ML060260259

RAI, Nominal Trip Setpoints (TAC MC4408, TAC MC4409)

ML060260259
Person / Time
Site:	Sequoyah
Issue date:	03/02/2006
From:	Pickett D Plant Licensing Branch III-2
To:	Singer K Tennessee Valley Authority
Pickett D, NRR/DLPM, 415-1364
References
TAC MC4408, TAC MC4409, TVA-SQN-TS-02-01
Download: ML060260259 (6)

Text

March 2, 2006Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 - REQUEST FORADDITIONAL INFORMATION REGARDING NOMINAL TRIP SETPOINTS (TAC NOS. MC4408 AND MC4409) (TVA-SQN-TS-02-01)

Dear Mr. Singer:

The U. S. Nuclear Regulatory Commission (NRC) staff is continuing its review of yourapplication dated August 18, 2004, Technical Specification Change No. 02-01, Revision 1, Nominal Trip Setpoints for Reactor Protection System and Engineered Safety Features Instrumentation. In a letter dated May 19, 2005 (ADAMS Accession Number: ML0512604640), the NRC staffrequested additional information from Tennessee Valley Authority (TVA) as part of the interim approach adopted by the NRC to review license amendments related to setpoint methodology.As a result of the NRC's updated approach to this issue, the request for additionalinformation (RAI) originally contained in our letter dated May 19, 2005, is hereby withdrawn and replaced by the RAI enclosed in this letter. Our letter dated May 19, 2005, also asked for the following three items:

1.An explicit regulatory commitment to adopt the final Technical Specification Task Forcetechnical specification change to come into conformance with the existing understanding of the requirements of 10 CFR 50.36.2.An explicit regulatory commitment to assess the operability of tested instrumentationbased on the previous as-left instrument setting and accounting for the uncertainties associated with the test or calibration.3.A revision to the technical specifications for the limiting safety system settings beingchanged by the license amendment request to incorporate a footnote that states:The as-left instrument setting shall be returned to a setting within thetolerance band of the trip setpoint established to protect the safety limit.These three items are likewise withdrawn and do not need to be addressed by TVA. Based upon discussions with your staff, we understand that you plan to respond to theenclosed RAI within 60 days of receipt of this letter. If you have any questions about this material, please contact me at (301) 415-1364.Sincerely,/RA/ Douglas V. Pickett, Senior Project ManagerPlant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-327 and 50-328

Enclosure:

Request for Additional Informationcc w/enclosure: See next page

ML060260259 NRR-088OFFICELPL2-2/PMLPL2-2/LABC:CSGBLPL2-2/BCNAMEDPickettRSolaAHoweMMarshallDATE 2 / 13 / 06 2 / 13 / 06 2 / 14 / 06 3 / 02 / 06 Mr. Karl W. SingerTennessee Valley Authority SEQUOYAH NUCLEAR PLANT 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, Vice PresidentNuclear Engineering & Technical Services 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 INFORMATIONSEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2TECHNICAL SPECIFICATIONS CHANGES FOR NOMINAL TRIP SETPOINTS FOR REACTOR PROTECTION SYSTEM AND ENGINEERED SAFETY FEATURESINSTRUMENTATIONDOCKET NOS. 50-327 AND 50-3281.Setpoint Calculation Methodology: Provide documentation (including samplecalculations) of the methodology used for establishing the limiting nominal setpoint andthe limiting acceptable values for the As-Found and As-Left setpoints as measured in periodic surveillance testing as described below. Indicate the related Analytical Limits and other limiting design values (and the sources of these values) for each setpoint.2.Safety Limit (SL)-Related Determination: Provide a statement as to whether or not thesetpoint is a limiting safety system setting for a variable on which a SL has been placedas discussed in Title 10 of the Code of Frederal Regulations (10 CFR) Part50.36(c)(ii)(A). Such setpoints are described as "SL-Related" in the discussions that follow. For each setpoint that you determined not to be SL-Related, explain the basisfor this determination.3.For setpoints that are determined to be SL-Related: The NRC letter to the NuclearEnergy Institute (NEI) Setpoint Methods Task Force (SMTF) dated September 7, 2005(ADAMS Accession Number: ML052500004), describes Setpoint-Related TS (SRTS) that are acceptable to the NRC for instrument settings associated with SL-related setpoints. Specifically: Part "A" of the Enclosure to the letter provides limiting condition for operation (LCO) notes to be added to the TS, and Part "B" includes a check list of the information to be provided in the TS Bases related to the proposed TS changes.a.Describe whether and how you plan to implement the SRTS suggested in theSeptember 7, 2005, letter. If you do not plan to adopt the suggested SRTS, thenexplain how you will ensure compliance with 10 CFR 50.36 by addressing items3b and 3c, below.b.As-Found Setpoint Evaluation: Describe how surveillance test results andassociated TS limits are used to establish operability of the safety system. Showthat this evaluation is consistent with the assumptions and results of the setpointcalculation methodology. Discuss the plant corrective action processes (including plant procedures) for restoring channels to operable status when channels are determined to be "inoperable" or "operable but degraded." If the criteria for determining operability of the instrument being tested are located in adocument other than the TS (e.g. plant test procedure), explain how the requirements of 10 CFR 50.36 are met.c.As-Left Setpoint Control: Describe the controls employed to ensure that theinstrument setpoint is, upon completion of surveillance testing, consistent withthe assumptions of the associated analyses. If the controls are located in a document other than the TS (e.g. plant test procedure) explain how the requirements of 10 CFR 50.36 are met.4.For setpoints that are not determined to be SL-related setpoints in response toQuestion 2: Describe the measures to be taken to ensure that the associatedinstrument channel is capable of performing its specified safety functions in accordance with applicable design requirements and associated analyses. Include in your discussion information on the controls you employ to ensure that the As-Left trip setting after completion of periodic surveillance is consistent with your setpoint methodology. If the controls are located in a document other than the TS (e.g., plant test procedure),describe how it is ensured that the controls will be implemented to satisfy operabilityrequirements.