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OL - TVA Letter to NRC_06-21-11_TS-TS Bases Comments Response
	ML11187A341
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Site:	Watts Bar
Issue date:	06/21/2011
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To:	; Division of Operating Reactor Licensing
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WBN2Public Resource From: Boyd, Desiree L [dlboyd@tva.gov]

Sent: Tuesday, June 21, 2011 8:22 AM 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_06-21-11_TS-TS Bases Comments Response Attachments: 06-21-11_TS-TS Bases Comments Response_Final.pdf Please see attached TVA letter that was sent to the NRC today.

Some of the enclosures 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: 428 Mail Envelope Properties (7AB41F650F76BD44B5BCAB7C0CCABFAF2015F329)

Subject:

TVA letter to NRC_06-21-11_TS-TS Bases Comments Response Sent Date: 6/21/2011 8:22:19 AM Received Date: 6/21/2011 8:22:53 AM 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 465 6/21/2011 8:22:53 AM 06-21-11_TS-TS Bases Comments Response_Final.pdf 382928 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 June 21, 2011 10 CFR 50.36 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 NRC Docket No. 50-391

Subject:

Watts Bar Nuclear Plant (WBN) Unit 2 - Response to NRC Staff Comments on Developmental Revisions of the Unit 2 Technical Specifications (TS) and Technical Specifications Bases (TS Bases); Submittal of Developmental Revision F TVAs letter to NRC dated March 4, 2009 (Reference 1), included Developmental Revision A of the Unit 2 TS and TS Bases. Developmental Revisions B through E were submitted to the NRC by TVAs letters dated February 2, 2010; August 16, 2010; October 12, 2010; and January 27, 2011, respectively (References 2 through 5).

TVAs letter dated February 16, 2011 (Reference 6), provided supplemental information to assist the NRC staff in Review of Developmental Revision A of the Unit 2 TSs and TS Bases.

In mid-April 2011, the NRC staff provided TVA with a CD containing the Unit 2 TS and TS Bases with staff comments noted. Applicable pages from the TS and TS Bases and TVAs response are provided in Enclosures 1 through 4.

A recurring NRC comment concerning TVA not justifying Unit 2s deletion of verbiage similar to movable incore detectors is not included because the staff considered this comment resolved based on TVA input that noted that Unit 2s incore detectors are fixed. For example, Unit 2 Final Safety Analysis Report (FSAR) 4.4.5.1 (Incore Instrumentation) includes core characteristics for all core quadrants using fixed incore neutron detector information.

Enclosures 5 through 8 provide Developmental Revision F of the Unit 2 TS and TS Bases to incorporate changes resulting from TVAs review of the NRC comments.

U.S. Nuclear Regulatory Commission Page 3 June 21, 2011

Enclosures:

1. NRC Comments on Unit 2 Technical Specifications

2. TVA Responses to NRC Comments on Unit 2 Technical Specifications

3. NRC Comments on Unit 2 Technical Specifications Bases

4. TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

5. Proposed Unit 2 Technical Specifications

6. Marked-up Version of Unit 2 Technical Specifications With Justifications for Revisions

7. Proposed Unit 2 Technical Specifications Bases

8. Marked-up Version of Unit 2 Technical Specifications Bases With Justifications for Revisions

9. New Regulatory Commitments

U.S. Nuclear Regulatory Commission Page 4 June 21, 2011 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 5 June 21, 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 NRC Comments on Unit 2 Technical Specifications

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

1. Page number / Item:

3.2-9 and 3.2-10 / AND between REQUIRED ACTIONS A.4 and A.5.

NRC Comment(s):

Move the AND from the top of page 3.2-10 to the bottom of page 3.2-9.

TVA Response(s):

Developmental Revision F of the Unit 2 TS moves the AND from the top of page 3.2-10 to the bottom of page 3.2-9.

A search of the Unit 2 TS for the same issue on other pages resulted in the same changes being made to the following page pairs: 3.4-30 / 3.4-31 and 3.8-1 / 3.8-2.

2. Page number / Item:

3.3-5 / REQUIRED ACTION N.2 NRC Comment(s):

Discrepancy: U1 A68 (TSTF-169) shows P-8 revised to P-7.

TVA Response(s):

Amendment 68 to the Unit 1 TS revised P-8 to P-7. The review matrix provided by Reference 1 noted that changes made by Amendment 68 would be implemented on Unit 2.

This change was inadvertently missed.

Developmental Revision F of the Unit 2 TS revises TS LCO 3.3.1, REQUIRED ACTION N.2 to read, Reduce THERMAL POWER to < P-7. instead of Reduce THERMAL POWER to

< P-8.

3. Page number / Item:

3.3-15 / ALLOWABLE VALUE column for items 3.a. and 4. (three places)

NRC Comment(s):

RTP is split such that R is at the end of the first line and TP is on the next line.

TVA Response(s):

Developmental Revision B of the Unit 2 TS inadvertently caused formatting issues such as this one.

Developmental Revision F of the Unit 2 TS corrects font size and column widths in affected instrumentation tables. Change bars are not shown for these format changes.

E2-1

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

4. Page number / Item:

3.3-15 / Note (c)

NRC Comment(s):

The following comment is shown for the last two sentences of this note: Revise Note (c) to specify a UFSAR citation.

TVA Response(s):

Developmental Revision F of the Unit 2 TS includes TSTF-493 changes to applicable instrumentation tables and (where applicable) SRs. This comment is addressed by these changes.

5. Page number / Item:

3.3-17 / APPLICABLE MODES ... column for the third line for Item 5.

NRC Comment(s):

(g) is separated from 5 on the previous line.

TVA Response(s):

See the response to Item 3.

6. Page number / Item:

3.3-17 / Note (c), last two sentences NRC Comment(s):

Revise Note (c) to specify a UFSAR citation.

TVA Response(s):

See the response to Item 4.

7. Page number / Item:

3.3-19 / ALLOWABLE VALUE column for Item 10.

NRC Comment(s):

A47 and A68 retained 89.7%. NTSP. JFD-8 (TSTF-493) shown in Bases markup does not apply to AV changes. Bases JFD-7 describes change as specific to Unit 1; Bases text changes AV from % indicated loop flow to % thermal design flow. EICB needs to confirm.

TVA Response(s):

1. Per setpoint calculation WCAP-17044, Rev. 0 (Setpoint Methodology for Watts Bar Unit 2),

the ALLOWABLE VALUE for item 10. Of Unit 2 TS Table 3.3.1-1 (Reactor Coolant Flow -

Low) should be 89.7%. Developmental Revision F of the Unit 2 TS (corrects) this value.

2. TSTF-493 does not apply to this change.

E2-2

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

3. The NTSP and AV units are correctly specified in the TS as % flow.

4. The response to Item 15.b. of Enclosure 4 (TVA Response to NRC Comments on Unit 2 Technical Specifications Bases) addresses the portion of the comment concerning

% indicated loop flow vs. % thermal design flow adjusted for uncertainties (95,000 gpm).

8. Page number / Item:

3.3-19 / Note (c), last two sentences NRC Comment(s):

Revise Note (c) to specify a UFSAR citation.

TVA Response(s):

See the response to Item 4.

9. Page number / Item:

3.3-20 / FUNCTION column for Items 13.a) and 13.b)

NRC Comment(s):

The OR just prior to Item 13.b. should be or.

TVA Response(s):

During TVA meeting with NRC staff on May 10, 2011, it was decided that the OR just prior to Item 13.b. needs to be deleted.

Developmental Revision F of the Unit 2 TS deletes the OR just prior to Item 13.b.

10. Page number / Item:

3.3-20 / ALLOWABLE VALUE column for the first time delay portion of Item 13.a)

NRC Comment(s):

licensee confirmatory item [This comment is for the (Refer to Note 3, Page 3.3-23) verbiage in the column.]

TVA Response(s):

The note is currently on the referenced page. TVA will ensure that this and any other cross-reference type items remain correct throughout the TS / TS Bases process.

E2-3

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

11. Page number / Item:

3.3-20 / SR 3.3.1.10 for Item 14.a.

NRC Comment(s):

Provide plant-specific design to justify not applying footnotes (a) and (b) per TSTF-493.

TVA Response(s):

See the response to Item 4. As part of these changes, the footnotes were added for SR 3.3.1.10 for Item 14.a.

12. Page number / Item:

3.3-20 / ALLOWABLE VALUE column for item 14.b.

NRC Comment(s):

open is split such that o is at the end of the first line and pen is on the next line.

TVA Response(s):

See the response to Item 3.

13. Page number / Item:

3.3-21 / ALLOWABLE VALUE column for item 16.e.

NRC Comment(s):

RTP is split such that R is at the end of the first line and TP is on the next line.

TVA Response(s):

See the response to Item 3.

14. Page number / Item:

3.3-28 / CONDITION J.

NRC Comment(s):

License Amendment No.?

TVA Response(s):

As noted in the TS - TS Bases Review matrix provided by Reference 2, this change was made as a result of Amendment 75 to the Unit 1 TS.

No change is required.

E2-4

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

15. Page number / Item:

3.3-31 / FREQUENCY for SR 3.3.2.5 NRC Comment(s):

JFD7. RAI: Need staff SE approving 18 Frequency for MDR relay tests.

TVA Response(s):

The safety evaluation that approved 18 month frequency for the Potter and Brumfield MDR series relays was documented in NRC to Westinghouse letter dated July 12, 2000, Review of Westinghouse Topical Reports WCAP-13877, Revision 2-P and WCAP-13878-P, Revision 2 on Solid State Protection System (SSPS) Slave Relays (TAC No. MA7264).

The first paragraph of this letter stated, The NRC staff has completed its review of the subject Westinghouse Electric Company (WEC) topical reports (TRs) which were submitted by letter dated November 5, 1999. The NRC staff had previously reviewed and approved Revision 1 of these TRs. A May 31, 1996, letter from Bruce A. Boger of the NRC to Tom Green, Chairman of the Westinghouse Owners Group (WOG), documents the NRC's acceptance of WCAP-13878, Revision 1, and an October 26, 1998, letter from Thomas E. Essig of the NRC to Louis F. Liberatori of the WOG documents the NRC acceptance of WCAP-13877, Revision 1. However, WEC subsequently discovered certain errors in the TRs and therefore submitted Revision 2 of these TRs to the NRC for review and approval. WEC has further determined that the changes do not affect the conclusions of the WCAPs and the NRC safety evaluations. The NRC staff has reviewed the changes and finds them acceptable. The enclosed safety evaluation (SE) confirms the acceptability of the proposed changes.

4.0 (Conclusion) of WCAP-13878, Revision 1, read as follows:

Based on the review of the WCAP-13878, Rev. 1., WCAP-14117, Rev. 1, and WCAP-13900, Rev. 0, the staff concludes that the failure data provided for P&B MDR slave relays support the proposed test interval extension to every refueling outage.

The staff, therefore, finds the above topical reports acceptable for proposed extensions of P&B MDR ESFAS slave relay tests to a refueling outage frequency. However, the staff further concludes that if two or more P&B MDR ESFAS subgroup relays fail in a 12-month period, a referencing licensee should reevaluate the adequacy of the extended surveillance interval. The reevaluation should consider design, maintenance and testing of all P&B MDR ESFAS subgroup relays. If the licensee determines that the surveillance interval is inadequate for detecting a single relay failure, the surveillance interval should be decreased. The revised surveillance interval should be such that the licensee can detect an ESFAS subgroup relay failure prior to the occurrence of a second failure.

Additionally, licensees that use WCAP-13878, Rev. 1 and WCAP-13900, Rev. 0 to implement plant specific TS changes for test interval extensions involving P&B MDR relays for ESFAS slave applications should also:

1. Confirm the applicability of the WCAP-13878, Rev. 1 analyses for their plant.

E2-5

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

2. Ensure that their procurement program for P&B MDR relays is adequate for detecting the types of failures that are discussed in References 9, 10, 11 and 12.

3. Ensure that all pre-1992 P&B MDR relays which are used in either normally energized or a 20% duty cycle have been removed from ESFAS applications.

4. Ensure that the contact loading analysis for P&B MDR relays has been performed to determine the acceptability of these relays.

TVA will address the items in the paragraph as follows: The WBN Maintenance Rule program implements the requirements of 10 CFR 50.65 and provides instructions for initiation, analysis, retrieval, trending, and periodic reporting of data relative to performance indicators of plant systems and components. The program includes guidance for trending and reporting of repetitive preventable failures of functions which are within the scope of the Maintenance Rule.

It also includes performance of cause determinations for failures to meet performance criteria and for repetitive failures. The program assigns plant system engineers responsibility for identifying when performance criteria are not met and increased monitoring under paragraph (a)(1) of the Maintenance Rule is required, along with the corrective actions necessary to restore acceptable performance. The functions performed by the slave relays are in the scope of the program.

Applicable attachment(s) of WBN Technical Instruction TI-119, Maintenance Rule Performance Indicator Monitoring, Trending, And Reporting, will be revised prior to implementation of the approved Unit 2 TS. This procedure change will require that the surveillance interval be evaluated and reduced, when needed, if two or more P&B MDR series relays used for Unit 2 TS LCOs 3.3.2 and 3.3.6 fail within a 12-month interval.

TVA addressed each of the numbered items above as follows:

1. Prior to implementation of the approved Unit 2 TS, TVA will confirm the applicability of the WCAP-13878, Rev. 1 analyses for P&B MDR series relays.

2. Prior to implementation of the approved Unit 2 TS, TVA will develop a Procurement Engineering Group package for procurement of P&B MDR series relays. This document will ensure TVAs procurement program for P&B MDR relays is adequate for detecting the types of failures that are discussed in References 9, 10, 11 and 12 of WCAP-13878, Revision 1.

3. WBN Unit 2 did not install any P&B MDR series relays as SSPS slave relays until the SSPS output cabinet refurbishment in 2010. P&B MDR series relays for the SSPS refurbishment were procured new.

4. Calculation WBNEEBIDQ00209920100002, Rev. 0 (SSPS ESFAS Slave Relay Contact Loading) concludes that the contact loading analysis for P&B MDR relays is acceptable.

E2-6

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

16. Page number / Item:

3.3-33 (page 1 of Table 3.3.2-1) / Note (c), last two sentences NRC Comment(s):

Revise Note (c) to specify a UFSAR citation.

TVA Response(s):

See the response to Item 4.

17. Page number / Item:

3.3-34 (page 2 of Table 3.3.2-1) / Note (c), last two sentences NRC Comment(s):

Revise Note (c) to specify a UFSAR citation.

TVA Response(s):

See the response to Item 4.

18. Page number / Item:

3.3-35 (page 3 of Table 3.3.2-1) / Note (c), last two sentences NRC Comment(s):

Revise Note (c) to specify a UFSAR citation.

TVA Response(s):

See the response to Item 4.

19. Page number / Item:

3.3-36 (page 4 of Table 3.3.2-1) / Note (c), last two sentences NRC Comment(s):

Revise Note (c) to specify a UFSAR citation.

TVA Response(s):

See the response to Item 4.

E2-7

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

20. Page number / Item:

3.3-37 (page 5 of Table 3.3.2-1) / FUNCTION column for Item 6.b.1) and 6.b.2)

NRC Comment(s):

a. The Or between the two time delay items should be or.

b. The OR just prior to Item 6.b.2) should be or.

TVA Response(s):

a. Developmental Revision F of the Unit 2 TS corrects this typographical error.

b. During TVA meeting with NRC staff on May 10, 2011, it was decided that the OR just prior to Item 6.b.2) needs to be deleted.

Developmental Revision F of the Unit 2 TS deletes the OR just prior to Item 6.b.2).

21. Page number / Item:

3.3-37 (page 5 of Table 3.3.2-1) / ALLOWABLE VALUE column for the first time delay portion of Item 6.b.1)

NRC Comment(s):

licensee confirmatory item [This comment is for the (Note 1, Page 3.3-40) verbiage in the column.]

TVA Response(s):

See the response to Item 10.

22. Page number / Item:

3.3-37 (page 5 of Table 3.3.2-1) / Note (c), last two sentences NRC Comment(s):

Revise Note (c) to specify a UFSAR citation.

TVA Response(s):

See the response to Item 4.

23. Page number / Item:

3.3-38 (page 6 of Table 3.3.2-1) / Top of the page NRC Comment(s):

JFD 8. Notes (b) & (c) not reviewed on this page.

TVA Response(s):

Comment withdrawn by NRC staff during May 10, 2011, meeting with TVA.

E2-8

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

24. Page number / Item:

3.3-38 (page 6 of Table 3.3.2-1) / FUNCTION column for Item 7.b.

NRC Comment(s):

The And just prior to the last portion of Item 7.b. should be and.

TVA Response(s):

Developmental Revision F of the Unit 2 TS corrects this typographical error.

25. Page number / Item:

3.3-38 (page 6 of Table 3.3.2-1) / Note (c), last two sentences NRC Comment(s):

Revise Note (c) to specify a UFSAR citation.

TVA Response(s):

See the response to Item 4.

26. Page number / Item:

3.3-39 (showed as page 8 of Table 3.3.2-1; was actually page 9 of Table 3.3.2-1) / Note (c),

last two sentences NRC Comment(s):

Revise Note (c) to specify a UFSAR citation.

TVA Response(s):

Developmental Revision F of the Unit 2 TS includes TSTF-493 changes to applicable instrumentation tables and (where applicable) SRs. This deletes the footnotes for SRs 3.3.2.4 and 3.3.2.9 for Functions 8.b.(1) and 8.b.(2).

The review of TS Table 3.3.2-1 to address this item noted the discrepancy in the (Page X of y) portion of the table header. Developmental Revision F of the Unit 2 TS also corrects this.

E2-9

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

27. Page number / Item:

3.3-46 / Items (f) and (h)

NRC Comment(s):

Justify deviations from WBN1 on this page.

TVA Response(s):

The portion of revision of interest is the replacement of ICCM with Common Q. The TS markup did not provide justification for this change. The markup of the equivalent TS Bases provided the following justification for its changes: Revised for Unit 2 specific configuration.

The marked-up pages for Developmental Revision F of the Unit 2 TS include a corrected markup with the applicable justification.

28. Page number / Item:

3.3-47 / APPLICABILITY NRC Comment(s):

Insert period (.) [following MODES 1, 2, and 3]

TVA Response(s):

Developmental Revision F of the Unit 2 TS corrects this editorial / formatting error with the APPLICABILITY.

A search of the Unit 2 TS for the same issue on other pages resulted in the correction of editorial / formatting error with the APPLICABILITY on the following pages: 3.1-15, 3.4-20, 3.4-18, 3.4-23, 3.4-28, 3.4-38, 3.5-6, 3.6-2, 3.6-22, 3.6-31, 3.7-1, 3.7-18, 3.7-21, 3.7-24, 3.9-1, 3.9-2, and 3.9-3.

29. Page number / Item:

3.3-56 / FREQUENCY for SR 3.3.6.5.

NRC Comment(s):

JFD7. RAI: Need staff SE approving 18 Frequency for MDR relay tests.

TVA Response(s):

See the response to Item 15.

E2-10

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

30. Page number / Item:

3.3-58 / ALLOWABLE VALUE for Item 3.

NRC Comment(s):

WBN1 deviation not justified TVA Response(s):

As noted in the TS - TS Bases Review matrix provided by Reference 2, this portion of the Unit 2 TS was revised to be consistent with change made to Unit 1 TS by Amendment 74.

However, the values in parentheses are not consistent with the Unit 1 values contained in parentheses.

A review of calculations 1-RE-90-130 (Demonstrated Accuracy Calculation For Containment Building Purge And Exhaust Monitors) and 2-RE-090-130 (Containment Building Purge Air Exhaust Monitors) confirms that the ALLOWABLE value for item 3. of TS Table 3.3.6-1 is correct as shown in both the Unit 1 TS and the Unit 2 TS.

The values in parentheses are different for the two units because of differences in the detector sensitivities for the instruments in Units 1 and 2. The cpm values in the Unit 2 TS reflect the preliminary detector sensitivity values provided by the manufacturer. The detector has been assembled and tested, and the final sensitivity value is different from the preliminary value.

TVA will revise the calculation and submit a change to the Unit 2 TS using the manufacturers final detector sensitivity value.

31. Page number / Item:

3.4-1 / B in lower right hand corner (i.e., the revision number)

NRC Comment(s):

Explain what changes were made to Developmental A. Note that TS A47 revised page 3.4-2, but not page 3.4-1.

TVA Response(s):

Comment withdrawn by NRC staff during May 10, 2011, meeting with TVA.

32. Page number / Item:

3.4-2 / SR 3.4.1.4 NRC Comment(s):

A47 change made for WBN1 is deleted for WBN2 TVA Response(s):

The TS - TS Bases Review matrix provided by Reference 2 noted the following for TS 3.4.1:

A47 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. This change will not be made on Unit 2 at this time.

E2-11

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications NRC approved A47 via letter dated 10/03/2003.

The justification provided in Reference 8 for this change provided the following:

Revised to delete TS A47 Reactor Coolant System Flow Measurement Using Elbow Tap Methodology and associated open item in TS 3.4 Bases:

In TS A47, NRC approved the use of an alternative method for measurement of reactor coolant system (RCS) total flow rate via measurement of the RCS elbow tap differential pressures ('p).

Unit 2 may implement the elbow tap methodology at a future date; however, for now, Unit 2 will use the precision calorimetric flow measurement methodology.

No change is required.

33. Page number / Item:

3.4-9 / NOTE NRC Comment(s):

SRXB Confirmatory item points toward the COMS arming temperature specified in the PTLR.

TVA Response(s):

Reference 7 provided the responses to several of the required action items contained in Appendix HH of NUREG-0847, Supplement 22, Safety Evaluation Report Related to the Operation of Watts Bar Nuclear Plant, Unit 2.

Required action 45. and the response to it from that letter were:

45. TVA stated in its response to RAI 5.3.2-2, dated July 31, 2010, that the PTLR would be revised to incorporate the COMS arming temperature. (Section 5.3.2)

Response: Revision 1 (effective August 12, 2010) to the Unit 2 System Description for the Reactor Coolant System (WBN2-68-4001) was revised to reflect the required revisions to the PTLR. Appendix B, Section 3.2 (Arming Temperature) states, COMS shall be armed when any RCS cold leg temperature is <225°F.

This is a Confirmatory item for the NRC.

No change is required.

E2-12

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

34. Page number / Item:

3.4-12 / NOTE 2.

NRC Comment(s):

SRXB Confirmatory item points toward the COMS arming temperature specified in the PTLR.

TVA Response(s):

See the response to item 33.

35. Page number / Item:

3.4-18 / APPLICABILITY, NOTE, and REQUIRED ACTION B.2 NRC Comment(s):

SRXB Confirmatory item points toward:

x ... > the COMS arming temperature specified in the PTLR. in the APPLICABILITY; x the COMS arming temperature specified in the PTLR in NOTE 2; and x with any RCS temperature < the COMS arming temperature specified in the PTLR. In REQUIRED ACTION B.2.

TVA Response(s):

See the response to item 33.

36. Page number / Item:

3.4-23 / APPLICABILITY NRC Comment(s):

SRXB Confirmatory item points toward ... < the COMS arming temperature specified in the PTLR. in the APPLICABILITY.

TVA Response(s):

See the response to item 33.

37. Page number / Item:

3.4-24 / REQUIRED ACTION D.1 NRC Comment(s):

SRXB Confirmatory item points toward > the COMS arming temperature specified in the PTLR.

TVA Response(s):

See the response to item 33.

E2-13

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

38. Page number / Item:

3.4-25 / CONDITION E.

NRC Comment(s):

SRXB Confirmatory item points toward ... < the COMS arming temperature specified in the PTLR.

TVA Response(s):

See the response to item 33.

39. Page number / Item:

3.4-27 / NOTE for SR 3.4.12.7 NRC Comment(s):

SRXB Confirmatory item points toward ... < the COMS arming temperature specified in the PTLR.

TVA Response(s):

See the response to item 33.

40. Page number / Item:

Pages 3.4-30 and 3.4-31 / AND between REQUIRED ACTIONS A.1 and A.2.

NRC Comment(s):

Move the AND from the top of page 3.4-31 to the bottom of page 3.4-30.

TVA Response(s):

See the response to Item 1.

41. Page number / Item:

3.4-33 / LCO 3.4.15, portion 2.

NRC Comment(s):

No deviations result from markup. Why is this Developmental B?

TVA Response(s):

The second page of the cover letter for Reference 2 noted, The Developmental Revision B of the TS and TS Bases was compared to the WBN Unit 1 TS and TS Bases through Amendment 82 and Revision 100, respectively.

The TS - TS Bases Review matrix provided by Reference 2 noted the following:

A71 amended the Unit 1 TS to remove the operability requirement for the containment atmospheric gaseous radiation monitor. This change is to be applied to Unit 2.

E2-14

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications NRC approved A71 via letter dated 11/25/2008.

No change is required.

42. Page number / Item:

3.4-34 / SR 3.4.15.2 NRC Comment(s):

Make change per LCO 3.4.15.2. Make conforming change to WNB1.

TVA Response(s):

Developmental Revision F of the Unit 2 TS deletes level from SR 3.4.15.2 to be consistent with the requirements of LCO 3.4.15.

43. Page number / Item:

3.5-1 / COMPLETION TIME for REQUIRED ACTION B.1 NRC Comment(s):

JFC Rev B TS/TS Bases 3.5, item 1 TVA Response(s):

The TS - TS Bases Review matrix provided by Reference 2 noted the following:

A81 amended the Unit 1 TS to extend the Completion Time for TS LCO 3.5.1, Condition B from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This change is to be applied to Unit 2.

NRC approved A81 via letter dated 09/09/2009.

Reference 8 provided the following justification for the change to page 3.5-1:

A81 amended the Unit 1 TS to extend the Completion Time for TS LCO 3.5.1, Condition B from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . R98 made the associated changes to the Unit 1 TS Bases.

These changes are to be applied to Unit 2.

NRC approved A81 via letter dated 09/09/2009.

No change is required.

44. Page number / Item:

3.5-2 / > 1000 psig portion of SR 3.5.1.5 NRC Comment(s):

Need to justify deviation from Unit 1 which includes TPBARs. Revise page to Developmental B.

E2-15

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications TVA Response(s):

This value has not been revised since the initial approval / issuance of the Unit 1 TS; Unit 2 TS is consistent with the Unit 1 TS.

During TVA meeting with NRC staff on May 10, 2011, it was noted that this comment should have been made against SR 3.5.1.4.

Unit 2s SR 3.5.1.4 is different than Unit 1s because the Unit 1 version includes information concerning the number of TPBARS. The boron concentration ranges are the same.

Information previously provided concerning Unit 1 TS Amendments to this SR include:

a. The review matrix provided by Reference 1 noted:

A40 amended the Unit 1 TS to allow Watts Bar to irradiate up to 2304 Tritium Producing Burnable Absorber Rods (TPBARs) in the reactor core each fuel cycle. TPBARS will NOT be used on Unit 2.

NRC approved A40 via letter dated 09/23/2002.

A48 amended the Unit 1 TS to revise the boron concentration requirements and limit the number of Tritium Producing Burnable Absorber Rods (TPBARs) that could be loaded and irradiated in the core to a corresponding value. TPBARS will NOT be used on Unit 2.

NRC approved A48 via letter dated 10/08/2003.

A67 amended the Unit 1 TS to revise the maximum number of TPBARs that can be irradiated in the Unit 1 reactor core to 400. TPBARS will NOT be used on Unit 2; however, the boron concentration changes per this amendment will be used on Unit 2.

NRC approved A67 via letter dated 01/18/2008.

b. The TS - TS Bases Review matrix provided by Reference 2 noted:

A77 amended the Unit 1 TS to revise the maximum number of TPBARs that can be irradiated in the Unit 1 reactor core to 704. TPBARS will NOT be used on Unit 2.

NRC approved A77 via letter dated 05/04/2009.

No change is required.

E2-16

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

45. Page number / Item:

3.5-8 / NRCs comment in the upper right hand corner NRC Comment(s):

Justifications for Rev B Changes to TS/TS Bases 3.5 (3.5.1-3.5.5) item 2 references Westinghouse letter WBT-D-1177 dated October 19, 2009 as affecting TS 3.5.4 (see report page E2-3 of 11). Justify why RWST TS are unchanged from Developmental A.

TVA Response(s):

The only change made to the Bases for 3.5.4 was minor and did not use a Westinghouse letter as justification.

No change is required.

46. Page number / Item:

3.6-8 / REQUIRED ACTION A.2, NOTE 2.

NRC Comment(s):

Matches U1 RA A.2 Notes. Why is this Developmental B?

TVA Response(s):

The second page of the cover letter for Reference 2 noted, The Developmental Revision B of the TS and TS Bases was compared to the WBN Unit 1 TS and TS Bases through Amendment 82 and Revision 100, respectively.

Additionally, the TS - TS Bases Review matrix provided by Reference 2 provided the following:

A79 amended the Unit 1 TS to allow administrative means of position verification for locked or sealed containment isolation valves. This change is to be applied to Unit 2.

NRC approved A79 via letter dated 09/30/2009.

No change is required.

47. Page number / Item:

3.6-9 / REQUIRED ACTION C.2, NOTE 2.

NRC Comment(s):

Matches U1 RA C.2 Notes. Why is this Developmental B?

TVA Response(s):

See the response to Item 46.

E2-17

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

48. Page number / Item:

3.6-12 / SR 3.6.3.2 and SR3.6.3.3 NRC Comment(s):

Matches U1. Why Developmental B?

TVA Response(s):

See the response to Item 46.

49. Page number / Item:

3.7-1 / REQUIRED ACTION A.1 NRC Comment(s):

59 is from U1 A31 which is not in U2.

TVA February 16, 2011 Letter, Enclosure 5, Commitments, Item #1, future Developmental Revision to revise the RTP value in Required Action A.1.

TVA Response(s):

Item 1 of Enclosure 5 of Reference 3 stated, 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%.

Developmental Revision F of the Unit 2 TS corrects the "58%" value in Unit 2 TS LCO 3.7.1, REQUIRED ACTION A.1 to "59%."

50. Page number / Item:

3.7-14 / REQUIRED ACTION A.1 NRC Comment(s):

Spell out ERCW.

TVA Response(s):

Unit 2 TS is consistent with Unit 1 TS.

No change is required.

E2-18

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

51. Page number / Item:

3.8-2 / as indicated NRC Comment(s):

a. Just after REQUIRED ACTION A.3: Confirmatory

b. CONDITION B.: Justify Unit 2 difference. [two places]

c. lower right corner of page: Verify Unit 2 deviation.

TVA Response(s):

a. This is a Confirmatory item for the NRC.

No change is required.

b. The TS - TS Bases Review matrix provided by Reference 2 provided the following:

A request was submitted to the NRC via letter dated 11/30/2009 to change the AOT from 14 days to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This change was made to Unit 2 TS in revision A.

This information is being provided for continuity purpose.

Reference 8 provided the following justification for the changes to this page: Deleted required from Condition B to remain consistent with TVA license amendment request submittal dated November 30, 2009 (ADAMS Accession ML093640790), requesting a similar change for Unit 1.

The NRC approved the requested changes for Unit 1 as Unit 1 TS Amendment 84 on July 6, 2010 (ADAMS Accession No. ML101390154). Developmental Revision B of the Unit 2 TS is the same as that approved by the NRC in Unit 1 TS Amendment 84.

c. This is a Confirmatory item for the NRC.

No change is required.

E2-19

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

52. Page number / Item:

4.0-1 / 4.2.1 NRC Comment(s):

Justify U2 deviation.

TVA Response(s):

The TS - TS Bases Review matrix provided by Reference 2 provided the following:

Reference 8 provided the following justification for this change: To provide accurate information for fuel composition. The revised information is consistent with information provided in FSAR 4.0.

No change is required.

53. Page number / Item:

4.0-2 / 4.3.1.1.a.

NRC Comment(s):

Justify U2 deviation.

TVA Response(s):

Reference 8 provided the following justification for this change: This is an editorial change; provides consistency with FSAR 4.3.2.7.

During TVA meeting with the NRC staff on May 10, 2011, the decision was made to go back to 5.0 weight percent.

Developmental Revision F of the Unit 2 TS revised 4.95 + 0.05 to 5.0.

E2-20

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

54. Page number / Item:

5.0-16 / 5.7.2.12.d.1.

NRC Comment(s):

Justify U2 deviation.

TVA Response(s):

Reference 8 provided the following justification for this change: Revised various typographical and minor editorial errors.

The version of 5.7.2.12.d.1. prior to the change made per Developmental Revision B of the Unit 2 TS was based on wording approved by NRC for Unit 1 via Amendment 65 on November 3, 2006. The change was based on TSTF-449 and was approved in conjunction with SG replacement.

Per Westinghouse Letter WBT-D-1323, dated December 3, 2009, The Guidelines still require 100% inspection of the tubes during the first In-Service inspection following the first refueling outage ....

Guidelines mean the Steam Generator Program Guidelines, NEI 97-06. Indirectly, this refers also to the EPRI Steam Generator Guidelines, which are six documents referenced in Section 1.5 of NEI 97-06.

No change is required.

E2-21

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications

55. Page number / Item:

5.0-17 / 5.7.2.12.d.2.

NRC Comment(s):

What's the justification for the deviation.

TVA Response(s):

Reference 8 provided the following justification for this change: Corrected / updated information in response to Westinghouse Letter WBT-D-1323, dated December 3, 2009.

The version of 5.7.2.12.d.2. prior to the change made per Developmental Revision B was based on wording approved by NRC for Unit 1 via Amendment 65 on November 3, 2006. The change was based on TSTF-449 and was approved in conjunction with SG replacement.

Per Westinghouse Letter WBT-D-1323, dated December 3, 2009, The inspection intervals in the draft tech spec are appropriate for a plant with alloy 690 thermally treated tubing. Watts Bar 2 has Alloy 600 Mill-Annealed tubing, and the above change makes the tech spec consistent with the guidelines.

A review of TSTF-449, R4 shows that the changes made by Developmental Revision B of the Unit 2 TS match the first proposed version of d.2. in the TSTF. The Unit 1 TS version of this paragraph matches the third (last) proposed version of d.2. in the TSTF.

References to the Guidelines mean the Steam Generator Program Guidelines, NEI 97-06.

Indirectly, this refers also to the EPRI Steam Generator Guidelines, which are six documents referenced in Section 1.5 of NEI 97-06.

Section 5 (Frequency of Verification of SG Tube Integrity) of TSTF-449 includes, The maximum inspection interval requirement for Alloy 600 mill annealed tubing (600MA) is Inspect 100% of the tubes at sequential periods of 60 effective full power months. The first sequential period shall be considered to begin after the first inservice inspection of the SGs.

No SG shall operate for more than 24 effective full power months or one refueling outage (whichever is less) without being inspected. This Frequency is at least as conservative as the current technical specification requirement.

WBN Unit 2 has the original model D3 steam generators, which have Alloy 600 mill-annealed tubing. Thus, the wording proposed for 5.7.2.12.d.2 by Developmental Revision B is that specified by TSTF-493.

No change is required.

56. Page number / Item:

5.0-18 / 5.7.2.14 and 5.7.2.14.a. (three places)

NRC Comment(s):

Justify U2 deviation.

E2-22

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications TVA Response(s):

Reference 8 provided the following justification for the changes on this page: Revised various typographical and minor editorial errors.

The Table 6.5 is not a valid number for either units FSAR. The table numbers provided in Developmental Revision B provide the complete / accurate table numbers for the systems as shown below:

x Table 6.5-1: EGT x Table 6.5-2: ABGT x Table 6.5-3: Reactor Building Purge x Table 6.5-4: Control Room These changes were made for completeness / consistency with the NRC.

No change is required.

57. Page number / Item:

5.0-19 / 5.7.2.14.b.

NRC Comment(s):

Justify U2 deviation.

TVA Response(s):

See the response to Item 56.

58. Page number / Item:

5.0-20 / 5.7.2.14.c.

NRC Comment(s):

Justify U2 deviation.

TVA Response(s):

See the response to Item 56.

59. Page number / Item:

5.0-30 / 5.9.5.2a.

NRC Comment(s):

Justify U2 deviations.

TVA Response(s):

Reference 8 provided the following justification for the change on this page: Corrected /

updated information in response to Westinghouse Letter WBT-D-1177, dated October 19, 2009.

E2-23

ENCLOSURE 2 TVA Responses to NRC Comments on Unit 2 Technical Specifications The revision to 5.9.5.2a. replaced WCAP-12945-P-A with WCAP-16009-P-A. As noted in Section 15.4 of the Unit 2 FSAR:

A LOCA evaluation methodology for three- and four-loop Pressurized Water Reactor (PWR) plants based on the revised10 CFR 50.46 rules was developed by Westinghouse with support of EPRI and Consolidated Edison and has been approved by the NRC (WCAP-12945-P-A

[46]).

More recently, Westinghouse developed an alternative methodology called ASTRUM, which stands for Automated Statistical TReament of Uncertainty Method (WCAP- 16009-P-A [49]).

This method is still based on the CQD methodology and follows the steps in the CSAU methodology (NUREG/CR-5249 [45]). However, the uncertainty analysis (Element 3 in the CSAU) is replaced by a technique based on order statistics. The ASTRUM methodology replaces the response surface technique with a statistical sampling method where the uncertainty parameters are simultaneously sampled for each case. The ASTRUM methodology has received NRC approval for referencing in licensing calculations in WCAP-16009-P-A [49].

No change is required.

60. Page number / Item:

5.0-32 and 5.0-33 / 5.9.6.a. and 5.9.6.c.2 through 5.9.6.c.5 NRC Comment(s):

SRXB confirmation that changes per Westinghouse WBT-D-1342, dated December 10, 2009 are per acceptable.

TVA Response(s):

This is a Confirmatory item for the NRC.

No change is required.

61. Page number / Item:

5.0-34 / 5.9.8 NRC Comment(s):

Validate (Confirm that the or F portion of the first sentence is correct.).

TVA Response(s):

F is the correct reference for the second Condition LCO 3.3.3 that has a REQUIRED ACTION that requires a report per 5.9.8.

Developmental Revision B deleted Condition D. which resulted in Condition G. being renumbered as Condition F. Thus, F is the correct reference.

No change is required.

E2-24

ENCLOSURE 3 NRC Comments on Unit 2 Technical Specifications Bases

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

1. Page number / Item:

B 3.1-10 / Reference 3 NRC Comment(s):

JFD1: Editorial correction. Tech Br. Confirmatory item. Also, Open Pending Receipt of Information is noted at the bottom of the page (i.e., just below Reference 3).

TVA Response(s):

Reference 5 provided the following as the justification for this change: Editorial correction to provide missing information.

No change is required.

2. Page number / Item:

B 3.1-55 / Reference 15.

NRC Comment(s):

Confirmatory approval needed from SCPB.

TVA Response(s):

Reference 5 provided the following justification for this change:

Revised to incorporate the Power Distribution Monitoring System (PDMS) (Reference WCAP-12472-P-A, BEACON Core Monitoring and Operations Support System, August 1994, and WCAP-12472-P-A, BEACON Core Monitoring and Operations Support System, Addendum 2, April 2002).

Amendment 82 amended the Unit 1 TS to implement the Beacon Core Power Distribution and Monitoring System. A change similar to this is to be applied to Unit 2.

NRC approved A82 via letter dated 10/27/2009. The Bases is being revised as needed to agree with the TS amendment.

No change is required.

3. Page number / Item:

B 3.1-62 / References 5 and 8 NRC Comment(s):

Confirmatory approval needed from SCPB.

TVA Response(s):

See response to Item 2.

E4-1

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

4. Page number / Item:

B 3.1-69 / References 5 and 6 NRC Comment(s):

Confirmatory approval needed from SCPB.

TVA Response(s):

Comment withdrawn by NRC staff during May 10, 2011, meeting with TVA.

5. Page number / Item:

B 3.2-10 / Reference 5 NRC Comment(s):

Revision 99 to WBN1 TS Bases per Westinghouse Technical Bulletin 08-04. Technical Branch Confirmatory. Also, Open Pending Receipt of Information is noted at the bottom of the page (i.e., just below Reference 5).

TVA Response(s):

Reference 5 provided the following justification for adding Reference 5:

Revision 99 to the Unit 1 TS Bases revised the Bases to incorporate Westinghouse Technical Bulletin (TB) 08-04. This change is to be applied to Unit 2.

This revision was approved on 10/09/2009.

No change is required.

6. Page number / Item:

B 3.2-13 / change in next to last paragraph NRC Comment(s):

RAI: JFD 3.Editorial correction to delete non-applicable Tech Branch Confirmatory item.

Also, Open Pending Receipt of Information applies to the same change.

TVA Response(s):

Reference 5 provided the following justification for the change to this page: Editorial correction to delete information that is not applicable to the Unit 2 fuel.

No change is required.

E4-2

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

7. Page number / Item:

B 3.2-22 / References 1. and 2.

NRC Comment(s):

Confirmatory approval needed from SCPB.

TVA Response(s):

Comment withdrawn by NRC staff during May 10, 2011, meeting with TVA.

8. Page number / Item:

B 3.2-30 / Reference 4 NRC Comment(s):

Confirmation needed from SCPB.

TVA Response(s):

See response to Item 2.

9. Page number / Item:

B 3.3-4 / middle paragraph NRC Comment(s):

Last sentence should end with behaviour observed during performance of the CHANNEL CHECK. versus behaviour observed furing performance of the CHANNEL CHECK.

TVA Response(s):

Developmental Revision F of the Unit 2 TS Bases replaced behaviour observed furing performance of the CHANNEL CHECK. with behavior observed during performance of the CHANNEL CHECK.

10. Page number / Item:

B 3.3-5 / last paragraph NRC Comment(s):

The last sentence should read, ... (Ref. 5), the NTSP specified in ... instead of ... (Ref. 5),

the Trip Setpoints specified in ...

TVA Response(s):

Developmental Revision F of the Unit 2 TS Bases revised the last sentence to read ...

(Ref. 5), the Allowable Values specified in ... This verbiage is consistent with TSTF-493.

E4-3

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

11. Page number / Item:

B 3.3-6 / middle of first paragraph NRC Comment(s):

Licensee to justify the setpoint basis.

TVA Response(s):

Developmental Revision F of the Unit 2 TS Bases revised the first sentence of the paragraph to read, A detailed description of the methodology used to calculate the Allowable Values, NTSPs, and as left and as found tolerance bands is provided in Reference 2. Reference 2 is Watts Bar FSAR, Section 7.0, Instrumentation and Controls.

12. Page number / Item:

B 3.3-7 / first paragraph NRC Comment(s):

a. In the first sentence, replace as found and as left with as-left and as-found.

b. Add the following after the existing first sentence of this paragraph: NEW PARAGRAPH:

Note that the Allowable Values listed in Table 3.3.1-1 are the least conservative value of the as-found setpoint that a channel can have during a periodic CHANNEL CALIBRATION, CHANNEL OPERATIONAL TESTS, or a TRIP ACTUATING DEVICE OPERATIONAL TEST that requires trip setpoint verification.

c. Add a paragraph break just prior to the existing sentence that begins with Each channel TVA Response(s):

a. TVA has noted inconsistent use of as found, as-found, as left, and as-left.

Developmental Revision F of the Unit 2 TS Bases made changes such that these words are used consistently, and that a hyphen is not used.

b. The noted paragraph to be added already existed as the second paragraph on the page.

Developmental Revision F of the Unit 2 TS Bases deleted the verbiage, Each channel ...

SRs for the channels are specified in the SRs section. from the end of the first paragraph.

End result is that the NRC comment is incorporated.

c. Developmental Revision F of the Unit 2 TS Bases revised this section to align it with the standard and the TSTF changes. The initial incorporation of the TSTF changes resulted in duplication of information and was hard to follow. This paragraph contained information discussed elsewhere in the section, albeit maybe different wording. The cited paragraph was deleted.

E4-4

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

13. Page number / Item:

B 3.3-7 / second paragraph NRC Comment(s):

In the second sentence, replace Trip Setpoint with NTSP.

TVA Response(s):

Developmental Revision F of the Unit 2 TS Bases revised this section to align it with the standard and the TSTF changes. The initial incorporation of the TSTF changes resulted in duplication of information and was hard to follow. This paragraph contained information discussed elsewhere in the section, albeit maybe different wording. The paragraph was deleted.

14. Page number / Item:

B 3.3-9 / last paragraph NRC Comment(s):

Decide if [ ] information is to be retained or deleted.

TVA Response(s):

The TS Bases submitted to the NRC by Reference 1 showed the brackets as being deleted.

The brackets do not apply. Note that the marked-up version which showed the brackets was not submitted.

A search of Developmental Revision E of the Unit 2 TS shows that brackets remain in three locations:

a. page B 3.3-73: This set of brackets should have been removed previously.

Developmental Revision F of the Unit 2 TS Bases deleted this set of brackets.

b. page B 3.6-64: The set of brackets used on this page is used intentionally. This is consistent with the equivalent page in the Unit 1 TS Bases (i.e., page B 3.6-70). This was approved with Unit 1 TS Amendment A33 which was approved by the NRC on November 29, 2001. No change is required.

c. page B 3.6-73: The set of brackets used on this page is used intentionally. This is consistent with the equivalent page in the Unit 1 TS Bases (i.e., page B 3.6-78). This was approved as part of Unit 1 TS Amendment A25 which was approved by the NRC on July 17, 2000. No change is required.

E4-5

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

15. Page number / Item:

B 3.3-23 / second paragraph under item 10 NRC Comment(s):

a. Bases JFD 9 page 7.2-22 FSAR 7.2.2.1.2 Reactor Coolant Flow Measurement The elbow taps used on each loop in the primary coolant system are instrument devices that are used to indicate reactor coolant flow. The basic function of this measurement is to ensure that thermal design flow is achieved.

??For Unit 2, precision colorimetric flow measurement used in lieu of elbow tap methodology. FSAR and TS Bases don't align with JFD 9.??

b. Bases JFD 7 FSAR 15.4.2.1.2 Analysis of Effects and Consequences page 15.4-17 (9) A thermal design flowrate of 372,400 gpm is used which accounts for the 10% steam generator tube plugging level and instrumentation uncertainty.

?? 95,000 gpm doesn't align with 372,400 gpm??

TVA Response(s):

a. The marked-up version of the TS Bases provided by Reference 5 provided the following justification for the changes to the last paragraph of item 10: Revised for Unit 2 specific configuration.

Item (4)(a) (Low Reactor Coolant Flow Trip portion of Reactor Trips) on the bottom of page 7.2-7 of the Unit 2 FSAR discusses this RTS value. The TS, TS Bases, and FSAR are consistent.

No change is required.

b. The change made per Developmental Revision B should not have been made on this page; the previous version was consistent with Unit 1, and was correct.

Developmental Revision F of the Unit 2 TS Bases corrects % thermal design flow adjusted for uncertainties (95,000 gpm) to read, % indicated loop flow. As defined in Unit 2 FSAR Chapter 15, the thermal design flow value of 372,400 gpm is the minimum measured flow minus measurement (instrument) uncertainty. The minimum measured flow value is 380,000 gpm (rounded) or 95,000 gpm/loop. The ALLOWABLE VALUE and NOMINAL TRIP SETPOINT values for item 10. of Unit 2 TS Table 3.3.1-1 are the same for either the precision calorimetric or the elbow tap dp methods of flow measurement.

E4-6

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

16. Page number / Item:

B 3.3-35 / item f.

NRC Comment(s):

a. first paragraph: Markup uses JFD 8 (TSTF-493); provide corrected JFD.

b. last paragraph: Markup uses JFD 8 (TSTF-493); provide corrected TVA Response(s):

a. The change was required due to physical differences in the Unit 1 and Unit 2 turbines. The justification was in error.

No change is required.

b. See response to a.

17. Page number / Item:

B 3.3-54 / as indicated NRC Comment(s):

Last sentence of first paragraph of SR 3.3.1.3: Editorial recommendation.... the use of OPERABLE in the sentence is unnecessary, and begs more questions than it provides answers to.

TVA Response(s):

The use of OPERABLE is consistent with the Unit 1 TS Bases; no change is recommended.

18. Page number / Item:

B 3.3-65 (one for B 3.3.1) / as noted below NRC Comment(s):

a. References 6, 7, 14, and 15: Confirmatory approval from EICB required.

b. Reference 13: Per JFD 9 A47 added the reference to WBN1. Justify the deletion.

TVA Response(s):

a. Reference 5 provided the following justification for the change to Reference 6:

Incorporated Technical Specification Tracking Form (TSTF) 493, R4. This is the reference to the setpoint methodology for Unit 2.

References 7, 14, and 15 were not affected by Developmental Revision B.

No change is required.

E4-7

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

b. Reference 5 provided the following justification for this change:

Revised to delete TS A47 Reactor Coolant System Flow Measurement Using Elbow Tap Methodology and associated open item in TS 3,4 Bases:

In TS A47, NRC approved the use of an alternative method for measurement of reactor coolant system (RCS) total flow rate via measurement of the RCS elbow tap differential pressures ('p).

Unit 2 may implement the elbow tap methodology at a future date; however, for now, Unit 2 will use the precision calorimetric flow measurement methodology.

No change is required.

19. Page number / Item:

B 3.3-65 (one for 3.3.2) / item 3.

NRC Comment(s):

a. 2750 psia should be 2735 psia.

b. Add paragraph break after the first sentence.

TVA Response(s):

a. 2750 psia - 14.7 = 2735 psig.

Unit 2 TS 2.1.2 (RCS Pressure SL) states, In MODES 1, 2, 3, 4, and 5, the RCS pressure shall be maintained 2735 psig.

It is not apparent why the TS uses psig and the TS Bases uses psia; however, they are both correct as is.

The use of 2750 psia in the Bases for 3.3.2 is consistent with the same usage in Unit 1 TS Bases 3.3.1 and Unit 2 TS Bases 3.3.1.

A search of the TS Bases for the RCS pressure SL showed that 2735 psig is used in TS Bases 2.1.2 and 3.4.10.

For consistency and clarity, Developmental Revision F of the Unit 2 TS Bases revised TS Bases 2.1.2, 3.3.1, 3.3.2, and 3.4.10 such that references to the RCS pressure SL use 2735 psig (2750 psia).

b. Developmental Revision F of the Unit 2 TS Bases added the paragraph break as noted.

E4-8

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

20. Page number / Item:

B 3.3-66 / last sentence of last paragraph NRC Comment(s):

a. Replace can be evaluated when its" with is determined by either.

b. Replace are compared against its documented acceptance criteria with evaluated during the CHANNEL CALIBRATION or by qualitative assessment of field transmitter or sensor as related to the channel behavior observed during performance of CHANNEL CALIBRATION.

TVA Response(s):

Developmental Revision F of the Unit 2 TS Bases revised the last sentence to read, The OPERABILITY of each transmitter or sensor is determined by either as found calibration data evaluated during the CHANNEL CALIBRATION or by qualitative assessment of field transmitter or sensor as related to the channel behavior observed during performance of the CHANNEL CHECK.

21. Page number / Item:

B 3.3-67 / third sentence of first paragraph NRC Comment(s):

Replace NTSPs with analytical limits.

TVA Response(s):

Developmental Revision F of the Unit 2 TS Bases replaced, These NTSPs are defined in Reference 6. with Analytical Limits are defined in FSAR ...

22. Page number / Item:

B 3.3-68 / as indicated NRC Comment(s):

a. The first sentence of the first paragraph should read The field setting... instead of The Trip Setpoints ...

b. The first sentence of the second paragraph should read, The trip setpoints ... instead of the Trip Setpoints ...

c. Eleventh line of the second paragraph: Allowable Values and ESFAS points towards NTSPs. [Does this mean to replace the existing wording with the new wording?]

d. Fifteenth line of the second paragraph: Add the following after Reference 6.: The magnitudes of these uncertainties are factored into the determination of each NTSP and corresponding Allowable Value.

E4-9

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

e. Sixth line of the last paragraph: this line should read ... as-left NTSP value is within the as-left tolerance for ... instead of ... as-left setpoint NTSP value is within the band as-left tolerance for ...

TVA Response(s):

a. Developmental Revision F of the Unit 2 TS Bases revised this section to align it with the standard and the TSTF changes. The initial incorporation of the TSTF changes resulted in duplication of information and was hard to follow. This paragraph contained information discussed elsewhere in the section, albeit maybe different wording. The cited paragraph was deleted.

b. Developmental Revision F of the Unit 2 TS Bases revised the sentence to read, The trip setpoints ... instead of the Trip Setpoints ...

c. Developmental Revision F of the Unit 2 TS Bases revised the sentence to read, A detailed description of the methodology used to calculate NTSPs and as left and as found tolerance bands is provided in Reference 2. instead of A detailed description of the methodology used to calculate the NTSPs including their explicit uncertainties, is provided in the Setpoint Methodology for Watts Bar Unit 2 (Ref. 6). Reference 2 is Watts Bar FSAR, Section 7.0, Instrumentation and Controls.

d. As part of the revision to this paragraph made by Developmental Revision F of the Unit 2 TS Bases, parts of two sentences were combined into one which reads, All of the known uncertainties applicable for each channel are factored into the determination of each NTSP and corresponding Allowable Value.

e. Developmental Revision F of the Unit 2 TS Bases revised this sentence to read, Any bistable is considered to be properly adjusted when the as left setpoint NTSP value is within the as left tolerance band for ...

E4-10

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

23. Page number / Item:

B 3.3-69 / second paragraph NRC Comment(s):

COMMENT (JFD7) TADOT surveillances do not have performance NOTES. Why is the TADOT included.

TVA Response(s):

The change implements TSTF-493 for SRs including 3.3.2.8 (i.e., the TADOT for Auxiliary Feedwater start on trip of all Main Feedwater Pumps).

No change is required.

24. Page number / Item:

B 3.3-70 / first and fifth lines of fourth paragraph NRC Comment(s):

Replace device with channel. (two places)

TVA Response(s):

Developmental Revision F of the Unit 2 TS Bases replaced device with channel in the two places.

25. Page number / Item:

B 3.3-72 / as indicated NRC Comment(s):

a. Ninth line of the first paragraph: for [greater than or]:

COMMENT (JFD8) reconcile the application of the bracketed information to WBN-2

b. Third line of the last paragraph: comment sticky is next to [field setting]; however, no comment is contained in it. It appears that the comment for item a. applies here also.

TVA Response(s):

See response to Item 14.

E4-11

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

26. Page number / Item:

B 3.3 second paragraph NRC Comment(s):

What is amendment made these Bases changes?

TVA Response(s):

Reference 5 provided the following justification: Incorporated Technical Specification Tracking Form (TSTF) 493, R4.

No change is required.

27. Page number / Item:

B 3.3-96 / last paragraph NRC Comment(s):

License amendment No.?

TVA Response(s):

Reference 5 provided the following justification:

A75 amended the Unit 1 TS to modify the TS requirements related to Mode 1 and 2 applicability for Function 6.e of TS Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, and the Bases for TS 3.3.2. In addition, Limiting Condition for Operation (LCO) 3.3.2, Condition J, has been revised to be consistent with the design basis for WBN Unit 1.

This change is to be applied to Unit 2.

The NRC approved A75 in a letter dated March 4, 2009.

No change is required.

28. Page number / Item:

B 3.3-97 / first paragraph NRC Comment(s):

License amendment No.?

TVA Response(s):

See the response to Item 27.

E4-12

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

29. Page number / Item:

B 3.3-107 / second paragraph, last two sentences NRC Comment(s):

OPEN ITEM U1/U2: WCAP-14333 (Ref 17) did not approve testing a channel in bypass with the inoperable channel also in bypass.

TVA Response(s):

The Unit 1 TS were issued by an NRC to TVA letter dated November 9, 1995 (Issuance of Facility Operating License No. NPF-20, Watts Bar Nuclear Plant, Unit 1 [TAC M91489]).

ACTIONS E.1, E.2.1, and E.2.2 of Revision 0 of the Unit 1 TS Bases read as follow:

Condition E applies to:

Containment Spray Containment Pressure-High High; Steam Line Isolation Containment Pressure-High High; and Containment Phase B Isolation Containment Pressure-High High.

None of these signals has input to a control function. Thus, two-out-of-three logic is necessary to meet acceptable protective requirements. However, a two-out-of-three design would require tripping a failed channel. This is undesirable because a single failure would then cause spurious containment spray initiation. Spurious spray actuation is undesirable because of the cleanup problems presented. Therefore, these channels are designed with two-out-of four logic so that a failed channel may be bypassed rather than tripped. Note that one channel may be bypassed and still satisfy the single failure criterion. Furthermore, with one channel bypassed, a single instrumentation channel failure will not spuriously initiate containment spray.

To avoid the inadvertent actuation of containment spray and Phase B containment isolation, the inoperable channel should not be placed in the tripped condition. Instead it is bypassed.

Restoring the channel to OPERABLE status, or placing the inoperable channel in the bypass condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , is sufficient to assure that the Function remains OPERABLE and minimizes the time that the Function may be in a partial trip condition (assuming the inoperable channel has failed high). The Completion Time is further justified based on the low probability of an event occurring during this interval. Failure to restore the inoperable channel to OPERABLE status, or place it in the bypassed condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , requires the plant be placed in MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 4 within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODE 4, these Functions are no longer required OPERABLE.

The Required Actions are modified by a Note that allows one additional channel to be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing. Placing a second channel in the bypass condition for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for testing purposes is acceptable based on the results of Reference 7.

Reference 7 was WCAP-10271-P-A, Supplement 1 and Supplement 2, Rev. 1, Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation E4-13

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases System, and Evaluation of Surveillance Frequencies and Out of Service Times for the Engineered Safety Features Actuation System, May 1986 and June 1990.

Reference 10 for this section was Evaluation of the applicability of WCAP-10271-P-A, Supplement 1, and Supplement 2, Revision 1, to Watts Bar.

Thus, the approval for testing a channel in bypass with the inoperable channel also in bypass is Revision 0 of the Unit 1 TS, and not WCAP-14333.

No change is required.

30. Page number / Item:

B 3.3-111 / third paragraph, last two sentences NRC Comment(s):

OPEN ITEM U1/U2: WCAP-14333 (Ref 17) did not approve testing a channel in bypass with the inoperable channel also in bypass.

TVA Response(s):

The Unit 1 TS were issued by an NRC to TVA letter dated November 9, 1995 (Issuance of Facility Operating License No. NPF-20, Watts Bar Nuclear Plant, Unit 1 [TAC M91489]).

ACTIONS K.1, K.2.1 and K.2.2 of Revision 0 of the Unit 1 TS bases read as follows:

Condition K applies to RWST Level - Low Coincident with Safety Injection and Coincident with Containment Sump Level - High.

RWST Level -Low Coincident With SI and Coincident With Containment Sump Level -High provides actuation of switchover to the containment sump. Note that this Function requires the comparators to energize to perform their required action. The failure of up to two channels will not prevent the operation of this Function. However, placing a failed channel in the tripped condition could result in a premature switchover to the sump, prior to the injection of the minimum volume from the RWST. Placing the inoperable channel in bypass results in a two-out-of-three logic configuration, which satisfies the requirement to allow another failure without disabling actuation of the switchover when required. Restoring the channel to OPERABLE status or placing the inoperable channel in the bypass condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is sufficient to ensure that the Function remains OPERABLE, and minimizes the time that the Function may be in a partial trip condition (assuming the inoperable channel has failed high). The 6 hour6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Completion Time is justified in Reference 7. If the channel cannot be returned to OPERABLE status or placed in the bypass condition within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , the plant must be brought to MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within the next 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems. In MODE 5, the plant does not have any analyzed transients or conditions that require the explicit use of the protection functions noted above.

E4-14

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases The Required Actions are modified by a Note that allows placing a second channel in the bypass condition for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing. The total of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reach MODE 3 and 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for a second channel to be bypassed is acceptable based on the results of Reference 7.

Reference 10 for this section was Evaluation of the applicability of WCAP-10271-P-A, Supplement 1, and Supplement 2, Revision 1, to Watts Bar.

Thus, the approval for testing a channel in bypass with the inoperable channel also in bypass is Revision 0 of the Unit 1 TS, and not WCAP-14333.

No change is required.

31. Page number / Item:

B 3.3-115 / last line NRC Comment(s):

Should read conservative with respect to the Allowable Values ... instead of within the Allowable Values ...

TVA Response(s):

Developmental Revision F of the Unit 2 TS Bases replaced within the Allowable Values ...

with conservative with respect to the Allowable Values ...

32. Page number / Item:

B 3.3-116 / last paragraph NRC Comment(s):

a. The bracketed section 't[NTSP and the]' of the sentence in Note (c) in Table 3.3.2-1 is not required in plant-specific Technical Specifications which include a [Nominal Trip Setpoint]

column in Table 3.3.2-1.

b. The second Note also requires that the methodologies for calculating the as-left and the as-found tolerances be in [insert the name of a document controlled under 10 CFR 50.59 such as the Technical Requirements Manual or any document incorporated into the facility FSAR].

TVA Response(s):

These comments appear to be suitable to the TS instead of the TS Bases. For example, see TS comment 4 and the response to it.

No change is required.

E4-15

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

33. Page number / Item:

B 3.3-118 / SR 3.3.2.8 NRC Comment(s):

Justify deviation from TSTF-493 Bases for F.6.e, Trip of All Turbine Driven Main Feedwater Pumps see Bases page B 3.3.2-60, B 3.3.2-61 for replacement text.

TVA Response(s):

Developmental Revision F of the Unit 2 TS Bases revised SR 3.3.2.8 to be consistent with TSTF-493 by adding a new paragraph.

34. Page number / Item:

B 3.3-119 / end of SR 3.3.2.9 NRC Comment(s):

a. The bracketed section '[NTSP and the]' of the sentence in Note (c) in Table 3.3.2-1 is not required in plant-specific Technical Specifications which include a [Nominal Trip Setpoint]

column in Table 3.3.2-1.

b. The second Note also requires that the [NTSP and the] methodologies for calculating the as-left and the as-found tolerances be in [insert the name of a document controlled under 10 CFR 50.59 such as the Technical Requirements Manual or any document incorporated into the facility FSAR].

TVA Response(s):

See the response to Item 32.

35. Page number / Item:

B 3.3-122 / as indicated NRC Comment(s):

a. References 6, 12, and 13: OPEN Confirmatory item - need license amendment for change to Unit 1 licensing basis?

b. Reference 17: Unit 1 & Unit 2 OPEN ITEM The Required Actions are modified by a Note that allows placing one channel in bypass for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months while performing routine surveillance testing. The channel to be tested can be tested in bypass with the inoperable channel also in bypass. The total of [12] hours to reach MODE 3 and [4] hours for a second channel to be bypassed is acceptable based on the results of Reference 10.

Issue: Reference 10 cannot be WCAP-14333. WCAP-14333 did not approve and therefore cannot be used as a basis for plant-specific approval to perform testing with two channels in bypass.

E4-16

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases TVA Response(s):

a. Reference 5 provided the following justifications for the noted references:

x Reference 6: Incorporated Technical Specification Tracking Form (TSTF) 493, R4.

This is the reference to the setpoint methodology for Unit 2.

x Reference 12: Revised for Unit 2 specific configuration.

x Reference 13: Editorial

b. See response to Items 29 and 30.

36. Page number / Item:

B 3.3-123 / References 20, 21, 22 NRC Comment(s):

OPEN Confirmatory item - need license amendment for change to Unit 1 license basis TVA Response(s):

Reference 5 provided the following justifications for the noted references:

x Reference 20:

A75 amended the Unit 1 TS to modify the TS requirements related to Mode 1 and 2 applicability for Function 6.e of TS Table 3.3.2-1, Engineered Safety Feature Actuation System Instrumentation, and the Bases for TS 3.3.2. In addition, Limiting Condition for Operation (LCO) 3.3.2, Condition J, has been revised to be consistent with the design basis for WBN Unit 1.

This change is to be applied to Unit 2.

The NRC approved A75 in a letter dated March 4, 2009.

x Reference 21: Incorporated Technical Specification Tracking Form (TSTF) 493, R4.

This is the reference to the setpoint methodology for Unit 2.

x Reference 22: Revised for Unit 2 specific configuration.

No change is required.

E4-17

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

37. Page number / Item:

B 3.3-135 / Reference 3 NRC Comment(s):

Confirmatory item - reference #3 applies to Unit 2.

TVA Response(s):

This reference was not affected by Developmental Revision B.

No change is required.

38. Page number / Item:

B 3.3-141 / Reference 3 (for B 3.3.5)

NRC Comment(s):

Confirmatory item - reference #3 applies to Unit 2.

TVA Response(s):

This reference was not affected by Developmental Revision B; however, during discussion of this comment during TVAs meeting with the NRC on May 10, 2011, TVA noted that the calculation number is incorrect. Review of the calculations cover sheet shows that it has 001 & 002 in the UNITS field.

Developmental Revision F of the Unit 2 TS Bases corrects WPE2119202001 to WBPE2119202001.

39. Page number / Item:

B 3.3-142 / Reference 4 (for B 3.3.5)

NRC Comment(s):

A similar reference was not provided for LCO 3.3.1 or LCO 3.3.2 TSTF-493 Surveillance Requirement Notes. Why?

TVA Response(s):

Both Unit 1 and Unit 2 TS Bases have references to similar TRM sections:

x The Bases for SR 3.3.1.15 refers to Ref. 8. Reference 8 is Watts Bar Technical Requirements Manual, Section 3.3.1, Reactor Trip System Response Times.

x The Bases for SR 3.3.2.10 refers to Ref. 8. Reference 8 is Watts Bar Technical Requirements Manual, Section 3.3.2, Engineered Safety Feature Response Times.

During the review of the TS Bases to respond to this comment, TVA noted that Reference 4 on page B 3.3-153 is not used in TS Bases 3.3.5.

Developmental Revision F of the Unit 2 TS Bases deletes existing Reference 4 and renumbers existing References 5 and 6 (and references to them).

E4-18

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

40. Page number / Item:

B 3.3-150 / Reference 3 NRC Comment(s):

OPEN Confirmatory item - need a licensing basis for deviation from Unit 1.

TVA Response(s):

Reference 5 provided the following justification for this change: Revised for Unit 2 specific configuration.

No change is required.

41. Page number / Item:

B 3.3-151 / Reference 5 NRC Comment(s):

OPEN Confirmatory item - need a licensing basis for deviation from Unit 1.

TVA Response(s):

Refer to response to Item 15 of the TS comments.

42. Page number / Item:

B 3.4-10 / fifth paragraph NRC Comment(s):

CPNB to verify acceptability of deviation from WBN1. (JFD-5)

Also, Open Pending Receipt of Information at the top of the page.

TVA Response(s):

Reference 1 provided the following justification for this change: Corrected / updated information in response to Westinghouse letter WBT-D-1342, dated December 10, 2009. This Westinghouse letter provides the final Pressure Temperature Limits Report and associated FSAR, Technical Specifications and TS Bases markups.

This paragraph of the Unit 2 TS Bases states, 10 CFR 50, Appendix G (Ref. 2), requires the establishment of P/T limits for specific material fracture toughness requirements of the RCPB materials. Reference 2 requires an adequate margin to brittle failure during normal operation, anticipated operational occurrences, and system hydrostatic tests. ...

IV.2.b. of 10 CFR 50, Appendix G states, The pressure-temperature limits identified as ASME Appendix G limits in Table 3 require that the limits must be at least as conservative as limits obtained by following the methods of analysis and the margins of safety of Appendix G of Section XI of the ASME Code.

Thus, the change from Section III to Section XI is justified.

E4-19

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

43. Page number / Item:

B 3.4-34 / last paragraph NRC Comment(s):

a. OPEN confirmatory item Unit 1, Revision 79, A61 changes do not apply to U2

b. In the last sentence, replace greater than or equal to with above.

TVA Response(s):

a. The review matrix for TS Bases 3.4.7 provided by Reference 4 stated:

R79 revised the Unit 1 TS Bases to reflect changes to the Unit 1 TS approved by Unit 1 TS A61 (authorize change in SG level requirement from greater than or equal to 6% to greater than or 32% following SG replacement). This change will NOT be made on Unit 2 at this time.

NRC approved A61 via letter dated 05/05/2006.

No change is required.

b. The existing wording is consistent with the Unit 1 TS Bases; STS uses >.

No change is required.

44. Page number / Item:

B 3.5-7 / Note following SR 3.5.1.2 and SR 3.5.1.3 NRC Comment(s):

stet per A81 TVA Response(s):

This deletion was intentional and consistent with deletion of similar verbiage in other Unit 2 TS Bases portions.

No change is required.

E4-20

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases

45. Page number / Item:

B 3.7-34 / 100.6% in third line of first paragraph under LCO NRC Comment(s):

was 102, A31, Rev 41 not on U2.

TVA Response(s):

This was not affected by Unit 2 Developmental Revision B.

The review matrix for TS Bases 3.7.6 provided by Reference 4 stated:

R41 revised the Unit 1 TS Bases to reflect changes to the Unit 1 TS approved by A31

{approve Power Uprate using Leading Edge Flow Meter (LEFM) for Unit 1}.

This change will NOT be implemented on Unit 2 at this time.

NRC approved A31 via letter dated 01/19/2001.

No change is required.

46. Page number / Item:

B 3.8-8 / as indicated NRC Comment(s):

a. sticky at top of page: Revision 50, Amendment 39 is not on U2. The added sentence is from U1 and should apply to U2, but was omitted.

b. last paragraph on page: add the following after the second sentence: For the performance of a Surveillance, Required Action B.3.1 is considered satisfied since the cause of the DG being inoperable is apparent.

TVA Response(s):

a. The review matrix for TS Bases 3.8.1 provided by Reference 4 included the following:

R50 revised the Unit 1 TS Bases to reflect changes to the Unit 1 TS approved by Unit 1 TS A39 (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 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 14 days). This change will NOT be applied to Unit 2.

NRC approved A39 via letter dated 07/01/2002.

No change is required.

b. The review matrix for TS Bases 3.8.1 provided by Reference 4 Included the following:

R65 revised the Unit 1 TS Bases to clarify that a common cause assessment is not required when a DG is made inoperable due to the performance of a surveillance. This change is to be applied to Unit 2.

R65 was provided to NRC via letter dated 04/20/2004.

E4-21

ENCLOSURE 4 TVA Responses to NRC Comments on Unit 2 Technical Specifications Bases This change was inadvertently omitted. Developmental Revision F of the Unit 2 TS Bases added the missing sentence.

47. Page number / Item:

B 3.8-26 / SR 3.8.1.14 NRC Comment(s):

TVA February 16, 2011 Letter, Enclosure 5, Commitments, item #2; a future Developmental revision to delete the Revision 50, Amendment 39 U1 paragraph lined out on page B 3.8-28 TVA Response(s):

Item 2 of Enclosure 5 of Reference 3 stated, 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.

Developmental Revision F of the Unit 2 TS Bases deleted 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. verbiage from the TS Bases for SR 3.8.1.14.

E4-22

ENCLOSURE 5 Proposed Unit 2 Technical Specifications

ENCLOSURE 6 Marked-up Version of Unit 2 Technical Specifications With Justifications for Revisions

ENCLOSURE 7 Proposed Unit 2 Technical Specifications Bases

ENCLOSURE 8 Marked-up Version of Unit 2 Technical Specifications Bases With Justifications for Revisions

ENCLOSURE 9 New Regulatory Commitments Prior to implementation of the Unit 2 TS, TVA will:

1. Revise applicable attachment(s) of Technical Instruction TI-119, Maintenance Rule Performance Indicator Monitoring, Trending, and Reporting, to require that the surveillance interval be evaluated and reduced, when needed, if two or more P&B MDR series relays used for Unit 2 TS LCOs 3.3.2 and 3.3.6 fail within a 12-month interval.

2. Confirm the applicability of the WCAP-13878, Rev. 1 analyses for P&B MDR series relays.

3. Develop a Procurement Engineering Group package for procurement of P&B MDR series relays.

This document will ensure TVAs procurement program for P&B MDR relays is adequate for detecting the types of failures that are discussed in References 9, 10, 11 and 12 of WCAP-13878, Revision 1.

4. For function 3 of Unit 2 TS Table 3.3.61, revise the calculation and submit a change to the Unit 2 TS using the manufacturers final detector sensitivity value.

ML11187A341

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