ML051260464
| 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 Nuclear Operations Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Larry S. Bryant, General Manager Nuclear Engineering Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Randy Douet Site Vice President Sequoyah Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Soddy Daisy, TN 37384-2000 General Counsel Tennessee Valley Authority ET 11A 400 West Summit Hill Drive Knoxville, TN 37902 Mr. John C. Fornicola, Manager Nuclear Assurance and Licensing Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Fredrick C. Mashburn Senior Program Manager Nuclear Licensing Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Paul L. Pace, Manager Licensing and Industry Affairs ATTN: James D. Smith Sequoyah Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Soddy Daisy, TN 37384-2000 Mr. David A. Kulisek, Plant Manager Sequoyah Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Soddy Daisy, TN 37384-2000 Senior Resident Inspector Sequoyah Nuclear Plant U.S. Nuclear Regulatory Commission 2600 Igou Ferry Road Soddy Daisy, TN 37379 Mr. Lawrence E. Nanney, Director Division of Radiological Health Dept. of Environment & Conservation Third Floor, L and C Annex 401 Church Street Nashville, TN 37243-1532 County Mayor Hamilton County Courthouse Chattanooga, TN 37402-2801 Ms. Ann P. Harris 341 Swing Loop Road Rockwood, Tennessee 37854
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 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.