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MONTHYEARML0603300482006-02-10010 February 2006 Documentation of Request for Additional Information Project stage: RAI ML0603304472006-02-27027 February 2006 RAI, Technical Specification Change to Modify Auxiliary Feedwater Start Signal Upon Trip of Main Feedwater Pumps Project stage: RAI ML0615903172006-05-25025 May 2006 Technical Specification (TS) Change No. 04-013 - Auxiliary Feedwater (AFW) Start Upon Trip of Turbine Driven Main Feedwater (Tdmfw) Pumps - Request for Additional Information (RAI) Project stage: Request ML0621304532006-07-28028 July 2006 Technical Specification Change No. 04-013 - Withdrawal of Proposed License Amendment Request Project stage: Withdrawal ML0621501532006-08-0808 August 2006 Withdrawal of Amendment Request TS-04-13 (TAC MC4586), Trip of All Main Feedwater Pumps Project stage: Withdrawal 2006-05-25
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Category:Letter
MONTHYEARML23319A2452024-01-29029 January 2024 Issuance of Amendment Nos. 366 and 360; 164 and 71 Regarding the Adoption of TSTF-567, Revision 1, Add Containment Sump TS to Address GSI-191 Issues ML24008A2462024-01-18018 January 2024 Revision to the Reactor Vessel Material Surveillance Capsule Withdrawal Schedule CNL-24-017, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure and Emergency Preparedness Department Procedure Revisions2024-01-17017 January 2024 Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure and Emergency Preparedness Department Procedure Revisions CNL-24-016, Supplement to Application to Modify the Technical Specification Surveillance Requirement 3.9.5.1 (WBN-TS-21-14)2024-01-10010 January 2024 Supplement to Application to Modify the Technical Specification Surveillance Requirement 3.9.5.1 (WBN-TS-21-14) CNL-23-052, Application to Adopt TSTF-427-A, Revision 2, Allowance for Non-Technical Specification Barrier Degradation on Supported System Operability2024-01-0909 January 2024 Application to Adopt TSTF-427-A, Revision 2, Allowance for Non-Technical Specification Barrier Degradation on Supported System Operability CNL-23-062, Application to Revise the Technical Specifications Section 3.8.2, AC Sources-Shutdown, to Remove Reference to the C-S Diesel Generator (WBN-TS-23-018)2024-01-0808 January 2024 Application to Revise the Technical Specifications Section 3.8.2, AC Sources-Shutdown, to Remove Reference to the C-S Diesel Generator (WBN-TS-23-018) ML23346A1382024-01-0303 January 2024 Regulatory Audit Summary Related to Request to Increase the Number of Tritium Producing Burnable Absorber Rods CNL-23-069, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-12-21021 December 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation IR 05000390/20234412023-12-21021 December 2023 Plantfinal Significance Determination for a Security-Related Greater than Green Finding, Nov, and Assessment Follow-up, 05000390-2023441 and 05000391-2023441-Public CNL-23-036, Application to Revise Function 5 of Technical Specification Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, for the Sequoyah Nuclear Plant and Watts Bar Nuclear Plant (SQN-TS-23-02 and WBN-TS-23-08)2023-12-18018 December 2023 Application to Revise Function 5 of Technical Specification Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, for the Sequoyah Nuclear Plant and Watts Bar Nuclear Plant (SQN-TS-23-02 and WBN-TS-23-08) IR 05000390/20234042023-12-14014 December 2023 Security Baseline Inspection Report 05000390/2023404 and 05000391/2023404 CNL-23-001, Rebaseline of Sections 3.1 and 3.2 of the Technical Specifications (WBN-TS-23-01)2023-12-13013 December 2023 Rebaseline of Sections 3.1 and 3.2 of the Technical Specifications (WBN-TS-23-01) ML23293A0572023-12-0606 December 2023 Issuance of Amendment Nos. 163 and 70 Regarding Adoption of TSTF-501-A, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control IR 05000390/20230102023-11-30030 November 2023 RE-Issue Watts Bar Nuclear Plant - Biennial Problem Identification and Resolution Inspection Report 050000390/2023010 and 05000391/2023010 and Apparent Violation CNL-23-067, Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-11-27027 November 2023 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions IR 05000390/20230032023-11-13013 November 2023 Integrated Inspection Report 05000390/2023003 and 05000391/2023003 and Apparent Violation ML23312A1432023-11-0808 November 2023 Submittal of Dual Unit Updated Final Safety Analysis Report (UFSAR) Amendment 5 CNL-23-059, Supplement to Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2, Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-2023-09-20020 September 2023 Supplement to Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2, Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-03 CNL-23-061, Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revision2023-09-20020 September 2023 Tennessee Valley Authority - Central Emergency Control Center Emergency Plan Implementing Procedure Revision ML23251A2002023-09-11011 September 2023 Request for Withholding Information from Public Disclosure for Watts Bar Nuclear Plant, Units 1 and 2 CNL-23-057, Central Emergency Control Center Emergency Plan Implementing Procedure Revisions. Includes CECC-EPIP-1, Revision 76 and CECC-EPIP-9, Revision 642023-09-0505 September 2023 Central Emergency Control Center Emergency Plan Implementing Procedure Revisions. Includes CECC-EPIP-1, Revision 76 and CECC-EPIP-9, Revision 64 IR 05000390/20230052023-08-30030 August 2023 Updated Inspection Plan for Watts Bar Nuclear Plant, Units 1 and 2 - Report 05000390/2023005 and 05000391/2023005 ML23233A0042023-08-28028 August 2023 Proposed Alternative to the Requirements of the ASME Boiler and Pressure Vessel Code for Upper Head Injection Dissimilar Metal Butt Welds IR 05000390/20230022023-08-16016 August 2023 Reissue - Watts Bar Nuclear Plant - Integrated Inspection Report 05000390/2023002 and 05000391/2023002 ML23220A1582023-08-0909 August 2023 Integrated Inspection Report 05000390/2023002 and 05000391/2023002 CNL-23-045, License Amendment Request to Revise Technical Specification Table 1.1-1 Regarding the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Bolts (WBN-TS-23-010)2023-08-0707 August 2023 License Amendment Request to Revise Technical Specification Table 1.1-1 Regarding the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Bolts (WBN-TS-23-010) CNL-23-028, Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-03 and WBN-TS-23-06)2023-08-0202 August 2023 Application to Revise Technical Specifications to Adopt TSTF-567-A, Revision 1, Add Containment Sump TS to Address GSI-191 Issues (SQN-TS-23-03 and WBN-TS-23-06) ML23192A4472023-07-31031 July 2023 Staff Assessment of Updated Seismic Hazards at TVA Sites Following the NRC Process for the Ongoing Assessment of Natural Hazards Information CNL-23-055, Tennessee Valley Authority - Emergency Preparedness Department Procedure Revision. Includes EPDP-3, Revision 3, Emergency Plan Exercises and Preparedness Drills2023-07-25025 July 2023 Tennessee Valley Authority - Emergency Preparedness Department Procedure Revision. Includes EPDP-3, Revision 3, Emergency Plan Exercises and Preparedness Drills IR 05000390/20230112023-07-24024 July 2023 Quadrennial Focused Engineering Inspection (FEI) Commercial Grade Dedication Report 05000390 2023011 and 05000391 2023011 CNL-23-053, Tennessee Valley Authority - Radiological Emergency Plan Revisions2023-07-18018 July 2023 Tennessee Valley Authority - Radiological Emergency Plan Revisions CNL-23-020, Application to Revise Technical Specifications to Adopt TSTF-501-A, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control (WBN-TS-22-06)2023-06-28028 June 2023 Application to Revise Technical Specifications to Adopt TSTF-501-A, Revision 1, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control (WBN-TS-22-06) CNL-23-049, Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan .2023-06-26026 June 2023 Tennessee Valley Authority - Radiological Emergency Plan and Central Emergency Control Center Emergency Plan . ML23122A2322023-06-0707 June 2023 Issuance of Amendment Nos. 162 and 69 Regarding Change to Date in Footnotes for Technical Specification 3.7.11, Control Room Emergency Air Temperature Control System (Creatcs) CNL-23-044, Transmittal of Revision 3 to WCAP-18774-P and WCAP-18774-NP, Addendum to the Rotterdam Dockyard Company Final Stress Report for 173 P.W.R. Vessels TVA III & IV (Report No. 30749-B-030, Rev. 3) - Evaluation of One Closure Stud Out2023-06-0101 June 2023 Transmittal of Revision 3 to WCAP-18774-P and WCAP-18774-NP, Addendum to the Rotterdam Dockyard Company Final Stress Report for 173 P.W.R. Vessels TVA III & IV (Report No. 30749-B-030, Rev. 3) - Evaluation of One Closure Stud Out IR 05000390/20234032023-05-30030 May 2023 Cyber Security Inspection Report 05000390/2023403 and 05000391/2023403 ML23131A1812023-05-23023 May 2023 Correction to Amendment No. 161 to Facility Operating License No. NPF-90 CNL-23-042, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-05-16016 May 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions IR 05000390/20220032023-05-0909 May 2023 Reissue Watts Bar Nuclear Plant - Integrated Inspection Report 05000390/2022003 and 05000391/2022003 ML23125A2202023-05-0505 May 2023 Issuance of Amendment No. 161 Regarding a Change to Footnotes for Technical Specification Table 1.1-1 Modes (Emergency Circumstances) IR 05000390/20230012023-05-0404 May 2023 Integrated Inspection Report 05000390/2023001 and 05000391/2023001 CNL-23-043, Emergency License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 1.1-1, Modes (WBN-TS-23-09)2023-05-0404 May 2023 Emergency License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 1.1-1, Modes (WBN-TS-23-09) CNL-23-032, Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Unit 1 and 2, Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 412023-04-27027 April 2023 Clinch River, Sequoyah, Units 1 and 2, Watts Bar, Unit 1 and 2, Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 41 CNL-23-030, Tennessee Valley Authority - Hydrologic Engineering Center River Analysis System Project Milestone Status Update2023-04-27027 April 2023 Tennessee Valley Authority - Hydrologic Engineering Center River Analysis System Project Milestone Status Update CNL-23-033, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revision2023-04-24024 April 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revision CNL-23-029, Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions2023-04-11011 April 2023 Radiological Emergency Plan and Central Emergency Control Center Emergency Plan Implementing Procedure Revisions ML23072A0652023-04-0505 April 2023 Units 1 and 2 Issuance of Amendment Nos. 364 and 358; 160 and 68 Regarding a Revision to Technical Specification 3.4.12 ML23073A2762023-04-0303 April 2023 Individual Notice of Consideration of Issuance of Amendments to Facility Operating Licenses, Proposed No Significant Hazards Consideration Determination, and Opportunity for a Hearing (EPID L-2023-LLA-0029) (Letter) CNL-23-023, Annual Insurance Status Report2023-03-30030 March 2023 Annual Insurance Status Report CNL-23-024, TVA Guarantee of Payment of Deferred Premiums - 2022 Annual Report2023-03-29029 March 2023 TVA Guarantee of Payment of Deferred Premiums - 2022 Annual Report 2024-01-09
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Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 MAY 2 5 lO1 10 CFR 50.90 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Gentlemen:
In the Matter of ) Docket No. 50-390 Tennessee Valley authority WATTS BAR NUCLEAR PLANT (WBN) UNIT 1 - TECHNICAL SPECIFICATION (TS) CHANGE NO.04-013 - AUXILARY FEEDWATER (AFW) START UPON TRIP OF TURBINE DRIVEN MAIN FEEDWATER (TDMFW) PUMPS - REQUEST FOR ADDITIONAL INFORMATION (RAI) - TAC NO. MC 4586 As a result of a teleconference regarding the subject TS Change on January 27, 2006, NRC issued a RAI on February 27, 2006. The enclosure provides the TVA response to this RAI.
The delay in submitting this response was coordinated with the NRC Staff.
There are no regulatory commitments associated with this letter. If you have any questions concerning this matter, please call me at (423) 365-1824.
I declare under penalty of perjury that the foregoing is true and correct. Executed on this 2 5 th day of May 2006.
Sincerely, 74Pa P Pace Manager, Site Licensing and Industry Affairs Enclosure
- 1. Response to Request for Additional Information cc: See Page 2 Printed on recycled paper
U.S. Nuclear Regulatory Commission Page 2 MAY 2 5 2006 Enclosure cc (Enclosure)
NRC Resident Inspector Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381 Mr. D. V. Pickett, Senior Project Manager U.S. Nuclear Regulatory Commission MS 08G9a One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 U.S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. Lawrence E. Nanny, Director Division of Radiological Health 3 rd Floor L & C Annex 401 Church Street Nashville, Tennessee 37243
ENCLOSURE WATTS BAR NUCLEAR PLANT, UNIT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION "The operability requirement that is specified by Technical Specification (TS) Table 3.3.2-1, "Engineered Safety Feature Actuation System Instrumentation," Item 6.e, "Trip of All Turbine Driven Main Feedwater Pumps," provides defense-in-depth for the low-low steam generator water level setpoint that is relied upon by the accident analyses for actuating the auxiliary feedwater system. This circuitry is required to be operable in Modes 1 and 2 because, as explained in the Basis for this Technical Specification requirement: "In MODES 3, 4, and 5, the RCPs and MFW pumps may be normally shut down, and thus neither pump trip is indicative of a condition requiring automatic AFW initiation."
Note that the TS Basis indicates that a loss of all main feedwater while operating in Modes 1 and 2 will automatically initiate AFW flow to the steam generators for decay heat and sensible heat removal without the need to rely upon operator actions. The practice of using the standby main feedwater pump until the plant is operating at around 18 percent power before starting a turbine driven main feedwater pump renders this AFW initiation circuitry incapable of performing its function in Mode 2 (as well as in Mode 1 below 18 percent power) and does not appear to satisfy the intent of the TS requirement that was established. In order to satisfy the intent of the TS requirement, the AFW automatic initiation circuitry would also have to apply to the standby main feedwater pump when it is being used in Modes 1 and 2 for providing steam generator makeup water. The fact that the turbine driven main feedwater pumps are not normally started until the plant reaches 18 percent power does not justify the proposed change; the intent of the existing TS requirement must be considered and addressed.
Therefore, the following additional information is required:
- 1. Please explain why the existing TS requirement should not be applicable to operation of the standby main feedwater pump when it is being used in lieu of a turbine driven main feedwater pump when the plant is operating in Modes 1 or 2 (up to about 18 percent power) so that a loss of the standby main feedwater pump will automatically actuate the AFW system, consistent with the discussion that is provided in the TS Basis."
Response to Question 1 The WBN TS Bases, in section B3.3.2.6.e, are clear that AFW activation is associated with just the Turbine Driven Main Feed Water (TDMFW) pumps and that absence of a discussion concerning E-1
the Standby Main Feedwater (SBMFW) is consistent with the WBN hardware configuration. WBN's motor driven standby main feedwater pump (SBMFWP) control circuitry does not contain the control logic necessary to provide the auxiliary feedwater auto start function due to the loss of all of main feedwater. The motor driven standby main feedwater pump (SBMFWP) was designed for operation at power and during startup. In particular, it was designed for use during startup and shutdown of the plant and does not have the capacity that the TDMFW pumps have. At WBN, only the TDMFW pumps contain the logic to provide this function.
There is no mention of the SBMFWP contained in the WBN Technical Specification or its bases. A comparison of the WBN TSs at the time of licensing in 1995 with the Westinghouse Owners Group standard technical specification (WOG STS) in existence during the same timeframe, reveals that while the WOG STS Bases include a reference to the standby main feedwater pump control logic and its trip function, the WBN TS Bases do not.
In addition, the WBN Updated Final Safety Analysis Report (UFSAR) is also clear in describing the SBMFWP and its function.
The UFSAR in various places (e.g. Section 15.2.8, "Loss of Normal Feedwater") describes the trip function as being limited to the TDMFW pumps.
The interaction between AFW start and SBMFW pump operation was reviewed by NRC staff and documented in Safety Evaluation Report, NUREG 0847, Section 10.4.7 on page 10-12 as follows:
"The use of the standby feedwater pump is the normal means for starting up and shutting down the plant. This pump is also automatically activated in the event of the loss of one main feedwater pump. This is accompanied by an automatic turbine runback to 85 percent of load if the power level is above 80 percent of full power. Should main feedwater flow continue to decrease, the auxiliary feedwater system will automatically activate when the low-low steam generator level is reached..."
Changing the plant design to add AFW start function circuitry exceeds 10 CFR 50.36 (c) (2) (ii) technical specification criteria. As discussed in question 2, start of AFW upon loss of the MFWPs is not part of the primary success path for postulated accident mitigation. This view is consistent with the one reflected in the initial comments and questions provided via email by NRC upon review of the original amendment request.
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"2. Please explain why the defense-in-depth capability that is intended by the existing TS requirement is not considered to be necessary for decay heat and sensible heat removal below a power level of 18 percent, considering the maximum heat load that can exist following full power operation.
Note that the NRC typically does not allow automatic safety features to be replaced by manual operator actions and therefore, any credit that is taken for manual operator actions in lieu of automatic protective features must be fully explained and justified."
Response to Question 2 As discussed above in response to Question 1, the motor driven SBMFWP was designed for operation at power and during startup.
In particular it was designed for use during startup and shutdown of the plant. On plant startup, the SBMFWP supplies steam generator makeup to approximately 10 to 15 percent when a turbine driven main feedwater pump is placed into service prior to placing the main turbine into service and closing the generator output breaker for connection to the power grid. On plant shutdown, the opposite situation occurs where the SBMFWP is used when the TDMFW pumps are shutdown as the plant power level decreases. The control logic circuit for the SBMFWP does not include an Auxiliary Feedwater auto start function as the TDMFW pumps have. This was the configuration in which WBN was licensed in 1995. Therefore, the existing TS requirement does not apply for the SBMFWP.
It is also important to note that a trip of the SBMFWP when neither TDMFW pump is in service requires the plant operator to start AFW in accordance with AOI-16, "Loss of Normal Feedwater,"
which provides the same result as the AFW auto start function upon trip of the TDMFW pumps. This manual action predated this amendment application and, besides being procedurally driven, would be the normal response one would expect the operator to perform upon a loss of normal feedwater event. This procedure driven start provides the necessary defense in depth capability.
In addition, automatic action is initiated on low-low level in the steam generator. This remains as the safety grade auxiliary feedwater start. The normal water level in the steam generator varies between approximately 38 percent and 60 percent narrow range. At low power levels, boil off rates are lower than at full power and additional time exists prior to water level depletion in the generator. Therefore, anticipatory start of auxiliary feedwater is not as significant as at higher power levels.
E-3
"3. Please revise the proposed TS and/or TS Basis (as appropriate) to establish requirements that are consistent with the responses to Questions 1 and 2, above."
Response to Question 3 As discussed above, TVA has concluded that no further changes are needed beyond what was indicated in the original amendment request.
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