ML110680653

OL - TVA Letter to NRC_02-16-11_TS-TS Bases Supplemental Info

ML110680653
Person / Time
Site:	Watts Bar
Issue date:	02/16/2011
From:	- No Known Affiliation
To:	Division of Operating Reactor Licensing
References
Download: ML110680653 (14)

Text

WBN2Public Resource From: Boyd, Desiree L [dlboyd@tva.gov]

Sent: Wednesday, February 16, 2011 1:09 PM To: Epperson, Dan; Poole, Justin; Raghavan, Rags; Milano, Patrick; Campbell, Stephen Cc: Crouch, William D; Hamill, Carol L; Boyd, Desiree L

Subject:

TVA letter to NRC_02-16-11_TS-TS Bases Supplemental Info Attachments: 02-16-11_TS-TS Bases Supplemental Info_Final .pdf Please see attached TVA letter that was sent to the NRC today.

Enclosures 2 & 3 are too large to send by email. For those of you who receive a cc in the mail, the enclosures will be included with your letter.

Thank You,

~*~*~*~*~*~*~*~*~*~*~*~*~*~*~

Désireé L. Boyd WBN 2 Licensing Support Sun Technical Services dlboyd@tva.gov 4233658764

~*~*~*~*~*~*~*~*~*~*~*~*~*~*~

1

Hearing Identifier: Watts_Bar_2_Operating_LA_Public Email Number: 288 Mail Envelope Properties (7AB41F650F76BD44B5BCAB7C0CCABFAF1B7A0666)

Subject:

TVA letter to NRC_02-16-11_TS-TS Bases Supplemental Info Sent Date: 2/16/2011 1:08:34 PM Received Date: 2/16/2011 1:08:57 PM From: Boyd, Desiree L Created By: dlboyd@tva.gov Recipients:

"Crouch, William D" <wdcrouch@tva.gov>

Tracking Status: None "Hamill, Carol L" <clhamill@tva.gov>

Tracking Status: None "Boyd, Desiree L" <dlboyd@tva.gov>

Tracking Status: None "Epperson, Dan" <Dan.Epperson@nrc.gov>

Tracking Status: None "Poole, Justin" <Justin.Poole@nrc.gov>

Tracking Status: None "Raghavan, Rags" <Rags.Raghavan@nrc.gov>

Tracking Status: None "Milano, Patrick" <Patrick.Milano@nrc.gov>

Tracking Status: None "Campbell, Stephen" <Stephen.Campbell@nrc.gov>

Tracking Status: None Post Office: TVANUCXVS2.main.tva.gov Files Size Date & Time MESSAGE 477 2/16/2011 1:08:57 PM 02-16-11_TS-TS Bases Supplemental Info_Final .pdf 119925 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Tennessee Valley Authority, Post Office Box 2000, Spring City, Tennessee 37381-2000 February 16, 2011 10 CFR 50.36 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 NRC Docket No. 50-391

Subject:

Watts Bar Nuclear Plant (WBN) Unit 2 - Supplemental Information For Review of Developmental Revision A of the Unit 2 Technical Specifications (TS) and Technical Specifications Bases (TS Bases)

TVAs letter to NRC dated March 4, 2009 (Reference 1), included Developmental Revision A of the Unit 2 TS and TS Bases. Enclosure 2 of that letter noted that the proposed WBN Unit 2 TS and TS Bases were developed by marking up Revision 0 of NUREG-1431, Standard Technical Specifications Westinghouse Plants, to indicate the WBN Unit 1 TS and TS Bases approved (as appropriate) through Amendment 70 and Revision 91, respectively.

Recently, an NRC staff member noted that the current licensing basis for Unit 1 was to be used as the reference basis for the review and licensing of Unit 2. Based on this, the staff member noted that the Developmental A versions of the TS and TS Bases should have been based on the Unit 1 TS amendment and TS Bases revision that were current when the first WBN Regulatory Framework letter was issued for Unit 2. As a result, the staff requested that a markup of these versions of the TS and TS Bases (i.e., when the framework letter was submitted) be provided that reflects the Unit 1 TS amendment and TS Bases revision that were current when Developmental Revision A of the Unit 2 TS and TS Bases was submitted.

To accomplish this activity, this letter provides the following:

x Enclosure 1 describes the process used to produce the requested markups of the TS and TS Bases. Additionally, the review matrix used for the markups is discussed.

x Enclosure 2 includes the TS Review Matrix and the associated marked-up TS pages.

x Enclosure 3 includes the TS Bases Review Matrix and the associated marked-up TS Bases pages.

U.S. Nuclear Regulatory Commission Page 3 February 16, 2011

References:

1. TVA to NRC letter dated March 4, 2009, Watts Bar Nuclear Plant (WBN) Unit 2 - Operating License Application Update (ADAMS Accession No. ML090700378)

[Developmental Revision A]

2. TVA to NRC letter dated January 29, 2008, Watts Bar Nuclear Plant (WBN) - Unit 2 -

Regulatory Framework for the Completion of Construction and Licensing Activities for Unit 2 (ADAMS Accession No. ML080320443)

3. TVA to NRC letter dated February 2, 2010, Watts Bar Nuclear Plant (WBN) - Unit 2 -

Developmental Revision B of the Technical Specifications (TS), TS Bases, Technical Requirements Manual (TRM), TRM Bases; and Pressure and Temperature Limits Report (PTLR) (ADAMS Accession No. ML100550326)

4. TVA to NRC letter dated August 16, 2010, Watts Bar Nuclear Plant (WBN) - Unit 2 -

Change to Developmental TS Section 4.2.2, Control Rod Assemblies (ADAMS Accession No. ML102290075) [Developmental Revision C]

5. TVA to NRC letter dated October 12, 2010, Watts Bar Nuclear Plant (WBN) - Unit 2 -

Change to Developmental Technical Specification (TS) Sections 3.6.11, Ice Bed, and 3.1.8, Rod Position Indication (ADAMS Accession No. ML1028505200)

[Developmental Revision D]

6. TVA to NRC letter dated January 27, 2011, Watts Bar Nuclear Plant (WBN) - Unit 2 -

Change to Developmental Technical Specification (TS) Section 3.1.8, Rod Position Indication (ADAMS Accession No. ML110270108) [Developmental Revision E]

cc (Enclosures):

U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257 NRC Resident Inspector Unit 2 Watts Bar Nuclear Plant 1260 Nuclear Plant Road Spring City, Tennessee 37381

U.S. Nuclear Regulatory Commission Page 4 February 16, 2011 bcc (Enclosures):

Stephen Campbell U.S. Nuclear Regulatory Commission MS 08H4A One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2738 Charles Casto, Deputy Regional Administrator for Construction U. S. Nuclear Regulatory Commission Region II Marquis One Tower 245 Peachtree Center Ave., NE Suite 1200 Atlanta, Georgia 30303-1257

ENCLOSURE 1 Process for Marking Up the Technical Specifications (TS) and TS Bases Pages Tennessee Valley Authority - Watts Bar Nuclear Plant - Unit 2, Docket No. 50-391 See Page 3 of the cover letter for references.

Developmental Revision A of the Unit 2 TS and TS Bases (Reference 1) were based on Revision 0 of NUREG-1431, Standard Technical Specifications Westinghouse Plants.

Developmental Revision A was constructed by starting with NUREG-1431 and then overlaying the Unit 1 TS amendments and TS Bases revisions made from Amendment 0 / Revision 0 through Amendment 70 / Revision 91, respectively.

The NRC staff reviewer has requested that an alternate markup be provided which is based on the versions of the Unit 1 TS and TS Bases which were current at the time of the first WBN Unit 2 regulatory framework letter (Reference 2). At that time, the Unit 1 TS and TS Bases were at Amendment 67 and Revision 86, respectively. Therefore, the attached markups depict the applicable changes from the date of Reference 2 to the date of Reference 1 (i.e., January 29, 2008, to March 4, 2009). Thus, the markups herein address Unit 1 TS Amendments 68 through 70 and TS Bases Revisions 87 through 91. Unit 1 TS Amendment 69 was found to be a temporary change that is not needed for Unit 2; thus, it is not included in the markup provided in Enclosure 2. Additionally, as noted below, some of the Unit 1 TS amendments and TS Bases revisions prior to Amendment 67 and Revision 86, respectively, will not apply to Unit 2 (e.g.,

Unit 2 will not utilize a tritium producing core).

Changes to the Unit 2 TS and TS Bases made after the date of Reference 1 are addressed by References 3 through 6.

The markups contained in this letter result in basically the same TS and TS Bases as provided in Reference 1 except for the discrepancies noted in Enclosure 4.

The requested markups provided in Enclosures 2 and 3 involve only the affected pages that resulted from the process described below:

For the TS:

x Marked up the applicable Unit 1 TS pages to show the changes that resulted from Unit 1 TS Amendments 68 and 70 (i.e., the amendments incorporated between the submittal of References 1 and 2).

x Designated the Unit 1 TS amendments that were not incorporated on Unit 2. Where appropriate, provided a markup to show how the TS looked prior to incorporation of the amendment that was not incorporated.

x Provided a review matrix for the TS. This matrix indicates, by TS section, which amendments were incorporated and which amendments were not incorporated. This matrix also delineates when / why a markup is not provided.

E1-1

ENCLOSURE 1 Process for Marking Up the Technical Specifications (TS) and TS Bases Pages Tennessee Valley Authority - Watts Bar Nuclear Plant - Unit 2, Docket No. 50-391 For the TS Bases:

x Marked up the applicable Unit 1 TS Bases pages to show the changes that resulted from Unit 1 TS Bases Revisions 87, 88, 89, and 90 (i.e., the revisions incorporated between the submittal of References 1 and 2).

x Noted the Unit 1 TS Bases revisions that were not incorporated on Unit 2. Where appropriate, provided a markup to show how the TS Bases looked prior to incorporation of the revision that was not incorporated.

x Provided a review matrix for the TS Bases. This matrix indicates, by TS Bases section, which revisions were incorporated and which revisions were not incorporated. This matrix also delineates when / why a markup is not provided.

Key to Abbreviations Use on Review Matrices x TS Technical Specifications x TS Bases Technical Specifications Bases x AXX Technical Specifications Amendment XX x RXX Technical Specifications Bases Revision XX x AXX (RXX) Technical Specifications Amendment XX (Technical Specifications Bases Revision XX)

E1-2

ENCLOSURE 2 Unit 2 TS Review Matrix: Unit 1 Amendments 67 through 70 With Associated Markups Tennessee Valley Authority - Watts Bar Nuclear Plant - Unit 2, Docket No. 50-391

ENCLOSURE 3 Unit 2 TS Bases Review Matrix: Unit 1 Revisions 86 through 91 With Associated Markups Tennessee Valley Authority - Watts Bar Nuclear Plant - Unit 2, Docket No. 50-391

ENCLOSURE 4 Discrepancies Identified During the Process of Marking Up the TS and TS Bases Tennessee Valley Authority - Watts Bar Nuclear Plant - Unit 2, Docket No. 50-391

1. Affected sections: TS 3.3.1 and 3.4.1; TS Bases 3.3.1 and 3.4.1

Background:

Unit 1 TS Amendment 47 amended the Unit 1 TS to allow an alternate method for the measurement of RCS total flow rate via measurement of the RCS elbow tap differential pressures. Unit 1 TS Bases Revision 60 revised the Unit 1 TS Bases to implement the changes made by Amendment 47.

The review matrix for Developmental Revision A stated the following for each section:

x TS 3.3.1: The changes will be applied to Unit 2.

x TS Bases 3.3.1: The changes will be applied to Unit 2.

x TS 3.4.1: The changes will be applied to Unit 2.

x TS Bases 3.4.1: The changes will be applied to Unit 2.

Discrepancy:

The changes should not have been incorporated in Developmental Revision A of the Unit 2 TS and TS Bases because the elbow tap differential pressure measurement method is not being used on Unit 2.

Corrective Action(s):

Developmental Revision B of the Unit 2 TS and TS Bases deleted the changes incorporated per Unit 1 TS Amendment 47 / Unit 1 TS Bases Revision 60. No further corrective action is required.

2. Affected section: TS Bases 3.6.9

Background:

Unit 1 TS Bases Revision 71 revised the Unit 1 TS Bases to reflect changes to the Unit 1 TS approved by Unit 1 TS Amendment 59 (support steam generator replacement by allowing TEMPORARY use of penetrations in Shield Building Dome during Modes 1-4).

The review matrix for Developmental Revision A stated, This change will NOT be applied to Unit 2.

Discrepancy:

Contrary to the above, a minor portion of Unit 1 TS Bases Revision 71 (i.e., "See TS Bases 3.6.15, Shield Building, for additional information on EGTS.") was incorporated into Developmental Revision A of the Unit 2 TS Bases.

E4-1

ENCLOSURE 4 Discrepancies Identified During the Process of Marking Up the TS and TS Bases Tennessee Valley Authority - Watts Bar Nuclear Plant - Unit 2, Docket No. 50-391 Corrective Action:

Since this wording is nothing more than an aid to indicate where additional information on EGTS can be found, leaving this statement in the Unit 2 TS Bases has no impact on the Bases.

The wording will be left in the Unit 2 TS Bases; no further corrective action is required.

3. Affected section: TS section 3.7.1

Background:

Unit 2 TS Amendment 31 amended the Unit 1 TS to approve Power Uprate using Leading Edge Flow Meter (LEFM).

The review matrix for Developmental Revision A stated, This change will NOT be implemented on Unit 2 at this time.

Discrepancy:

Contrary to this statement, the "58%" value in REQUIRED ACTION A.1 should have remained at "59%."

Corrective Action:

A future Developmental Revision to the Unit 2 TS will correct the "58%" value in TS LCO 3.7.1, REQUIRED ACTION A.1 to "59%."

4. Affected section: TS Bases 3.8.1

Background:

Unit 1 TS Bases Revision 50 revised the Unit 1 TS Bases to reflect changes to the Unit 1 TS approved by Unit 1 TS Amendment 39 (revise LCO 3.8.1's allowed outage time to restore an inoperable emergency diesel generator to operable status from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days).

The review matrix for Developmental Revision A stated, This change will NOT be applied to Unit 2.

Discrepancy:

Contrary to the above, the version showing the changes incorporated for Unit 2 TS Bases 3.8.1 that was provided in Developmental Revision A of the Unit 2 TS Bases included the following verbiage at the end of SR 3.8.1.14:

"Prior to performance of this SR in Modes 1 or 2, actions are taken to establish that adequate conditions exist for performance of the SR. The required actions are defined in Bases Table 3.8.1-2."

E4-2

ENCLOSURE 4 Discrepancies Identified During the Process of Marking Up the TS and TS Bases Tennessee Valley Authority - Watts Bar Nuclear Plant - Unit 2, Docket No. 50-391 This verbiage was not shown in the markup provided for Developmental Revision A of the Unit 2 TS Bases, and should NOT have been incorporated. Table 3.8.1-2 was not added by the markup, and it was not incorporated.

Corrective Action:

A future Developmental Revision to the Unit 2 TS Bases will remove the above wording from the TS Bases for SR 3.8.1.14.

E4-3

ENCLOSURE 5 Commitments Tennessee Valley Authority - Watts Bar Nuclear Plant - Unit 2, Docket No. 50-391

1. A future Developmental Revision to the Unit 2 TS will correct the "58%" value in Unit 2 TS LCO 3.7.1, REQUIRED ACTION A.1 to "59%."

2. A future Developmental Revision to the Unit 2 TS Bases will remove the "Prior to performance of this SR in Modes 1 or 2, actions are taken to establish that adequate conditions exist for performance of the SR. The required actions are defined in Bases Table 3.8.1-2." wording from the TS Bases for SR 3.8.1.14.