ML11236A158

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Unit 2 - Final Safety Analysis Report (Fsar), Amendment 105
ML11236A158
Person / Time
Site: Watts Bar Tennessee Valley Authority icon.png
Issue date: 08/12/2011
From: Stinson D
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML11236A158 (27)
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Text

Attachment 1 to be withheld from Public Disclosure Under 10 CFR 2.390. When separated from this Enclosure, this letter is decontrolled.

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 August 12, 2011 10 CFR 50.4(b)(6) 10 CFR 50.34(b) 10 CFR 2.390(d)(1)

U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 Docket No. 50-391

Subject:

WATTS BAR NUCLEAR PLANT (WBN) - UNIT 2 - FINAL SAFETY ANALYSIS REPORT (FSAR), AMENDMENT 105

References:

1. TVA letter to NRC dated June 3, 2011, "Watts Bar Nuclear Plant (WBN) -

Unit 2 - Final Safety Analysis Report Amendment 104"

2. TVA letter to NRC dated October 11, 2007, "Watts Bar Nuclear Plant (WBN) - Unit 2 - Exemptions, Reliefs, Deviations and Exceptions" (ML072910331)
3. NRC Supplemental Safety Evaluation Report (SSER) 5 dated November 1, 1990 (ML073520360)
4. TVA letter to NRC dated February 13, 1985, "Exemption Request" (ML073511898)

This letter transmits WBN Unit 2 FSAR Amendment 105 (Al 05), which reflects changes made since the issuance of Amendment 104 on June 3, 2011 (Reference 1). contains a summary listing of FSAR sections and corresponding Unit 2 change package numbers associated with the Al 05 FSAR changes. Most of these changes were the result of resolutions to NRC Requests for Additional Information.

FSAR A105 is contained on the enclosed Optical Storage Media (OSM #1) (Attachment 1).

The FSAR contains security-related information identified by the designation "Security-Related Information - Withhold Under 10 CFR 2.390." TVA hereby requests this information be withheld from public disclosure in accordance with the provisions of 10 CFR 2.390. A redacted version of the FSAR is contained on OSM #2 (Attachment 2),

which is suitable for public disclosure. contains a listing of the FSAR pages that have been redacted. Enclosure 3 lists the files and file sizes on the security-related OSM (OSM #1), and Enclosure 4 lists the files and file sizes on the publicly available OSM (OSM #2).

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U.S. Nuclear Regulatory Commission Page 2 August 12, 2011 In addition, TVA requests a deviation for Unit 2 from the requirement contained in Regulatory Guide 1.68, Revision 2, "Initial Test Programs for Water-Cooled Nuclear Power Plants," WBN Technical Specifications (TS) , and the WBN Unit 2 FSAR for cold no-flow, cold full-flow, and hot no-flow rod drop testing. In 2007, TVA had initially indicated in Reference 2 that no deviation would be requested for this item. However, TVA has since determined that a deviation would be pursued for the U2 completion project. Precedent for this deviation exists since a deviation was approved for Unit 1 by NRC in Reference 3. It is also stated in SSER 5 that Callaway Nuclear Plant Unit 1 had also been granted a similar deviation. Since WBN Unit 1 was the last U.S. plant licensed, no other later precedent is expected to exist. With A105, Chapter 14 has been revised to reflect this deviation, but will not be implemented pending NRC review and approval. Enclosure 5 provides the further details for this deviation request.

There are no new commitments made in this letter. This amendment closes SSERs 22/23, Item Nos. 47, 66, 95, 96, 99, 100, and 102. This letter does not close any "Generic Communications." If you have any questions, please contact Bill Crouch at (423) 365-2004.

I declare under the penalty of perjury that the foregoing is true and correct. Executed on the 12th day of August, 2011.

Respectfully, David Stinson Watts Bar Unit 2 Vice President

Enclosures:

1. WBN Unit 2 FSAR Al 05, "Summary Listing of Al 05 FSAR Changes"
2. WBN Unit 2 FSAR A105, "Summary of Redacted Pages"
3. WBN Unit 2 FSAR A105, "List of files and file sizes on the security-related OSM (OSM #1)"
4. WBN Unit 2 FSAR Al 05, "List of files and file sizes on the publicly available OSM (OSM #2)"
5. WBN Unit 2, "Deviation Request from Regulatory Guide 1.68, Revision 2" Attachments:
1. OSM #1: WBN Unit 2 FSAR Amendment 105 - Security-Related Information - Withhold Under 10 CFR 2.390
2. OSM #2: WBN Unit 2 FSAR Amendment 105 - Publicly Available Version cc: See Page 3

U.S. Nuclear Regulatory Commission Page 3 August 12, 2011 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 WBN Unit 2 FSAR A105 "Summary Listing of A105 FSAR Changes" Item Change No. Change Area Change Description Package Number Insert the following paragraph WBN conforms fully with the criteria of 10 CFR 50.68(b)(6).

There are five radiation monitors located on elevation 757 of the Auxiliary Building in the vicinity of the new fuel vault and the spent fuel pool. Two of the monitors, 1-RE-90-1 and 2-RE-90-1, are area monitors that alert personnel in the vicinity of the fuel storage areas of excessive radiation for personnel protection and to initiate safety actions. These monitors also alarm in the main control room to alert the operators to initiate appropriate safety actions. There are two additional area radiation monitors, 0-RE-90-102 and 0-RE-90-103, that are located at the spent fuel

1. Section 4.3.2.7 pool to provide a more rapid response to a fuel handling 2-105-01 accident, the presence of excessive radiation, or the presence of a fuel bundle with inadequate water shielding. These monitors alarm in the main control room and also isolate the normal Auxiliary Building ventilation system to reduce the release of radioactivity offsite. These monitors will also isolate the containment ventilation system if the containment or annulus is open to the Auxiliary Building during refueling operations. The fifth radiation monitor in the spent and new fuel area is a particulate air monitor. This monitor alarms locally for protection of personnel in the vicinity of the monitor and also serves to alert the plant staff of an excessive radiation condition that requires action.
2. Table 6.2.6-3 Remove the phrase, "as specified in 10 CFR 50, Appendix J," in 2-105-02 Note 3.

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ENCLOSURE I WBN Unit 2 FSAR A105 "Summary Listing of A105 FSAR Changes" Item Change No. Change Area Change Description Package Number

1. On Page 11.2-19, modify Section 11.2.6.5.1 to read as follows (changes are bolded and underlined):

11.2.6.5.1 Expected Normal Plant Operation The expected plant alignment and resultant releases are as follows:

  • CVCS letdown waste processed by the CVCS demineralizers and then by the mobile demineralizer.
  • The reactor coolant drain tank, the tritiated drain collector tank, and the floor drain collector tank discharges and processed using the mobile demineralizer.
  • Liquid releases from the Laundry and Hot Shower Drain Tank and the Turbine Building drains can be released without processing by mobile demineralizer.

" Steam Generator Blowdown is released without processing.

  • The condensate demineralizers are bypassed. Thus there is no condensate demineralizer regeneration waste to be
3. Section 11.2 processed. 2-105-03
2. On Page 11.2-20, modify Section 11.2.6.5.2 to read as follows:

11.2.6.5.2 Other Plant Alignment Evaluations The values in Table 11.2-5 Column 4 assume the following:

  • CVCS letdown waste processed by the CVCS demineralizers and then by the mobile demineralizer.
  • The reactor coolant drain tank, the tritiated drain collector tank, and the floor drain collector tank discharges and processed using the mobile demineralizer.
  • Activity from Condensate Demineralizer waste due to the processing of condensate and steam generator blowdown is routed directly to the Cooling Tower Blowdown or the turbine building sump.
  • Liquid releases from the Laundry and Hot Shower Drain Tank and the Turbine Building drains were released without processing by mobile demineralizer.

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ENCLOSURE1 WBN Unit 2 FSAR A105 "Summary Listing of A105 FSAR Changes" Item Change Not Change Area Change Description Package Number The values in Table 11.2-5 Column 5 assume the following:

  • CVCS letdown waste processed by the CVCS demineralizers and then by the mobile demineralizer.
  • The reactor coolant drain tank, the tritiated drain collector tank, and the floor drain collector tank discharges and processed using the mobile demineralizer.
  • Condensate demineralizer regeneration waste is processed by the mobile demineralizer.
3. Liquid releases from the Laundry and Hot Shower Drain Section 11.2 Tank and the Turbine Building drains were released without 2-105-03 (cont.)

processing by mobile demineralizer.

3. On Page 11.2-38, modify Footnote F and Footnote for columns 4 and 5, as follows:

F (Ci/yr) = Activity from Condensate Demineralizer regeneration waste = Activity from 6 days of processing of condensate and steam generator blowdown flow by the condensate demineralizer.

Column 4: ((A+B/C)/D) + E + F + G Column 5: ((A+B/C)/D) + E + F/D + G E1-3

ENCLOSURE I WBN Unit 2 FSAR A105 "Summary Listing of A105 FSAR Changes" Item Change No. Change Area Change Description Package Number Insert the following text at the end of Section 12.3. 1, but before heading for Section 12.3.2, "Shielding."

"Integration of Unit 2 for Dual Unit Operation The following section supplements the above discussion (written primarily for one unit operation) with the integration of Unit 2 operation for dual unit operation:

Controlled Access Areas The Unit 2 controlled access area will be common with the Unit 1 controlled access area. This facility is located in the Service Building and is sized and situated properly to support two operating units.

Personnel and Equipment Decontamination The Unit 2 personnel and equipment decontamination facilities will be common areas shared with the Unit 1 personnel and equipment decontamination facilities. The personnel decontamination facility is located in the Service Building and is

4. Section 12.3.1 sized and situated properly to support two operating units. The 2-105-04 equipment decontamination facility is located in the Auxiliary Building and is sized and situated properly to support two operating units.

Contamination Control Areas The primary Unit 2 contamination control area (i.e., radiologically controlled area [RCA] exit personnel monitoring station) will be a common area shared with the Unit 1 contamination control areas. This facility is located in the Service Building adjacent to the Auxiliary Building common entrance/exit point. This RCA exit point is equipped with personnel contamination monitors (PCMs), personnel gamma monitors, and tool and equipment monitors. PCMs are also provided at common locations inside the Auxiliary Building (i.e., 676', 713', and 757' elevations) for prompt personnel contamination monitoring when personnel exit contaminated areas. Frisker stations are also set up at remote exit points from the RCA when the use of PCMs is not practicable. Remote exit points are used only after prior approval by Radiation Protection and in the event of an emergency.

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ENCLOSURE1 WBN Unit 2 FSAR A105 "Summary Listing of A105 FSAR Changes" Item Change No. Change Area Change Description Package Number Protective clothing laundry services are provided offsite by a contractor. Soiled protective clothing is temporarily stored onsite in designated containers until ready for shipment offsite.

Laundered protective clothing returned from the laundry contractor is received at the plant Power Stores loading dock and temporarily stored in a room adjacent to the loading dock until issued for use. This facility is located in the Service Building and is sized and situated properly to support two operating units. Hot machine shop type activities are not normally performed onsite. Instead, radioactive materials requiring machine shop support are normally sent to either the TVA Western Area Radiological Laboratory or to a contractor licensed to receive radioactive material. If machining is performed onsite, a temporary RCA is set up in the clean area machine shop and controlled by Radiation Protection.

Contamination control barriers, containments, or tents, as appropriate, are used to prevent the spread of contamination and airborne radioactivity. Storage facilities are established in

4. the Auxiliary Building and the Service Building to maintain a Section 12.3.1 2-105-04 (cont.) central location for the inventory of standard portable decontamination equipment and supplies (i.e., high energy particulate air [HEPA] vacuums, HEPA ventilation units, pressure washers, spray wands, mops, etc.) that may be used during the normal decontamination and control of radioactive contamination in the plant. These facilities are sized and situated properly to support two operating units.

In Plant Traffic Patterns to Radiologically Controlled Areas The Unit 2 in plant traffic patterns to RCAs will be virtually the mirror image of the Unit 1 in plant traffic patterns to RCAs.

Access to Unit 1 and Unit 2 RCAs will share common corridors at each elevation of the Auxiliary Building. Common areas are sized and situated properly to support two operating units.

Access to satellite Unit 2 RCAs (i.e., outside tanks) will be controlled in the same manner as Unit 1.

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ENCLOSUREI WBN Unit 2 FSAR A105 "Summary Listing of A105 FSAR Changes" Item Change No. Change Area Change Description Package Number Health Physics Facilities The Unit 2 Health Physics facilities (including dosimetry issue and maintenance, respiratory protection issue and maintenance, in-vivo and in-vitro bioassay, protective clothing and radiation survey instrument issue, Radiation Protection Manager [RPM]

and technical staff office/work space) will be common with Unit 1 facilities. These facilities and offices are located in the Training Center (dosimetry issue and maintenance, and in-vivo and in-vitro bioassay), Service Building (respiratory protection issue and maintenance, protective clothing and radiation survey instrument issue), and Office Building (RPM and technical staff office/work space). These facilities are sized and situated properly to support two operating units.

4. Section 12.3.1 Onsite Laboratory for Analysis of Chemical and Radiological 2-105-04 (cont.) Samples The Unit 2 onsite laboratory for analysis of chemical and radiological samples will be common with the Unit 1 onsite laboratory for analysis of chemical and radiological samples.

These facilities are located in the Auxiliary Building and the Service Building and are sized and situated properly to support two operating units.

Radiological Counting Room The Unit 2 radiological counting room will be common with the Unit 1 radiological counting room. This facility is located in the Service Building and is sized and situated properly to support two operating units."

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ENCLOSURE11 WBN Unit 2 FSAR A105 "Summary Listing of A105 FSAR Changes" Item No. Change Area Change Description Change Package Number On Page 12.4-2, insert prior to the Reference section, the following new section:

"Unit 2 Dose Assessment Watts Bar Unit 2 operation and maintenance is expected to be virtually the same as that experienced in the operation and maintenance of Watts Bar Unit 1, including the radiation source term. Historic exposures for Watts Bar Unit 1 are provided in NUREG-0713, Volume 29, beginning in 1997 until 2007. The annual collective dose (person-rem) for this time frame ranged from a low of 3.106 person-rem to a high of 322.682 person-rem. The high collective dose of 322.682 person-rem occurred in 2006 at which time all four Unit 1 steam generators were

5. 12.4 replaced. Steam generator replacement and the resultant 2-105-05 collective dose is not typical of normal operation and maintenance activities, thus is treated as special maintenance and not included in the proposed Watts Bar Unit 2 exposure estimate. (Steam generator replacement activities contributed to approximately 180 person-rem of the 322.682 person-rem for that year.) The proposed annual collective dose was determined by averaging the annual dose (less the steam generator replacement dose). This yields an average annual dose estimate of [(113 + 3.106 + 98.946 + 122.453 + 5.912 +

93.598 + 165.741 + 5.893 + 143.506 + (322.682-180) +

4.414)/l1)] = 81.75 person-rem. Additionally, the collective doses for years 2008 and 2009 show a continuing downward trend towards dose reduction."

In Section 13.1.3, "Qualification Requirements for Nuclear Facility Personnel," on page 13.1-4, insert the following information:

1. Place a "1"as a footnote indicator after the position of Radiological Control Superintendent.
2. Insert the following as footnote 1, "1The position of Radiological Control Superintendent will meet the
6. Section 13.1.3 requirements of RG 1.8, Revision 2, and ANSI/ANS 3.1- 2-105-06 1981, for all new personnel qualifying on positions identified in RG 1.8, Regulatory Position C.1, after January 1, 1990 as clarified by Reference 3.
3. Add a new Reference 3 as follows:

"(3) TVA Standard Program and Processes, NPG-SPP-05.1, "Radiological Controls.""

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ENCLOSURE1 WBN Unit 2 FSAR A105 "Summary Listing of A105 FSAR Changes" Item No. Change Area Change Description Change Package Number

1. In Sections 1.1.1 and 1.2.2.2, change heat input for Reactor Coolant Pumps (RCPs) from 14MWt to 16MWt.
2. Insert new section 7.4.2 entitled, "Auxiliary Control Room (ACR)," and renumber 7.4.2, "Analysis," to 7.4.3.
3. For Section 7.1.2, remove the entries that are duplicated in Table 7.1-1, provide appropriate reference to Table 7.1-1 and renumber remaining items.
4. For Section 1.1.1, 7.1.2, 7.4.3, and Tables 7.1-1 and 7.5-2, correct the use of quotes, correct spelling errors, and adjust page numbers and entries in Table 7.1-1. Reformat Table 7.1-1 Notes for consistency and clarity.

Section 1.1.1 5. For Table 7.1-1, add entries and notes associated with Section 1.2.2.2 installation of the Common Q Post Accident Monitoring Section 7.1.2 System (PAMS) and the RM-1000 digital radiation monitors Section 7.2.1.1.5 Section 7.4.2

6. For Table 7.2-2, delete the word chamber from the Section 7.4.3 description of the P-7 interlock.

Table 7.1-1

7. Table 7.2-2 7. For Section 7.5.1.2 and Table 7.5-2, revise definition of 2-105-07 Section 7.5.1.2 Type A variables to reflect the fact that TVA includes Table 7.5-2 variables that do not meet the Regulatory Guide (RG) 1.97 References 7.1 definition and identify those variables in Table 7.5-2.

References 7.2 References 7.3

8. For References 7.1, 7.2, and 7.3, correct reference entries Section 11.4.4 for WCAPs 17044 and 13869.

Section 12.3.4.1.3

9. For Section 12.3.4.1.3, provide details of Channel Operability Test (COT) periodic test frequency in accordance with calculation WBN EEB EDQ1090-99005, Rev. 2.
10. For Section 11.4.4, revise terms used to describe monitor testing.
11. For 12.3.4.1.3, delete reference to the Offsite Dose Calculation Manual (ODCM) and reword for clarity.
12. For 7.2.1.1.5, delete discussion of the pressurizer level condensing chambers.

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ENCLOSUREI WBN Unit 2 FSAR A105 "Summary Listing of A105 FSAR Changes" Item Change No. Change Area Change Description Package Number On Table 6.3-8, Sheets 7 and 8 of 66, change the Method of

8. Table 6.3-8 Detection for the Stuck Closed and Stuck Open Failure Modes 2-105-08 associated with Items 8 and 9, as revised.

Revise Chapter 15 Tables as listed below with new values provided from recent dose calculation revisions:

15.5-2, "Doses from Loss of A/C Power" 15.5-5, "Doses from Gas Decay Tank Rupture" 15.5-9, "Doses from Loss of Coolant Accident" 15.5-13, "Doses from Recirculation Loop Leakage following a

9. Section 15.5 LOCA" 2-105-09 15.5-14, "Atmospheric Dilution Factors at the Control Building" 15.5-17, "Doses from Main Steam Line Break" 15.5-18, "Parameters Used in Steam Generator Tube Rupture Analysis" 15.5-19, "Doses from Steam Generator Tube Rupture"3 15A-2, "Accident Atmospheric Dilution Factors (sec/m )"'
1. On page 14.2-19, insert new Item "j" to read as follows:

"(j) Appendix A, subparagraphs 2.b.

Cold, no-flow, cold, full-flow and hot, no-flow rod drops do not provide any additional useful data. The drop times for these flow conditions are less conservative than for hot full flow conditions. WBN does not intend to perform cold, no-flow, cold, full-flow and hot, no-flow rod drops."

2. Since Table 14.2-2, Sheet 11 of 39 was previously deleted, modify the title on Table 14-2.2 (Sheet 1 of 39) POWER ASCENSION TEST SUMMARIES INDEX to read
10. Section 14.2 "DELETED" rather than say "Spent Fuel Pool Cooling 2-105-10 System."
3. For Table 14.2-2, Sheet 3 of 39, under TEST METHOD, revise the third sentence from "A minimum of two source range channels will be responding following the loading of the initial nucleus of eight assemblies." to reword to read as follows: "A minimum of two source range channels will be responding to source neutrons before additional assemblies are loaded. Then following the loading of the initial nucleus of eight assemblies near each of the two installed source range channels, each channel will be adequately responding to subcritical multiplication of additional assemblies loaded."

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ENCLOSUREI WBN Unit 2 FSAR A105 "Summary Listing of A105 FSAR Changes" Item Change No. Change Area Change Description Package Number

4. For Table 14.2-2, Sheet 3 of 39: correct typographical error by adding space between "increased" and "(decrease)" at ACCEPTANCE CRITERIA.
5. For Table 14.2-2, Sheet 4 of 39, revise the sentence in the PREREQUISITES that now reads from: "The water level in the reactor vessel has been established." to "The water level in the reactor cavity has been established."
10. 6. For Table 14.2-2, Sheet 9 of 39: revise TEST Method (cont.) Section 14.2 Description in the fifth sentence to read, "Testing will be 2-105-10 performed under hot full flow conditions. In addition, add Note to say: "NOTE: Additional rod drops may be performed at either hot or cold RCS conditions with any RCS flow conditions. These drops are not used to satisfy acceptance criteria and their times are not included in calculating averages."
7. For Table 14.2-2, Sheet 15 of 39, revise PREREQUISITES 1 to read: "RCS flow measurement testing has been completed in Mode 3."
1. On Pages 2.3-25 and 2.3-26 (Al 04), correct typographical errors in Table 2.3-1 B header by changing "Surronding" to Surrounding"
2. On page 2.3-41 (A104), delete "98" from heading of Table Section 2.3 2.3-32. (By making this change in this section, this heading
11. Section 7.7 in the list of tables will be automatically changed) 2-105-11
3. On Page 7.7-20 (A104), correct typographical error by changing Section 7.7.1.11 heading from "Distribution Control System to "Distributed Control System." (By making this change in this section, this heading in the table of contents will be automatically changed.)

Delete valves ISV-41-586, ISV-41-589, ISV-41-592 and ISV 12. Table 6.2.6-3 595 from FSAR Table 6.2.6-3 as shown on the attached FSAR 2-105-12 mark-up.

1. For Section 9.2.2.4, correct the typographical error in the second sentence of the first paragraph on FSAR page 9.2-19 (A104), as shown on the attached markup.
13. Section 9.2.2.4 Section 9.2.5.3 2. Clarify Section 9.2.5.3 to indicate the UHS has sufficient capacity to support bringing the non-accident unit to cold shutdown within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from entry into the Hot Standby mode.

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ENCLOSURE2 WBN Unit 2 FSAR A105 "Summary of Redacted Pages" Chapter Page(S) Section No. Figure No. Basis For Redaction I 1 1.2-15 1.2 1.2-1 Security Related, 10CFR2.390(d)(1) 1 1.2-16 1.2 1.2-2 Security Related, 10CFR2.390(d)(1) 1 1.2-17 1.2 1.2-3 Security Related, 10CFR2.390(d)(1) 1 1.2-18 1.2 1.2-4 Security Related, 10CFR2.390(d)(1) 1 1.2-19 1.2 1.2-5 Security Related, 10CFR2.390(d)(1) 1 1.2-20 1.2 1.2-6 Security Related, 10CFR2.390(d)(1) 1 1.2-21 1.2 1.2-7 Security Related, 10CFR2.390(d)(1) 1 1.2-22 1.2 1.2-8 Security Related, 10CFR2.390(d)(1) 1 1.2-23 1.2 1.2-9 Security Related, 10CFR2.390(d)(1) 1 1.2-24 1.2 1.2-10 Security Related, 10CFR2.390(d)(1) 1 1.2-25 1.2 1.2-11 Security Related, 10CFR2.390(d)(1) 1 1.2-26 1.2 1.2-12 Security Related, 10CFR2.390(d)(1) 1 1.2-27 1.2 1.2-13 Security Related, 10CFR2.390(d)(1) 1 1.2-28 1.2 1.2-14 Security Related, 10CFR2.390(d)(1) 1 1.2-29 1.2 1.2-15 Security Related, 10CFR2.390(d)(1) 2 2.2-7 2.2 2.2-1 Security Related, 10CFR2.390(d)(1) 2 2.2-8 2.2 2.2-2 Security Related, 10CFR2.390(d)(1) 2 2.4-89 2.4 2.4-2 Security Related, 10CFR2.390(d)(1) 2 2.4-159 2.4 2.4-24 Security Related, 10CFR2.390(d)(1) 2 2.4-162 2.4 2.4-27 Security Related, 10CFR2.390(d)(1) 2 2.4-163 2.4 2.4-28 Security Related, 10CFR2.390(d)(1) 2 2.4-168 2.4 2.4-40a Security Related, 10CFR2.390(d)(1) 2__2.4-168_2.4 Sheet 1 2 2.4-171 2.4 2.4-40b Security Related, 10CFR2.390(d)(1) 2 2.4-172 2.4 2.4-40c Security Related, 10CFR2.390(d)(1) 2 2.4-173 2.4 2.4-40d Security Related, 10CFR2.390(d)(1)

Sheet 1 2 2.4-178 2.4 2.4-40f Security Related, 10CFR2.390(d)(1)

Sheet 1 2 2.4-181 2.4 2.4-40g Security Related, 10CFR2.390(d)(1)

Sheet 1 2 2.4-206 2.4 2.4-76 Security Related, 10CFR2.390(d)(1) 2 2.4-209 2.4 2.4-79 Security Related, 10CFR2.390(d)(1) 2 2.4-212 2.4 2.4-82 Security Related, 10CFR2.390(d)(1) 2 2.4-213 2.4 2.4-83 Security Related, 10CFR2.390(d)(1) 2 2.4-218 2.4 2.4-88 Security Related, 10CFR2.390(d)(1) 2 2.4-219 2.4 2.4-89 Security Related, 10CFR2.390(d)(1) 2 2.4-220 2.4 2.4-90 Security Related, 10CFR2.390(d)(1) 2 2.5-471 2.5 2.5-185 Security Related, 10CFR2.390(d)(1) 2 2.5-472 2.5 2.5-185a Security Related, 10CFR2.390(d)(1) 2 2.5-513 2.5 2.5-225 Security Related, 10CFR2.390(d)(1) 2 2.5-514 2.5 2.5-226 Security Related, 10CFR2.390(d)(1) 2 2.5-515 2.5 2.5-226a Security Related, 10CFR2.390(d)(1) 2 2.5-575 2.5 2.5-273 Security Related, 10CFR2.390(d)(1) 2 2.5-690 2.5 2.5-358 Security Related, 10CFR2.390(d)(1)

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ENCLOSURE2 WBN Unit 2 FSAR A105 "Summary of Redacted Pages" Chapter Page(S) ISection No. Figure No.I Basis For Redaction I 2 2.5-934 2.5 2.5-592 Security Related, 10CFR2.390(d)(1) 3 3.5-53 3.5 3.5-3 Security Related, 10CFR2.390(d)(1) 3 3.5-54 3.5 3.5-4 Security Related, 10CFR2.390(d)(1) 3 3.6-73 3.6 3.6-21 Security Related, 10CFR2.390(d)(1) 3 3.6-74 3.6 3.6-22 Security Related, 10CFR2.390(d)(1) 3 3.6-75 3.6 3.6-23 Security Related, 10CFR2.390(d)(1) 3 3.6-76 3.6 3.6-24 Security Related, 10CFR2.390(d)(1) 3 3.7-217 3.7 3.7-39 Security Related, 10CFR2.390(d)(1) 3 3.7-218 3.7 3.7-40 Security Related, 10CFR2.390(d)(1) 3 3.7-219 3.7 3.7-41 Security Related, 10CFR2.390(d)(1) 3 3.7-222 3.7 3.7-44 Security Related, 10CFR2.390(d)(1) 3 3.8.3-60 3.8.3 3.8.3-6 Security Related, 10CFR2.390(d)(1) 3 3.8.3-61 3.8.3 3.8.3-7 Security Related, 10CFR2.390(d)(1) 3 3.8.4-94 3.8.4 3.8.4-2 Security Related, 10CFR2.390(d)(1) 3 3.8.4-95 3.8.4 3.8.4-3 Security Related, 10CFR2.390(d)(1) 3 3.8.4-96 3.8.4 3.8.4-4 Security Related, 10CFR2.390(d)(1) 3 3.8.4-97 3.8.4 3.8.4-5 Security Related, 10CFR2.390(d)(1) 3 3.8.4-98 3.8.4 3.8.4-6 Security Related, 10CFR2.390(d)(1) 3 3.8.4-101 3.8.4 3.8.4-9 Security Related, 10CFR2.390(d)(1) 3 3.8.4-109 3.8.4 3.8.4-17 Security Related, 10CFR2.390(d)(1) 3 3.8.4-110 3.8.4 3.8.4-18 Security Related, 10CFR2.390(d)(1) 3 3.8.4-111 3.8.4 3.8.4-19 Security Related, 10CFR2.390(d)(1) 3 3.8.4-112 3.8.4 3.8.4-20 Security Related, 10CFR2.390(d)(1) 3 3.8.4-116 3.8.4 3.8.4-24 Security Related, 10CFR2.390(d)(1) 3 3.8.4-120 3.8.4 3.8.4-28 Security Related, 10CFR2.390(d)(1) 3 3.8.4-127 3.8.4 3.8.4-35 Security Related, 10CFR2.390(d)(1) 3 3.8.4-128 3.8.4 3.8.4-36 Security Related, 10CFR2.390(d)(1) 3 3.8.4-129 3.8.4 3.8.4-36a Security Related, 10CFR2.390(d)(1) 3 3.8.4-132 3.8.4 3.8.4-37 Security Related, 10CFR2.390(d)(1) 3 3.8.4-149 3.8.4 3.8.4-50 Security Related, 10CFR2.390(d)(1) 3 3.8.4-150 3.8.4 3.8.4-51 Security Related, 10CFR2.390(d)(1) 3 3.8.6-19 3.8.6 3.8.6-7 Security Related, 10CFR2.390(d)(1) 6 6.2.2-24 6.2.2 6.2.2-4 Security Related, 10CFR2.390(d)(1) 6 6.2.3-76 6.2.3 6.2.3-4 Security Related, 10CFR2.390(d)(1) 6 6.2.3-77 6.2.3 6.2.3-5 Security Related, 10CFR2.390(d)(1) 6 6.2.3-78 6.2.3 6.2.3-6 Security Related, 10CFR2.390(d)(1) 6 6.2.3-79 6.2.3 6.2.3-7 Security Related, 10CFR2.390(d)(1) 6 6.2.3-80 6.2.3 6.2.3-8 Security Related, 10CFR2.390(d)(1) 6 6.2.3-81 6.2.3 6.2.3-9 Security Related, 10CFR2.390(d)(1) 6 6.2.3-82 6.2.3 6.2.3-10 Security Related, 10CFR2.390(d)(1) 6 6.2.3-92 6.2.3 6.2.3-18 Security Related, 10CFR2.390(d)(1) 6 6.2.3-93 6.2.3 6.2.3-19 Security Related, 10CFR2.390(d)(1) 8 8.1-21 8.1 8.1-1 Security Related, 10CFR2.390(d)(1) 8 8.2-14 8.2 Text only Security Related, 10CFR2.390(d)(1) 8 8.2-15 8.2 Text only Security Related, 10CFR2.390(d)(1)

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ENCLOSURE2 WBN Unit 2 FSAR A105 "Summary of Redacted Pages" Chapter Page(S) lSection No. Figure No. Basis For Redaction I 8 8.2-30 8.2 8.2-3 Security Related, 10CFR2.390(d)(1) 8 8.2-31 8.2 8.2-4 Security Related, 10CFR2.390(d)(1) 8 8.2-44 8.2 8.2-11 Security Related, 10CFR2.390(d)(1) 8 8.3-97 8.3 8.3-1 Security Related, 10CFR2.390(d)(1) 8 8.3-99 8.3 8.3-2 Security Related, 10CFR2.390(d)(1) 8 8.3-100 8.3 8.3-3 Security Related, 10CFR2.390(d)(1) 8 8.3-102 8.3 8.3-4b Security Related, 10CFR2.390(d)(1) 8 8.3-205 8.3 8.3-46 Security Related, 10CFR2.390(d)(1) 8 8.3-218 8.3 8.3-59 Security Related, 10CFR2.390(d)(1) 9 9.2-211 9.2 9.2-40 Security Related, 10CFR2.390(d)(1) 9 9.4-276 9.4 9.4-21 Security Related, 10CFR2.390(d)(1) 9 9.4-280 9.4 9.4-22c Security Related, 10CFR2.390(d)(1) 9 9.4-281 9.4 9.4-23 Security Related, 10CFR2.390(d)(1) 9 9.4-282 9.4 9.4-24 Security Related, 10CFR2.390(d)(1) 12 12.3-39 12.3 12.3-1 Security Related, 10CFR2.390(d)(1) 12 12.3-40 12.3 12.3-2 Security Related, 10CFR2.390(d)(1) 12 12.3-41 12.3 12.3-3 Security Related, 10CFR2.390(d)(1) 12 12.3-42 12.3 12.3-4 Security Related, 10CFR2.390(d)(1) 12 12.3-43 12.3 12.3-5 Security Related, 10CFR2.390(d)(1) 12 12.3-44 12.3 12.3-6 Security Related, 10CFR2.390(d)(1) 12 12.3-45 12.3 12.3-7 Security Related, 10CFR2.390(d)(1) 12 12.3-46 12.3 12.3-8 Security Related, 10CFR2.390(d)(1) 12 12.3-47 12.3 12.3-9 Security Related, 10CFR2.390(d)(1) 12 12.3-48 12.3 12.3-10 Security Related, 10CFR2.390(d)(1) 12 12.3-49 12.3 12.3-11 Security Related, 10CFR2.390(d)(1) 12 12.3-50 12.3 12.3-12 Security Related, 10CFR2.390(d)(1) 12 12.3-51 12.3 12.3-13 Security Related, 10CFR2.390(d)(1) 12 12.3-52 12.3 12.3-14 Security Related, 10CFR2.390(d)(1) 12 12.3-53 12.3 12.3-15 Security Related, 10CFR2.390(d)(1) 12 12.3-54 12.3 12.3-16 Security Related, 10CFR2.390(d)(1) 12 12.3-55 12.3 12.3-17 Security Related, 10CFR2.390(d)(1) 12 12.4-7 12.4 12.4-1 Security Related, 10CFR2.390(d)(1)

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ENCLOSURE3 WBN Unit 2 FSAR A105 "List Of Files And File Sizes On The Security-Related OSM (OSM #1)"

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ENCLOSURE 3 TVA Watts Bar Nuclear Plant Unit 2 FSAR Amendment 105 - List of Files on Security-Related OSM File Name File Size - Bytes TVAWBN-2_FSARFiles 001 TVA WB_FSAR TOC.pdf 362,108 002_TVA WB FSAR LRP.pdf 88,451 003_TVA WB FSAR Section_l .pdf 4,643,883 004 TVA WB FSARSection 2 A.pdf 10,467,163 005_TVAWBFSARSection 2 B Part 1 of 2.pdf 44,606,435 005_TVA WB FSAR Section 2 B Part 2 of 2.pdf 49,572,114 006_TVAWBFSARSection_2_C.pdf 2,107,389 007.TVA WB FSAR Section 2 D.pdf 31,323,839 008_TVA WB FSAR Section 2 E.pdf 47,312,480 009 TVA WB FSAR Section 3 A.pdf 2,622,917 010_TVA WB FSAR Section 3 B.pdf 7,063,082 01 ITVA WB FSAR Section 3 C.pdf 30,016,094 012_TVA WB FSAR Section 3 D.pdf 11,764,620 013 TVA WB FSAR Section 4.pdf 10,713,352 014_TVAWBFSAR Section 5.pdf 9,119,079 015_TVAWBFSAR Section 6 A.pdf 26,047,923 016 TVA WB FSAR Section 6 B.pdf 7,617,151 017_TVA WB FSAR Section 7.pdf 13,195,628 0 T8_TVAW B FSAR Section_8.pdf 29,723,997 019 TVA WB FSAR Section 9 A.pdf 24,536,294 020 TVA WB FSAR Section 9 B.pdf 16,485,358 021 TVA WB FSAR Section 10.pdf 13,430,648 022_TVAWBFSAR Section 1 .pdf 3,965,291 023 TVA WB FSAR Section 12.pdf 5,994,207 024 TVA WB FSAR Section 13.pdf 3,240,070 025_TVA WB FSAR Section 14.pdf 1,170,286 Page 1 of 3

ENCLOSURE 3 TVA Watts Bar Nuclear Plant Unit 2 FSAR Amendment 105 - List of Files on Security-Related OSM File Name File Size - Bytes 026 TVA WB FSAR Section 15.pdf 027 TVA WB FSAR Section_ 16.pdf 028_TVAW BFSARSection 17.pdf Total 407,189,859 TVA_WBN-2_Oversized_FSARFigures 001 TVA WB FSAR Figure 2.5 3.pdf 1,757,743 002_TVA WBFSAR Figure 2.5 11.pdf 1,689,538 003 TVA WB FSAR Figure 2.5 71_.pdf 2,263,087 004 TVA WB FSAR Figure 2.5 222.pdf 909,429 005 TVA WB FSAR Figure 2.5 281_1.pdf 2,155,627 006 TVA WB FSAR Figure 2.5 281 2.pdf 2,117,562 007 TVA WBFSAR Figure 2.5 549 1.pdf 3,600,807 008 TVA WB FSAR Figure 2.5 549_2.pdf 3,989,180 009 TVA WB FSAR Figure 2.5 549 3.pdf 2,863,719 010 TVA WBFSAR Figure 2.5 549 4.pdf 2,809,599 011 TVA WB FSAR Figure 2.5 550.pdf 1,803,985 012_TVA WB FSAR Figure 2.5 551.pdf 1,996,869 013_TVA WB FSAR Figure 2.5 554 1.pdf 3,081,060 014 TVA WB FSAR Figure 2.5 554 2.pdf 1,996,707 015_TVA WBFSAR Figure 2.5 555.pdf 1,993,312 016_TVA WB FSARFigure 2.5 556.pdf 2,998,087 017_TVAWBFSAR Figure 2.5 571_1.pdf 844,484 018_TVA WB FSAR Figure 2.5 571_2.pdf 3,128,329 019 TVA WBFSAR Figure 2.5 571 3.pdf 3,284,555 020_TVAWBFSARFigure 2.5 571 4.pdf 2,142,316 021_TVA WB FSAR Figure 2.5 572.pdf 2,196,945 Page 2 of 3

ENCLOSURE 3 TVA Watts Bar Nuclear Plant Unit 2 FSAR Amendment 105 - List of Files on Security-Related OSM File Name File Size - Bytes 022_TVAWBFSARFigure 2.5 573.pdf 2,013,286 023_TVAWB_FSARFigure 2.5 576_1.pdf 3,238,525 024_TVAWBFSAR Figure 2.5 576 2.pdf 2,151,750 025 TVA WB FSARFigure 2.5 577.pdf 2,207,622 026_TVAWBFSAR Figure 2.5 578.pdf 2,080,032 027_TVAWBFSAR Figure 2.5 579.pdf 2,308,985 028_TVAWBFSARFigure 2.5 583.pdf 2,487,346 029 TVA WB FSAR Figure 2.5 588.pdf 2,528,515 030 TVA WB FSARFigure 2.5 589.pdf 2,480,438 031 TVA WBFSAR Figure 2.5 594.pdf 13,054,127 032 TVAWBFSAR_Figure 2.5 595.pdf 2,323,267 033_TVAWBFSARFigure 2.5 596.pdf 5,732,107 034_TVAWBFSARFigure 2.5 597.pdf 1,287,336 035 TVAWBFSARFigure 2.5 602.pdf 5,549,537 036 TVA WB FSAR Figure 2.5, 603.pdf 4,830,835 037 TVA WBFSAR Figure 2.5 604.pdf 6,392,279 038 TVA WB FSAR Figure 2.5 605.pdf 20,823,108 Total 131,112,035 TVA_WBN-2_OversizedFSARTable 001 TVA WB FSAR Table 6.2.4-1.pdf 1,215,573 Total 1,215,573 Page 3 of 3

ENCLOSURE 4

WBN Unit 2 FSAR "List Of Files And A105 On The Publicly File Sizes Available OSM (OSM #2)"

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ENCLOSURE 4 TVA Watts Bar Nuclear Plant Unit 2 FSAR Amendment 105 List of Files on PubliclyAvailable OSM File Name File Size - Bytes TVA_WBN-2_FSARFiles 001_TVA WB FSARTOC.pdf 362,108 002 TVA WB_FSARLRP.pdf 88,451 003_TVA_ WB_FSARSection_ 1.pdf 837,309 004 TVA WB FSAR Section 2_A.pdf 10,130,617 005 TVA WB FSAR Section 2 B Part lIof_2.pdf 34,359,034 005 TVA WB FSAR Section 2 B Part 2 of_2.pdf 43,314,021 006 TVA WB FSAR Section_2 C.pdf 2,1 07,389 007 TVA WB FSAR Section 2_D.pdf 31,323,839 008 TVA WB FSAR Section 2_E.pdf 45,933,088 009 TVA WB FSAR Section 3_A.pdf 2,331,495 010 TVA WB FSAR Section 3_B.pdf 5,661,310 011 TVA WB FSAR Section 3_C.pdf 25,183,693 012 TVA WB FSAR Section 3_D.pdf 11,495,906 013_TVA_WB_FSARSection_4.pdf 10,713,352 014 TVAW FSARSection_5.pdf 9,119,079 015 TVA WB FSARSection 6_A.pdf 23,167,481 016_ TVA_B FSARSection_6_B.pdf 7,617,151 017 TVA WB FSAR Section 7.pdf 13,195,628 018 TVA WB FSARSection 8.pdf 26,763,889 019 TVA WB FSAR Section 9 A.pdf 24,275,275 020 TVA WB FSAR Section 9_B.pdf 15,270,859 021 TVA WB FSAR Sectionl 0.pdf 13,430,648 022 TVA WB FSAR Section 1 .pdf 3,965,291 023W TVA WB FSAR Section 12.pdf 1,726,180 024 TVA WB FSAR Section_ 13.pdf 3,240,070 025 TVA WB FSAR Section 14.pdf 1,170,286 Note: Byte amounts in italics are redacted files. Page 1 of 3

ENCLOSURE 4 TVA Watts Bar Nuclear Plant Unit 2 FSAR Amendment 105 List of Files on PubliclyAvailable OSM File Name File Size - Bytes 026_TVA WB FSAR Section 15.pdf 46,591,104 027 TVA WB FSAR Section 16.pdf 148,383 028 TVA WB FSAR Section_17.pdf 145,004 Total 413,667,940 TVA_WBN-2_Oversized_FSARFigures 001 TVAWBFSAR Figure 2.5 3.pdf 1,757,743 002_TVAWBFSAR Figure 2.5 11 .pdf 1,689,538 003_TVA WB FSAR Figure 2.5 71.pdf 2,263,087 004_TVAWBFSAR Figure 2.5 222.pdf 909,429 005_TVA WB FSAR Figure 2.5 281_1.pdf 2,155,627 006_TVAWB FSAR Figure 2.5 281_2.pdf 2,117,562 007 TVA WB FSARFigure 2.5 549 l.pdf 3,600,807 008_TVAWBFSAR Figure 2.5 549 2.pdf 3,989,180 009_TVAWB_FSAR Figure 2.5 549_3.pdf 2,863,719 010_TVA WB FSAR Figure 2.5 549 4.pdf 2,809,599.

011_TVA WB FSAR Figure 2.5 550.pdf 1,803,985 012_TVAWB_FSAR Figure 2.5 551.pdf 1,996,869 013_TVA WB FSAR Figure 2.5 554 1.pdf 3,081,060 014_TVAWBFSAR Figure 2.5 554 2.pdf 1,996,707 015 TVA WB FSAR Figure 2.5 555.pdf 1,993,312 016_TVA WB FSAR Figure 2.5 556.pdf 2,998,087 017 TVA WB FSAR Figure 2.5 571_1.pdf 844,484 018_TVA WBFSAR Figure 2.5 571 2.pdf 3,128,329 019 TVA WB FSAR Figure 2.5 571 _3.pdf 3,284,555 020_TVAWBFSAR Figure 2.5 571 _4.pdf 2,142,316 021_TVAWB FSAR Figure 2.5 572.pdf 2,196,945 Note: Byte amounts in italics are redacted files. Page 2 of 3

ENCLOSURE 4 TVA Watts Bar Nuclear Plant Unit 2 FSAR Amendment 105 Listof Files on PubliclyAvailable OSM File Name File Size - Bytes 022_TVAWBFSAR Figure_2.5 573.pdf 2,013,286 023_TVA WB FSARFigure 2.5 576 1.pdf 3,238,525 024_TVAWBFSAR Figure 2.5 576 2.pdf 2,151,750 025_TVAWBFSAR Figure 2.5 577.pdf 2,207,622 026 TVA WB FSAR Figure 2.5 578.pdf 2,080,032 027_TVAWBFSAR Figure 2.5 579.pdf 2,308,985 028_TVAWBFSAR Figure 2.5 583.pdf 2,487,346 029_TVAWBFSAR Figure 2.5 588.pdf 2,528,515 030 TVA WB FSAR Figure 2.5 589.pdf 2,480,438 031 TVA WB FSAR Figure 2.5 594.pdf 13,054,127 032_TVAWBFSAR Figure 2.5 595.pdf 2,323,267.

033 TVA WB FSAR Figure 2.5 596.pdf 5,732,107 034 TVA WB FSAR Figure 2.5 597.pdf 1,287,336 035_TVAWBFSAR Figure 2.5 602.pdf 5,549,537 036 TVA WB FSAR Figure 2.5 603.pdf 4,830,835 037_TVAWBFSAR Figure 2.5 604.pdf 6,392,279 038 TVA WB FSAR Figure 2.5_605.pdf 20,823,108 Total 131,112,035 TVA_WBN-2_OversizedFSARTable 001 TVA WB FSAR Table 6.2.4-1.pdf 1,215,573 Total 1,215,573 Note: Byte amounts in italics are redacted files. Page 3 of 3

ENCLOSURE5 Deviation Request from Regulatory Guide 1.68, Revision 2

Background

In 1985, as documented in Reference 1, TVA formally requested an exemption from cold no-flow, cold full-flow, and hot no-flow rod drop testing for WBN Unit 1. The NRC reviewed and approved this request as shown in the following excerpt from Supplemental Safety Evaluation Report (SSER) 5 (Reference 3 below):

"Cold No-Flow, Cold Full-Flow, and Hot No-Flow Rod Drop Testing By letter dated February 13, 1985, the applicant requested a deviation from RG 1.68, Revision 2, which would allow the removal of rod drop timing tests at cold no-flow, cold full-flow, and hot no-flow conditions from the Watts Bar Initial Test Program. In support of this request, the applicant stated that scram capability is only required for the hot full-flow conditions by the Watts Bar Technical Specifications, except when exempted by Special Test Exemption 3.10.4. The staff has reviewed the February 13, 1985, submittal, concurs with its contents, and finds the deviation acceptable on the basis of the following:

(1) There is nothing new or unique in the design of the Watts Bar control rod system.

(2) Scram capability is only required for hot full-flow conditions.

(3) The deviation is consistent with a similar one allowed for the Initial Test Program at the Callaway Nuclear Plant, Unit 1.

Therefore, the staff approves the deviation and has determined that the applicant does not have to perform cold no-flow, cold full-flow, and hot no-flow rod drop testing at the Watts Bar Nuclear Plant, Unit 1."

As a result of NRC approval, TVA subsequently submitted FSAR Amendment 56 (Reference 2 below) to incorporate this deviation into Chapter 14, "Initial Test Program." In 2007, in the initial phases of Unit 2 completion, as stated in Reference 4, TVA initially did not intend to request a similar deviation for WBN Unit 2 for this item. However, based upon further review of the request granted for Unit 1, TVA has determined that it would pursue this request for Unit 2.

Justification for Request The Unit 1 justification for this request was provided in February 13, 1985 letter (Reference 1 below). Provided in the following is a point-by-point discussion of the Unit 1 justifications as documented in Reference 1 and their applicability to Unit 2:

Justification 1:

"Regulatory Guide 1.68, Revision 2, Appendix A, section 2.b, states 'To the extent practical, testing should demonstrate control rod scram times... as required to bound conditions under which scram might be required.' It is our position that hot full-flow rod drop testing fully meets these conditions of the Regulatory Guide."

Unit 2 Applicability: TVA's position remains unchanged and also applies to Unit 2.

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Justification 2:

"Scram capability is required whenever the reactor is critical, i.e., Modes 1 and 2. Watts Bar TS 3.1.1.4 requires the reactor coolant system operating loop temperature (TAVG) to be greater than or equal to 5510 F in Modes 1 and 2. Specification 3.4.1.1 requires that all reactor coolant loops be in operation in Modes 1 and 2 except when exempted by Special Test Exemption 3.10.4. From these two specifications, it can be seen that hot full-flow rod drop testing would bound the conditions present for a critical reactor (Modes 1 and 2)."

Unit 2 Applicability: The operating loop temperature, Tavg for Unit 2, will be the same as for Unit 1, with the Original Steam Generators (OSG), as required by LCO 3.4.2, "RCS Minimum Temperature for Criticality." Condition A of LCO 3.4.2 requires the unit to be placed into Mode 3 if Tavg, in one or more RCS loops, is not within limit. Therefore, the hot full-flow rod drop testing would also bound the Unit 2 conditions present for a critical reactor in Modes 1 and 2.

Justification 3:

"Scram capability is also required in the event of an uncontrolled rod cluster control assembly bank withdrawal from a subcritical condition. As discussed in the Watts Bar FSAR Section 15.2.1.2, hot zero power conditions (Mode 2) are the most conservative for this event. Thus, this transient condition is bounded by hot, full-flow rod drop testing conditions."

Unit 2 Applicability: This position remains unchanged and also applies to Unit 2.

Justification 4:

"Additional justification for exemption from hot, no-flow rod drop testing is obtained from the analysis rod drop test data for Sequoyah Unit 2 (provided in Reference 1). The rod drop times indicate that in all cases the hot, full-flow rod drop times were longer (more conservative) than the hot, no-flow rod drop times."

Unit 2 Applicability: This position remains unchanged and also applies to WBN Unit 2.

Justification 5:

"Exemption from cold, no-flow, cold, full-flow, and hot, no-flow rod drop testing would be economically beneficial to Watts Bar. As each rod drop test requires at least one shift to complete, a significant amount of critical path work would be eliminated from the plant startup schedule. This is allowed by the requirements of Regulatory Guide 1.68, Revision 2, which requires testing 'To the extent practical....' TVA does not believe it obtains a practical benefit from the performance of these rod drop tests, as the hot full-flow rod drop test bounds the conditions necessary for scram capability. Consequently, TVA believes that exemption from all but hot, full-flow rod drop testing will still meet the requirements of Regulatory Guide 1.68, Revision 2. The Watts Bar TS and FSAR ensure that the conditions requiring scram are bounded by hot, full-flow rod drop testing conditions."

Unit 2 Applicability: This position remains unchanged and also applies to Unit 2.

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==

Conclusion:==

Therefore, based on the evaluation above, TVA requests the same deviation for Unit 2 as was approved for Unit 1 from the cold no-flow, cold full-flow, and hot no-flow rod drop testing requirements of Regulatory Guide 1.68, Revision 2.

References

1. TVA letter to NRC dated February 13, 1985, "Deviation Request" (ML073511898)
2. TVA letter to NRC dated April 30, 1985, "Deviation Request - FSAR Revision 56" (ML072890492)
3. NRC Supplemental Safety Evaluation Report (SSER) 5 dated November 1, 1990 (ML073520360)
4. TVA letter to NRC dated October 11, 2007, "Watts Bar Nuclear Plant (WBN) - Unit 2 -

Exemptions, Reliefs, Deviations and Exceptions" (ML072910331)

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