ML24309A055

NRR E-mail Capture - Request for Additional Information - TVA LAR to Revised Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2 Re TS Table 3.3.2-1, Function 5

ML24309A055
Person / Time
Site:	Sequoyah, Watts Bar
Issue date:	11/01/2024
From:	Kimberly Green Plant Licensing Branch II
To:	Hughes S Tennessee Valley Authority
References
L-2023-LLA-0175
Download: ML24309A055 (4)

Text

From:

Kimberly Green Sent:

Friday, November 1, 2024 1:59 PM To:

Hughes, Shawna Marie

Subject:

Request for Additional Information - TVA LAR to Revised Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2 re TS Table 3.3.2-1, Function 5 (EPID L-2023-LLA-0175)

Attachments:

Table 3.3.2-1 Function 5 RAI.docx

Dear Shawna Hughes,

By letter dated December 18, 2023 (Agencywide Documents Access and Management System Accession No. ML23352A298), as supplemented by letter dated August 19, 2024 (ML24232A071), Tennessee Valley Authority (TVA) requested changes to Sequoyah Nuclear Plant (Sequoyah), Units 1 and 2, and the Watts Bar Nuclear Plant (Watts Bar), Units 1 and 2, Technical Specification (TS) Tables 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation. Specifically, the proposed changes would add a note to Functions 5.a and 5.b related to the turbine trip function. Also, the proposed changes for Watts Bar, Units 1 and 2, would revise notes (f) of Watts Bar, Unit 1, TS Table 3.3.2-1 and note (h) of Watts Bar, Unit 2, TS Table 3.3.2-1 to be consistent with the corresponding note in Sequoyah, Units 1 and 2, TS Table 3.3.2-1.

The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing your application and has identified an area where additional information is needed to complete its review. A draft request for additional information (RAI) was previously transmitted to you via email on October 22, 2024.

At TVAs request, a clarification call was held on October 30, to clarify the NRC staffs requests.

No changes were made to the RAI as a result of the call.

A response to the attached RAI is requested within 30 days of the date of this email. 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 at (301) 415-1627 or via email at Kimberly.Green@nrc.gov.

Sincerely, Kimberly Green Senior Project Manager Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1627

Hearing Identifier:

NRR_DRMA Email Number:

2636 Mail Envelope Properties (SA1PR09MB916375939A416009BFC18A098F562)

Subject:

Request for Additional Information - TVA LAR to Revised Sequoyah Nuclear Plant, Units 1 and 2, and Watts Bar Nuclear Plant, Units 1 and 2 re TS Table 3.3.2-1, Function 5 (EPID L-2023-LLA-0175)

Sent Date:

11/1/2024 1:58:52 PM Received Date:

11/1/2024 1:58:00 PM From:

Kimberly Green Created By:

Kimberly.Green@nrc.gov Recipients:

"Hughes, Shawna Marie" <smhughes@tva.gov>

Tracking Status: None Post Office:

SA1PR09MB9163.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1921 11/1/2024 1:58:00 PM Table 3.3.2-1 Function 5 RAI.docx 26514 Options Priority:

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REQUEST FOR ADDITIONAL INFORMATION TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-390 AND 50-391 TECHNICAL SPECIFICATION 3.3.2-1, FUNCTION 5 By letter dated December 18, 2023 (Agencywide Documents Access and Management System Accession No. ML23352A298), as supplemented by letter dated August 19, 2024 (ML24232A071), the Tennessee Valley Authority (TVA) submitted license amendment requests (LAR) for the Sequoyah Nuclear Plant (Sequoyah), Units 1 and 2, and the Watts Bar Nuclear Plant (Watts Bar), Units 1 and 2. Specifically, the proposed amendments would revise Sequoyah and Watts Bar Technical Specification (TS) Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, by adding a note to Functions 5.a and 5.b related to the turbine trip function. The amendments for Watts Bar, Units 1 and 2, would also revise note (f) of Watts Bar, Unit 1, TS Table 3.3.2-1 and note (h) of Watts Bar, Unit 2, TS Table 3.3.2-1 to be consistent with the corresponding note in Sequoyah, Units 1 and 2, TS Table 3.3.2-1.

The U.S. Nuclear Regulatory Commission (NRC or Commission) is reviewing the LAR, and has identified an area where additional information is needed to complete its review. The requested information is identified below.

Basis:

The Commissions regulatory requirements related to the content of TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, Technical Specifications, which require, in pertinent part, that the TSs include: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.

NUREG-14311, contains improved Standard Technical Specifications (STS) for Westinghouse plants. The NUREG encourages licensees to upgrade their TSs consistent with those criteria and conforming, to the practical extent, to Revision 5 of the improved STS.

In the STS for Westinghouse plants (i.e., NUREG-1431), for note k to Table 3.3.2-1, it states:

(k) Except when all MFIVs, MFRVs, [and associated bypass valves] are closed and [de-activated] [or isolated by a closed manual valve].

1 U.S. Nuclear Regulatory Commission, Standard Technical Specifications, Westinghouse Plants, NUREG-1431, Volume 1, Specifications, and Volume 2, Bases, Revision 5, September 2021 (ML21259A155 and ML21259A159, respectively).

As noted in TSTF-GG-05-01, Writers Guide for Plant-Specific Improved Technical Specifications, brackets are typically used in the generic TSs and Bases to indicate where plant-specific input is needed. Bracketed values or requirements in STS are those that are based on plant-specific design, analysis, or licensing basis.

TVA is requesting the removal of the words associated bypass valves and and deactivated, and the addition of the words, MFRV bypass valves, and stated in the LAR that the proposed changes are administrative in nature in that they are consistent with Note (i) of Sequoyah Units 1 and 2, TS Table 3.3.2-1, Functions 5.a and 5.b; however, TVA has not provided a plant-specific reason for the changes.

Watts Bar Dual-Unit Updated Final Safety Analysis Report (UFSAR) Figure 10.4-8 (ML23346A225) shows the main feedwater isolation valves (MFIVs) and main feedwater regulator valves (MFRVs) on the 16-inch main feedwater line, and the MFIV bypass and MFRV bypass valves on the 6-inch startup flow feedwater line. The NRC staff notes that the feedwater configuration at Watts Bar is not consistent with the feedwater configuration at Sequoyah.

The NRC staff also notes that TS Table 3.3.2-1, notes (f) and (h) for Watts Bar Units 1 and 2, respectively, apply to the main steam valve vault rooms level switches for level high. According to the Watts Bar TS Bases for TS 3.7.3 (ML23312A013), the MFIVs and bypass MFIVs are located in the main steam valve vault close to containment.

Request:

Based on its review of information in the UFSAR, the NRC staff was unable to determine if the subject valves do not need to be deactivated nor could the staff determine if all the subject valves could be isolated by a closed manual valve.

Provide the plant-specific justification for the requested addition and removal of the noted words as they relate to Functions 5.a, 5.b, 5.d, and 5.e.