Text

Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 5 of 8
	ML15176A688
Person / Time
Site:	Sequoyah
Issue date:	06/19/2015
From:	; Tennessee Valley Authority
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML15176A678	List: CNL-15-128, Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 5 of 8; ML15176A664; ML15176A679; ML15176A681; ML15176A682; ML15176A718; ML15176A740; ML15176A748; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 1 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 2 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 3 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 4 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 5 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 7 of 8;
References
	SQN-TS-11-10, CNL-15-128
	Download: ML15176A688 (499)
	v • d • e

Sequoyah ITS Conversion Database Page 1 of 2 Licensee Response/NRC Response/NRC Question Closure Id 365 NRC Question KAB064 Number Select NRC Response Application Attachment 1

Attachment 2

Response Page 10 of the Calculation B87 140924 017, Revision 9, dated September Statement 24, 2104 notes 4 and 4a state:

4. An Ab = +/-0.5% of value is a requirement of the calculation.

Applies to 27DAT, 27DBT, 27DCT.

4a. Per Requirement 1, the acceptance band for calibration of the under voltage relays shall be set equal to the Re (+/-0.2% of value) per the requirements of TSTF-493. However, an acceptance band of 0.5% of value is conservatively retained from previous revisions in the calculation of the accuracy values for determination of the Allowable Values. Applies to 271A, 271B, 272A, 272B.

Ab493 = Re = +/-0.2% of value (for use in calibration tolerances) Ab =

+/-0.5% of value (for use in accuracy calculations)

With regard to note 4 on sheet 10 of the calculation, please clarify the definition of An Ab. These are two different terms per the definitions and abbreviations on sheet 4 of the calculation. The note also states that it is a requirement of the calculation. NRC staff understands that the calculation is normally performed to find the requirements for the setting. Please explain what is meant by is the requirement of the calculation.

Note 4a states Ab493 to be +/-0.2% but uses an Ab of +/-0.5%. The statement that an acceptance band of 0.5% of value is conservatively retained is confusing. Regulatory Information Summary (RIS) 2006-17 provides the guidance to calculate the as-left value. RIS 2006-17 in part states, the setting tolerance band is less than or equal to the square root of the sum of the squares of reference accuracy, measurement and test equipment, and readability uncertainties. Please explain how you meet the guidance contained in RIS 2006-17.

Response

10/6/2014 6:00 PM Date/Time Closure Statement Question Closure Date Notification Scott Bowman Michelle Conner Khadijah Hemphill Andrew Hon https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=365 1/13/2015

Sequoyah ITS Conversion Database Page 2 of 2 Lynn Mynatt Ray Schiele Roger Scott Added By Kristy Bucholtz Date Added 10/6/2014 1:00 PM Date Modified Modified By https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=365 1/13/2015

Sequoyah ITS Conversion Database Page 1 of 3 Licensee Response/NRC Response/NRC Question Closure Id 377 NRC Question KAB064 Number Select Licensee Response Application Attachment 1

Attachment 2

Response

Statement The following information is provided concerning the Staffs comments to the response to RAI KAB064 and SQN calculation B87 140924 017, Revision 9.

1. With regard to note 4 on sheet 10 of the calculation, please clarify the definition of An Ab. These are two different terms per the definitions and abbreviations on sheet 4 of the calculation.

Response

As it pertains to Note 4, An Ab, is not defining two different terms. An is the beginning article for the sentence. Note 4 explains that for calculation B87 140924 017, Revision 9, the term Ab (Acceptance band

- the range of values around the correct value determined to be acceptable without recalibration) equals +/- 0.5% of value.

2. The note also states that it is a requirement of the calculation. NRC staff understands that the calculation is normally performed to find the requirements for the setting. Please explain what is meant by is the requirement of the calculation.

Response

Note 4 applies to relays 27DAT, 27DBT, and 27DCT.

These relays are not within the scope of TSTF-493.

Therefore, for these instruments, an acceptance band https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=377 1/13/2015

Sequoyah ITS Conversion Database Page 2 of 3 (Ab) = 0.5% must be used for the as-left tolerance and will be documented in an output configuration control document.

3. Note 4a states Ab493 to be +/-0.2% but uses an Ab of

+/-0.5%. The statement that an acceptance band of 0.5% of value is conservatively retained is confusing.

Response

The calculation was revised to incorporate the requirements of TSTF-493. The term Ab493 was added to determine the acceptance band for the As-Left tolerance to comply with TSTF-493. Ab493 is smaller than Ab, which produces a tighter As-Left tolerance. An Ab of +/-0.5% is maintained in the calculation for the determination of the Allowable Value. A larger Ab is more conservative for the determination of the Allowable Value.

4. Regulatory Information Summary (RIS) 2006-17 provides the guidance to calculate the as-left value.

RIS 2006-17 in part states, the setting tolerance band is less than or equal to the square root of the sum of the squares of reference accuracy, measurement and test equipment, and readability uncertainties. Please explain how you meet the guidance contained in RIS 2006-17.

Response

TVA is adopting NUREG-1431, Revision 4, which incorporates TSTF-493. TSTF-493 satisfies the guidance of RIS 2006-17 when calculating As-Left tolerances.

For the As-Left tolerances, TVA is setting the tolerance band equal to the square root sum of the squares (SRSS) of the reference accuracy and measuring and test equipment (M&TE) inaccuracies. In some calculation, the M&TE inaccuracies may be set to zero, which will cause a tighter As-Left tolerance.

Response

10/22/2014 2:30 PM Date/Time Closure Statement https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=377 1/13/2015

Sequoyah ITS Conversion Database Page 3 of 3 Question Closure Date Notification Scott Bowman Michelle Conner Khadijah Hemphill Andrew Hon Lynn Mynatt Ray Schiele Added By Scott Bowman Date Added 10/22/2014 1:28 PM Date Modified Modified By https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=377 1/13/2015

Sequoyah ITS Conversion Database Page 1 of 3 Licensee Response/NRC Response/NRC Question Closure Id 389 NRC Question KAB064 Number Select NRC Response Application Attachment 1

Attachment 2

Response

Statement

1. Item 1 of the licensee response stated the term AnAb is not defining two different terms. Sheet 4 of calculation 27DAT, Revision 9, defines An as the normal accuracy of the device and Ab as the acceptance band - the range of values around the correct value determined to be acceptable without recalibration. These are clearly two separate terms with different meanings. The use of term AnAb is confusing.

Response to Item 1 also stated the term Ab (Acceptance band

- the range of values around the correct value determined to be acceptable without recalibration) equals +/-0.5% of value. Staff agrees with the use of term Ab for this explanation as cited by the licensee. Licensee explanation used the correct term Ab as opposed to AnAb. Please update the calculation to avoid any confusion. If the licensee plans to continue the use of term AnAb then it must be clearly defined as a single term in the definitions and abbreviations section of the calculation.

Further please clarify that the term Ab - acceptance band without calibration is the same as the term as-left used in TSTF-493. If not clarify the difference and provide the values of the term as-left.

2. The licensee response that acceptance band for TSTF-493, Ab493 =+/-0.2% is acceptable as used in the calculation.

However, the term acceptance band for allowable value is confusing. The licensee seems to be discussing the tolerance for allowable value or setting tolerance for allowable value. Since the allowable value has to consider drift and should avoid unnecessary reportability, its value will be somewhat larger than Ab, the acceptance band around the setpoint that is acceptable without recalibration.

https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=389 1/13/2015

Sequoyah ITS Conversion Database Page 2 of 3 Hence the use of Ab = +/-0.5% for allowable value allowance or tolerance is confusing and undesirable. Staff suggests the calculation be changed to prevent confusion by using terms Ab with two different meanings.

3. TSTF-493 Notes 1 and 2 have not been added to the technical specifications (TS) to address as-left and as-found values.

Please add these notes to the technical specifications. If these notes are detailed in another document then reference the appropriate documents in the TS affected pages. Also please provide the wording of the notes and the values for as-left and as-found terms for staff review. These notes apply to reactor coolant pump (RCP) undervoltage loops (271A, 271B, 272A, and 272B) and 6.9kV shutdown board loss of voltage relays (27TS1A, 27TS1B, 27TS1C).

4. Definitions of Westinghouse methodology related terms have not been included in the definitions and abbreviations section of the calculation. These definitions should be included for completeness and to prevent confusion while reviewing the calculation.

5. Calculation sheets 4 and 5 provide definitions and abbreviations. However, these sheets do not include terms Lan and Las which are used on sheet 39 of the calculation.

Also the term Afc used on sheets 23 and 39 of the calculation is not included in the definitions and abbreviations section.

Please define these and any other abbreviations that have been used but not included in the definitions and abbreviations section of the calculation.

6. On page 23A of the calculation it is stated that An=As where An is the normal accuracy and As is the seismic accuracy as defined on sheet 4 of the calculation. Normally these two values are different unless the seismic accuracy is negligible. If the seismic accuracy is negligible then it should be so stated in the calculation. If not, the two values will be different. Please clarify.

Response

12/1/2014 6:00 PM Date/Time Closure Statement Question Closure Date https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=389 1/13/2015

Sequoyah ITS Conversion Database Page 3 of 3 Notification Scott Bowman Michelle Conner Khadijah Hemphill Andrew Hon Lynn Mynatt Ray Schiele Roger Scott Added By Kristy Bucholtz Date Added 12/1/2014 1:01 PM Date Modified Modified By https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=389 1/13/2015

Sequoyah ITS Conversion Database Page 1 of 4 Licensee Response/NRC Response/NRC Question Closure Id 402 NRC Question KAB064 Number Select Licensee Response Application Attachment 1

Attachment 2

Response

Statement 1. Calculation 27DAT does not use the term, AnAb anywhere. In three different locations, the calculation uses the phrase, An Ab, not AnAb (difference is the space between An and Ab). In all three of these cases, the An is the article used in a sentence (such as a, an, or the), not the defined calculation term, An. The only calculation term used in those three instances is the term, Ab. Therefore, since the calculation does not use any term designated as AnAb no clarifications are required in the definitions or abbreviations.

Ab - acceptance band without calibration is the same as the term as-left used in TSTF-493, and is defined in Branch Technical Instruction, BTI-EEB-TI-28, R10. BTI-EEB-TI-28, R10 has a specific section that addresses TSTF-493 requirements and indicates that the As-Left Tolerance is equivalent to the Acceptance Band (Ab).

Calculation 27DAT, provided in the SQN response to KAB064 on October 21, 2014, as Attachment 2, contains the value of Ab493 for the relays subject to TSTF-493 requirements.

2. There is no term acceptance band for allowable value used in calculation 27DAT. Note 4a on page 37 of the pdf (sheet 10) of calculation 27DAT states that, the acceptance band [As-Left] for calibration of the under voltage relays shall be set to the Re

(+/-0.2% of value) per the requirements of TSTF-493. Where Re (repeatability inaccuracy) = Ab493. This value of +/-0.2% is more conservative than the previous value of +/-0.5%, in that it establishes a tighter tolerance for the As-Left acceptance criteria.

Therefore, in terms of the calibration tolerances, the tighter requirements for TSTF-493 (Ab493) are used.

Note 4a further states that an acceptance band of 0.5% of value is conservatively retained from previous revisions in the calculation https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=402 1/13/2015

Sequoyah ITS Conversion Database Page 2 of 4 of the accuracy values for determination of the Allowable Values [emphasis added]. Note 4a shows, Ab = +/-0.5% of value (for use in accuracy calculations). These statements do not mean that the Allowable Value (AV) is equal to the acceptance band of

+/-0.5%.

The inclusion of any Ab term within the accuracy computation addresses the fact that uncertainty can be imparted to the measurement of the process in question due to the calibration process, including tolerances. When used in an accuracy computation that will be used for the derivation of Setpoints and Allowable Values, the use of a larger uncertainty term is conservative because it produces more separation between the Analytical Limit and the Setpoint. Therefore, the larger Ab term is retained for use in the accuracy computations for the Setpoint and Allowable Value. Although the Setpoint is specifically defined in another calculation, the summary of results on pdf page 88, of calculation 27DAT, (Sheet 49B) shows that margin exists between the Setpoint and Analytical Limit, considering the uncertainty values (An and As), which include the larger Ab value within their computations, as shown on pdf page 59 (Sheet 23A) of the calculation. In calculation 27DAT, page 80 of the pdf (Sheet 40) shows the computation of the Allowable Value using accuracies, based on the larger Ab. Therefore, Ab has been conservatively applied to the accuracy computations for the Setpoint and Allowable Value, and Ab493 has been conservatively applied for the calibration tolerances.

3. As part of the original submittal for the ITS LAR, the two TSTF-493 notes were included in ITS LCO 3.3.1 and 3.3.2 for all the functions that are required to meet TSTF-493. The functions have the (b) and (c) footnote annotation and the footnotes are at the bottom of the pages. See page 5 and 6 of Attachment 1 to the initial response for RAI KAB064 for examples of these footnotes.

As stated in footnote (c), the methodologies used to determine the as-found and as-left values are specified in UFSAR Section 7.1.2.

An FSAR change is currently in progress to provide the methodologies in Section 7.1.2 of the UFSAR, and will be complete prior to implementation of ITS. In calculation 27DAT, the As-Found value for the RCP Undervoltage loops (271A, 271B, 272A, and 272B) is found on page 59 of the pdf (Sheet 23A), As-Found is equal to +/-0.57% of setpoint. The As-Left value for the RCP Undervoltage loops is found on page 22 of the pdf (Sheet 2), the As-Left is equal to +/-0.2% of value. The As-Found value for the https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=402 1/13/2015

Sequoyah ITS Conversion Database Page 3 of 4 6.9kV shutdown board loss of voltage relays (27TS1A, 27TS1B, 27TS1C) is found on page 60 of the pdf (Sheet 24), As-Found is equal to +/-1.926% of setpoint. The As-Left value for the 6.9kV shutdown board loss of voltage relays is found on page 22 of the pdf (Sheet 2), As-Left is equal to +/-0.5% of value.

As-Found and As-Left values are controlled through Setpoint and Scaling Documents (SSDs). SSDs serve as the design output document to transmit the requirements to site organizations to ensure values assessed in the safety analyses and/or other design documents relative to instrument setpoints, scaling and calibration are in fact incorporated in the plant as assessed in the relevant design documents. Changes to As-Found and/or As-Left values require a Design Change to be processed via the Engineering Change Process. The As-Found and As-Left values listed in the SSDs are incorporated into Surveillance Instructions (SIs) that are performed to verify Technical Specification Surveillance Requirements. The SIs are annotated with requirements to evaluate setpoints found outside the As-Found tolerances to verify the channel is functioning as required before returning the channel to service. Additionally, this condition will be entered into the Corrective Action Program. The SIs also require that an instrument channel shall be declared inoperable if it cannot be reset to within the As-Left tolerance.

4. TVAs process for describing the method for determining the acceptability of setpoints for nuclear safety-related and Technical Specification instrumentation channels is governed by Branch Technical Instruction BTI-EEB-TI-28. Calculations under the scope of this instruction must follow the process outlined in this branch instruction. In some cases, terms and definitions are specified within the individual calculations; however, any term not specified within the individual calculation is defined in this branch technical instruction.

5. The terms LAn and LAs are defined in BTI-EEB-TI-28, Revision

10. LAn is the Normal Loop Accuracy. LAs is the Post-Seismic Loop Accuracy. The term Afc is defined on pdf page 59 (sheet 23A) of calculation 27DAT. Afc is the Acceptable-As-Found, Component. Therefore, Afc is the As-Found value for a particular component. BTI-EEB-TI-28, Rev. 10 also defines the term Afc as the Acceptable As-Found - Component.

6. Calculation 27DAT defines the term Se on pdf page 27 (Sheet 5) https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=402 1/13/2015

Sequoyah ITS Conversion Database Page 4 of 4 as the inaccuracy following a seismic event. Page 36 of the pdf (Sheet 9) states that Se is negligible and refers to Note 6, which is on pdf page 38 (Sheet 11). Note 6 states that post-seismic effects are negligible for this solid state relay. Therefore, An = As, as stated in the calculation.

Response

12/16/2014 5:00 PM Date/Time Closure Statement Question Closure Date Notification Scott Bowman Kristy Bucholtz Michelle Conner Khadijah Hemphill Andrew Hon Lynn Mynatt Ray Schiele Added By Scott Bowman Date Added 12/16/2014 3:58 PM Date Modified Modified By https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=402 1/13/2015

Sequoyah ITS Conversion Database Page 1 of 1 Licensee Response/NRC Response/NRC Question Closure Id 403 NRC Question KAB064 Number Select Application NRC Question Closure Attachment 1 Attachment 2

Response

Statement

Response

Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.

Question Closure 12/18/2014 Date Notification Scott Bowman Kristy Bucholtz Michelle Conner Khadijah Hemphill Andrew Hon Lynn Mynatt Ray Schiele Roger Scott Added By Khadijah Hemphill Date Added 12/18/2014 2:31 PM Date Modified Modified By https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=403 1/13/2015

Sequoyah ITS Conversion Database Page 1 of 2 ITS NRC Questions Id 174 NRC Question KAB065 Number Category Technical ITS Section 3.3 ITS Number 3.3.1 DOC Number JFD Number JFD Bases Number Page Number(s)

NRC Reviewer Rob Elliott Supervisor Technical Gursharan Singh Branch POC Conf Call N

Requested NRC Question Request for additional information regarding Sequoyah RCP Underfrequency Relays setpoint calculation number SQN-EEB-MS-T128-0076, Rev. 5 The above calculation was provided in support of the Sequoyah ITS request. Staff requests the following clarifications with request to this calculation:

1. Note 2 on page number 14 of the calculation justifies the use of a drift value of +/-0.553 Hz. In its letter dated June 3, 1994 ABB stated that ABB Type 81 Frequency Relay employs a very stable crystal controlled oscillator as frequency reference. It further stated that a drift value of 0.01 Hz over a period of 22.5 months will be very conservative. ABB also stated that the suggested drift of high magnitude suggested by the licensee would be indicative of a defective relay. In note 2, the licensee states that the drift value of

+/-0.553 Hz is highly conservative.

Please note that using a high drift value will mask the potential degrading of the instrument. The deviation in the as-found value should be based on regulatory information summary (RIS) 2006-17.

The deviation number selected should be high enough to prevent unwanted excursions beyond the allowable value while it should be low enough to detect potential degradation of the instrument. The licensee is requested to use a drift number using the guidance of https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=174 1/13/2015

Sequoyah ITS Conversion Database Page 2 of 2 RIS 2006-17.

2. Please note that ISA RP-67.04.02 recommends that the accuracy of measurement and test equipment should be four times better than the accuracy of the instrument that is being calibrated. IEEE-498 also recommends this accuracy. The staff notes that the accuracy of the underfrequency relay is 0.008Hz whereas the accuracy of the test instrument is 0.05 Hz. The selection of a calibration instrument that is six times more inaccurate than the instrument being calibrated is highly undesirable and must be justified within the calculation.

Attach File 1 Attach File 2 Issue Date 7/15/2014 Added By Kristy Bucholtz Date Modified Modified By Date Added 7/15/2014 8:18 AM Notification Scott Bowman Michelle Conner Khadijah Hemphill Andrew Hon Lynn Mynatt Ray Schiele Roger Scott https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=174 1/13/2015

Sequoyah ITS Conversion Database Page 1 of 2 Licensee Response/NRC Response/NRC Question Closure Id 371 NRC Question KAB065 Number Select Licensee Response Application Attachment Attachment 1 to KAB065.pdf (81KB) 1 Attachment Attachment 2 SQN-EEB-MS-T128-0076.pdf (14MB) 2 Response In response to KAB065, the RCP Underfrequency Relay setpoint calculation Statement number SQN-EEB-MS-TI28-0076, Revision 5, has been revised . Revision 7 revises the RCP underfrequency relay drift, Measuring and Test Equipment (M&TE) values and calibration tolerances to support the implementation of TSTF-493. Due to the reference accuracy of the relay greatly exceeding the minimum increment available to adjust the relay setpoint, the drift value is considered negligible and set to zero. This drift value has been factored into the as-found value calculation using the square root sum of the squares method based on TSTF-493, Revision 4, which incorporated the guidance of RIS 2006-17. The accuracy of the M&TE is also addressed in the calculation revision. The reference accuracy of the underfrequency relay is +/-0.008 Hz, the M&TE will be at least as accurate as the underfrequency relay. TVAs standard program and processes dictates that the calibration standards shall have an accuracy of at least four times the required accuracy of the M&TE being calibrated. When it is not possible to have a 4:1 ratio, standards shall have an accuracy that ensures that the plant equipment being calibrated will be within its required tolerances. The basis for acceptance of standards with accuracies less than four times that of the M&TE will be documented and authorized by the responsible TVA management. With the calibration requirements of the M&TE to a reference standard and the M&TE being at least as accurate as the underfrequency relay, which is in compliance with TVAs calibration program, the as-found values will be low enough to detect potential degradation of the instrument.

Additionally, as a result of the increased accuracy used in calculation, SQN-EEB-MS-TI28-0076, Revision 7, the Allowable Value (AV) for ITS Table 3.3.1-1, Function 12 (Underfrequency RCPs), on pages 120 and 152 of Enclosure 2, Volume 8, will be revised. The AV will be revised from the originally proposed value of 56.3 Hz to 56.973 Hz. Corresponding changes will be made to the CTS markups for CTS Table 2.2-1, Functional Unit 16 (Underfrequency-Reactor Coolant Pumps), and Discussion of Change M24.

See Attachment 1 for the draft revised CTS and ISTS markups.

See Attachment 2 for the revised calculation for the RCP underfrequency relays.

Response

10/16/2014 2:05 PM Date/Time https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=371 1/13/2015

Sequoyah ITS Conversion Database Page 2 of 2 Closure Statement Question Closure Date Notification Scott Bowman Kristy Bucholtz Michelle Conner Khadijah Hemphill Andrew Hon Lynn Mynatt Ray Schiele Added By Scott Bowman Date Added 10/16/2014 1:05 PM Date Modified Modified By https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=371 1/13/2015

Enclosure 2, Volume 8, Rev. 0, Page 22 of 1148 ITS A01 ITS 3.3.1 Table 3.3.1-1 TABLE 2.2-1 (Continued)

REACTOR TRIP SYSTEM INSTRUMENTATION TRIP SETPOINTS FUNCTIONAL UNIT NOMINAL TRIP SETPOINT ALLOWABLE VALUES

14. Deleted 56.973 11 15. Undervoltage-Reactor 5022 volts-each bus 4739 volts-each bus Coolant Pumps 57.0 M24 56.3 12

16. Underfrequency-Reactor 56.0 Hz - each bus 55.9 Hz - each bus Coolant Pumps 14

17. Turbine Trip A. Low Trip System 45 psig 39.5 psig Pressure B. Turbine Stop Valve 1% open 1% open Closure 15 18. Safety Injection Input Not Applicable Not Applicable from ESF 16.a 19. Intermediate Range Neutron 1 x 10-4% of RATED THERMAL 6 x 10-5% of RATED Flux - (P-6) Enable Block POWER THERMAL POWER Source Range Reactor Trip LA07 16.e 20. Power Range Neutron Flux 10% of RATED THERMAL 12.4% of RATED (not P-10) Input to Low Power POWER THERMAL POWER Reactor Trips Block P-7 A21 September 20, 2007 SEQUOYAH - UNIT 1 2-6a Amendment No. 16, 85, 136, 141, 307, 310, 316 Page 18 of 47 Enclosure 2, Volume 8, Rev. 0, Page 22 of 1148

Enclosure 2, Volume 8, Rev. 0, Page 46 of 1148 ITS A01 ITS 3.3.1 Table 3.3.1-1 TABLE 2.2-1 (Continued)

REACTOR TRIP SYSTEM INSTRUMENTATION TRIP SETPOINTS FUNCTIONAL UNIT NOMINAL TRIP SETPOINT ALLOWABLE VALUES

b. RCS Loop T Equivalent to Power > 50% RTP Coincident with Steam Generator Water 15.0% of narrow range 14.4% of narrow range Level -- Low-Low (Adverse) instrument span instrument span and Containment Pressure (EAM) 0.5 psig 0.6 psig or Steam Generator Water 10.7% of narrow range 10.1% of narrow range Level -- Low-Low (EAM) instrument span instrument

14. Deleted 56.973 11 15. Undervoltage-Reactor 5022 volts-each bus 4739 volts - each bus Coolant Pumps M24 57.0 56.3 12 16. Underfrequency-Reactor 56.0 Hz - each bus 55.9 Hz - each bus Coolant Pumps 14 17. Turbine Trip 14.a A. Low Trip System 45 psig 39.5 psig Pressure 14.b B. Turbine Stop Valve 1% open > 1% open Closure 15

18. Safety Injection Input from Not Applicable Not Applicable ESF September 20, 2007 SEQUOYAH - UNIT 2 2-7 Amendment Nos. 7, 76, 132, 296, 299, 306 Page 42 of 47 Enclosure 2, Volume 8, Rev. 0, Page 46 of 1148

Enclosure 2, Volume 8, Rev. 0, Page 76 of 1148 DISCUSSION OF CHANGES ITS 3.3.1, REACTOR TRIP SYSTEM (RTS) INSTRUMENTATION requirements to ensure that the automatic protective action will correct the abnormal situation before a safety limit is exceeded. This change is consistent with TSTF-493 Option A. This change is considered a more restrictive change because additional requirements have been added to Surveillance Requirements.

56.973 M24 CTS Table 2.2-1 for Functional Unit 16 (Underfrequency-Reactor Coolant Pumps) lists the Nominal Trip Setpoint as 56.0 Hz - each bus, and the Allowable Value as 55.9 Hz - each bus. ITS Table 3.3.1-1 for Function 12 (Underfrequency RCPs) lists the Nominal Trip Setpoint as 57.0 Hz and the Allowable Value as 56.3 Hz. This changes the CTS by increasing the Nominal Trip Setpoint and the Allowable Value for the Underfrequency RCP reactor trip.

Additionally, TVA is proposing to The purpose of the Underfrequency RCP reactor trip is to ensure that protection change the is provided against violating the DNBR limit due to a loss of flow in two or more Allowable Value RCS loops from a major network frequency disturbance. TVA has determined based on TVA's that to provide adequate protection changes to the Underfrequency RCP Nominal Trip Setpoint and the Allowable Value are needed. This change was value revised calculations previously proposed in SQN license amendment request TVA-SQN-TS-02-01, necessary to Revision 1 (ADAMS Accession No. 042430467) but later withdrawn in TVA-SQN-support the TS-02-01, Revision 2 (ADAMS Accession No. ML061990303) pending resolution implementation of of issues with TSTF-493. In Revision 2 TVA stated that a new TS amendment TSTF-493. request would be submitted to the NRC once TSTF-493 receives NRC approval.

As TSTF-493 has been approved by the NRC and is being adopted under this conversion, TVA is proposing to change the setpoints to those proposed in the previous submittal. This change is acceptable because the revised Allowable Value and Nominal Trip Setpoint continue to provide assurance that the safety limit for the underfrequency reactor trip function is not impacted. In addition, this change ensures instrument uncertainties have been included in the as-found tolerance calculations in a manner that is acceptable and the surveillance Note requirements also ensure that there will be a reasonable expectation that these instruments will perform their safety function if required. This change is designated as more restrictive because more stringent acceptance requirements are being applied in the ITS than were applied in the CTS.

These changes are Nominal Trip S RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES LA01 (Type 5 - Removal of SR Frequency to the Surveillance Frequency Control Program) The proposed change removes all designated periodic Surveillance Frequencies from CTS 4.3.1.1.1, as addressed in CTS Table 4.3-1, CTS 4.3.1.1.2, and CTS 4.3.1.1.3, and places the Frequencies under licensee control in accordance with a new program, the Surveillance Frequency Control Program.

ITS 3.3.1 Surveillance Requirements require similar Surveillances and, except for special or conditional frequencies stated in the individual surveillance, specifies the periodic Frequency as, "In accordance with the Surveillance Frequency Sequoyah Unit 1 and Unit 2 Page 25 of 45 Enclosure 2, Volume 8, Rev. 0, Page 76 of 1148

Enclosure 2, Volume 8, Rev. 0, Page 120 of 1148 CTS RTS Instrumentation (Without Setpoint Control Program) 1 3.3.1A 56.973 Table 3.3-1 Table 3.3.1-1 (page 4 of 8)

Table 4.3-1 Reactor Trip System Instrumentation APPLICABLE MODES (l)

OR OTHER [NOMINAL SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE TRIP 3 FUNCTION CONDITIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT]

12 56.3 57.0 (g) 2 3 17 13. Underfrequency 1 [3] per bus K SR 3.3.1.9 (b)(c) [57.1] Hz [57.5] Hz Table 2.2-1 RCPs SR 3.3.1.10 1 SR 3.3.1.16 9 Function 16 14 13 14 14. Steam Generator 1,2 [4 per SG] E SR 3.3.1.1(b)(c) [30.4]% [32.3]%

Table 2.2-1 (SG) Water Level - SR 3.3.1.7 (b)(c)

Function 13 Low Low INSERT 4 SR 3.3.1.10 SR 3.3.1.16 14 INSERT 5

15. SG Water Level - 1,2 2 per SG E SR 3.3.1.1(b)(c) [30.4]% [32.3]%

Low SR 3.3.1.7 (b)(c) 2 SR 3.3.1.10 SR 3.3.1.16 Coincident with 1,2 2 per SG E SR 3.3.1.1(b)(c) [42.5]% full [40]% full Steam SR 3.3.1.7 (b)(c) steam flow at steam flow at Flow/Feedwater Flow SR 3.3.1.10 RTP RTP SR 3.3.1.16 Mismatch 14 18 2 Table 2.2-1 16. Turbine Trip h Function 17 L 39.5 45 (j) (b)(c)

a. Low Fluid Oil 1 3 N SR 3.3.1.10 [750] psig [800] psig 2 3 Pressure SR 3.3.1.15 13 (j)

b. Turbine Stop 1 4 N SR 3.3.1.10 [1]% open [1]% open 2 3 Valve Closure SR 3.3.1.15 2 M

15 13 19 17. Safety Injection (SI) 1,2 2 trains O SR 3.3.1.14 NA NA 2 Table 2.2-1 Input from Function 18 12 Engineered Safety Feature Actuation System (ESFAS)

DOC M22 (b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

DOC M23 (c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTSP and the methodologies used to determine the as-found and 10 as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR 3

by reference]. UFSAR Section 7.1.2 DOC L02 (g) Above the P-7 (Low Power Reactor Trips Block) interlock.

h Note ** (j) Above the P-9 (Power Range Neutron Flux) interlock. 2

REVIEWERS NOTE--------------------------------------------------------------------------------------

(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. 4 Sequoyah Unit 1 Amendment XXX Westinghouse STS 3.3.1A-20 Rev. 4.0 2 1 Enclosure 2, Volume 8, Rev. 0, Page 120 of 1148

Enclosure 2, Volume 8, Rev. 0, Page 152 of 1148 CTS RTS Instrumentation (Without Setpoint Control Program) 1 3.3.1A 56.973 Table 3.3-1 Table 3.3.1-1 (page 4 of 8)