ML060400472

License Amendment, Issuance of Amendment Safety Features Actuation System Instrumentation Setpoints and Surveillance Testing Requirements, MC3084

ML060400472
Person / Time
Site:	Davis Besse
Issue date:	08/09/2006
From:	Campbell S J NRC/NRR/ADRO/DORL/LPLIII-2
To:	Bezilla M B FirstEnergy Nuclear Operating Co
Sands, S, NRR/DPLM/LPD III-2, 415-315
Shared Package
ML060400485	List: ML060400472 ML062230087
References
TAC MC3084
Download: ML060400472 (14)

Text

August 9, 2006Mr. Mark B. BezillaVice President FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station Mail Stop A-DB-3080 5501 North State Route 2 Oak Harbor, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 - ISSUANCE OF AMENDMENT RE: SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SETPOINTS AND SURVEILLANCE TESTING REQUIREMENTS (TAC NO. MC3084)

Dear Mr. Bezilla:

The Commission has issued the enclosed Amendment No. 275 to Facility Operating LicenseNo. NPF-3 for the Davis-Besse Nuclear Power Station, Unit 1. The amendment revises the Technical Specifications (TSs) in response to your application dated May 5, 2004, as supplemented by letters dated January 17, October 10, and November 2, 2005 and May 30, 2006.The amendment revises TS Table 1.2, ?Frequency Notation"; TS 3/4.3.2, ?Safety SystemInstrumentation" -

?Safety Features Actuation System Instrumentation"; TS 3/4.3.2.1 Table 3.3-3, ?Safety Features Actuation System Instrumentation"; TS 3/4.3.2.1 Table 3.3-4, ?SafetyFeatures Actuation System Trip Setpoints"; and TS 3/4.3.2.1 Table 4.3-2, ?Safety FeaturesActuation System Instrumentation Surveillance Requirements."A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in theCommission's next biweekly Federal Register notice.Sincerely,/RA/Stephen J. Campbell, Project ManagerPlant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-346

Enclosures:

1. Amendment No. 275 to NPF-3

2. Safety Evaluationcc w/encls: See next page Mr. Mark B. BezillaAugust 9, 2006Vice President-Nuclear, Davis-Besse FirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station 5501 North State Route 2 Oak Harbor, OH 43449-9760

SUBJECT:

DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1 - ISSUANCE OF AMENDMENT RE: SAFETY FEATURES ACTUATION SYSTEM INSTRUMENTATION SETPOINTS AND SURVEILLANCE TESTING REQUIREMENTS (TAC NO. MC3084)

Dear Mr. Bezilla:

The Commission has issued the enclosed Amendment No. 275 to Facility Operating LicenseNo. NPF-3 for the Davis-Besse Nuclear Power Station, Unit 1. The amendment revises the Technical Specifications (TSs) in response to your application dated May 5, 2004, as supplemented by letters dated January 17, October 10, and November 2, 2005 and May 30, 2006.The amendment revises TS Table 1.2, ?Frequency Notation"; TS 3/4.3.2, ?Safety SystemInstrumentation" -

?Safety Features Actuation System Instrumentation"; TS 3/4.3.2.1 Table 3.3-3, ?Safety Features Actuation System Instrumentation"; TS 3/4.3.2.1 Table 3.3-4, ?SafetyFeatures Actuation System Trip Setpoints"; and TS 3/4.3.2.1 Table 4.3-2, ?Safety FeaturesActuation System Instrumentation Surveillance Requirements."A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in theCommission's next biweekly Federal Register notice.Sincerely,/RA/Stephen J. Campbell, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-346

Enclosures:

1. Amendment No. 275 to NPF-3

2. Safety Evaluationcc w/encls: See next pageDISTRIBUTION

PUBLICLPL3-2 R/F RidsNrrPMSCampbell RidsNrrDirsItsb RidsOGCRPRidsRgn3MailCenter RidsAcrsAcnwMailCenterGHill (2)RidsNrrLADClarke RidsNrrDorlLpl3-2RidsNrrDeEeib DORL DPRRidsNrrDeEicbPackage Accession Number: ML060400485Amendment Accession Number: ML060400472 TS Accession Number: ML062230087*no legal objectionOFFICELPL3-2/PMLPL3-2/LAEICB/BCEEIB/BCITSB/BCOGC LPL3-2/BC NAMESCampbell:m wDClarkeAHoweGWilsonTKobetzMZobler*DCollinsDATE 8/9 /06 8/9/06 6 / 27 /06 7 / 7 /06 7 / 13 /067 / 25 /068 9 /06 OFFICIAL RECORD COPY Davis-Besse Nuclear Power Station, Unit 1 cc:Manager - Regulatory AffairsFirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station5501 North State - Route 2Oak Harbor, OH 43449-9760Director, Ohio Department of CommerceDivision of Industrial ComplianceBureau of Operations & Maintenance 6606 Tussing Road P.O. Box 4009Reynoldsburg, OH 43068-9009Regional AdministratorU.S. Nuclear Regulatory Commission801 Warrenville RoadLisle, IL 60523-4351Resident InspectorU.S. Nuclear Regulatory Commission5503 North State Route 2 Oak Harbor, OH 43449-9760Barry Allen, Plant ManagerFirstEnergy Nuclear Operating Company Davis-Besse Nuclear Power Station 5501 North State - Route 2Oak Harbor, OH 43449-9760Dennis ClumRadiological Assistance Section SupervisorBureau of Radiation ProtectionOhio Department of Health

P.O. Box 118 Columbus, OH 43266-0118Carol O'Claire, Chief, Radiological BranchOhio Emergency Management Agency 2855 West Dublin Granville RoadColumbus, OH 43235-2206Zack A. ClaytonDERROhio Environmental Protection AgencyP.O. Box 1049 Columbus, OH 43266-0149State of OhioPublic Utilities Commission 180 East Broad StreetColumbus, OH 43266-0573Attorney General Office of Attorney General30 East Broad StreetColumbus, OH 43216President, Board of CountyCommissioners of Ottawa CountyPort Clinton, OH 43252 President, Board of CountyCommissioners of Lucas CountyOne Government Center, Suite 800 Toledo, OH 43604-6506The Honorable Dennis J. KucinichUnited States House of Representatives Washington, D.C. 20515The Honorable Dennis J. Kucinich United States House of Representatives 14400 Detroit Avenue Lakewood, OH 44107 Gary R. LeidichPresident and Chief Nuclear Officer FirstEnergy Nuclear Operating CompanyMail Stop A-GO-1976 South Main Street Akron, OH 44308Joseph J. HaganSenior Vice President of Operations and Chief Operating Officer FirstEnergy Nuclear Operating CompanyMail Stop A-GO-1476 South Main Street Akron, OH 44308David W. Jenkins, AttorneyFirstEnergy Corporation Mail Stop A-GO-18 76 South Main StreetAkron, OH 44308 Davis-Besse Nuclear Power Station, Unit 1 cc:Danny L. PaceSenior Vice President, Fleet Engineering FirstEnergy Nuclear Operating CompanyMail Stop A-GO-1476 South Main Street Akron, OH 44308Manager, Fleet LicensingFirstEnergy Nuclear Operating Company Mail Stop A-GHE-107 395 Ghent RoadAkron, OH 44333Manager, Site Regulatory ComplianceFirstEnergy Nuclear Operating CompanyDavis-Besse Nuclear Power StationMail Stop A-DB-3065 5501 North State Route 2 Oak Harbor, OH 43449-9760Jeannie M. RinckelVice President, Fleet Oversight FirstEnergy Nuclear Operating CompanyMail Stop A-GO-1476 South Main Street Akron, OH 44308 FIRSTENERGY NUCLEAR OPERATING COMPANYANDFIRSTENERGY NUCLEAR GENERATION CORP.DOCKET NO. 50-346DAVIS-BESSE NUCLEAR POWER STATION, UNIT NO. 1AMENDMENT TO FACILITY OPERATING LICENSEAmendment No. 275 License No. NPF-31.The U.S. Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment filed by FirstEnergy Nuclear Operating Companyet al., (the licensee) dated May 5, 2004, as supplemented by letters dated January 17, October 10, and November 2, 2005 and May 30, 2006, complieswith the standards and requirements of the Atomic Energy Act of 1954, asamended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the rules and regulations of the Commission; C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of thepublic, and (ii) that such activities will be conducted in compliance with theCommission's regulations;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment and paragraph 2.C.(2) of FacilityOperating License No. NPF-3 is hereby amended to read as follows: (2)Technical SpecificationsThe Technical Specifications contained in Appendix A, as revised throughAmendment No. 275, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the TechnicalSpecifications. 3.This license amendment is effective as of its date of issuance and shall be implementedwithin 120 days of the date of issuance.FOR THE NUCLEAR REGULATORY COMMISSION/RA/Daniel S. Collins, ChiefPlant Licensing Branch III-2 Division of Operating Reactor LicensingOffice of Nuclear Reactor Regulation

Attachment:

Changes to the Technical SpecificationsDate of Issuance: August 9, 2006 ATTACHMENT TO LICENSE AMENDMENT NO. 275FACILITY OPERATING LICENSE NO. NPF-3DOCKET NO. 50-346Replace the following pages of the Facility Operating License and of the Appendix A TechnicalSpecifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.RemoveInsertLicense Page 4License Page 41-81-83/4 3-93/4 3-93/4 3-113/4 3-11 3/4 3-133/4 3-13 3/4 3-213/4 3-213/4 3-223/4 3-22 2.C.This license shall be deemed to contain and is subject to theconditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41of Part 40, Sections 50.54 and 50.59 of Part 50, and Section 70.32of Part 70; and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditionsspecified or incorporated below:(1)Maximum Power LevelFENOC is authorized to operate the facility at steady state reactorcore power levels not in excess of 2772 megawatts (thermal).

Prior to attaining the power level, Toledo Edison Company shall comply with the conditions identified in Paragraph (3) (o) belowand complete the preoperational tests, startup tests and otheritems identified in Attachment 2 to this license in the sequence specified. Attachment 2 is an integral part of this license.(2)Technical SpecificationsThe Technical Specifications contained in Appendix A, asrevised through Amendment No. 275, are hereby incorporatedin the license. FENOC shall operate the facility inaccordance with the Technical Specifications.(3)Additional ConditionsThe matters specified in the following conditions shall becompleted to the satisfaction of the Commission within the stated time periods following the issuance of the license orwithin the operational restrictions indicated. The removalof these conditions shall be made by an amendment to the license supported by a favorable evaluation by the Commission: (a)FENOC shall not operate the reactor in operationalModes 1 and 2 with less than three reactor coolant pumps in operation.(b)Deleted per Amendment 6(c)Deleted per Amendment 5Amendment No. 5,6,133,228 , 275 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 275 TO FACILITY OPERATING LICENSE NO. NPF-3FIRSTENERGY NUCLEAR OPERATING COMPANYFIRSTENERGY NUCLEAR GENERATION CORP.DAVIS-BESSE NUCLEAR POWER STATION, UNIT 1DOCKET NO. 50-34

61.0 INTRODUCTION

By letter to the U.S. Nuclear Regulatory Commission (NRC, the Commission) dated May 5,2004, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML041310374) as supplemented by letters dated January 17 (ADAMS Accession No.ML050210170), October 10 (ADAMS Accession No. ML052870376), and November 2, 2005(ADAMS Accession No. ML053120383), and May 30, 2006 (ADAMS Accession No. ML061520316), FirstEnergy Nuclear Operating Company, et al., (the licensee) requested changes to the technical specifications (TSs) for the Davis-Besse Nuclear Power Station, Unit 1(Davis-Besse). The supplemental letters dated January 17, October 10, and November 2,2005, and May 30, 2006, contained clarifying information and did not change the NRC staff'sinitial proposed finding of no significant hazards consideration.The proposed changes would revise TS 3/4.3.2, "Safety System Instrumentation," setpoints andsurveillance requirements (SRs). Specifically the proposed changes would revise the following specifications:*TS Table 1.2, ?Frequency Notation"*TS 3/4.3.2, ?Safety System Instrumentation" -

?Safety Features ActuationSystem [SFAS] Instrumentation"*TS 3/4.3.2.1 Table 3.3-3, ?Safety Features Actuation System Instrumentation"*TS 3/4.3.2.1 Table 3.3-4, ?Safety Features Actuation System Trip Setpoints"*TS 3/4.3.2.1 Table 4.3-2, ?Safety Features Actuation System InstrumentationSurveillance Requirements"The proposed changes would also add a definition of "annual" frequency for use in the TS, andremove the

?trip setpoint" values for functional unit sequence logic channel "a", "Essential BusFeeder Breaker Trip (90%)," and functional unit sequence logic channel "b", "Diesel Generator Start, Load Shed on Essential Bus (59%)" and rename these trip relays to more accuratelyreflect their design function. The proposed amendment would also revise the "Allowable Values[AV]" entries and would establish annual calibration requirements for these same functional units, consistent with updated calculations and current setpoint methodology.

2.0 REGULATORY EVALUATION

In Section 5.2 of Enclosure 1 of its submittal, the licensee identified the following regulatoryrequirements for this amendment request:General Design Criterion (GDC) 17, "Electric power systems," of Appendix A, to Title 10 of theCode of Federal Regulations (10 CFR) Part 50, requires that nuclear power plants have onsiteand offsite electric power systems to permit the functioning of structures, systems, andcomponents that are important safety. The onsite system is required to have sufficientindependence, redundancy, and testability to perform its safety function, assuming a singlefailure. The offsite power system must be supplied by two physically independent circui ts thatare designed and located so as to minimize, to the extent practical, the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. Inaddition, this criterion requires provisions to minimize the probability of losing electric powerfrom the remaining electric power supplies as a result of loss of power from the nuclear power unit, the offsite transmission network, or the onsite power supplies. GDC 18, "Inspection and testing of electric power systems," of Appendix A, to 10 CFR Part 50,requires that electric power systems that are important to safety must be designed to permitappropriate periodic inspection and testing.The NRC staff finds that the licensee identified the applicable regulatory requirements inSection 5.0 of its May 5, 2004, submittal. The regulatory requirements that the NRC staffconsidered in its review of the application are in 10 CFR Part 50. The system is designed tomeet the requirements specified in GDC 17 and GDC 18 of 10 CFR Part 50, Appendix A.Pursuant to 10 CFR 50.36, ?Technical specifications," TSs include items in the following fivespecific categories related to station operation: (1) safety limits, limiting safety system settings,and limiting control settings; (2) limiting conditions for operation (LCOs); (3) SRs; (4) designfeatures; and (5) administrative controls. The rule does not specify the particular requirementsto be included in a plant's TSs. As stated in 10 CFR 50.36(c)(2)(i), the

?Limiting conditions foroperation are the lowest functional capability or performance levels of equipment required forsafe operation of the facility. When an LCO of a nuclear reactor is not met, the licensee shallshut down the reactor or follow any remedial action permitted by the technical specification..."

3.0 TECHNICAL EVALUATION

Section 8.3.1, "AC Power System," of the Davis-Besse Updated Safety Analysis Report (USAR)describes the functions of the onsite power systems. Normally, unit power from the maingenerator is supplied to the 4160-volt essential buses via the auxiliary transformer. W hen themain generator is unavailable, offsite power is provided from the Davis-Besse switchyard to the4160-volt essential buses from two redundant startup transformers. A fast bus transfer schemefrom the auxiliary transformer to the startup transformers provides for continued powering of the4160-volt essential buses after the main generator trips off line. The 4160-volt essential buses provide power to various 4160-volt essential loads.The 4160-volt essential bus undervoltage protection is described in USAR Section 8.3.1.1.3,"4160 Volt Auxiliary System." Each 4160-volt essential bus is provided with two levels ofvoltage protection. Four relays per bus at each voltage level (two per functional unit) operatewith coincidental logic to preclude spurious trips of the offsite source. The undervoltage tripsetpoints and associated time delays for the sequence logic channels "Essential Bus Feeder Breaker Trip (90%)" and the "Diesel Generator Start, Load Shed on Essential Bus (59%)," areprovided in TS Table 3.3-4, "Safety Features Actuation System (SFAS) Trip Setpoints". Thetime delays associated with the relays are chosen so as to minimize the possibility that short-duration disturbances will unnecessarily reduce availability of the offsite power source, toassure that the allowable time duration of a degraded voltage condition does not result in failureof safety systems or components, and to assure that the starting times of equipment assumedin the accident analysis are not exceeded. The degraded voltage (90%) relays (DVRs) automatically disconnect the offsite source whenever the bus voltage drops below the relay setpoint for longer than allowed by the relay time delay setpoint. Disconnecting the offsitesource causes the loss of voltage (59%) relays (LVRs) to actuate. The LVRs will lock out theoffsite source, load-shed the bus, and start the associated emergency diesel generator (EDG) whenever the bus voltage drops below the relay setpoint for longer than the relay time delay setpoint. For the DVR and LVR setpoint calculations, the licensee used methods from American NuclearStandards Institute/Instrument Society of America (ANSI/ISA)-S67.04.01-2000, "Setpoints forNuclear Safety Instrumentation." This document was prepared by ISA with a goal of providinguniformity in the field of instrumentation. ANSI/ISA-RP67.04.02-2000 presents guidelines andexamples of methods for the implementation of ANSI/ISA-67.04.01-2000. ANSI/ISA-S67.04.01-2000 definition 3.1 and ANSI/ISA-RP67.04.02-2000 definition 3.1 define the AV as"a limiting value that the trip setpoint may have when tested periodically, beyond whichappropriate action shall be taken." ANSI/ISA-RP67.04.02-2000, paragraph 7.1 furtherinterprets

?appropriate action" as an evaluation for operability. ANSI/ISA-S67.04.01-2000paragraph 4.3.2 states that "the purpose of the AV is to identify a value that, if exceeded, maymean that the instrument has not performed within the assumptions of the setpoint calculation." The licensee's analysis is based on Method 2 from ANSI/ISA-RP67.04.02-2000, Section 7.3. Method 2 determines the AV by calculating the instrument channel uncertainty without includingdrift and uncertainties observed during normal operation. This result is then added to or subtracted from the Analytical Limit (AL) to establish the AV.The current AVs for the DVR voltage, which have been in TSs since 1977, would permitoperation with some motor-operated valves below the minimum voltage required for proper operation as defined in Generic Letter 89-10, "Safety-Related Motor Operated Valve Testingand Surveillance." The licensee determined a lower AL of 3700 volts and an upper AL of 3786volts for the DVR setpoint. The licensee used Method 2 described in ANSI/ISA-RP67.04.02-2000 and determined a lower AV of 3712 volts (dropout) and an upper AV of 3771 volts (pickup). This change reflects updated analyses to ensure the DVRs will not interfere with loadsequencing or EDG breaker closure. The new AVs will also protect against inadvertentactuation of the DVRs. Similarly, the licensee determined the lower AL time delay as 6.21 seconds, which is thebounding acceleration time for the 4160-volt motors due to a SFAS, based on the high pressureinjection motors' start time at 70-percent nominal voltage. The upper AL for the DVR time delay was determined at 8.1 seconds, which is based on a delay time approved in Amendments 7 and 58 of the Davis-Besse TSs, including breaker and generator operational characteristics anduncertainties. The licensee used Method 2 described in ANSI/ISA-RP67.04.02-2000 anddetermined a lower AV of 6.4 seconds and an upper AV of 7.9 seconds. Based on the calculated lower and upper AV for the DVR voltage and time delay, the licenseeproposed that the AV listed in TS table 3.3-4 for the Functional Unit Sequence Logic Channel"a", "Essential Bus Feeder Breaker Trip (90%)," be changed from "> 3558 volts < 7.8 sec" to

"> 3712 volts (dropout) and < 3771 volts (pickup) with a time delay of >

6.4 and < 7.9 sec". The proposed change to the DVR AV will ensure that adequate voltage is available to electricalloads, while minimizing the possibility of inadvertent DVR actuations. For the LVR voltage, to preclude undesired interaction between the LVR and the EDG loadsequence, the upper AL was established at the minimum EDG transient analysis voltage,including margin applied in the transient analysis. The licensee determined the upper AL at2500 volts, which includes margins for analysis uncertainties. The licensee used Method 2 described in ANSI/ISA-RP67.04.02-2000 and determined an AV of 2492 volts. The licensee did not propose a change for the LVR lower AV voltage and, therefore, a lower AV was notcalculated. Similarly, the licensee established the LVR AL for time delay at a level equal to the current AVof 0.6 second, which accounts for the combined DVR response time using the AL for each relay(DVR, LVR, dead bus timer). The new lower AL is intended to preclude spurious trips due totransient events that may occur on the transmission system or within the onsite electricaldistribution system. The licensee determined a lower AL of 0.4 second and an upper AL of0.6 seconds. The licensee analytically calculated the channel uncertainties using the samemethods as previously described for the DVR time delay. The lower AV was determined to be0.42 second and the upper AV was determined to be 0.58 second. Based on the calculated lower and upper AV for the DVR voltage and time delay, the licenseeproposed that the AV listed in TS Table 3.3-4 for the "Allowable Value" for Functional UnitSequence Logic Channel "b", "Diesel Generator Start, Load Shed on Essential Bus (59%)", be changed from ">

2071 and < 2450 volts for 0.5 +/- 0.1 sec" to "> 2071 volts (dropout) and <

2492volts (pickup) with a time delay of >

0.42 and < 0.58 sec". This change reflects updatedsetpoint and EDG transient response analyses to ensure that the LVRs will not interfere withload sequencing or EDG operation.The NRC staff reviewed Regulatory Guide 1.105, Revision 3, "Setpoints for Safety-RelatedInstrumentation," and determined that the guide endorses the use of ANSI/ISA-S67.04-1994 asan acceptable method for determining safety-related setpoints. The NRC staff reviewedANSI/ISA-67.04-01-2000 and ANSI/ISA-RP-67.04.02-2000 and determined that the applicableportions of ANSI/ISA-67.04-01-2000 and ANSI/ISA-RP67.04.02-2000 are equivalent to thecorresponding NRC-endorsed sections of ANSI/ISA-S67.04-1994. Additionally, the licensee proposed replacing the words "Trip Setpoints" with "Allowable Values"in the title for Table 3.3-4 and deleting the trip setpoints from this table to be consistent withNUREG-1430, "Standard Technical Specifications for Babcock and Wilcox Pressurized WaterReactors," Revision 2. The NRC staff reviewed current Revision 3, of NUREG-1430 datedJune, 2004. The NUREG specified placing "Allowable Values" in the section describing reactorprotection instrumentation setpoints. The NRC staff determined that this change improved theStandard TSs, which was the intent of the NUREG, and could be applied to SFASinstrumentation setpoints. The licensee maintained that the nominal trip setpoints are specifiedin the setpoint analysis, and are included in the Davis-Besse Relay Setting Manual, a Davis-Besse controlled document. Further, the licensee stated that these trip setpoints will alsobe listed in the USAR and subject to evaluation under the regulatory requirements of 10 CFR 50.59 ?Changes, tests and experiments" prior to changing their values in the future. The NRCstaff determined this administrative change is acceptable. The remaining licensee proposed changes are administrative and editorial in nature and are, therefore, acceptable. The NRC staff issued several requests for additional information (RAIs), each with multiplequestions, and a clarification seeking information from the licensee that demonstrates compliance with GDCs 17 and 18 of 10 CFR Part 50, Appendix A. By letter dated January 17,2005, the licensee submitted a response to an NRC staff question regarding the impact on thesafety-related equipment served by electromechanical LVRs that were replaced with solid state LVRs. The purpose of this RAI was to determined whether clearly defined bases for uncertainties associated with the total instrument uncertainties were calculated for the TS AVs. In their response, the licensee provided a comparison between the original General Electricmodel 12NGV13B25A (NGV) LVR relays and the solid state Asea Brown Boveri LVR relays currently installed. The licensee stated that the original undervoltage relays operated in tandemwith Agastat model 7014PA or model E-7014PA electropneumatic time delay relays set atapproximately 0.5 seconds. The relay manufacturer's (General Electric's) setting band for theNGV relays was70-100 volts. In addition, the time delay settings were significantly affected by temperature variations. These undesirable features were eliminated by replacing the original undervoltage and time delay relays with integrated solid-state time delay harmonic-compensated undervoltage units. The replacement relays provide the same function as theoriginal relays and are qualified for safety-related mild environment applications for use in seismic installations. With respect to the capability of the relays to perform their function, thereplacement relays provide a more accurate setpoint, a more accurate time delay, and a morecomprehensively documented uncertainty basis. This allows a more clearly defined basis foruncertainties associated with the total instrument uncertainties calculated for the TS AVs. This change improved setting accuracy and stability, but the nominal setting values were maintai ned. The NRC staff reviewed the comparison and determined that this LVR replacement improvedsetting accuracy and stability, while maintaining the nominal setting values. The January 17, 2005, letter also addressed an NRC staff question regarding the potentialeffect on the overcurrent relay protection and the pump speed characteristics, considering anydifference between the original relays and the new solid-state relays for both accident and nonaccident conditions. The licensee performed a comprehensive evaluation of several required equipment and overcurrent protective devices. The licensee evaluated any detrimental impacts of the degraded voltage event on potential transformers, current transformers, ground faultrelays, heaters, battery chargers, rectifiers, steam and feedwater rupture control system logiccabinets, motors, contactors, breakers on essential load center transformers, and 480-volt overcurrent protective devices. The licensee stated that the required equipment will start afterthe EDGs restore power and that no potential equipment damage was identified. The NRCstaff determined this is acceptable.

Additionally, the NRC staff issued an RAI clarification involving a footnote to be added to TSTable 4.3-2, regarding returning the as-left setpoint to within the tolerance band of the tripsetpoint. This proposed change was consistent with an NRC position described in a March 31,2005, letter (ADAMS Accession No. ML050870008) to the Nuclear Energy Institute. By letters dated October 10, and November 2, 2005, and May 30, 2006, the licensee proposed to add thisfootnote to TS Table 4.3-2. The proposed footnote would ensure that the as-left setting forthese relays following annual channel calibrations and monthly channel functional tests arewithin the assumptions of the instrument setpoint methodology. This meets the requirements of10 CFR 50.36 and, therefore, is acceptable to the NRC staff. Finally, the NRC staff issued an RAI question that asked whether the licensee declares therelays inoperable, if during channel calibration and functional tests, the results exceed the calibration tolerance and whether this would be added to the licensee's corrective action program. By letters dated October 10 and November 2, 2005, and May 30, 2006, the licenseeresponded that the operability of the tested instruments will be evaluated based on the as-f oundsetting being within the calculated trip setpoint and the calibration tolerance. This will provideassurance that the instrument is functioning within the criteria established in the calculations. The calibration tolerance is smaller compared to uncertainties between the calculated setpointand the AV. The licensee's corrective action program requires the initiation of a conditionreport anytime surveillance acceptance criteria for TS instruments are not met. In addition toequipment trend analysis, the results of the calibrations and functional tests are added to the system engineer's performance book. The licensee's approach to determine instrumentoperability provides assurance that instrument will perform within the calibration limits,therefore, the NRC staff finds this acceptable. Based on its review of the licensee's submittal and their responses to the RAIs, the NRC staffconcludes that the proposed changes are acceptable. Also, the NRC staff reviewed andaccepted the licensee's instrumentation methodology (described in ANSI/ISA-S67.04.01-2000,as mentioned above) including associated calculations. As discussed above, the NRC staff hasevaluated the proposed changes to the TSs. Additionally, the NRC staff concludes that it issafe to operate the plant using the proposed SFAS instrumentation AVs and the proposedchanges to the TSs and SRs. Therefore, the proposed changes meet the requirements of10 CFR 50.36 and GDCs 17 and 18 of 10 CFR Part 50, Appendix A. Based on this conclusion, the NRC staff further concludes that the proposed amendment is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Ohio State official was notified of theproposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

This amendment changes a requirement with respect to installation or use of a facilitycomponent located within the restricted area as defined in 10 CFR Part 20 and changes a surveillance requirement. The NRC staff has determined that the amendment involves nosignificant increase in the amounts, and no significant change in the types, of any effluent thatmay be released offsite, and that there is no significant increase in individual or cumulativeoccupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there has been no publiccomment on such finding (69 FR 32074; June 8, 2004). Accordingly, the amendment meetsthe eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to10 CFR 51.22(b), no environmental impact statement or environmental assessment need beprepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The NRC staff has concluded, based on the considerations discussed above, that: (1) there isreasonable assurance that the health and safety of the public will not be endangered byoperation in the proposed manner, (2) such activities will be conducted in compliance with theCommission's regulations, and (3) the issuance of this amendment will not be inimical to thecommon defense and security or to the health and safety of the public.Principal Contributors: N. Patel H. GargDate: August 9, 2006