ML24282A672
| ML24282A672 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 10/08/2024 |
| From: | Michael Mahoney NRC/NRR/DORL/LPL2-2 |
| To: | Mack J Florida Power & Light Co |
| References | |
| L-2023-LLA-0161 | |
| Download: ML24282A672 (12) | |
Text
From:
Michael Mahoney Sent:
Tuesday, October 8, 2024 7:39 AM To:
Mack, Jarrett Cc:
Subject:
Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Request for Additional Information - Transition to 24-Month Fuel Cycles (L-2023-LLA-0161)
Attachments:
RAIs (EICB) - Turkey Point 24-Month Fuel Cycle LAR (L-2023-LLA-0161).docx Hi Jarrett, By letter L-2023-078, dated November 15, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession Package No. ML23320A028), as supplemented by letter dated February 9, 2024 (ML24040A189), Florida Power and Light Company (FPL, the licensee) submitted a license amendment request (LAR) to for the Turkey Point Nuclear Generating Unit Nos. 3 and 4 (Turkey Point). The LAR proposes to revise the Turkey Point licensing basis by incorporating advanced fuel features (e.g., AXIOM cladding, ADOPT' fuel pellets, and a PRIME' fuel skeleton), extending Technical Specification (TS) surveillance intervals, modifying TS Allowable Values (AVs) and a Trip Setpoint, and conforming changes to the Updated Final Safety Analysis Report to facilitate a transition to 24-month fuel cycles.
The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing your submittal and has identified areas where additional information is needed to complete its review. Attached are the NRC staffs request for additional information (RAIs) from the Instrumentation and Controls Branch (EICB).
As discussed, response to the attached RAIs is requested no later than 30 business days from todays date.
The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me.
Once this email is added to ADAMS, I will provide the accession number.
Thanks Mike Mahoney Project Manager, LPL2-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Desk: (301)-415-3867 Mobile: (301)-250-0450 Email: Michael.Mahoney@nrc.gov
Hearing Identifier:
NRR_DRMA Email Number:
2617 Mail Envelope Properties (SA1PR09MB94866D8D786FDD20FA71E24EE57E2)
Subject:
Turkey Point Nuclear Generating Unit Nos. 3 and 4 - Request for Additional Information - Transition to 24-Month Fuel Cycles (L-2023-LLA-0161)
Sent Date:
10/8/2024 7:39:21 AM Received Date:
10/8/2024 7:39:00 AM From:
Michael Mahoney Created By:
Michael.Mahoney@nrc.gov Recipients:
"Perry Buckberg" <Perry.Buckberg@nrc.gov>
Tracking Status: None "Mack, Jarrett" <Jarrett.Mack@fpl.com>
Tracking Status: None Post Office:
SA1PR09MB9486.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1815 10/8/2024 7:39:00 AM RAIs (EICB) - Turkey Point 24-Month Fuel Cycle LAR (L-2023-LLA-0161).docx 58203 Options Priority:
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Page 1 of 10 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO CHANGE SURVEILLANCE INTERVALS TO ACCOMMODATE 24-MONTH FUEL CYCLE EPID L-2023-LLA-0161 INTRODUCTION By letter dated November 15, 2023 (ADAMS Accession No. ML23320A027), as supplemented by letter dated February 9, 2024 (ML24040A189), Florida Power and Light (the licensee) submitted a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) for changes to the Turkey Point Nuclear Generating Station, Units 3 and 4 (Turkey Point),
technical specifications (TS). The proposed license amendment would, in part, extended TS Surveillance Requirement (SR) intervals, modify TS Allowable Values (AVs) and a Trip Setpoint, and conform changes to the Updated Final Safety Analysis Report (UFSAR) to facilitate a transition to 24-month fuel cycles.
After reviewing the LAR, the Instrumentation and Controls Branch (EICB) staff requests a response to the following requests for additional information (RAIs):
REGULATORY BASIS:
In Subsection (c)(1)(ii)(A) of 10 CFR Part 50.36, it requires, in part, that:
Limiting safety system settings for nuclear reactors are settings for automatic protective devices related to those variables having significant safety functions.
Where a limiting safety system setting is specified for a variable on which a safety limit has been placed, the setting must be so chosen that automatic protective action will correct the abnormal situation before a safety limit is exceeded. If, during operation, it is determined that the automatic safety system does not function as required, the licensee shall take appropriate action, which may include shutting down the reactor. The licensee shall notify the Commission, review the matter, and record the results of the review, including the cause of the condition and the basis for corrective action taken to preclude recurrence Additionally, subsection (c)(3) of 10 CFR 50.36, Surveillance requirements, requires:
Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
Also, the staffs interpretation of the implementation of 10 CFR 50.36 requirements is captured in regulatory issue summary (RIS) 2006-17, NRC Staff Position on the Requirements of 10 CFR 50.36, "Technical Specifications," Regarding Limiting Safety System Settings During
Page 2 of 10 Periodic Testing and Calibration of Instrument Channels. The RIS describes not only how setpoints are created, but also how setpoints for automated equipment must be maintained.
The staff reviewed the documentation provided by Florida Power & Light Company (FPL),
related to a license amendment request for Turkey Point Units 3 and 4 (hereafter referred to as the licensee). The staff requires additional information related to its setpoint methodology, description of the use and application of the setpoint methodology in the final safety analysis report, as updated, (UFSAR), the impact of the requested modification on the technical specifications (TSs) and technical specification bases (TSBs), and other related topics. The staff determined that the information provided in the LAR and its Supplements does not provide the regulatory clarity needed by the NRC staff to find the license amendment acceptable for approval.
REQUEST FOR ADDITIONAL INFORMATION Part A - Setpoint Methodologies In Section 1.0 Introduction, of WCAP-18888-P, Revision 0, Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 24 Month Fuel Cycle, it states, in part, that:
This report has been prepared to replace the following four WCAPs: (emphasis added)
- 1. WCAP-12745, Revision 0,Westinghouse Setpoint Methodology for Protection Systems -Turkey Point Units 3 & 4, November 1990.
- 2. WCAP-12745, Revision 1,Westinghouse Setpoint Methodology for Protection Systems, Turkey Point Units 3 and 4, Thermal Up-rate Project
- 3. WCAP-17070-P, Revision 3, "Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 (Power Uprate to 2644 MWt
- Core Power),January 2021.
- 4. WCAP-17283-P, Revision 2,Westinghouse Setpoint Methodology for Protection Systems Turkey Point Units 3 & 4 (Consolidation of WCAP-12745, Revisions 0 and 1 with WCAP-17070-P Revision 3), September 2021.
RAIs Regarding WCAP 12783-P versus WCAP 18888-P:
The staff has reviewed several documents placed by the licensee or its contractor on the Certrec Portal during the regulatory audit. WCAP-17283-P, Rev 2, explains that it was prepared for personnel use and as such was not prepared in a manner that would support transmittal to the Nuclear Regulatory Commission (NRC).
In examining Table 3-26, of WCAP-17283-P, Reactor Trip System/Engineered Safety Features Actuation System Channel Error Allowances Turkey Point 3&4, of WCAP 17283-P it lists values that are either part of the uncertainty analysis for each instrument or the
Page 3 of 10 resultant combination of certain terms to formulate values related to setpoint determination (e.g., channel statistical allowance, margin, etc.)
The staff notes that the values generated in the table do not match the values for allowable value (AV) and trip setpoint as displayed in the Turkey Point Technical Specifications for the same period. For example, for the Protection Channel for Power Range Neutron Flux - High Setpoint in Table 3-26 the Trip Setpoint is listed as 109% of rated thermal power (RTP) and the AV is listed as 109.6% of RTP respectively. However, in the Technical Specifications dated January 11, 2023, which was approved after the WCAP-17283 report was issued (in September 2021), the trip setpoint and the AV for the Power Range Neutron Flux - High instrument channel are listed as 108% and 108.6% RTP respectively.
EICB-RAI-1
- a.
Please explain this apparent discrepancy (i.e., why are the values in the TS table different from the values in the WCAP-17283-P report immediately prior to issuance of WCAP-18888-P that purports to replace all previous WCAP reports) and describe what specific licensing basis document controls the establishment of the values that are listed in TS Tables 3.3.1-1, Reactor Trip System Instrumentation, and 3.3.2-1, ESFAS Instrumentation, for each of the TS setpoints and the AVs for reactor trip and engineered safety features actuation system functions listed in the proposed TS included in the LAR.
- b.
Since the WCAP-17283-P report states in the Introduction, in part:
This WCAP was prepared for Turkey Point personnel use only and as such is not prepared in a manner that would support transmittal to the Nuclear Regulatory Commission (NRC).
Therefore, immediately prior to the implementation of WCAP-18888-P,
- i.
What technical basis document established the technical basis for the Nominal Trip Setpoint and the AV in the Technical Specifications for the Power Range Neutron Flux High Setpoint and other LSSS related functions? and, ii.
What Turkey Point personnel use WCAP-17283-P and for what purpose do they use the WCAP-17283 report?
- c.
For each function listed in the RTS and ESFAS Technical Specification tables, which setpoint methodology(ies) govern(s) which process values that will be implemented in the RTS and the ESFAS function plant calibration procedures and then used as a basis for the calibration and functional test values derived and documented in the plant calibration and functional test procedures as TS surveillance test acceptance criteria and limiting values?
RAIs Regarding WCAP-18888-P Methodology Application Also, in Section 4.0, Applicability of the Setpoint Methodology, of WCAP-18888-P, it discusses the steps that must be taken should any instrumentation channel be found outside its as-found tolerance (AFT).
Specifically, in Subsection 4.1, Uncertainty Calculation Basic Assumptions/Premises, of WCAP-18888-P, it states, in part, Recalibration is explicitly required any time the as found
Page 4 of 10 condition of the device or channel is outside of the ALT. Additionally, it states, On those rare occasions that the channel is found outside of the AFT = ALT, then operability requirements would be initially satisfied via recalibration, or reset, about the NTS.
In addition, in Subsection 4.2, Process Rack Operability Determination Program and Criteria, of WCAP-18888-P, it states, in part, A channel found outside the RCA tolerance (ALT) is evaluated and recalibrated.
Additionally, it states, in part, At a later date, once the as found data is compiled, the relative drift (as-found - as left) can be calculated and compared against the RD value. This comparison can then be utilized to ensure consistency with the assumptions of the uncertainty calculations documented in Tables 3-1 through 3-26. A channel found to exceed this criterion multiple times should trigger a more comprehensive evaluation of the operability of the channel.
The use of Equation (Eq.) 2.1 of WCAP-18888-P, is identical to the channel statistical allowance (CSA) formula in WCAP 17070-P which was implemented to support the extended power update (EPU) license amendment. The information in Section 4.0, Application of the Setpoint Methodology, of WCAP-18888-P, is consistent with the language used in WCAP-17070. Based on this, the staff concludes all the RTS and ESFAS setpoints and allowable values in the scope of WCAP-18888-P have been developed in a manner identical to those developed under WCAP-17070-P. Of note is that during the EPU license amendment the licensee adopted the use of technical specification task force (TSTF)-493, Clarify Application of Setpoint Methodology for LSSS Functions, (Option A) for the EPU impacted TS instruments.
EICB-RAI-2 Given that the methodology used in WCAP-18888-P has expanded its scope of applicability to incorporate all the reactor trip system and engineered safety features actuation system instruments and the method for establishing setpoints is consistent with the method applied in WCAP-17070:
- a.
Please explain how this cited language in Subsections 4.1 and 4.2 is consistent, for all the related RTS and ESFAS instrument channels in WCAP-18888-P. Also describe how it conforms with the description in UFSAR Section 7.2 regarding technical specification task force (TSTF) - 493 Option A criteria for maintenance of setpoints for the related RTS and ESFAS instrument channels now that WCAP-18888-P uses and describes how the as-found and as-left tolerances will be used for all the instrument channels listed in the WCAP-18888-P report.
- b.
Please explain the reason for the difference between Subsections 4.1 and 4.2 of WCAP-18888. Section 4.1 states: Recalibration is explicitly required any time the as found condition of the device or channel is outside of the ALT. Section 4.2 states: A channel found outside the RCA tolerance (ALT) is evaluated and recalibrated. Please explain the process for evaluating whether the channel is functioning as required before recalibrating, and why this is not explicitly stated in Subsection 4.1.
Evaluation of Setpoint As-Found Measured Values Also, since Turkey Point chose to submit WCAP-18888-P as a supplement to the LAR, that incorporates a single methodology for all setpoints for RTS and ESFAS setpoints and allowable values, that includes reference in Subsection 4.2 explaining that for as-found measured values
Page 5 of 10 for LSSS related values found outside of the ALT, the instrument channel must be evaluated before returning the channel to service. As this language is identical to the language used in WCAP-17070-P whose current TSs incorporate the use of TSTF-493 Option A footnotes for LSSS setpoints for the EPU, the license did not explain why the non-EPU affected functions do not adopt the same wording as footnotes (b) and (c) for RTS Instrumentation and footnotes (g) and (h) for the ESFAS Instrumentation. Since WCAP-18888-P, Subsection 4.2 states, A channel found outside the RCA tolerance (ALT) is evaluated and recalibrated, and this language is similar to the footnotes applied to the functions covered within WCAP-17070-P, the staff is unable to determine why not adopting the referenced footnotes is appropriate.
EICB-RAI-3 Please explain why the licensee has not adopted footnotes (b) and (c) for RTS Instrumentation and footnotes (g) and (h) for the ESFAS Instrumentation and instead relies on footnotes (f) and (g) for the RTS instrumentation and footnotes (b) and (c) for ESFAS Instrumentation that do not require the out of specification as-found measured value be evaluated to ensure the instrument channel is functioning as required.
EICB-RAI-4 Provide relevant portions of the operations and/or maintenance procedures that describe what actions the operator and maintenance personnel need to take when, the as-found channel setpoint is outside its predefined as-found tolerance, to comply with UFSAR Section 7.2 regarding surveillance of RTS and ESFAS function setpoints, WCAP-18888-P, RIS 2006-17, and 10 CFR 50.36(c)(1)(ii)(a), Technical specifications.
Part B - Updated Final Safety Analysis Report Mark-ups In reviewing the marked-up description of Section 7.2 Setpoint Methodology, in the Turkey Point UFSAR, described as AQ-EICB-8 (FSAR Chapter-7 markup.pdf) on the Certrec portal, the NRC staff has multiple questions:
While the first portion of the first paragraph in the Setpoint Methodology subsection of the marked-up UFSAR lined out information that stated the referenced setpoint methodology was only applicable to those trip setpoints affected by the EPU, the last sentence in the same paragraph continues to describe that those RTS and ESFAS using TSTF-493 are only those RTS and ESFAS instruments impacted by the EPU.
Since the WCAP-18888-P Setpoint Methodology now applies to all RTS and ESFAS instrument setpoints and uses the formulas and terminology consistent to those in WCAP-17070-P, whose accompanying license amendment incorporates the method described in TSTF-493 Option A, the licensee has not explained how the licensees assertion of two approaches (one using TSTF-493 Option A and other not), for RTS and ESFAS setpoints in one setpoint methodology, (i.e., WCAP-18888-P) consistent with the approach taken in WCAP 17070-P is acceptable.
Specifically, based on the approach the licensee chose to implement, the staff asserts that the use of the footnotes adopted via the implementation of TSTF-493 for EPU related instrument channels in the currently approved technical specifications that require evaluation of an as-found setpoint outside of the AV now apply to all the instruments listed in the scope of WCAP-18888-P, versus only those instruments identified in the EPU.
Page 6 of 10 For example, in NUREG-1431, in Table 3.3.1-1, Reactor Trip System Instrumentation, Page 1 of 8 (Page 124 of Page 542 of the PDF), Surveillance Requirements 3.3.1.8 and 3.3.1.11 for Power Range Neutron Flux - Low, (listed in the license amendment request supplement in Table 3.3.1-1, Reactor Trip System Instrumentation, (Page 1 of 10) are amplified by footnotes (b) and (c), yet those specific footnotes are not depicted in the license amendment request submittal or supplement.
EICB-RAI-5 Using the method described in WCAP 18888-P as a reference, please explain the licensees apparent position as to why it believes it is acceptable for some RTS and ESFAS instruments to apply footnotes similar to those in TSTF-493 Option A and why some LSSS-related instruments do not apply the footnotes similar in composition to TSTF-493 footnotes.
EICB-RAI-6 In the UFSAR mark-up paragraph that states, in part, (after the mark-up):
Surveillance limits are established to verify that RTS and ESFAS instrumentation operates within the boundaries of applicable instrument uncertainty calculations. These limits are implemented in plant procedures in accordance with TS Notes [(a) and (b)] below which are consistent with the wording provided in TSTF-493 Rev 4. These notes specify operability criteria and require that out-of-tolerance conditions detected during surveillances be evaluated before returning the channel to service. [Notes (b) and (c)] [The notes]
have been inserted into TS Table [4.3.1] [3.3.1-1], RTS instrumentation
[Surveillance Requirements] and [Notes (g) and (h) have been inserted into] TS Table [4.3.2] [3.3.2-1] ESFAS Instrumentation [Surveillance Requirements]. The methods used to determine the NTS and AV values and summaries of the associated calculations are described in WCAP-[17070-P] [18888-P] (Reference 5).
Note (a) [or (g)] states:
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.
Note (b) [or (h)] states:
The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTS) 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 settings) to confirm channel performance. The NTS and the methodologies used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2.
Are these letters the correct labels for these footnotes, or should this have been Notes (b) and (c)? Please explain.
Page 7 of 10 Part C - Technical Specifications Markups In the Table 3.3.1-1 Reactor Trip System Instrumentation, starting on the page 1 of 10 of the mark-up, multiple surveillance requirements (SR) point to footnotes consistent with TSTF-493 Option A. Subsection 4.2, of WCAP-18888-P Process Rack Operability Determination Program and Criteria, states, in part, A channel found outside the RCA tolerance (ALT) is evaluated and recalibrated.
Based on this language the staff understands the marked-up TSs, including all setpoints in the scope of WCAP-18888-P should point to footnotes (b) and (c), instead of to footnotes (f) and (g).
Footnotes (f) and (g) state:
(f) The instrument channel setpoint shall be reset to a value within the calibration tolerance of the Trip Setpoint at the completion of the surveillance; otherwise, the channel shall be declared inoperable.
(g) If the instrument channel setpoint is less conservative than the Allowable Value, the setpoint shall be reset consistent with the Trip Setpoint and within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> determine the affected channel is OPERABLE; otherwise, the channel shall be declared inoperable.
Footnotes (f) and (g) in Reactor Trip System Instrumentation are not consistent with the application of the language described in WCAP-18888-P Subsection 4.2, which incorporated the methodology of WCAP 17070-P that also uses the as-found and as-left tolerance terms.
EICB-RAI-7
- a.
Verify whether the staffs understanding regarding the use of the footnotes (b) and (c) is correct.
- b.
If the staffs understanding is incorrect, please explain why the licensee believes it is acceptable to use footnotes that do not require an evaluation be conducted for certain instrument channels when the as-found measured value exceeds the AFT (i.e., the AV).
In the Table 3.3.1-2 Engineered Safety Feature Actuation System Instrumentation, starting on the page 1 of 7 mark-up multiple surveillance requirements (SR) point to footnotes consistent with TSTF-493 Option A. Subsection 4.2, of WCAP-18888-P Process Rack Operability Determination Program and Criteria, states, in part, A channel found outside the RCA tolerance (ALT) is evaluated and recalibrated.
Based on this language the staff understands the marked-up TSs, including all setpoints in the scope of WCAP-18888-P should point to footnotes (g) and (h), instead of to footnotes (b) and (c).
Footnotes (b) and (c) state:
Page 8 of 10 (b) The instrument channel setpoint shall be reset to a value within the calibration tolerance of the Trip Setpoint at the completion of the surveillance; otherwise, the channel shall be declared inoperable.
(c) If the instrument channel setpoint is less conservative than the Allowable Value, the setpoint shall be reset consistent with the Trip Setpoint and within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> determine the affected channel is OPERABLE; otherwise, the channel shall be declared inoperable.
Footnotes (b) and (c) in ESFAS Instrumentation are not consistent with the application of the language described in WCAP-18888-P Subsection 4.2, which incorporated the methodology of WCAP 17070-P that also uses the as-found and as-left tolerance terms.
EICB-RAI-8
- a. Verify whether the staffs understanding regarding the use of the footnotes (g) and (h) is correct.
- b. If the staffs understanding is incorrect, please explain why the licensee believes it is acceptable to use footnotes that do not require an evaluation be conducted for certain instrument channels when the as-found measured value exceeds the AFT (i.e., the AV).
Part D - Technical Specifications Bases Markups In several locations within the Technical Specification Bases (TSB), the licensee lined out the phrase Allowable Value or Allowable Values and replaced it with the term Trip Setpoint or Trip Setpoints respectively.
The staff reviewed this information does not agree wholly with the licensees new definition of Trip Setpoint or Trip Setpoints when used in certain contexts.
For example, the licensee states on Page B.3.3.1-5:
To allow for calibration tolerances, instrumentation uncertainties, instrument drift, and severe environment errors for those TS channels that must function in harsh environments as defined by 10 CFR 50.49 (Ref. 5), the [Allowable Values] [Trip Setpoints] specified in Table 3.3. 1-1 in the accompanying LCO are conservative with respect to the analytical limits.
The staff notes that this change in the context is acceptable as both the allowable value and the trip setpoints are conservative with respect to analytical limits.
However, the manner in which several changes have been made to the TSB are not technically accurate.
For example, the licensee also states on Page B.3.3.1-5:
The [Allowable Value is the LSSS and] [Trip Setpoint] ensures the safety analysis limits are met during the surveillance interval selected when a channel is adjusted based on stated channel uncertainties.
Page 9 of 10 This statement as written prior to the LAR mark-up (refer to the red strikeout text above), is not accurate since, per Turkey Points UFSAR Section 7.2s subsection on, Setpoint Methodology describes the NTS (nominal trip setpoint) values as the LSSS value, not the Allowable Value.
With the proposed change to the text in the UFSAR as written above, it states that the trip setpoint ensures the safety analysis limits are met during the surveillance interval selected when a channel is adjusted based on stated channel uncertainties.
This statement is also not accurate since it is the allowable value, not the trip setpoint that ensures the safety analysis limits are met for the instrument channel. Additionally, in the Turkey Point UFSAR, the nominal trip setpoint is defined as the LSSS value in Section 7.2.
EICB-RAI-9 Explain the licensees understanding of why the text, as previously written and as proposed meets the requirements of 10 CFR 50.36 or any changes to the text that will be required so that the language complies with 10 CFR 50.36.
Part E - Typographical Errors The following requests for additional information (RAI) concern potential typographical errors.
The staff requests the licensee explain the apparent discrepancies.
EICB-RAI-10 In Section 2, Evaluation of Change in, Supplement to License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals, and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles, the markup of Table C1 (Enclosure 1, Page 4 of 6) the second row describes the surveillance requirement as "SR 3.3.1.10" and the Tech. Spec. Function as Table 3.3.1-1 Function 10 as "Perform CHANNEL Calibration, Pressurizer Pressure-High. However, the Function Number for Pressurizer Pressure-High is Function 8.
Please explain the discrepancy and resolution of the issue.
EICB-RAI-11 In the Supplement to License Amendment Request 278, Incorporate Advanced Fuel Products, Extend Surveillance Intervals, and 10 CFR 50.46 Exemption Request to Facilitate Transition to 24-Month Fuel Cycles, the marked-up pages of Table 3.3.1-1, Reactor Trip System Instrumentation, in Note (c) it states, in part, The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2.
Additionally, in the marked-up pages of Table 3.3.1-2 Engineered Safety Feature Actuation System Instrumentation, in Note (h) it states, in part, The NTSP and the methodologies used to determine the as-found and as-left tolerances are specified in UFSAR Section 7.2.
Please explain why the term 'methodologies is used when only WCAP-18888-P appears to be the basis document as described in the supplement. Will other setpoint methodologies still be in use and if so, where are they described in the UFSAR?
Page 10 of 10