ML060030317

Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications for Loss of Power Diesel Generator Start Instrumentation (TAC Nos. MC4584 and MC4585)

ML060030317
Person / Time
Site:	Sequoyah
Issue date:	01/13/2006
From:	Pickett D V Plant Licensing Branch III-2
To:	Singer K W Tennessee Valley Authority
Pickett , NRR/DLPM, 415-1364
References
TAC MC4584, TAC MC4585
Download: ML060030317 (5)

Text

January 13, 2006Mr. Karl W. SingerChief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 - REQUEST FORADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS FOR LOSS OFPOWER DIESEL GENERATOR START INSTRUMENTATION (TAC NOS. MC4584 AMD MC4585)

Dear Mr. Singer:

By letter dated September 30, 2004 (ADAMS No. ML042860054), Tennessee Valley Authorityrequested a license amendment for the Sequoyah Nuclear Plant, Units 1 and 2 technical specifications (TVA-SQN-TS-04-01). The proposed changes request the relocation of the loss of power instrumentation for emergency diesel generators to a new limiting condition for operation (LCO), replace the setpoint and allowable values for the auxiliary feedwater loss ofpower start function by referring to the new proposed LCO, and add new allowable values consistent with Standard Technical Specification Change Traveler TSTF-365.In order for the Nuclear Regulatory Commission to complete its review of these reports, wehave identified the enclosed request for additional information (RAI). Based on discussions with your staff, we understand that you intend to respond to this RAI by approximately February 17, 2006.Please feel free to contact me at 301-415-1364, if you have any questions.Sincerely,/RA/Douglas V. Pickett, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-327 and 50-328

Enclosure:

As stated cc w/enclosure: See next page January 13, 2006Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 - REQUEST FORADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS FOR LOSS OFPOWER DIESEL GENERATOR START INSTRUMENTATION (TAC NOS. MC4584 AMD MC4585)

Dear Mr. Singer:

By letter dated September 30, 2004 (ADAMS No. ML042860054), Tennessee Valley Authorityrequested a license amendment for the Sequoyah Nuclear Plant, Units 1 and 2 technical specifications (TVA-SQN-TS-04-01). The proposed changes request the relocation of the loss of power instrumentation for emergency diesel generators to a new limiting condition for operation (LCO), replace the setpoint and allowable values for the auxiliary feedwater loss ofpower start function by referring to the new proposed LCO, and add new allowable values consistent with Standard Technical Specification Change Traveler TSTF-365.In order for the Nuclear Regulatory Commission to complete its review of these reports, wehave identified the enclosed request for additional information (RAI). Based on discussions with your staff, we understand that you intend to respond to this RAI by approximately February 17, 2006.Please feel free to contact me at 301-415-1364, if you have any questions.Sincerely,/RA/Douglas V. Pickett, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-327 and 50-328

Enclosure:

As stated cc w/enclosure: See next page DistributionPUBLICRidsOgcRpLPL2-2 r/fRidsNrrDorlLpldRidsNrrPMDPickettAHoweBMarcusRidsRgn2MailCenter (SCahill)RSolaBKS1 (BSingal)

ADAMS ACCESSION NO.: ML060030317 NRR-088OFFICENRR/LPL2-2:PMNRR/LPL2-2:LABC:EICBNRR/LPL2-2:BCNAMEDPickettRSolaAHowe (by memo)MMarshallDATE / /06 / /0610 / 24 /05 / /06OFFICIAL RECORD COPY Mr. Karl W. SingerSEQUOYAH NUCLEAR PLANTTennessee Valley Authority cc: Mr. Ashok S. Bhatnagar, Senior Vice President Nuclear Operations Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Larry S. Bryant, General ManagerNuclear Engineering Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801Mr. Robert J. Beecken, Vice PresidentNuclear Support Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Randy DouetSite Vice President Sequoyah Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Soddy Daisy, TN 37384-2000General CounselTennessee Valley Authority ET 11A 400 West Summit Hill DriveKnoxville, TN 37902Mr. John C. Fornicola, ManagerNuclear Assurance and Licensing Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801Mr. Glenn W. Morris, Manager Corporate Nuclear Licensing and Industry Affairs Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801Mr. Paul L. Pace, ManagerLicensing and Industry Affairs ATTN: Mr. James D. Smith Sequoyah Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Soddy Daisy, TN 37384-2000Mr. David A. Kulisek, Plant ManagerSequoyah Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Soddy Daisy, TN 37384-2000Senior Resident InspectorSequoyah Nuclear Plant U.S. Nuclear Regulatory Commission 2600 Igou Ferry Road Soddy Daisy, TN 37379Mr. Lawrence E. Nanney, DirectorDivision of Radiological Health Dept. of Environment & Conservation Third Floor, L and C Annex 401 Church Street Nashville, TN 37243-1532County MayorHamilton County Courthouse Chattanooga, TN 37402-2801Ms. Ann P. Harris341 Swing Loop Road Rockwood, Tennessee 37854 ENCLOSUREREQUEST FOR ADDITIONAL INFORMATIONLICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONSFOR LOSS OF POWER DIESEL GENERATOR START INSTRUMENTATIONTENNESSEE VALLEY AUTHORITYSEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2The license amendment request (LAR) proposes the addition of new upper limit allowablevalues for 6.9 kv Shutdown Board - Loss of Voltage - Voltage Sensors and 6.9 kv ShutdownBoard - Degraded Voltage - Voltage Sensors in Technical Specification (TS) 3.3.3.11, Table 3.3-14 consistent with Standard Technical Specification Traveler TSTF-365 and theaddition of a lower allowable value for the 6.9 kv Shutdown Board - Degraded Voltage - Diesel Generator Start and Load Shed Timer in TS 3.3.3.11, Table 3.3-14.In recent public communications available on the Nuclear Regulatory Commission's (NRC)public website, ADAMS Nos. ML052500004, ML050870008 and ML051660447, the NRC staffhas identified a concern on the use of allowable values as limits that are used in TSs to satisfy the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36,"Technical Specifications." The NRC staff has been working with the Nuclear Energy Institute'sSetpoint Methods Task Force to address these concerns.To assess the acceptability of your LAR related to this issue, the NRC staff requests thefollowing additional information:1. Describe the instrumentation setpoint methodology used at Sequoyah for establishingTS limits. This discussion should include acceptable as found band, acceptable as left band, setting tolerance, and reset criteria used to determine the acceptability of theinstrumentation.2.For the allowable values to be added, clarify whether it is a Limiting Safety SystemSetting (LSSS) as discussed in 10 CFR 50.36(c)(ii)(A). If you determined that it is not, explain why not.The NRC staff will generally use the following criteria to determine whether the allowablevalues being changed fall within the scope of this LSSS issue or not:(a)Instrument allowable values and setpoints for TS functions in the Reactor Protection(Trip) System.(b)Instrument allowable values and setpoints for TS functions that protect a safetylimit (SL) (whether or not the Bases designates the function as an LSSS). (c)Allowable values and setpoints that are not in instrumentation LCOs but whosefunction protects an SL (whether or not the Bases designate the function as an LSSS).3. As required by 10 CFR 50.36(c)(ii)(A), if it is determined that the automatic safetysystem does not function as required, the licensee shall take appropriate action. Describe how the surveillance test results and the associated TS limits as determined by the plant setpoint methodology are used to establish the operability of the safety system. Include a discussion of plant processes for evaluating channels identified to be operable but degraded. If the requirements for determining operability of the instrumentationbeing tested are located in a document other than the TSs (e.g., plant test procedure),

discuss how the requirements of 10 CFR 50.36 are met.4.As required by 10 CFR 50.36(c)(ii)(A), an LSSS be so chosen that automatic protectiveaction will correct the abnormal situation before an SL is exceeded. Discuss how TSlimits established by the plant setpoint methodology will ensure that the SL will not beexceeded. Include in your discussion information on the controls you employ to ensure that the as left trip setting after completing periodic surveillance, is consistent with your setpoint methodology. If the controls are located in a document other than the TSs(e.g., plant test procedure), discuss how those controls satisfy the requirements of 10 CFR Part 50.36.5.For setpoints that are not defined as LSSS in response to question 2, discuss whatmeasures have been taken to ensure that it is capable of performing its specified safety functions. Include in your discussion information on the controls you employ to ensure that the as left trip setting after completing periodic surveillance, is consistent with your setpoint methodology. If the controls are located in a document other than the TSs(e.g., plant test procedure), discuss how those controls satisfy operability requirements.