ML103120711

Instrumentation and Controls Staff Information Requests

ML103120711
Person / Time
Site:	Watts Bar
Issue date:	10/29/2010
From:	Bajestani M Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML103120711 (26)

Text

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 October 29, 2010 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 10 CFR 50.4 NRC Docket No. 50-391

Subject:

WATTS BAR NUCLEAR PLANT (WBN) UNIT 2 - INSTRUMENTATION AND CONTROLS STAFF INFORMATION REQUESTS

Reference:

1. Licensee Open Items to be Resolved for SER Approval List The purpose of this letter is to provide TVA's responses to NRC's information requests on the "Licensee Open Items to be Resolved for SER Approval List." Enclosure 1 to this letter provides TVA's responses to the information requested by NRC. contains the supporting documents for TVA's responses to NRC's requests/questions provided in Enclosure 1. Enclosure 3 contains a list of references on which TVA's responses are based. Enclosure 4 provides a list of the new regulatory commitments contained in this letter.

I declare under the penalty of perjury that the foregoing is true and correct. Executed on the 2 9 th day of October, 2010 If you have any questions, please contact William Crouch at (423) 365-2004.

Sincerely, Masoud *estani Watts B nit 2 Vice President

U.S. Nuclear Regulatory Commission Page 2 October 29, 2010

Enclosures:

1. Responses to Licensee Open Items To Be Resolved For SER Approval

2. Attachments

3. References

4. Regulatory Commitments cc (Enclosures):

U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Resident Inspector Unit 2 Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381

Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval For some NRC RAI requests, this letter provides TVA's initial response. For the other NRC RAI requests in this letter, a response has been provided in previous TVA letters to the NRC and the NRC has subsequently requested additional information. For these requests, the initial TVA response is not repeated below. The additional NRC information requests are identified in this letter as "Follow-up NRC Requests." TVA responses to these items are identified as "TVA Response to Follow-up NRC Request".

1. NRC Request (Item Number 050)

How should the "shall"statements outside of the bracketed requirements in Common Q requirements documents be interpreted?.

Follow-up NRC Request:

TVA response is inconsistent (e.g., WNA-DS-01667-WBT Rev. 1 page 1-1, Section 1.3.1 implies that "SysRS Section ###" has requirements. See also SDS4.4.2. 1-1 on page 4-32).

Is there a requirement on the shall referenced above??

TVA Response to Follow-up NRC Request:

Shall statements within the scope of the System Requirements Specification (SysRS) and System Design Specification (SysDS) were reviewed by Westinghouse. The statements were either relocated to the numbered requirements section or the wording was changed to identify that it was not a requirement. This item is resolved by submittal of revision 2 of the SysRS and the SysDS (attachments 7 and 8 of TVA Letter to NRC dated 10/25/10).

2. NRC Request (Item Number 054)

Please describe all the different environments in which the RM- 1000 will be requiredto operate. Pleasegroup these environments into two categories (a) Harsh environment, per 10 CFR 50.49, and (b) Mild Environment.

Follow-up NRC Request:

What is Reference 3?

TVA Response to Follow-up NRC Request:

Reference 3 is TVA Design Criteria WB-DC-40-54, Environmental Qualification To 10CFR50.49, which provides the definition of mild and harsh environments. Attachment 13 contains WB-DC-40-54, Revision 4.

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Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval

3. NRC Request (Item Number 055)

The "QualificationTest Report Supplement, RM- 1000 Upgrades,"Document No.

04508905-1SPRev. A states that the qualification was done in accordance with IEEE 323-1974 and -1983. Please describe andjustify all differences in this qualification methodology and that endorsed by Regulatory Guide 1.209. Specifically addressEMI and RFI Follow-up NRC Request:

What is Reference 3?

TVA Response to Follow-up NRC Request:

Reference 3 is TVA Design Criteria WB-DC-40-54, Environmental Qualification To 10CFR50.49, which provides the definition of mild and harsh environments. Attachment 13 contains WB-DC-40-54, Revision 4.

4. NRC Request (Item Number 103)

TVA to submit excerpts of EDCR 52321.

TVA Response:

Attachment 1 contains excerpts from draft EDCR 52321 (i.e., draft Scope and Intent, Unit Difference and Technical Evaluation). The final excerpts will be submitted within two weeks after issuance of the EDCR.

5. NRC Request (Item Number 104)

TVA to submit excerpts of EDCR 52351.

TVA Response:

Attachment 2 contains excerpts from draft EDCR 52351 (i.e., draft Scope and Intent, Unit Difference and Technical Evaluation). The final excerpts will be submitted within two weeks after issuance of the EDCR.

6. NRC Request (Item Number 114)

Provide the resolution of the Eagle 21 Rack 5 lockup on update issue.

Follow-up NRC Request:

The write-up shows that there was differences between Unit 1 and 2 but was not identified to NRC in earlierresponse. Are there any more surpriseslike this?

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Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval TVA Response to Follow-up NRC Request:

The Eagle 21 system is installed and the Site Acceptance Test has been completed. To the best of TVA's knowledge there are no unknown issues with the system.

7. NRC Request (Item Number 117)

Does TVA use a single sided or double sided methodology for as-found and as-left instrumentsetpoint values. (RIS2006-7)

Follow-up NRC Request:

TVA needs to address that trip setpoint and allowable value uncertaintiesare not reduced by the reduction factor for the single sided reduction factor. TVA response not acceptable.

TVA need to clarify if single sided methodology has been used in calculating trip setpoint and allowable value and if it is used then providejustifications.

TVA Response to Follow-up NRC Request:

For Technical Specification Tracking Form (TSTF) 493 parameters, WBN Unit 2 uses only double-sided correction factors. Attachment 3 contains the FSAR Amendment 102 Change Markups that reflect this change.

8. NRC Request (Item Number 118)

TVA to submit excerpts of EDCR 55385 TVA Response:

Attachment 4 contains excerpts from draft EDCR 55385 (i.e., draft Scope and Intent, Unit Difference and Technical Evaluation). The final excerpts will be submitted within two weeks after issuance of the EDCR.

9. NRC Request (Item Number 128)

Submit the report on the final resolution of the Eagle 21 Rack 2 RTD input issue TVA Response:

This item will be corrected by a design change based on the following:

The Unit 1/Unit 2 Eagle 21 configuration has a sufficient number of spare Narrow Range (NR) and Wide Range (WR) RTD inputs available on the installed ERI-01 and ERI-02 boards to wire these spare inputs to the active channels. The spare input will provide the parallel resistance to resolve the problem. The WR RTD inputs provide the same input impedance as the NR RTD inputs. Jumpers will be installed at the Eagle 21 termination frame to provide a parallel connection from each existing NR RTD input to an existing spare input, thus simulating the hardware connection for shared RTDs. Therefore, as configured, the Rack 2 Loop Calculation Processor (LCP) will provide the correct 3

Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval temperature calculation for the NR RTDs. The design change will be issued by April 29, 2011.

Post modification testing will be performed to verify that the design change corrects the Eagle 21, Rack 2 RTD accuracy issue prior to WBN Unit 2 fuel load.

10. NRC Request (Item Number 140)

The first requirement in the WBN2 PAMS SysRS (i.e., R2.2-1) states: "The PAMS shall be capable of operation during normal and abnormalenvironments and plant operating modes." The rationalfor this requirementis that it is necessary to meet Regulatory Guide (RG) 1.97.

What document specifies which RG 1.97 variablesare implemented in the Common Q based WBN2 PAMS?

TVA Response:

WBN Unit 2 FSAR Amendment 100 Section 7.5.1.8, "Post Accident Monitoring System (PAMS)" specifies the Reg. Guide 1.97 variables implemented in the Common Q based WBN Unit 2 PAMS.

11. NRC Request (Item Number 149)

FSAR Section 7.1.1.2(2), Overtemperaturedelta T and Overpressure delta T equations have been simplified and many values are removed from the FSAR. Provide the justification for this change.

Follow-up NRC Request:

TVA need to identify when Unit 1 UFSAR was revised with this information.

TVA Response to Follow-up NRC Request:

This change was incorporated in the Unit 1 FSAR in Amendment 0 by FSAR change package 1473.

12. NRC Request (Item Number 152)

Deleted portion of FSAR section 7.2.3.3.4 and moved to FSAR section 7.2.1.1.5.

However, the FSAR section 7.2.1.1.5 does not include the discussion of ambient temperature and also on the calibrationof the sealed reference leg system. No justification was provided for deleting this discussion. Please explain the bases for deletion of this information.

Follow-up NRC Request:

TVA need to identify when Unit 1 UFSAR was revised with this information.

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Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval TVA Response to Follow-up NRC Request:

The change was incorporated into the Unit 1 UFSAR in Amendment 1 by FSAR change package 1553.

13. NRC Request (Item Number 154)

FSAR section 7.2. 1.1.10, setpoints: NRC staff has issued RIS 2006-17 to provide guidance to the industry regarding the instrumentsetpoint methodology which complies with 10 CFR 50.36 requirements. (01) Provide the information on how the WBN2 setpoint methodology meets the guidance of RIS 2006-17 and include this discussion in this section. Also, by letter dated May 13, 2010, TVA provided Rev. 7 of EEB-TI-28 to the staff. The staff noted that section 4.3.3.6 of EEB-TI-28 discusses the correction for setpoints with a single side of interest. It should be noted that the staff has not approved this aspect of setpoint methodology for Unit 1. The staff finds this reduction in uncertaintiesis not justified unless it can be demonstratedthat the 95/95 criteriais met.

(Q2) Therefore, either remove this reduction factor for single sided uncertaintiesorjustify how you meet the 95/95 criteriagiven in RG 1.105.

Follow-up NRC Request:

Why the last sentence has been modified by adding TI-28. It was NRC's understanding that all setpoints have to meet TI-28?

TVA Response to Follow-up NRC Request:

In order to respond to other NRC comments on the setpoint methodology discussion in FSAR Amendment 100, TVA reviewed the previous response to this RAI. This resulted in a complete rewrite of the responses to this question as shown below. As a result, the response does not specifically address the NRC Follow-up Request. However, the overall responses to all of the NRC RAIs on setpoint methodology addresses this item.

(01) WBN Unit 2 implementation of TSTF-493, Rev. 4, Option A includes addition of a discussion of the WBN setpoint methodology in FSAR section 7.1.2.1.9.

(02) Electrical Engineering Branch (EEB) Technical Instruction (TI) 28, Setpoint Calculations, single-sided methodology conforms to WBN's design basis commitment to ensure that 95% of the analyzed population is covered by the calculated tolerance limits as defined in NRC Regulatory Guide 1.105, Revision 2, 1986, which was in effect during WBN Unit 1 licensing. Single-sided multipliers are not used for any TSTF-493 setpoints.

There are some areas where a 95% confidence level could not be achieved. Some examples would be harsh environment instrumentation where only 2 or 3 devices were tested in the 10CFR50.49 program. In these situations, the Confidence is referred to as "high".

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Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval

14. NRC Request (Item Number 186)

Along with Amendment 96, TVA submitted a list of Bechtel changes for each section.

Change number 45 addressesa change to section 7.71.12, AMSAC, however, the Justification column states "This change is not included. EDCR 52408 installs the AMSAC in Unit 2. It does not have a trouble alarms. The existing words better reflect the operation of the system."

Even though this change was not included in Amendment 96, will it be included in a future amendment?

Also, please submit a summary of EDCR 52408.

Follow-up NRC Request:

TVA to state that no further FSAR changes are planned.

TVA Response to Follow-up NRC Request:

No further changes to the FSAR associated with AMSAC are planned.

15. NRC Request (Item Number 277)

NUREG 0847, "Safety evaluation report Related to the operation of Watts Bar Nuclear Plant, Units 1 and 2." has section 7.6.3 which discusses the, "UpperHead Injection Manual Control"system but has been removed from the FSAR. Please provide the information regarding when this system was removed, and the justification for the removal of the system and if the NRC staff has previously reviewed and accepted the removal of the system provide the reference to the staff's SE.

TVA Response:

Removal of the Upper Head Injection (UHI) System was reviewed as part of the WBN Unit 1 original licensing and was reviewed by the staff in SER Supplement 7:

1.7 Summary of Outstanding Issues - PAGE 1-3 "Supplement 7" (22) Removal of upper head injection system Resolved (SSER 7) 6.3.1 (TAC 77195)

When the removal of UHI System was evaluated by the NRC, this should be applied to both sections 6.3.1 and 7.6.3, since the UHI Control System has no function once the UHI System has been removed.

16. NRC Request (Item Number 281)

For FSAR Section 7.6.8 in amendment 96, redline version has completely rewritten this section of the FSAR, however, the staff is not able to determine any changes made to the section. Explain what changes have been made to this FSAR Section.

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Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval TVA Response:

Attachment 5 contains the WBN Unit 2 FSAR markup for Section 7.6.8, "Interlocks for RCS Pressure Control During Low Temperature Operation," showing what was changed between Amendments 95 and 96.

17. NRC Request (Item Number 283)

Follow-up to item 96 On Open Item 96, regardingthe implementation of IEN 79-22, part of TVA's response was:

The non-safety-related device/systems within the scope of IEN 79-22 are:

1. Steam generatorpower operated relief valve control system

2. Pressurizerpower operatedrelief valve control system

3. Main feedwater control system

4. Automatic rod control system.

Failure of these systems/devices due to a high energy line break is fully addressedin Chapter 15, "AccidentAnalysis" of the WBN Unit 2 FSAR.

Pleaseidentify the sections of FSAR Chapter 15 that addressthe failures of these systems.

TVA Response:

1. Steam Generator Power Operated Relief Valve Control System The potential scenario for this event is addressed in WBN Unit 2 FSAR Section 15.2.13, Accidental Depressurization of the Main Steam System.

2. Pressurizer Power Operated Relief Valve Control System The potential scenario for this event is depressurization of the reactor coolant system due to a relief valve failing open. This is addressed in WBN Unit 2 FSAR Section 15.2.12, Accidental Depressurization of the Reactor Coolant System and WBN Unit 2 FSAR Section 15.3.1, Loss Of Reactor Coolant From Small Ruptured Pipes Or From Cracks In Large Pipes Which Actuate The Emergency Core Cooling System.

3. Main Feedwater Control System The potential scenarios for this event are:

a. A loss of feedwater due a feedwater isolation valve failing closed. This is addressed in WBN Unit 2 FSAR Section 15.2.8, Loss of Normal Feedwater.

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Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval

b. A feedwater regulating valve failing open. This is addressed in WBN Unit 2 FSAR Section 15.2.10, Excessive heat removal due to feedwater system malfunctions.

4. Automatic Rod Control System The potential scenarios are uncontrolled rod withdrawal events that are addressed in WBN Unit 2 FSAR Section 15.2.1, Uncontrolled Rod Cluster Control Assembly Bank Withdrawal From A Subcritical Condition; WBN Unit 2 FSAR Sections 15.2.2, Uncontrolled Rod Cluster Control Assembly Bank Withdrawal At Power; and 15.2.3, Rod Cluster Control Assembly Misalignment.

18. NRC Request (Item Number 285)

Follow-up to item 22 Do the control loops meet the requirementsof IEEE-279? If not are they isolated from the circuit which meets the requirements of 279.

TVA Response:

The Foxboro SPEC 200 components are physically arranged in the racks to meet the requirements of IEEE-279 and Watts Bar Design Criteria WB-DC-30-4, Separation/Isolation.

Foxboro (Invensys) uses two IE analog modules to isolate IE to Non-IE signals. These are Contact Output Isolator (Model Number 2A0-L2C-R Relay Output) and Voltage-to-Current Converter (Model Number 2A0-VAI), both of which have the Input and Output signals isolated.

19. NRC Request (Item Number 293)

FSAR Amendment 100, Section 7.2.2.3.5 discusses Steam Generator Water Level and protection againstlow water level. However, this section does not discuss protection against Steam Generatoroverfill. Additionally, FSAR Section 7.2.2.3.4 discusses PressurizerWater Level and provides minimal information concerning Pressurizeroverfill.

Pleaseprovide a discussionof protection against Pressurizerand Steam Generator overfill.

TVA Response:

Steam Generator Overfill The steam generator High-High level interlock (P-14) protects against steam generator overfill by initiating feedwater isolation and a turbine trip. Reactor trip occurs indirectly as a result of the turbine trip if power is above 50%, the P-9 interlock. This function is identified as ESFAS interlock P-14 in FSAR Section 7.3, Table 7.3-3. The High-High level interlock is also discussed in FSAR Section 10.4.7.3. Section 15.2.10 analyzes the feedwater malfunction event which causes one or more feedwater control valves to fail to the fully open position.

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Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval Pressurizer Overfill The high pressurizer water level reactor trip protects against pressurizer overfill. This trip is described in FSAR Section 7.2.1.1.2 (3). The high water level trip setpoint provides sufficient margin such that the undesirable condition of discharging liquid coolant through the safety valves is avoided. Pressurizer level is modeled in various Chapter 15 events to ensure that critical protection functions will function as required.

20. NRC Request (Item Number 300)

(1) Need Radiation Monitoring System Description/DesignCriteria (2) Are detectors different from Unit 1. Describe any differences.

(3) Are there any commercially dedicated parts in the RM- 1000? If so, how are they dedicated?

(4) Please confirm that digital communication ports available in RM- 1000 are not used.

TVA Response:

(1) Attachment 6 contains TVA design criteria document Radiation Monitoring Design Criteria Document, WB-DC-40-24, Revision 21.

(2) Attachment 7 contains the General Atomics Electronic Systems, Inc., detector differences report. The containment high range radiation monitors are loops 271-274.

(3) For safety-related applications, General Atomics supplies the RM-1000 module assembly as a Basic Component. This assembly does contain component parts that are Safety-Related Commercial Grade Items (SRCGI). Because these SRCGI components are assembled into the delivered Basic Component, they are dedicated to the assembly by virtue of the acceptance test of the full RM-1000 assembly. Safety-related commercial grade items are dedicated in accordance with General Atomics approved 10 CFR 50 Appendix B program.

(4) The digital communications ports on the safety-related RM-1000 radiation monitors are not used.

21. NRC Request (Item Number 301)

(1) TVA is requested to address the consequences of total loss of CERPI. (2) In addition, address how the actions stipulatedin the plant Technical Specifications will be taken when the CERPI system indicationsare lost. Information notice IN 2010-10 (ML100080281) addresses the need to consider software failures and the actions requiredto assure that the plant will stay within its licensing basis. (3) Provide FMEA in support of your response.

(4) FSAR Table 7. 7-1, Plant Control System Interlocks lists interlock C- 11 to block automatic rod withdrawal when 1/1 Control Bank D rod position is above setpoint. This 9

Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval interlock capability would be lost in case of total loss of CERPI. How is the rod block assuredfor this event?

(5) How is automatic rod withdrawalaffected in case of total loss of signals from the CERPI to the ICS? Is this interlock fail safe?

(6) FSAR chapter 15, Section 2.3.2.1 states that the resolution of the rod position indicator channel is 5% of span (7.2 inches). The CERPI system accuracyspecified in the CERPI System requirements Specification, WNDS-DS-OOOO1_WBT, Rev. 2 is 12 steps or 5.19%.

The specified system accuracy seems to be greater than the accuracy assumed in the FSAR Chapter 15. Please clarify this anomaly.

TVA Partial Response:

For all accidents analyzed in WBN Unit 2 FSAR, Chapter 15, no credit is taken for the rod position indication system. For all continuous rod withdrawal accidents analyzed in WBN Unit 2 FSAR, Chapter 15, no credit is taken for any rod stop/block.

(1) Technical Specification 3.1.8, Rod Position Indication, does not have an action for total loss of indication; therefore, a total loss of CERPI puts the plant into LCO 3.0.3 which states:

When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable.

Action shall be initiated within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to place the unit, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />;

b. MODE 4 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />; and

c. MODE 5 within 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />.

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

(2) CERPI common mode software failure will be addressed in a future RAI response letter.

(3) There is no FMEA for the CERPI system.

(4) Control Bank D Automatic Rod Withdrawal Limit would be assured by Operations and control circuitry by the following 2 methods:

a. A simultaneous failure of all indications of the Rod Position Indication System places the plant in LCO 3.0.3, since it would prevent compliance with actions in 10

Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval LCO 3.1.8.

b. CERPI cabinet relays A-KX-18 and B-KX-18 are the PLC controlled components of Rod Withdrawal Limit. The relays are "active low" requiring power to activate the contacts in the control circuit. Total loss of CERPI will open the contacts and block Automatic Rod Withdrawal. Additionally, Annunciator window 64F will annunciate to show "C-11 BANK D AUTO WITHDRAWAL BLOCKED."

(5) The CERPI Maintenance and Test Panels are used to set the Rod Withdrawal Limit with output signal to ICS as a parallel path. As stated above, the relays are the controlling functions and loss of signal to ICS will not affect the capability of the control circuit to disable the Automatic Rod Withdrawal function. The C-1 1 interlock is fail safe with regards to loss of power.

(6) The cycle-specific analyses for the static rod misalignment assume full misalignment of an individual rod from the bank position indicator(s). Such a misalignment exceeds that which is possible during plant operations when accounting for the most adverse combination of the rod deviation alarm and uncertainty of the rod position indicator (both 12 steps). For consistency of parameter (and units) with the deviation alarm and position indicator uncertainty, the WBN Unit 2 FSAR Chapter 15, Section 2.3.1 will be revised in Amendment 102 to read:

"The resolution of the rod position indicator channel is +/- 12 steps. Deviation of any RCCA from its group by twice this distance (24 steps) will not cause power distributions worse than the design limits. The deviation alarm alerts the operator to rod deviation with respect to group demand position in excess of 12 steps. If the rod deviation alarm is not operable, the operator is required to take action as required by the Technical Specifications."

This change is consistent with FSAR section 4.3.2.2.5, Limiting Power Distributions Page 4.3-13, which states the maximum deviation assumed is 12 steps.

22. NRC Request (Item Number 302)

Item 208 requested a description of the changes that were performed under 10 CFR 50.59 for 16 Unit 1 PAM variables that were identified in Enclosure 1 Item No.6 of the letter dated June 18, 2010 (ML101940236). Please identify the specific 10 CFR 50.59 documentation that applies to each of these 16 variables.

TVA Response:

Attachment 8 contains the requested 50.59 evaluations and the variable table cross referencing each variable to the appropriate DCN. There are two changes to the original table. Variable 9, RCS Pressurizer Level, and variable 10, RCS Pressure Wide Range, have been changed from 10 CFR 50.59 Y to N. The original response showed these variables as changed under 10 CFR 50.59. The response was based on the plan to replace all paper recorders in Unit 1. The assumption was that these Unit 1 recorders would be replaced prior to Unit 2 startup. While this may still occur, the Unit 1 recorders have not been replaced at this time.

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Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval

23. NRC Request (Item Number 303)

Enclosure 1 Item 6 of the letter dated June 18, 2010 included a column to indicate the Unit 2 variable source for each PAM variable and also if the variable was unique to Unit 2. For each variable that was indicatedas unique to Unit 2 and the Unit 2 variable source is (1)

Foxboro Spec 200, (2) Common Q PAMS, or (3) Foxboro IA, identify the Unit 1 variable source.

TVA Response:

Attachment 9 contains the cross reference between the Unit 2 and Unit 1 variable sources for the unique WBN Unit 2 variables within the scope of the Foxboro Spec 200, Common Q PAMS and Foxboro I/A changes.

NOTE: An error was identified during preparation of this response. Variable 37 CCS Surge Tank Level was incorrectly identified as being within the scope of the Foxboro I/A system in TVA to NRC letter dated June 18, 2010. Variable 37 will be provided by the Foxboro Spec 200 system for Unit 2.

24. NRC Request (Item Number 304)

Enclosure 1 Item 6 of the letter dated June 18, 2010 indicatedthat the Unit 2 variable source for 14 PAM variables is Eagle 21. Please confirm that for each of these 14 variables the Unit 1 variable source is also the Eagle 21.

TVA Response:

The source for the Unit 1 variables is the Eagle 21 System.

25. NRC Request (Item Number 305)

Enclosure 1 Item 6 of the letter dated June 18, 2010 indicated that the Unit 2 variable source for 2 PAM variables is the IntegratedComputer System. Please confirm that for these 2 variables the Unit 1 variable source was the Unit 1 plant computer system.

TVA Response:

The source for the Unit 1 variables is the Integrated Computer System.

26. NRC Request (Item Number 306)

FSAR amendment 100, page 7.1-12 provides the definition of Allowable value which is not consistent with TSTF-493 as allowable value is the value beyond which instrument channel is declared inoperable.

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Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval TVA Response:

The FSAR Allowable Value definition will be revised to be consistent with the TSTF-493 in FSAR Amendment 102. Attachment 3 contains the FSAR Amendment 102 Change Markup that reflects this change.

27. NRC Request (Item Number 307)

(1) FSAR amendment 100, Section 7. 1, page 7. 1-12, definition of Acceptable as found tolerance is not in accordance with TSTF-493 as AAF is the limit beyond which the instrument channel is degradedbut may be operable and its operabilitymust be evaluated. (2) Also it states that AAF is based on measurable instrumentchannel uncertainties,such as drift, expected during the surveillance interval. These wording should be revised to agree with the wording given in RIS2006-17 as these wordings are very vague. (3) Also it states that RPS functions use double sided tolerance limits for the AAF. Since AAF is a band it will always be double sided and therefore, this clarification does not mean anything and it clouds the issue.

TVA Response:

(1) and (2) The Acceptable As Found (AAF) definition will be revised to be consistent with TSTF-493 as discussed with the NRC Staff, in FSAR Amendment 102. Attachment 3 contains the revised FSAR Amendment 102 Change Markup that reflects this change.

(3) The statement about double sided limits addresses a TSTF requirement that the AAF tolerance consider errors in both the conservative and non-conservative directions and ensures that an as-found value which exceeds these limits, even in the conservative direction (away from the safety limit), will be evaluated. Attachment 3 contains the revised FSAR Amendment 102 Change Markup that reflects this change.

28. NRC Request (Item Number 308)

FSAR Amendment 100, Section 7.1, page 7.1-13, definition of Acceptable as left tolerance is not in accordance with TSTF-493 as it states that this may take calibrationhistory into consideration. This is very vague and ambiguous. Also it states that RPS functions use double sided tolerance limits. Since ALF is a band it will always be double sided and therefore, this clarificationdoes not mean anything and clouds the issue.

TVA Response:

(1) The Acceptable As Left (AAL) definition will be revised to be consistent with TSTF-493 as discussed with the NRC Staff, in FSAR Amendment 102. Attachment 3 contains the revised FSAR Amendment 102 Change Markup that reflects this change.

(2) See response to letter item 7 (NRC Matrix Item 117).

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Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval

29. NRC Request (Item Number 309)

(1) FSAR amendment 100, Page 7.1-14, Westinghouse setpoint methodology, states that AAF is the algebraicsum of the . This is not acceptable. As algebraicsum is non conservative compared to the SRSS method and will mask the operabilityof the instrument channel and therefore, it is not acceptable to the staff. (2) It also makes the statement that AL T may take calibrationhistory into considerationwhich is vague and ambiguous.

TVA Response:

(1) The AAF calculation for Westinghouse setpoint methodology calculations in TI-28 for TSTF-493 will be revised to use the Square Root Sum of the Squares (SRSS) method.

(2) AAF definition will be revised to be consistent with TSTF-493 as discussed with the NRC Staff, in FSAR Amendment 102. Attachment 3 contains the revised FSAR Amendment 102 Change Markup that reflects this change.

30. NRC Request (Item Number 310)

(1) FSAR amendment 100, Page 7.1-14, TVA setpoint methodology, states that for AAF

.... and other measurable uncertaintiesas appropriate(i.e., those present during calibration.... ) should be changed to present during normal operation...... (2) Also on page 7.1-15, states thatALT may take calibrationhistory into considerationwhich is vague and ambiguous.

TVA Response:

(1) AAF definition will be revised to be consistent with TSTF-493 as discussed with the NRC Staff, in FSAR Amendment 102. Attachment 3 contains the revised FSAR Amendment 102 Change Markup that reflects this change.

31. NRC Request (Item Number 311)

Both Westinghouse and TVA setpoint methodology do not have any discussion on single sided calculation. Please confirm that single sided calculation has not been used for all setpoints with TSTF-493 and provide a statement to that effect in the FSAR.

TVA Response:

A statement that single-sided corrections are not used for TSTF-493 setpoints will be included in FSAR Amendment 102. Attachment 3 contains the revised FSAR Amendment 102 Change Markup that reflects this change.

32. NRC Request (Item Number 313)

EDCR 52408 (installationof AMSAC in Unit 2) states that Design Criteria WB-DC-40-57 needs to be modified to reflect AMSAC in Unit 2.

14

Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval (1) Has WB-DC-40-57 been completed for Unit 2? If so, please submit.

(2) If WB-DC-40-57 has not been completed for Unit 2, please give an estimated date of completion and submittal.

(3) Please submit WB-DC-40-57 for Unit 1 and identify any changes to the Unit 2 version.

TVA Response:

(1) The review of WB-DC-40-57 for Unit 2 applicability has been completed and included in Revision 4 of the document. Attachment 10 contains TVA Design Criteria WB-DC-40-57, Revision 4, Anticipated Transients Without Scram Mitigation System Actuation Circuitry (AMSAC).

(2) The revision for Unit 2 is complete with open items as identified in item (3) below.

(3) Attachment 10 contains TVA Design Criteria WB-DC-40-57, Revision 4, Anticipated Transients Without Scram Mitigation System Actuation Circuitry (AMSAC), which is applicable to both WBN Unit 1 and Unit 2. There are 17 open WBN Unit 2 Startup Integration Task Equipment List (WITEL) punch list items associated with Revision 4 that require resolution. A list of the punch list items is contained in Attachment 10.

33. NRC Request (Item Number 317)

TVA has provided a proprietaryand a non-proprietaryversion of Technical Manual for RM-1000 Digital Radiation Processorunder ML101680582 and ML101680587).

(i) Are these documents applicable to WBN2 as provided (October2003 version).

(ii) Why is DCN38993-A attachedat the back of the proprietaryversion? It is for WBN1 Turbine Governor Control Valve.

(iii) This document does not state the requirements for RM-1000 units. Pleaseprovide a document that states the requirementsfor the RM- 1000 radiationmonitors for WBN2.

TVA Response:

(i) These documents are applicable to WBN Unit 2.

(ii) This was an error in document preparation that occurred when attachments were assembled for a previous letter. Please disregard DCN 38993-A.

(iii) The Technical Manual is not intended to include equipment requirements.

Attachment 11 contains the Material Requisition Specification Revisions 1 and 4, which contains the requested information.

34. NRC Request (Item Number 318)

TVA has provided the following documents for RM- 1000 equipment qualification:

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Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval

i. Qualification Test Report for RM- 1000 ProcessorModule and Current-To-Frequency Converter 04508905-QR (January2001) ii. Qualification Test Report Supplement, RM- 1000 Upgrades 04508905-1SP (June 2006) iii. Qualification Test Report Supplement, RM- 1000 Upgrades 04508905-2SP (June 2008) iv. Qualification Test Report Supplement, RM- 1000 Upgrades 04508905-3SP (May 2008)

Please clarify whether all of these are fully applicable to WBN2 or are they applicable with exceptions? If with exceptions, then please clarify what those are.

Supplement 3 was issued one month prior to supplement 2. Please explain the reason for the same.

TVA Response:

i. Applicable to WBN Unit 2. 04508905-QR is applicable only in regard to the RM-1000, with the exception of requalification of certain RM-1000 equipment differences covered in the -1SP report. The Current-to-Frequency (I-F) converter module qualifications in the base report and the -1SP report are not applicable to the RM-1000s, and will be used later as references in the WBN Unit 2 specific qualification reports.

ii. Applicable to WBN Unit 2.

iii. Not applicable to WBN Unit 2.

iv. Not applicable to WBN Unit 2.

The 04508905-2SP and -3SP reports were prepared for another TVA plant, as a monitor system-level report, where the system included equipment. However, these reports do not apply to WBN and should be disregarded.

35. NRC Request (Item Number 319)

TVA provided System Verification Test Results 04507007-1TR (July 1999) for Sequoyah to support test verification. However, the document states (page v) that it is not applicable for high range monitors with an action noted for fixing a problem with the high range RM-1000 monitors on page vi. TVA to respond to the following clarifications:

Has the anomaly noted on page vi been resolved for the high range monitors?

Provide the high range verification document for WBN2.

TVA Response:

See TVA letter to the NRC dated October 21, 2010, item 26 (RAI Matrix Item 316)

(Reference 2) for non-applicability of 04507007-1TR. The recorded anomaly was later resolved through the verification of software version 1.2, reported in RM-1000 v1.2 Software Verification Report 04508006.

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Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval The high range verification documents are the Sequoyah RM-1000 v1.1 Software Verification Report 04508006 and RM-1000 v1.2 Software Verification Report 04508006 submitted in TVA letter to NRC dated July 15, 2010 (Reference 3).

36. NRC Request (Item Number 323)

WCAP- 13869 revision 1 was previously reviewed under WBN Unit 1 SER SSER 13 (Reference 8). Unit 2 references revision 2. An analysis of the differences and their acceptabilitywill be submitted to the NRC by November 15, 2010.

TVA Response:

Attachment 12 contains the WCAP 13869 Revision 1 to Revision 2 Change Analysis.

37. NRC Request (Item Number 326)

TVA uses double-sided methodology for as-found and as-left Reactor Trip and ESFAS instrument setpoint values. The FSAR will be revised in a future amendment to reflect this methodology.

TVA Response:

Attachment 3 contains the revised FSAR Amendment 102 Change Markup that reflects this change.

38. NRC Request (Item Number 328)

Provide the model number for the four containmenthigh range area monitors, RM- 1000 and identify how the software V& V and qualificationdocuments apply to them. If there is no specific model number then how is it ensured that the correct radiationmonitor is received at the site and subsequently installed?

TVA Response:

The Containment High Range Radiation Monitors are model RM-1000. The monitors are uniquely identified by serial numbers which are assigned when the equipment is assembled. The applicability of V&V reports and quality documentation for the RM-1000 model is in accordance with manufacturer's approved 10 CFR 50 Appendix B Quality Program and the requirements of the purchase order.

39. NRC Request (Item Number 329)

Section 7.6.7 of the FSAR (Amendment 100) states that, "The DMIMS-DX TM audio and visual alarm capability will remain functional after an OperatingBasis Earthquake(OBE).

All of the DMIMS-DXTM components are qualified for structuralintegrity during a Safe Shutdown Earthquake (SSE) and will not mechanically impact any safety-related equipment."

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Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval TVA to clarify the seismic qualification of the loose parts monitoring system and include the appropriateinformation in Table 3.10 (or anothersuitable section) of the FSAR.

TVA Response:

The title of FSAR Section 3.10 is Seismic Design of Category I Instrumentation and Electrical Equipment. Since the Loose Part Monitoring System is not a Category 1 system, it is not included in the scope of 3.10. FSAR Section 7.6.7, "Loose Parts Monitoring System (LPMS) System Description," identifies basic system seismic design criteria which are consistent with the requirements of TVA Design Criteria, WB-DC-30-31, Loose Parts Monitoring System. As identified in FSAR Table 7.1-1, Watts Bar Nuclear Plant NRC Regulatory Guide Conformance, the system conforms to Reg. Guide 1.133 as modified by Note 12. Reg. Guide 1.133 identifies the seismic requirements and Note 12 does not contain any exception to the Regulatory Guide seismic requirements.

40. NRC Request (Item Number 331)

As a follow up of 01190, Staff has reviewed the proprietary version of the DMIMS-DX system description to verify the conformance claims in the FSAR. Staff has noted the following insufficiencies and discrepanciesbetween the FSAR and the proprietaryversion of the system descriptionfor loose parts monitoringsystem provided by TVA.

1) FSAR, Amendment 100, page 7.6-5 states, "Duringbaseline testing, the reactorvessel and steam generatorare impacted three feet from each sensor with a force of 0.5 ft-lb.

Loose parts detection is accomplishedat a frequency of 1 kHz to 20 kHz, where background signals from the RCS are acceptable. Spurious alarming from control rod stepping is prevented by a module that detects CRDM motion commands and automaticallyinhibits alarms during control rod stepping.

The online sensitivity of the DMIMS-DXTM is such that the system will detect a loose part that weighs from 0.25 to 30 lb. and impacts with a kinetic energy of 0.5 ft-lb on the inside surface of the RCS pressure boundary within 3 ft of a sensor."

The source of this information is not cited nor is it described in the system description.

TVA to provide the source of the information and update the system description as needed.

2) Regulatory Guide (RG) 1.133, rev. 1, regulatoryposition C. 1.g states that, "Operability for Seismic and Environmental Conditions. Components of the loose-partdetection system within containmentshould be designed and installed to perform their function following all seismic events that do not requireplant shutdown, i.e., up to and including the OperatingBasis Earthquake (OBE). Recording equipment need not function without maintenance following the specified seismic event provided the audio or visual alarm capabilityremains functional. The system should also be shown to be adequate by analysis, test, or combined analysis and test for the normal operating radiation, vibration, temperature,and humidity environment.

FSAR, Amendment 100, page 7.6-5 states, "The DMIMS-DXTM audio and visual alarm capability will remain functional after an Operating Basis Earthquake (OBE). All of the 18

Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval DMIMS-DXTM components are qualified for structuralintegrity during a Safe Shutdown Earthquake (SSE) and will not mechanically impact any safety-relatedequipment."

Paragraphs4.c and 4.d of the system description are not consistent with the seismic qualificationsdescribed in the FSAR. TVA to provide the source of the information containedin the FSAR and update the system description as needed.

3) The system description clearly describes the "In-containmentequipment"and 'DIMMS-DXTM Cabinet equipment. The FSAR should be updated to reflect the equipment locations for clarificationpurposes.

4) The information regardingfrequency ranges of the sensors is included on page 7.6-6 of Amendment 100 of the FSAR but the system descriptiondoes not contain this information. Please provide the source of this information and update the system description to reflect the appropriateinformation.

5) Please provide information as to how the in-containmentcomponents are qualified for vibration as addressedin regulatoryposition C. 1.g of RG 1.133.

TVA Partial Response:

1) The source of the information is the DMIMS-DXTM Operations and Maintenance Manual, TS3176, Revision 0, dated August 2010. Attachment 14 contains the revised system description, 'Westinghouse DIMMS-DXTM Loose Part Detection System Description," Revision 1.

2) The source of the information is the DMIMS-DXTM seismic qualification report, Westinghouse report EQ-QR-33-WBT, Revision 0, Seismic Evaluation of the Digital Metal Impact Monitoring System (DMIMS-DX TM ) for Watts Bar Unit 2. Attachment 14 contains the revised system description, 'Westinghouse DIMMS-DXTM Loose Part Detection System Description," Revision 1.

3) The entries for the following items in FSAR Section 7.6.7 will be modified in Amendment 102 as shown in Attachment 3 for draft revision to WBN Unit 2 FSAR Section 7.6.7, "Loose Part Monitoring System (LPMS) System Description."

Sensors (In Containment)

Softline Cable (In Containment)

Preamplifier (In Containment)

Attachment 3 contains the FSAR Amendment 102 Change Markups that reflect these changes.

4) The source of the information is Westinghouse Letter WBT-D-2580, Tennessee Valley Authority Watts Bar Nuclear Plant Unit 2 Response to NRC RAIs on LPMS (Reference 5). Attachment 14 contains 'Westinghouse DIMMS-DXTM Loose Part Detection System Description," Revision 1.

In responding to Item 4, conflicting information was found between the Westinghouse-prepared FSAR section and various Westinghouse technical documents. To fully 19

Enclosure 1 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval respond to this item, a change to the FSAR is required to change the minimum flat sensor frequency response from 5 Hz to 10 Hz. Attachment 3 contains the FSAR Amendment 102 Change Markups that reflect the revised frequency response of the sensor.

5) In-containment component qualification for vibration as addressed in regulatory position C.1 .g of RG 1.133, will be addressed in a future RAI response letter.

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Enclosure 2 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval Attachments

1. EDCR 52321 - Draft Scope and Intent, Unit Difference and Technical Evaluation.

2. EDCR 52351 - Draft Scope and Intent, Unit Difference and Technical Evaluation.

3. FSAR Amendment 102 Change Markups Revised WBN Unit 2 FSAR Section 7.1.2.1.9, "Trip Setpoints".

4. EDCR 55385 - Draft Scope and Intent, Unit Difference and Technical Evaluation.

5. FSAR Section 7.6.8, "COMS Changes".

6. TVA Design Criteria Document WB-DC-40-24, "Radiation Monitoring Design Criteria Document," Revision 21.

7. General Atomics Detector Differences Report.

8. Unit 1 PAM Variables changed under 10 CFR 50.59 Listing and 50.59 documents.

9. Cross reference between the Unit 2 and Unit 1 PAMS variable sources for unique WBN Unit 2 variables within the scope of the Foxboro Spec 200, Common Q PAMS and Foxboro I/A changes.

10. TVA Design Criteria Document WB-DC-40-57, "Anticipated Transients Without Scram Mitigation System Actuation Circuitry (AMSAC)," Revision 4 and WITEL open items report.

11. TVA Material Requisition 25402-011-MRA-HARA-00002, "Safety Related Radiation Monitoring System," Revisions 1 and 4.

12. WCAP 13869 Revision 1 to Revision 2 Change Analysis.

13. TVA Design Criteria Document WB-DC-40-54, "Environmental Qualification To 10CFR50.49".

14. Westinghouse DIMMS-DXTM Loose Part Detection System Description, Revision 1.

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Enclosure 3 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval References

1. TVA Letter to NRC Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, Dated October 5, 2010.

2. TVA Letter to NRC Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, Dated October 20, 2010.

3. TVA Letter to NRC Watts Bar Nuclear Plant (WBN) Unit 2 - Instrumentation And Controls Staff Information Requests, Dated July 15, 2010.

4. TVA Letter to NRC, In the Matter of the Application of Tennessee Valley Authority Docket Nos. 50-390 and 50-391, Response to NRC questions 31.147, dated March 11, 1982 (ML073530129).

5. Westinghouse Letter WBT-D-2580, Tennessee Valley Authority Watts Bar Nuclear Plant Unit 2, Response to NRC RAIs on LPMS, dated October 28, 2010.

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Enclosure 4 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval Commitments

1. (Letter Item 4) - Attachment 1 contains excerpts of EDCR 52321 (i.e., draft Scope, Intent, and Unit Difference and Technical Evaluation). The final excerpts will be submitted within two weeks after issuance of the EDCR.

2. (Letter Item 5) - Attachment 2 contains excerpts of EDCR 52351 (i.e., draft Scope, Intent and Unit Difference and Technical Evaluation). The final excerpts will be submitted within two weeks after issuance of the EDCR.

3. (Letter Item 7) - For TSTF-493 parameters, WBN Unit 2 uses only double-sided correction factors. Attachment 3 contains the FSAR Amendment'102 Change Markups that reflect this change.

4. (Letter Item 8) - Attachment 4 contains excerpts of EDCR 55385 (i.e., draft Scope, Intent, and Unit Difference and Technical Evaluation). The final excerpts will be submitted within two weeks after issuance of the EDCR.

5. (Letter Item 9) - This item will be corrected by a design change based on the following:

The Unit 1/Unit 2 Eagle 21 configuration has a sufficient number of spare Narrow Range (NR) and Wide Range (WR) RTD inputs available on the installed ERI-01 and ERI-02 boards to wire these spare inputs to the active channels. The spare input will provide the parallel resistance to resolve the problem. The WR RTD inputs provide the same input impedance as the NR RTD inputs. Jumpers will be installed at the Eagle 21 termination frame to provide a parallel connection from each existing NR RTD input to an existing spare input, thus simulating the hardware connection for shared RTDs. Therefore, as configured, the Rack 2 Loop Calculation Processor (LCP) will provide the correct temperature calculation for the NR RTDs. The design change will be issued by April 29, 2011.

Post modification testing will be performed to verify that the design change corrects the Eagle 21, Rack 2 RTD accuracy issue prior to WBN Unit 2 fuel load.

6. (Letter Item 21, Q6) - For consistency of parameter (and units) with the deviation alarm and position indicator uncertainty, the WBN Unit 2 FSAR Chapter 15, Section 2.3.1, will be revised in Amendment 102 to read:

"The resolution of the rod position indicator channel is +/- 12 steps. Deviation of any RCCA from its group by twice this distance (24 steps) will not cause power distributions worse than the design limits. The deviation alarm alerts the operator to rod deviation with respect to group demand position in excess of 12 steps. Ifthe rod deviation alarm is not operable, the operator is required to take action as required by the Technical Specifications."

7. (Letter Item 26) - The FSAR Allowable Value definition will be revised to be consistent with the TSTF-493 in FSAR Amendment 102. Attachment 3 contains the FSAR Amendment 102 Change Markups that reflect this change.

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Enclosure 4 TVA Letter Dated October 29, 2010 Responses to Licensee Open Items to be Resolved for SER Approval

8. (Letter Items 27, Q1 and Q2; 28, Q1) - The Acceptable As Found (AAF) definition will be revised to be consistent with TSTF-493 as discussed with the NRC Staff, in FSAR Amendment 102. Attachment 3 contains the revised FSAR Amendment 102 Change Markups that reflect this change.

9. (Letter Item 27 Q3, 37) - Attachment 3 contains the revised FSAR Amendment 102 Change Markups that reflect this change.

10. (Letter Item 29, Q1) - The AAF calculation for Westinghouse setpoint methodology calculations in TI-28 for TSTF 493, will be revised to use the Square Root Sum of the Squares (SRSS) method.

11. (Letter Item 29, Q2; 30, Q1) - AAF definition will be revised to be consistent with TSTF-493 as discussed with the NRC Staff, in FSAR Amendment 102. Attachment 3 contains the revised FSAR Amendment 102 Change Markups that reflect this change.

12. (Letter Item 31) - A statement that single-sided corrections are not used for TSTF-493 setpoints will be included in FSAR Amendment 102. Attachment 3 contains the revised FSAR Amendment 102 Change Markups that reflects this change.

13. (Letter Item 40, Q3) - The entries for the following items in FSAR Section 7.6.7 will be modified in Amendment 102 as shown: (See Attachment 15 for draft revision to WBN Unit 2 FSAR Section 7.6.7, "Loose Part Monitoring System (LPMS) System Description").

Sensors (In Containment)

Softline Cable (In Containment)

Preamplifier (In Containment)

14. (Letter Item 40, Q4) - In responding to Item 4, conflicting information was found between the Westinghouse prepared FSAR section and various Westinghouse technical documents. To fully respond to this item, a change to the FSAR is required to change the minimum flat sensor frequency response from 5 Hz to 10 Hz. Attachment 3 contains the FSAR Amendment 102 Change Markups that reflect the revised frequency response of the sensor.

15. (Letter Item 21, Q1) - CERPI common mode software failure will be addressed in a future RAI response letter.

16. (Letter Item 40, Q5) - In containment component qualification for vibration as addressed in regulatory position C.1.g of RG 1.133, will be addressed in a future RAI response letter.

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