Text

Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 4 of 8
	ML15176A682
Person / Time
Site:	Sequoyah
Issue date:	06/19/2015
From:	; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML15176A678	List: CNL-15-128, Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 5 of 8; ML15176A664; ML15176A679; ML15176A681; ML15176A682; ML15176A718; ML15176A740; ML15176A748; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 1 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 2 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 3 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 4 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 5 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 7 of 8;
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' . Since this loop involves only the rack instrumentation, the error terms for the process error and sensor are not applicable.

The source range and intermediate range rack instrumentation use the same detector.

The instrumentation is located in an auxiliary and control building area and is not subjected to the harsh environmental parameters of radiation and temperature of a design basis accident.

Therefore, the unmeasurable uncertainties during the channel operational test are 1.3332 percent. This calculation provides assurance that the margin between AV and As-Left Value includes all the uncertainties not measured during the channel operational test (COT). On this basis, the staff finds that the revised AVis adequate to provide assurance that the permissive will be given before the source range trip occurs. Engineering design output Setpoint and Scaling Documents will specify the as-left calibration tolerance and the as-found tolerance for the trip setpoint setting as evaluated within TVA calculations.

Periodic plant calibration will incorporate the as-left calibration tolerance value ensuring compliance with design basis requirements during performance of calibration activities.

For setpoint values found outside the as-left value and inside the as-found value, the setpoint will be adjusted and left within the as-left tolerance per the surveillance requirement.

Also, the licensee committed to using its setpoint calibration procedures to maintain the trip setpoints within the established setting tolerance to ensure that the instrument remains capable of performing its specified safety function.

If the allowable value is exceeded or a potential channel inoperability exists, Plant Procedure SPP-6.7, "Instrument Setpoint, Scaling, and Calibration Program," gives direction for controlling out-of-calibration instrument conditions and contains the requirements for entering the issue into the TVA Corrective Action Program (CAP). SPP-6.7 ensures that the condition is handled in accordance with the CAP including immediate actions to return the instrument to meet TS required functions.

Trending, recurrence controls, and cause of the condition are also part of the CAP process. Based on review of the licensee's procedures, the staff finds that the setpoint calibration procedures maintain the trip setpoints within the established setting tolerance to ensure that the instruments will be capable of performing their specified safety functions and are, therefore; acceptable.

4.5 Revise Fuel Storage Pool Area Radiation Monitor Setpoint Two area type exposure rate radiation detectors are installed in the spent fuel pool area of the auxiliary building to monitor the gross radiation in the air space above the spent fuel pool. The function of the monitors is to initiate isolation of the ventilation paths in the auxiliary building upon detection of high radiation levels and to activate the auxiliary building gas treatment system. The limiting radiation event in the auxiliary building is the fuel handling accident over spent fuel pool. No credit is taken for any of the isolation or filtration functions initiated by the fuel storage pool area radiation monitors.

As such, the automatic functions initiated by these monitors are anticipatory only. They are not variables on which a safety limit has been placed. TS Table 3.3-6, "Radiation Monitoring Instrumentation," Item 1, provides the fuel storage pool area radiation monitor. The licensee has proposed to revise the alarm/trip setpoint from ;:o:200 mR/hr to ;:o: 151 mRihr. The setpoint revision is needed to address identified errors in the dose calculations for a fuel-handling event. The identified errors in the dose calculation have been addressed by the TVA CAP. The licensee evaluated the proposed setpoint in the calculation to ensure that sufficient margin exists to the analytical limit. According to the licensee's calculation, the analytical limit is 7.149 volts. The AVis derived as follows: AV = analytical limit-(uncertainties not measured during COT+ margin) = 7.149 -0.172 = 6.977 volts. Converting 6.977 volts to mR!hr gives 307 mR!hr of the AV. Setpoint = AV -uncertainties measured during COT = 6.977 -0.618 = 6.359 volts. Converting to mR/hr gives 151 mR/hr of the Setpoint.

The staff concludes that the fuel storage pool area radiation monitor will actuate within the required accident analysis assumptions to support accident mitigation.

Therefore, the staff finds the proposed setpoint acceptable.

4.6 Auxiliary Feedwater and Emergency Diesel Generator Loss-of-Power Timers TS Table 3.3-3, Functional Unit 6.e provides for the automatic actuation of the AFW system upon loss of off-site power. This Functional Unit includes both voltage sensors and load shed timers. TS Table 3.3-3, Functional Unit 7 provides for the automatic actuation of the EDGs upon either loss-of-voltage or degraded voltage at the 6.9 kV Shutdown Board. This Functional Unit includes voltage sensors, load shed timers, and logic enable timers. The SON TSs has redundant load shed and logic enable timers for each shutdown board in each train for both Functional Units 6.e and 7. These timers support automatic actuation of the loss-of-power start of the AFW pumps and EDGs. Thus, the Minimum Channels Operable column of TS Table 3.3-3 requires that 2 load shed and logic enable timers per shutdown board remain operable.

The licensee has proposed to reduce the Minimum Channels Operable from 2 per shutdown board to only 1 per shutdown board. Since there is no NRC requirement for the licensee to have redundant timers, the staff finds the proposed change acceptable.

Actions 34 and 35 toTS Table 3.3-3 currently require prompt licensee action if one of the two load shed or logic enable timers of Functional Units 6.e or 7 become inoperable.

Since the Minimum Channels Operable requirement has been changed from 2 to 1 per shutdown board, the licensee has proposed modifications to Actions 34 and 35 to permit continued plant operation with only a single load shed or logic enable timer. The proposed changes to Actions 34 and 35 support the previous change to the Minimum Channels Operable.

The staff considers these changes to be administrative in nature and, therefore, acceptable.

5.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Tennessee State official was notified of the proposed issuance of the amendment.

The State official had no comments.

8-6.0 ENVIRONMENTAL CONSIDERATION The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 1 0 CFR Part 20 and changes surveillance requirements.

The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.

The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (69 FR 60688). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

7.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public. Principal Contributor:

Sang Rhow Hukam Garg Date: September 13, 2006 Licensee Response/NRC Response/NRC Question Closure Id270NRC Question Number KAB022Select Application NRC Question ClosureAttachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.Question Closure Date 8/20/2014Notification Scott BowmanMichelle ConnerKhadijah HemphillAndrew HonLynn MynattRay SchieleRoger ScottAdded By Kristy Bucholtz Date Added 8/20/2014 10:45 AMDate Modified Modified By Page 1of 1 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

p h p?re q uestT yp e=areaItemPrint&itemId=270 ITS NRC Questions Id 46NRC Question Number KAB023Category TechnicalITS Section 3.3ITS Number 3.3.2DOC Number L-6JFD Number JFD Bases Number Page Number(s) 437NRC Reviewer Supervisor Rob ElliottTechnical Branch POC Add NameConf Call Requested NNRC Question On page 437 of Enclosure 2, Volume 8, L06 provides the discussion of CTS Table 3.3-3 footnote (a) which is applicable to function unit 6.f, "Auxiliary Feedwater Trip of Main Feedwater Pumps Start Motor-Driven Pumps and Turbine Driven Pump."Footnote (a) states, "One channel may be inoperable during Mode 1 for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when placing the second main feedwater (MFW) pump in service or removing one of two MFW pumps from service."TVA has chosen to add this footnote into the ITS as a required actions note in Condition N, which is applicable to function 6.e, "Auxiliary Feedwater Trip of all Main Feedwater Pumps."However, the ITS required action note does not include the phrase, "during Mode 1."Without the phrase, "during Mode 1,"added to the Note it expands the use of the note to Mode 2. This note is not in ISTS and the proposed change to the note is not allowed by CTS, therefore this is a beyond scope change. Provide the technical evaluation for NRC review or revise the note to be consistent with the CTS requirements.Attach File 1 Attach File 2 Issue Date 5/9/2014Added By Kristy Bucholtz Date Modified Modified By Date Added 5/9/2014 8:44 AMNotification Scott BowmanMichelle ConnerAndrew HonLynn MynattRay SchieleRoger ScottPage 1of 1 Sequoyah ITS Conversion Databas e 10/15/201 4htt p s://members.excelservices.com/rai/index.

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Licensee Response/NRC Response/NRC Question Closure Id 95NRC Question Number KAB023 Select Application Licensee ResponseAttachment 1 Attachment 2 Response Statement SQN is requesting a relaxation to the MODE of APPLIC ABILITY for Main Feedwater (MFW) pump OPERABILITY, fr om "during MODE 1" to "during MODES 1 and 2". The proposed relaxation to CTS Table 3.3-3 Function 6.f, Trip of Main Feedwater Pumps Star t Motor-Driven Pumps and Turbine Driven Pump, Footnote (a), as discussed in ITS 3.3.2, discussion of change (DOC) L06 provides for an operational al lowance during Modes 1 and 2 for placing MFW pumps in service or securing MFW pumps. This change is justified because the AFW Start function is anticipatory for loss of normal heat sink and is not credited in the accident analysis. Also, this relaxation does not affect the function that act uates AFW due to a blackout signal, low-low steam generator (S G) level, or a safety injection (SI) signal. The technical justificat ion for the addition of MODE 2 relaxa tion is the same as the previously approved MODE 1 relaxation.

On August 26, 2008, Tennessee Valley Authority (TVA) submitted a request for a TS change (TS-08-05) to Li censes DPR-77 and DPR-79 for SQN. The requested TS change would revise Functional Unit 6.f of Table 3.3-3, "Engineered Safety Feature Actuation System Instrumentation,"modifying the mode of applicabilit

y. A footnote was added to indicate that the AFW auto-start function associated with the trip of MFW pumps in Mode 2 is only required when one or mo re MFW pumps are suppl ying feedwater to the steam generators. Functional Unit 6.f of TS Table 3.3-3 is an anticipatory trip function that provides early actuation of the AFW system. This specific change was requested based on an NRC issued Inspection Report 2008-003 dated August 7, 2008, to Watts Bar Nuclear (WBN) Plant. In this report, NRC informed TVA that plant operation is not conforming to TS 3.3.2 Item 6.e when a non-operating main feedwa ter (MFW) pump is reset. This TS function is equivalent to the SQN TS Functional Unit 6.f of Table 3.3-3. TVA had considered the associated AFW auto-start channel operable; however, NRC informed WBN that a non-operating MFW pump in the reset condition impacts operability of the AFW auto-start due to the false indication of the MFW pump status.

On August 28, 2008, durin g a teleconference with NRC it was noted that entry into a limiting c ondition of operation (LCO) Action for placing the second main feedwater (M FW) pump in service or re moving it from service would be inconsistent with TS appl ication without addi tional notation. APage 1of 3 Sequoyah ITS Conversion Databas e 10/15/201 4htt p s://members.excelservices.com/rai/index.

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supplement to LAR TS-08-05, was submitted on A ugust 28, 2008, to add a footnote to the Minimum Channels Operable column for Functional Unit 6.f of TS Table 3.3-3 to i ndicate one channel may be inoperable during Mode 1 for up to four hours wh en starting up or shut ting down a MFW pump.

On August 29, 2008, the Nuclear Regulator y Commission issued Amendment No. 312 to Facility Operating License No. DPR-77 and Amendment No. 319 to Facility Operating License No. DPR-79 for the Sequoyah Nuclear Plant (SQN), Units 1 and 2, respectively (ML082401385). The amendment revised the requirements for the auxiliary feedwater system auto-start function associated with the trip of main feedwater pumps. The approved change added (1)

Footnote (b), to i ndicate that Mode 2 applicability is limited to operati on when one or more MFW pumps are supplying feedwater to th e steam generato rs (SGs), and (2) Footnote (a), delaying the entry into the action statement when starting or stopping MFW pumps in Mode 1.The NRC stated in Section 3, Techni cal Evaluation, the following, "The second proposed change addresses a conflict be tween the TS channel operability requirement a nd the design of the MFW pump control circuitry, which requires the pump to be reset before being placed into operation.

Starting and stopping MFW pumps durin g plant startup and shutdown is a normal evolution, which will normally be accomplished within a short time.

It was not intended to result in unnecessary entries into the action statement, which provides a timefr ame to correct unpl anned equipment failures. For the normal operating evolution of starting and stopping pumps, the proposed change would allow a de lay of up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months before entering the action statement. The evo lution should be completed in less time, but the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides a re asonable allowance for operating contingencies. If the evolution takes longer than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , it is probably indicative of an equipment problem and entering the action statement would be appropriate. The 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is consistent with similar allowances in other SQN TSs, such as the emergency core cooling system and low-temperature overpre ssure protection."Response Date/Time 6/5/2014 4:10 PM Closure Statement Question Closure Date Notification Scott BowmanKristy BucholtzMichelle ConnerKhadijah HemphillAndrew HonRay SchieleAdded By Scott Bowman Date Added 6/5/2014 3:08 PMPage 2of 3 Sequoyah ITS Conversion Databas e 10/15/201 4htt p s://members.excelservices.com/rai/index.

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Date Modified Modified By Page 3of 3 Sequoyah ITS Conversion Databas e 10/15/201 4htt p s://members.excelservices.com/rai/index.

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Licensee Response/NRC Response/NRC Question Closure Id 159NRC Question Number KAB023Select Application NRC ResponseAttachment 1 Attachment 2 Response Statement Please explain if Sequoyah operates with one MFP pump or two MFP pumps during Mode 2 with a brief explanation of your preferred method of operation in Mode 2 and before or during switchover to Mode 1.Response Date/Time 6/27/2014 6:00 PM Closure Statement Question Closure Date Notification Scott BowmanMichelle ConnerKhadijah HemphillAndrew Hon Lynn MynattRay SchieleRoger ScottAdded By Kristy Bucholtz Date Added 6/27/2014 12:39 PMDate Modified Modified By Page 1of 1 Sequoyah ITS Conversion Databas e 10/15/201 4htt p s://members.excelservices.com/rai/index.

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Licensee Response/NRC Response/NRC Question Closure Id357 NRC Question Number KAB023Select Application Licensee Response Attachment 1 KAB023 Attachment 1 second response STB.pdf (87KB)Attachment 2 Response Statement In response to KAB023, the ITS 3.3.2 Condition N, NO TE (ISTS markups, Insert 6) on pages 458 and 492 of Enclosure 2, Volu me 8, will be revised.Specifically, the Note will be revised to state, "One channel may be inoperable during MODE 1 for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when placing the second main feedwater (MFW) pump in service or removing one of two MFW pumps from service."The CTS markups for CTS Ta ble 3.3-3, Function 6.f (Auxiliary Feedwater, Trip of Main Feedwater Pumps Start Motor-Driven Pumps and Turbine Driven Pump), Footnote (a) will be revised to retain the phrase, "during Mode 1."(Pages 346 and 386)Discussion of change (DOC) L06, that justified the removal of the phrase will be deleted, as well as, DOC L06 indicators. (Pages 346, 386, 438, and 439)The IT S 3.3.2 Bases, Actions Section for ITS Actions N.1 and N.2 (Insert 16) will be revised to state, "The Required Actions are modified by a note delaying the entry into the Required Action statement when st arting or stopping MFW pumps during MODE 1."(Pages 581 and 659)Additionally, during review for KAB023, it was identified that the ITS 3.3.2 Bases, Applicable Safety Analyses, LCO and Applic ability Section, for ITS Table 3.3.2-1, Function 6.e (Auxiliary F eedwater, Trip of all Main Feedwater Pumps) indicated that there are two Footnotes associat ed with Function 6.e.The ITS 3.3.2 Bases (Inser t 9) will be revised to indicate that there is only one footnote associat ed with ITS Table 3.3.

2-1 Function 6.e, and the discussion concerning the second footnote will be deleted.(Pages 560 and 638)See Attachment 1 for the draft revised CTS, ITS, and ITS Bases markups and the deletion of DOC L06.Response Date/Time 9/26/2014 10:05 AMClosure Statement Question Closure Date Notification Scott BowmanKristy BucholtzMichelle Conner Khadijah HemphillPage 1of 2 Sequoyah ITS Conversion Databas e 10/15/201 4htt p s://members.excelservices.com/rai/index.

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Andrew HonRay Schiele Added By Scott Bowman Date Added 9/26/2014 9:03 AMDate Modified Modified By Page 2of 2 Sequoyah ITS Conversion Databas e 10/15/201 4htt p s://members.excelservices.com/rai/index.

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ITS A01 ITS 3.3.2 TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION

FUNCTIONAL UNIT TOTAL NO.

OF CHANNELS CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES ACTION e. Loss of Power Start

1. Voltage Sensors 3/shutdown board** 2/shutdown board** 3/shutdown board** 1, 2, 3 35

2. Load Shed Timer 2/shutdown 1/shutdown 1/shutdown 1, 2, 3 35 board** board** board** f. Trip of Main Feedwater Pumps Start Motor-Driven Pumps and Turbine Driven Pump 1/pump 1/pump 1/pump (a) 1, 2 (b) 20 g. Auxiliary Feedwater Suction Pressure-Low 3/pump 2/pump 3/pump 1, 2, 3 21

h. Auxiliary Feedwater Suction Transfer Time Delays 1. Motor-Driven Pump 1/pump 1/pump 1/pump 1, 2, 3 21

2. Turbine-Driven Pump 2/pump 1/pump 2/pump 1, 2, 3 21

- Unit 1 shutdown boards only

(a) One channel may be inoperable during Mode 1 for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when placing the second main feedwater (MFW) pump in service or removing one of two MFW pumps from service.

(b) When one or more Main Feedwater Pump(s) are supplying feedwater to steam generators.

August 29, 2008 SEQUOYAH - UNIT 1 3/4 3-20 Amendment No. 41, 129, 182, 188, 207, 301, 310, 319 Page 15 of 80REQUIRED LA01 A02 ITS ACTION Table 3.3.2-1 6.d.(1) 6.d. 6.d.(2) 6.e 6.f 6.g 6.g.(1) 6.g.(2) L,M M N O O O Footnote (j) Required Action N Note Footnote (k) L06 ITS ITS 3.3.2 A01TABLE 3.3-3 (Continued)

ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION FUNCTIONAL UNIT TOTAL NO.

OF CHANNELS CHANNELS TO TRIP MINIMUM CHANNELS OPERABLE APPLICABLE MODES ACTION e. Loss of Power Start

1. Voltage Sensors 3/shutdown board** 2/shutdown board** 3/shutdown board** 1, 2, 3 35 2. Load Shed Timer 2/shutdown 1/shutdown 1/shutdown 1, 2, 3 35 board** board** board** f. Trip of Main Feedwater Pumps Start Motor-Driven Pumps and Turbine Driven Pump 1/pump 1/pump 1/pump (a) 1, 2 (b) 20 g. Auxiliary Feedwater Suction Pressure-Low 3/pump 2/pump 3/pump 1, 2, 3 21

h. Auxiliary Feedwater Suction Transfer Time Delays 1. Motor-Driven Pump 1/pump 1/pump 1/pump 1, 2, 3 21

2. Turbine-Driven Pump 2/pump 1/pump 2/pump 1, 2, 3 21

- Unit 2 Shutdown Boards Only (a) One channel may be inoperable during Mode 1 for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when placing the second main feedwater (MFW) pump in service or removing one of two MFW pumps from service.

(b) When one or more Main Feedwater Pump(s) are supplying feedwater to steam generators.

August 29, 2008 SEQUOYAH - UNIT 2 3/4 3-20 Amendment No. 29, 116, 174, 180, 197, 290, 299, 312 Page 55 of 80Table 3.3.2-1 ITS ACTION LA01REQUIRED A02L.M M N O O O 6.g.(2) 6.g.(1) 6.g 6.f 6.e 6.d.(2) 6.d.(1) 6.d. Footnote (j) Footnote (k)

Required Action N Note L06 DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 27 of 35 The purpose of the ITS Table 3.3.2-1 Function 4 Applicability is to provide an exception to clarify that the Steam Line Isolation instrumentation Functions are not required when the MSIVs are in a position that supports the safety analyses.

This change is acceptable because the requirements continue to ensure that the structures, systems, and components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. When all the MSIVs are in the closed position, they are in their assumed accident position, thus the isolation instrumentation is not needed. In addition, the MSIVs are not required to be OPERABLE in MODES 2 and 3 when the valves are closed, thus there is no purpose in requiring the instrumentation that closes the valves to be OPERABLE. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS. L05 (Category 2 - Relaxation of Applicability) CTS Table 3.3-3 requires Functional Unit 5.a (Turbine Trip and Feedwater Isolation Steam Generator Water Level - High High) and 5.b (Turbine Trip and Feedwater Isolation - Automatic Actuation Logic) to be OPERABLE in MODES 1, 2, and 3. ITS Table 3.3.2-1 requires the same Functions (ITS Table 3.3.2-1 Functions 5.a and 5.b) to be OPERABLE in MODE 1, and in MODES 2 and 3 except when all MFIVs, MFRVs, and MFRV bypass valves are closed or isolated by a closed manual valve, Footnote (k). This changes the CTS by not requiring the instrumentation to be OPERABLE when all MFIVs, MFRVs, and MFRV bypass valves are closed or isolated by a closed manual valve.

The purpose of the ITS Table 3.3.2-1 Functions 5.a and 5.b Applicability is to provide an exception to clarify that the Turbine Trip and Feedwater Isolation Steam Generator Water Level - High High (P-14) instrumentation and the Turbine Trip and Feedwater Isolation Automatic Actuation Logic and Actuation Relays are not required when all MFIVs, MFRVs, and MFRV bypass valves are closed or isolated by a closed manual valve. In this condition, the Function will not need to function since the valves are in a position that supports the safety analyses. This change is acceptable because the requirements continue to ensure that the structures, systems, and components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis. When all MFIVs, MFRVs, and MFRV bypass valves are in the closed position, they are in their assumed accident position. This change is designated as less restrictive because the LCO requirements are applicable in fewer operating conditions than in the CTS.

L06 (Category 2 - Relaxation of Applicability) CTS Table 3.3.3 footnote (a) is applicable to Functional Unit 6.f (Trip of Main Feedwater Pumps Start Motor-Driven Pumps and Turbine Driven Pump) "Minimum Channels OPERABLE" requirement. CTS Table 3.3.3 footnote (a) states that one channel may be inoperable during Mode 1 for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when placing the second main feedwater (MFW) pump in service or removing one of two MFW pumps from service. ITS 3.3.2 ACTION N is applicable Function 6.e (Auxiliary Feedwater, Trip of Main Feedwater Pumps) and is modified by a similar Required Action Note. ITS 3.3.2 ACTION N Required Action Note states that one channel may DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 28 of 35 be inoperable for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when placing the second main feedwater (MFW) pump in service or removing one of two MFW pumps from service. This changes the CTS by increasing the MODES in which this footnote relaxation is Applicable.

The purpose of CTS Table 3.3.3 footnote (a) is to prevent unnecessary entries into the ACTION statement during the normal evolution of starting or stopping a main feedwater pump. Making this relaxation Applicable in MODE 2 addresses the possibility that a situation may exist requiring starting or stopping of a main feedwater pump, preventing an unnecessary entry into the associated ACTION.

This change is acceptable because the requirements continue to ensure that the structures, systems, and components are maintained in the MODES and other specified conditions assumed in the safety analyses and licensing basis as the AFW auto-start function provides an anticipatory trip to reduce the effect of a feedwater transient. In addition, as in MODE 1, the evolution should be completed in less than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months providing a reasonable allowance for operating contingencies. This change is designated as less restrictive because the Required Channel relaxation is applicable in more operating conditions than in

the CTS.

L07 (Category 9 - Allowed Outage Time, Surveillance Frequency, and Bypass Time Extensions Based on Generic Topical Reports)

CTS Table 3.3-3 ACTION 17, requires in part that with the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the inoperable channel is placed in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This action is applicable to CTS Table 3.3-3 Functional Units: 1.c (Containment Pressure - High); 1.d (Pressurizer Pressure - Low); 1.f (Steam Line Pressure - Low); 4.d (Steam Line Pressure - Low); 4.e (Negative Steam Line Pressure Rate - High); and 5.a (Steam Generator Water Level - High-High). ITS 3.3.2, Required Action D.1 require placing the associated channel in trip with a Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for ITS Table 3.3.2-1 Functions 1.c (Containment Pressure - High); 1.d (Pressurizer Pressure - Low); 1.e (Steam Line Pressure - Low); 4.d.(1) (Steam Line Pressure - Low); 4.d.(2) (Negative Steam Line Pressure Rate - High); and 5.b (SG Water Level - High-High (P-14)). This changes the CTS by increasing the Completion Time for placing an inoperable channel for these Functional Units from six (6) hours to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months .

The purpose of CTS Table 3.3-3 ACTION 17 is to limit the maximum time allowed for maintenance activities, in which the channel is unavailable or prior to being placed in a tripped state. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. Additionally, this change is acceptable based on TVA's confirmation of applicability and incorporation of insights as described in Enclosure 4 of this submittal, required by the NRC in their letter and enclosed Safety Evaluation Report (SER) dated July 15, 1998, "Review of Westinghouse Owners Group Topical Reports WCAP-14333-P and WCAP-14334-NP, dated May 1995, 'Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times' (TAC NO. M92782)." This change is 3.3.2 Insert Page 3.3.2-5a CTS INSERT 6 ----------------NOTE--------------

One channel may be inoperable for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when placing the second main feedwater (MFW) pump in service or removing one of two MFW pumps from service. ---------------------------------------

Table 3.3-3, Footnote (a) 2 3.3.2 Insert Page 3.3.2-5a CTS INSERT 6 ----------------NOTE--------------

One channel may be inoperable for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when placing the second main feedwater (MFW) pump in service or removing one of two MFW pumps from service. ---------------------------------------

Table 3.3-3, Footnote (a) 2 B 3.3.2 Insert Page B 3.3.2-33a INSERT 9 This Function includes two footnotes. The first footnote indicates that MODE 2 applicability is limited to operation when one or more MFW pumps are supplying feedwater to the steam generators (SGs), and the second footnote provides for delaying the entry into the action statement when starting or stopping MFW pumps in MODE 1.

The first footnote limits the Applicability to require the auto-start logic to be operable in MODE 2 only when at least one MFW pump is in service supplying feedwater to the SGs. Because plant conditions at the time of entry into Mode 2 do not allow the MFW pumps to operate, without this footnote the channels would need to be tripped resulting in an AFW start signal, starting the turbine-driven pump in addition to the motor-driven AFW pumps, which is an undesirable situation. This resolves a conflict between the MODE applicability and plant design, which does not support MFW pump operation at the time of entry into MODE 2. Also, modifying the requirement for auto-start of the AFW pumps to be only required when the MFW pumps are in service limits the potential for inadvertent AFW actuations during normal plant startups and shutdowns that could lead to reactivity control issues due to over cooling transients.

The second footnote delays entry into the Required Action for less than minimum channels operable for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . During the time of starting and stopping a second MFW pump, when the pump is in reset, the auto-start function is inoperable. Starting and stopping MFW pumps during plant startup and shutdown is a normal evolution, which will normally be accomplished within a short time. This note is intended to prevent unnecessary entries into the Required Actions, which provides a timeframe to correct unplanned equipment failures. For the normal operating evolution of starting and stopping pumps, the footnote allows a delay of up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months before entering the Required Action.

The evolution should be completed in less time, but the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides a reasonable allowance for operating contingencies. If the evolution takes longer than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , it is probably indicative of an equipment problem and entering the Required Action is appropriate.

5 B 3.3.2 Insert Page B 3.3.2-47e INSERT 16 The Required Actions are modified by a not e delaying the entry into the Required Action statement when starting or stopping MFW pumps. Starting and stopping MFW pumps during plant startup and shutdown is a normal evolution, which will normally be accomplished within a short time. It was not intended to result in unnecessary entries into the Required Actions, which provides a timeframe to correct unplanned equipment failures. The 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is consistent with similar allowances in other SQN TSs.

O.1 Condition O applies to the following ESFAS Functions:

Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - Low,

Auxiliary Feedwater Suction Transfer Time Delays, Motor-Driven Pump, and

Auxiliary Feedwater Suction Transfer Time Delays, Turbine-Driven Pump.

These functions are provided by three pressure sensors located on the suction of

each AFW pump arranged in a two-out-of-three logic scheme. The motor driven AFW pumps have one time delay, while the TDAFW pump has two. The motor driven and the first TDAFW pump time delays prevent spurious transfer. The TDAFW Pump second time delay ensures ERCW Train A valves stroke open sufficiently.

If a pressure sensor channel or a time delay channel is inoperable, the associated AFW pump must be declared inoperable immediately.

7 2 B 3.3.2 Insert Page B 3.3.2-33a INSERT 9 This Function includes two footnotes. The first footnote indicates that MODE 2 applicability is limited to operation when one or more MFW pumps are supplying feedwater to the steam generators (SGs), and the second footnote provides for delaying the entry into the action statement when starting or stopping MFW pumps in MODE 1.

The first footnote limits the Applicability to require the auto-start logic to be operable in MODE 2 only when at least one MFW pump is in service supplying feedwater to the SGs. Because plant conditions at the time of entry into Mode 2 do not allow the MFW pumps to operate, without this footnote the channels would need to be tripped resulting in an AFW start signal, starting the turbine-driven pump in addition to the motor-driven AFW pumps, which is an undesirable situation. This resolves a conflict between the MODE applicability and plant design, which does not support MFW pump operation at the time of entry into MODE 2. Also, modifying the requirement for auto-start of the AFW pumps to be only required when the MFW pumps are in service limits the potential for inadvertent AFW actuations during normal plant startups and shutdowns that could lead to reactivity control issues due to over cooling transients.

The second footnote delays entry into the Required Action for less than minimum channels operable for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . During the time of starting and stopping a second MFW pump, when the pump is in reset, the auto-start function is inoperable. Starting and stopping MFW pumps during plant startup and shutdown is a normal evolution, which will normally be accomplished within a short time. This note is intended to prevent unnecessary entries into the Required Actions, which provides a timeframe to correct unplanned equipment failures. For the normal operating evolution of starting and stopping pumps, the footnote allows a delay of up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months before entering the Required Action.

The evolution should be completed in less time, but the 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months provides a reasonable allowance for operating contingencies. If the evolution takes longer than 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months , it is probably indicative of an equipment problem and entering the Required Action is appropriate.

5 B 3.3.2 Insert Page B 3.3.2-47e INSERT 16 The Required Actions are modified by a not e delaying the entry into the Required Action statement when starting or stopping MFW pumps. Starting and stopping MFW pumps during plant startup and shutdown is a normal evolution, which will normally be accomplished within a short time. It was not intended to result in unnecessary entries into the Required Actions, which provides a timeframe to correct unplanned equipment failures. The 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is consistent with similar allowances in other SQN TSs.

O.1 Condition O applies to the following ESFAS Functions:

Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - Low,

Auxiliary Feedwater Suction Transfer Time Delays, Motor-Driven Pump, and

Auxiliary Feedwater Suction Transfer Time Delays, Turbine-Driven Pump.

These functions are provided by three pressure sensors located on the suction of

each AFW pump arranged in a two-out-of-three logic scheme. The motor driven AFW pumps have one time delay, while the TDAFW pump has two. The motor driven and the first TDAFW pump time delays prevent spurious transfer. The TDAFW Pump second time delay ensures ERCW Train A valves stroke open sufficiently.

If a pressure sensor channel or a time delay channel is inoperable, the associated AFW pump must be declared inoperable immediately.

7 2 Licensee Response/NRC Response/NRC Question Closure Id363NRC Question Number KAB023Select Application NRC Question ClosureAttachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.Question Closure Date 9/30/2014Notification Scott BowmanMichelle ConnerKhadijah HemphillAndrew HonLynn MynattRay SchieleRoger ScottAdded By Kristy Bucholtz Date Added 9/30/2014 10:48 AMDate Modified Modified By Page 1of 1 Sequoyah ITS Conversion Databas e 10/15/201 4htt p s://members.excelservices.com/rai/index.

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ITS NRC Questions Id 47NRC Question Number KAB024 Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number A-14JFD Number JFD Bases Number Page Number(s) 419, 420NRC Reviewer Supervisor Rob ElliottTechnical Branch POC Add Name Conf Call Requested NNRC Question On page 419 of Enclosure 2, Volume 8, A14 provides the discussion of CTS Table 3.3-3 functional unit 4.d, "Ste am Line Isolation Steam Line Pressure -Low,"and footnote #.CT S permit functional unit 4.d (ITS function 4.d.(1)) to be bypassed in Mode 3 below P-11 (Pressurizer Pressure Bl ock of Safety Injection) setpoint.

On page 420 of Enclosure 2, Volume 8, A15 provides the discussion of CTS Table 3.3-3 func tional unit 4.e , "Steam Line Isolation Negative Steam Line Pressure Rate-High,"and footnote ##.CTS permit functional unit 4.e (ITS function 4.d.(2)) to be bypassed in Mode 3 below P-11 when Safety Injection on Steam Line Pressure Low is not blocked and it states that this function is automatically blocked above P-11.

ITS footnote (a) states, "Above the P-11 (Pressurizer Pressure) interlock."ITS footnote (a) is the equivalent of CTS footnote #, the only difference between the two footnotes is that the ITS footnote discusses when it is re quired to be operable and the CTS footnote discusses when it is permitted to be bypassed.However, TVA is not proposing to add ITS footnote (a) to ITS function 4.d.

(1).TVA is proposing to add ne w footnote (f), which states, "When Steam Line Isolation on Steam Line Pressure, Negative Rate-High is blocked."ITS footnote (f) would not require function 4.d.(1) to be operable in Mode 3 unless the Steam Line Isolation Steam Line Pressu re, Negative Rate-High is Page 1of 2 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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blocked/bypassed.

Furthermore, a similar footnote (g) is proposed for ITS function 4.d.(2), "Steam Line Isolation St eam Line Pressure Negative Rate-High,"and states that this function would not be required to be operable in Mode 3 unless the Stea m Line Isolation on Steam Line Pressure, Low is blocked."Therefore, in Mode 3 if neither function is blocked/bypassed then neither function is required to be operable.CTS operability of functional unit 4.d is not depend ent on functional unit 4.e, nor should the operability of ITS f unction 4.d.(1) be dependent on function 4.d.(2).In addition, if ITS function 4.d.(1) becomes inoperable and is placed in bl ock/bypass while above P-11 then ITS requires function 4.d.(2) to be operable, however this is not possible due to the design auto matically blocking above P-11.These footnotes are not in ISTS and the re sults of the proposed footnotes are not allowed by CTS, therefore this is a beyond scope change. Provide

the technical evaluation for NRC re view or revise the footnotes to be consistent with the CTS requirements.

Attach File 1 Attach File 2 Issue Date 5/9/2014 Added By Kristy BucholtzDate Modified Modified By Date Added 5/9/2014 8:48 AMNotification Scott BowmanMichelle ConnerAndrew HonLynn MynattRay SchieleRoger ScottPage 2of 2 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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Licensee Response/NRC Response/NRC Question Closure Id 96 NRC Question Number KAB024 Select Application Licensee Response Attachment 1 Attachment 1 revised submittal pages for 3.3.2 Footnotes.pdf (1MB)Attachment 2 Response Statement In response to KAB-024, SQ N will revise the ISTS Table 3.3.2-1 Footnotes (a), (f), and (g) associated with ITS Table 3.3.2-1 Func tions 1.d, 1.e, 4.d.(1), and 4.d.(2), to be consistent wi th CTS Table 3.3-3 Notes # and ##

requirements.

(1) CTS TABLE 3.3-3 Note #

as it applies to ITS Table 3.3.2-1 Footnote (a), will be revised to read, "Safety Injection, Pressurizer Pressure - Low and Safety Injection, Steam Line Pressure - Low may be bypassed below the P-11 (Pressurizer Pressure) interlock."Associated changes for ITS Table 3.3.2-1 Footnote (a) will be made to the CTS markups for Units 1 and 2 (pages 350 and 390 of Enclosure 2, Volume 8), discussion of change (DOC) A13 (page 419), and ISTS markups for Units 1 and 2 (pages 466 and 500).

(2) CTS TABLE 3.3-3 Note

as it applies to ITS Table 3.3.2-1 Footnote (f) will be revised to read, "Steam Line Isolation, Steam Line Pressure - Low may be bypassed below the P-11 (Pressurizer Pressure) interlock."Associated changes for ITS Table 3.3.2-1 Footnote (f) will be made to the CTS markups for Units 1 and 2 (pages 350 and 390 of Encl osure 2, Volume 8), DOC A14 (page 419), and ISTS markups for Units 1 and 2 (pages 470 and 504).(3) CTS TABLE 3.3-3 Note ## as it applies to ITS Table 3.3.2-1 footnote (g) will be revised to read , "Steam Line Isolation, Steam Line Pressure Negative Rate-High is automatically blocked above P-11 and may be blocked below P-11 when Safety Inject ion, Steam Line Pr essure - Low is not blocked."Associated changes for ITS Table 3.3.2-1 Foot note (g) will be made to the CTS markups for Units 1 and 2 (pages 350 and 390 of Enclosure 2, Volume 8), DOC A15 (page 420), and ISTS markups for Units 1 and 2 (pages 470 and 504).

See Attachment 1 for the draft revised CTS markups/I nserts for Units 1 and 2; DOCs A13, A14, a nd A15; and ISTS Markups for Units 1 and 2.Response Date/Time 6/5/2014 4:15 PMClosure Statement Page 1of 2 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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Question Closure Date Notification Scott BowmanKristy BucholtzMichelle Conner Khadijah HemphillAndrew HonRay Schiele Added By Scott Bowman Date Added 6/5/2014 3:13 PMDate Modified Modified By Page 2of 2 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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ITS A01 ITS 3.3.2TABLE 3.3-3 (Continued)

TABLE NOTATION

Trip function may be bypassed in this MODE below P

-11 (Pressurizer Pressure Block of Safety Injection) setpoint. ## Trip function automatically blocked above P

-11 and may be blocked below P11 when Safety Injection on Steam Line Pressure

-Low is not blocked. ACTION STATEMENTS

ACTION 15 - With the number of OPERABLE Channels one less than the Total Number of Channels, be in at least HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1.1 provided the other channel is OPERABLE.

ACTION 16 - Deleted.

ACTION 17 - With the number of OPERABLE Channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:

a. The inoperable channel is placed in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . b. The Minimum Channels OPERABLE requirements is met; however, the inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels per Specification 4.3.2.1.1.

ACTION 18 - With the number of OPERABLE Channels one less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the bypassed condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and the Minimum Channels OPERABLE requirement is met; one additional channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1.1.

ACTION 19 - With less than the Minimum Channels OPERABLE, operation may continue provided the containment purge supply and exhaust valves are maintained closed.

ACTION 20 - With the number of OPERABLE Channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

September 14, 2006 SEQUOYAH - UNIT 1 3/4 3-22 Amendment No. 63, 141, 168, 182, 188, 202, 207, 213, 301, 311 Page 18 of 80Table 3.3.2-1 Footnote (a) and Footnote (f) (e) Except when all MSIV's are closed.

L04Table 3.3.2-1 Footnote (g)

ACTION S ACTION D ACTION B ACTION N 72 12Add proposed Required Action D.2.1 and D.2.2 Add proposed Required Action E.2.1 and E.2.2 ACTION E ACTION P 72 for ACTION E, otherwise 612 for ACTION E, otherwise 4 See ITS 3.3.6 Add proposed Required Action P.2.1 and P.2.2 (i) Except when all MFIVs, MFRVs, and MFRV bypass valves are closed or isolated by a closed manual valve.

L05 L07 L08 M07 M08 L10 L09 M09 A16 ACTION S Note INSERT 3 A13 INSERT 5 A15 INSERT 4 A14 Insert Page 3/4 3-22 ITS ITS 3.3.2Table 3.3.2-1 INSERT 3 Above the P-11 (Pressurizer Pressure) interlock.

INSERT 4 When Steam Line Isolation, Steam Line Pressure, Negative Rate-High is blocked.

INSERT 5 When Steam Line Isolation on Steam Line Pressure, Low is blocked.

A13 A14 A15 Footnote (a) Footnote (f) Footnote (g)

Page 19 of 80 ITS ITS 3.3.2 A01TABLE 3.3-3 (Continued)

TABLE NOTATION

Trip function may be bypassed in this MODE below P

-11 (Pressurizer Pressure Block of Safety Injection) setpoint.

1. Trip function automatically blocked above P

-11 and may be blocked below P-11 when Safety Injection on Steam Line Pressure

-Low is not blocked.

ACTION STATEMENTS

ACTION 15 - With the number of OPERABLE Channels one less than the Total Number of Channels, be in HOT STANDBY within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ; however, one channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1.1 provided the other channel is OPERABLE.

ACTION 16 - Deleted.

ACTION 17 - With the number of OPERABLE Channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following conditions are satisfied:

a. The inoperable channel is placed in the tripped condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . b. The Minimum Channels OPERABLE requirements is met; however, the inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels per Specification 4.3.2.1.1.

ACTION 18 - With the number of OPERABLE Channels one less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the bypassed condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and the Minimum Channels OPERABLE requirement is met; one additional channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1.1.

ACTION 19 - With less than the Minimum Channels OPERABLE, operation may continue provided the containment purge supply and exhaust valves are maintained closed.

ACTION 20 - With the number of OPERABLE Channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

September 14, 2006 SEQUOYAH - UNIT 2 3/4 3-22 Amendment Nos. 55, 132, 158, 174, 180, 192, 197, 203, 290, 300 Page 58 of 80Table 3.3.2-1 Footnote (a) and Footnote (f) Table 3.3.2-1 Footnote (g) (j) Except when all MSIV's are closed.

L04(k) Except when all MFIVs, MFRVs, and MFRV bypass valves are closed or isolated by a closed manual valve.

L05 ACTION S ACTION D 72 12Add proposed Required Action D.2.1 and D.2.2 L07 L08 M07 ACTION E ACTION P Add proposed Required Action E.2.1 and E.2.2 M08 L10 L09 See ITS 3.3.6 ACTION B ACTION N Add proposed Required Action P.2.1 and P.2.2 M09 ACTION S Note A16 72 for ACTION E, otherwise 6 12 for ACTION E, otherwise 4 INSERT 3 A13INSERT 4 A14 INSERT 5 A15 Insert Page 3/4 3-22 ITS ITS 3.3.2Table 3.3.2-1 INSERT 3 Above the P-11 (Pressurizer Pressure) interlock.

INSERT 4 When Steam Line Isolation, Steam Line Pressure, Negative Rate-High is blocked.

INSERT 5 When Steam Line Isolation on Steam Line Pressure, Low is blocked.

Page 59 of 80 A13 A14 A15 Footnote (a) Footnote (f) Footnote (g)

DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 8 of 35 A13 CTS Table 3.3-3 Note #, in part, is associated with Functional Units 1.d (Safety Injection, Pressurizer Pressure-Low) and 1.f (Safety Injection, Steam Line Pressure-Low). CTS Table 3.3-3 Note # modifies the Functional Unit's MODE of Applicability by stating that the trip function may be bypassed in MODE 3 below P-11 (Pressurizer Pressure Block of Safety Injection) setpoint. ITS Table 3.3.2-1 footnote (a) is associated with Functions 1.d (Safety Injection, Pressurizer Pressure-Low), and 1.e (Safety Injection, Steam Line Pressure-Low). ITS Table 3.3.2-1 footnote (a) modifies the Function's Applicability by stating "Above the P-11 (Pressurizer Pressure) interlock." This changes the CTS by replacing the description of how the P-11 interlock operates and when the Functions are allowed to be bypassed, with a statement of when the Functions are required to be OPERABLE.

The purpose of CTS Table 3.3-3 Note # is to modify the Applicability for the associated Functional Units stating when it is permissible for these Functional Units to be bypassed. Note # does this by providing information on the Functional Units interaction with interlock P-11. One purpose of P-11 is to prevent an inadvertent ECCS actuation during plant heatup and cooldown by blocking portions of the safety injection and steam line isolation signal actuation logic. The pressurizer low pressure and steamline low pressure safety injection actuation signals can be manually blocked when RCS pressure is below the P-11 permissive setpoint. CTS Table 3.3-3 Note # states that these Functional Units may be bypassed when below P-11. ITS Table 3.3.2-1 footnote (a) modifies the applicability of the pressurizer low pressure and steamline low pressure safety injection Functions, stating that they are required to be OPERABLE above the P-11 (Pressurizer Pressure) interlock. Thus replacing the statements in CTS for when they may be bypassed with statements in ITS for when these Functions are required to be OPERABLE. Therefore, ITS requires these Functions to provide a signal that will actuate safety injection under the same Conditions as CTS. This change is designated as administrative because it does not result in technical changes to the CTS.

A14 CTS Table 3.3-3 Note #, in part, is associated with Functional Unit 4.d (Steam Line Isolation, Steam Line Pressure-Low). CTS Table 3.3-3 Note # modifies the Functional Unit's MODE of Applicability by stating that the trip function may be bypassed in MODE 3 below P-11 (Pressurizer Pressure Block of Safety Injection) setpoint. ITS Table 3.3.2-1 footnote (f) is associated with Function 4.d.(1) (Steam Line Isolation, Steam Line Pressure, Low). ITS Table 3.3.2-1 footnote (f) modifies the Function's applicability by stating when Steam Line Isolation on Steam Line Pressure Negative Rate-High is blocked." This changes the CTS by replacing the description of how the P-11 interlock operates and when the Function is allowed to be bypassed, with a statement of when the Function is required to be OPERABLE.

The purpose of CTS Table 3.3-3 Note # is to modify the Applicability for the associated Functional Units stating when it is permissible for this Functional Unit to be bypassed. Note # does this by providing information on the Functional Units interaction with interlock P-11. One purpose of P-11 is to prevent an inadvertent ECCS actuation during plant heatup and cooldown by blocking DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 9 of 35 portions of the steam line isolation signal actuation logic. The steam line isolation steam pressure low actuation signal can be manually blocked when RCS pressure is below the P-11 permissive setpoint. CTS Table 3.3-3 Note #

states that this Functional Unit may be bypassed when below P-11. ITS Table 3.3.2-1 footnote (a) modifies the Applicability of the Steamline Isolation, Steam Line Pressure, Low Function by stating that this Function is required to be OPERABLE when Steam Line Isolation on Steam Line Pressure Negative Rate-High is blocked. Therefore, ITS requires this Function to provide a signal that will actuate steam line isolation under the same Conditions as CTS. This change is designated as administrative because it does not result in technical changes to the CTS. A15 CTS Table 3.3-3 Note ## is associated with Functional Unit 4.e (Steam Line Isolation, Negative Steam Line Pressure Rate-High). CTS Table 3.3-3 Note ##

modifies the Functional Unit's MODE of Applicability by stating that that the trip function is automatically blocked above P-11 and that it may be blocked below P11 when Safety Injection on Steam Line Pressure-Low is not blocked. ITS Table 3.3.2-1 footnote (g) is associated with Function 4.d.(2) (Steam Line Isolation, Steam Line Pressure, Negative Rate-High). ITS Table 3.3.2-1 footnote (g) modifies the applicability of the Steam Line Isolation, Steam Line Pressure, Negative Rate-High Function by stating that this Function is required to be OPERABLE when the Steam Line Isolation on Steam Line Pressure-Low Function is blocked." This changes the CTS by replacing the description of how the P-11 interlock operates and when the Function is allowed to be blocked, with a statement of when the Function is required to be OPERABLE.

The purpose of CTS Table 3.3-3 Note ## is to modify the Applicability for the associated Functional Unit stating when it is permissible for this Functional Unit to be blocked. Note ## does this by providing information on the Functional Unit's interaction with interlock P-11. One purpose of P-11 is to prevent an inadvertent ECCS or steam line isolation actuation during plant heatup and cooldown by blocking portions of the safety injection and steam line isolation signal actuation logic. The steam line isolation Negative Steam Line Pressure Rate-High actuation signal is automatically blocked when RCS pressure is above the P-11 permissive setpoint and can be manually enabled below P-11. CTS Table 3.3-3 Note ## states that this Functional Unit's trip function is automatically blocked above P-11 and may be blocked below P-11 when Safety Injection on Steam Line Pressure-Low is not blocked. ITS Table 3.3.2-1 footnote (g) modifies the Applicability of the Steam Line Isolation, Steam Pressure, Negative Rate-High Function by stating that this Function is required to be OPERABLE when Steam Line Isolation on Steam Line Pressure-Low is blocked. Therefore, ITS requires this Function to provide a signal that will actuate steam line isolation under the same Conditions as CTS. This change is designated as administrative because it does not result in technical changes to the CTS.

A16 CTS Table 3.3-3 ACTION 20 requires that with the number of OPERABLE Channels one less than the Total Number of Channels, restore the inoperable channel to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . CTS Table 3.3-3 ACTION 20 is applicable to CTS Table 3.3-3 Functional Units ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-11 Rev. 4.0 SEQUOYAH UNIT 1 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 1 of 11) Engineered Safety Feature Actuation System Instrumentation

FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS

REQUIRED CHANNELS CONDITIONS

SURVEILLANCE REQUIREMENTS

ALLOWABLE VALUE

[NOMINAL (l) TRIP SETPOINT] 1. Safety Injection

a. Manual Initiation 1,2,3,4 2 B SR 3.3.2.

8 NA NA

b. Automatic Actuation Logic and Actuation Relays 1,2,3,4 2 trains C SR 3.3.2.2 SR 3.3.2.

4 SR 3.3.2.

6 NA NA c. Containment Pressure -

High 1 1,2,3 3 D SR 3.3.2.1 SR 3.3.2.

5 (b)(c) SR 3.3.2.

9 (b)(c) SR 3.3.2.

10 [3.86] psig [3.6] psig d. Pressurizer Pressure - Low 1,2,3 (a) [3] D SR 3.3.2.1 SR 3.3.2.

5 (b)(c) SR 3.3.2.

9 (b)(c) SR 3.3.2.

10 [1839] psig [1850] psig e. Steam Line Pressure (1) Low 1,2,3 [(a)] 3 per steam line D

SR 3.3.2.1 SR 3.3.2.

5 (b)(c) SR 3.3.2.

9 (b)(c) SR 3.3.2.

10 [635](d) psig [6 75](d) psig (2) High Differential Pressure Between Steam Lines 1,2,3 3 per steam line D

[SR 3.3.2.1] SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 [106] psig

[97] psig (a) Above the P-11 (Pressurizer Pressure) interlock.

(b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P and the methodologies used to determine the as-found and as-left tolerances are specified in

[insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].

(d) Time constants used in the lead/lag controller are t 1 [50] seconds and t 2 [5] seconds.

REVIEWER'S NOTE---------------------------------------------------------------------

(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------

- 1.6 1.54 1864.8 1870592.2 600 3.3.2.1, and ACTION 3.3.2.1, and ACTION 1.a 1.b 1.c 1.d 1.f Note # Table 3.3-3 Table 3.3-4 Note 1 7 3 5 9 9 9 4 4 8 8 4 8 4 3 3 3 3 3 2 2 2 2 3 2UFSAR Section 7.1.2 2 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-15 Rev. 4.0 SEQUOYAH UNIT 1 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 5 of 11) Engineered Safety Feature Actuation System Instrumentation

FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS

CONDITIONS

SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE [NOMINAL (l) TRIP SETPOINT] 4. Steam Line Isolation

d. Steam Line Pressure (1) Low 1,2 (j),3 (j) (a) 3 per steam lineD SR 3.3.2.1 SR 3.3.2.

5 (b)(c)SR 3.3.2.

9 (b)(c)SR3.3.2.10 [635](d) psig [675](d) psig (2) Negative Rate - High 3 (h) (j) 3 per steam lineD SR 3.3.2.1 SR 3.3.2.

5 (b)(c)SR 3.3.2.

9 (b)(c)SR 3.3.2.

10 [121.6](i) psi [110](i) psi (a) Above the P

-11 (Pressurizer Pressure) in terlock.

(b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].

(d) Time constants used in the lead/lag controller are t 1 [50] seconds and t 2 [5] seconds.

(h) Below the P

-11 (Pressurizer Pr essure) interlock.

(i) Time constant utilized in the rate/lag controller is [50] seconds.

(j) Except when all MSIVs are closed and [de-activated].

REVIEWER'S NOTE---------------------------------------------------------------------

(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used b y the unit. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------

592.2 600 107.8 100.0Table 3.3-3 4.d 4.e 3.3.2.1, and ACTION 3.3.2.1, and ACTION Table 3.3-4 Note 1 Table 3.3-4 Note 2 DOC L04 Table 3.3-3 Note ## 9 9 4 8 4 8 4 3 2 3 3 3 3 3 3 2UFSAR Section 7.1.2 2 2Note # When Steam Line Isolationon Steam Line Pressure, Low is blocked When Steam Line Isolation on Steam Line Pressure, Negative Rate-High is blocked f f e e e g h g h ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-11 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 1 of 11) Engineered Safety Feature Actuation System Instrumentation

FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS

REQUIRED CHANNELS CONDITIONS

SURVEILLANCE REQUIREMENTS

ALLOWABLE VALUE

[NOMINAL (l) TRIP SETPOINT] 1. Safety Injection

a. Manual Initiation 1,2,3,4 2 B SR 3.3.2.

8 NA NA

b. Automatic Actuation Logic and Actuation Relays 1,2,3,4 2 trains C SR 3.3.2.2 SR 3.3.2.

4 SR 3.3.2.

6 NA NA c. Containment Pressure -

High 1 1,2,3 3 D SR 3.3.2.1 SR 3.3.2.

5 (b)(c) SR 3.3.2.

9 (b)(c) SR 3.3.2.

10 [3.86] psig [3.6] psig d. Pressurizer Pressure - Low 1,2,3 (a) [3] D SR 3.3.2.1 SR 3.3.2.

5 (b)(c) SR 3.3.2.

9 (b)(c) SR 3.3.2.

10 [1839] psig [1850] psig e. Steam Line Pressure (1) Low 1,2,3 [(a)] 3 per steam line D

SR 3.3.2.1 SR 3.3.2.

5 (b)(c) SR 3.3.2.

9 (b)(c) SR 3.3.2.

10 [635](d) psig [6 75](d) psig (2) High Differential Pressure Between Steam Lines 1,2,3 3 per steam line D

[SR 3.3.2.1] SR 3.3.2.5 (b)(c) SR 3.3.2.9 (b)(c) SR 3.3.2.10 [106] psig

[97] psig (a) Above the P-11 (Pressurizer Pressure) interlock.

(b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P and the methodologies used to determine the as-found and as-left tolerances are specified in

[insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].

(d) Time constants used in the lead/lag controller are t 1 [50] seconds and t 2 [5] seconds.

REVIEWER'S NOTE---------------------------------------------------------------------

(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used by the unit. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------

- 1.6 1.54 1864.8 1870592.2 600 3.3.2.1, and ACTION 3.3.2.1, and ACTION 1.a 1.b 1.c 1.d 1.f Note # Table 3.3-3 Table 3.3-4 Note 1 7 3 5 9 9 9 4 4 8 8 4 8 4 3 3 3 3 3 2 2 2 2 3 2UFSAR Section 7.1.2 2 ESFAS Instrumentation (Without Setpoint Control Program) 3.3.2 A Westinghouse STS 3.3.2 A-15 Rev. 4.0 SEQUOYAH UNIT 2 Amendment XXX 1 2CTS 1Table 3.3.2-1 (page 5 of 11) Engineered Safety Feature Actuation System Instrumentation

FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS

CONDITIONS

SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE [NOMINAL (l) TRIP SETPOINT] 4. Steam Line Isolation

d. Steam Line Pressure (1) Low 1,2 (j),3 (j) (a) 3 per steam lineD SR 3.3.2.1 SR 3.3.2.

5 (b)(c)SR 3.3.2.

9 (b)(c)SR3.3.2.10 [635](d) psig [675](d) psig (2) Negative Rate - High 3 (h) (j) 3 per steam lineD SR 3.3.2.1 SR 3.3.2.

5 (b)(c)SR 3.3.2.

9 (b)(c)SR 3.3.2.

10 [121.6](i) psi [110](i) psi (a) Above the P

-11 (Pressurizer Pressure) in terlock.

(b) If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c) The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The NTS P and the methodologies used to determine the as-found and as-left tolerances are specified in [insert the facility FSAR reference or the name of any document incorporated into the facility FSAR by reference].

(d) Time constants used in the lead/lag controller are t 1 [50] seconds and t 2 [5] seconds.

(h) Below the P

-11 (Pressurizer Pr essure) interlock.

(i) Time constant utilized in the rate/lag controller is [50] seconds.

(j) Except when all MSIVs are closed and [de-activated].

REVIEWER'S NOTE---------------------------------------------------------------------

(l) Unit specific implementations may contain only Allowable Value depending on Setpoint Study methodology used b y the unit. ------------------------------------------------------------------------------------------------------------------------------------------------------------------------

592.2 600 107.8 100.0Table 3.3-3 4.d 4.e 3.3.2.1, and ACTION 3.3.2.1, and ACTION Table 3.3-4 Note 1 Table 3.3-4 Note 2 DOC L04 Table 3.3-3 Note ## 9 9 4 8 4 8 4 3 2 3 3 3 3 3 3 2UFSAR Section 7.1.2 2 2Note # When Steam Line Isolationon Steam Line Pressure, Low is blocked When Steam Line Isolation on Steam Line Pressure, Negative Rate-High is blocked f f e e e g h g h Licensee Response/NRC Response/NRC Question Closure Id106NRC Question Number KAB024Select Application NRC Question ClosureAttachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.Question Closure Date 6/6/2014Notification Scott BowmanMichelle ConnerKhadijah HemphillAndrew HonLynn MynattRay SchieleRoger ScottAdded By Kristy Bucholtz Date Added 6/6/2014 10:05 AMDate Modified Modified By Page 1of 1 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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ITS NRC Questions Id 48NRC Question Number KAB025Category Editorial ITS Section 3.3ITS Number 3.3.2DOC Number L-8JFD Number JFD Bases Number Page Number(s) 440NRC Reviewer Supervisor Rob ElliottTechnical Branch POC Add NameConf Call Requested NNRC Question On page 440 of Enclosure 2, Volume 8, L08 provides the discussion of the requirements for bypassing inoperable channels during surveillance testing as stated in CTS Table 3.3-3 ACTION 17. In the discussion, some of the numerical references are intermixed in such a way that they should reference the CTS numerical functional units and instead they reference the ITS numerical functions, and vice versa. For example, L08 states, "This allowance is applicable to CT S Table 3.3-3 Functional Units -:1.e (Steam Line Pressure -

Low); 4.d.(1) (Steam Line Pressure-Low); 4.d.(2) (Negative Steam Line Pressure Rate-High)-,"this sentence should list the CTS numbers for the functional units but instead lists the numbers for the same functions in ITS. Please review L08 and submit the needed corrections, or explain why intermixing the numerical identifiers is correct.Attach File 1 Attach File 2 Issue Date 5/9/2014 Added By Kristy BucholtzDate Modified Modified By Date Added 5/9/2014 8:50 AMNotification Scott BowmanMichelle Conner Andrew HonLynn MynattRay Schiele Roger ScottPage 1of 1 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

p h p?re q uestT yp e=areaItemPrint&itemId=48 Licensee Response/NRC Response/NRC Question Closure Id 65NRC Question Number KAB025 Select Application Licensee Response Attachment 1 Attachment 1 revised 3.3.2 DOC L08.pdf (16KB)Attachment 2 Response Statement In response to KAB025, discussion of change (DOC) L08, on page 440 of Enclosure 2, Volume 8, will be revised.Specifically, CTS Table 3.3-3 references to Functional Units 1.e, 4.d.(1), and 4.d.(2) will be revised to 1.f, 4.d, and 4.e, respectively.ITS Table 3.3.2-1 references to Functional Units 1.f, 4.d, 4.e, and 5.a will be revised to 1.e, 4.d.(1), 4.d.(2), and 5.b, respectively.

See Attachment 1 for the draft revised DOC L08.Response Date/Time 5/29/2014 1:30 PMClosure Statement Question Closure Date Notification Scott BowmanKristy BucholtzMichelle ConnerKhadijah HemphillAndrew HonRay Schiele Added By Scott Bowman Date Added 5/29/2014 12:25 PMDate Modified Modified By Page 1of 1 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 29 of 35 designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

L08 (Category 9 - Allowed Outage Time, Surveillance Frequency, and Bypass Time Extensions Based on Generic Topical Reports) CTS Table 3.3-3 ACTION 17 allows in part that with the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and/or POWER OPERATION may proceed provided the following listed conditions are satisfied but further states that the inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels per Specification 4.3.2.1.1. This allowance is applicable to CTS Table 3.3-3 Functional Units 1.c (Containment Pressure - High); 1.d (Pressurizer Pressure - Low); 1.e (Steam Line Pressure - Low); 4.d.(1) (Steam Line Pressure - Low); 4.d.(2) (Negative Steam Line Pressure Rate - High); and 5.a (Steam Generator Water Level - High-High). ITS 3.3.2 ACTION D Required Actions are modified by a Note that states; "The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels." This allowance is applicable to ITS Table 3.3.2-1 Functional Units 1.c (Containment Pressure - High); 1.d (Pressurizer Pressure - Low); 1.f (Steam Line Pressure -

Low); 4.d (Steam Line Pressure - Low); 4.e (Negative Steam Line Pressure Rate

- High); and 5.a (Steam Generator Water Level - High-High). This changes the CTS by increasing the time allowed for these functions to be bypassed from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

The purpose of CTS Table 3.3-3 ACTION 17 is to limit the maximum time allowed for maintenance activities, in which the channel is unavailable or prior to being placed in a tripped state. The proposed bypass time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in ITS 3.3.2 ACTION D is a sufficient time to perform train or channel surveillance. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period is acceptable based on TVA's confirmation of applicability and incorporation of insights as described in Enclosure 4 of this submittal, required by the NRC in their letter and enclosed Safety Evaluation Report (SER) dated July 15, 1998, "Review of Westinghouse Owners Group Topical Reports WCAP-14333-P and WCAP-14334-NP, dated May 1995, 'Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times' (TAC NO. M92782)." This change is designated as less restrictive because additional time is allowed for an inoperable channel to be bypassed for maintenance than was allowed in

the CTS. L09 (Category 9 - Allowed Outage Time, Surveillance Frequency, and Bypass Time Extensions Based on Generic Topical Reports) CTS Table 3.3-3 ACTION 18, requires, in part, that with the number of OPERABLE channels one less than the Total Number of Channels, operation may proceed provided the inoperable channel is placed in the bypassed condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . This action is applicable to CTS Table 3.3-3 Functional Units 2.c (Containment Pressure -- High-High); 3.b.3) (Containment Pressure -- High-High); 4.c (Containment Pressure -- High-High); 9.a (RWST Level - Low); and 9.a (Containment Sump Level - High). ITS Table 3.3.2-1 designates Condition E as the referenced Condition for Functions 2.c (Containment Pressure -- High-High), 3.b.(3)

(Containment Pressure -- High-High), and 4.c (Containment Pressure -- High-High) while designating Condition P as the referenced Condition for Functions 7.b (RWST Level - Low) and 7.b (Containment Sump Level - High). ITS 3.3.2, Licensee Response/NRC Response/NRC Question Closure Id 79NRC Question Number KAB025Select Application NRC Question ClosureAttachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.Question Closure Date 5/30/2014Notification Scott BowmanMichelle ConnerKhadijah HemphillAndrew HonLynn MynattRay SchieleRoger ScottAdded By Kristy Bucholtz Date Added 5/30/2014 8:38 AMDate Modified Modified By Page 1of 1 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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ITS NRC Questions Id 49NRC Question Number KAB026Category Technical ITS Section 3.3 ITS Number 3.3.2 DOC Number L-10JFD Number JFD Bases Number Page Number(s) 441NRC Reviewer Supervisor Rob ElliottTechnical Branch POC Add Name Conf Call Requested NNRC Question On page 441 of Enclosure 2, Volume 8, L10 provides the discussion of the requirements for bypassing in operable channels during surveillance testing as stated in CTS Table 3.3-3 ACTION 18.

L10 states:

ITS 3.3.2 ACTIONS E Required Ac tions are modified by a Note that states; "The inoper able channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels."This allowance is applicable to ITS Table 3.3.2-1 Functional Units-and 7.b (RWST Level -Low).ITS 3.3.2 Required Action Note retains the CTS inoperable channel bypass allowance of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance

testing of other channels.

The note modifying ITS 3.3.2 Required Actions for Condition E is not quoted correctly.The note in ITS 3.3.2 Required Actions for Condition E is not applicable to function 7.b (RWST Level -Low).The last se ntence of the quote above is confusing because the note in ITS 3.3.2 Required Actions for Condition E has an allowance is 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Please (1) correct quote of the note modifying ITS 3.3.2 Required Actions for Condition E, (2) remove function 7.b from the discussion of ITS Condition E or revise the sentence Page 1of 2 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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to include discussion of ITS Condition P, and (3) explain the meaning of the last sentence.Attach File 1 Attach File 2 Issue Date 5/9/2014Added By Kristy BucholtzDate Modified Modified By Date Added 5/9/2014 8:52 AMNotification Scott BowmanMichelle ConnerAndrew HonLynn MynattRay SchieleRoger ScottPage 2of 2 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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Licensee Response/NRC Response/NRC Question Closure Id 97 NRC Question Number KAB026Select Application Licensee Response Attachment 1 Attachment 1 3.3.2 revised DOC L10.pdf (17KB)Attachment 2 Response Statement In response to KAB026, discussion of change (DOC) L10, on page 441 of Enclosure 2, Volume 8, will be revised.The following changes will be made:(1)The ITS 3.3.2 ACTION S E Required Actions Note will be revised to state, "One additional channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels."(2)ITS function 7.b (RWST Level -Low) will be removed from the discussion concerning the applicatio n of ITS 3.3.2 ACTIONS E Required Actions Note.(3)The sentence, "ITS 3.3.2 Required Action Note retains the CTS inoperable channel bypass allowance of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels."will be revised to state, "ITS 3.3.2 ACTIONS P Required Action Note retains the CTS one additional channel bypass allowance of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels."This sentence is included in DOC L10 to indicate th at CTS ACTION 18 becomes ITS ACTIONS E and P, and although ITS ACTIONS E is increasing the time allowed for an additional channel to be bypassed (4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months s to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ); ITS ACTIONS P retains the CTS allowance time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .(4)The sentence, "This changes the CTS by incr easing the time allowed for an additional channel to be bypassed for these Functional Units from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ."will be revised to state, "This cha nges the CTS by increasing the time allowed for an additional channel to be bypassed for Functional Units 2.c, 3.b.(3), and 4.c, from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ."This sentence will be revised to indicate that the change to CTS, increasing the time allowed for an additional channel to be bypassed, is only applicable to Functional Units 2.c, 3.b.(3), and 4.c.

See Attachment 1 for the draft revised DOC L10.Response Date/Time 6/5/2014 4:20 PMClosure Statement Page 1of 2 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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Question Closure Date Notification Scott BowmanKristy BucholtzMichelle Conner Khadijah HemphillAndrew HonRay Schiele Added By Scott Bowman Date Added 6/5/2014 3:16 PMDate Modified Modified By Page 2of 2 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 30 of 35 Required Actions E.1 requires placing the associated channel in bypass with a Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for ITS Table 3.3.2-1 Functions 2.c (Containment Pressure -- High-High), 3.b.(3) (Containment Pressure -- High-High), and 4.c (Containment Pressure -- High-High). ITS 3.3.2 Required Action P.1 retains the CTS Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for placing the associated inoperable channel in bypass. This changes the CTS by increasing the Completion Time for placing an inoperable channel in bypass for these Functional Units from six (6) hours to 72

hours.

The purpose of CTS Table 3.3-3 ACTION 18 is to limit the maximum time allowed for maintenance activities, in which the channel is unavailable or prior to being placed in a bypassed state. This change is acceptable because the Completion Time is consistent with safe operation under the specified Condition, considering the OPERABLE status of the redundant systems or features. This includes the capacity and capability of remaining systems or features, a reasonable time for repairs or replacement, and the low probability of a DBA occurring during the allowed Completion Time. Additionally, this change is acceptable based on TVA's confirmation of applicability and incorporation of insights as described in Enclosure 4 of this submittal, required by the NRC in their letter and enclosed Safety Evaluation Report (SER) dated July 15, 1998, "Review of Westinghouse Owners Group Topical Reports WCAP-14333-P and WCAP-14334-NP, dated May 1995, 'Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times' (TAC NO. M92782)." This change is designated as less restrictive because additional time is allowed to restore parameters to within the LCO limits than was allowed in the CTS.

L10 (Category 9 - Allowed Outage Time, Surveillance Frequency, and Bypass Time Extensions Based on Generic Topical Reports) CTS Table 3.3-3 ACTION 18 requires, in part, that with the number of OPERABLE channels one less than the Total Number of Channels operation may proceed provide the specified conditions are met but further states that one additional channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing per Specification 4.3.2.1.1. This allowance is applicable to CTS Table 3.3-3 Functional Units 2.c (Containment Pressure - High-High); 3.b.3) (Containment Pressure - High-High); 4.c (Containment Pressure - High-High); 9.a (RWST Level - Low); and 9.a (Containment Sump Level - High). ITS Table 3.3.2-1 designates Condition E as the referenced Condition for Functions 2.c (Containment Pressure -- High-High), 3.b.(3) (Containment Pressure -- High-High), and 4.c (Containment Pressure -- High-High) while designating Condition P as the referenced Condition for Functions 7.b (RWST Level - Low) and 7.b (Containment Sump Level - High). ITS 3.3.2 ACTIONS E Required Actions are modified by a Note that states; "The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels." This allowance is applicable to ITS Table 3.3.2-1 Functional Units 2.c (Containment Pressure - High-High); 3.b.3) (Containment Pressure - High-High); 4.c (Containment Pressure - High-High);

and 7.b (RWST Level - Low). ITS 3.3.2 Required Action Note retains the CTS

inoperable channel bypass allowance of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels. This changes the CTS by increasing the time allowed for an additional channel to be bypassed for these Functional Units from 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Licensee Response/NRC Response/NRC Question Closure Id107NRC Question Number KAB026Select Application NRC Question ClosureAttachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.Question Closure Date 6/6/2014Notification Scott BowmanMichelle ConnerKhadijah HemphillAndrew HonLynn MynattRay SchieleRoger ScottAdded By Kristy Bucholtz Date Added 6/6/2014 10:06 AMDate Modified Modified By Page 1of 1 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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ITS NRC Questions Id 50NRC Question Number KAB027 Category Editorial ITS Section 3.3 ITS Number 3.3.2DOC Number L-11JFD Number JFD Bases Number Page Number(s) 442NRC Reviewer Supervisor Rob ElliottTechnical Branch POC Add Name Conf Call Requested NNRC Question On page 442 of Enclosure 2, Volume 8, L 11 provides the discussion of CTS Table 3.3-3 ACTION 23. CTS ACTION 23 is co mpared to ITS 3.3.2 Condition H.

However, in the last paragraph it discu sses ITS 3.3.2 Condition G. Please provide a revised L11 that discusses the approp riate ITS 3.3.2 Condition or explain why both ITS Conditions are correct.Attach File 1 Attach File 2 Issue Date 5/9/2014Added By Kristy BucholtzDate Modified Modified By Date Added 5/9/2014 8:54 AMNotification Scott BowmanMichelle ConnerAndrew HonLynn Mynatt Ray SchieleRoger ScottPage 1of 1 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

p h p?re q uestT yp e=areaItemPrint&itemId=50 Licensee Response/NRC Response/NRC Question Closure Id 64NRC Question Number KAB027Select Application Licensee Response Attachment 1 revised 3.3.2 DOC L11.pdf (13KB)Attachment 2 Response Statement In response to KAB027, discussion of change (DOC) L11, on page 442 of , Volume 8, will be revised.Specificall y, the reference to ITS 3.3.2 ACTION G will be revised to referen ce ITS 3.3.2 ACTION H.See Attachment 1 for th e draft revised DOC L11.Response Date/Time 5/29/2014 12:45 PM Closure Statement Question Closure Date Notification Scott BowmanKristy BucholtzMichelle ConnerKhadijah HemphillAndrew HonRay SchieleAdded By Scott Bowman Date Added 5/29/2014 11:41 AMDate Modified Modified By Page 1of 1 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 31 of 35 The purpose of CTS Table 3.3-3 ACTION 18 is to limit the maximum time allowed for maintenance activities, in which the channel is unavailable or prior to being placed in a bypassed state. The proposed bypass time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months in ITS 3.3.2 ACTION E is a sufficient time to perform train or channel surveillance. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months period is acceptable based on TVA's confirmation of applicability and incorporation of insights as described in Enclosure 4 of this submittal, required by the NRC in their letter and enclosed Safety Evaluation Report (SER) dated July 15, 1998, "Review of Westinghouse Owners Group Topical Reports WCAP-14333-P and WCAP-14334-NP, dated May 1995, 'Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times' (TAC NO. M92782)." This change is designated as less restrictive because additional time is allowed for an inoperable channel to be bypassed for maintenance than was allowed in

the CTS.

L11 (Category 9 - Allowed Outage Time, Surveillance Frequency, and Bypass Time Extensions Based on Generic Topical Reports)

CTS Table 3.3-3, ACTION 23 for Functional Units 4.b (Steam Line Isolation, Automatic Actuation Logic), 5.b (Turbine Trip & Feedwater Isolation, Automatic Actuation Logic), and 6.b (Auxiliary Feedwater, Automatic Actuation Logic) states, "With the number of OPERABLE channels one less than the Total Number of Channels, be in at least HOT STANDBY within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ; however, one channel may be bypassed for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for surveillance testing per Specification 4.3.2.1.1." ITS 3.3.2, ACTION H for Functions 4.b (Steam Line Isolation, Automatic Actuation Logic and Actuation Relays), 5.a (Turbine Trip & Feedwater Isolation, Automatic Actuation Logic and Actuation Relays), and 6.a (Auxiliary Feedwater, Automatic Actuation Logic and Actuation Relays) requires restoration of the inoperable train to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or be in MODE 3 within 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months and MODE 4 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months ; and is modified by a Note stating, "One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE." This changes the CTS by allowing 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for train maintenance to restore the train to an OPERABLE status before requiring a power reduction to MODE 3 within an additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 in additional 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for an inoperable Steam Line Isolation, Automatic Actuation Logic, Turbine Trip & Feedwater Isolation, Automatic Actuation Logic, or Auxiliary Feedwater, Automatic Actuation Logic, plus increasing the allowed time a train can be bypassed for surveillance testing from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

The purpose of CTS Table 3.3-3, ACTION 23 is to allow some time to restore the inoperable train before requiring a unit shut down. ITS LCO 3.3.2 ACTION G allows 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to restore the train to an OPERABLE status and the Required Actions Note allows placing one train in the bypassed condition for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months while performing routine surveillance testing provided the other train is OPERABLE. These changes are acceptable and are the result of WCAP-14333-P-A, Revision 1 ("Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times"), dated October 1998, or WCAP-15376-P-A, Revision 1 ("Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times"), dated March 2003 (or a combination of the WCAPs). TVA has performed evaluations of the applicable changes associated with the two Licensee Response/NRC Response/NRC Question Closure Id 80NRC Question Number KAB027Select Application NRC Question ClosureAttachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.Question Closure Date 5/30/2014Notification Scott BowmanMichelle ConnerKhadijah HemphillAndrew HonLynn MynattRay SchieleRoger ScottAdded By Kristy Bucholtz Date Added 5/30/2014 8:39 AMDate Modified Modified By Page 1of 1 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

p h p?re q uestT yp e=areaItemPrint&itemId=80 ITS NRC Questions Id 51NRC Question Number KAB028Category TechnicalITS Section 3.3ITS Number 3.3.2DOC Number L-12JFD Number JFD Bases Number Page Number(s) 443NRC Reviewer Supervisor Rob ElliottTechnical Branch POC Add Name Conf Call Requested NNRC Question On page 443 of Enclosure 2, Volume 8, L12 provides the discussion of the proposed change that adds required action k.2, whic h allows placing the affected protection set, steam generator water level low low channel in trip within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . L12 states, "Once the channel is placed in the tripped condition the RCS T TTD circuitry is removed from the active portion of the Steam Generator Low-Low Level channel, reference UFSAR Figure 7.2.1-1, Sheets 17 thro ugh 20 and this action is no longer necessary."Please explain how placing the steam generator low-low level channel in trip, removes the RCS T TTD circuitry. In additi on, explain how placing the steam generator low low level channel in trip will not affect the TTD circuitry for the other operable SG water level low low channels.Attach File 1 Attach File 2 Issue Date 5/9/2014Added By Kristy BucholtzDate Modified Modified By Date Added 5/9/2014 8:55 AMNotification Scott BowmanMichelle ConnerAndrew Hon Lynn MynattRay SchieleRoger ScottPage 1of 1 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

p h p?re q uestT yp e=areaItemPrint&itemId=51 Licensee Response/NRC Response/NRC Question Closure Id 66 NRC Question Number KAB028Select Application Licensee ResponseAttachment 1 Attachment 1 UFSAR and Training Documents for KAB028.pdf (840KB)Attachment 2 Attachment 2 ITS DOC L12 Markup for KAB028.pdf (1MB)Response Statement Placing the Steam Generator Water Level Low-Low Channel in trip does not literally remove the RCS T TTD circuitry from th e active portion of the circuitry, as stated in discussion of change (DOC) L12. In the signal flow path for the Steam Generator Low-Low Level Channel trip, the manual trip is downstream of the RCS T TTD input into the Ea gle 21 System, thereby negating the RCS T TTD effect on the tr ip circuit. The RCS T TTD input remains in the circuit, but with the manual tr ip in place, the RCS T TTD has no effect on the circuit.Therefore, DOC L12 will be revised to replace the sentence, "Once the channel is placed in the tripped condition the RCS T TTD circuitry is removed from the active portion of the Steam Generator Low-Low Level channel, reference UFSAR Figure 7.2.1-1, Sheets 17 through 20 and this action is no longer necessary,"with, "Once the channel is placed in the trippe d condition, the RCS T TTD input has no effect on the circuit, and this action is no longer necessary."Because of the location of the ma nual Steam Generato r Low-Low Level Channel Trip in the circuitry, there is no impact on the RCS T TTD setpoint selection for the other opera ble Steam Generator Low-Low Level channels.Each RCS T TTD channel only impacts Steam Generator Low-Low Level Channels from the same Protection Set channel. contains UFSAR Figure 7.2.1-1, Sheet 19 and 20 along with the Operations training material associated with the Eagle 21 System.The UFSAR figures depict the logic for Auxiliary Feedwater Start and are annotated to show where the manual trip would impact the circuit.It also shows that an RCS T TTD channel only impacts the associated level channels. The Eagle 21 material illustrates the location of the manual trip within the Eagle 21 System.See Attachment 2 for a draft ITS DOC L12 markup.Response Date/Time 5/29/2014 3:30 PM Closure Statement Question Closure Date Page 1of 2 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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Notification Scott BowmanKristy BucholtzMichelle ConnerKhadijah HemphillAndrew HonRay SchieleAdded By Scott Bowman Date Added 5/29/2014 2:27 PMDate Modified Modified By Page 2of 2 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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Eagle 21 OverviewBlock diagram The block diagram of an Eagle 21 channel is shown below. Only one channel is shown, other channels are similar. Tester SubsystemOutputSubsystemPowerSupply&DistributionSubsystemCabinetDiagnostics118 VAC(Non-Vital)EPT(1 TO 7)EAO(1 TO 4)ECO(1 OR 2)MMI SubsystemTouch ScreenDLHMMIPiSCB286/12KeyboardMULTIBUS DDCiSBC519H.P. DACDT-716D(2)TSP iSBC286/12 DLHiSBC88/45FRONT TEST PANELMULTIBUSI/OSubsystemDFP iSBC88/40A(1 or 2)LCP iSBC286/12DLHiSCB88/45MULTIBUSERI(1 TO 8)EAI(1 TO 8)MULT/15PWR SUPLoopProcessorSubsystem+15v+12v+5v-12v+15v+12v+5v-12v118v ACAs many as 16 input/DFP15/MULTPWR SUP118v AC(VITAL)SECISPC 286/12 toFOC+15v RelayRear TestPanelBBC DACMP8316-V(1 or 2)Transmitter orContact Closure RTD orNISRack1, 3, 4, 5, 7,8, 9, 11, 12XHP(0-7)A B+15v A+15v B+15vRelayDaughterBoard+15v A+15v B118v AC DDCiSCB519Control andIndication MCRAnnunciatorsandTest SignalsTrain ATrain BSolid StateProtection SystemField SideField SideSIRBUSSIRBUSSIRBUSPrinterEAGLE 21Block Diagram(Typical of each cabinet)

Loop Processor Subsystem The Loop Processor Subsystem performs the following major functions: Converts analog inputs to numerical representations. Automatically calibrates the input signals and corrects for differences. Provides dynamic compensation (like OPT, OPT calculations) Provides algebraic calculations (Tavg). Compares inputs to trip setpoint values and provides a trip signal to the partial trip bistable (maintains reactor trip setpoints in memory for comparison). Provides analog outputs for indication and control. Provides data to Tester Subsystem.

Eagle 21 Loop Processor SubsystemFunctional diagram of LCP The functional diagram for a typical LCP is shown below. SUMCalc IERIDFPERI DFPERIDFPFilterFilterFilterAverage TcAverage ThTh StreamingTavgTCalc OTTSetpointT TripSummer DDC DDCEPTEPT DAC DACEAOEAOTurbineRunbackCtrl BoardMeterCtrl BoardMeter DACEAOCtrl BoardMeterT TripBistableT RnBkBistableLo TavgBistable DDC EPTFeedwaterIsolationLo-Lo TavgBistableDDC EPTP-12Hot Leg RTDsCold Leg RTDsPzr PressurePwr RangeNeutron FluxLowerUpperCalculatesStreamingEffectsComputerSoftwareFunctionTo OtherRacksRng ChkRng ChkRng Chk 1 2 3 4 5 6 7 8 9LoopCalculationProcessor TE TE TE EAIDFPERIDFPERI DFPFilterFilterRng ChkRng ChkRng Chk TE TE PTERIDFPRng ChkERI DFPRng Chk Eagle-08 Output SubsystemDescription The Output Subsystem consists of three types of output cards: EPT - Eagle Partial Trip board. Th is board provides 118 VAC output to SSPS except for 21 channel receive 118V AC from SSPS. EAO - Eagle Analog Output board. This board provides isolation from and out to the Foxbro control and indications racks. ECO - Eagle Contact Output board. This board provides outputs from the testersysystem.Diagram of EPT board Each EPT board has four EPT circuits. The purpose of the Eagle Partial Trip Boards (EPT) is to: control the 118 VAC to the SSPS input relays. allow the tester subsystem to remotely place any or all of the four channels in a trip or bypass state. allow personnel to manually place any channel in a trip condition. supply channel status information to the tester subsystem and provide local indication of the output state of each channel The EPT circuit is described below. MicroControllerBufferOptoIsolatorDeadmanTimer 2StatusDetect 1StatusDetect 2BoardPowerSupply+8V-8V+15V+5V V Ref15V A15V BCommonPulledCard118 V ACLineNeutTo OtherChannelsOptoIsolatorStatusDetector ToSSPSInputRelaysswcSW5 SSROptoIsolatorSW4ManualTripTrickle0.25 MAMain17 MASW2TesterPartialTripSW1AttemptPartial Trip1 SEC120 MSEC SW3BypassTrip Channel

+5VDeadmanTimer 1 RTesterSubsystem5 VDC PulseTrain fromLCP/DDCCurrent SuppliesLED 3 5 4 2 1 R G The current flow to maintain SW5 energized flows in a loop as follows: the main current supply which prov ides the power to maintain SW5 energized, through Manual Trip switch SW4 wh ich is used to manually trip the channel, to Attempt Partial Trip switch SW 1 which is the automatic trip signal from the LCP/DDC for the channel, DISCUSSION OF CHANGES ITS 3.3.2, ENGINEERED SAFETY FEATURE ACTUATION SYSTEM (ESFAS) INSTRUMENTATION Sequoyah Unit 1 and Unit 2 Page 32 of 35 WCAPs to justify the above changes. The evaluations supporting these changes are provided in Enclosure 4 of this submittal. This change is designated as less restrictive because more time is allowed in the ITS for the maintenance and testing of trains than was allowed in the CTS.

L12 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 ACTION 37 requires that with the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and POWER OPERATION may proceed provided that within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , for the affected protection set, the Trip Time Delays (T S and T M) threshold power level for zero seconds time delay is adjusted to 0% RTP. This action is applicable to CTS Functional Unit 6.c.i.c (Auxiliary Feedwater, Main Stm. Gen Water Level - Low-Low, Start Motor-Driven Pumps, RCS Loop T) and Functional Unit 6.c.ii.c (Auxiliary Feedwater, Main Stm. Gen Water Level - Low-Low, Start Turbine-Driven Pump, RCS Loop T). ITS 3.3.2 Required Action K.2 allows an alternative of placing the Steam Generator Water Level -- Low-Low channel in trip instead of adjusting the Trip Time Delays (T S and T M) threshold power level for zero seconds time delay to 0% RTP with the same Completion Time. This changes the CTS by adding an alternative to adjusting the TTD threshold power level for zero seconds.

The purpose of CTS Table 3.3-3 ACTION 37 is to limit the maximum time allowed for maintenance activities, in which the channel is unavailable prior to adjusting the affected protection sets Trip Time Delays (T S and T M) threshold power level for zero seconds time delay to 0% RTP. With the trip time delay adjusted to zero seconds the additional operational margin that allows the operator time to recover SG Water level is removed and the associated SG Water level channel is returned to OPERABLE. If the threshold power level for zero seconds time delay is not adjusted from 50% RTP to 0% RTP within the specified Completion Time this proposed change allows placing the affected protection set's SG Water Level Low-Low channels in the tripped condition.

Once the channel is placed in the tripped condition the RCS T TTD circuitry is removed from the active portion of the Steam Generator Low-Low Level channel, reference UFSAR Figure 7.2.1-1, Sheets 17 through 20 and this action is no longer necessary. The action of tripping the channel provides the protection sets input to the 2/3 logic gates located on UFSAR Figure 7.2.1-1 Sheet 19. The ITS Required Action K.2 Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is consistent with CTS TABLE 3.3-3 ACTION 37 and the proposed ITS Required Action K.1. This change is designated as less restrictive because less stringent Required Actions are being applied in ITS than were applied in CTS.

L13 (Category 4 - Relaxation of Required Action) CTS Table 3.3-3 ACTION 38 requires that with the number of OPERABLE channels one less than the Total Number of Channels, STARTUP and POWER OPERATION may proceed provided that within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , for the affected protection set, the Steam Generator Water Level -Low-Low (EAM) channels trip setpoint is adjusted to the same value as Steam Generator Water Level - Low-Low (Adverse). This action is applicable to CTS Functional Unit 6.c.i.d (Auxiliary Feedwater, Main Stm. Gen Water Level - Low-Low, Start Motor-Driven Pumps, Containment Pressure (EAM)) and Functional Unit 6.c.ii.d (Auxiliary Feedwater, Main Stm. Gen Water Level - Low-Low, Start Turbine-Driven Pump, Containment Pressure (EAM)).

Licensee Response/NRC Response/NRC Question Closure Id 81NRC Question Number KAB028Select Application NRC Question ClosureAttachment 1 Attachment 2 Response Statement Response Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.Question Closure Date 5/30/2014Notification Scott BowmanMichelle ConnerKhadijah HemphillAndrew HonLynn MynattRay SchieleRoger ScottAdded By Kristy Bucholtz Date Added 5/30/2014 8:39 AMDate Modified Modified By Page 1of 1 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

p h p?re q uestT yp e=areaItemPrint&itemId=81 ITS NRC Questions Id 52 NRC Question Number KAB029Category TechnicalITS Section 3.3ITS Number 3.3.2DOC Number L-13JFD Number JFD Bases Number Page Number(s) 443 NRC Reviewer Supervisor Rob ElliottTechnical Branch POC Add Name Conf Call Requested N NRC Question On page 443 of Enclosure 2, Volume 8, L13 provides the discussion of the proposed change that adds required action j.2, which allows placing the affected protection set, steam generator water level Low-low channel(s) in trip within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . L13 states, "Once the channel is placed in the tripped condition the Steam Generator Water Level --Low-Low EAM/Adverse circuitry is removed from the active portion of the Steam Generator Water Level --Low-Low channel, reference UFSAR Fi gure 7.2.1-1, Sheets 17 through 20, and these actions are no longer necessary."Please explain how placing the steam generator low low level channel in trip, removes the Steam Generator Low-Low EAM/Adverse circuitry.

In addition, explain how placing the steam generator low low level channel in trip will not affect the EAM setpoint selection for the other operable SG water level low low channels.Attach File 1 Attach File 2 Issue Date 5/9/2014Added By Kristy Bucholtz Date Modified Modified By Date Added 5/9/2014 8:56 AMNotification Scott BowmanMichelle Conner Andrew HonLynn Mynatt Ray Schiele

Roger ScottPage 1of 1 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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Licensee Response/NRC Response/NRC Question Closure Id 67NRC Question Number KAB029 Select Application Licensee ResponseAttachment 1 Attachment 1 UFSAR and Training Documents for KAB029.pdf (362KB)Attachment 2 Attachment 2 ITS DOC L13 Markup for KAB029.pdf (926KB)Response Statement Placing the Steam Generator Low-Low Level Channel in trip does not literally remove the EAM/Adverse circuitry from the active portion of the circuitry, as stated in the discussion of change (DOC) L13. In the signal flow path for the Steam Generator Lo w-Low Level Channel trip, the manual trip is downstream of th e EAM/Adverse input into the Eagle 21 System, thereby negating the EAM/Adverse effect on the trip circuit. The EAM/Adverse input remains in the circuit, but with the manual trip in place, the EAM/Adverse has no effect on the circuit.Therefore, DOC L13 will be revised to replace the sentence, "Once the channel is placed in the tripped condition the Steam Generator Water Level Low-Low EAM/Adverse circuitry is removed from the active portion of the Steam Generator Water Level Low-Low channel, reference UFSA R Figure 7.2.1-1, Sheets 17 through 20 and these actions are no longer necessary,"with, "Once the channel is placed in the tripped condition, the EAM/Adverse input has no effect on the circuit, and these actions are no longer necessary."

Because of the location of the manual Steam Generator Low-Low Level Channel Trip in the circuitry, ther e is no impact on the EAM setpoint selection for the other operable Steam Generator water level low-low channels.Each EAM channel only impacts Steam Generator Level Channels from the same Protection Set channel. contains UFSAR Figure 7.2.1-1, Sh eet 19 and 20 along with the Operations training material associated with the Eagle 21 System.The UFSAR figures depict the logic for Auxiliary Feedwater Start and are annotated to show where the manual trip would impact the circuit.It also shows that an EAM channel only impacts the associated level channels. The Eagle 21 material illu strates the location of the manual trip within the Eagle 21 System.See Attachment 2 for a draft ITS DOC L13 markup.Response Date/Time 5/29/2014 3:30 PM Closure Statement Question Closure Page 1of 2 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.

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Date Notification Scott BowmanKristy BucholtzMichelle ConnerKhadijah HemphillAndrew HonLynn MynattRay SchieleAdded By Scott Bowman Date Added 5/29/2014 2:29 PMDate Modified Modified By Page 2of 2 Sequoyah ITS Conversion Databas e 8/20/201 4htt p s://members.excelservices.com/rai/index.