 27)

8.2.2

(206) Compliance with GDC 18 Resolved (SER)

(SSER 22)

8.2.3

(207) Evaluation Findings Resolved (SER)

(SSER 22)

8.2.4

(208) Onsite Power Systems Resolved (SER)

(SSER 10)

(SSER 19)

(SSER 22)

8.3

(209) Onsite AC Power System 

Compliance with GDC 17

Resolved (SER)

(SSER 2)

(SSER 7)

(SSER 9)

(SSER 10)

(SSER 13)

(SSER 14)

(SSER 18)

(SSER 20)

(SSER 22)

(SSER 27)

(SSER 28)

8.3.1

(210) Onsite Direct Current System 

Compliance with GDC 17

Resolved (SER)

(SSER 2)

(SSER 3)

(SSER 13)

(SSER 14)

(SSER 22)

8.3.2

(211) Common Electrical Features and 

Requirements

Resolved (SER)

(SSER 2)

(SSER 3)

(SSER 7)

(SSER 13)

(SSER 14)

(SSER 15)

(SSER 16)

(SSER 22)

8.3.3

1-15
Issue Status Section Note

(212) Evaluation Findings Resolved (SER)

(SSER 2)

(SSER 3)

(SSER 7)

(SSER 13)

(SSER 14)

(SSER 15)

(SSER 16)

(SSER 22)

8.3.4

(213) Station Blackout Resolved (SSER 22) 8.4

(214) Auxiliary Systems Resolved (SER)

(SSER 10)

9

(215) Fuel Storage Facility 9.1

(216) New-Fuel Storage Resolved (SER) 9.1.1 1

(217) Spent-Fuel Storage Resolved (SER)

(SSER 5)

(SSER 15)

(SSER 16)

(SSER 22)

9.1.2

(218) Spent Fuel Pool Cooling and 

Cleanup System

Resolved (SER)

(SSER 11)

(SSER 15)

(SSER 23)

(SSER 26)

9.1.3

(219) Fuel-Handling System Resolved (SER)

(SSER 3)

(SSER 13)

(SSER 22)

(SSER 24)

9.1.4

(220) Water Systems 9.2

(221) Essential Raw Cooling Water and 

Raw Cooling Water System

Resolved (SER)

(SSER 9)

(SSER 10)

(SSER 18)

(SSER 23)

(SSER 27)

9.2.1

(222) Component Cooling System 

(Reactor Auxiliaries Cooling Water 

System)

Resolved (SER)

(SSER 5)

(SSER 23)

(SSER 27)

9.2.2

(223) Demineralized Water Makeup 

System

Resolved (SER)

(SSER 22)

9.2.3

(224) Potable and Sanitary Water 

Systems

Resolved (SER)

(SSER 9)

(SSER 22)

9.2.4

(225) Ultimate Heat Sink Resolved (SER)

(SSER 23)

(SSER 27)

9.2.5

1-16
Issue Status Section Note

(226) Condensate Storage Facilities Resolved (SER)

(SSER 12)

(SSER 22)

9.2.6

(227) Process Auxiliaries 9.3

(228) Compressed Air System Resolved (SER)

(SSER 22)

9.3.1 1

(229) Process Sampling System Resolved (SER)

(SSER 3)

(SSER 5)

(SSER 14)

(SSER 16)

(SSER 24)

9.3.2

(230) Equipment and Floor Drainage 

System

Resolved (SER)

(SSER 22)

9.3.3 3

(231) Chemical and Volume Control 

System

Resolved (SER)

(SSER 22)

9.3.4 3

(232) Heat Tracing Resolved (SSER 22) 9.3.8

(233) Heating, Ventilation, and Air 

Conditioning Systems

9.4

(234) Control Room Area Ventilation 

System

Resolved (SER)

(SSER 9)

(SSER 22)

9.4.1

(235) Fuel-Handling Area Ventilation 

System

Resolved (SER)

(SSER 22)

9.4.2

(236) Auxiliary Building and Radwaste 

Area Ventilation System

Resolved (SER)

(SSER 22)

9.4.3

(237) Turbine Building Area Ventilation 

System

Resolved (SER)

(SSER 22)

9.4.4

(238) Engineered Safety Features 

Ventilation System

Resolved (SER)

(SSER 9)

(SSER 10)

(SSER 11)

(SSER 14)

(SSER 16)

(SSER 19)

(SSER 22)

9.4.5

(239) Reactor Building Purge Ventilation 

System

Resolved (SSER 22) 9.4.6

(240) Containment Air Cooling System Resolved (SSER 22) 9.4.7

(241) Condensate Demineralizer Waste 

Evaporator Building Environmental 

Control System

Resolved (SSER 22) 9.4.8

(242) Other Auxiliary Systems 9.5

(243) Fire Protection Open (NRR) (SER)

(SSER 10)

(SSER 18)

(SSER 19)

(SSER 26)

9.5.1 3

1-17
Issue Status Section Note

(244) Communications System Resolved (SER)

(SSER 5)

9.5.2 1

(245) Lighting System Resolved (SER)

(SSER 22)

9.5.3

(246) Emergency Diesel Engine Fuel Oil 

Storage and Transfer System

Resolved (SER)

(SSER 5)

(SSER 9)

(SSER 10)

(SSER 11)

(SSER 12)

(SSER 22)

9.5.4 2

(247) Emergency Diesel Engine Cooling 

Water System

Resolved (SER)

(SSER 5)

(SSER 11)

9.5.5 1

(248) Emergency Diesel Engine Starting 

Systems

Resolved (SER)

(SSER 5)

(SSER 10)

(SSER 22)

9.5.6 2

(249) Emergency Diesel Engine 

Lubricating Oil System

Resolved (SER)

(SSER 3)

(SSER 5)

(SSER 10)

(SSER 22)

9.5.7 2

(250) Emergency Diesel Engine 

Combustion Air Intake and Exhaust 

System

Resolved (SER)

(SSER 5)

(SSER 10)

(SSER 22)

9.5.8 2

(251) Steam and Power Conversion 

System

10

(252) Summary Description Resolved (SER) 10.1

(253) Turbine Generator Resolved (SER)

(SSER 5)

10.2

(254) Turbine Generator Design Resolved (SER)

(SSER 12)

(SSER 22)

10.2.1

(255) Turbine Disc Integrity Resolved (SER)

(SSER 23)

10.2.2

(256) Main Steam Supply System Resolved (SER) 10.3

(257) Main Steam Supply System (Up to 

and Including the Main Steam 

Isolation Valves)

Resolved (SER)

(SSER 19)

(SSER 22)

10.3.1

(258) Main Steam Supply System Resolved (SER)

(SSER 22)

10.3.2 2

(259) Steam and Feedwater System 

Materials

Resolved (SER)

(SSER 22)

10.3.3

(260) Secondary Water Chemistry Resolved (SER)

(SSER 5)

(SSER 22)

10.3.4

(261) Other Features 10.4

1-18
Issue Status Section Note

(262) Main Condenser Resolved (SER)

(SSER 9)

(SSER 22)

10.4.1

(263) Main Condenser Evacuation System Resolved (SER)

(SSER 22)

10.4.2

(264) Turbine Gland Sealing System Resolved (SER)

(SSER 22)

10.4.3

(265) Turbine Bypass System Resolved (SER)

(SSER 5)

(SSER 22)

10.4.4

(266) Condenser Circulating Water 

System

Resolved (SER)

(SSER 22)

10.4.5

(267) Condensate Cleanup System Resolved (SER)

(SSER 22)

(SSER 27)

10.4.6

(268) Condensate and Feedwater 

Systems

Resolved (SER)

(SSER 14)

(SSER 22)

10.4.7

(269) Steam Generator Blowdown System Resolved (SER)

(SSER 22)

(SSER 24)

10.4.8

(270) Auxiliary Feedwater System Resolved (SER)

(SSER 14)

(SSER 23)

(SSER 24)

10.4.9

(271) Heater Drains and Vents Resolved (SSER 22) 10.4.10

(272) Steam Generator Wet Layup 

System

Resolved (SSER 22) 10.4.11

(273) Radioactive Waste Management 11

(274) Summary Description Resolved (SER)

(SSER 16)

(SSER 24)

11.1 2

(275) Liquid Waste Management Resolved (SER)

(SSER 4)

(SSER 16)

(SSER 24)

11.2

(276) Gaseous Waste Management Resolved (SER)

(SSER 8)

(SSER 16)

(SSER 24)

(SSER 25)

(SSER 27)

11.3

(277) Solid Waste Management System Resolved (SER)

(SSER 16)

(SSER 24)

11.4

(278) Process and Effluent Radiological 

Monitoring and Sampling Systems

Resolved (SER)

(SSER 16)

(SSER 20)

(SSER 24)

11.5

1-19
Issue Status Section Note

(279) Evaluation Findings Resolved (SER)

(SSER 8)

(SSER 16)

11.6

(280) NUREG-0737 Items Open (NRR) (SER) 11.7

(281) Wide-Range Noble Gas, Iodine, and 

Particulate Effluent Monitors (TMI 

Action Items II.F.1(1) and II.F.1(2))

Open 

(Inspection)

(SER)

(SSER 5)

(SSER 6)

11.7.1

(282) Primary Coolant Outside 

Containment (TMI Action item 

III.D.1.1)

Open (NRR) (SER)

(SSER 5)

(SSER 6)

(SSER 10)

(SSER 16)

11.7.2

(283) Radiation Protection 12

(284) General Resolved (SER)

(SSER 10)

(SSER 14)

(SSER 24)

12.1

(285) Ensuring that Occupational 

Radiation Doses Are As Low As 

Reasonably Achievable (ALARA)

Resolved (SER)

(SSER 14)

(SSER 24)

12.2 2

(286) Radiation Sources Resolved (SER)

(SSER 14)

(SSER 24)

12.3

(287) Radiation Protection Design 

Features

Resolved (SER)

(SSER 10)

(SSER 14)

(SSER 18)

(SSER 24)

(SSER 26)

12.4

(288) Dose Assessment Resolved (SER)

(SSER 14)

(SSER 24)

(SSER 27)

12.5

(289) Health Physics Program Resolved (SER)

(SSER 10)

(SSER 14)

(SSER 24)

(SSER 26)

12.6

(290) NUREG-0737 Items 12.7

(291) Plant Shielding

(TMI Action Item II.B.2)

Resolved (SER)

(SSER 14)

(SSER 16)

(SSER 24)

(SSER 27)

12.7.1

(292) High Range In-Containment Monitor 

(TMI Action Item II.F.1.(3))

Open (NRR) (SER)

(SSER 5)

12.7.2

(293) In-Plant Radioiodine Monitor (TMI 

Action Item II.D.3.3)

Open (NRR) (SER)

(SSER 16)

12.7.3

(294) Conduct of Operations 13

1-20
Issue Status Section Note

(295) Organization Structure of the 

Applicant

Resolved (SER)

(SSER 16)

(SSER 22)

13.1

(296) Management and Technical 

Organization

Resolved (SER) 13.1.1

(297) Corporate Organization and 

Technical Support

Resolved (SER) 13.1.2

(298) Plant Staff Organization Resolved (SER)

(SSER 8)

(SSER 22)

(SSER 25)

(SSER 27)

13.1.3

(299) Training 13.2

(300) Licensed Operator Training 

Program

Resolved (SER)

(SSER 9)

(SSER 10)

(SSER 22)

13.2.1

(301) Training for Non-licensed Personnel Resolved (SER) 13.2.2

(302) Emergency Preparedness 

Evaluation

13.3

(303) Introduction Resolved (SER)

(SSER 13)

(SSER 20)

(SSER 28)

13.3.1

(304) Evaluation of the Emergency Plan Resolved (SER)

(SSER 13)

(SSER 20)

(SSER 22)

(SSER 28)

13.3.2

(305) Conclusions Resolved (SER)

(SSER 13)

(SSER 20)

(SSER 22)

(SSER 28)

13.3.3

(306) Review and Audit Resolved (SER)

(SSER 8)

(SSER 22)

13.4

(307) Plant Procedures Resolved (SER)

(SSER 22)

13.5

(308) Administrative Procedures Resolved (SER)

(SSER 22)

13.5.1

(309) Operating and Maintenance 

Procedures

Resolved (SER)

(SSER 9)

(SSER 10)

(SSER 22)

13.5.2

(310) NUREG-0737 Items Resolved (SER)

(SSER 3)

(SSER 16)

(SSER 22)

13.5.3

1-21
Issue Status Section Note

(311) Physical Security Plan Resolved (SER)

(SSER 1)

(SSER 10)

(SSER 15)

(SSER 20)

(SSER 22)

13.6

(312) Introduction Resolved (SSER 22) 13.6.1

(313) Summary of Application Resolved (SSER 22) 13.6.2

(314) Regulatory Basis Resolved (SSER 22) 13.6.3

(315) Technical Evaluation Resolved (SSER 22) 13.6.4

(316) Conclusions Resolved (SSER 22) 13.6.5

(317) Cyber security Plan Resolved (SSER 24)

(SSER 28)

13.6.6

(318) Initial Test Program Resolved (SER)

(SSER 3)

(SSER 5)

(SSER 7)

(SSER 9)

(SSER 10)

(SSER 12)

(SSER 14)

(SSER 16)

(SSER 18)

(SSER 19)

(SSER 23)

14

(319) Accident Analyses 15

(320) General Discussion Resolved (SER) 15.1

(321) Normal Operation and Anticipated 

Transients

Resolved (SER) 15.2

(322) Loss-of-Cooling Transients Resolved (SER)

(SSER 13)

(SSER 14)

(SSER 24)

15.2.1

(323) Increased Cooling Inventory 

Transients

Resolved (SER)

(SSER 24)

15.2.2

(324) Change in Inventory Transients Resolved (SER)

(SSER 18)

(SSER 24)

15.2.3

(325) Reactivity and Power Distribution 

Anomalies

Resolved (SER)

(SSER 4)

(SSER 7)

(SSER 13)

(SSER 14)

(SSER 24)

(SSER 26)

15.2.4

(326) Conclusions Resolved (SER)

(SSER 4)

15.2.5

(327) Limiting Accidents Resolved (SER) 15.3

1-22
Issue Status Section Note

(328) Loss-of-Coolant Accident (LOCA) Resolved (SER)

(SSER 12)

(SSER 15)

(SSER 24)

15.3.1

(329) Steamline Break Resolved (SER)

(SSER 3)

(SSER 14)

(SSER 24)

15.3.2

(330) Feedwater System Pipe Break Resolved (SER)

(SSER 14)

(SSER 24)

15.3.3

(331) Reactor Coolant Pump Rotor 

Seizure

Resolved (SER)

(SSER 14)

(SSER 24)

15.3.4

(332) Reactor Coolant Pump Shaft Break Resolved (SER)

(SSER 14)

(SSER 24)

15.3.5

(333) Anticipated Transients Without 

Scram

Resolved (SER)

(SSER 3)

(SSER 5)

(SSER 6)

(SSER 10)

(SSER 11)

(SSER 12)

(SSER 24)

15.3.6

(334) Conclusions Resolved (SER) 15.3.7

(335) Radiological Consequences of 

Accidents

Resolved (SER)

(SSER 15)

(SSER 25)

15.4

(336) Loss-of-Coolant Accident Resolved (SER)

(SSER 5)

(SSER 9)

(SSER 18)

(SSER 25)

15.4.1

(337) Main Steamline Break Outside of 

Containment

Resolved (SER)

(SSER 15)

(SSER 25)

15.4.2

(338) Steam Generator Tube Rupture Resolved (SER)

(SSER 2)

(SSER 5)

(SSER 12)

(SSER 14)

(SSER 15)

(SSER 25)

15.4.3

(339) Control Rod Ejection Accident Resolved (SER)

(SSER 15)

(SSER 25)

15.4.4

1-23
Issue Status Section Note

(340) Fuel-Handling Accident Resolved (SER)

(SSER 4)

(SSER 15)

(SSER 25)

15.4.5

(341) Failure of Small Line Carrying 

Coolant Outside Containment

Resolved (SER)

(SSER 25)

15.4.6

(342) Postulated Radioactive Releases as 

a Result of Liquid Tank Failures

Resolved (SER)

(SSER 25)

15.4.7

(342a) Postulated Waste Gas Decay Tank 

Rupture

Resolved (SSER 25) 15.4.8

(343) NUREG-0737 Items 15.5

(344) Thermal Mechanical Report (TMI 

Action Item II.K.2.13)

Resolved (SER)

(SSER 4)

(SSER 24)

15.5.1

(345) Voiding in the Reactor Coolant 

System during Transients (TMI 

Action Item II.K.2.17)

Resolved (SER)

(SSER 4)

(SSER 24)

15.5.2

(346) Installation and Testing of Automatic 

Power-Operated Relief Valve 

Isolation System (TMI Action Item 

II.K.3.1) Report on Overall Safety 

Effect of Power-Operated Relief 

Valve Isolation System (TMI Action 

Item II.K.3.2)

Resolved (SER)

(SSER 5)

15.5.3

(347) Automatic Trip of Reactor Coolant 

Pumps (TMI Action Item II.K.3.5)

Resolved (SER)

(SSER 4)

(SSER 16)

(SSER 24)

15.5.4

(348) Small-Break LOCA Methods 

(II.K.3.30) and Plant-Specific 

Calculations (II.K.3.31)

Open 

(Inspection)

(SER)

(SSER 4)

(SSER 5)

(SSER 16)

15.5.5

(349) Relative Risk of Low-Power 

Operation

Resolved (SER) 15.6

(350) Technical Specification Open (NRR) 16

(351) Quality Assurance 17

(352) General Resolved (SER) 17.1

(353) Organization Resolved (SER) 17.2

(354) Quality Assurance Program Resolved (SER)

(SSER 2)

(SSER 5)

(SSER 10)

(SSER 13)

(SSER 15)

(SSER 22)

17.3

(355) Conclusions Resolved (SER) 17.4

(356) Maintenance Rule 17.6

(357) Control Room Design Review 18

1-24
Issue Status Section Note

(358) General Resolved (SER)

(SSER 5)

(SSER 6)

(SSER 15)

(SSER 16)

(SSER 22)

18.1

(359) Conclusions Resolved (SER)

(SSER 16)

(SSER 22)

18.2

(360) Report of the Advisory Committee 

on Reactor Safeguards

Resolved (SER)

(SSER 1)

(SSER 4)

(SSER 14)

(SSER 20)

(SSER 28)

19

(361) Common Defense and Security Resolved (SER) 20

(362) Financial Qualifications Resolved (SER) 21

(363) TVA Financial Qualifications for 

WBN, Unit 2

Resolved (SSER 22)

(SSER 23)

21.1

(364) Foreign Ownership, Control, or 

Domination

Resolved (SSER 22) 21.2

(365) Financial Protection and Indemnity 

Requirements

22

(366) General Resolved (SER) 22.1

(367) Preoperational Storage of Nuclear 

Fuel

Resolved (SER) 22.2

(368) Operating Licenses Open (NRR) (SSER 22) 22.3

(369) Quality of Construction, Operational 

Readiness, and Quality Assurance 

Effectiveness

25

(370) Program for Maintenance and 

Preservation of the Licensing Basis 

for Units 1 and 2

Resolved (SSER 22)

(SSER 27)

25.9

Notes:

1. In the process of further validating the information in the WBN Unit 2, FSAR, TVA 

identified minor administrative/typographical changes to sections previously 

considered resolved. TVA addressed these changes to the applicable sections 

in its submittals and clearly indicated them to the NRC staff. The NRC staff has 

reviewed and confirmed that the changes made are administrative/typographical 

and do not impact the NRC staff’s conclusions as stated in previous SSERs. 

Based on this review, no additional review is necessary and this section remains 

resolved.

2. During the assessment of the regulatory framework for completion of the project, 

the NRC staff characterized certain topics as “Open” pending TVA’s validation of 

the information contained in the section. TVA has determined that the 

information presented in the FSAR remained valid and only identified minor 

1-25
administrative or typographical changes to the section. TVA addressed the 

changes in its submittals and clearly indicated the changes. The NRC staff 

reviewed and confirmed that the changes made to the section are 

administrative/typographical and do not impact its conclusions as stated in 

previous SSERs. Therefore, no additional review is necessary and the NRC staff 

considers this section resolved.

3. In SSER 21, this issue was identified as “Resolved.” However, TVA made 

changes to the Unit 2 FSAR affecting the previous NRC staff conclusions. The 

NRC staff evaluated the changes and the results are documented in SSERs 

subsequent to SSER 21.

1.8 Confirmatory Issues

At this point in the review, there are some items that have essentially been resolved to the NRC 

staff’s satisfaction, but for which certain confirmatory information has not yet been supllied by 

the applicant. In these instances, the applicant has committed to supply the confirmatory 

information in the near future. If NRC staff review of this information does not confirm 

preliminary conclusions on an item, that item will be treated as open, and the NRC staff will

report on its resolution in a supplement to this report.

The confirmatory items, with appropriate references to subsections of this report, are noted in 

Appendix HH.

1.9 License Conditions

1.9.1 Flooding License Condition

The NRC staff had proposed two license conditions in Section 2.4 of SSER 24. TVA has 

supplemented Section 2.4 since publication of SSER 24. The NRC staff’s review of this 

information can be found in Section 2.4 of SSER 28. The NRC staff has determined that the 

previously proposed license conditions were no longer appropriate and in their place the NRC 

staff is proposing the following license condition.

Flooding Protection Proposed License Condition:

TVA shall implement permanent modifications to prevent overtopping of the 

embankments of the Fort Loudoun Dam due to the Probable Maximum Flood by 

February 1, 2017. 

1.9.2 Cyber security License Condition

The NRC staff had proposed two license conditions discussed in Section 13.6.6.3.22 of

SSER 24. The NRC has received an updated implementation schedule from TVA. The 

previous license conditions were deleted and a new condition has been proposed and is 

discussed in Section 13.6.6.3.3 of this SSER. 

Cyber security Proposed License Condition:

The licensee shall fully implement and maintain in effect all provisions of the 

Commission approved cyber security plan (CSP), including changes made pursuant to 

1-26
the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The licensee CSP was approved 

by NUREG-0847, Supplement 28.

1.9.3 Core Operating Limits License Condition

The NRC staff proposed a license condition discussed in Section 4.2.2 of SSER 27.

Performance Analysis and Design (PAD) Thermal Conductivity Degradation (TCD) 

Proposed License Condition:

PAD4TCD may be used to establish core operating limits prior to the initial cycle, and 

prior to any remaining portion of the initial cycle. PAD 4 TCD may not be used to 

establish core operating limits prior to any reload cycle, and prior to any remaining 

portion of any reload cycle.

1.9.4 Electrical Design License Condition

The NRC staff proposed a license condition discussed in Section 8.2.2 of SSER 27.

Bulletin 2012-01, “Design Vulnerability in Electrical Power System,” Proposed License 

Condition:

By December 31, 2017, TVA will report to the NRC that the actions to resolve the issues 

identified in Bulletin 2012-01, “Design Vulnerability in Electrical Power System,” have 

been implemented.

1.13 Implementation of Corrective Action Programs and Special Programs

In 1985, TVA developed a corporate NPP that identified and proposed corrections to problems 

concerning the overall management of its nuclear program and a site-specific plan for WBN

entitled, “Watts Bar Nuclear Performance Plan.” TVA established 18 corrective action programs 

(CAPs) and 11 special programs (SPs) to address these concerns. 

SSER 21, Table 1.13.1 documented the status of NRC staff review of the CAPs and SPs. 

Currently, as indicated all items are resolved.

1.13.1 Corrective Action Programs

No. Title Program Review Status

(1) Cable Issues

a. Silicon Rubber Insulated Cable 

b. Cable Jamming

c. Cable Support in Vertical Conduit 

d. Cable Support in Vertical Trays

e. Cable Proximity to Hot Pipes

f. Cable Pull-Bys 

g. Cable Bend Radius 

h. Cable Splices 

i. Cable Sidewall Bearing Pressure 

j. Pulling Cables Through 90° Condulet and Flexible 

Resolved

(See Appendix HH)

1-27
No. Title Program Review Status

Conduit 

k. Computer Cable Routing System Software and 

Database Verification and Validation

(2) Cable Tray and Tray Supports Resolved

(3) Design Baseline and Verification Program Resolved

(4) Electrical Conduit and Conduit Support Resolved

(5) Electrical Issues

a. Flexible Conduit Installations 

b. Physical Cable Separation and Electrical Isolation

c. Contact and Coil Rating of Electrical Devices

d. Torque Switch and Overload Relay Bypass Capability 

for Active Safety-Related Valves

e. Adhesive-Backed Cable Support Mount 

Resolved

(6) Equipment Seismic Qualification Resolved

(7) Fire protection Resolved

(8) Hanger and Analysis Update Program Resolved

(9) Heat Code Traceability Resolved

(10) Heating, Ventilation, and Air-Conditioning Duct and 

Duct Supports

Resolved

(11) Instrument Lines Resolved

(12) Prestart Test Program Plan Resolved

(13) Quality Assurance Records Resolved

(14) Quality-List (Q-List) Resolved

(15) Replacement Items Program (Piece Parts) Resolved

(16) Seismic Analysis Resolved

(17) Vendor Information Program Resolved

(18) Welding Resolved

1-28
1.13.2 Special Programs

No. Title Program Review Status

(1) Concrete Quality Program Resolved

(2) Containment Cooling Resolved

(3) Detailed Control Room Design Review Resolved

(4) Environmental Qualifications Program Resolved

(5) Master Fuse List Resolved

(6) Mechanical Equipment Qualification Resolved

(7) Microbiologically Induced Corrosion Resolved

(8) Moderate Energy Line Break Flooding Resolved

(9) Radiation Monitoring System Resolved

(11) Use-As-Is Condition Adverse to Quality Resolved

1.14 Implementation of Applicable Bulletin and Generic Letter Requirements

From time to time, the NRC staff issues generic requirements or recommendations in the form 

of orders, bulletins (BLs), generic letters (GLs), regulatory issue summaries, and other 

documents to address certain safety and regulatory issues. These are generally termed 

“generic communications.”

The table below outlines the status of the resolution of the generic communications. It should 

be noted that although many of the generic communications have been documented or 

otherwise resolved, the NRC staff has determined that there may be circumstances that could 

result in the need to reopen a previously closed topic.

Correspondence No. Title

(1) GL 1980-14

TVA Action:

NRC Action:

Light-Water Reactor Primary Coolant System Pressure 

Isolation Valves.

Submit Technical Specifications (TSs) for NRC Review.

To be reviewed during validation of TS 3.4.14.

(2) GL 1980-77

TVA Action:

NRC Action:

Refueling Water Level - Technical Specifications Changes.

Submit Technical Specifications for NRC Review.

To be reviewed during validation of TS 3.9.5 –TS 3.9.

1-29
Correspondence No. Title

(3) GL 1982-28

TVA Action:

NRC Action:

Inadequate Core Cooling Instrumentation System.

Closed.

Closed. Subsumed as part of NRC staff review of 

Instrumentation and Controls submitted April 8, 2010.

(4) GL 1983-28 Required Actions Based on Generic Implications of Salem 

Anticipated Transient without Scram Events (Screened into 

the Items 4 through 7).

(4.a) GL 1983-28 (item 

3.1)

TVA Action:

NRC Action:

Post-Maintenance Testing (reactor trip system components).

Submit Technical Specifications for NRC Review.

To be reviewed during validation of TS Bases 3.0.1.

(4.b) GL 1983-28 (3.2)

TVA Action

NRC Action

Post-Maintenance Testing (All Surveillance Requirement 

Components).

Submit Technical Specifications and NRC Review.

To be reviewed during validation of TS Bases 3.0.1.

(4.c) GL 1983-28 (4.2)

TVA Action

NRC Action

Reactor Trip System Reliability (Preventive Maintenance and 

Surveillance Program for Reactor Trip Breakers).

Submit Technical Specifications and NRC Review.

To be reviewed during NRC staff evaluation of Item 17 of TS 

Table 3.3.1-1.

(4.d) GL 1983-28 (4.5)

TVA Action

NRC Action

Reactor Trip System Reliability (Automatic Actuation of Shunt 

Trip Attachment).

Submit Technical Specifications and NRC Review.

To be reviewed during NRC staff evaluation of Item 18 of TS 

Table 3.3.1-1.

(8) GL 1986-09

TVA Action

NRC Action

Technical Resolution of Generic Issue B-59 (N-1) Loop 

Operation in BWRs and PWRs.

Submit Technical Specifications for NRC Review.

To be reviewed during validation of TS 3.4.4 - TS 3.4.8.

1-30
Correspondence No. Title

(9) GL 1988-20

TVA Action

NRC Action

Individual Plant Examination for Severe Accident Vulnerability.

Closed.

Closed. NRC letter dated August 12, 2011 (ADAMS 

Accession No. ML111960228).

(10) GL 1988-20s1

TVA Action

NRC Action

Initiation of the Individual Plant Examination for Severe 

Accident Vulnerabilities — 10 CFR 50.54.

Closed.

Closed. NRC letter dated August 12, 2011 (ADAMS 

Accession No. ML111960228).

(11) GL 1988-20s2

TVA Action

NRC Action

Individual Plant Examination for Severe Accident Vulnerability. 

Accident Management Strategies for Consideration in the 

Individual Plant Examination Process.

Closed.

Closed. NRC letter dated August 12, 2011 (ADAMS 

Accession No. ML111960228).

(12) GL 1988-20s3

TVA Action

NRC Action

Individual Plant Examination for Severe Accident Vulnerability. 

Completion of Containment Performance Improvement 

Program and Forwarding of Insights for Use in the IPE for 

Severe Accident Vulnerabilities.

Closed.

Closed. NRC letter dated August 12, 2011 (ADAMS 

Accession No. ML111960228).

(13) GL 1988-20s4

TVA Action

NRC Action

Individual Plant Examination of External Events (IPEEE) for 

Severe Accident Vulnerabilities.

Closed.

Closed. NRC letter dated September 20, 2011 (ADAMS 

Accession No. ML111960300).

1-31
Correspondence No. Title

(14) GL 1988-20s5

TVA Action

NRC Action

Individual Plant Examination of External Events (IPEEE) for 

Severe Accident Vulnerabilities - 10 CFR 50.54(f).

Closed.

Closed. NRC letter dated September 20, 2011 (ADAMS 

Accession No. ML111960300).

(15) GL 1989-04

TVA Action

NRC Action

Guidelines on Developing Acceptable Inservice Testing 

Programs.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC letter dated October 21, 2014 (ADAMS 

Accession No. ML14289A222).

(16) GL 1989-21

TVA Action

NRC Action

Request for Information Concerning Status of Implementation 

of Unresolved Safety Issue Requirements.

TVA provided an updated status of unresolved safety issues 

on September 26, 2008, as supplemented on December 2, 

2010, and January 25, 2011.

Closed. See Appendix C of SSER 23.

(17) GL 1990-06

TVA Action

NRC Action

Resolution of Generic Issues 70, “PORV [power-operated 

relief valve] and Block Valve Reliability,” and 94, “Additional 

LTOP [low-temperature overpressure] Protection for PWRs.”

Submit Technical Specifications for NRC Review.

To be reviewed during validation of TS 3.4.11 - TS 3.4.12.

(18) GL 1992-08

TVA Action

NRC Action

Thermo-Lag 330-1 Fire Barriers.

The proposed approach has been approved for WBN, Unit 1; 

the same approach will be proposed for use on WBN, Unit 2, 

without change.

Open. Pending NRC staff inspection verification.

1-32
Correspondence No. Title

(19) GL 1995-03

TVA Action

NRC Action

Circumferential cracking of Steam Generator (SG) Tubes.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated January 21, 2010 (ADAMS 

Accession No. ML093631061).

(20) GL 1995-05 

TVA Action

NRC Action

Voltage –Based Repair Criteria for Westinghouse Steam 

Generator Tubes affected by Outside Diameter Stress 

Corrosion Cracking.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated January 21, 2010 (ADAMS 

Accession No. ML093631061).

(21) GL 1996-06

TVA Action

NRC Action

Assurance of Equipment Operability and Containment Integrity 

During Design-Basis Accident Conditions.

The proposed approach has been approved for WBN, Unit 1; 

the same approach will be proposed for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated January 21, 2010 (ADAMS 

Accession No. ML100130227).

(22) GL 1995-07

TVA Action

NRC Action

Pressure Locking and Thermal Binding of Safety-Related 

Power-Operated Gate Valves (Not identified in SSER 21 as 

“Open”).

The proposed approach has been approved for WBN, Unit 1; 

the same approach will be proposed for use on WBN, Unit 2, 

without change.

Closed. NRC letter dated August 12, 2010 (ADAMS 

Accession No. ML100190443).

1-33
Correspondence No. Title

(23) GL 1997-01

TVA Action

NRC Action

Degradation of Control Rod Drive Mechanism Nozzle and 

Other Vessel Closure Head Penetrations.

The proposed approach has been approved for WBN, Unit 1; 

the same approach will be proposed for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated June 30, 2010 (ADAMS Accession 

No. ML100539515).

(24) GL 1997-04

TVA Action

NRC Action

Assurance of Sufficient Net Positive Suction Head for 

Emergency Core Cooling and Containment Heat Removal 

Pumps Integrity During Design-Basis Accident Conditions.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated February 18, 2010 (ADAMS 

Accession No. ML100200375).

(25) GL 1997-05

TVA Action

NRC Action

SG Tube Inspection Techniques.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated January 21, 2010 (ADAMS 

Accession No. ML093631061).

(26) GL 1997-06

TVA Action

NRC Action

Degradation of SG Internals.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated January 21, 2010 (ADAMS 

Accession No. ML093631061).

1-34
Correspondence No. Title

(27) GL 1998-02

TVA Action

NRC Action

Loss of Reactor Coolant Inventory and Associated Potential 

for Loss of Emergency Mitigation Functions While in a 

Shutdown Condition.

The proposed approach has been approved for WBN, Unit 1; 

the same approach will be proposed for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated May 11, 2010 (ADAMS Accession 

No. ML101200155).

(28) GL 1998-04

TVA Action

NRC Action

Potential for Degradation of the ECCS [Emergency Core 

Cooling System] and the Containment Spray System after a 

LOCA because of Construction and Protective Coating 

Deficiencies and Foreign Material in Containment.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated February 1, 2010 (ADAMS 

Accession No. ML100260594).

(29) GL 2003-01

TVA Action

NRC Action

Control Room Habitability.

No action or documentation is provided to show the NRC staff 

has reviewed the item for WBN, Unit 2, and the resolution is 

through submittal of a technical specification.

Closed. NRC Letter dated February 1, 2010 (ADAMS 

Accession No. ML100270076).

(30) GL 2004-01

TVA Action

NRC Action

Requirements for SG Tube Inspection.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated January 21, 2010 (ADAMS 

Accession No. ML093631061).

1-35
Correspondence No. Title

(31) GL 2004-02

TVA Action

NRC Action

Potential Impact of Debris Blockage on Emergency 

Recirculation during Design-Basis Accidents at PWRs.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated September 18, 2014 (ADAMS 

Accession No. ML14163A658).

(32) GL 2006-01

TVA Action

NRC Action

SG Tube Integrity and Associated Technical Specifications.

No action or documentation is provided to show the NRC staff 

has reviewed the item for WBN, Unit 2, and the resolution is 

through submittal of a technical specification.

Closed. NRC Letter dated January 21, 2010 (ADAMS 

Accession No. ML093631061) (See Appendix HH).

(33) GL 2006-02

TVA Action

NRC Action

Grid Reliability and the Impact on Plant Risk and the 

Operability of Offsite Power.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated January 21, 2010 (ADAMS 

Accession No. ML093631061) (See Appendix HH Open 

Item 6). Staff has reviewed Revision I to the proposed 

technical specifications and found that Technical Specificaiton 

Task Force (TSTF) 449 has been incorporated.

(34) GL 2006-03

TVA Action

NRC Action

Potentially Nonconforming Hemyc and MT Fire Barrier 

Configurations.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC Letter February 25, 2010 (ADAMS Accession 

No. ML100470398).

1-36
Correspondence No. Title

(35) GL 2007-01

TVA Action

NRC Action

Inaccessible or Underground Power Cable Failures that 

Disable Accident Mitigation Systems or Cause Plant 

Transients.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated January 26, 2010 (ADAMS 

Accession No. ML100120052).

(36) GL 2008-01

TVA Action

NRC Action

Managing Gas Accumulation in Emergency Core Cooling, 

Decay Heat Removal, and Containment Spray Systems.

TVA submitted the information requested by the GL.

Closed. NRC letter dated August 23, 2011 (ADAMS 

Accession No. ML112232205).

(37) BL 1992-01 and 

Supplement 1

TVA Action

NRC Action

Failure of Thermo-Lag 330 Fire Barrier System to Perform its 

Specified Fire Endurance Function.

The proposed approach has been approved for WBN, Unit 1; 

the same approach will be proposed for use on WBN, Unit 2, 

without change.

Open. Pending NRC staff inspection verification.

(38) BL 1996-01

TVA Action

NRC Action

Control Rod Insertion Problems (PWR)

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC letter dated May 3, 2010 (ADAMS Accession 

No. ML101200035) required Confirmatory Action (See 

Appendix HH Open Items 5 and 8). By letter dated July 30, 

2012, TVA provided the information in the Confirmatory Action 

and the NRC staff verified the information and has closed 

Appendix HH Open Items 5 and 8. 

1-37
Correspondence No. Title

(39) BL 1996-02 Movement of Heavy Loads Over Spent Fuel, Over Fuel In the 

Reactor Core, or Over Safety-Related Equipment.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated March 4, 2010 (ADAMS Accession 

No. ML100480062).

(40) BL 2001-01

TVA Action

NRC Action

Circumferential Cracking of Reactor Pressure Vessel (RPV) 

Head Penetration Nozzles.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. See NRC Letter dated June 30, 2010 (ADAMS 

Accession No. ML100539515).

(41) BL 2002-01

TVA Action

NRC Action

RPV Head Degradation and Reactor Coolant Pressure 

Boundary Integrity.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. See NRC Letter dated June 30, 2010 (ADAMS 

Accession No. ML100539515).

(42) BL 2002-02

TVA Action

NRC Action

RPV Head and Vessel Head Penetration Nozzle Inspection 

Program.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. See NRC Letter dated June 30, 2010 (ADAMS 

Accession No. ML100539515).

1-38
Correspondence No. Title

(43) BL 2003-02 

TVA Action

NRC Action

Leakage from RPV Lower Head Penetrations and Reactor 

Coolant Pressure Boundary Integrity.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC Letter dated January 21, 2010 (ADAMS 

Accession No. ML093631061).

(44) BL 2004-01

TVA Action

NRC Action

Inspection of Alloy 82/182/600 Materials Used in the 

Fabrication of Pressurizer Penetrations and Steam Space 

Piping Connections at PWRs.

The proposed approach has been approved for WBN, Unit 1; 

the same approach was submitted for use on WBN, Unit 2, 

without change.

Closed. NRC letter dated August 4, 2010 (ADAMS Accession 

No. ML102080017).

(45) BL 2007-01

TVA Action

NRC Action

Security Officer Attentiveness.

The proposed approach has been approved for WBN, Unit 1; 

the same approach will be proposed for use on WBN, Unit 2, 

without change.

Closed. NRC letter dated March 25, 2010 (ADAMS Accession 

No. ML100770549).

(46) BL 2011-01

TVA Action

NRC Action

Mitigating Strategies

The proposed approach has been approved for WBN, Unit 1; 

an updated approach will be proposed for use on WBN, 

Unit 2, without change.

Open.

(47) BL 2012-01

TVA Action

NRC Action

Design Vulnerability In Electric Power System

TVA submitted a letter on September 3, 2014 (ADAMS 

Accession No. ML14247A231) providing wording for the FSAR 

and proposed a license condition.

Resolved, see license condition described in SER 

Section 1.9.4.

1-39
Correspondence No. Title

NUREG-0737, TMI Action Items (TVA letter dated September 14, 1981, applies

to all of the following NUREG-0737 issues):

(48) NUREG-0737 

Item I.B.1.2

TVA Action

NRC Action

Independent Safety Engineering Group.

The proposed approach has been approved for WBN, Unit 1; 

the same approach will be proposed for use on WBN, Unit 2, 

without change.

Open.

(49) NUREG-0737 

Item I.D.1

TVA Action

NRC Action

Control Room Design Review (CRDR).

The proposed approach has been approved for WBN, Unit 1; 

the same approach will be proposed for use on WBN, Unit 2, 

without change.

Closed in SSER 22, Section 18.2.

(50) NUREG-0737 

Item II.B.3

TVA Action

NRC Action

Post-accident Sampling.

No action or documentation is provided to show the NRC staff 

has reviewed the item for WBN, Unit 2, and the resolution is 

through submittal of a technical specification.

Closed in SSER 24, Section 9.3.2.

(51) NUREG-0737 

Item II.E.4.2

TVA Action

NRC Action

Containment Isolation Dependability.

No action or documentation is provided to show the NRC staff 

has reviewed the item for WBN, Unit 2, and the resolution is 

through submittal of a technical specification.

Open.

1-40
Correspondence No. Title

(52) NUREG-0737 

Item II.F.2

TVA Action

NRC Action

Instrumentation for Detection of Inadequate Core-Cooling.

Closed.

Closed. See SSER 25 and SSER 26, Section 7.5.2.2. Open 

Items 72, 95, 96, 97, 99, 100, 102, 103, 104, 106, 107, and 

109 were closed in SSER 25, Section 7.5.2.2. Open items 94, 

98, 101, 105, 108, 110, and 111 were closed in SSER 26, 

Section 7.5.2.2.

(53) NUREG-0737 

Item II.K.3.3

TVA Action

NRC Action

Reporting Safety Valve/Reactor Vessel Failures/Challenges. 

No action or documentation is provided to show the NRC staff 

has reviewed the item for WBN, Unit 2, and the resolution is 

through submittal of a technical specification.

Closed in SSER 22, Section 13.5.3.

(54) NUREG-0737 

Item II.K.3.10

TVA Action

NRC Action

Anticipatory Trip at High Power.

No action or documentation is provided to show the NRC staff 

has reviewed the item for WBN, Unit 2, and the resolution is 

through submittal of a technical specification.

Closed (SSER 23, Section 7.8.4).

(55) NUREG-0737 

Item III.D.1.1

TVA Action

NRC Action

Primary Coolant Outside Containment.

No action or documentation is provided to show the NRC staff 

has reviewed the item for WBN, Unit 2, and the resolution is 

through submittal of a technical specification.

Open.

(56) NUREG-0737

Item III.D.3.4

TVA Action

NRC Action

Control-Room Habitability.

The proposed approach has been approved for WBN, Unit 1; 

the same approach will be proposed for use on WBN, Unit 2, 

without change.

Closed in SSER 22, Section 6.4.

1-41
Correspondence No. Title

(57) Office of Inspection 

and Enforcement 

Bulletin (IEB) 75-08

TVA Action

NRC Action

PWR Pressure Instrumentation.

The item has been approved either for both units at WBN or 

explicitly for WBN, Unit 2; however, a change to the original 

approval requires submittal of the technical specifications and 

NRC staff review.

Open.

(58) IEB 77-04

TVA Action

NRC Action

Calculation Error Affecting Performance of a System for 

Controlling pH of Containment Sump Water Following a 

LOCA.

The item has been approved either for both units at WBN or 

explicitly for WBN, Unit 2; however, a change to the original 

approval requires submittal of the technical specifications and 

NRC staff review.

Open.

Fukushima-Related Orders (NRC letters dated March 12, 2012):

(59) EA-12-049

TVA Action

NRC Action

Mitigating Strategies for Beyond-Design-Basis External Events

(ADAMS Accession No. ML12054A735)

Provide final compliance letter by December 17, 2014.

Open.

(60) EA-12-051

TVA Action

NRC Action

Reliable Spent Fuel Pool Instrumentation

(ADAMS Accession No. ML12054A679)

Compliance letter sent October 29, 2014.

Open

1-42
2 SITE CHARACTERISTICS

2.4 Hydrologic Engineering

2.4.10 Flooding Protection Requirements

Disposition of Open Item (Appendix HH)

Open Item 134

Open Item 134 states:

TVA should provide to the NRC staff supporting technical justification for the 

statements in Amendment 104 of FSAR Section 2.4.4.1, “Dam Failure 

Permutations,” page 2.4-32 (in the section “Multiple Failures”) that, “Fort 

Loudoun, Tellico, and Watts Bar have previously been judged not to fail for the 

OBE [operating basis earthquake] (0.09 g). Postulation of Tellico failure in this 

combination has not been evaluated but is bounded by the SSE [safe shutdown 

earthquake] failure of Norris, Cherokee, Douglas and Tellico.”

In Supplemental Safety Evaluation Report (SSER) 24, the NRC staff documented its review of 

updated information supplied by TVA in Amendment No. 104 of the final safety analysis report 

(FSAR) on flooding protection. During its review, the NRC staff documented the need for 

resolution to Open Item 134. Following the publication of SSER 24, TVA informed the NRC 

staff that further evaluation had been completed regarding the hydrologic analysis at the Watts 

Bar Nuclear Plant (WBN) site and that a slightly higher probable maximum flood had been 

calculated. As this information affected both WBN Units 1 and 2, TVA submitted a license 

amendment for WBN, Unit 1, and Updated FSAR (UFSAR) pages for WBN, Unit 2. Considering 

the guidance in SRM SECY-07-0096 that Unit 1’s licensing basis could be used as a reference 

for the licensing basis for Unit 2, the NRC staff focused its review on the WBN, Unit 1, license 

amendment request (LAR) as a means to update the hydrologic analysis for the WBN site. If 

approved, this would also provide the basis for WBN, Unit 2. 

During the NRC staff’s review of the application, questions were raised on the actions taken by 

TVA to evaluate dam stability. Following many discussions with the NRC staff, TVA revised its 

hydrologic analysis for the WBN site, including the use of the U.S. Army Corps of Engineers 

Hydrolic Engineering Centers Hydrologic Modeling System and River Analysis System software, 

which resulted in changes to the flooding protection requirements for certain structures, 

systems, and components impacted by the revised analysis. In addition, TVA also revised the 

dam stability acceptance criteria by adopting the updated TVA River Operations Standards (the 

TVA dam authority having jurisdiction). TVA supplied this by a supplement to the WBN, Unit 1,

LAR, and a letter for WBN, Unit 2, followed up by Amendment No.113 to the FSAR. By letter 

dated January 28, 2015 (Agencywide Documents Access and Management System (ADAMS) 

Accession No. ML15005A314), the NRC staff approved the WBN, Unit 1, LAR. 

Based on the fact that TVA revised its hydrologic analysis for the WBN site, including the dam 

stability acceptance criteria, the NRC staff considers its previous concern to no longer be an 

issue and, therefore, considers Open Item 134 to be closed. The evaluation previously 

documented for this section has been superseded by the evaluation done for the license 

amendment and the two units no longer have a differing licensing basis. 

2-1
The following license condition was imposed as part of the WBN, Unit 1, license amendment 

approval and is being proposed for WBN, Unit 2:

Flooding Protection Proposed License Condition:

TVA shall implement permanent modifications to prevent overtopping of the 

embankments of the Fort Loudoun Dam due to the Probable Maximum Flood by 

February 1, 2017. 

2-2
8 ELECTRICAL POWER SYSTEMS

8.3 Onsite (Standby) Power System

8.3.1 Alternating Current Power System

8.3.1.2 Low and Degraded Voltage Conditions

Disposition of Open Items (Appendix HH)

Open Item 30

Open Item 30 states:

TVA should confirm that all other safety-related equipment (in addition to the

Class 1E motors) will have adequate starting and running voltage at the most 

limiting safety related components (such as motor-operated valves, contactors, 

solenoid valves or relays) at the degraded voltage relay [DVR] setpoint dropout 

setting. TVA should also confirm that the final Technical Specifications are 

properly derived from these analytical values for the degraded voltage settings.

(SSER 22, Section 8.3.1.2).

By e-mail dated February 27, 2014, the U.S. Nuclear Regulatory Commission (NRC) staff 

issued an RAI (ADAMS Accession No. ML14059A158) related to Open Item No. 30 for WBN,

Unit 2, SSER, NUREG-0847 (June 1982). By letter dated January 30, 2015 (ADAMS Accession 

No. ML15030A511), TVA (the applicant) supplied further information on the licensing basis for 

WBN, Units 1 and 2. Open item No. 30 is related to DVR setpoints for protection of safetyrelated equipment during sustained low voltage conditions on offsite power sources.

Two levels of undervoltage protection are given on the WBN 6.9 (kilovolt) kV safe shutdown 

boards to protect the safety-related electrical distribution system from unexpected low voltage 

conditions. The first level of undervoltage protection is the loss of voltage relay (LVR), whose 

primary function is to detect and disconnect the safety-related boards upon a loss of offsite 

power. The second level of undervoltage protection is the DVR, which protects Class 1E

equipment from sustained low or degraded voltage conditions on the offsite power grid. The

LVR and DVR also supply a start signal to the onsite source(s) to ensure that power to the

safety-related loads can be established in a timely manner for safe shutdown of the dual units

during postulated events.

The DVRs have a nominal 10-second time delay at the technical specification (TS) specified 

relay voltage setting. When the 10-second time delay has elapsed, the plant loads are removed 

from the offsite power supply and transferred to the onsite emergency diesel generators. The 

DVRs drop-out (de-energize) when sufficient voltage is not available and normally pick-up 

(energize) if voltage is recovered within the 10-second delay on the 6900 (volt alternating 

current (VAC) Class 1E bus.

TVA’s January 30, 2015 letter supplied a detailed explanation of degraded voltage and loss of 

voltage protection schemes installed at WBN, Units 1 and 2. Enclosure 1 of the letter gave

details on applicable design and licensing basis requirements and included an overview of how 

8-1
the Class 1E bus undervoltage protection schemes fully comply with applicable design and 

licensing basis requirements, including General Design Criterion (GDC) 17, “Electric Power 

Systems,” of Appendix A, “General Design Criteria for Nuclear Power Plants,” to 10 CFR Part 50. 

The letter also states that, “Branch Technical Position (BTP) PSB-1: Adequacy of Station Electric 

Distribution System Voltages,” Revision 2 (July 1981) is part of the licensing basis for WBN, Units 

1 and 2, and the design of the DVRs is in full compliance with this BTP.

Section 7.2 of Enclosure 1 of the letter dated January 30, 2015, gives a summary of the

analyses done on the WBN alternating current (AC) power distribution system and auxiliary 

loads to demonstrate that the offsite power system can perform its intended safety functions. 

The detailed studies are documented in TVA Calculation EDQ00099920070002, “AC Auxiliary 

Power System Analysis (Dual Unit Operation),” Revision 43. The applicant has stated the 

following pertinent design features:

• The calculation evaluates the system performance and resultant equipment voltages

when powered from the 161kV offsite preferred power supply and the 500kV system.

• The AC system analyses were performed for the various transformer, bus, and circuit

breaker alignments and design-basis events, including the 6.9kV Shutdown Boards

aligned to a single Common Station Service Transformer (CSST) C or D, the 6.9kV

Shutdown Boards aligned to CSST A or B, loss-of-coolant accident (LOCA) in one unit

with orderly shutdown of the other, and Safety Injection actuation Phase A or Safety

Injection actuation Phase B.

• The analysis considers the operation of the safety-related electrical distribution system

under accident conditions (accident initiated block starting) with the offsite power supply

at the minimum grid voltage for operable offsite sources (153kV), which bounds to a

minimum expected grid voltage and capacity for an N-1 contingency.

• The scope of TVA Calculation EDQ00099920070002 includes the CSSTs A, B, C, and 

D, Unit Station Service Transformers 1A, 1B, 2A, and 2B, 6.9kV Reactor Coolant Pump

Boards, 6.9kV Start Busses, 6.9kV Common Station Switchgear C and D, 6.9kV

Shutdown Boards, 6.9kV Unit Boards, 6.9kV Common Boards, and the downstream

6900-480 (volt) V transformers, 480V distribution boards and all interconnections.

The analysis assumes that:

a. Equipment started by an automatic safety injection actuation signal (SIAS) is 

started at the same time (block start) unless the load’s control circuitry has a 

sequential time delay.

b. Equipment that is tripped off by an SIAS is disconnected.

c. Loads that could be operating immediately after the safety injection, whether 

safety-related or not, are running.

d. The analysis considers the maximum expected loading conditions is associated

with a design-basis accident (DBA) in one reactor unit and the other reactor unit 

in a simultaneous orderly shutdown.

8-2
The applicant has established that approximately 7000V at the 6.9kV safety bus ensures that all 

safety-related equipment is capable of performing the safety functions when relying on offsite 

power. The applicant has indicated that the safety-related bus voltage drops below the DVR 

dropout voltage analytical limit (6555V) during the accident (block-start) transient and recovers 

above the DVR pickup voltage analytical limit (6681V) before the DVR minimum time delay 

analytical limit (8.5 seconds) is exceeded. Since the voltage recovers and the safeguards loads 

are not adversely impacted, the applicant has concluded the offsite source has the capacity and 

capability (start and run all required loads) to perform its intended safety functions for postulated 

DBA conditions and established operability limits for offsite power sources during normal plant 

operation.

Based on the information provided by the applicant, the NRC staff determined that the Offsite 

Power and Station Electric Power System Design Calculations specify the voltage operating

parameters of the plant electrical distribution system using the transmission network (grid)

operating parameters. This interface calculation establishes operating voltage bands for all

plant electrical busses, which ensures that all plant safety-related components and systems 

have proper voltage for starting and running in all operational configurations (expected 

operational and accident line-ups and conditions). Therefore, based on normal grid operation 

(including post-contingency grid conditions), the plant buses will have adequate voltage above 

the DVR actuation point, thus maintaining the offsite power supply to the plant electrical 

distribution system. This design meets the capacity and capability requirement with respect to 

voltage requirements, thus demonstrating compliance with GDC 17 requirements.

In view of the proposed operation of WBN, Unit 2, sharing the common offsite source with WBN,

Unit 1, the NRC staff requested information on protocols between the WBN units and 

transmission system operator (TSO) with respect to dual unit operation.

The applicant stated that WBN, Units 1 and 2, will maintain existing protocols between the

nuclear power plant and the TSO to determine the operability of offsite power. These protocols

are consistent with the guidance given in NRC GL 2006-02, “Grid Reliability and the Impact on 

Plant Risk and Operability of Offsite Power” (ADAMS Accession No. ML060180352). The 

design-basis requirements established for dual unit operation are discussed in Enclosure 1 of 

the applicant’s letter dated January 30, 2015.

North American Electric Reliability Corporation Standard NUC-001-2.1, “Nuclear Plant Interface 

Coordination” requires coordination between nuclear plant operators and transmission entities 

for the purpose of ensuring safe nuclear plant operations. The standard delineates nuclear 

plant interface requirements for TSOs and nuclear plant operators.

The bulk power electric system around WBN, Units 1 and 2, is owned by TVA and operated by 

Transmission and Power Supply (TPS). TVA Nuclear Power Group (NPG) is responsible for

operation of the nuclear plants. The two entities have developed TVA intergroup agreement

TVA-SPP-10.010 that established mutually agreed NPIRs and documents how the NPG and 

TPS satisfy the requirements of NUC-001-2.1. This TVA intergroup agreement defines how and

when grid status, and changes to grid status, is communicated between TPS and WBN.

WBN Technical Instruction (TI)-12.15, “161kV Offsite Power Requirements,” Revision 26,

supplies guidance to plant operators when notified by the grid operator that the 161kV power

source cannot meet the pre-established criteria for either of the offsite power sources. TI-12.15

directs the plant operator to enter the appropriate WBN technical specification (TS) limiting 

condition of operation.

8-3
The applicant stated that the current offsite voltage acceptance criteria for the 161kV source

(normal operation) for WBN is as follows:

Maximum voltage drop from pre-event to post-event for a design bases event is 

an 11kV drop with a minimum post-event grid voltage at WBN of 153kV. The 

“ALTERNATE” offsite acceptance criteria for the 161kV source for WBN is a 

maximum voltage drop from pre-event to post-event for a design bases event is 

6kV drop with a minimum post-event grid voltage at WBN of 153kV.

The applicant stated that with dual unit operation, the offsite voltage acceptance criteria for the 

161kV source will be revised as follows to account for the additional load associated with an 

accident in one unit and concurrent shutdown of the second unit: “A maximum pre-event to 

post-event voltage drop of 9kV with a minimum grid of 153kV in “NORMAL” and a 6kV drop with 

a minimum grid voltage of 153kV in “ALTERNATE.”

The potential loss of generation from dual WBN units has not been incorporated into the

contingency planning tools used by TPS as a requirement for evaluating offsite power

capabilities. The applicant has indicated that TPS procedures will be updated in alignment with

WBN procedures for dual unit operation. In a followup email dated February 25, 2015 (ADAMS 

Accession No. ML15063A008), TVA stated the following:

NRC Inspection Planning & Scheduling (IP&S) Item 210 for Watts Bar Unit 2, has 

an open action to incorporate the dual unit operation into the Transmission 

Operation Procedures. Specifically, IP&S Item 210 includes:

“Revision to incorporate WBN dual unit operating requirements is required for 

Transmission Operation procedures TRO-EA-[Environmental Assessment] 

SOP-30.405, “Nuclear Offsite Power Operating Requirements” (Tab 12) and 

TRO-EA-SOP-30.406, “Incorporation of Nuclear Offsite Power NPIRs and 

Accident Loading into Operating System Models” (Tab 13), and WBN procedure 

1-PI-OPS-1-500kV, “Main Control Room Voltage Monitoring” (Tab 15).”

Based on the information provided in Sections 7.3, 7.4, and 7.5 of Enclosure 1 (letter dated

January 30, 2015) and satisfactory closure of IP&S Item 210 for WBN related to TPS and NPG

interface requirements, the NRC staff has concluded that WBN has established adequate 

controls and procedures for notifications when the grid operator identifies an inadequacy in the 

offsite power systems.

In Section 8.2 of Enclosure 1 to the TVA letter dated January 30, 2015, the applicant gave a 

summary of the analysis documented in TVA Calculation WBN-EEB-MST1060029, “Degraded 

Voltage Analysis,” Revision 37, on establishing the DVR dropout voltage analytical limit. To 

ensure that the DVRs protect the plant equipment, an industry recommended approach is 

analyze from the bottom up (lowest voltage level to 6.9kV bus level). For this method, the 

minimum required operating voltage is determined for each safety load, including ancillary 

equipment, based on vendor recommended nameplate values or other approaches supported 

by test and analysis or special procurement specifications (e.g., starting and running for motors 

or minimum voltage requirements for relays, contactors, etc., to operate). The minimum 

required bus voltage is derived by adding voltage drop due to the impedances of 

interconnecting components. An iterative process is used to optimize the minimum required 

voltage and establish the analytical limit. Based on this approach, TVA has established a value 

8-4
of 6555V as the DVR dropout (actuation) voltage analytical limit. The applicant stated that the 

following key elements were considered for establishing the analytical limit:

• The connected medium and low voltage safety-related loads required for accident and 

normal operating conditions are verified to have an acceptable operating (running) 

voltage.

• Each safety-related motor connected to the Class 1E system under normal loading 

conditions as well as safety injection actuation Phase A and safety injection Phase B 

loading conditions is verified to have adequate starting voltage.

• Motor terminal voltage is verified to be sufficient to prevent motor overheating damage.

• Motor control circuits and 120V distribution panel loads are verified to have adequate

voltages.

• Resultant terminal voltages are verified to be adequate to stroke individual 

motor-operated valves (MOV) as per guidance provided in NRC GL 89-10, 

“Safety-Related Motor-Operated Valve Testing and Surveillance.”

The applicant stated that the DVR time delay setpoint is based on evaluation of the following 

factors:

• Short enough duration to provide adequate protection for the safety-related equipment.

• Long enough to avoid trips during starting transients, including the automatic actuation of 

the engineered safety features (ESF) loads.

• The upper limit of the DVR time delay is bounded by the time required by emergency 

diesel generators (EDGs) to come up to rated speed and voltage.

• The lower limit of the DVR time delay exceeds the time required for the safety bus 

voltage to recover from voltage transients resulting from large motor starts.

The applicant stated that to ensure that the analytical value is not exceeded, the nominal trip 

setpoint with allowable values (between ≤6606VAC and ≥6593VAC with a time delay between 

9.73 and 10.2 seconds) were derived after consideration of all applicable errors and tolerances 

in accordance with TVA setpoint methodology and industry standards such as ANSI/ISA 

Standard 67.04.01-2000, “Setpoints for Nuclear Safety-Related Instrumentation.” The NRC 

staff noted that the design basis for WBN is block starting the ESF loads (versus sequencing of 

loads from offsite power source).

Based on the technical evaluations and performance capabilities of the DVR and LVR protection 

schemes, TVA has concluded that the plant analytical and TS trip setpoints (voltage and time 

delays) for these relays are properly derived. A summary of the supporting evaluations for plant 

response during postulated DBA conditions with normal and degraded grid voltage conditions is 

discussed in Section 8.3 of Enclosure 1 to the letter dated January 30, 2015.

TVA evaluated three specific safety bus voltage bands that bound all postulated transmission 

system voltage variations that could impact the plant safety buses in the DVR operating range.

8-5
The first band considered is with plant safety buses operating at minimal allowable grid voltage.

This condition assumes that the offsite power voltage is adequate to support all analyzed DBAs, 

events, conditions, and abnormal operating occurrences as verified by the offsite/station electric 

power system design calculations.

During normal operation, the 6.9kV safeguards buses are maintained between 7010V and 

7135V. The applicant stated that an analysis was performed for the following limiting case:

• Dual unit operation;

• 161kV transmission system at minimum operable voltage of 153kV;

• The 6.9kV safeguards bus voltage is at the lower limit of 7010V pre-accident signal

actuation;

• Worst case loading accident conditions considered; and

• Limiting system alignments (i.e., single station service transformer CSST C or D carrying 

all the safety loads).

The applicant has concluded that the safety-related bus voltage drops below the DVR dropout 

voltage analytical limit (6555V) during the block-start and run of accident loads and recovers 

above the DVR pickup voltage (reset) analytical limit (6681V) before the DVR minimum time 

delay analytical limit (8.5 seconds) is exceeded. During this transient, the safeguards loads 

remain connected to the offsite source and the DVR relay provides adequate protection. Since 

the voltage recovers to an acceptable level after block loading and the safeguards loads are 

available to mitigate the consequences of the event, the requirements of GDC 17 are met.

The second band considered is the 6.9kV safeguards bus voltage degrades to DVR analytical 

limit of 6555V. The NRC staff considers this to imply that the offsite power voltage is below the 

minimum grid voltage <153kV (i.e., sustained degraded voltage).

For this scenario, the applicant considered the 6.9kV safeguards bus voltage at the DVR 

dropout analytical limit of 6555V pre-accident signal actuation. Assuming the transmission 

system does not recover from degraded voltage conditions, the study concluded that the DVR 

will actuate and separate the plant buses from the offsite source after the relay has timed out. 

At this voltage, the offsite power source is not capable of block starting the safety loads. 

However, the offsite source is capable of providing adequate voltage for the safety-related loads 

that may be operating before the event and starting individual safety loads, including 

safety-related MOVs. The applicant has verified that none of the protective devices actuate if 

loads were to start based on the plant design requirements and operating configuration. 

Therefore, all required loads will be available to meet their intended safety functions from the 

onsite power system. After separating from the offsite source, the onsite EDGs are able to 

automatically connect to the safeguards buses and support safe shutdown of the plant in a 

timeframe consistent with the plant’s safety analysis assumptions, thus maintaining compliance 

with GDC 17 requirements.

The third band considered is with 6.9kV safeguards bus voltage sustained between DVR 

analytical limit of 6555V and the minimum operable bus voltage of 7010V.

If the pre-accident signal bus voltage is below the minimum operability limit of 7010V, then the 

offsite power source may not be capable of performing its intended safety function depending 

on the capacity of the grid, transformer and bus alignments, and plant loading. The applicant 

performed a sensitivity analysis (TVA WBN Calculation STUDY-EEB-WBN-12-001, “Sensitivity 

Study of DVR Protection During Motor Starting, Revision 2”) to evaluate combinations of grid 

8-6
conditions and various postulated design-basis events and plant configurations to distinguish 

between types of events that result in safety buses remaining connected to the offsite source or 

types of events that result in transferring safety buses. Based on the results of specific 

analyses documented in Appendices B and H of this calculation, the applicant stated the 

following conclusions:

a. During any motor starting event where voltage drops below the DVR dropout setting and 

then recovers to the reset value, it will recover above the DVR Dropout Analytical Limit 

(6555V) within a maximum 4-second time delay.

b. The time delay is acceptable based on WBN’s accident analysis assuming a 5-second 

time delay for restoration of safety-related bus voltage, when relying on offsite power.

c. For all cases evaluated in the sensitivity study, the offsite power source is capable of 

providing adequate voltage for the safety-related loads that may be operating prior to the 

event and starting safety loads as required automatically by the design including 

safety-related MOVs.

d. The DVR provides adequate protection of the Class 1E loads and prevents inadvertent 

trip of safety loads.

e. If the bus voltage does not recover (due to sustained degraded grid condition) to the 

DVR reset setpoint within the allowable limit of 10.2 seconds, then the DVR will actuate 

and separate the plant buses and permit the safety-related buses to be powered from 

the onsite standby sources in a timeframe consistent with the plant’s safety analysis 

assumptions.

f. The scenarios for which the onsite power source is automatically allowed to power the 

safety busses in time consistent with accident analyses and the requirements of GDC 17 

are maintained.

g. The capability to successfully actuate the accident loads on the onsite power source is 

maintained to assure compliance with GDC 17 requirements.

The NRC staff has not reviewed the detailed calculations and analyses associated with

(1) development of the analytical and allowable limits for DVR setpoints, and (2) establishing the

adequacy of the setpoints for events postulated during DBA conditions or anticipated 

operational occurrences coupled with varying conditions for offsite power sources. In a followup 

email dated February 25, 2015, the applicant stated, “TVA understands and will support 

subsequent inspections of the calculations that support TVA’s Response to Watts Bar Nuclear 

Plant Unit 2 Request for Additional Information Regarding Chapter 8, ‘Electrical Power’ -

Supplemental Safety Evaluation Report (SSER 22, Open Item 30) (TAC No. ME2731).”

The NRC staff relied on the attachments to the applicant’s letter dated January 30, 2015, which

supplied an explanation of WBN, Unit 2, degraded voltage protection scheme. Based on the

overview of the protection scheme supplied by TVA, the NRC staff has concluded that the DVR

analytical limit will protect the safety-related equipment that is operating or required to operate

during degraded grid conditions. The applicant has also stated that in the event of degraded

voltage conditions concurrent with an accident signal, safety-related equipment will have

adequate starting and running voltage at the most limiting safety-related components (such as

motor-operated valves, contactors, solenoid valves or relays), either from the offsite source or 

8-7
from the onsite source after an automatic transfer. Based on these statements, the NRC staff 

has concluded that the DVR protection scheme for WBN, Unit 2, will adequately support

operation of safety-related equipment during design-basis events in accordance with

requirements of GDC 17.

By letter dated January 30, 2015, the applicant has stated that the WBN offsite power sources 

and Class 1E bus undervoltage protection scheme fully comply with NRC BTP PSB-1. The 

NRC staff did not conduct a detailed, line-by-line review and comparison of NRC BTP PSB-1 

and the WBN design as part of its review. However, during the course of its review, the NRC 

staff noted that TVA’s approach for addressing degraded voltage protection deviates from the 

position described in BTP PSB-1 B.1.b. For example, Section B.1.b of BTP PSB-1 states that 

two separate time delays shall be selected for the degraded voltage protection scheme. By

e-mail dated February 25, 2015, TVA stated that TVA’s DVR scheme at WBN, Units 1 and 2,

includes two separate time delay relays, both of which have the same setpoint. The NRC staff 

determined that the existing DVR design at WBN deviates from PSB position B.1.b in that the 

existing design provides only one time delay (10-seconds nominal) and alarms only when 

separation of the preferred power source occurs due to the DVR timing out (i.e., ESF buses 

start initiating diesel start and bus transfer from offsite to onsite power source). Nonetheless, 

the NRC staff has determined that TVA’s degraded voltage protection scheme is acceptable, in 

accordance with the requirements of GDC 17.

The NRC staff reviewed the summary of applicant’s analyses provided in the enclosures with 

TVA letter dated January 30, 2015, to evaluate the adequacy of degraded voltage relay 

setpoints and functional requirements. Supporting TVA controlled documents were not included 

in the review.

TVA has established a minimum grid voltage and a corresponding 6.9 kV safeguards bus 

voltage at or above which the offsite power is capable of supporting plant safe shutdown of 

WBN, Unit 2. The applicant has established a DVR setpoint at or above which all equipment 

required for mitigating the consequences of an accident in one unit and concurrent safe 

shutdown of the other unit is adequately protected from degraded voltage conditions. The 

applicant has stated that in the event of sustained degraded voltage conditions at or above the 

DVR setpoint, the onsite or offsite power source is available in a time commensurate with 

assumptions in the accident analysis. If the safeguards bus voltage degrades to a value below 

the DVR setpoint, the DVR or the loss of voltage relay will separate the offsite sources from the 

plant busses to allow the onsite source to support plant shutdown.

Based on the information provided by the applicant, the NRC staff finds the proposed DVR 

protection scheme provides reasonable assurance that the safety-related equipment will 

perform its intended safety functions during postulated grid conditions as all safety-related 

equipment will have adequate starting and running voltage. Therefore, the NRC staff concludes 

that DVR scheme and offsite power system at WBN, Unit 2, meets the intent of GDC 17 

requirements.

Based on the above evaluation, the NRC staff finds the responses acceptable and, therefore,

considers Open Item 30 to be closed.

8-8
13 CONDUCT OF OPERATIONS

13.3 Emergency Preparedness

13.3.1 Introduction

Section 13.3, “Emergency Preparedness,” of Supplement 22 to NUREG-0847 (SSER 22) 

reported on the NRC staff’s review and determinations regarding the Tennessee Valley 

Authority (TVA) Nuclear Radiological Emergency Plan (REP). The TVA REP consists of two 

portions: (1) a generic REP that is applicable to all TVA-licensed nuclear power reactors and, 

(2) a series of site-specific appendices for each of the TVA nuclear sites. Appendix C addresses 

WBN site-specific information. The generic REP and the WBN-specific Appendix C, hereafter 

referred to in this supplemental safety evaluation report (SSER) as the “WBN-REP,” constitutes 

the “emergency plan” required by Title 10 of the Code of Federal Regulations (CFR) Part

50.34(b)(6)(v), 10 CFR 50.47, and 10 CFR Part 50, Appendix E (hereafter Appendix E).

The content in this SSER updates corresponding content in SSER 22. Otherwise, the content 

of Chapter 13.3 of SSER 22 remains applicable. The two situations that made this update 

necessary are:

• The NRC staff performed the review documented in SSER 22 using Revision 92xx of the

WBN-REP. Although TVA may make changes to its emergency plans for WBN, Unit 1,

and the other TVA reactor sites under the provision of 10 CFR 50.54(q)(3), that change 

process does not apply to WBN, Unit 2, until the issuance of its OL. The NRC identified 

Confirmatory Item 37 to provide the NRC staff with an opportunity to evaluate whether 

the changes made by TVA to the WBN-REP since Revision 92xx affected the bases of 

the NRC staff’s findings in SSER 22. The most recent WBN-REP reviewed by the NRC

staff was Revision 106X. This confirmatory item is closed in Section 13.3.2.18 of this 

supplement.

• On November 23, 2011, the NRC issued a final rulemaking that amended existing rules

and created new rules on emergency preparedness. This rulemaking became effective

on December 23, 2011, with various implementation dates. The rule contained

language that specified that WBN, Unit 2, would meet the requirements as applicable to 

nuclear power reactor licensees. The implementation dates for all but one of the 

amended and new rules have now expired. The one amended rule that the 

implementation date has not expired is Appendix E, § IV.f. The NRC staff’s evaluation of 

this amended rule is discussed in SSER Section 13.3.2.14. Although the 

implementation of these requirements at operating nuclear power reactors is being 

evaluated through the NRC’s Reactor Oversight Process (ROP), the applicant for an OL 

under 10 CFR Part 50 must demonstrate that it has complied with all regulatory 

requirements applicable to the facility prior to the issuance of the license. Accordingly, 

the NRC staff has reviewed Revision 104X of WBN-REP, to evaluate the implementation 

of the new regulatory requirements with regard to WBN, Unit 2. See the following table 

for a list of new requirements implemented in this rulemaking, along with the section in 

this SSER in which the requirement is discussed.

13-1
Table 13.3-1

WBN, Unit 2, Compliance with November 2011 Emergency Preparedness Rulemaking

Rule New 

requirement 

topic

Description/Discussion SSER Section

10 CFR 

50.54(q)

Amended 

Emergency 

Plan Change 

Process

These requirements will become a 

condition of the license if an OL is issued 

for WBN, Unit 2.

N/A

10 CFR 50, 

Appendix E, 

§ IV

Evacuation 

Time Estimate 

(ETE) 

Updating

This rule requires licensees to (1) submit 

an evacuation time estimate (ete) update 

by December 22, 2012 and (2) Use the 

ETE results in establishing evacuation 

strategies.

13.3.2.10

13.3.2.17

10 CFR 50, 

Appendix E, 

§ IV.A.7

Licensee 

Coordination

with Offsite 

Response 

Organizations

This rule requires licensees to identify 

and describe the assistance expected 

from appropriate State, local, and 

Federal agencies, including hostile action 

at the site.

13.3.2.3

10 CFR 50, 

Appendix E, 

§ IV.A.9

On-Shift 

Staffing 

Analysis

This rule requires licensees to perform a 

detailed analysis demonstrating 

adequate on-shift personnel. 

13.3.2.2

Appendix E, 

§ IV.B.1

Emergency 

Action Levels 

for Hostile 

Action

This rule was a codification of a previous 

order. The WBN, Unit 2, EAL scheme 

was reviewed as described in SSER 22, 

Section13.3.2.4.

13.3.2.4

10 CFR 50, 

Appendix E. 

§ IV.C.2

Emergency 

Declaration 

Timeliness

This rule requires the licensee to 

establish and maintain the capability to 

assess, classify, and declare an 

emergency condition within 15 minutes.

13.3.2.4

10 CFR 50, 

Appendix E

§ IV.D.3

Alert and 

Notification 

Backup Means

This rule requires the licensee to provide 

a backup public alerting means.

13.3.2.5

10 CFR 50, 

Appendix E

§ IV.E.8.b

Emergency 

Operations 

Facility –

Performance 

Based 

Approach

This rule is not applicable to TVA as the 

NRC explicitly approved TVA’s Central 

Emergency Control Center Emergency 

Operations Facility (EOF). This rule

could be applicable if TVA should seek to 

relocate or modify the approved facility. 

N/A

10 CFR 50, 

Appendix E §

IV.E.8.c

Emergency 

Operations 

Facility –

Performance 

Based 

Approach

This rule requires the licensee EOF to 

have certain capabilities. The exclusion 

identified above does not apply. 

13.3.2.8

13-2
Rule New 

requirement 

topic

Description/Discussion SSER Section

10 CFR 50, 

Appendix E, 

§ IV.E.8.d

Emergency 

Response 

Organization 

Augmentation 

and Alternative 

Facility

This rule requires the licensee to 

establish an alternative facility that would 

be accessible even if the site were under 

threat or experience hostile action. Part 

of this amended rule is a codification of a 

previous order. The additional response 

capabilities identified in the rule were

implemented by December 23, 2014. 

13.3.2.8

10 CFR 50, 

Appendix E, 

§ IV.f

Challenging 

Drills and 

Exercises

This rule requires the licensee to modify 

its EP drill and exercise program to make 

them more effective. Some changes 

were effective on December 23, 2011. 

The licensee is required to conduct a 

hostile action based (HAB) biennial 

exercise by December 23, 2015. 

The remaining requirements are indexed 

to the 8-year exercise cycle that 

commences with the HAB. TVA has 

modified the generic REP to reflect these 

changes once the HAB is conducted. 

13.3.2.14

10 CFR 50, 

Appendix E, 

§ IV.I

Protective 

Actions for 

Onsite 

Personnel

This rule requires the licensee to have a 

range of protective actions to protect 

onsite personnel during a hostile action.

13.3.2.10

13.3.1.3 Regulatory Basis

In addition to the regulatory bases identified in Section 13.3.1.3 of SSER 22, the following 

regulations and regulatory guidance were used in the review described in this supplement:

• “Enhancements to Emergency Preparedness Regulations,” Final Rule to 

10 CFR Parts 50 and 52,” Volume 26 Federal Register 72560 – 72600

• “Emergency Preparedness and Response Actions for Security-Based Events,” NRC 

Bulletin 2005-02 (ADAMS Accession No. ML051740058) 

• “Interim Staff Guidance: Emergency Planning for Nuclear Power Plants,” NSIR/DPRISG-01 (hereafter “ISG”) (ADAMS Accession No. ML113010523)

• “Criteria for Development of Evacuation Time Estimate Studies,” NUREG/CR-7002

(ADAMS Accession No. ML113010515) 

• "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and 

Preparedness in Support of Nuclear Power Plants - Guidance for Protective Action 

Strategies," NUREG-0654 (ADAMS Accession No. ML113010596)

• “Assessment of On-Shift Emergency Response Organization Staffing and Capabilities,” 

Nuclear Energy Institute NEI-10-5, Revision 0 (ADAMS Accession No. ML111751698)

13-3
13.3.2 Evaluation of the Emergency Plan

13.3.2.2 Onsite Emergency Organization

Regulatory Basis: 10 CFR 50.47(b)(2) requires that on-shift facility licensee responsibilities for 

emergency response are unambiguously defined, adequate staffing to provide initial facility 

accident response in key functional areas is maintained at all times, timely augmentation of 

response capabilities is available, and the interfaces among various onsite response activities 

and offsite support and response activities are specified. Supporting requirements are provided 

in Appendix E § IV.A to 10 CFR 50.

Subsequent to the issuance of SSER 22, the NRC issued a new regulation, Appendix E § IV.A.9

to 10 CFR 50 which requires nuclear power reactor licensees do a detailed analysis by 

December 24, 2012 demonstrating that on-shift personnel can perform their assigned 

emergency plan functions is a timely manner in the presence of other assigned responsibilities. 

The ISG gives guidance on complying with the new requirement.

Technical Evaluation: In Section 13.3.2.2 of SSER 22, the NRC staff described its evaluation of 

the WBN-REP onsite emergency organization and its finding that the planning standard 

10 CFR 50.47(b)(2) was met for WBN, Units 1 and 2. 

TVA developed the on-shift staffing analysis (OSA) Revision 1 for WBN, Unit 1, but was not 

required to submit the WBN, Unit 1, OSA for review, as the NRC staff will evaluate the OSAs of 

existing licensees as part of routine inspection activities. The WBN, Unit 1, OSA cannot serve 

as a reference basis for WBN, Unit 2, licensing, as it did not address the additional WBN, Unit 2,

staffing, and the NRC staff did not previously approve the WBN, Unit 1, OSA. TVA submitted 

Revision 2 of the OSA for WBN, Units 1 and 2, on September 12, 2014 (ADAMS Accession No. 

ML15205A111). This version includes the WBN Unit 2, on-shift staffing in the required analyses 

for the series of potential events that could occur at either unit.1

 

The NRC staff reviewed the WBN OSA, Revision 2, against the guidance of the ISG. TVA used 

the analysis methodology in NEI-10-05, which the ISG identified as an acceptable approach. 

The NRC staff confirmed that the staffing levels assumed in the OSA were consistent with those 

identified in Revision 104X of the emergency plan. The NRC staff reviewed TVA’s identification 

of events and conditions analyzed and determined it to be reasonable and generally consistent 

with the guidance in the ISG. Events and conditions not included were appropriately justified in 

the analysis. The NRC staff reviewed the individual scenario analyses, the task overlap 

summary, and the time-motion analyses for reasonableness and consistency with the guidance. 

Because of the design and operational fidelity between the two units, there are no unit-specific 

events. However, the NRC staff identified differences between the OSA discussion and in the 

FSAR, which is the licensing basis upon which the OSA is required to be based. By email dated

October 20, 2014 (ADAMS Accession No. ML14293A227), the NRC staff issued request for 

additional information (RAI) 28.a-d to resolve these differences. In its December 15, 2014

(ADAMS Accession No. ML15205A123), response, TVA explained the observed differences 

with the FSAR and responded to the NRC staff’s other requests. As part of this response, TVA 

submitted Revision 3 of the OSA. The NRC staff reviewed the changes made to the OSA and 

1 Note that this does not address staffing for events occurring simultaneously at both units. This 

additional staffing is a Fukushima recommendation and is being addressed, along with the other 

Fukushima lessons learned, in separate SERs. 

13-4

 
evaluated the applicant’s other responses against the applicable guidance. None of the 

changes made affected the NRC staff’s conclusions of the OSA. Based upon this review and 

the fidelity between WBN, Units 1 and 2, the NRC staff finds that TVA has met the requirement 

of Appendix E § IV.A.9 to 10 CFR 50 for WBN.

In its review of Revision 103 of the emergency plan, the NRC staff identified an apparent 

inconsistency between the Emergency Response Organization (ERO) augmentation time in the 

generic REP and that in Appendix C. The NRC staff issued RAI 24.c on June 16, 2014 (ADAMS 

Accession No. ML14168A001). In its August 29, 2014 response (ADAMS Accession No. 

ML15205A130) TVA stated that it would include the acceptable Appendix C language into the 

emergency plan. The NRC staff confirmed that TVA incorporated this change in Revision 104X of 

the emergency plan.

Conclusion: The NRC staff concludes that the WBN-REP meets the requirements of 10 CFR 

50.47(b)(2) and § IV.A of Appendix E to 10 CFR Part 50 with regard to onsite emergency 

response organization. The NRC staff bases its conclusion upon (1) the approval of the WBNREP for WBN, Units 1 and 2, as described in SSER 22, (2) the NRC staff’s review described 

above, (3) the OSA demonstration of adequate on-shift staffing, and (4) the design and 

operational fidelity between the two units.

13.3.2.3 Emergency Response Support and Resources

Regulatory Basis: 10 CFR 50.47(b)(3) requires that arrangements for requesting assistance 

and effectively using resources have been made, arrangements to accommodate various State 

and local staff at the licensee’s near-site emergency operations facility (EOF) have been made, 

and other organizations capable of augmenting the planned response have been identified. 

Supporting requirements are provided in Appendix E § IV.A to 10 CFR 50.

Subsequent to the issuance of SSER 22, the NRC amended Appendix E § IV.A.7 to 10 CFR 50

to require that the emergency plan include an identification and description of the assistance 

expected from appropriate State, local, and Federal agencies with responsibilities for coping 

with emergencies, including hostile action at the site by June 23, 2014. The ISG provides 

guidance on complying with the amended requirement.

Technical Evaluation: In Section 13.3.2.3 of SSER 22, the NRC staff described its evaluation of 

the arrangements for emergency response support and resources as described in the WBNREP and its finding that the planning standard in 10 CFR 50.47(b)(3) was met for WBN, Units 1

and 2.

In reviewing Revisions 103 and 104X of the WBN-REP, the NRC staff determined that 

additional information was required to determine whether TVA had adequately complied with 

Appendix E § V.A.7 to 10 CFR 50. Although WBN-REP § 2.5, § 2.6, and Table 2-1 identify 

offsite emergency support and resources, and WBN-REP § 16.5 provides a listing of letters of 

agreement for these resources, the plan is silent regarding the commitment of those offsite 

resources to provide the expected support and resources during hostile action events that is the 

primary objective of the amended rule. The NRC staff issued RAI 25.a on June 16, 2014. In its 

August 29, 2014, response, TVA stated that descriptions of provisions for addressing hostile 

actions against the plant is maintained on file with site security, with specific details in 

referenced offsite plans, agreement letters, and memorandum of understanding. The NRC staff 

evaluated TVA’s arrangements during an onsite inspection. The results of the NRC staff’s 

inspection is documented in Inspection Report 05000391/2015605.

13-5
Conclusion: The NRC staff concludes that the WBN-REPwill meet the requirements of 10 CFR 

50.47(b)(3) and § IV.A of Appendix E to 10 CFR Part 50 with regard to arrangements for 

emergency response support and resources, including hostile actions. The NRC staff bases its 

conclusion upon (1) the approval of the WBN-REP for WBN, Units 1 and 2, as described in 

SSER-22, (2) the NRC staff’s review described above, (3) TVA’s demonstrated performance in 

maintaining emergency preparedness at Unit 1, and (4) the design and operational fidelity 

between the two units.

13.3.2.4 Emergency Classification System

Regulatory Basis: 10 CFR 50.47(b)(4) requires that a standard emergency classification and 

action level scheme, the bases of which include facility system and effluent parameters, is in 

use by the nuclear facility licensee, and State and local response plans call for reliance on 

information provided by the facility licensees for determinations of minimum initial offsite 

response measures. Supporting requirements are provided in Appendix E § IV.B and § IV.C to 

10 CFR 50.

Subsequent to the issuance of SSER 22, the NRC amended Appendix E § IV.B to 10 CFR 50 to

require licensees to consider hostile action events in establishing emergency action level (EAL) 

schemes by June 20, 2012. This amended requirement codifies a corresponding requirement in 

NRC Bulletin (BL) 2005-02, “Emergency Preparedness and Response Actions for 

Security-Based Events” (ADAMS Accession No. ML051740058), previously addressed at WBN, 

Unit 1. The bulletin provided guidance on the EAL schemes.

Subsequent to the issuance of SSER 22, the NRC added a new requirement, Appendix E 

§ IV.C.2 to 10 CFR 50 to require that licensees, by June 20, 2012, establish and maintain the 

capability to assess, classify, and declare an emergency condition within 15 minutes after the 

availability of indications to plant operators that an emergency action level has been exceeded 

and promptly declare the emergency condition as soon as possible following identification of the 

appropriate emergency classification level. The ISG provides guidance on complying with the 

new requirements.

Technical Evaluation: In § 13.3.2.4 of SSER-22, the NRC staff described its evaluation of the

WBN-REP emergency classification scheme and its finding that the planning standard in 

10 CFR 50.47(b)(4) was met for Units 1 and 2. As discussed therein, TVA implemented the 

security EALs identified in the NRC-endorsed Revision 5 to NEI-99-01 for Unit 1. By letter 

dated December 18, 2006 (ADAMS Accession No. ML063170443), the NRC staff notified TVA 

that its response to BL 2005-02 for all three sites (Browns Ferry Nuclear Plant, Sequoyah 

Nuclear Plant, and WBN) was acceptable, and no further action was required at that time. The 

WBN, Unit 2, security EALs are identical to those approved for WBN, Unit 1. Accordingly, given 

the fidelity between the two units, TVA complied with the amended Appendix E § IV.B to 10 

CFR 50.

In reviewing Revision 104X of the WBN-REP, the NRC staff identified that Section 4.2.C 

provided a commitment to maintain the required classification timeliness capability. Section 

3.1.C of WBN-EPIP-1, “Emergency Plan Classification Logic” (ADAMS Accession No. 

ML15205A136), requires the Shift Manager/Station Emergency Director to assess, classify, and 

declare an emergency condition within 15 minutes after information is first available to plant 

operators to recognize that an exceeded EAL and to make the declaration promptly upon 

identification of the appropriate emergency classification level. This procedure provides 

13-6
guidance regarding the initiation and termination of the 15-minute criterion, the definition of 

“plant operator” and “promptly,” and the role of validation or confirmation of indications and 

reports. This guidance is consistent with the guidance in the ISG and is, therefore, acceptable. 

On April 1, 2015 (ADAMS Accession No. ML15205A226), TVA submitted Revision 106X of 

Appendix C of the WBN-REP. This revision contained technical and editorial changes to the 

EAL thresholds associated with certain WBN, Unit 1, effluent radiation monitors installed to 

replace the existing Unit 1, monitors. TVA also changed the high river level EAL thresholds for 

consistency with an NRC-approved license amendment for WBN, Unit 1, related to a hydrology 

analysis. These river water level EAL changes will apply to WBN, Unit 2, on issuance of the 

WBN, Unit 2, license, as both units share the same river reservoir and the same reference 

licensing basis. Accordingly, the changes in Revision 106X of WBN-REP do not affect the NRC 

staff’s conclusions drawn in Section 13.3 of SSER 22 for WBN, Unit 2. 

Conclusion: The NRC staff concludes that the WBN-REP meets the requirements of 

10 CFR 50.47(b)(4) and § IV.B and § IV.C of Appendix E to 10 CFR Part 50 with regard to the 

emergency classification and action level scheme. The NRC staff bases its conclusion upon (1) 

the approval of the WBN-REP for Units 1 and 2, as described in SSER 22, (2) the NRC staff’s 

review described above, (3) TVA’s demonstrated performance in maintaining emergency 

preparedness at WBN, Unit 1, and (4) the design and operational fidelity between the two units. 

13.3.2.5 Notification Methods and Procedures

Regulatory Basis: 10 CFR 50.47(b)(5) requires that procedures are established for notification 

by the licensee of State and local response organizations and for notification of emergency 

personnel by all response organizations; the content of initial and followup messages to 

response organizations and the public has been established; and means to provide early 

notification and clear instructions to the populace within the plume exposure pathway 

Emergency Planning Zone have been established. Supporting requirements are provided in 

Appendix E § IV.D to 10 CFR 50.

Subsequent to the issuance of SSER 22, the NRC staff amended Appendix E § IV.D.3 to

10 CFR 50 add a new requirement that licensees demonstrate that an administrative and 

physical means for a backup method of public alerting exists for use in the event the primary 

method of alerting and notification is unavailable. The rule at 10 CFR Part 50 Appendix E, 

§IV.D.4 to 10 CFR 50 established different implementation dates dependent on the status of 

such a capability at a given site. For WBN the date was December 24, 2012. Under the 

“Memorandum of Understanding between NRC and the Federal Emergency Management 

Agency (FEMA) Related to Radiological Emergency Planning and Preparedness” (44 CFR 

Part 353 Appendix A), the NRC relies upon FEMA’s findings and determinations regarding 

public alerting and notification. The ISG provides guidance on complying with the new 

requirements.

Technical Evaluation: In Section 13.3.2.5 of SSER 22, the NRC staff described its evaluation of 

the notification methods and procedures in the WBN-REP and its finding that the planning 

standard 10 CFR 50.47(b)(5) was met for WBN, Units 1 and 2. 

Subsequent to the issuance of SSER 22, TVA modified the manner in which external 

notifications (e.g., to Federal and State officials) would be made. This change has the Shift 

Manager/Station Emergency Director at the affected unit main control room make all initial 

notifications to the State and the NRC for all emergency classifications rather than by the TVA 

13-7
Operations Duty Specialist (ODS) as was stated in SSER 22. As before, the ODS would 

continue to make other external notifications, including notification of emergency personnel. 

The NRC staff finds this revision to be acceptable, as TVA retains the capability to make the 

required notifications within the performance criterion established in § IV.D.3 to Appendix E and 

to activate the ERO in a manner that supports timely activation of the emergency response 

facilities. 

Subsequent to the issuance of SSER 22, TVA replaced all of the WBN alert and notification 

system sirens. FEMA’s letter dated August 28, 2014 (ADAMS Accession No. ML14247A452),

described the upgraded system. The sirens have backup batteries to allow siren operation if 

local AC power distribution is lost. The Tennessee Emergency Management Agency activates 

the sirens by radio from the State Emergency Operations Center. Backup activation capability 

is located in the Rhea County 911 Center. TVA supplemented the sirens by providing schools 

and other institutions within the emergency planning zone (EPZ) with tone alert radios on the 

frequencies of the National Oceanic and Atmospheric Administration Weather Radio All 

Hazards network. In its August 28, 2014, letter, FEMA advised the NRC that the upgraded alert 

and notification system would continue to comply with program requirements. FEMA also 

stated that the Tennessee Multi-Jurisdiction REP and the procedures of the affected local 

counties established an acceptable backup alerting system comprised of route alerting. Based 

upon its review of the FEMA findings and determinations, the NRC staff finds the updated alert 

and notification system and the backup alerting means acceptable.

Conclusion: The NRC staff concludes that the WBN-REP meets the requirements of 

10 CFR 50.47(b)(5) and § IV.D of Appendix E to 10 CFR Part 50 with regard to notification 

means and procedures. The NRC staff bases its conclusion upon (1) the approval of the 

WBN-REP for WBN, Units 1 and 2, as described in SSER 22, (2) the NRC staff’s review 

described above, (3) TVA’s demonstrated performance in maintaining emergency 

preparedness at WBN, Unit 1, (4) FEMA’s approval of the primary and backup alerting means, 

and (5) the design and operational fidelity between the two units.

13.3.2.8 Emergency Facilities and Equipment

Regulatory Basis: 10 CFR 50.47(b)(8) requires that adequate emergency facilities and 

equipment to support the emergency response are provided and maintained. Supporting 

requirements are provided in Appendix E § IV.E to 10 CFR 50.

Subsequent to the issuance of SSER 22, the NRC amended Appendix E § IV.E to 10 CFR 50 to 

add two new requirements. Section IV.E.8.c to 10 CFR 50 Appendix E requires that by 

June 20, 2012, the licensee have an emergency operations facility that has the capabilities 

specified in the rule, including for each reactor on a nuclear power reactor site and for each 

nuclear power reactor site that the facility serves. Section IV.E.8.d to 10 CFR 50 Appendix E 

requires licensees to have an alternative facility (or facilities) that would be accessible, even if 

the site were under threat of or experiencing a hostile action. The first phase, a capability for 

staging ERO personnel, was required by June 20, 2012. The second phase, additional 

capabilities, is due by December 23, 2014. The ISG provides guidance on complying with the 

new requirements.

Technical Evaluation: In Section 13.3.2.8 of SSER 22, the NRC staff described its evaluation of 

the emergency facilities and equipment in the WBN-REP and its finding that the planning 

standard 10 CFR 50.47(b)(8) was met for WBN, Units 1 and 2. 

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In reviewing Revision 103 of the WBN-REP, the NRC staff determined that additional 

information was required for the NRC staff to determine whether TVA had adequately complied 

with Appendix E § IV.E.8.c and § IV.E.8.d to 10 CFR 50. The NRC staff issued RAIs 25.c and 

25.d to request this information on June 16, 2014. In its August 29, 2014, response to RAI 25.c, 

TVA stated that it had completed staffing capabilities and physical facility modifications to the 

Central Emergency Control Center (CECC) to meet the new EOF performance requirements. 

Although TVA has previously used a team-based ERO augmentation approach, it has adopted 

an approach in which all personnel assigned to the minimum activation CECC positions are 

called out to respond, enhancing the availability of responders. Several changes have been 

made to § 3.0 of CECC EPIP-1, “Central Emergency Control Center Operations” (ADAMS 

Accession No. ML15205A139). This emergency preparedness implementation procedure 

(EPIP) directs the CECC Director to staff additional ERO positions as deemed necessary for 

events that warrant extra staffing (e.g., a multi-unit or multi-site event). The EPIP identifies 

several specific ERO positions that the CECC Director is to consider for augmentation. The 

CECC Director may also request assistance from other organizations within TVA. TVA 

expanded the CECC layout to provide working locations for additional Assistant CECC 

Directors, Radiological Assessment Coordinators, Dose Assessors, and Environs Assessors for 

additional affected sites. The response also describes modifications made to the Web 

Emergency Operations Center (WebEOCTM) and the TVA Enterprise Emergency Notification 

System (TEENS) with color-coordinated site-specific capability for display. The NRC staff finds 

that the existing CECC, modified as described, would meet Appendix E § IV.E.8.c to 10 CFR 

50. The NRC staff evaluated the acceptability of TVA’s CECC during an onsite inspection. The 

results of the NRC staff’s inspection is documented in Inspection Report 05000391/2015605.

In its August 29, 2014, response to RAI 25.d, TVA identified that it had relocated the Alternate 

Facility for WBN to meet the new requirements and that the new facility currently meets the 

June 20, 2012, requirements of § IV.E.8.d to Appendix E of 10 CFR Part 50. TVA stated that 

this facility would satisfy the new requirements prior to December 3, 2014. TVA revised the 

ERO augmentation call out messages to include staffing at the new alternative facility. The 

NRC staff evaluated the acceptability of WBN’s Alternative Facility modifications during an 

onsite inspection. The results of the NRC staff’s inspection is documented in Inspection Report 

05000391/2015605. The NRC staff finds that the new WBN alternative facility, modified as 

described, meets the requirements of Appendix E § IV.E.8.d. 

Conclusion: The NRC staff concludes the WBN-REP meets the requirements of 10 CFR 

50.47(b)(8) and § IV.E of Appendix E to 10 CFR Part 50 with regard to emergency facilities and 

equipment. The NRC staff bases its conclusion upon (1) the approval of the WBN-REP for 

WBN, Units 1 and 2, as described in Supplement 22 to the SER, (2) the NRC staff’s review 

described above, (3) TVA’s demonstrated performance in maintaining emergency preparedness 

at WBN, Unit 1, and (4) the design and operational fidelity between the two units.

13.3.2.10 Protective Response

Regulatory Basis: 10 CFR 50.47(b)(10) requires that a range of protective actions has been 

developed for the plume exposure pathway EPZ for emergency workers and the public. In 

developing this range of actions, consideration has been given to evacuation, sheltering, and, 

as a supplement to these, the prophylactic use of potassium iodide, as appropriate. Evacuation 

time estimates have been developed by applicants and licensees. Licensees shall update the 

evacuation time estimates on a periodic basis. Guidelines for the choice of protective actions 

during an emergency, consistent with Federal guidance, are developed and in place, and 

protective actions for the ingestion exposure pathway EPZ appropriate to the locale have been 

developed. Supporting requirements are provided in Appendix E §IV and § IV.I to 10 CFR 50.

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Subsequent to the issuance of SSER 22, a new regulation, Appendix E § IV.I to 10 CFR 50,

was issued to codify actions implemented by licensees, including WBN, Unit 1, in response to 

BL 2005-02. This new regulation required licensees provide, by June 20, 2012, a range of 

protective actions to protect onsite personnel during hostile action to ensure that continued 

ability of the licensee to safely shutdown the reactor and perform the functions of the licensee’s 

emergency plan. BL 2005-02 and the ISG provide guidance on complying with the new 

requirement.

Subsequent to the issuance of SSER 22, the NRC amended 10 CFR 50.47(b)(10) and issued 

new regulations in 10 CFR 50, Appendix E § IV with regard to evacuation time estimates (ETE) 

and the use of those estimates. Section IV.2 to 10 CFR 50 Appendix E requires licensees to 

provide an ETE analysis. Section IV.3 requires licensees to use the ETE in the formulation of 

protective action recommendations and to provide the ETE to State and local governmental 

authorities. Section IV.4 to 10 CFR 50 Appendix E requires licensees to develop an ETE within 

365 days of the later of the date of the most recent decennial census data from the U.S. Census 

Bureau, or by December 23, 2011. Sections IV.5 and IV.6 to 10 CFR 50 Appendix E require 

licensees to assess changes in population trends and update the ETE as necessary between 

decennial censuses. The ISG, NUREG/CR-7002, and Supplement 3 to NUREG-0654 provide 

guidance on complying with these new requirements.

Technical Evaluation: In Section 13.3.2.10 of SSER 22, the NRC staff described its evaluation 

of the range of protective measures in the WBN-REP and its finding that the planning standard

10 CFR 50.47(b)(10) was met for WBN. 

With regard to Appendix E § IV.I to 10 CFR 50, the NRC staff reviewed WBN-REP Revision 

104X and related EPIPs and determined that TVA had provided for a range of onsite protective 

actions for hostile action events. TVA incorporated these actions in multiple EPIPs and in other 

station procedures. WBN-REP Section 10.2, “Onsite Protective Actions for Hostile Action 

Events,” contains a commitment to provide a range of onsite protective actions for hostile action 

events. The four EPIPs that address the response to emergencies at each emergency 

classification level have provisions to delay assembly, accountability, and site evacuation for 

events involving an on-site security risk as determined by the station emergency director or 

nuclear security. Above the alert level, these EPIPs also block personnel notifications using the 

site public address systems. Similar provisions are included the EPIP for personnel 

accountability and evacuation. TVA satisfactorily demonstrated these protection actions during 

the hostile action based (HAB) exercises already conducted at the Sequoyah and Browns Ferry 

sites, and scheduled to be conducted at WBN in the fall of 2015. Based on the above review, 

the NRC staff has determined that TVA has complied with Appendix E § IV at WBN.

By letter dated December 18, 2012 (ADAMS Accession No. ML123620581), TVA submitted the 

updated ETEs for the reactors for which it is holder of OLs, including WBN, Unit 1, as required 

by Appendix E § IV.4 to 10 CFR 50. TVA supplemented this submittal by letters dated March 4, 

2013 (ADAMS Accession No. ML13070A024) and August 16, 2013 (ADAMS Accession No. 

ML13234A356). The NRC staff performed a review of the submitted WBN, Unit 1, ETE and 

concluded that the updated ETE was complete in accordance with NUREG/CR-7002. The NRC 

staff documented its review of the updated ETE in WBN, Unit 1, Inspection Report 

05000390/2013005 (ADAMS Accession No. ML14038A351). 

By letter dated June 5, 2014 (ADAMS Accession No. ML14276A088), TVA submitted an 

addendum to the WBN ETE on both WBN, Unit 1 and Unit 2, dockets. This submittal addresses 

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changes to the population in the evacuation zone, the impact of peak construction traffic for 

WBN, Unit 2, in 2014, and the dual unit normal operating staff during the first operating year of 

WBN, Unit 2. TVA concluded that the longest ETE value did not increase by more than 

25 percent, or 30 minutes, as specified in Appendix E § IV.6 to 10 CFR 50. The 2014 ETE used 

the same general assumptions, data sources, and methodologies used in the preparation of the 

2013 ETE, which had been found to be complete, with the following exceptions: 

• The 2013 ETE only considered the worker population associated with normal WBN, 

Unit 1, operations. The 2014 ETE included the large working population associated with 

the WBN, Unit 2, construction and evaluated the dual unit population once WBN, Unit 2,

goes into commercial service.

• The 2014 ETE models an increase in the projected permanent population from 22,569 to 

22,851 in 2014 and 22,983 in 2016. 

• The only change in transient population is associated with the WBN, Unit 2, construction 

force now included in the analysis.

• The offsite emergency response plan remained substantially the same. With the 

exception of changes associated with WBN traffic, the 2014 ETE used the same road 

network used in the preparation of the 2013 ETE.

Based on the above, the design and operation fidelity between the two units, the role of WBN, 

Unit 1, as the reference design basis, and the identical plume exposure EPZs, the NRC staff 

finds that TVA has demonstrated compliance with the new and amended ETE requirements for 

WBN. Since the ETE is to be periodically updated, the objective of the NRC staff’s review was 

to verify consistent application of the ETE guidance.

In response to Appendix E § IV.3 to 10 CFR 50, TVA replaced the protective action 

recommendation logic flowcharts that had been developed based on NUREG-0654, 

Supplement 3 guidance. These are Figure 10-1 and Figure 10-2 of Revision 104X of the 

generic portion of the WBN-REP. These charts address the three sites for which TVA holds a

license. These charts, while generic to all sites contain site-specific decision criteria based on 

the site-specific EALs and ETEs. WBN-EPIP-5, “General Emergency,” includes facsimiles of 

these charts. The NRC staff reviewed these replacement charts against the guidance in 

Supplement 3 to NUREG-0654. The NRC staff found the charts to be consistent with that 

guidance but identified a concern regarding the alerting of members of the public within the EPZ 

not addressed by the applicant’s protective action recommendation. By email dated October 

20, 2014, the NRC staff issued RAI 27 regarding this concern. In its response dated December 

15, 2014, TVA submitted an updated WBN EPIP-5, “General Emergency.” The NRC staff found 

that content in the EPIP resolved the concern, and found that TVA has complied with Appendix 

E § IV.3 to 10 CFR 50 for WBN Units 1 and 2.

Conclusion: The NRC staff concludes the WBN-REP meets the requirements of 10 CFR 

50.47(b)(10) and § IV of Appendix E to 10 CFR Part 50 with regard to protective response. The 

NRC staff bases its conclusion upon (1) the approval of the WBN-REP for WBN, Units 1 and 2,

as described in SSER-22, (2) the NRC staff’s review described above, (3) TVA’s demonstrated 

performance in maintaining emergency preparedness at WBN, Unit 1, and (4) the design and 

operational fidelity between the two units.

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13.3.2.14 Exercises and Drills

Regulatory Basis: 10 CFR 50.47(b)(14) requires that periodic exercises be conducted to 

evaluate major portions of emergency response capabilities, that periodic drills be conducted to 

develop and maintain key skills, and deficiencies identified as a result of exercises or drills be 

corrected. Appendix E § IV.F to 10 CFR Part 50 provides supporting requirements.

Subsequent to the issuance of SSER 22, the NRC issued amended Appendix E § IV.F.2 to 

10 CFR 50 add new requirements for drills and exercises. Appendix E, § IV.F.2.a to 10 CFR 50 

was amended to require licensees to submit biennial exercise scenarios for prior NRC review. 

Appendix E, § IV.F.2.b to 10 CFR 50 was amended to provide an expanded list of principal 

functional areas of emergency response to be exercised. Appendix E, § IV.F.2.g to 10 CFR 50 

was amended to require licensees to correct any weaknesses identified during exercises, drills, 

or training that provide performance-enhancing opportunities. Appendix E, § IV.F.2.i

to 10 CFR 50, a new requirement, requires licensees to use drill and exercise scenarios that 

minimize preconditioning of players and that include a wide spectrum of events, including hostile 

actions. Appendix E, § IV.F.2.j, to 10 CFR 50 has two parts. The first part established 

standards for the conduct of exercises with regard to providing varied opportunities for 

demonstrating key skills necessary to implement the principal functional areas of emergency 

response. TVA was required to implement the above requirements by December 23, 2011. 

The second part of Appendix E, § IV.F.2.j to 10 CFR 50 identified scenario elements, including 

hostile action, that are to be exercised over an 8-year exercise cycle. The rule requires the 

conduct of the first HAB exercise before December 31, 2015, and that the first 8-year cycle 

commences with the completion of the first HAB exercise. The ISG provides guidance on 

complying with these new requirements.

Technical Evaluation: In Section 13.3.2.14 of SSER 22, the NRC staff described its evaluation 

of the exercises and drill program described in the WBN-REP and its finding that the planning 

standard 10 CFR 50.47(b)(14) and the requirements of 10 CFR Part 50 Appendix E § IV.F was 

met for WBN, Units 1 and 2. 

Appendix E § I.6 to 10 CFR 50 states that WBN, Unit 2, would meet the requirements of the 

final rule as applicable to operating nuclear power licensees (e.g., WBN, Unit 1). The intent of 

this language was to allow for the licensing of WBN, Unit 2, without the need to meet the 

regulations that WBN, Unit 1, had not yet been required to meet. Accordingly, TVA does not 

need to comply with the 8-year exercise cycle requirements until the date of the first HAB 

exercise or December 31, 2015, whichever is sooner. TVA has scheduled a biennial exercise 

with a HAB scenario at WBN in the fall of 2015. TVA’s drill and exercise program for its sites is 

described in Section 14.0 of the generic REP. The NRC staff found insufficient information 

regarding the methods that TVA had and will implement to meet the new requirements of 

Appendix E § IV.F.2 to 10 CFR 50 and on October 6, 2014 issued RAI 26 (ADAMS Accession 

No. ML14279A251). In its response dated November 14, 2014, TVA submitted administrative 

procedure EPDP-3, “Emergency Plan Exercises and Preparedness Drills” (ADAMS Accession 

No. ML15205A144). This procedure describes TVA’s methods for developing and conducting 

drills and exercises. The NRC staff reviewed the procedure and determined that TVA’s drill and 

exercise program as described in Section 14.0 of the generic REP and EPDP-3 was consistent 

with the ISG and that the WBN-REP meets the amended and new requirements of Appendix E 

§ IV.F.2 to 10 CFR 50.

Conclusion: The NRC staff concludes the WBN-REP meets the requirements of 10 CFR 

50.47(b)(14) and § IV.F.2 of Appendix E to 10 CFR Part 50 with regard to the exercise and drill 

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program. The NRC staff bases its conclusion upon (1) the approval of the WBN-REP for WBN, 

Units 1 and 2, as described in SSER 22, (2) the NRC staff’s review described above, (3) TVA’s 

demonstrated performance in maintaining emergency preparedness at the existing WBN, Unit 

1, and (4) the design and operational fidelity between the two units.

13.3.2.15 Radiological Emergency Response Training

The NRC staff’s review of this planning standards and its findings was described in Section

13.3.2.15 of SSER 22. This planning standard was not affected by the regulations issued 

subsequent to SSER 22.

13.3.2.16 Responsibility for the Planning Effort; Development, Periodic Review, and Distribution 

 of Emergency Plans

The NRC staff’s review of this planning standards and its findings was described in 

Section 13.3.2.16 of SSER 22. This planning standard was not affected by the regulations 

issued subsequent to SSER 22.

13.3.2.17 Evaluation of Offsite Emergency Preparedness

Note: The discussion and staff’s findings on the evacuation time estimates were relocated to 

Section 13.3.2.10 of this supplement and are updated there.

Regulatory Basis: 

Based on the regulatory requirements of 10 CFR 50.47(b) and Appendix E to 10 CFR Part 50, 

the NRC staff reviewed the application. In accordance with 10 CFR 50.47(a)(1)(i), no initial OL 

for a nuclear power reactor will be issued under 10 CFR Part 50 unless the NRC finds that there 

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

radiological emergency. As provided by 10 CFR 50.47(a)(2), the NRC will base its finding on a 

review of FEMA’s findings and determinations as to whether State and local offsite emergency 

plans are adequate, and whether there is reasonable assurance that they can be implemented, 

and on the NRC assessment, documented herein, as to whether TVA's onsite emergency plans 

are adequate and whether there is reasonable assurance that they can be implemented.

In accordance with 44 CFR Part 353, Appendix A, FEMA is responsible for the findings and 

determinations as to whether offsite emergency plans are adequate and can be implemented. 

FEMA regulations for this review appear in 44 CFR Part 350, “Review and Approval of State 

and Local Radiological Emergency Plans and Preparedness.” These regulations require that 

10 CFR 50.47, “Emergency Plans,” Appendix E to 10 CFR Part 50, and NUREG-0654/FEMA 

REP-1, Revision 1, be used in evaluating State and local emergency plans and preparedness. 

FEMA radiological offsite emergency preparedness program documents provide guidance on 

various topics for use by State and local organizations responsible for radiological emergency 

preparedness and response.

Technical Evaluation: In Section 13.3.2.17 of SSER 22, the NRC staff described its review of 

the findings and determinations of FEMA regarding the status of emergency preparedness of 

the State and local authorities within the WBN EPZ. Included was a discussion of the FEMA 

Interim Finding Report (IFR) upon which Sections 13.3.2.5 and 13.3.2.17 of SSER 22 were 

based in part. SSER 22 Section 13.3.2.17 also provided the rationale for basing the evaluation 

of offsite preparedness using exercises conducted at WBN, Unit 1. 

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Because of construction delays, nearly four years have passed since FEMA issued the IFR that 

formed part of the basis of the NRC staff’s evaluation in Section 13.3.2.17 of SSER 22. During 

this period, TVA and the offsite response organizations successfully conducted full participation 

exercises. Also during this period, TVA upgraded the alert and notification system at all of their 

sites. The NRC staff’s review of this latter modification is described in Section 13.3.2.5 of this 

supplement. 

By letter dated May 19, 2014 (ADAMS Accession No. ML14112A561), the NRC staff asked 

FEMA to confirm its earlier findings and determinations regarding offsite plans and 

preparedness. FEMA responded by letter dated August 28, 2014. FEMA stated that it had 

evaluated the full participation exercises conducted on October 19, 2011, and October 30-31, 

2013. FEMA also stated that they reviewed and approved the annual letters of certification for 

Tennessee relative to WBN for calendar years 2011 through 2013. Based upon these reviews, 

FEMA determined that the radiological emergency response plans and preparedness for the 

State of Tennessee and the affected jurisdictions surrounding WBN can be implemented and 

are adequate to provide reasonable assurance that appropriate measures can be taken offsite 

to protect the health and safety of the public in the event of a radiological emergency at the site. 

FEMA further stated that the 44 CFR Part 350 approval of the State of Tennessee’s offsite 

radiological emergency response plans and preparedness site-specific to Watts Bar Nuclear 

Plan granted on July 3, 1997, would remain in effect. 

The NRC staff reviewed the FEMA findings and determinations and found its bases to be 

understandable and clear. The NRC staff review did not identify any discrepancies in the 

integration of the WBN-REP with those of State and local authorities. 

Conclusion: The NRC staff concludes that the State and local emergency plans for the WBN 

site provide an adequate planning basis and that there is reasonable assurance that the State 

and local emergency plans can be implemented. The NRC staff bases it conclusion upon (1) its 

review of the FEMA findings on the offsite plans discussed above, (2) its review of the FEMA 

findings on the 2011 and 2013 WBN, Unit 1, full participation exercises for State and local 

agencies discussed above, and (3) the design and operational fidelity between the two units.

13.3.2.18 Other Matters

Section 13.3.2.18 of SSER 22 addressed the requirement of Appendix E § V that TVA submit its 

detailed implementing procedures for its emergency plan no less than 180 days before the 

scheduled issuance of an OL. The NRC staff treated completion of this requirement as 

Confirmatory Item 43 that must be resolved prior to the issuance of an OL. 

By letter dated January 10, 2014, TVA (ADAMS Accession No. ML14010A191) submitted the 

combined WBN, Units 1 and 2, EPIPs in response to Confirmatory Item 43. These procedures 

are designated “Unit 0” to signify their applicability to both units. TVA supplemented this 

submittal in letters dated February 14, 2014; March 7, 2014; April 11, 2014; June 5, 2014;

June 16, 2014; June 23, 2014; November 3, 2014; November 7, 2014; and December 15, 2014

(ADAMS Accession Nos. ML15205A150, ML15205A156, ML15205A161, ML15205A163, 

ML15205A166, ML15205A136, ML14307A851, ML14311A747, and ML15205A123, 

respectively). The NRC staff’s review of these EPIPs was limited to assessing the 

completeness of the submittal; they remain subject to periodic inspection.

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With the exception of the November 5, 2014, submittal (ADAMS Accession No. ML15205A171) 

of CECC-EPIP-2 and CECC-EPIP-3, TVA did not submit the EPIPs for the Central Emergency 

Control Center (CECC) that serves as the emergency operations facility for each of the reactors 

for which TVA is the holder of the OL, including WBN, Unit 1, and will serve WBN, Unit 2, after 

the issuance of its OL. The CECC EPIPs have been submitted on the dockets of the operating 

units, including WBN, Unit 1,by letters dated July 13, 2012; October 18, 2013; October 31, 

2013; November 8, 2013; December 13, 2013; December 24 (three letters), 2013; July 16, 

2014; August 22, 2014; and August 26, 2014 (ADAMS Accession Nos. ML15205A179,

ML15205A185, ML15205A188, ML15205A191, ML15205A196, ML15205A201, ML15205A206, 

ML15205A209, ML14198A536, ML15205A215, and ML15205A139, respectively). The NRC 

staff accepts these CECC procedures, even though they were not explicitly docketed under 

WBN, Unit 2, because of (1) the Commission direction that the WBN, Unit 1, licensing basis 

would serve as the reference basis for WBN, Unit 2, and (2) the design and operational fidelity 

between both units. The NRC staff review of these EPIPs was limited to assessing the 

completeness of the submittal.

Accordingly, TVA has complied with the § V of Appendix E to 10 CFR Part 50 and, therefore, 

Confirmatory Item 43 is closed. 

Section 13.3.2 of SSER-12 created Open Item 37 (Appendix HH):

The NRC staff will review the combined WBN, Units 1 and2 Appendix C prior to 

issuance of the Unit 2 OL to confirm (1) that the proposed Unit 2 changes were 

incorporated into Appendix C, and (2) that changes made to Appendix C for Unit 1 since 

Revision 92 and the changes made to the generic REP since Revision 92 do not affect 

the bases of the NRC staff’s findings in this SER supplement (Section 13.3.2).

By letter dated April 16, 2014 (ADAMS Accession No. ML15205A221), TVA submitted 

Revision 103 of REPlan (generic part of WBN-REP), and REP Appendix C (site-specific part of 

WBN-REP). The NRC staff performed a line-by-line comparison against Revision 92xx of the 

WBN-REP. As a result of this review, the NRC staff requested additional information by e-mail 

dated June 16, 2014. TVA responded by letter dated September 12, 2014. The NRC staff 

performed a line-by-line comparison against Revision 104 of the WBN-REP. The NRC staff 

dispositioned any significant changes in Sections 13.3.2.1- 13.3.2.16 of this supplement. Based 

upon this review, the NRC staff determined that the changes made did not affect the bases of 

the NRC staff’s findings in SSER 22. Therefore, the NRC staff considers Confirmatory Item 37 

to be closed.

13.3.3 Conclusion

On the basis of its review of the WBN-REP, the results of onsite inspections, and its evaluation 

of TVA’s performance in exercises, the NRC staff concluded in Supplement 22 that the WBNREP provided an adequate basis for an acceptable state of onsite emergency preparedness, 

and that the WBN-REP met the requirements of 10 CFR 50.47(b), Appendix E to 10 CFR 

Part 50, with regard to WBN, Units 1 and 2.

For the present review, the NRC staff evaluated TVA’s compliance with the amended and new 

requirements of the November 2011, Emergency Preparedness rulemaking, which became 

effective subsequent to the issuance of SSER 22. In addition, the NRC staff evaluated the 

impact of changes made by TVA under the authority granted by 10 CFR 50.54(q)(3) to the 

WBN-REP since the issuance of SSER 22. The NRC staff documented its review and its 

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findings as tabulated in Table 13.3-1 of this supplement. In performing its review, the NRC staff 

identified three changes that potentially affected offsite preparedness. As described in 

Sections 13.3.2.5 and 13.3.2.17 of this supplement, FEMA reconfirmed its findings and 

determinations that formed part of the basis of SSER 22. 

On the basis of the foregoing review, the NRC staff concludes that the WBN-REP (i.e., 

Revision 106X of the site-independent TVA REP and the site-specific WBN, Units 1 and 2,

Appendix C, Revision 106X), upon satisfactory completion of the confirmatory items identified 

above, will provide an adequate planning basis for an acceptable state of onsite emergency 

preparedness for WBN, Units 1 and 2, is compliant with the planning standards of 10 CFR 

50.47(b) and the requirements of Appendix E to Part 50, and there is reasonable assurance that 

the WBN-REP can be implemented. 

FEMA has provided its findings and determinations on the adequacy of offsite emergency 

planning and preparedness based upon its plan reviews, exercise observations, and analyses. 

Based on its review of the FEMA findings, the NRC staff concludes, pursuant to 10 CFR 

50.47(a)(2), that the WBN offsite emergency plans provide an adequate planning basis and 

there is reasonable assurance that they can be implemented.

Accordingly, the NRC staff concludes that pursuant to 10 CFR 50.47(a)(1)(i), and subject to the 

satisfactory completion of the confirmatory items identified above, there is reasonable 

assurance that adequate protective measures can and will be taken in the event of a 

radiological emergency at either WBN, Units 1 or 2.

13.6 Physical Security

13.6.6 Cyber security Plan

13.6.6.1 Introduction

In NUREG-0847, “Safety Evaluation Report – Related to the Operation of Watts Bar Nuclear 

Plant, Unit 2, Supplement 24” (ADAMS Accession No. ML11277A148) the NRC staff approved 

TVA’s Cyber security Plan and Implementation Schedule. By letter dated January 9, 2015 

(ADAMS Accession No. ML15010A051), supplemented by letter dated April 1, 2015 (ADAMS 

Accession No. ML15097A523), TVA submitted a revised Cyber security Plan (CSP) 

Implementation Schedule required by 10 CFR Section 73.54.

13.6.6.2 Regulatory Basis

General Requirements

Consistent with 10 CFR 73.54(a), the applicant must provide high assurance that digital 

computer and communication systems and networks are adequately protected against cyber

attacks, up to and including, the design basis threat as described in 10 CFR 73.1. The applicant 

shall protect digital computer and communication systems and networks associated with (i) 

safety-related and important-to-safety functions; (ii) security functions; (iii) emergency 

preparedness functions, including offsite communications; and (iv) support systems and 

equipment, which if compromised, would adversely impact safety, security, and emergency 

preparedness (SSEP) functions. The rule specifies that digital computer and communication 

systems and networks associated with these functions must be protected from cyberattacks that 

would adversely impact the integrity or confidentiality of data and software; deny access to 

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systems, services, or data; or provide an adverse impact to the operations of systems, 

networks, and associated equipment.

In the October 21, 2010, SRM-COMWCO-10-0001, the Commission stated that the NRC’s 

cyber security rule at 10 CFR 73.54 should be interpreted to include structures, systems, and 

components (SSCs) in the balance of plant (BOP) that have a nexus to radiological health and 

safety. The NRC staff determined that SSCs in the BOP that have a nexus to radiological 

health and safety are those that could directly or indirectly affect reactivity of a nuclear power 

plant, and are, therefore, within the scope of important-to-safety functions described in 10 CFR 

73.54(a)(1). The rule also specifies that each submittal must include a proposed 

implementation schedule. Implementation of the cyber security program must be consistent 

with the approved schedule. 

13.6.6.3 Technical Evaluation

The NRC staff performed a technical evaluation of the applicant’s submittal. The applicant’s 

submittal contains three sections. One section of the submittal requested a delay in the date for 

completion of Milestone 8 of the implementation schedule. This section conformed to the 

guidance in a publically available NRC internal memorandum dated October 24, 2013 (ADAMS 

Ascension No. ML13295A467) containing criteria for evaluating licensee requests to modify 

cyber security implementation schedules. The NRC staff reviewed the applicant’s submittal 

against the memorandum guidance. One section of the submittal requested revisions to 

Milestones 6 and 7 and the deletion of the previously proposed license conditions. One section 

of the submittal proposed a CSP license condition. The NRC staff’s evaluation of each section 

of TVA’s submittal is discussed below.

13.6.6.3.1 Delay of Milestone 8

The NRC staff has evaluated the licensee’s request for delaying Milestone 8 consistent with 

guidance in the October 24, 2013, NRC memorandum. The NRC staff’s evaluation is below, 

numbered as the criteria are in the October 24, 2013, NRC memorandum. 

1) Identification of the specific requirement(s) of the CSP that the licensee needs additional 

time to implement.

TVA stated that many of the actions required to address Milestone 8 have been completed for 

WBN, Unit 2. Among those completed actions are the performance of cyber security

assessments for all WBN, Unit 2, critical digital assets (CDAs), excluding the common Security 

and Corporate Emergency Preparedness systems and the determination of remediation actions 

for deficient controls. Several remediation actions have already been implemented, and others 

are in the process of being implemented. However, the additional guidance provided to the 

industry following Milestone 1 through 7 inspections has caused TVA to re-evaluate work that 

had previously been completed. This re-evaluation has resulted in an increase in the scope of 

remediation work, including work that requires the implementation of design changes and the 

unit to be shutdown. These cyber security remediation actions potentially impact the current 

WBN, Unit 2, start-up schedule. The additional requested time allows TVA to design, install, 

and test plant changes without impacting the start-up schedule, consistent with its outage 

planning milestone schedules, which ensures the scope of all outage work is understood and 

integrated into the outage schedule and scope for work that must be done with the unit 

shutdown. The licensee provided a list of remaining remediation actions.

13-17
The NRC staff finds that implementation of the listed actions requires the outage as TVA stated.

2) Detailed justification that describes the reason the licensee requires additional time to 

implement the specific requirement(s) identified.

TVA stated that most of the activities described in response to 1) above require an outage. The 

requested extension date allows for one additional refueling outage to methodically plan, 

implement, and test the required additions or changes and allows those additions or changes 

that require a design change to be performed within TVA milestone dates for refueling outage 

scope determination. Original schedules for the completion of the cyber security control 

assessments, and thus the implementation of remediation actions for deficient controls and 

other program areas as described above in 1), have been delayed in part due to additional 

actions TVA is taking that were not anticipated when the original schedules were set. 

The NRC staff finds there are implementation issues with CSP tasks that were not anticipated 

when the original schedules were set. Based on the information provided by TVA in its letter, 

the NRC staff finds that it will not be able to fully implement its CSP prior to startup. The NRC 

staff recognizes that critical digit assets assessment work is resource intensive and that the 

licensee has a large number of additional tasks not originally considered. The NRC staff 

concludes that TVA’s explanation of the need for additional time is compelling. 

3) A proposed completion date for Milestone 8 consistent with the remaining scope of work to 

be conducted and the resources available.

TVA proposed a Milestone 8 completion date of March 31, 2017. TVA also stated that changing 

the completion date of Milestone 8 will encompass one refueling outage to implement the 

remaining cyber security remediation actions. TVA provided a list of activities that must be 

performed during an outage and a list of activities that are more safely performed during an 

outage.

The NRC staff concludes that delaying final implementation of the cyber security program will 

provide opportunities to get work done safely during the outage.

4) An evaluation of the impact that the additional time to implement the requirements will have 

on the effectiveness of the licensee’s overall cyber security program in the context of 

milestones already completed.

TVA indicated completion of activities associated with the CSP provides a high degree of 

protection to ensure that digital computer and communication systems and networks associated 

with safety, security, and emergency preparedness (SSEP) systems are sufficiently protected 

against cyber attacks. It detailed activities completed for each milestone and noted several 

elements of Milestone 8 have already been implemented.

The NRC staff concludes TVA’s site is much more secure because the activities the licensee 

completed mitigate the most significant cyberattack vectors for the most significant CDAs.

5) A description of the licensee’s methodology for prioritizing completion of work for critical 

digital assets associated with significant safety consequences and with reactivity effects in 

the balance of plant.

13-18
TVA stated its methodology for prioritizing completion of cyber security activities associated with 

significant SSEP consequences and with reactivity effects in the balance of plant focused on 

competing Milestones 1 through 7 and implementation of remediation actions for Milestone 8 

and is consistent with the TVA design change processes. Work is implemented consistent with 

work management processes and available resources. Prioritization of work was performed per 

TVA’s work scheduling processes and was based on safety significance, required availability of 

significant systems, and consideration for all aspects and elements of risk management. The 

remaining actions to be completed for Milestone 8 will be implemented according to the 

scheduled actions. 

The NRC staff finds the licensee’s methodology is appropriate.

6) A discussion of the licensee’s cyber security program performance.

TVA stated implementation of the requirements of Milestones 1 through 7 provides a high 

degree of protection against cyberattacks, including radiological sabotage, during full program 

implementation. In addition to these actions, cyber security assessments for all WBN, Unit 2,

CDAs, excluding the common Security and Corporate Emergency Preparedness Systems, have 

been completed, and remediation actions have been determined for deficient controls. Many of 

the controls that do not require a design change have already been implemented. A 

self-assessment of cyber security milestones was completed in June 2014. Deficiencies and 

learning opportunities identified during the self-assessment have been entered into the 

Corrective Action Program (CAP). The licensee provided a discussion about ongoing 

monitoring, logging, and assessment activities and performance monitoring. It closed its 

discussion by stating that the actions described show good evidence of strong cyber security

program performance.

The NRC staff concludes that implementation of Milestones 1 through 7 provides significant 

protection against cyberattacks. The NRC staff concludes that the licensee program is active 

and functioning and the licensee is using the tools at its disposal to verify and improve the cyber

security program. 

7) A discussion of cyber security issues pending in the licensee’s CAP.

TVA stated the site and corporate CAP are used to document cyber security issues. The 

licensee listed cyber security program actions pending in the CAP.

The NRC staffs finds that the discussion reflects a functioning CAP and that the examples 

reflect the implementation and evolution of the cyber security program and reinforce the 

licensee discussions above.

8) A discussion of modifications completed to support the cyber security program and a 

discussion of pending cyber security modifications.

The licensee provided a discussion of completed modifications and pending modifications. 

These are consistent with the discussions provided above and the licensee CSP. 

13.6.6.3.2 Revisions to Milestones

With regard to the revisions to Milestones 6 and 7, the licensee proposed:

13-19
1. Deleting the reference to “all CDAs” in Milestones 6a, 6b, and 7 to align with the Nuclear 

Energy Institute (NEI) Template and WBN, Unit 1;

2. Realigning Milestones 6a and 6b into the NEI Template Milestone 6;

3. Revising Milestone 7 completion date from "Prior to Startup" to “Prior to Fuel Load”; and

4. Deleting the Milestone 6 and 7 exceptions and proposed license conditions associated 

with the Security System and Corporate Emergency Preparedness System. 

The NRC staff has evaluated the license’s proposal regarding Milestones 6a, 6b, and 7. 

Deleting “all CDAs” focuses the milestones on the target set CDAs. The NRC staff finds this 

change is acceptable because it focuses the cyber security program on the most significant 

CDAs. Realignment of Milestones 6a and 6b into a single Milestone 6 results in implementation 

of all security controls for target set equipment. The NRC staff finds this change is acceptable 

because it maximizes protection of the most significant CDAs. Revising the Milestone 7 

completion date from “Prior to Startup” to “Prior to Fuel Load” results in the milestone being 

accomplished earlier. The NRC staff finds this change is acceptable because it provides the 

protection of implementation of Milestones 1 through 7 earlier in the startup schedule. Finally, 

deleting the Milestone 6 and 7 exceptions and the license conditions associated with the 

Security System, and Corporate Emergency Preparedness System in NUREG-0847, “Safety 

Evaluation Report – Related to the Operation of Watts Bar Nuclear Plant, Unit 2,” Supplement 

24 (ADAMS Accession No. ML11277A148), removes unnecessary exceptions and license 

conditions. The NRC staff finds this change is acceptable because it results in complete 

implementation of the cyber security program in Milestone 8.

13.6.6.3.3 License Condition

The NRC staff has evaluated the licensee’s proposal of including a license condition in the 

WBN, Unit 2, Facility Operating License. The license condition would be, “The licensee shall 

fully implement and maintain in effect all provisions of the Commission approved cyber security

plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 50.54(p). 

The licensee CSP was approved by NUREG-0847 Supplement 28.” The NRC staff finds this 

change is acceptable because it conditions the license on full implementation and maintenance 

of the CSP, including CSP changes approved by the NRC staff and CSP changes made by the 

licensee which do not decrease the effectiveness of the cyber security plan. 

13.6.6.4 Conclusion

Based on its review of the licensee’s submission, the NRC staff concludes that implementation 

of Milestones 1 through 7 provides significant protection against cyber attacks; the licensee’s 

explanation of the need for additional time is compelling, and it is acceptable for TVA to 

complete implementation of Milestone 8, full implementation of the CSP, by March 31, 2017. 

The NRC staff’s review and evaluation of the applicant’s CSP was conducted using the NRC 

staff positions established in the relevant sections of Regulatory Guide (RG) 5.71. Based on the 

NRC staff’s review, the NRC finds that the applicant addressed the information necessary to 

satisfy the requirements of 10 CFR 73.54, 10 CFR 73.55(a)(1), 10 CFR 73.55(b)(8), and 

10 CFR 73.55(m), and that the applicant’s CSP provides high assurance that CDAs are 

adequately protected against cyberattacks, up to and including, the design basis threat as 

described in 10 CFR 73.1. 

13-20
Therefore, the NRC staff finds the information contained in this CSP to be acceptable, and upon 

successful implementation of this program, operation of WBN, Unit 2, will not be inimical to the 

common defense and security.

13-21

19 REPORT OF THE ADVISORY COMMITTEE ON 

REACTOR SAFEGUARDS

In SSERs 1, 4, and 14, the NRC staff addressed the concerns raised by the Advisory 

Committee on Reactor Safeguards (ACRS) in its letter report of August 16, 1982, which was 

published in Appendix F to SSER 1. In SSER 20, the NRC staff documented the ACRS review 

of the Watts Bar Nuclear Plant’s (WBN), Unit 1, ability to operate at core power levels up to 

3411 megawatts thermal. 

During the 609th meeting of ACRS from November 7 - 8, 2013, ACRS met with representatives 

of the Nuclear Regulatory Commission (NRC) staff and the applicant, Tennessee Valley 

Authority (TVA), to discuss the WBN, Unit 2, operating license (OL) request. By letter to Mr. 

Mark A. Satorius, Executive Director for Operations, dated November 26, 2013 (ADAMS 

Accession No. ML13318A154), the ACRS provided its interim conclusions based on its review 

to date of the WBN, Unit 2, OL request.

During the 621st meeting of the ACRS from February 5-7, 2015, ACRS met with representatives 

of the NRC staff and TVA to discuss the WBN, Unit 2, OL request. By letter to Chairman 

Stephen G. Burns, dated February 12, 2015 (ADAMS Accesssion No. ML15039A005), ACRS 

provided its conclusions and recommendations related to the operation of WBN, Unit 2. The 

ACRS letter stated there is reasonable assurance that WBN, Unit 2, can operate as the second 

unit of the dual-unit WBN without undue ruisk to the health and safety of the public and that an 

OL for WBN, Unit 2, should be approved, following completion of remaining staff inspections 

and closure of remaining open items. The ACRS letter is provided in Appendix F of this SSER.

19-1

APPENDIX A CHRONOLOGY OF RADIOLOGICAL REVIEW OF

WATTS BAR NUCLEAR PLANT, UNIT 2, OPERATING 

LICENSE REVIEW

Public correspondence exchanged between the Nuclear Regulatory Commission (NRC) and 

TVA during the review of the operating license application for Watts Bar Nuclear Plant (WBN), 

Units 1 and 2, is available through the NRC’s Agencywide Documents Access and Management 

System (ADAMS) or the Public Document Room (PDR). This correspondence includes that 

occurring subsequent to TVA’s letter notifying the NRC of its decision to reactivate construction 

of WBN, Unit 2, which had been in a deferred status under the Commission’s Policy Statement 

on Deferred Plants. 

Web-based ADAMS (WBA) is the latest interface to ADAMS. This search engine enables 

searching the ADAMS repository of official agency records (Publicly Available Records System 

(PARS) and Public Legacy libraries) for publicly available regulatory guides, NUREG-series 

reports, inspection reports, Commission documents, correspondence, and other regulatory and 

technical documents written by NRC staff, contractors, and licensees. WBA permits full-text 

searching and enables users to view document images, download files, and print locally. New 

documents become accessible on the day they are published, and are released periodically 

throughout the day. ADAMS documents are provided in Adobe Portable Document Format 

(PDF). 

The NRC PDR reference staff is available to assist with ADAMS. Contact information for the 

PDR staff is on the NRC Web site at http://www.nrc.gov/reading-rm/contact-pdr.html.

A-1

APPENDIX E PRINCIPAL CONTRIBUTORS TO SSER 28

E. Bowman, NRR/JLD

N. DiFrancesco, NRR/JLD/JHMB

S. LaVie, NSIR/DPR

G.S. Matharu, NRR/DE/EEEB

R. Mathew, NRR/DE/EEEB

J. Poole, NRR/DORL/LPWB

J. Rycyna, NSIR/CSD

E-1

APPENDIX F REPORT OF THE ADVISORY COMMITTEE ON

REACTOR SAFEGUARDS

During the 621st meeting of the ACRS from February 5-7, 2015, ACRS met with representatives 

of the NRC staff and TVA to discuss the WBN, Unit 2, OL request. By letter to Chairman 

Stephen G. Burns, dated February 12, 2015 (ADAMS Accesssion No. ML15039A005), the 

Advisory Committee on Reactor Safeguards provided its conclusions and recommendations 

related to the operation of WBN, Unit 2. A copy of this letter is provided on the following pages 

of this Appendix.

F-1
UNITED STATES 

NUCLEAR REGULATORY COMMISSION 

ADVISORY COMMITTEE ON REACTOR SAFEGUARDS 

WASHINGTON, DC 20555 - 0001 

February 12, 2015 

The Honorable Stephen G. Burns 

Chairman 

U.S. Nuclear Regulatory Commission 

Washington, DC 20555-0001 

SUBJECT: FINAL ACRS REVIEW OF WATTS BAR NUCLEAR PLANT UNIT 2 

OPERATING LICENSE APPLICATION 

Dear Chairman Burns: 

During the 621st meeting of the Advisory Committee on Reactor Safeguards, February 5-7, 2015, 

we met with representatives of the NRC staff and the applicant, Tennessee Valley Authority 

(TVA), to review the current status of the construction completion, inspection, and licensing 

activities related to the Watts Bar Nuclear Plant, Unit 2 (WBN 2) Operating License (OL) 

application. 

WBN 2 is the second unit of a dual-unit plant consisting of two Westinghouse-designed fourloop pressurized water reactors within ice-condenser containments. TVA received a 

Construction Permit (CP) for both units in 1973 and suspended construction in 1985. 

Construction for WBN 1 was resumed in 1989, and WBN 1 received its full-power OL in early 

1996. 

Construction for WBN 2 remained suspended until 2007 when TVA informed the NRC of its plan 

to complete the unit under the existing CP. In Staff Requirements Memorandum SRM-SECY07-0096, dated July 25, 2007, the Commission directed the NRC staff to employ the current 

licensing basis for WBN 1 for the license review of WBN 2. 

Our Plant Operations and Fire Protection Subcommittee held its first meeting concerning 

completion of WBN 2 on March 31, 2009, and has held nine subsequent meetings. We issued 

an interim letter dated November 26, 2013, to reflect our review to that date. A final 

subcommittee meeting was held on January 13, 2015. During these meetings, we had the 

benefit of discussions with the NRC staff and TVA, as well as comments from several members 

of the public. We also had the benefit of the documents referenced. 

F-2
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CONCLUSIONS AND RECOMMENDATIONS 

1 . There is reasonable assurance that WBN 2 can operate as the second unit of the dualunit Watts Bar Nuclear Plant without undue risk to the health and safety of the public. 

The OL for WBN 2 should be approved following completion of remaining staff 

inspections and closure of remaining open items. 

2. The integration of WBN 2 as the second unit in a dual-unit plant which has operated as a

single unit for almost 20 years requires specific, detailed planning to ensure against

creating challenges to WBN 1 operation. Our review indicates that this planning has

been done and necessary preparations for WBN 2 operation have been made.

3. Adequate recirculation core cooling will be assured following a Loss of Coolant Accident,

taking debris effects into account, provided high levels of containment cleanliness are

maintained.

4. We strongly endorse the development of a methodology for Probabilistic Flooding

Hazard Analysis. This is important for future use consistent with risk-informed,

performance-based approaches to natural hazard assessment.

BACKGROUND 

In our interim letter dated November 26, 2013, we stated that our review to that date had not 

identified any issue which we did not expect to be resolved satisfactorily prior to OL issuance, 

and we identified eight specific items for our further review. This included seven items listed in 

the staff’s Supplemental Safety Evaluation Report 26. 

Our interim letter also noted that we had focused on the potential for the period of deferral of 

WBN 2 construction to affect the integration of WBN 2 operation into the dual-unit design. This 

included both the validation of compliance of structures, systems and components (SSCs) with 

the current licensing basis, which is to apply for both units, and validation that the process of 

startup and initial operation of WBN 2 will not adversely affect continued operation of WBN 1. 

We conclude that this has been satisfactorily achieved. 

In SECY-14-0102 dated September 29, 2014, the staff provides a comprehensive summary of 

the unique construction and licensing history for WBN 2. This summary includes ongoing 

licensing actions applicable to the current licensing basis for WBN 1, and therefore also to WBN 

2 pursuant to SRM-SECY-07-0096. 

In a few instances, we have reviewed issues which are being addressed for WBN 2 in advance 

of their resolution as part of the WBN 1 licensing basis. This is also pursuant to SRM-SECY-07-

0096. An example is TVA’s response, dated May 17, 2012, to Generic Letter (GL) 2004-02, 

“Potential Impact of Debris Blockage on Emergency Recirculation during Design Basis 

Accidents at Pressurized-Water Reactors.” Resolution prior to initial operation will avoid 

unnecessary radiation exposure. 

F-3
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DISCUSSION 

The results of our review of the items identified in our interim letter are summarized as follows: 

Generic Safety Issue (GSI)-191 and GL 2004-02

In a letter dated September 16, 2013, TVA affirmed that a confirmatory inspection for loose 

debris will be performed on WBN 2 after construction has been completed and the containment 

has been cleaned. In a letter to TVA dated September 18, 2014, NRC staff describes its 

closeout of GL 2004-02 for WBN 2 based on the “clean plant” guidelines and methodology 

developed by the Nuclear Energy Institute. 

In support of this closeout, TVA performed a detailed evaluation for both WBN units which 

included conservative estimates of debris transport within the containment building, of the head 

loss across the sump strainer, and of vortex formation above the strainer. This evaluation was 

supported by appropriate testing, which was witnessed by NRC staff. 

Because WBN 2 uses containment sump strainers consisting of stacked discs, we reviewed the 

potential for miscellaneous debris, such as tapes and labels, to block entry into the spaces 

between the discs and thereby to result in a loss of flow area much greater than for an 

equivalent mass of fibrous debris. We reviewed in detail the testing performed, the assumptions 

used, in-vessel debris effects, and the margin remaining in the available pump suction head. 

We conclude that adequate margin will remain available for recirculation flow, provided that 

rigorous standards of containment cleanliness, with latent debris loads of less than 100 pounds, 

are maintained. 

Compliance with General Design Criterion (GDC) 5

GDC 5 requires that SSCs important to safety shall not be shared, unless it can be shown that 

such sharing will not significantly impair their ability to perform their safety functions, including, 

in the event of an accident in one unit, an orderly shutdown and cooldown of the remaining unit. 

TVA documented in the Updated Final Safety Analysis Report (UFSAR) a calculation which 

shows that the cooling water systems have the capability to bring the non-accident unit to cold 

shutdown within 72 hours from its entry into the hot standby mode. This assumes that the 

component cooling system carries all required heat loads for both the accident unit and, later in 

the event, the non-accident unit. 

Cyber Security Confirmatory Testing

Testing was conducted by TVA to verify that the External Communications Interface for the 

WBN 2 Eagle 21 Process Protection System only allows data flow in one direction (i.e., data out 

to the non-safety-related Plant Computer System and no data into the Eagle 21 system). We 

reviewed this testing and its results, and the physical design provisions which ensure it will be 

maintained. We conclude that these are acceptable. 

F-4
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Calculation of Core Fuel Temperature

The NRC staff noted that the methodology used initially for WBN 2 to determine peak clad 

temperature, and other variables such as stored energy, following a Large Break Loss of 

Coolant Accident potentially provided non-conservative results due to lack of a thermal 

conductivity degradation (TCD) model. TVA performed and the staff approved further analyses 

which included the effects of TCD. The results have shown adequate peak clad temperature 

margin to the 10 CFR 50.46(b)(1) limits for the initial WBN 2 core loading. A license condition 

will be imposed requiring the use of methodologies which include an approved TCD model for 

subsequent fuel cycles. These methodologies are under staff review. 

Site Licensing Basis Hydrology

By letter dated July 19, 2012, TVA submitted a License Amendment Request (LAR) seeking 

approval to revise the WBN 1 UFSAR to adopt a revised hydrologic analysis for the site. This 

LAR was later supplemented by 10 letters submitted between March 1, 2013, and December 5, 

2014. These letters provided additional information, but did not change the flood elevation or 

warning time. The revised hydrologic analysis for the site results in changes to the flooding 

protection requirements for certain WBN 1 SSCs. As the LAR revises the WBN 1 licensing 

basis, it is applicable to WBN 2 as well. Accordingly, we included the LAR revisions in our 

review. The LAR was approved and the UFSAR updated by an NRC letter dated January 28, 

2015. 

The site licensing basis provides for conditions in which the flood level may exceed plant grade. 

This is termed “Flood Mode Operation”, and SSCs required to maintain plant safe shutdown 

under this condition are protected or designed for submergence. To prevent floods from 

exceeding the design basis flood level, temporary measures taken for WBN 1 will be replaced 

by permanent modifications prior to WBN 2 fuel loading. We have no further questions or 

concerns following our review. 

Fire Protection Procedures Related to Operator Manual Actions

The Watts Bar Fire Protection Program is developed for Unit 1 and Unit 2 in accordance with 

the requirements in 10 CFR 50, Appendix R, and the guidance in Regulatory Guide 1.189, 

Revision 2, “Fire Protection for Nuclear Power Plants.” The Watts Bar Fire Protection Report 

documents the Fire Protection Plan for Unit 1 and Unit 2, the supporting fire hazards analysis, 

and the strategies to ensure safe shutdown. These are applicable for a fire in any plant 

location. The Fire Protection Plan identifies numerous operator manual actions that are needed 

to mitigate the consequences from fire damage and to implement the safe shutdown strategies. 

F-5
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We examined several challenging WBN 2 fire scenarios that require coordinated responses of 

several Auxiliary Unit Operators to perform local actions in Unit 1 and Unit 2. We questioned 

whether the feasibility and reliability of these actions were evaluated according to the methods 

outlined in NUREG-1852, “Demonstrating the Feasibility and Reliability of Operator Manual 

Actions in Response to Fire.” TVA explained that the fire response procedures contain detailed 

guidance for every local action that is required for a fire in each plant location. 

TVA also described the design of the Watts Bar fire detection systems, which provide clear 

indication of the fire location. They explained that a time line was developed for each fire 

scenario that accounts for fire detection, diagnosis of plant conditions, assembly of personnel in 

the Main Control Room, supervisory coordination and direction, dispatch of local operators, 

transit times, access requirements, action implementation times, and communication. 

Challenging scenarios were evaluated by walkthroughs and timing assessments. The total time 

required to perform the needed actions was compared with the amount of time that is available, 

as determined by the identified safe shutdown strategy. A 100% time margin was used to 

account for uncertainties in the assessments. For example, if it is necessary to complete the 

actions within 60 minutes, the strategy was determined to be feasible and reliable if the 

operators demonstrated successful completion in 30 minutes, or less. The staff audited these 

timing assessments and observed a sample of the walkthroughs. 

These activities provide reasonable assurance that the identified operator manual actions have 

been adequately assessed for their feasibility. 

Operational Readiness Preparations

Both TVA and NRC staff are following detailed plans for closeout of remaining inspections and 

open items prior to each stage of operational readiness, with active management oversight of 

these activities. The required resources appear to be available and capable of meeting 

currently scheduled milestones, and emergent inspection findings are being addressed 

appropriately. 

Development of Probabilistic Flood Hazard Assessment Capability

During our review, we noted that the Probable Maximum Flood is a deterministically established 

value for each plant site. This is increasingly inconsistent with the agency use of risk-informed, 

performance-based approaches to natural hazard assessment. In response to our questions in 

this regard, the staff informed us of their consideration of a multi-year Probabilistic Flooding 

Hazard Analysis (PFHA) Research Plan. We strongly endorse development of a PFHA 

methodology and would welcome further discussion with the staff. 

F-6
-6- 

SUMMARY 

There is reasonable assurance that WBN 2 can operate as the second unit of the dual-unit 

Watts Bar Nuclear Plant without undue risk to the health and safety of the public. The OL for 

WBN 2 should be approved following completion of remaining staff inspections and closure of 

remaining open items. 

Sincerely,

/RA/ 

John W. Stetkar 

Chairman

REFERENCES

1. Tennessee Valley Authority, Watts Bar Nuclear Plant Unit 2 Final Safety Analysis Report

(FSAR), Amendments No. 92 through 112.

Below is the list of FSAR Amendments that was submitted as part of the Unit 2 review.

Amendment 92, dated December 18, 2008 (ML090980525)

Amendment 93, dated April 30, 2009 (ML091400068)

Amendment 94, dated August 27, 2009 (ML092460758)

Amendment 95, dated November 24, 2009 (ML093370274)

Amendment 96, dated December 14, 2009 (ML093570464)

Amendment 97, dated January 11, 2010 (ML100191426)

Amendment 98, dated May 7, 2010 (ML101340795)

Amendment 99, dated May 27, 2010 (ML101610291)

Amendment 100, dated September 1, 2010 (ML102530216)

Amendment 101, dated October 29, 2010 (ML103160411)

Amendment 102, dated December 17, 2010 (ML112210425)

Amendment 103, dated March 15, 2011 (ML110840665)

Amendment 104, dated June 3, 2011 (ML111780527)

Amendment 105, dated August 12, 2011 (ML121700642)

Amendment 106, dated September 15, 2011 (ML121700412)

Amendment 107, dated November 17, 2011 (ML121780190)

Amendment 108, dated March 5, 2012 (ML120830237)

Amendment 109, dated August 23, 2012 (ML122440027)

Amendment 110, dated August 14, 2013 (ML13255A164)

Amendment 111, dated February 13, 2014 (ML14051A680)

Amendment 112, dated May 30, 2014 (ML14160A901)

F-7
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2. U.S. Nuclear Regulatory Commission, NUREG-0847, “Safety Evaluation Report Related

to the Operation of Watts Bar Nuclear Plant, Unit 2,” Supplements (SSER) 21 - 27.

Below is the list of SSERs issued as part of the Unit 2 review.

SSER 21, dated February 28, 2009 (ML090570741)

SSER 22, dated January 31, 2011 (ML110390197)

SSER 23, dated June 30, 2011 (ML11206A499)

SSER 24, dated September 30, 2011 (ML11277A148)

SSER 25, dated November 30, 2011 (ML12011A024)

SSER 26, dated June 30, 2013 (ML13205A136)

SSER 27, dated January, 31, 2015 (ML15033A041)

3. Staff Requirements Memorandum, SECY-07-0096, “Possible Reactivation of

Construction and Licensing Activities for the Watts Bar Nuclear Plant Unit 2,” dated July

25, 2007 (ML072060688)

4. Tennessee Valley Authority, “Watts Bar Nuclear Plant (WBN) Unit 2 – Transmittal of

Revised Unit 1/Unit 2 As-Designed Fire Protection Report,” dated March 13, 2013

(ML13081A002, ML13081A003, ML13081A004)

5. Regulatory Guide 1.189, Revision 2, “Fire Protection for Nuclear Power Plants,” dated

October, 2009 (ML092580550)

6. NUREG-1852, “Demonstrating the Feasibility and Reliability of Operator Manual Actions

in Response to Fire,” dated October, 2007 (ML073020676)

7. NRC Generic Letter (GL) 2004-02, “Potential Impact of Debris Blockage on Emergency

Recirculation during Design Basis Accidents at Pressurized-Water Reactors”, dated

September 13, 2004 (ML042360586)

8. Information Notice 2011-21, “Realistic Emergency Core Cooling System Evaluation

Model Effects Resulting from Nuclear Fuel Thermal Conductivity Degradation,” dated

December 13, 2011 (ML113430785)

9. Staff Requirements Memorandum, SECY-14-0102, “Construction and Licensing for

Watts Bar Nuclear Plant, Unit 2, dated September 29, 2014 (ML14238A672)

F-8
APPENDIX HH WATTS BAR, UNIT 2, ACTION ITEMS TABLE

This table provides a status of required action items associated of all open items, confirmatory 

issues, and proposed license conditions that the U.S. Nuclear Regulatory Commission (NRC)

staff has identified. Unless otherwise noted, the item references are to sections of this SSER. 

Items that are still open are listed first, and items that have been closed are listed second. 

Some numbers were not used in the sequential list. There are 11 items still open and 117

items that have been closed as of May 7, 2015.

Open Items

Item Type Action Required Lead Status

(1) Confirmatory 

Issue (CI)

Review evaluations and corrective actions 

associated with a power assisted cable pull. 

(NRC safety evaluation, dated August 31, 

2009, Agencywide Documents Access and 

Management System (ADAMS) Accession 

No. ML092151155)

RII Open

(16) Based on the uniqueness of environmental 

qualification (EQ), the NRC staff must perform 

a detailed inspection and evaluation prior to 

fuel load to determine how the WBN, Unit 2,

EQ program complies with the requirements of 

10 CFR 50.49. (Suppplemental Safety 

Evaluation Report (SSER) 22, Section 3.11.2) 

RII/NRR Open

(25) Prior to the issuance of an operating license

(OL), the Tennessee Valley Authority (TVA) is

required to provide satisfactory documentation

that it has obtained the maximum secondary 

liability insurance coverage pursuant to 

10 CFR 140.11(a)(4), and not less than the 

amount required by 10 CFR 50.54(w), with 

respect to property insurance, and the NRC 

staff has reviewed and approved the 

documentation. (SSER 22, Section 22.3)

NRR Open

(75) CI The NRC staff will verify that the test 

procedures and qualification testing for 

auxiliary feedwater initiation and control and 

flow indication are completed in WBN, Unit 2,

before fuel load. (SSER 23, Section 7.8.2) 

RII Open

(79) TVA should perform a radiated susceptibility 

survey, after the installation of the hardware 

but prior to the RM-1000 being placed in 

service, to establish the need for exclusion 

distance for the high range containment air 

radiation (HRCAR) monitors while using 

handheld portable devices (e.g., walkie-talkie) 

in the control room, as documented in 

NRR Open

HH-1
Attachment 23 to TVA’s letter, dated February 

25, 2011, and item number 355 of TVA’s letter,

dated April 15, 2011. (SSER 23, Section 

7.5.2.3)

(83) CI TVA should confirm to the NRC staff the 

completion of the data storm test on the

distribution control system. (SSER 23, Section 

7.7.1.4)

NRR Open

(90) CI The NRC staff should verify that the essential 

raw cooling water (ERCW) dual unit flow 

balance confirms that the ERCW pumps meet 

all specified performance requirements and 

have sufficient capability to supply all required 

ERCW normal and accident flows for dual unit 

operation and accident response, in order to 

verify that the ERCW pumps meet GDC 5 for 

two-unit operation. (SSER 23, Section 9.2.1)

RII/NRR Open

(140) CI TVA to confirm to the staff the completion of 

the Unit 2, OMA feasibility walkdowns. (SSER 

26, Appendix FF, Section 8.0)

NRR Open

(141) CI TVA to confirm to the staff the completion of 

the multiple spurious operation scenario 

resolution actions for scenarios that only affect 

Unit 2. (SSER 26, Appendix FF, Section 8.0)

NRR Open

(142) CI TVA to confirm to the staff the completion of 

the electrical coordination modifications. 

(SSER 26, Appendix FF, Section 8.0)

NRR Open

(143) CI TVA to confirm the as-built fire protection 

report aligns with as-designed fire protection 

report. Gaps to be submitted to the NRC for 

approval. (SSER 26, Appendix FF, Section 

8.0)

NRR Open

Closed Items

(2) CI Conduct appropriate inspection activities to verify 

cable lengths used in calculations and analysis 

match as-installed configuration. (NRC safety 

evaluation, dated August 31, 2009, ADAMS 

Accession No. ML092151155). Closed in 

Inspection Report 05000391/2013604, dated 

June 27, 2013, ADAMS Accession No. 

ML13179A079.

RII Closed

(3) CI Confirm TVA submitted update to FSAR section 

8.3.1.4.1. (NRC safety evaluation (SE) dated August 

31, 2009, ADAMS Accession No. ML092151155) 

NRR Closed

HH-2
Closed in SSER 24, Section 8.1.

(4) CI Conduct appropriate inspection activities to verify 

that TVA’s maximum SWBP criteria for signal level 

and coaxial cables do not exceed the cable 

manufacturer’s maximum SWBP criteria. (NRC 

safety evaluation, dated August 31, 2009, ADAMS 

Accession No. ML092151155) Closed in Inspection 

Report 0500391/2012602, dated March 27, 2012, 

ADAMS Accession No. ML12087A324.

RII Closed

(5) CI Verify timely submittal of pre-startup core map 

and perform technical review. (TVA letter, dated 

September 7, 2007, ADAMS Accession 

No. ML072570676). By letter dated July 30, 2012, 

TVA provided the pre-startup core map. The 

staff has verified the information and has closed 

Appendix HH Open Items 5 and 8, which came 

from the review of BL 1996-01. 

NRR Closed

(6) CI Verify implementation of TSTF-449. (TVA letter 

dated September 7, 2007, ADAMS Accession 

No. ML072570676). Staff has reviewed Revision I 

to the proposed TSs and found that TSTF 449 has 

been incorporated.

NRR Closed

(7) CI Verify commitment completion and review electrical 

design calculations. (TVA letter dated October 9, 

1990, ADAMS Accession No. ML073551056). 

Closed in Inspection Report 05000391/2013610, 

dated February 14, 2014, ADAMS Accession 

No. ML14049A158.

RII Closed

(8) CI TVA should provide a pre-startup map to the NRC 

staff indicating the rodded fuel assemblies and a 

projected end of cycle burnup of each rodded 

assembly for the initial fuel cycle 6-months prior to 

fuel load. (NRC safety evaluation, dated May 3, 

2010, ADAMS Accession No. ML101200035). By 

letter dated July 30, 2012, TVA provided the 

pre-startup core map. The staff has verified the 

information and has closed Appendix HH Open 

Items 5 and 8, which came from the review of 

BL 1996-01.

NRR Closed

(9) CI Confirm that education and experience of 

management and principal supervisory positions 

down through the shift supervisory level conform to 

Regulatory Guide 1.8. (SSER 22, Section 13.1.3). 

Closed in Inspection Report 0500391/2014603, 

dated May 9, 2014, ADAMS Accession 

No. ML14129A381.

RII Closed

HH-3
(10) CI Confirm that TVA has an adequate number of 

licensed and non-licensed operators in the training 

pipeline to support the preoperational test program, 

fuel loading, and dual unit operation. (SSER 22, 

Section 13.1.3). Closed in Inspection Report 

0500391/2014603, dated May 9, 2014, ADAMS 

Accession No. ML14129A381.

RII Closed

(11) CI The plant administrative procedures should clearly 

state that, when the Assistant Shift Engineer 

assumes his duties as Fire Brigade Leader, his 

control room duties are temporarily assumed by the 

Shift Supervisor (Shift Engineer), or by another 

senior reactor operator, if one is available. The 

plant administrative procedures should clearly 

describe this transfer of control room duties. (SSER 

22, Section 13.1.3) Closed in SSER 25, Section 

13.1.3.

NRR Closed

(12) TVA’s implementation of New Generation 

Development and Construction PP-20 and 

Engineering Document Construction Release 

Appendix J is subject to future NRC audit and 

inspection. (SSER 22, Section 25.9). Closed in 

SSER 27, Section 25.9.

NRR Closed

(13) TVA is expected to submit an inservice testing

program and specific relief requests for WBN, Unit 

2, 9 months before the projected date of OL 

issuance. (SSER 22, Section 3.9.6). Closed in 

SSER 27, Section 3.9.6.

NRR Closed

(14) TVA stated that the Unit 2, Pressure and 

Temperature Limits Report (PTLR) is included in the 

Unit 2, System Description for the Reactor Coolant 

System (WBN2-68-4001), which will be revised to 

reflect required revisions to the PTLR by

September 17, 2010. (SSER 22, Section 5.3.1) 

Closed in SSER 25, Section 5.3.1.

NRR Closed

(15) TVA should confirm to the NRC staff the completion 

of Primary Stress Corrosion Cracking (PWSCC) 

mitigation activities on the Alloy 600 dissimilar metal 

butt welds (DMBWs) in the primary loop piping. 

(SSER 22, Section 3.6.3) Closed in SSER 24, 

Section 3.6.3. 

NRR Closed

(17) The NRC staff should verify the accuracy of the 

WBN, Unit 2, EQ list prior to fuel load. (SSER 22, 

Section 3.11.2.1) Closed in Inspection Report 

05000391/2014615, dated February 13, 2014,

ADAMS Accession No. ML15044A424.

RII/NRR Closed

(18) Based on the extensive layup period of equipment 

within WBN, Unit 2, the NRC staff must review, prior 

to fuel load, the assumptions used by TVA to 

re-establish a baseline for the qualified life of 

RII/NRR Closed

HH-4
equipment. The purpose of the staff’s review is to 

ensure that TVA has addressed the effects of 

environmental conditions on equipment during the 

layup period. (SSER 22, Section 3.11.2.2) Closed 

in Inspection Report 0500391/2011604, dated 

June 29, 2011, ADAMS Accession 

No. ML111810890.

(19) The NRC staff should complete its review of TVA’s 

EQ Program procedures for WBN, Unit 2, prior to 

fuel load. (SSER 22, Section 3.11.2.2.1) Closed in 

Inspection Report 0500391/2011604, dated 

June 29, 2011, ADAMS Accession No. 

ML111810890.

RII/NRR Closed

(20) CI Resolve whether or not routine maintenance 

activities should result in increasing the EQ of the 

6.9 kV motors to Category I status in accordance 

with 10 CFR 50.49. (SSER 22, Section 3.11.2.2.1; 

SSER 24, Section 8.1) Closed in Inspection Report 

0500391/2011605, dated August 5, 2011, ADAMS 

Accession No. ML112201418.

RII/NRR Closed

(21) The NRC staff should confirm that the electrical 

penetration assemblies (EPAs) are installed in the 

tested configuration, and that the feedthrough 

module is manufactured by the same company and 

is consistent with the EQ test report for the EPA. 

(SSER 22, Section 3.11.2.2.1) Closed in Inspection 

Report 05000391/2011607, dated September 30, 

2011, ADAMS Accession No. ML112730197.

RII/NRR Closed

(22) TVA must clarify its use of the term “equivalent” 

(e.g., identical, similar) regarding the replacement 

terminal blocks to the NRC staff. If the blocks are 

similar, then a similarity analysis should be 

completed and presented to the NRC for review. 

(SSER 22, Section 3.11.2.2.1) Closed in SSER 24, 

Section 8.1.

NRR Closed

(23) Resolve whether or not TVA’s reasoning for not 

upgrading the main steam isolation valve solenoid 

valves to Category I is a sound reason to the 

contrary, as specified in 10 CFR 50.49(l). (SSER 

22, Section 3.11.2.2.1; SSER 24, Section 8.1). 

Closed in SSER 27, Section 3.11.2.2.1.

NRR Closed

(24) The NRC staff requires supporting documentation 

from TVA to justify its establishment of a mild 

environment threshold for total integrated dose of 

less than 1x103 rads for electronic components such 

as semiconductors or electronic components 

containing organic material. (SSER 22, Section 

3.11.2.2.1) Closed in SSER 24, Section 8.1.

NRR Closed

HH-5
(26) For the scenario with an accident in one unit and 

concurrent shutdown of the second unit without 

offsite power, TVA stated that Unit 2, preoperational testing will validate the diesel response 

to sequencing of loads on the Unit 2, emergency 

diesel generators (EDGs). The NRC staff will 

evaluate the status of this issue and will update the 

status of the EDG load response in a future SSER. 

(SSER 22, Section 8.1). Closed in SSER 27, 

Section 8.1.

NRR Closed

(27) TVA should provide a summary of margin studies 

based on scenarios described in Section 8.1 for 

CSSTs A, B, C, and D. (SSER 22, Section 8.2.2) 

Closed in SSER 24, Section 8.1. 

NRR Closed

(28) TVA should provide to the NRC staff a detailed 

discussion showing that the load tap changer is able 

to maintain the 6.9 kV bus voltage control band,

given the normal and post-contingency transmission 

operating voltage band, bounding voltage drop on 

the grid, and plant conditions. (SSER 22, 

Section 8.2.2) Closed in SSER 24, Section 8.1. 

NRR Closed

(29) TVA should provide information about the operating 

characteristics of the offsite power supply at the 

Watts Bar Hydro Plant (for dual-unit operation), 

including the operating voltage range, 

postcontingency voltage drops (including bounding 

values and post-unit trip values), and operating 

frequency range. (SSER 22, Section 8.2.2) 

(corrected version of Open Item 29 from SSER 22 

Appendix HH) Closed in SSER 24, Section 8.1.

NRR Closed

(30) TVA should confirm that all other safety-related 

equipment (in addition to the Class 1E motors) will 

have adequate starting and running voltage at the 

most limiting safety-related components (such as 

motor-operated valves (MOVs), contactors, solenoid 

valves or relays) at the degraded voltage relay 

setpoint dropout setting. TVA should also confirm 

that the final Technical Specifications are properly 

derived from these analytical values for the 

degraded voltage settings. (SSER 22, Section 

8.3.1.2) Closed in SSER 28, Section 8.3.1.2.

RII/NRR Closed

(31) TVA should clarify the loading sequence as 

explained in its letter dated December 6, 2010, to 

the staff. TVA should clarify whether the existing 

statements in FSAR regarding automatic 

sequencing logic are correct. If the FSAR 

description is correct, TVA should explain how the 

EDG and logic sequencing circuitry will respond to a 

LOCA followed by a loss-of-offsite power (LOOP)

scenario. (SSER 22, Section 8.3.1.11) (corrected 

NRR Closed

HH-6
version of Open Item 31 from SSER 22 Appendix 

HH) Closed in SSER 24, Section 8.1 

(32) TVA should provide to the NRC staff the details of 

the administrative limits of EDG voltage and speed 

range, and the basis for its conclusion that the 

impact is negligible, and describe how it accounts 

for the administrative limits in the Technical 

Specification surveillance requirements for EDG 

voltage and frequency. (SSER 22, 

Section 8.3.1.14). Closed in SSER 27, Section 8.3.

NRR Closed

(33) CI TVA stated in Attachment 9 of its letter dated July 

31, 2010, that certain design change notices 

(DCNs) are required or anticipated for completion of 

WBN, Unit 2, and that these DCNs were unverified 

assumptions used in its analysis of the 125 volt 

direct current (VDC) vital battery system. 

Verification of completion of these DCNs to the NRC 

staff is necessary prior to issuance of the OL.

(SSER 22, Section 8.3.2.3; SSER 24, Section 8.1) 

Closed in Inspection Report 05000391/2015602, 

dated March 24, 2015, ADAMS Accession 

No. ML15083A276.

RII/NRR Closed

(34) CI TVA stated that the method of compliance with 

Phase I guidelines would be substantially similar to 

the current Unit 1,program and that a new Section 

3.12 will be added to the Unit 2, FSAR that will be 

materially equivalent to Section 3.12 of the current 

Unit 1, FSAR. (SSER 22, Section 9.1.4) Closed in 

SSER 24, Section 9.1.4.

NRR Closed

(35) TVA should provide information to the NRC staff 

that the CCS will produce feedwater purity in 

accordance with BTP Materials Engineering Branch 

5-3 or, alternatively, provide justification for 

producing feedwater purity to another acceptable 

standard. (SSER 22, Section 10.4.6). Closed in 

SSER 27, Section 10.4.6.

NRR Closed

(36) TVA should provide information to the NRC staff to 

enable verification that the SGBS meets the 

requirements and guidance specified in the SER or 

provide justification that the SGBS meets other 

standards that demonstrate conformance to GDC 1 

and GDC 14. (SSER 22, Section 10.4.8) Closed in 

SSER 24, Section 10.4.8. 

NRR Closed

(37) CI The NRC staff will review the combined WBN, Unit 

1, and 2 Appendix C prior to issuance of the Unit 2,

OL to confirm (1) that the proposed Unit 2, changes 

were incorporated into Appendix C, and (2) that 

changes made to Appendix C for Unit 1, since 

Revision 92 and the changes made to the Nuclear 

NSIR Closed

HH-7
Power Radiological Emergency Plan (REP) since 

Revision 92 do not affect the bases of the staff’s 

findings in this SER supplement. (SSER 22, 

Section 13.3.2) Closed in SSER 28, Section 13.3.2.

(38) CI The NRC staff will confirm the availability and 

operability of the ERDS for Unit 2, prior to issuance 

of the Unit 2 OL. (SSER 22, Section 13.3.2.6) 

Closed in Inspection Report 05000391/2014614, 

dated December 29, 2014, ADAMS Accession No. 

ML14363A315.

RII/NSIR Closed

(39) CI The NRC staff will confirm the adequacy of the 

communications capability to support dual unit 

operations prior to issuance of the Unit 2 OL. 

(SSER 22, Section 13.3.2.6) Closed in Inspection 

Report 0500391/2011609, dated December 16, 

2011, ADAMS Accession No. ML11350A229. 

RII/NSIR Closed

(40) CI The NRC staff will confirm the adequacy of the 

emergency facilities and equipment to support dual 

unit operations prior to issuance of the Unit 2, OL.

(SSER 22, Section 13.3.2.8) Closed in Inspection 

Report 05000391/2014614, dated December 29, 

2014, ADAMS Accession No. ML14363A315.

RII/NSIR Closed

(41) CI TVA committed to (1) update plant data displays as 

necessary to include Unit 2, and (2) to update dose 

assessment models to provide capabilities for 

assessing releases from both WBN units. The NRC 

staff will confirm the adequacy of these items prior 

to issuance of the Unit 2 OL. (SSER 22, Section 

13.3.2.9) Closed in Inspection Report 

05000391/2015603, dated May 1, 2015, ADAMS 

Accession No. ML15124A921.

RII/NSIR Closed

(42) CI The NRC staff will confirm the adequacy of the 

accident assessment capabilities to support dual 

unit operations prior to issuance of the Unit 2 OL. 

(SSER 22, Section 13.3.2.9) Closed in Inspection 

Report 0500391/2011609, dated December 16, 

2011, ADAMS Accession No. ML11350A229.

RII/NSIR Closed

(43) CI Section V of Appendix E to 10 CFR Part 50 requires 

TVA to submit its detailed implementing procedures 

for its emergency plan no less than 180 days before 

the scheduled issuance of an OL. Completion of 

this requirement will be confirmed by the NRC staff 

prior to the issuance of an OL. (SSER 22, Section 

13.3.2.18) Closed in SSER 28, Section 13.3.2.18

NSIR Closed

(44) TVA should provide additional information to clarify 

how the initial and irradiated RTNDT was 

determined. (SSER 22, Section 5.3.1) Closed in 

SSER 25, Section 5.3.1.

NRR Closed

HH-8
(45) CI TVA stated in its response to RAI 5.3.2-2, dated 

July 31, 2010, that the PTLR would be revised to 

incorporate the cold overpressure mitigation system

arming temperature. (SSER 22, Section 5.3.2) 

Closed in SSER 25, Section 5.3.2.

NRR Closed

(46) CI The LTOP lift settings were not included in the 

PTLR, but were provided in TVA’s response to RAI 

5.3.2-2 in its letter dated July 31, 2010. TVA stated 

in its RAI response that the PTLR would be revised 

to incorporate the LTOP lift settings into the PTLR.

(SSER 22, Section 5.3.2) Closed in SSER 25, 

Section 5.3.2.

NRR Closed

(47) CI The NRC staff noted that TVA’s changes to 

Section 6.2.6 in FSAR Amendment No. 97, 

regarding the implementation of Option B of 

Appendix J, were incomplete, because several 

statements remained regarding performing watersealed valve leakage tests “as specified in 

10 CFR [Part] 50, Appendix J.” With the adoption of 

Option B, the specified testing requirements are no 

longer applicable; Option A to Appendix J retains 

these requirements. The NRC discussed this 

discrepancy with TVA in a telephone conference on 

September 28, 2010. TVA stated that it would 

remove the inaccurate reference to Appendix J for 

specific water testing requirements in a future FSAR 

amendment. (SSER 22, Section 6.2.6) Closed in 

SSER 26, Section 6.2.6.

NRR Closed

(48) CI The NRC staff should verify that its conclusions in 

the review of FSAR Section 15.4.1 do not affect the 

conclusions of the staff regarding the acceptability 

of Section 6.5.3. (SSER 22, Section 6.5.3) Closed 

in SSER 26, Section 6.5.3.

NRR Closed

(49) CI The NRC staff was unable to determine how TVA 

linked the training qualification requirements of 

ANSI N45.2-1971 to TVA Procedure Technical 

Instruciton (TI)-119. Therefore, the implementation 

of training and qualification for inspectors will be the 

subject of future NRC staff inspections. (NRC letter 

dated July 2, 2010, ADAMS Accession No. 

ML101720050). Closed in Inspection Report 

0500391/2014602, dated March 27, 2014, ADAMS 

Accession No. ML14086A063.

RII Closed

(50) CI TVA stated that about 5 percent of the anchor bolts 

for safety-related pipe supports do not have quality 

control documentation, because the pull tests have 

not yet been performed. Since the documentation is 

still under development, the NRC staff will conduct 

inspections to follow-up on the adequate 

implementation of this construction refurbishment 

RII Closed

HH-9
program requirement. (NRC letter dated July 2, 

2010, ADAMS Accession No. ML101720050) 

Closed in Inspection Report 0500391/2013612, 

dated March 28, 2013, ADAMS Accession 

No. ML13088A066.

(51) CI The implementation of TVA Procedure TI-119 will 

be the subject of NRC follow-up inspection to 

determine if the construction refurbishment program 

requirements are being adequately implemented. 

(NRC letter dated July 2, 2010, ADAMS Accession 

No. ML101720050). Closed in Inspection Report 

0500391/2014602, dated March 27, 2014, ADAMS 

Accession No. ML14086A063.

RII Closed

(52) 

through 

(58)

Not used.

(59) The staff’s evaluation of the compatibility of the ESF 

system materials with containment sprays and core 

cooling water in the event of a LOCA is incomplete 

pending resolution of Generic Safety Issue-191 for 

WBN, Unit 2. (SSER 23, Section 6.1.1.4). Closed 

in SSER 27, Section 6.1.

NRR Closed

(60) CI TVA should amend the FSAR description of the 

design and operation of the spent fuel pool cooling 

and cleanup system in FSAR Section 9.1.3 as 

proposed in its December 21, 2010, letter to the 

NRC. (SSER 23, Section 9.1.3) Closed in 

SSER 26, Section 9.1.3.

NRR Closed

(61) TVA should provide information to the NRC staff to 

demonstrate that Performance Analysis and Design 

(PAD) 4.0 can conservatively calculate the fuel 

temperature and other impacted variables, such as 

stored energy, given the lack of a fuel thermal 

conductivity degradation model. (SSER 23, Section 

4.2.2). Closed in SSER 27, Section 4.2.

NRR Closed

(62) CI Confirm TVA’s change to FSAR Section 10.4.9 to 

reflect its intention to operate with each condensate 

storage tank isolated from the other. (SSER 23, 

Section 10.4.9) Closed in SSER 24, Section 10.4.9.

NRR Closed

(63) CI TVA should confirm to the NRC staff that testing 

prior to Unitt 2 fuel load has demonstrated that twoway communications is impossible with the Eagle 

21 communications interface. (SSER 23, Section 

7.2.1.1). Closed in SSER 27, Section 7.2.

RII Closed

(64) CI TVA stated that, “Post modification testing will be 

performed to verify that the design change corrects 

the Eagle 21, Rack 2 resistance temperature 

detector accuracy issue prior to WBN, Unit 2 fuel 

load.” This issue is open pending NRC staff review 

of the testing results. (SSER 23, Section 7.2.1.1). 

RII Closed

HH-10
Closed in Inspection Report 05000391/2014602, 

dated March 27, 2014, ADAMS Accession No. 

ML14086A063.

(65) TVA should provide justification to the staff 

regarding why different revisions of Westinghouse 

Commercial Atomic Power-13869 are referenced in 

WBN, Units 1 and 2. (SSER 23, Section 7.2.1.1) 

Closed in SSER 26, Section 7.2.1.1.

NRR Closed

(66) CI TVA should clarify FSAR Section 9.2.5 to add the 

capability of the ultimate heat sink to bring the 

nonaccident unit to cold shutdown within 72 hours. 

(SSER 23, Section 9.2.5). Closed in SSER 27, 

Section 9.2.5.

NRR Closed

(67) CI TVA should confirm, and the NRC staff should 

verify, that the component cooling booster pumps 

for Unit 2 are above probable maximum flood level. 

(SSER 23, Section 9.2.2). Closed in SSER 27, 

Section 9.2.2 and Inspection Report 

05000391/2014615, dated February 13, 2014,

ADAMS Accession No. ML15044A424.

NRR Closed

(68) Not used.

(69) CI The WBN, Unit 2, reactor coolant system (RCS)

vent system is acceptable, pending verification that 

the RCS vent system is installed. (SSER 23, 

Section 5.4.5) Closed in Inspection Report 

05000391/2014614, dated December 29, 2014,

ADAMS Accession No. ML14363A315.

RII Closed

(70) TVA should provide the revised WBN, Unit 2,

preservice inspection program ASME Class 1, 2, 

and 3 Supports “Summary Tables,” to include 

numbers of components so that the NRC staff can 

verify that the numbers meet the reference ASME 

Code. (Section 3.2.3 of Appendix Z of SSER 23). 

Closed in SSER 27, Section 3.2.3 of Appendix Z.

NRR Closed

(71) By letter dated April 21, 2011 (ADAMS Accession 

No. ML111110513), TVA withdrew its commitment 

to replace the Unit 2 clevis insert bolts. TVA should 

provide further justification for the decision to not 

replace the bolts to the NRC staff. (SSER 23, 

Section 3.9.5) Closed in SSER 26, Section 3.9.5.

NRR Closed

(72) The NRC staff should complete its review and 

evaluation of the additional information provided by 

TVA regarding the inadequate core cooling

instrumentation. (SSER 23, Section 4.4.8) Closed 

in SSER 25, Section 7.5.2.2.

NRR Closed

(73) CI The NRC staff will inspect to confirm that TVA has 

completed the WBN, Unit 2, emergency operating 

procedures (EOPs) prior to fuel load. (SSER 23, 

Section 7.5.3). Closed in Inspection Report 

RII Closed

HH-11
05000391/2014604, dated June 25, 2014, ADAMS 

Accession No. ML14177A214.

(74) CI The NRC staff will verify installation of the acousticmonitoring system for the power-operated relief 

valve (PORV) position indication in WBN, Unit 2,

before fuel load. (SSER 23, Section 7.8.1) Closed 

in Inspection Report 05000391/2015604, dated 

June 29, 2015, ADAMS Accession No. 

ML15181A446.

RII Closed

(76) CI The NRC staff will verify that the derivative time 

constant is set to zero in WBN, Unit 2, before fuel 

load. (SSER 23, Section 7.8.3) Closed in 

Inspection Report 05000391/2011607, dated 

September 30, 2011, ADAMS Accession 

No. ML112730197.

RII Closed

(77) It is unclear to the NRC staff which software

verification and validation (V&V) documents are 

applicable to the HRCAR monitors. TVA should 

clarify which software V&V documents are 

applicable, in order for the staff to complete its 

evaluation. (SSER 23, Section 7.5.2.3) Closed in 

SSER 26, Section 7.5.2.3.4

NRR Closed

(78) TVA intends to issue a revised calculation reflecting 

that the total integrated dose in the control room is 

less than 1×103 rads, which will be evaluated by the 

NRC staff. (SSER 23, Section 7.5.2.3) Closed in 

SSER 25, Section 7.5.2.3.

NRR Closed

(80) TVA should provide clarification to the staff on how 

TVA Standard Specification SS-E18-14.1 meets the 

guidance of Regulatory Guide (RG) 1.180, and 

should address any deviations from the guidance of 

the RG. (SSER 23, Section 7.5.2.3). Closed in 

SSER 27, Section 7.5.2.3.

NRR Closed

(81) The extent to which TVA’s supplier, General 

Atomics (GA), complies with Electric Power 

Research Institute TR-106439 and the methods that 

General Atomics used for its commercial dedication 

process should be provided by TVA to the NRC staff 

for review. (SSER 23, Section 7.5.2.3) Closed in 

SSER 26, Section 7.5.2.3.4.

NRR Closed

(82) The staff concluded that the information provided by 

TVA pertaining to the in-containment loose part 

monitoring system equipment qualification for 

vibration was incomplete. TVA should provide (item 

number 362 of ADAMS Accession No. 

ML111050009), documentation that demonstrates 

the loose part monitoring system in-containment 

equipment has been qualified to remain functional in 

its normal operating vibration environment, per RG 

NRR Closed

HH-12
1.133, Revision 1. (SSER 23, Section 7.6.1) 

Closed in SSER 24, Section 7.6.1.4.5.

(84) 

through 

(89)

Not used.

(91) TVA should update the FSAR with information 

describing how WBN, Unit 2, meets GDC 5, 

assuming the worst case single failure and a LOOP, 

as provided in TVA’s letter dated April 13, 2011. 

(SSER 23, Section 9.2.1). Closed in SSER 27, 

Section 9.2.1.

NRR Closed

(92) Not used.

(93) TVA should confirm to the staff that testing of the 

Eagle 21 system has sufficiently demonstrated that 

two-way communication to the ICS is precluded with 

the described configurations. (SSER 23, 

Section 7.9.3.2). Closed in SSER 27, Section 7.9.

RII Closed

(94) TVA should provide to the staff either information 

that demonstrates that the WBN, Unit 2, Common Q 

post-accident monitoring system (PAMS) meets the 

applicable requirements in Institute of Electrical and 

Electronics Engineers (IEEE) Std. 603-1991, or 

justification for why the Common Q PAMS should 

not meet those requirements. (SSER 23, Section 

7.5.2.2.3) Closed in SSER 26, Section 7.5.2.2.

NRR Closed

(95) TVA should update FSAR Table 7.1-1, “Watts Bar 

Nuclear Plant NRC Regulatory Guide 

Conformance,” to reference IEEE Std. 603-1991 for 

the WBN, Unit 2, Common Q PAMS. (SSER 23, 

Section 7.5.2.2.3) Closed in SSER 25, Section 

7.5.2.2.

NRR Closed

(96) TVA should (1) update FSAR Table 7.1-1 to include 

RG 1.100, Revision 3, for the Common Q PAMS, or 

(2) demonstrate that the Common Q PAMS is in 

conformance with RG 1.100, Revision 1, or provide 

justification for not conforming. (SSER 23, 

Section 7.5.2.2.3) Closed in SSER 25, Section 

7.5.2.2.

NRR Closed

(97) TVA should demonstrate that the WBN, Unit 2,

Common Q PAMS is in conformance with 

RG 1.153, Revision 1, or provide justification for not 

conforming. (SSER 23, Section 7.5.2.2.3) Closed 

in SSER 25, Section 7.5.2.2.

NRR Closed

(98) TVA should demonstrate that the WBN, Unit 2,

Common Q PAMS is in conformance with 

RG 1.152, Revision 2, or provide justification for not 

conforming. (SSER 23, Section 7.5.2.2.3) Closed 

in SSER 26, Section 7.5.2.2.3.

NRR Closed

HH-13
(99) TVA should update FSAR Table 7.1-1 to reference 

IEEE 7-4.3.2-2003 as being applicable to the WBN, 

Unit 2, Common Q PAMS. (SSER 23, Section 

7.5.2.2.3; SSER 25, Section 7.5.2.2) Closed in 

SSER 25, Section 7.5.2.2.

NRR Closed

(100) TVA should update FSAR Table 7.1-1 to reference 

RG 1.168, Revision 1; IEEE 1012-1998; and IEEE 

1028-1997 as being applicable to the WBN, Unit 2,

Common Q PAMS. (SSER 23, Section 7.5.2.2.3) 

Closed in SSER 25, Section 7.5.2.2.

NRR Closed

(101) TVA should demonstrate that the WBN, Unit 2,

Common Q PAMS application software is in 

conformance with RG 1.168, Revision 1, or provide 

justification for not conforming. (SSER 23, 

Section 7.5.2.2.3) Closed in SSER 26, 

Section 7.5.2.2.

NRR Closed

(102) TVA should update FSAR Table 7.1-1 to reference 

RG 1.209 and IEEE Std. 323-2003 as being 

applicable to the WBN, Unit 2, Common Q PAMS. 

(SSER 23, Section 7.5.2.2.3) Closed in SSER 25, 

Section 7.5.2.2.

NRR Closed

(103) TVA should demonstrate that the WBN, Unit 2,

Common Q PAMS conforms to RG 1.209 and IEEE 

Std. 323-2003, or provide justification for not 

conforming. (SSER 23, Section 7.5.2.2.3) Closed 

in SSER 25, Section 7.5.2.2.

NRR Closed

(104) CI The NRC staff will review the Westinghouse Electric 

Corporation self-assessment to verify that it the 

WBN, Unit 2, PAMS is compliant to the V&V 

requirements in the software program manual or 

that deviations from the requirements are 

adequately justified. (SSER 23, Section 

7.5.2.2.3.4.2) Closed in SSER 25, Section 7.5.2.2.

NRR Closed

(105) TVA should produce an acceptable description of 

how the WBN, Unit 2, Common Q PAMS System 

Requirements Specification and software 

requirements specification (SRS) implement the 

design-basis requirements of IEEE Std. 603-1991 

Clause 4. (SSER 23, Section 7.5.2.2.3.4.3.1) 

Closed in SSER 26, Section 7.5.2.2.

NRR Closed

(106) TVA should produce a final WBN, Unit 2, Common 

Q PAMS SRS that is independently reviewed. 

(SSER 23, Section 7.5.2.2.3.4.3.1) Closed in 

SSER 25, Section 7.5.2.2.

NRR Closed

(107) CI TVA should provide to the NRC staff documentation 

to confirm that the final WBN, Unit 2, Common Q 

PAMS software design descriptions that are 

independently reviewed. (SSER 23, Section 

7.5.2.2.3.4.3.2) Closed in SSER 25, Section 

7.5.2.2.

NRR Closed

HH-14
(108) TVA should demonstrate to the NRC staff that there 

are no synergistic effects between temperature and 

humidity for the Common Q PAMS equipment. 

(SSER 23, Section 7.5.2.2.3.5.2) Closed in 

SSER 26, Section 7.5.2.2.

NRR Closed

(109) TVA should demonstrate to the NRC staff 

acceptable data storm testing of the Common Q 

PAMS. (SSER 23, Section 7.5.2.2.3.7.1.8) Closed 

in SSER 25, Section 7.5.2.2.

NRR Closed

(110) TVA should provide information to the NRC staff 

describing how the WBN, Unit 2, Common Q PAMS 

design supports periodic testing of the RVLIS 

function. (SSER 23, Section 7.5.2.2.3.9.2.6) 

Closed in SSER 26, Section 7.5.2.2.

NRR Closed

(111) TVA should confirm to the staff that there are no 

changes required to the TSs as a result of the 

modification installing the Common Q PAMS. If any 

changes to the TSs are required, TVA should 

provide the changes to the NRC staff for review. 

(SSER 23, Section 7.5.2.2.3.11) Closed in SSER 

26, Section 7.5.2.2.

NRR Closed

(112) CI TVA should provide an update to the FSAR 

reflecting the radiation protection design features 

descriptive information provided in its letter dated 

October 4, 2010. (SSER 24, Section 12.4) Closed 

in SSER 26, Section 12.4.

NRR Closed

(113) CI TVA should provide an update to the FSAR 

reflecting the justification for the periodicity of the 

channel operability test frequency for WBN nonsafety-related area radiation monitors. (SSER 24, 

Section 12.4) Closed in SSER 26, Section 12.4.

NRR Closed

(114) CI TVA should update the FSAR to reflect that WBN 

meets the radiation monitoring requirements of 

10 CFR 50.68. (SSER 24, Section 12.4) Closed in 

SSER 26, Section 12.4.

NRR Closed

(115) CI TVA should update the FSAR to reflect the 

information regarding design changes to be 

implemented to lower radiation levels as provided in 

its letter to the NRC dated June 3, 2010. (SSER 24, 

Section 12.5). Closed in SSER 27, Section 12.5

NRR Closed

(116) CI TVA should update the FSAR to reflect the 

qualification standards of the radiation protection 

manager as provided in its letter to the NRC dated 

October 4, 2010. (SSER 24, Section 12.6) Closed 

in SSER 26, Section 12.6.

NRR Closed

(117) CI TVA should update the FSAR to reflect the 

calculational basis for access to vital areas as 

provided in its letter dated February 25, 2011. 

(SSER 24, Section 12.7.1). Closed in SSER 27, 

Section 12.7.1

NRR Closed

HH-15
(118) TVA should provide to the NRC staff a description of 

how the other vanadium detectors within the in-core 

instrumentation thimble assembly (IITA) would be 

operable following the failure of a self-powered 

neutron detector (SPND). (SSER 24, Section 

7.7.1.9.2) Closed in SSER 26, Section 7.7.1.9.

NRR Closed

(119) TVA should submit WNA-CN-00157-WBT, 

Revision 0, to the NRC by letter. The NRC staff 

should confirm by review of WNA-CN-00157-WBT, 

Revision 0, that no credible source of faulting can 

negatively impact the CETs or PAMS train. 

(SSER 24, Section 7.7.1.9.5) Closed in SSER 25, 

Section 7.7.1.9.

NRR Closed

(120) TVA must confirm to the NRC staff that the 

maximum over-voltage or surge voltage that could 

affect the system is 264 VAC, assuming that the

power supply cable to the signal processing system 

(SPS) cabinet is not routed with other cables greater 

than 264 VAC. (SSER 24, Section 7.7.1.9.5; SSER 

25, Section 7.7.1.9) Closed in SSER 26, Section 

7.7.1.9.

NRR Closed

(121) TVA should submit the results to the NRC staff of a 

600 VDC dielectric strength test performed on the 

IITA assembly. (SSER 24, Section 7.7.1.9.5) 

Closed in SSER 26, Section 7.7.1.9.

NRR Closed

(122) TVA should confirm to the NRC staff that different 

divisions of safety power are supplied to the in-core 

instrumentation system SPS cabinets, with the 

power cables routed in separate shielded conduits. 

(SSER 24, Section 7.7.1.9.5) Closed in SSER 25, 

Section 7.7.1.9.

NRR Closed

(123) TVA should provide an explanation to the NRC staff 

of how the system will assign a data quality value to 

notify the power distribution calculation software to 

disregard data from a failed SPND. (SSER 24, 

Section 7.7.1.9.5) Closed in SSER 26, 

Section 7.7.1.9.

NRR Closed

(124) While the BEACON datalink on the Application 

server can connect to either BEACON machine, 

only BEACON A is used for communication. TVA 

should clarify to the NRC staff whether automatic 

switchover to the other server is not permitted. 

(SSER 24, Section 7.7.1.9.5) Closed in SSER 25, 

Section 7.7.1.9.

NRR Closed

(125) TVA should provide clarification to the NRC staff of 

the type of connector used with the MI cable in 

Unit 2, and which EQ test is applicable. (SSER 24, 

Section 7.7.1.9.5) Closed in SSER 26, 

Section 7.7.1.9.

NRR Closed

HH-16
(126) To enable the NRC staff to evaluate and review the 

IITA EQ, TVA should provide the summary report of 

the EQ for the IITA. (SSER 24, Section 7.7.1.9.5) 

Closed in SSER 26, Section 7.7.1.9.

NRR Closed

(127) TVA should provide a summary to the NRC staff of

the electro-magnetic interference/radio-frequency 

interference testing for the MI cable electro-

magnetic compatibility (EMC) qualification test 

results. (SSER 24, Section 7.7.1.9.5) Closed in 

SSER 26, Section 7.7.1.9.

NRR Closed

(128) TVA should submit the seismic qualification test 

report procedures and results for the SPS cabinets 

to the NRC staff for review. (SSER 24, 

Section 7.7.1.9.5) Closed in SSER 25, 

Section 7.7.1.9.

NRR Closed

(129) TVA should verify to the NRC staff resolution of the 

open item in WNA-CN-00157-WBT for the Quint 

power supply (to be installed in the SPS cabinet) to 

undergo EMC testing of 4 kV to validate the 

assumptions made in the Westinghouse analysis. 

(SSER 24, Section 7.7.1.9.5) Closed in SSER 26, 

Section 7.7.1.9.

NRR Closed

(130) TVA should provide a summary to the NRC staff of 

the EMC qualification test results of the SPS 

cabinets. (SSER 24, Section 7.7.1.9.5) Closed in 

SSER 25, Section 7.7.1.9.

NRR Closed

(131) TVA should review the EOP action level setpoint to 

account for the difference between core exit 

temperature readings for Units1 and 2, and confirm 

the EOP action level setpoint to the NRC staff. 

(SSER 24, Section 7.7.1.9.5). Closed in SSER 27, 

Section 7.7.

NRR Closed

(132) TVA must provide the NRC staff with analyses of 

the boron dilution event that meet the criteria of 

Standard Review Plan (SRP) Section 15.4.6, 

including a description of the methods and 

procedures used by the operators to identify the 

dilution path(s) and terminate the dilution, in order 

for the staff to determine that the analyses comply 

with GDC 10. (SSER 24, Section 15.2.4.4) Closed 

in SSER 26, Section 15.2.4.4.

NRR Closed

(133) In order to confirm the stability analysis of the sand 

baskets used by TVA in the WBN, Unit 2, licensing 

basis, TVA will perform either a hydrology analysis 

without crediting the use of the sand baskets at the 

Fort Loudoun Dam for the seismic dam failure and 

flood combination, or TVA will perform a seismic 

test of the sand baskets, as stated in TVA’s letter 

dated April 20, 2011. TVA will report the results of 

this analysis or test to the NRC by 

NRR Closed

HH-17
October 31, 2011. (SSER 24, Section 2.4.10). 

Closed in SSER 27, Section 2.4.10.

(134) TVA should provide to the NRC staff supporting 

technical justification for the statements in 

Amendment No. 104 of FSAR Section 2.4.4.1, “Dam 

Failure Permutations,” page 2.4-32 (in the section 

“Multiple Failures”) that, “Fort Loudoun, Tellico, and 

Watts Bar have previously been judged not to fail for 

the operating basis earthquake (OBE) (0.09 g). 

Postulation of Tellico failure in this combination has 

not been evaluated but is bounded by the SSE [safe 

shutdown earthquake] failure of Norris, Cherokee, 

Douglas and Tellico.” (SSER 24, Section 2.4.10) 

Closed in SSER 28, Section 2.4.10

NRR Closed

(135) TVA has not provided the analysis required by 

10 CFR Part 50, Appendix I, subsection II.D. TVA 

must demonstrate with a cost-benefit analysis that a 

sufficient reduction in the collective dose to the 

public within a 50-mile radius would not be achieved 

by reasonable changes to the design of the WBN 

gaseous effluent processing systems. (SSER 24, 

Section 11.3) Closed in SSER 25, Section 11.3.

NRR Closed

(136) CI The joinst frequency distribution summary for the 

data from 1991 through 2010 provided by letter 

dated November 7, 2011, and a discussion of the 

long-term representativeness of these data should 

be provided in the WBN, Unit 2, FSAR. Upon 

receipt of the UFSAR, the NRC staff will confirm that 

these updates have been made by TVA. (SSER 25, 

Section 2.3.3) Closed in SSER 26, Section 2.3.3.

NRR Closed

(137) CI The NRC staff will confirm, upon receipt, that TVA 

integrated the updated control room atmospheric 

diversion estimate (χ/Q) values from its letter dated 

September 15, 2011, into a future amendment of 

the FSAR. (SSER 25, Section 2.3.4) Closed in 

SSER 26, Section 2.3.4.

NRR Closed

(138) CI Upon receipt of the updated Offsite Dose 

Calculation Manual (ODCM), the NRC staff will 

confirm that corresponding revisions related to the 

updated annual average χ/Q and deposition factor

values have been made to the ODCM. (SSER 25, 

Section 2.3.5) Closed in SSER 26, Section 2.3.5.

NRR Closed

(139) CI The results of the cost-benefit analysis required by 

10 CFR Part 50, Appendix I, subsection II.D, should 

be provided in the WBN, Unit 2, FSAR. Upon 

receipt of the UFSAR, the NRC staff will confirm that 

the update has been made by TVA. (SSER 25, 

Section 11.3). Closed in SSER 27, Section 11.3

NRR Closed

HH-18
APPENDIX II COMPLIANCE WITH TITLE 10 OF THE CODE OF 

FEDERAL REGULATIONS 50.54(hh)(2) REQUIREMENTS

II.1 Introduction

II.1.1 Purpose

This appendix documents the U.S. Nuclear Regulatory Commission (NRC) staff’s regulatory 

assessment of the adequacy of the actions taken by Tennessee Valley Authority (TVA) to meet 

the requirements of paragraph (i) of Title 10 of the Code of Federal Regulations (10 CFR),

Section 50.34, “Contents of applications; technical information,” regarding the guidance and 

strategies required by paragraph (hh)(2) of 10 CFR 50.54, “Conditions of licenses.” This 

appendix describes the basis for finding TVA’s strategies adequate. 

II.1.2 Background

The NRC issued EA-02-026, “Order for Interim Safeguards and Security Compensatory 

Measures” (Interim Compensatory Measures (ICM) Order), which imposed interim 

compensatory measures on power reactor licensees. ICM Order, Section B.5.b, “Mitigative 

Measures,” required the development of, “specific guidance and strategies to maintain or 

restore core cooling, containment, and spent fuel pool (SFP) cooling capabilities using existing 

or readily available resources (equipment and personnel) that can be effectively implemented 

under the circumstances associated with loss of large areas of plant due to explosions or fire.” 

These actions were to be implemented by the end of August 2002. Inspections of the 

implementation of the B.5.b requirements were conducted in 2002 and 2003 (Temporary 

Instruction (TI) 2515/148). The inspections identified large variability in scope and depth of the 

enhancements made by licensees. As a result, the NRC determined that additional guidance 

and clarification was needed for nuclear power plant licensees.

Subsequent to the conduct of the inspections, the NRC Office of Nuclear Regulatory Research 

(RES) conducted engineering studies, which provided insights into the implementation of 

mitigation strategies to address the loss of large areas of a plant due to explosions or fire, 

including those that an aircraft impact might create. The NRC actions resulting from those 

studies included (1) NRC inspections of licensee actions that address plant-specific 

consequences, (2) NRC advisories distributed to the industry that involve processes and 

protocols for licensee notification of an imminent aircraft threat, and (3) the identification of 

mitigative measures to enhance spent fuel cooling and to prevent or ameliorate fuel damage for 

events in which significant SFP damage may occur. The spent fuel cooling and damage 

mitigative measures were described in an NRC letter to licensees.

The NRC issued a letter to licensees providing information on the Commission’s phased 

approach for enhancing reactor mitigative measures and strategies for responding to 

Section B.5.b of the ICM Order. The NRC subsequently issued guidance (the “Guidance 

Document”) to more fully describe the NRC staff’s expectations for implementing Section B.5.b 

of the ICM Order.

II-1
The Guidance Document relied upon lessons learned from RES studies involving plant 

assessments, as well as industry best practices. These best practices were identified during the 

inspections conducted in 2002 and 2003. The Guidance Document also incorporated industry 

comments made at two B.5.b-related workshops held on January 14, 2005, and February 2, 

2005.

II.2 Regulatory Evaluation

II.2.1 Three Phase Concept

Section B.5.b of the ICM Order required licensees to develop specific guidance and strategies 

to maintain or restore core cooling, containment, and SPF cooling capabilities, using existing or 

readily available resources (equipment and personnel) that can be effectively implemented 

under the circumstances associated with loss of large areas of the plant due to explosions or 

fire. Determination of the specific strategies required to satisfy the ICM Order elaborated on by 

the Guidance Document was termed Phase 1. 

The NRC determined that differences in plant design and configuration warranted independent 

assessments to verify that the likelihood of damage to the reactor core, containment, and SFPs,

and the release of radioactivity, is low at each nuclear power plant to assure public health and 

safety. The Commission directed the NRC staff to conduct site-specific security and safety 

assessments to further identify and implement enhanced mitigating capabilities. The scope of

these site-specific assessments included a broad range of pre-determined, non-threat-specific 

damage footprints that encompassed a spectrum of potential threats (e.g., land attack, vehicle 

or waterborne bombs, and impact of a large commercial aircraft). The effort involving sitespecific assessments of SFPs is referred to as Phase 2 and that for site-specific assessments of 

reactor core and containments is referred to as Phase 3.

SRM-M050421B-SUPP stated that the goals of the Phase 2 and 3 assessments were for the 

NRC and licensees to achieve a new level of cognition of safety and security through a 

comprehensive understanding of the capabilities and limitations of the plants under normal, 

abnormal, and severe circumstances (from whatever cause) and that based on this improved 

understanding, licensees have taken reasonable steps to strengthen their capabilities and 

reduce their limitations. The Commission expected that safety and security will be well-served 

by further enhancing the licensee’s severe accident management strategies for mitigating a 

wide spectrum of events through the use of readily available resources and by identifying 

potential practicable areas for the use of beyond-readily-available resources.

During 2005, the NRC staff performed inspections to determine licensees’ compliance with 

B.5.b (Phase 1). Subsequent meetings were held with licensees to resolve identified open 

issues. Confirmatory B.5.b Phase 1 inspections were conducted during the period of July to 

December 2006. The NRC staff conducted site visits as part of the Phase 2 assessments 

during 2005. In 2006, the NRC staff observed licensee Phase 3 studies and conducted 

independent Phase 3 assessments.

The Nuclear Energy Institute (NEI) submitted a letter describing an industry proposal for 

resolving (“closing”) Phase 2. The industry proposed high level functional mitigating strategies 

for a spectrum of potential scenarios involving postulated damage to SPFs. In a letter to all 

holders of licenses for operating power reactors, the NRC accepted the Phase 2 proposal,

pending review of site-specific details of its application and implementation. In arriving at this 

II-2
conclusion, the NRC staff placed significant weight on portions of the proposal that rely on 

industry commitments to provide beyond readily available measures not previously available. 

These additions will significantly enhance licensees’ mitigating strategies capabilities.

NEI proposed language to clarify Phase 1, expectation B.2.m.1, regarding spent fuel dispersal. 

The proposal stated that where feasible and practical, consistent with safe fuel handling 

practices, licensees would make every attempt to pre-configure the SPF to enable direct 

placement of the expended assemblies from the vessel to the final distributed fuel pattern. 

Further, the proposal stated that where this is not feasible or practical, licensees would 

distribute the fuel into the final pattern as soon as possible but no later than 60 days after 

subcriticality absent extenuating circumstances. By letter dated March 16, 2006, the NRC staff

agreed with the NEI proposal, including the stated considerations involving extended outages 

for major component replacement. The letter also noted the NRC staff's concern that it is 

important to minimize the time that fuel is not in a favorable configuration and each licensee’s

efforts to achieve a favorable configuration in the shortest time is an appropriate goal that 

provides for improved safety for the storage of spent fuel.

NEI submitted two letters, one of which proposed a license condition to capture the B.5.b 

requirements and addressed items deferred from Phase 1 to 2. The license condition included

14 items in the same broad categories as the February 2005 Guidance Document; firefighting 

response strategy, plant operations to mitigate fuel damage, and actions to minimize releases. 

The proposal suggested that implementing details found to be acceptable means of meeting the 

license condition would be treated as commitments and managed in accordance with 

NEI 99-04, “Guidelines for Managing NRC Commitment Changes.” The other letter proposed 

generic strategies for closure of Phase 3. The required strategies for all three phases would be 

covered by the license condition, and all implementing details would be managed by NEI 99-04.

The Guidance Document included 34 expectations. Two of these items were deferred to 

Phase 2 and seven items (i.e., six expectations and one element of a seventh expectation) were 

deferred to Phase 3. The NRC staff reached agreement with licensees on the non-deferred 

items under Phase 1.

The two items deferred to Phase 2 were:

B.2.m.4 Enhanced air circulation

B.2.m.5 Emergency pool makeup, leak reduction/repair

One of the two NEI letters discussed above provided a generic response to B.2.m.4 and the 

leak reduction/repair aspect of B.2.m.5. The response stated that these two items did not add 

value, given the significantly greater benefits of the proposed strategies; however, NEI 

committed to work with the industry to ensure that damage control measures would be 

incorporated in plant procedures and guidance. This was apparent from review of the 

subsequent licensee submittals. Regarding building ventilation, the NRC staff believes that it 

would be beneficial for some scenarios, but that, on balance, fuel dispersal and the internal and 

external spray strategies are sufficient to meet the goals stated in SRM-M050421B-SUPP. The 

emergency pool makeup aspect was the prime focus of the Phase 2 assessments. Thus, these 

two items were satisfied by accomplishing the Phase 2 assessments.

The items deferred to Phase 3 were:

II-3
B.2.c Procedures for firefighting and recovery operations,

B.2.d Evaluation of vulnerable buildings and equipment,

B.2.g Best practice for use of plant equipment (portable diesel and transformer element only),

B.2.f Industry best practice for compensatory function,

B.2.i Best practice involving plant areas potentially affected by fire or explosions,

B.2.j Best practice for use of plant equipment - portable generator and transformer, and

B.3.c Dose projection.

These items were intrinsic to the Phase 3 licensee studies and the NRC’s independent 

assessments. Most of the plant-specific and generic strategies fall into one or more of these 

categories. None of the generic strategies mapped directly to B.2.i or B.3.c, but equipment 

survivability and dose projection were inseparable from the process of identifying the strategies 

and evaluating their confidence level.

SRM-M060607 states, “The staff should work expeditiously with appropriate stakeholders to 

establish an effective method of capturing the February 25, 2002 B.5.b. order requirements (i.e., 

those reasonable, evident strategies that fall within the scope of the B.5.b. guidance issued on 

February 25, 2005) in each plant’s license, security plan, or other appropriate regulatory 

document. Other strategies are to be considered for voluntary implementation and managed in 

accordance with the licensee’s commitment management program.” By letter dated June 29, 

2006, the NRC staff conditionally accepted NEI’s proposed license condition and strategies 

(ADAMS Accession No. ML061790306). The letter reiterated that mitigation strategies in NEI’s 

proposals that were identified during the Phases 2 and 3 assessments, which utilize reasonable, 

evident, readily available measures (as identified in the February 25, 2005, guidance document) 

are required pursuant to Section B.5.b of the order. The implementing details of the required 

strategies would be implemented by commitment and managed in accordance with the NEI 

commitment management guideline, NEI 99-04. The NRC staff believes the NEI proposal 

reasonably justifies excluding from formal regulatory controls those additional strategies 

identified during the site-specific Phases 2 and 3 assessments that the NRC previously deemed 

required under Section B.5.b of the order, but not identified in NEI’s proposals. Inherent in this 

conclusion is recognition of the addition of beyond readily available measures included in the 

proposals. The implementing details of mitigation strategies included in the proposal, including 

those that utilize beyond readily available resources, would be treated as commitments, which 

become part of the licensing basis of the plant. Additional strategies identified during sitespecific assessments, which licensees deem acceptable and valuable to promote diversification 

and survivability, would be incorporated into licensees’ Severe Accident Management 

Guidelines, Extreme Damage Mitigation Guidelines, or appended to other site implementation 

guidance. Acceptance for individual facilities was conditional upon staff evaluation of sitespecific implementation and documentation of the proposed Phases 2 and 3 mitigating 

strategies that this safety evaluation (SE) provides for Watts Bar Nuclear Plant, Unit 2.

By publishing new requirements in the Federal Register dated March 27, 2009 (74 FR 13926), 

the NRC amended 10 CFR Part 50, 10 CFR Part 52, “Licenses, Certifications, and Approvals 

for Nuclear Power Plants,” and 10 CFR Part 73, “Physical Protection of Plants and Materials.” 

This rulemaking added paragraph (i) to 10 CFR 50.34, “Contents of Applications; Technical 

Information,” and paragraph (d) to 10 CFR 52.80 “ Contents of Applications; Additional 

Technical Information,” to require submittal of a “description and plans for implementation of the 

guidance and strategies intended to maintain or restore core cooling, containment, and SFP

cooling capabilities under the circumstances associated with the loss of large areas of the plant 

due to explosions or fire as required by § 50.54(hh)(2) of this chapter.” This rulemaking also 

II-4
added 10 CFR 50.54(hh)(2) to impose the same mitigating strategies requirements on all 

reactor applicants and licensees as those imposed by the ICM Order and associated license 

conditions. The Statement of Considerations for this rulemaking specifically notes that “[n]ew 

reactor licensees are required to employ the same strategies as current reactor licensees to 

address core cooling, SFP cooling, and containment integrity” (74 FR 13926).

II.3 Technical Evaluation

The implementing details of the mitigating strategies required by 10 CFR 50.54(hh)(2) and 

identified in TVA submittals constituting the description and plans for implementation required 

by 10 CFR 50.34(i), will be implemented by commitment and managed in accordance with the 

NEI commitment management guideline, NEI 99-04. The NRC staff concludes this provides 

reasonable controls for mitigating strategy implementation and for subsequent evaluation of 

identified changes.

Because the 3 items required by 10 CFR 50.54(hh)(2) correlate to the items in the Phase 1 

guidance and the mitigating strategies within NEI’s Phase 2 and 3 proposals, and because the 

implementing details will be managed under NEI 99-04, the NRC staff is satisfied that there will 

be sufficient controls to ensure that the strategies are adequately maintained.

II.4 Conclusion 

Based on the NRC staff’s review, TVA’s description and plans for implementation of the 

guidance and strategies intended to maintain or restore core cooling, containment, and SPF 

cooling capabilities under the circumstances associated with the loss of large areas of the plant 

due to explosions or fire, meet the requirements of 10 CFR 50.34(i). The NRC staff concludes 

that full implementation of TVA’s enhancements constitutes satisfactory compliance with the 10 

CFR 50.54(hh)(2), and represents reasonable measures to enhance TVA’s effectiveness in 

maintaining core and SPF cooling and containment integrity under circumstances involving the 

loss of large areas of the plant due to fires or explosions.

The Commission has concluded, based on the considerations discussed above, that: (1) there 

is reasonable assurance that the health and safety of the public will not be endangered by 

operation in the proposed manner, (2) such activities will be conducted in compliance with the 

Commission’s regulations, and (3) issuance of the operating license will not be inimical to the 

common defense and security or to the health and safety of the public with respect to 

compliance with 10 CFR 50.54(hh)(2).

II-5

APPENDIX JJ FUKUSHIMA ACTIONS

JJ.1 Introduction

Following the events on March 11, 2011, at the Fukushima Dai-ichi nuclear power plant in 

Japan, the Nuclear Regulatory Commission (NRC) has taken significant actions to enhance the 

safety of reactors in the United States based on the lessons learned from this accident. In 

March 2011, the NRC established a senior-level agency task force referred to as the Near-Term 

Task Force (NTTF). The NTTF conducted a systematic and methodical review of the NRC 

regulations and processes in order to determine if the agency should make additional 

improvements to these programs in light of the events at Fukushima Dai-ichi. As a result of this 

review, the NTTF developed a comprehensive set of recommendations, documented in the 

enclosure to SECY-11-0093 (Agencywide Document Access & Management System (ADAMS) 

Accession No. ML111861807).

Based on these recommendations, the NRC issued three orders and a request for information 

under 10 CFR 50.54(f) (the 50.54(f) letter) on March 12, 2012.

JJ.2 Regulatory Evaluation

As part of implementing the NTTF recommendations, the NRC issued the applicable orders and 

a 10 CFR 50.54(f) letter to operating reactors and construction permit (CP) holders, including 

Watts Bar Nuclear Plant (WBN), Unit 2. WBN, Unit 2, to support receiving the operating license 

(OL) is required to be in compliance with the orders and responsive to the 50.54(f) requests. 

The NRC staff notes that Recommendation 2.3 for flooding and seismic walkdowns was 

included in the 50.54(f) letter. As discussed in the 50.54(f) letter, this Recommendation is not 

applicable to WBN, Unit 2.

JJ.2.1 NRC Orders to Enhance Safety for Beyond Design Basis Events 

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

(EA-12-051, “Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation 

(effective immediately)” (ADAMS Accession No. ML12056A044), and EA-12-049, “Order to 

Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design Basis 

External Events” (ADAMS Accession No. ML12054A736)). 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. Attachment 1 of the orders provides a list 

of licensees and CP holders that the orders apply to, which includes WBN, Unit 2. Attachment 2 

of the orders describes specific requirements that licensees and CP holders must follow to 

achieve full compliance. 

On August 21, 2012, the Nuclear Energy Institute (NEI) submitted document NEI 12-06, 

"Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0 (ADAMS 

Accession No. ML12242A378) to the NRC to provide specifications for an industry-developed 

methodology for the development, implementation, and maintenance of guidance and strategies 

in response to the mitigation strategies order. The NRC staff reviewed NEI 12-06 and on 

August 29, 2012, issued its final version of Japan Lessons-Learned Directorate 

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(JLD)-ISG-2012-01, "Compliance with Order EA-12-049, Order Modifying Licenses with Regard 

to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," (ADAMS 

Accession No. ML12229A174) endorsing NEI 12-06, Revision 0, with comments as an 

acceptable means of meeting the requirements of Order EA-12-049, and published a notice of 

its availability in the Federal Register (77 FR 55230). 

On August 24, 2012, the NEI submitted document NEI 12-02, “Industry Guidance for 

Compliance with NRC Order EA-12-051, ‘To Modify Licenses with Regard to Reliable Spent 

Fuel Pool Instrumentation,’” Revision 1 (ADAMS Accession No. ML12240A307) to the NRC to 

provide specifications for an industry-developed methodology for compliance with Order 

EA-12-051. On August 29, 2012, the NRC staff issued its final version of JLD-ISG-2012-03, 

“Compliance with Order EA-12-051, Reliable Spent Fuel Pool Instrumentation” (ADAMS 

Accession No. ML12221A339) endorsing NEI 12-02, Revision 1, as an acceptable means of 

meeting the requirements of Order EA-12-051 with certain clarifications and exceptions, and 

published a notice of its availability in the Federal Register (77 FR 55232).

JJ.2.2 Requests for Information Related to Re-evaluated Seismic and Flooding Hazards

On March 12, 2012, the NRC issued a 10 CFR 50.54(f) letter to CP holders, which, in part, 

requested that licensees re-evaluate the seismic and flooding hazards at their sites using 

updated seismic and flooding hazard information and present-day regulatory guidance and 

methodologies (NTTF Recommendation 2.1). The 50.54(f) letter stated that information

provided in response would then be used to determine if a license should be suspended, 

revoked or modified.

The 50.54(f) letter noted that NRC regulations and associated regulatory guidance provide a 

robust regulatory approach for the evaluation of site hazards associated with natural 

phenomena. However, this framework has evolved over time as new information regarding site 

hazards and the potential consequence has become available. As a result, the licensing basis, 

design, and level of protection from natural phenomena differ among the existing operating 

reactors in the U.S., depending on when the plant was constructed and licensed for operation. 

Additionally, the assumptions and factors that were considered in determining the level of 

protection necessary at these sites vary depending on a number of contributing factors. 

JJ.2.3 Request Regarding Emergency Preparedness 

The March 12, 2012, 50.54(f) letter also requested information related to NTTF

Recommendation 9.3. The letter requested that licensees assess their Emergency 

Preparedness (EP) communications and staffing requirements with the objective of ensuring the 

capability to implement effective measures to mitigate the consequences of a radiological 

emergency. Specifically, the letter requested that licensees assess their current staffing levels 

and determine if enhancements were needed to fill all positions necessary to respond to a 

multi-unit event during a beyond design-basis natural event. The letter also requested licensees 

to assess their current communications systems and equipment and any appropriate 

enhancements, and to consider the means to power this communications equipment needed to 

communicate onsite and offsite during a prolonged station blackout.

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JJ.3 Technical Evaluation

JJ.3.1 Orders EA-12-049 and EA-12-051

TVA informed the NRC that it was in compliance with the requirements of the Fukushima 

Order for SPF instrumentation by letters dated October 29 and December 19, 2014 (ADAMS 

Accession Nos. ML14303A561 and ML15002A202, respectively). On March 12, 2015

(ADAMS Accession No. ML15072A116), TVA informed the NRC that it was in compliance with 

the Fukushima Order EA-12-049 regarding mitigating strategies for beyond-design-basis 

events. The NRC staff reviewed TVA’s strategies for the WBN site and issued a safety 

evaluation (SE) on March 27, 2015(ADAMS Accession No. ML15078A193), describing that 

the integrated plans at the WBN site, if implemented appropriately, would adequately address 

the requirements of both Fukushima Orders, EA-12-049 and EA-12-051. On March 30, 2015, 

the NRC performed an inspection per Temporary Instruction (TI) 191, "Implementation of 

Mitigation Strategies and Spent Fuel Pool Instrumentation Orders and Emergency 

Preparedness Communications/Staffing/Multi-Unit Dose Assessment Plans" (ADAMS 

Accession No. ML14273A444). The inspection results are documented in Inspection Report 

2015616 (ADAMS Accession No. ML15173A317).

JJ.3.2 Recommendation 2.1 - Reevaluated Seismic and Flooding Hazards 

By letters dated March 31, 2014 (ADAMS Accession No. ML14098A478), and March 12, 2015

(ADAMS Accession No. ML15071A262), TVA submitted the reevaluated seismic and flooding 

hazards, respectively, for WBN, Units 1 and 2, in response to the 50.54(f) letter. NRC 

assessments of the seismic and flood hazard reevaluations being performed pursuant to the 

50.54(f) letter remains under staff review. By letter dated June 24, 2015 (ADAMS Accession 

No. ML15169A904), TVA revised its flooding hazard report, which resulted in a reduction of the 

flooding level and compensatory actions are no longer necessary.

On December 30, 2014 (ADAMS Accession No. ML14365A072), TVA submitted the expedited 

seismic evaluation process report, which evaluated the safe shutdown lineup credited in the 

WBN, Units 1 and 2, mitigating strategies against the reevaluated hazard. A review level 

earthquake of 2.0 times the design and licensing basis safe shutdown earthquake was used in 

analysis to assess equipment robustness. The review level earthquake effectively bounds the 

probabilistic ground motion response spectra determined for the site in the 1 to 10 hertz (hz)

spectral acceleration range. The licensee reported that no modifications to plant equipment 

were required based on the assessment. 

JJ.3.3 Recommendation 9.3 - Emergency Preparedness during a Beyond Design Basis 

Natural Event 

In accordance with NTTF Recommendation 9.3, the March 12, 2012 50.54(f) letter requested 

licensees and CP holders to assess: (1) the number of emergency staff needed to respond to a 

large accident that may affect multiple reactors at their site, and make changes as necessary; 

and (2) their capability to power communications equipment for emergency response during a 

multi-unit, beyond-design-basis natural event.

These assessments were performed in accordance with NEI 12-01, "Guideline for Assessing 

Beyond Design Basis Accident Response Staffing and Communications Capabilities." (ADAMS 

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Accession No. ML12125A412), which was endorsed by the NRC staff by letter dated May 15, 

2012 (ADAMS Accession No. ML12131A043).

By letter dated October 31, 2012 (ADAMS Accession No. ML12311A297), TVA submitted its 

communication assessment for WBN, Units 1 and 2, and by letter dated February 22, 2013 

(ADAMS Accession No. ML13058A067), TVA provided additional information regarding generic 

technical issues for resolution regarding its communications assessment. TVA assessed its 

current communications systems and equipment used during an emergency event and identified 

several enhancements in order for the emergency plan (EP) equipment to survive a 

beyond-design-basis external event.

On July 3, 2013, the NRC staff issued its safety assessment regarding the communications 

information submitted for Watts Bar (ADAMS Accession No. ML13142A348). This assessment 

concluded that TVA's assessment for communications was reasonable, and the interim 

measures, analyzed existing systems, and proposed enhancements will help to ensure that 

communications are maintained during a beyond design-basis event. On October 15, 2014

(ADAMS Accession No. ML14295A103), TVA submitted revised commitment dates for 

implementing the communications enhancements committed to in its assessment. The NRC 

staff verified that WBN has implemented the identified enhancements identified in the response 

to NTTF Recommendation 9.3 by inspection using NRC Inspection Manual Temporary 

Instruction (TI)-191, “Inspection of the Implementation of Mitigation Strategies and Spent Fuel 

Pool Instrumentation Orders and Emergency Preparedness Communication/Staffing/Multi-Unit 

Dose Assessment Plan.” The inspection results are documented in Inspection Report 

2015616 (ADAMS Accession No. ML15173A317).

The 50.54(f) letter in part, required licensee responses pertaining to onsite and augmented staff 

availability to implement the strategies discussed in the EP and/or plant operating procedures,

including new staff or functions resulting from the assessment, any identified collateral duties, 

an implementation schedule to perform the assessments, any identified modifications, and any 

changes that have been made or will be made to the EP regarding on-shift or augmented 

staffing. In addition, NTTF Recommendation 9.3 has a dependency on the implementation of 

NTTF Recommendation 4.2 (mitigating strategies). As a result of this dependency, licensees 

responded to the 50.54(f) letter request for staffing information in two phases. The Phase 1 

staffing assessment requested licensees to evaluate their ability to respond to a multi-unit 

extended loss of AC power event utilizing existing processes and procedures. TVA did not 

provide a Phase 1 staffing assessment for WBN because at the time WBN, Unit 1, was 

considered a single-unit site and only multi-unit sites were requested to provide a Phase 1 

staffing assessment.

The Phase 2 responses provided assessments of the staffing necessary to perform the 

functions related to the strategies developed in response to NTTF Recommendation 4.2 and the 

resulting Order EA-12-049. TVA submitted its Phase 2 staffing assessment for WBN, Units 1 

and 2, on October 6, 2014 (ADAMS Accession No. ML14280A258). The NRC staff evaluated 

this staffing assessment and provided its response by letter dated December 17, 2014 (ADAMS 

Accession No. ML14329A036). The NRC staff found that that the proposed emergency 

response resources, as described in the WBN EP, are sufficient to perform the required plant 

actions and EP functions, and implement the multi-unit event response strategies that were 

developed in response to NRC Order EA-12-049 without the assignment of collateral duties that 

would impact the performance of assigned emergency plan functions. The NRC staff concluded 

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that TVA’s Phase 2 staffing submittal adequately addresses the response strategies needed to 

respond to a beyond-design-basis external event using procedures and guidelines at WBN.

In response to NTTF Recommendation 9.3, the U.S. nuclear power plant licensees provided 

information to the NRC staff regarding their capabilities to perform multi-unit dose assessments 

and explanation of how this capability would be implemented, if not already in place. By letter 

dated June 28, 2013 (ADAMS Accession No. ML13183A070), TVA submitted its assessment of 

multi-unit/multi-source dose assessment capabilities. The NRC staff responded by letter dated 

January 29, 2014 (ADAMS Accession No. ML13233A205) and concluded that WBN had 

appropriate plans to have this capability in place by December 31, 2014. 

JJ.4 Conclusion

As discussed above, coincident with the issuance of the mitigating strategies order, on 

March 12, 2012, the NRC staff issued a 50.54(f) letter, which requested that licensees 

evaluated emergency preparedness and reevaluate the seismic and flooding hazards at their 

sites using updated hazard information and current regulatory guidance and methodologies. 

TVA’s compliance with the mitigating strategies order provides additional protection against 

beyond design-basis events. The NRC inspection activities have verified licensee compliance 

with Orders EA-12-049 and EA-12-051. 

Based on the ongoing review of the information received in response to the 50.54(f) letter, the 

NRC staff finds that new hazard information does not impact conclusions reached, that WBN,

Unit 2, is in compliance with the orders. The NRC staff will continue to review the reevaluated 

hazard information in accordance with agency established processes and take any appropriate 

actions, if necessary.

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NUREG

-0847

Supplement 28

Safety Evaluation Report Related to the Operation of 

Watts Bar Nuclear Plant, Unit 2