Letter Sequence Meeting |
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EPID:L-2020-LLA-0004, Application to Revise Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis, (TS-19-02) (Approved, Closed) |
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MONTHYEARCNL-19-066, Application to Revise Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis, (TS-19-02)2020-01-14014 January 2020 Application to Revise Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis, (TS-19-02) Project stage: Request ML20049A0322020-02-13013 February 2020 NRR E-mail Capture - SQN Hydrologic Analysis LAR Acceptance Review - L-2020-LLA-0004 Project stage: Acceptance Review CNL-20-026, Supplement to Application to Revise Sequoyah Nuclear Plant Units 1 and 2 Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis, (TS-19-02)2020-02-18018 February 2020 Supplement to Application to Revise Sequoyah Nuclear Plant Units 1 and 2 Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis, (TS-19-02) Project stage: Supplement ML20054B5532020-02-20020 February 2020 NRR E-mail Capture - Sequoyah Nuclear Plant, Units 1 and 2 - Acceptance of License Amendment Request to Modify the UFSAR Based on a New Hydrologic Analysis Project stage: Acceptance Review ML20106F1042020-04-14014 April 2020 Request for Additional Information Regarding the Hydrologic Analysis LAR Project stage: RAI CNL-20-032, Response to Request for Additional Information (TS-19-02) Application to Revise Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis2020-05-14014 May 2020 Response to Request for Additional Information (TS-19-02) Application to Revise Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis Project stage: Response to RAI ML20141L7672020-05-28028 May 2020 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML20189A2112020-07-0101 July 2020 Request for Additional Information Regarding Hydrologic UFSAR Update Project stage: RAI ML20196L6892020-07-16016 July 2020 TVA Non-Proprietary Slides for Open Session of July 16, 2020, Partially Closed Public Meeting to Discuss Sequoyah License Amendment Request Project stage: Meeting ML20203M0572020-07-16016 July 2020 Updated TVA Non-Proprietary Slides for Open Session of July 16, 2020, Partially Closed Public Meeting to Discuss Sequoyah License Amendment Request Project stage: Meeting ML20196L7922020-07-16016 July 2020 Corrected TVA Non-Proprietary Slides for Open Session of July 16, 2020, Partially Closed Public Meeting to Discuss Sequoyah License Amendment Request Project stage: Meeting ML20203M2292020-08-11011 August 2020 July 16, 2020, Summary of Partially Closed Meeting with Tennessee Valley Authority to Discuss Responses to Requests for Additional Information Regarding Updated Final Safety Analysis Report Hydrologic Analysis License Amendment Request Project stage: RAI CNL-20-057, Tennessee Valley Authority - Application to Revise Sequoyah Nuclear Plant Units 1 & 2 Updated FSAR Changes to Hydrologic Analysis - Partial Response to Additional Request for Additional Information (TS-19-02)2020-08-12012 August 2020 Tennessee Valley Authority - Application to Revise Sequoyah Nuclear Plant Units 1 & 2 Updated FSAR Changes to Hydrologic Analysis - Partial Response to Additional Request for Additional Information (TS-19-02) Project stage: Request ML20261H4162020-09-0202 September 2020 NRR E-mail Capture - Draft Request for Additional Information - Sequoyah Nuclear Plant, Units 1 and 2, Request to Revise UFSAR Hydrologic Analysis Project stage: Draft RAI ML20261H4172020-09-14014 September 2020 NRR E-mail Capture - Sequoyah Nuclear Plant, Units 1 and 2 - Request for Additional Information Regarding Hydrologic UFSAR Update Project stage: RAI ML20261H4182020-09-14014 September 2020 NRR E-mail Capture - Sequoyah Nuclear Plant, Units 1 and 2 - Audit Plan and Setup of Online Reference Portal Project stage: Other ML20293A0802020-10-28028 October 2020 Summary of October 13, 2020, Closed Meeting with TVA on Responses to Requests for Additional Information Updated Final Safety Analysis Report Hydrologic Analysis License Amendment Request Project stage: RAI ML20316A0182020-11-10010 November 2020 NRR E-mail Capture - Sequoyah Nuclear Plant, Units 1 and 2 - Audit Plan and Setup of Online Reference Portal Project stage: Other CNL-20-082, Partial Response to Request for Additional Information Regarding Application to Revise Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis (TS-19-02)2020-11-10010 November 2020 Partial Response to Request for Additional Information Regarding Application to Revise Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis (TS-19-02) Project stage: Response to RAI ML20343A1182021-01-12012 January 2021 Request for Withholding Information from Public Disclosure Project stage: Withholding Request Acceptance ML21068A4082021-03-0909 March 2021 NRR E-mail Capture - Sequoyah Nuclear Plant, Units 1 and 2 - Supplement 2 to Audit Plan and Setup of Online Reference Portal Project stage: Other CNL-21-024, Partial Response to Additional Request for Information Re Application to Revise Updated Final Safety Analysis Report Re Changes to Hydrologic Analysis (TS-19-02)2021-06-15015 June 2021 Partial Response to Additional Request for Information Re Application to Revise Updated Final Safety Analysis Report Re Changes to Hydrologic Analysis (TS-19-02) Project stage: Request ML21239A1152021-08-13013 August 2021 Partial Response to Additional Request for Additional Information, (Question 2) Regarding Application to Revise Sequoyah Nuclear Plant, Units 1 and 2 Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis - Correction Project stage: Request CNL-21-095, Submittal of Application to Revise Sequoyah Nuclear Plant, Units 1 and 2, 10 CFR 50.90 Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis - Software Dedication Report 16-01 - Update .2021-12-21021 December 2021 Submittal of Application to Revise Sequoyah Nuclear Plant, Units 1 and 2, 10 CFR 50.90 Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis - Software Dedication Report 16-01 - Update . Project stage: Request CNL-23-012, Revision to the Application to Revise Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis, (TS-19-02)2023-04-11011 April 2023 Revision to the Application to Revise Updated Final Safety Analysis Report Regarding Changes to Hydrologic Analysis, (TS-19-02) Project stage: Request ML24039A0792024-02-12012 February 2024 – Summary of Regulatory Audit Regarding the License Amendment Request for Hydrologic Analysis Changes to the Updated Final Safety Analysis Report (EPID L-2020-LLA-0004) - Public Project stage: Other ML24074A4252024-03-14014 March 2024 NRR E-mail Capture - Sequoyah Hydrologic Analysis License Amendment Request - Notification of Change to Estimated Completion and Hours Project stage: Other ML24040A2062024-03-26026 March 2024 Issuance of Amendment Nos. 367 and 361 Regarding Changes to the Hydrologic Analyses (EPID L-2020-LLA-0004) - Public Project stage: Approval 2020-08-11
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Sequoyah Nuclear Plant (SQN)
Responses to NRC Request for Additional Information (RAI) Regarding License Amendment Request (LAR) for Hydrological Analysis Update July 16, 2020
Agenda
- Proposed Responses to NRC RAIs (Non-Proprietary)
- Proposed Responses to NRC RAIs (Proprietary) l 2
Introduction
- Purpose of the meeting is to resolve questions raised by the NRC Quality Assurance and Vendor Inspection Branch (IQVB) regarding the TVA LAR for the SQN Hydrologic Analysis.
- Resolution of these questions is important to not only the SQN LAR, but also the planned WBN Hydrology LAR.
- Portions of the NRC RAI and proposed TVA responses contain proprietary information and will be discussed during the closed session.
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Background===
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NRC Question 1.1 TVA stated that the ArcGIS software uses gridded shapefile data to create a Triangular Irregular Network (TIN) surface that is used via a polygon volume tool to compute the sub-basin average Probable Maximum Precipitation (PMP) depths. In contrast, the QGIS alternate methodology utilizes the nearest neighbor geoprocessing tool to generate a raster surface that then uses a grid statistics tool to generate the nearest neighbor geoprocessing tool. It is unclear what the technical difference is between methodologies used to create a TIN surface and a raster surface and between the polygon volume tool and nearest neighbor geoprocessing tool used to create the sub-basin average PMP depths. Therefore, the NRC staff requests TVA to clarify how these two methodologies are technically different such that the use of these alternate calculation methodologies can be credited to prevent the same erroneous outputs in both GIS tools.
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TVA Response to NRC Question 1.1
- PMP Evaluation Tool outputs gridded PMP depth data along a uniform grid with resolution 0.025 by 0.025 decimal degrees
- ArcGIS triangulation to create a Triangular Irregular Network (TIN) surface representing PMP Depth over basin where depth is interpolated along triangle edges
- Average basin precipitation depth =
Volume of PMP Surface above the basin boundary divided by basin area l 6
TVA Response to NRC Question 1.1 QGIS Methodology
- PMP Evaluation Tool depths used to create Raster through QGIS Nearest Neighbor tool.
- Only grid cells with centroid in basin utilized.
- Improved accuracy by bilinear interpolation by resampling tool
- Average basin precipitation depth= sum of cell volumes divided by area of basin boundary Differences in Methods
- Triangulation vs Bilinear interpolation
- Polygon volume vs Arithmetic averaging of grid cells l 7
NRC Question 1.2 In Enclosure 3, Gridded PMP Development Calculation of the RAI response, Appendix A GIS PMP Event Depth Computations, Section 6.5, states Review of computed PMP depths across the ArcGIS and QGIS platforms identified a project PMP depth above Chatuge as an outlier. Analysis indicated areas around the sub-basin boundary with zero depth as the PMP points from the [Applied Weather Associates (AWA)] tool did not provide adequate coverage during TIN creation for the single sub-basin. PMP depths utilized for Chatuge are based on QGIS analysis to eliminate results without the complete PMP coverage. Since QGIS is used to verify the results of ArcGIS and their results are dissimilar for Chatuge, it is not clear what the basis is for using the output of QGIS instead of ArcGIS for this area. In addition, since the TVA determined that ArcGIS did not provide adequate coverage for Chutage, it is not clear how the output of QGIS is determined to be correct for this area. Therefore, the NRC staff requests TVA to justify the use of the QGIS output for the Chatuge sub-basin.
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TVA Response to NRC Question 1.2
- Alternate calculation check of ArcGIS calculations in QGIS led to additional review of results
- Review showed Triangulation in ArcGIS had an area of 0.88 square-miles less than QGIS, equating to less than 0.5% of the total 189.1-sq.-mi. Chatuge basin area without TIN coverage
- The alternate calculation check in QGIS via the alternate methodology ensures full coverage of PMP depth data points over the basin by use of the QGIS resample tool to provide a grid of PMP depths at a 0.0025 by 0.0025 decimal degree grid Minor Lack of Coverage l 9
TVA Response to NRC Question 1.2
- Over 2,500 individual PMP surfaces were checked in QGIS with only those surfaces associated with a Chatuge PMP resulting in differences greater than 0.6% for the Chatuge sub-basin average.
- Application of the adjacent grid point depths to the small uncovered area by the ArcGIS method result would approximate the QGIS result, providing the alternate calculation comparison and justification of the QGIS result for the Chatuge basin l 10
Schedule for Submittal
- NRC Requested that TVA respond to the RAI within 45 days
- TVA plans to submit the RAI response no later than August 14, 2020
- NRC is expected to approve the LAR by February 2022 l 11