ML051260464

RAI, Normal Trip Setpoints Using Revised Method 3 (Tac No. MC4408, MC4409) (TVA-SQN-TS-02-01)

ML051260464
Person / Time
Site:	Sequoyah
Issue date:	05/19/2005
From:	Pickett D NRC/NRR/DLPM/LPD2
To:	Singer K Tennessee Valley Authority
Pickett D, NRR/DLPM, 415-1364
References
TAC MC4408, TAC MC4409
Download: ML051260464 (5)

Text

May 19, 2005 Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 REQUEST FOR ADDITIONAL INFORMATION REGARDING NOMINAL TRIP SETPOINTS (TAC NOS. MC4408 AND MC4409) (TVA-SQN-TS-02-01)

Dear Mr. Singer:

The U. S. Nuclear Regulatory Commission (NRC) staff is continuing its review of your application dated August 18, 2004, Technical Specification Change No. 02-01, Revision 1, Nominal Trip Setpoints for Reactor Protection System and Engineered Safety Features Instrumentation. As described in the staffs letter to the Nuclear Energy Institute dated March 31, 2005 (Agencywide Documents and Access Management Systems accession No. ML050910433), the NRC staff has adopted an interim approach in its review of licensing amendment requests. In this regard, the staff will be requesting additional information in the form of the enclosed Revised Method 3 Request for Additional Information and the following three items:

1. An explicit regulatory commitment to adopt the final Technical Specification Task Force technical specification change to come into conformance with the existing understanding of the requirements of 10 CFR 50.36.

2. An explicit regulatory commitment to assess the operability of tested instrumentation based on the previous as-left instrument setting and accounting for the uncertainties associated with the test or calibration.

3. A revision to the technical specifications for the limiting safety system settings being changed by the license amendment request to incorporate a footnote that states:

The as-left instrument setting shall be returned to a setting within the tolerance band of the trip setpoint established to protect the safety limit.

K. Singer If you believe you have previously provided information on the docket that satisfies the enclosed request for additional information, please provide the appropriate reference.

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosure:

As stated cc w/enclosure: See next page

ML051260464 NRR-088 OFFICE PDII-2/PM PDII-2/LA SC:EEIB PDII-2/SC NAME DPickett BClayton EMarinos MMarshall DATE 05 / 09 / 05 05 / 09 / 05 05 / 12 / 05 05 / 19 / 05 Mr. Karl W. Singer SEQUOYAH NUCLEAR PLANT Tennessee Valley Authority cc:

Mr. Ashok S. Bhatnagar, Senior Vice President Mr. Paul L. Pace, Manager Nuclear Operations Licensing and Industry Affairs Tennessee Valley Authority ATTN: James D. Smith 6A Lookout Place Sequoyah Nuclear Plant 1101 Market Street Tennessee Valley Authority Chattanooga, TN 37402-2801 P.O. Box 2000 Soddy Daisy, TN 37384-2000 Mr. Larry S. Bryant, General Manager Nuclear Engineering Mr. David A. Kulisek, Plant Manager Tennessee Valley Authority Sequoyah Nuclear Plant 6A Lookout Place Tennessee Valley Authority 1101 Market Street P.O. Box 2000 Chattanooga, TN 37402-2801 Soddy Daisy, TN 37384-2000 Mr. Randy Douet Senior Resident Inspector Site Vice President Sequoyah Nuclear Plant Sequoyah Nuclear Plant U.S. Nuclear Regulatory Commission Tennessee Valley Authority 2600 Igou Ferry Road P.O. Box 2000 Soddy Daisy, TN 37379 Soddy Daisy, TN 37384-2000 Mr. Lawrence E. Nanney, Director General Counsel Division of Radiological Health Tennessee Valley Authority Dept. of Environment & Conservation ET 11A Third Floor, L and C Annex 400 West Summit Hill Drive 401 Church Street Knoxville, TN 37902 Nashville, TN 37243-1532 Mr. John C. Fornicola, Manager County Mayor Nuclear Assurance and Licensing Hamilton County Courthouse Tennessee Valley Authority Chattanooga, TN 37402-2801 6A Lookout Place 1101 Market Street Ms. Ann P. Harris Chattanooga, TN 37402-2801 341 Swing Loop Road Rockwood, Tennessee 37854 Mr. Fredrick C. Mashburn Senior Program Manager Nuclear Licensing Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801

REVISED METHOD 3 REQUEST FOR ADDITIONAL INFORMATION The Sequoyah Nuclear Power Plant (SQN), Units 1 and 2, Technical Specifications (TSs) define Limiting Safety System Settings (LSSS) as an allowable value (AV). During reviews of proposed license amendments that contain changes to LSSS setpoints, the U. S. Nuclear Regulatory Commission (NRC) staff identified concerns regarding the method used by some licensees to determine the AVs identified in the TSs. AVs are identified in the TS as LSSS to provide acceptance criteria for determination of instrument channel operability during periodic surveillance testing. The NRC staffs concern relates to one of the three methods for determining the AV as described in the Instrument Society of America (ISA) recommended practice ISA-RP67.04-1994, Part II, Methodologies for Determination of Setpoints for Nuclear Safety-Related Instrumentation.

The NRC staff has determined that to ensure a plant will operate in accordance with the assumptions upon which the plant safety analyses have been based, additional information is required regardless of the methodology used to establish LSSS values in TSs. Details about the NRC staff's concerns are available on the NRC's public website under ADAMS Accession Numbers ML041690604, ML041810346, and ML050670025.1 In order for the NRC staff to assess the acceptability of your license amendment request related to this issue, the staff requests the following additional information:

1. Discuss the setpoint methodology used at SQN to establish AVs associated with LSSS setpoints.

2. Regardless of the methodology used, the NRC staff has the following questions regarding the use of the methodology at SQN:

a. Discuss how the methodology and controls you have in place ensure that the analytical limit (AL) associated with an LSSS will not be exceeded (the AL is a surrogate that ensures the safety limits will not be exceeded). Include in your discussion information on the controls you employ to ensure the trip setpoint established after completing periodic surveillances satisfies your methodology. If the controls are located in a document other than the TSs, discuss how those controls satisfy the requirements of 10 CFR 50.36.

b. Discuss how the TS surveillances ensure the operability of the instrument channel. This should include a discussion on how the surveillance test results relate to the TS AV and describe how these are used to determine the operability of the instrument channel. If the requirements for determining operability of the LSSS instrument being tested are in a document other than the TS (e.g., plant test procedure), discuss how this meets the requirements of 10 CFR 50.36.

1 To access the document, go to www.nrc.gov, click on Electronic Reading Room, then Documents in ADAMS, then Web-Based Access, then "Begin ADAMS Search," then Advanced Search, and enter the accession number into the Accession Number box near the top of the page. Click on the Search button near the bottom of the page. You will need to select Image File on the search results page to view the document. NOTE: You will need Adobe Acrobat Reader to open this file.

Enclosure