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Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 2 of 8
	ML15176A679
Person / Time
Site:	Sequoyah
Issue date:	06/19/2015
From:	; Tennessee Valley Authority
To:	; Office of Nuclear Reactor Regulation
Shared Package
ML15176A678	List: CNL-15-128, Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 8 of 8; ML15176A664; ML15176A679; ML15176A681; ML15176A682; ML15176A688; ML15176A718; ML15176A740; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 1 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 2 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 3 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 4 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 5 of 8; NL-15-128, Sequoyah Nuclear Plants, Units 1 and 2 Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10) - Supplement 2. Part 7 of 8;
References
	SQN-TS-11-10, CNL-15-128
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Licensee Response/NRC Response/NRC Question Closure Id 16 NRC Question Number CSS-001 Select Application NRC Question Closure

Response

Statement

Response

Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation. Follow-up question is KAB001.

Question Closure Date 4/24/2014 Notification Scott Bowman Kristy Bucholtz Michelle Conner Robert Elliott Khadijah Hemphill Lynn Mynatt Lisa Regner Carl Schulten Roger Scott Added By Khadijah Hemphill Date Added 4/24/2014 3:59 PM Date Modified Modified By Page 1 of 1 Sequoyah ITS Conversion Database 8/20/2014 https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=16

ITS NRC Questions Id 29 NRC Question Number CSS-002 Category Technical ITS Section 3.0 ITS Number DOC Number L-1 JFD Number JFD Bases Number Page Number(s)

NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question In order to adopt Technical Specification Task Force (TSTF) Improved Standard Technical Specification (STS) Change Traveler, TSTF-427, "Allowance for Non-Technical Specification Barrier Degradation on Supported System OPERABILITY" (LCO 3.0.9) as part of the Sequoyah conversion, the licensee will need to supplement the application to meet the requirements of the approved TSTF-427.

The availability of the model safety evaluation for this TS improvement was announced in the Federal Register on October 3, 2006 (71 FR 58444) as part of the Consolidated Line Item Improvement Process (CLIIP). The approved TSTF-427 CLIIP identified those requirements that licensees needed to meet in order to receive approval to adopt TSTF-427. It appears that TVA did not provide all of the required information to adopt TSTF-427 in its conversion license amendment request. Specifically, TVA needs to address the following:

1) The licensee needs to either state that the change is consistent with NRC approved Revision 2 toTSTF-427 with no deviations from improved STS, or provide the list of deviations and the technical basis for each deviation;

2) The licensee needs to state that they have reviewed the TSTF-427 documentation and the technical justifications presented in the model SE prepared by the NRC staff, and that the technical justifications presented in the model SE are applicable to Sequoyah Units 1 & 2; and

3) The licensee needs to state that the Technical Specification Bases for Page 1 of 2 Sequoyah ITS Conversion Database 8/20/2014 https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=29

LCO 3.0.9 will be adopted with the license amendment.

In addition, as discussed in the notice of availability published in the Federal Register on October 3, 2006 for this TS improvement, plant-specific regulatory commitments shall be made when adopting TSTF-427, as follows:

1) The licensee commits to the guidance of NUMARC 93-01, Revision 3, Section 11, which provides guidance and details on the assessment and management of risk during maintenance, and

2) The licensee commits to the guidance of NEI 04-08, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY (TSTF-427) Industry Implementation Guidance," March 2006.

Please either revise your application to provide the supporting information/commitments for adoption of TSTF-427, or remove the TSTF-427 elements from your conversion application.

Attach File 1 Attach File 2 Issue Date 5/6/2014 Added By Khadijah Hemphill Date Modified Modified By Date Added 5/6/2014 5:07 PM Notification Scott Bowman Michelle Conner Khadijah Hemphill Andrew Hon Lynn Mynatt Carl Schulten Roger Scott Page 2 of 2 Sequoyah ITS Conversion Database 8/20/2014 https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=29

Licensee Response/NRC Response/NRC Question Closure Id 94 NRC Question Number CSS-002 Select Application Licensee Response Attachment 1 Attachment 1 draft revised 3.0.9 DOC L01.pdf (17KB)

Attachment 2

Response

Statement SQN is adopting TSTF-427, Revision 2, as incorporated in NUREG-1431, Revision 4, with no deviations from Specification LCO 3.0.9. TVA has reviewed the TSTF-427 documentation and the technical justifications presented in the model application safety evaluation prepared by the NRC staff and find that the technical justifications presented are applicable to SQN Units 1 and 2. In addition, TVA will be adopting the LCO 3.0.9 Bases, as indicated in the ITS conversion submittal. The only deviations to the LCO 3.0.9 Bases have been made for clarity and are justified in the Bases Justification for Deviations., Regulatory Commitments, of the ITS submittal contains commitments associated with TSTF-427, as required by the Reviewers Note in NUREG-1431 Bases for LCO 3.0.9. The two commitments included within Enclosure 8 for adoption of TSTF-427 are:

7. Sequoyah Unit 1 & Unit 2 will incorporate the guidance of NUMARC 93-01 Section 11, which provides guidance and details on the assessment of risk during maintenance.

8. Sequoyah Unit 1 & Unit 2 will revise procedures to ensure that the risk assessment and management process described in NEI 04-08 is used whenever a barrier is considered unavailable and the requirements of LCO 3.0.9 are to be applied, in accordance with an overall configuration risk management program (CRMP) to ensure that potentially risk-significant configurations resulting from maintenance and other operational activities are identified and avoided The due dates for the commitments are upon implementation.

Additionally, discussion of change DOC L01 will be revised to include the following paragraph.

SQN is adopting TSTF-427, Revision 2, as incorporated in NUREG-1431, Revision 4, with no deviations from Specification LCO 3.0.9. TVA has reviewed the TSTF-427 documentation and the technical justifications presented in the model application safety evaluation prepared by the NRC staff and find that the technical justifications presented are applicable to Page 1 of 2 Sequoyah ITS Conversion Database 8/20/2014 https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=94

SQN Units 1 and 2. In addition, TVA will be adopting the LCO 3.0.9 Bases, as indicated in the ITS conversion submittal. The only deviations to the LCO 3.0.9 Bases have been made for clarity and are justified in the Bases Justification for Deviations.

See Attachment 1 for the draft revised DOC L01.

Response

Date/Time 6/5/2014 4:00 PM Closure Statement Question Closure Date Notification Scott Bowman Michelle Conner Khadijah Hemphill Andrew Hon Ray Schiele Carl Schulten Added By Scott Bowman Date Added 6/5/2014 3:01 PM Date Modified Modified By Page 2 of 2 Sequoyah ITS Conversion Database 8/20/2014 https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=94

DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY Sequoyah Unit 1 and 2 Page 9 of 10 which the first performance demonstrates the acceptability of the current condition. Such demonstrations should be accomplished within the specified Frequency without extension in order to avoid operation in unacceptable conditions. This change is designated as more restrictive because an allowance to extend Frequencies by 25 percent is eliminated for some Surveillances.

RELOCATED SPECIFICATIONS None REMOVED DETAIL CHANGES None LESS RESTRICTIVE CHANGES L01 CTS Section 3.0 does not contain an allowance when barriers cannot support their support function. The proposed change to CTS 3.0, "LCO Applicability" adds a new LCO 3.0.9. The addition of LCO 3.0.9 to the CTS is to address barriers which cannot perform their related support function for Technical Specification systems. ITS LCO 3.0.9 allows barriers to be able to not perform their safety function for up to 30 days before declaring the supported system inoperable. Furthermore, due to this addition, an allowance is also needed in LCO 3.0.1. This allowance has been added.

Barriers are defined as doors, walls, floor plugs, curbs, hatches, installed structures or components, or other devices, not explicitly described in Technical Specifications, which are designed to provide for the performance of the safety function for the Technical Specification system after the occurrence of one or more initiating events.

The barrier which cannot perform its related support function will be evaluated and managed under the Maintenance Rule plant configuration control requirement, 10 CFR 50.65(a)(4), and the associated industry guidance (NUMARC 93-01, Revision 3). This provision is applicable whether the barrier is affected due to planned maintenance or due to a discovered condition. Should the risk assessment and risk management actions for a specific plant configuration or emergent condition not support the 30 day allowed time, the Maintenance Rule risk management determined allowed time and actions must be implemented or the supported systems LCO be considered not met.

Application of LCO 3.0.9 is dependent on the OPERABILITY of at least one train or subsystem of the supported Technical Specification system and the system's ability to mitigate the consequences of the specified initiating events. However, during the 30 day period allowed by LCO 3.0.9, there exists the possibility that the train or subsystem required to be OPERABLE will unexpectedly become inoperable. Absent any further consideration, this would likely result in both trains of a Technical Specification required system being declared inoperable, Volume 5, Rev. 0, Page 27 of 90, Volume 5, Rev. 0, Page 27 of 90

DISCUSSION OF CHANGES ITS 3.0, LCO AND SR APPLICABILITY Sequoyah Unit 1 and 2 Page 10 of 10 (i.e., the train supported by the barriers to which LCO 3.0.9 was being applied and the emergent condition of the inoperable train). This would likely result in entering LCO 3.0.3 and a rapid plant shutdown. While this scenario is of low likelihood, it is of very high consequence to the licensee and, therefore, should be avoided unless necessary to avoid an actual plant risk. As a result, LCO 3.0.9 contains a provision which addresses the emergent condition of the required OPERABLE train or subsystem becoming inoperable while LCO 3.0.9 is being used. LCO 3.0.9 provides 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to either restore the inoperable train or subsystem or to cease relying on the provisions of LCO 3.0.9 to consider the train or subsystem supported by the affected barrier(s) OPERABLE. This 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months period is not based on a generic risk evaluation, as it would be difficult to perform such an analysis in a generic fashion. Rather, plant risk during this 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowance is managed using the contemporaneous risk assessment and management required by 10 CFR 50.65(a)(4) and recognizes the unquantified advantage to plant safety of avoiding a plant shutdown with the associated transition risk.

A risk impact of the 30 day allowance for barriers was performed. All Sequoyah initiating events are located on the table depicted in TSTF-427 OR Sequoyah has evaluated the use of LCO 3.0.9 for a barrier protecting against an initiating event not on the table located in TSTF-427 and calculated the frequency ranges within the ranges in the table so the above analysis is applicable for those initiators.

Therefore, LCO 3.0.9 can be utilized when inoperable barriers affect Systems, Structures, or Components (SSCs).

L02 CTS 4.0.2 states, "Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval." ITS SR 3.0.2 states, " The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. For Frequencies specified as "once," the above interval extension does not apply. If a Completion Time requires periodic performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance. Exceptions to this Specification are stated in the individual Specifications." This changes the CTS by adding, " If a Completion Time requires periodic performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance." The remaining changes to CTS 4.0.2 are discussed in DOC A10 and DOC M01.

This change is acceptable because the 25 percent Frequency extension given to provide scheduling flexibility for Surveillances is equally applicable to Required Actions that must be performed periodically. The initial performance is excluded because the first performance demonstrates the acceptability of the current condition. Such demonstrations should be accomplished within the specified Completion Time with extension in order to avoid operation in unacceptable conditions. This change is designated as less restrictive because addition time is provided to perform some periodic Required Actions.

, Volume 5, Rev. 0, Page 28 of 90, Volume 5, Rev. 0, Page 28 of 90 Insert 1

Insert 1 SQN is adopting TSTF-427, Revision 2, as incorporated in NUREG-1431, Revision 4, with no deviations from Specification LCO 3.0.9. TVA has reviewed the TSTF-427 documentation and the technical justifications presented in the model application safety evaluation prepared by the NRC staff and find that the technical justifications presented are applicable to SQN Units 1 and 2. In addition, TVA will be adopting the LCO 3.0.9 Bases, as indicated in the ITS conversion submittal. The only deviations to the LCO 3.0.9 Bases have been made for clarity and are justified in the Bases Justification for Deviations.

Licensee Response/NRC Response/NRC Question Closure Id 174 NRC Question Number CSS-002 Select Application NRC Question Closure

Response

Statement

Response

Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.

Question Closure Date 7/16/2014 Notification Robert Elliott Khadijah Hemphill Caroline Tilton Added By Caroline Tilton Date Added 7/16/2014 12:47 PM Date Modified Modified By Page 1 of 1 Sequoyah ITS Conversion Database 8/20/2014 https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=174

ITS NRC Questions Id 31 NRC Question Number CSS-003 Category Technical ITS Section 2.0 ITS Number DOC Number JFD Number JFD Bases Number 1 Page Number (s) 21, 22 NRC Reviewer Supervisor Select Technical Branch POC Add Name Conf Call Requested N NRC Question Sequoyah ITS Section 2.0 Reactor Core SL Bases Background Section Insert 3 references JFD 1 for changes to the Reactor Core Safety Limits Bases Background section. Bases are added that provide in depth discussion (6 new paragraphs) on DNB and its correlation to RCS temperature and pressure. In general, Bases provide a summary statement of the reasons for the technical specification requirements.

JFD1 justifies the changes as: Changes made to the ISTS Bases that reflect the plant specific nomenclature, number, reference, system description, analysis, or licensing basis description.

Please provide the staff the source document reference pertaining to the language added to the RC SL Bases for the staff to verify the Bases are applicable licensing basis description.

Attach File 1 Attach File 2 Issue Date 5/8/2014 Added By Carl Schulten Date Modified Modified By Date Added 5/8/2014 2:29 PM Notification Scott Bowman Michelle Conner Andrew Hon Lynn Mynatt Ray Schiele Carl Schulten Roger Scott Page 1 of 1 Sequoyah ITS Conversion Database 9/17/2014 https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=31

Licensee Response/NRC Response/NRC Question Closure Id 30 NRC Question Number CSS-003 Select Application Licensee Response Attachment 1

Attachment 2

Response

Statement The new paragraphs (Insert 3 in the ITS submittal) added to the Bases Background Section of ITS 2.1.1, Reactor Core SLs, reflect the SQN CTS Bases revised as part of SQNs license amendment to allow the use of Areva Advanced W17 High Thermal Performance Fuel. The NRC issued Amendments 331 (Unit 1) and 324 (Unit 2) (ML12249A394) on September 26, 2012, in response to SQNs application dated June 17, 2011 (ML11172A071), as supplemented by letters dated July 27, 2011 (ML11210B531), November 14, 2011 (ML11320A003), March 23 (ML12088A170), April 26 (ML12118A165), May 15 (ML12137A297), May 24 (ML12153A377), and June 26, 2012 (ML121850009).

The paragraphs in the SQN CTS Bases reference Figure 2.1-1. As discussed in DOC LA01, Figure 2.1-1 is being moved to the COLR.

Therefore, in the ITS Bases, the reference to Figure 2.1-1 was replaced with a reference to the COLR.

Response

Date/Time 5/16/2014 2:00 PM Closure Statement Question Closure Date Notification Scott Bowman Michelle Conner Andrew Hon Lynn Mynatt Ray Schiele Carl Schulten Added By Scott Bowman Date Added 5/16/2014 12:53 PM Date Modified Modified By Page 1 of 1 Sequoyah ITS Conversion Database 9/17/2014 https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=30

Licensee Response/NRC Response/NRC Question Closure Id 329 NRC Question Number CSS-003 Select Application NRC Question Closure

Response

Statement

Response

Date/Time Closure Statement This question is closed and no further information is required at this time to draft the Safety Evaluation.

Question Closure Date 9/10/2014 Notification Scott Bowman Michelle Conner Khadijah Hemphill Andrew Hon Lynn Mynatt Ray Schiele Roger Scott Added By Caroline Tilton Date Added 9/10/2014 1:29 PM Date Modified Modified By Page 1 of 1 Sequoyah ITS Conversion Database 9/17/2014 https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=329

ITS NRC Questions Id 33 NRC Question Number CSS-004 Category Technical ITS Section 3.0 ITS Number DOC Number JFD Number JFD Bases Number 3 Page Number(s) 54 NRC Reviewer Supervisor Rob Elliott Technical Branch POC Add Name Conf Call Requested N NRC Question Sequoyah ITS Section 3.0 Bases for LCO 3.0.9 LCO 3.0.9 Bases is revised by JFD3 with the addition of the underlined text below.

Barriers are doors, walls, floor plugs, curbs, hatches, installed structures or components, or other devices, not explicitly described in Technical Specifications, that support the performance of the safety function of systems described in the Technical Specifications. This LCO states that the supported system is not considered to be inoperable solely due to required barriers not capable of performing their related support because discovered function(s) under the described conditions. LCO 3.0.9 allows 30 days before declaring the supported system(s) inoperable and the LCO(s) associated with the supported system(s) not met. A maximum time is placed on each use of this allowance to ensure that as required barriers are found or are otherwise made unavailable, they are restored. However, the allowable duration may be less than the specified maximum time based on the risk assessment.

JFD3 stated the change is made for clarity. The TVA proposed changes are not in accordance with the approved ITS. Please adopt the ITS, and clarify the sentence to read:

A maximum time is placed on each use of this allowance to ensure that required barriers are restored.

Page 1 of 2 Sequoyah ITS Conversion Database 8/20/2014 https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=33

Attach File 1

Attach File 2

Issue Date 5/8/2014 Added By Carl Schulten Date Modified Modified By Date Added 5/8/2014 2:35 PM Notification Scott Bowman Michelle Conner Khadijah Hemphill Andrew Hon Lynn Mynatt Ray Schiele Carl Schulten Roger Scott Page 2 of 2 Sequoyah ITS Conversion Database 8/20/2014 https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=33

Licensee Response/NRC Response/NRC Question Closure Id 31 NRC Question Number CSS-004 Select Application Licensee Response Attachment 1 Attachment 1 draft revised Bases pages for RAI CSS-004.pdf (25KB)

Attachment 2

Response

Statement In response to CSS-004, the proposed change to the ITS Bases for LCO 3.0.9 will be made. Specifically, the ISTS sentence, A maximum time is placed on each use of this allowance to ensure that as required barriers are found or are otherwise made unavailable, they are restored, will be revised in ITS to state, A maximum time is placed on each use of this allowance to ensure that required barriers are restored.

See Attachment 1 for the draft revised Bases pages.

Response

Date/Time 5/16/2014 6:00 PM Closure Statement Question Closure Date Notification Scott Bowman Michelle Conner Khadijah Hemphill Andrew Hon Lynn Mynatt Ray Schiele Carl Schulten Added By Scott Bowman Date Added 5/16/2014 12:57 PM Date Modified Modified By Page 1 of 1 Sequoyah ITS Conversion Database 8/20/2014 https://members.excelservices.com/rai/index.php?requestType=areaItemPrint&itemId=31

LCO Applicability B 3.0 Westinghouse STS B 3.0-13 Rev. 4.0 1

Revision XXX Sequoyah Unit 1 BASES

REVIEWER'S NOTE-----------------------------------

Adoption of LCO 3.0.9 requires the licensee to make the following commitments:

1. [LICENSEE] commits to the guidance of NUMARC 93-01, Revision 3, Section 11, which provides guidance and details on the assessment and management of risk during maintenance.

2. [LICENSEE] commits to the guidance of NEI 04-08, "Allowance for Non Technical Specification Barrier Degradation on Supported System OPERABILITY (TSTF-427) Industry Implementation Guidance," March 2006.

LCO 3.0.9 LCO 3.0.9 establishes conditions under which systems described in the Technical Specifications are considered to remain OPERABLE when required barriers are not capable of providing their related support function(s).

Barriers are doors, walls, floor plugs, curbs, hatches, installed structures or components, or other devices, not explicitly described in Technical Specifications, that support the performance of the safety function of systems described in the Technical Specifications. This LCO states that the supported system is not considered to be inoperable solely due to required barriers not capable of performing their related support function(s) under the described conditions. LCO 3.0.9 allows 30 days before declaring the supported system(s) inoperable and the LCO(s) associated with the supported system(s) not met. A maximum time is placed on each use of this allowance to ensure that as required barriers are found or are otherwise made unavailable, they are restored.

However, the allowable duration may be less than the specified maximum time based on the risk assessment.

If the allowed time expires and the barriers are unable to perform their related support function(s), the supported systems LCO(s) must be declared not met and the Conditions and Required Actions entered in accordance with LCO 3.0.2.

This provision does not apply to barriers which support ventilation systems or to fire barriers. The Technical Specifications for ventilation systems provide specific Conditions for inoperable barriers. Fire barriers are addressed by other regulatory requirements and associated plant programs. This provision does not apply to barriers which are not required to support system OPERABILITY (see NRC Regulatory Issue Summary 2001-09, "Control of Hazard Barriers," dated April 2, 2001).

6 discovered 3

3 3

because that, Volume 5, Rev. 0, Page 54 of 90, Volume 5, Rev. 0, Page 54 of 90

LCO Applicability B 3.0 Westinghouse STS B 3.0-13 Rev. 4.0 1

Revision XXX Sequoyah Unit 2 BASES