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, 2006 Mr. 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 FOR ADDITIONAL 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 your application 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 staff requested 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 NRCs updated approach to this issue, the request for additional information (RAI) originally contained in our letter dated May 19, 2005, is hereby withdrawn and replaced by the RAI enclosed in this letter.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 Force technical 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 instrumentation based 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 being changed by the license amendment request to incorporate a footnote that states:

The as-left instrument setting shall be returned to a setting within the tolerance 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These three items are likewise withdrawn and do not need to be addressed by TVA.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 the enclosed 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 Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosure:

Request for Additional Information cc w/enclosure: See next page

ML060260259 NRR-088 OFFICE LPL2-2/PM LPL2-2/LA BC:CSGB LPL2-2/BC NAME DPickett RSola AHowe MMarshall DATE 2 / 13 / 06 2 / 13 / 06 2 / 14 / 06 3 / 02 / 06 Mr. Karl W. Singer Tennessee Valley Authority SEQUOYAH NUCLEAR PLANT cc:

Mr. Ashok S. Bhatnagar, Senior Vice President Mr. Glenn W. Morris, Manager Nuclear Operations Corporate Nuclear Licensing Tennessee Valley Authority and Industry Affairs 6A Lookout Place Tennessee Valley Authority 1101 Market Street 4X Blue Ridge Chattanooga, TN 37402-2801 1101 Market Street Chattanooga, TN 37402-2801 Mr. Larry S. Bryant, Vice President Nuclear Engineering & Technical Services Mr. Paul L. Pace, Manager Tennessee Valley Authority Licensing and Industry Affairs 6A Lookout Place ATTN: Mr. James D. Smith 1101 Market Street Sequoyah Nuclear Plant Chattanooga, TN 37402-2801 Tennessee Valley Authority P.O. Box 2000 Mr. Robert J. Beecken, Vice President Soddy Daisy, TN 37384-2000 Nuclear Support Tennessee Valley Authority Mr. David A. Kulisek, Plant Manager 6A Lookout Place Sequoyah Nuclear Plant 1101 Market Street Tennessee Valley Authority Chattanooga, TN 37402-2801 P.O. Box 2000 Soddy Daisy, TN 37384-2000 Mr. Randy Douet Site Vice President Senior Resident Inspector Sequoyah Nuclear Plant Sequoyah Nuclear Plant Tennessee Valley Authority U.S. Nuclear Regulatory Commission P.O. Box 2000 2600 Igou Ferry Road Soddy Daisy, TN 37384-2000 Soddy Daisy, TN 37379 General Counsel Mr. Lawrence E. Nanney, Director Tennessee Valley Authority Division of Radiological Health ET 11A Dept. of Environment & Conservation 400 West Summit Hill Drive Third Floor, L and C Annex Knoxville, TN 37902 401 Church Street Nashville, TN 37243-1532 Mr. John C. Fornicola, Manager Nuclear Assurance and Licensing County Mayor Tennessee Valley Authority Hamilton County Courthouse 6A Lookout Place Chattanooga, TN 37402-2801 1101 Market Street Chattanooga, TN 37402-2801 Ms. Ann P. Harris 341 Swing Loop Road Rockwood, Tennessee 37854

REQUEST FOR ADDITIONAL INFORMATION SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 TECHNICAL SPECIFICATIONS CHANGES FOR NOMINAL TRIP SETPOINTS FOR REACTOR PROTECTION SYSTEM AND ENGINEERED SAFETY FEATURES INSTRUMENTATION DOCKET NOS. 50-327 AND 50-328

1. Setpoint Calculation Methodology: Provide documentation (including sample calculations) of the methodology used for establishing the limiting nominal setpoint and the 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 the setpoint is a limiting safety system setting for a variable on which a SL has been placed as discussed in Title 10 of the Code of Frederal Regulations (10 CFR) Part 50.36(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 basis for this determination.

3. For setpoints that are determined to be SL-Related: The NRC letter to the Nuclear Energy 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 the September 7, 2005, letter. If you do not plan to adopt the suggested SRTS, then explain how you will ensure compliance with 10 CFR 50.36 by addressing items 3b and 3c, below.

b. As-Found Setpoint Evaluation: Describe how surveillance test results and associated TS limits are used to establish operability of the safety system. Show that this evaluation is consistent with the assumptions and results of the setpoint calculation 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 ENCLOSURE

criteria for determining operability of the instrument being tested 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.

c. As-Left Setpoint Control: Describe the controls employed to ensure that the instrument setpoint is, upon completion of surveillance testing, consistent with the 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 to Question 2: Describe the measures to be taken to ensure that the associated instrument 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 operability requirements.