CNL-24-014, License Amendment Request to Revise the Sequoyah Nuclear Plant, Units 1 and 2 and Watts Bar Nuclear Plant, Units 1 and 2 Technical Specifications to Use Online Monitoring Methodology (SQN-TS-24-02 and WBN-TS-23-22)

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License Amendment Request to Revise the Sequoyah Nuclear Plant, Units 1 and 2 and Watts Bar Nuclear Plant, Units 1 and 2 Technical Specifications to Use Online Monitoring Methodology (SQN-TS-24-02 and WBN-TS-23-22)
ML24309A061
Person / Time
Site: Sequoyah, Watts Bar  
Issue date: 11/04/2024
From: Hulvey K
Tennessee Valley Authority
To:
Office of Nuclear Reactor Regulation, Document Control Desk
References
CNL-24-014
Download: ML24309A061 (1)
v • d • e


Text

10 CFR 50.90 1101 Market Street, Chattanooga, Tennessee 37402 CNL-24-014 November 4, 2024 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328 Watts Bar Nuclear Plant, Units 1 and 2 Facility Operating License Nos. NPF-90 and NPF-96 NRC Docket Nos. 50-390 and 50-391

Subject:

License Amendment Request to Revise the Sequoyah Nuclear Plant, Units 1 and 2 and Watts Bar Nuclear Plant, Units 1 and 2 Technical Specifications to Use Online Monitoring Methodology (SQN-TS-24-02 and WBN-TS-23-22)

In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.90, Application for amendment of license, construction permit, or early site permit, Tennessee Valley Authority (TVA) is submitting a request for an amendment to Renewed Facility Operating License Nos. DPR-77 and DPR-79 for the Sequoyah Nuclear Plant (SQN), Units 1 and 2; and Facility Operating License Nos. NPF-90 and NPF-96 for the Watts Bar Nuclear Plant (WBN), Units 1 and 2, respectively.

The proposed amendment revises SQN and WBN Technical Specification (TS) 1.1, Use and Application Definitions and adds new SQN TS 5.5.19 and new WBN TS 5.7.2.24 Online Monitoring Program. TVA proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The proposed change is based on the Nuclear Regulatory Commission (NRC)-approved topical report Analysis and Measurement Services (AMS)-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

The enclosure to this submittal provides a description and assessment of the proposed change, a regulatory evaluation, and a discussion of environmental considerations. provides a marked-up version of the affected TS pages of SQN Units 1 and 2 showing the proposed changes. Attachment 2 provides a marked-up version of the affected TS pages of WBN Units 1 and 2 showing the proposed changes. Attachment 3 provides a marked-up version of the SQN Units 1 and 2 TS Bases. Attachment 4 provides a marked-up version of the WBN Units 1 and 2 TS Bases. Changes to the existing TS Bases

U.S. Nuclear Regulatory Commission CNL-24-014 Page 2 November 4, 2024 are provided for information only and will be implemented under the Technical Specification Bases Control Program.

TVA requests approval of the proposed license amendment within one year from the date of this submittal with implementation within 6 months of issuance of the amendment.

TVA has determined that there are no significant hazards considerations associated with the proposed change and that the TS change qualifies for a categorical exclusion from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9). In accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and enclosure to the Tennessee State Department of Environment and Conservation.

There are no new regulatory commitments contained in this letter. Please address any questions regarding this request to Amber V. Aboulfaida, Senior Manager, Fleet Licensing, at avaboulfaida@tva.gov.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 4th day of November 2024.

Respectfully, Kimberly D. Hulvey General Manager, Nuclear Regulatory Affairs & Emergency Preparedness

Enclosure:

Description and Assessment of the Proposed Change cc (Enclosure):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Sequoyah Nuclear Plant NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRC Project Manager - Sequoyah Nuclear Plant NRC Project Manager - Watts Bar Nuclear Plant Director, Division of Radiological Health - Tennessee Department of Environment and Conservation Digitally signed by Edmondson, Carla Date: 2024.11.04 09:58:49 -05'00'

CNL-24-014 E1 of 22 Enclosure Description and Assessment of the Proposed Change

Subject:

License Amendment Request to Revise the Sequoyah Nuclear Plant, Units 1 and 2 and Watts Bar Nuclear Plant, Units 1 and 2 Technical Specifications to Use Online Monitoring Methodology (SQN-TS-24-02 and WBN-TS-23-22)

CONTENTS 1.0

SUMMARY

DESCRIPTION............................................................................................... 3 2.0 DETAILED DESCRIPTION................................................................................................ 3 2.1 Background.................................................................................................................... 3 2.2 System Design and Operation........................................................................................ 4 2.3 Reason for the Proposed Change.................................................................................. 5 2.4 Description of the Proposed Change.............................................................................. 5 2.4.1 SQN Units 1 and 2.................................................................................................. 5 2.4.2 WBN Units 1 and 2.................................................................................................. 7 2.4.3 New Program for SQN Units 1 and 2 and WBN Units 1 and 2 TS.......................... 8

3.0 TECHNICAL EVALUATION

............................................................................................... 9 3.1 OLM Implementation Process Development.................................................................. 9 3.1.1 Determine if Transmitters are Amenable to OLM.................................................... 9 3.1.2 List Transmitters in Each Redundant Group........................................................... 9 3.1.3 Determine if OLM Data Covers Applicable Setpoints............................................ 10 3.1.4 Calculate Backstops.............................................................................................. 10 3.1.5 Establish Method of Data Acquisition.................................................................... 10 3.1.6 Specify Data Collection Duration and Sampling Rate........................................... 10 3.1.7 Identify Data Analysis Methods............................................................................. 10 3.1.8 Establish OLM Limits............................................................................................. 10 3.2 OLM Program Implementation..................................................................................... 10 3.2.1 Retrieve OLM Data................................................................................................ 11 3.2.2 Perform Data Qualification.................................................................................... 11 3.2.3 Select Appropriate Region of Any Transient Data................................................. 12 3.2.4 Perform Data Analysis........................................................................................... 12 3.2.5 Plot the Average Deviation for Each Transmitter.................................................. 12 3.2.6 Produce a Table for Each Group That Combines All Results............................... 12 3.2.7 Determine OLM Results for Each Transmitter...................................................... 12 3.2.8 Address Uncertainties in the Unexercised Portion of Transmitter Range............. 12 3.2.9 Select Transmitters to Be Checked for Calibration as a Backstop........................ 13

Enclosure CNL-24-014 E2 of 22 3.2.10 Perform Dynamic Failure Mode Assessment........................................................ 13 3.2.11 Produce a Report of Transmitters Scheduled for Calibration Check........................ 13 3.3 OLM Noise Analysis Implementation............................................................................ 13 3.3.1 Select Qualified Noise Data Acquisition Equipment.............................................. 14 3.3.2 Connect Noise Data Acquisition Equipment to Plant Signals................................ 14 3.3.3 Collect and Store Data for Subsequent Analysis.................................................. 14 3.3.4 Screen Data for Artifacts and Anomalies.............................................................. 15 3.3.5 Perform Data Analysis........................................................................................... 15 3.3.6 Review and Document Results............................................................................. 15 3.4 Application Specific Action Items from AMS OLM TR.................................................. 15

4.0 REGULATORY EVALUATION

......................................................................................... 17 4.1 Applicable Regulatory Requirements and Criteria........................................................ 17 4.1.1 10 CFR 50.36 Technical Specifications................................................................ 17 4.1.2 General Design Criteria......................................................................................... 17 4.1.3 IEEE Standard 338................................................................................................ 18 4.2 Precedent..................................................................................................................... 19 4.3 No Significant Hazards Consideration Determination Analysis.................................... 19 4.4 Conclusion.................................................................................................................... 20

5.0 ENVIRONMENTAL CONSIDERATION

........................................................................... 20

6.0 REFERENCES

................................................................................................................. 21 Attachments

1. Proposed TS Changes (Markups) for SQN Units 1 and 2
2. Proposed TS Changes (Markups) for WBN Units 1 and 2
3. Proposed TS Bases Changes (Markups) for SQN Units 1 and 2 (For Information Only)
4. Proposed TS Bases Changes (Markups) for WBN Units 1 and 2 (For Information Only)

Enclosure CNL-24-014 E3 of 22 Description and Assessment of the Proposed Change 1.0

SUMMARY

DESCRIPTION In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.90, Application for amendment of license, construction permit, or early site permit, Tennessee Valley Authority (TVA) is submitting a request for an amendment to Renewed Facility Operating License Nos. DPR-77 and DPR-79 for Sequoyah Nuclear Plant (SQN), Units 1 and 2, and Facility Operating License Nos. NPF-90 and NPF-96 for Watts Bar Nuclear Plant (WBN), Units 1 and 2.

The proposed amendment revises SQN and WBN Technical Specification (TS) 1.1, Use and Application Definitions and adds new SQN TS 5.5.19 and new WBN TS 5.7.2.24 Online Monitoring Program. TVA proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The proposed change is based on the Nuclear Regulatory Commission (NRC)-approved Analysis and Measurement Services (AMS) Topical Report (TR) AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

2.0 DETAILED DESCRIPTION

2.1 Background

OLM technologies have been developed and validated for condition monitoring applications in a variety of process and power industries. This application of OLM is used to optimize maintenance of instrumentation and control (I&C) systems including online drift monitoring and assessment of dynamic failure modes of transmitters. AMS-TR-0720R2-A (References 1 and 2) focused on the application of OLM for monitoring drift of pressure, level, and flow transmitters in nuclear power plants. AMS-TR-0720R2-A addressed the following topics:

Advances in OLM implementation technology to extend transmitter calibration intervals Experience with OLM implementation in nuclear facilities Comparison between OLM results and manual calibrations Transmitter failure modes that can be detected by OLM Related regulatory requirements and industry standards and guidelines Procedures for implementation of OLM methodology Changes that must be made to existing technical specifications to adopt OLM AMS-TR-0720R2-A provided the NRC with the information needed to approve the AMS OLM methodology for implementation in nuclear power plants. AMS-TR-0720R2-A is intended to be used by licensees to support plant-specific technical specification changes to switch from time-based calibration frequency of pressure, level, and flow transmitters to a condition-based calibration frequency based on OLM results and to develop procedures to assess dynamic failure modes of pressure sensing systems using the noise analysis technique.

NRC determined that the methodology outlined in the AMS OLM TR for applying OLM techniques to pressure, level, and flow transmitters can be used to provide reasonable assurance that required TS instrument calibration requirements for transmitters will be

Enclosure CNL-24-014 E4 of 22 maintained. This determination was based on the NRC finding that OLM techniques: a) are effective at identifying instrument calibration drift during plant operation, b) provide an acceptable means of identifying when manual transmitter calibration using traditional calibration methods are needed, and c) will maintain an acceptable level of performance that is traceable to calibration prime standards.

The NRC staff found that implementation of an OLM program in accordance with the approved AMS OLM TR provides an acceptable alternative to periodic manual calibration surveillance requirements upon implementation of the application-specific action items (ASAI) in Section 4.0 of its safety evaluation. The ASAIs are addressed in Section 3.4 of this enclosure.

2.2 System Design and Operation The transmitters to be included in the OLM program provide input to the reactor trip systems (RTS) and engineered safety feature actuation systems (ESFAS) and are used for post accident monitoring (PAM), the remote shutdown system (RSS), and low temperature overpressure protection (LTOP) or cold overpressure mitigation system (COMS).

The RTS initiates a unit shutdown, based on the values of selected unit parameters, to protect against violating the core fuel design limits and reactor coolant system (RCS) pressure boundary during anticipated operational occurrences and to assist the engineered safety feature (ESF) systems in mitigating accidents. The RTS and related instrumentation are identified in the SQN and WBN TS Table 3.3.1-1.

The ESFAS and related systems initiate necessary safety systems, based on the values of selected unit parameters, to protect against violating core design limits and the RCS pressure boundary, and to mitigate accidents. The ESFAS and related instrumentation are identified in the SQN and WBN TS Table 3.3.2-1.

The primary purpose of the PAM instrumentation is to display unit variables that provide information required by the control room operators during accident situations. This information provides the necessary support for the operator to take the manual actions for which no automatic control is provided and that are required for safety systems to accomplish their safety functions for design basis accidents. The PAM instrumentation is identified in the SQN and WBN TS Table 3.3.3-1.

The RSS provides the operator with sufficient instrumentation and controls to place and maintain the unit in a safe shutdown condition from a location other than the control room. This capability is necessary to protect against the possibility that the control room becomes inaccessible. The RSS instrumentation is addressed in the SQN and WBN TS 3.3.4 and identified in SQN and WBN Bases Table B 3.3.4-1.

The LTOP (SQN) or COMS (WBN) controls RCS overpressure at low temperatures, so the integrity of the reactor coolant pressure boundary is not compromised by violating the pressure and temperature limits of 10 CFR 50 Appendix G. The LTOP or COMS instrumentation is identified in SQN and WBN TS 3.4.12, respectively.

The RTS, ESFAS, PAM, RSS, and LTOP or COMS transmitters were evaluated in accordance with the methodology in AMS-TR-0720R2-A. The transmitters to be included in the OLM program and the bases for their selection can be found in the following AMS reports, which are available for NRC review:

AMS Report SYA2307R0, "OLM Amenable Transmitters Report for Sequoyah Units 1 and 2 (Reference 3)

AMS Report WBR2302R0, "OLM Amenable Transmitters Report for Watts Bar Units 1 and 2 (Reference 4)

Enclosure CNL-24-014 E5 of 22 Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency will not create any physical changes to the plants. The changes will not impact how the plants operate. TVA will use condition-based frequency to determine when transmitter calibrations are needed instead of performing calibrations based on a calendar frequency. Existing calibration methods will be used when it is determined that transmitter calibration is needed.

2.3 Reason for the Proposed Change TVA is proposing to use the NRC-approved OLM methodology described in AMS-TR-0720R2-A. The use of the NRC-approved OLM methodology ensures that plant safety is maintained by demonstrating that transmitters are functioning correctly. The OLM methodology encompasses environmental and process conditions in the assessment of transmitter calibration.

The use of condition-based monitoring for transmitter calibration provides additional safety benefits, as described in AMS-TR-0720R2-A. The use of OLM will result in elimination of unnecessary transmitter calibration and associated opportunities for human errors. The use of OLM further eliminates occupational exposure or human error opportunities related to calibration activities that were unnecessary. Elimination of unnecessary calibrations will also reduce calibration-induced damage to transmitters and other plant equipment. The use of OLM provides for timely detection of out-of-calibration transmitters. Experience has shown that human errors during calibration of transmitters that did not require recalibration have resulted in additional repairs to correct the mistakes.

2.4 Description of the Proposed Change 2.4.1 SQN Units 1 and 2 TVA proposes to change SQN Units 1 and 2 TS 1.1 Use and Application Definitions definition of CHANNEL CALIBRATION as follows.

Current TS 1.1 CHANNEL CALIBRATION - A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY. Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

Proposed TS 1.1 CHANNEL CALIBRATION - A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal

Enclosure CNL-24-014 E6 of 22 calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

TVA proposes to change SQN Units 1 and 2 TS 1.1 Use and Application Definitions definition of ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME as follows.

Current TS 1.1 ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME - The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

Proposed TS 1.1 ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME - The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

TVA proposes to change SQN Units 1 and 2 TS 1.1 Use and Application Definitions definition of REACTOR TRIP SYSTEM (RTS) RESPONSE TIME as follows.

Current TS 1.1 REACTOR TRIP SYSTEM (RTS) RESPONSE TIME - The RTS RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

Proposed TS 1.1 REACTOR TRIP SYSTEM (RTS) RESPONSE TIME - The RTS RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that

Enclosure CNL-24-014 E7 of 22 the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, (including transmitters in the online monitoring program) or the components have been evaluated in accordance with an NRC approved methodology.

2.4.2 WBN Units 1 and 2 TVA proposes to change WBN Units 1 and 2 TS 1.1 Use and Application Definitions definition of CHANNEL CALIBRATION as follows.

Current TS 1.1 CHANNEL CALIBRATION - A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. THE CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY. Calibration of instrument channels with resistance temperature detector (RTD) or the thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

Proposed TS 1.1 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. THE CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY (excluding transmitters in the online monitoring program). Calibration of instrument channels with resistance temperature detector (RTD) or the thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

TVA proposes to change WBN Units 1 and 2 TS 1.1 Use and Application Definitions definition of ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME as follows.

Current TS 1.1 ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME - The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so

Enclosure CNL-24-014 E8 of 22 that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

Proposed TS 1.1 ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME - The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

TVA proposes to change WBN Units 1 and 2 TS 1.1 Use and Application Definitions definition of REACTOR TRIP SYSTEM (RTS) RESPONSE TIME as follows.

Current TS 1.1 REACTOR TRIP SYSTEM (RTS) RESPONSE TIME - The RTS RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, or the components have been evaluated in accordance with an NRC approved methodology.

Proposed TS 1.1 REACTOR TRIP SYSTEM (RTS) RESPONSE TIME - The RTS RESPONSE TIME shall be the time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

2.4.3 New Program for SQN Units 1 and 2 and WBN Units 1 and 2 TS TVA proposes to add a new Online Monitoring Program TS, as shown below.

Proposed SQN Units 1 and 2 TS 5.5.19 and WBN Units 1 and 2 TS 5.7.2.24 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

Enclosure CNL-24-014 E9 of 22 The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a. Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.
1. Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check.
2. Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance.
3. Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and
4. Documentation of the results of the online monitoring data analysis.
b. Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.
c. Performance of calibration checks for transmitters at the specified backstop frequencies.
d. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

The proposed TS changes are an adaptation from the illustrative changes presented in AMS-TR-0720R2-A that simplify the required plant-specific changes. The proposed Definition changes eliminated the need to modify the Channel Calibration and Response Time Surveillance Requirements. The proposed Online Monitoring Program description was reorganized to better align with the OLM implementation activities.

3.0 TECHNICAL EVALUATION

3.1 OLM Implementation Process Development This section describes the steps that were performed to implement the OLM program for SQN and WBN by following the steps identified in AMS-TR-0720R2-A Section 11.1.1. This work is documented in the AMS reports on OLM Amenable Transmitters (References 3 and 4) and OLM Analysis Methods and Limits (References 5 and 6).

The AMS reports on OLM Amenable Transmitters address steps 1-6 from AMS-TR-0720R2-A Section 11.1.1. These steps were designed to arrive at a list of transmitters that can be included in an OLM program and determine how to obtain OLM data. The RTS, ESFAS, PAM, RSS, and LTOP or COMS transmitters to be included in the OLM program and the bases for their selection can be found in the AMS reports on OLM Amenable Transmitters.

3.1.1 Determine if Transmitters are Amenable to OLM AMS-TR-0720R2-A Chapter 12 includes Table 12.4 that lists the nuclear grade transmitter models that are amenable to OLM. Any transmitter model that is not listed in this table should only be added to the OLM program if it can be shown by similarity analysis that its failure modes are the same as the listed transmitter models or otherwise detectable by OLM.

3.1.2 List Transmitters in Each Redundant Group This step establishes how to group the transmitters and evaluates the redundancy of each group.

Enclosure CNL-24-014 E10 of 22 3.1.3 Determine if OLM Data Covers Applicable Setpoints This step evaluates the OLM data for each group to determine if it covers applicable setpoints.

Additional details are described in AMS-TR-0720R2-A Chapter 14.

3.1.4 Calculate Backstops A backstop, as described in AMS-TR-0720R2-A Chapter 13, must be established for each group of redundant transmitters amenable to OLM as a defense against common mode drift.

The backstop identifies the maximum period between calibrations without calibrating at least one transmitter in a redundant group.

3.1.5 Establish Method of Data Acquisition OLM data is normally available in the plant computer or an associated data historian. If data is not available from the plant computer or historian, a custom data acquisition system including hardware and software must be employed to acquire the data.

3.1.6 Specify Data Collection Duration and Sampling Rate OLM data must be collected during startup, normal operation, and shutdown periods at the highest sampling rate by which the plant computer takes data. AMS-TR-0720R2-A Chapter 15 describes a process to determine the minimum sampling rate for OLM data acquisition to monitor for transmitter drift. AMS-TR-0720R2-A Chapter 8 describes a process to help determine the optimal sampling rate and minimum duration of OLM data collection.

AMS reports on OLM Analysis Methods and Limits (References 5 and 6) address steps 7-8 from AMS-TR-0720R2-A Section 11.1.1. These steps address the calculation of the OLM limits and establish the methods of OLM data analysis.

3.1.7 Identify Data Analysis Methods OLM implementations must employ both simple averaging and parity space methods for data analysis as described in AMS-TR-0720R2-A Chapter 6.

3.1.8 Establish OLM Limits OLM limits must be established as described in AMS-TR-0720R2-A Chapter 7 for each group of redundant transmitters. Calculation of OLM limits must be based on combining uncertainties of components of each instrument channel from the transmitter in the field to the OLM data storage.

The AMS report on OLM Analysis Methods and Limits provides the OLM Limit calculations for the transmitters that are amenable to OLM at SQN and WBN.

3.2 OLM Program Implementation This section summarizes the steps that must be followed to implement the OLM program for transmitter drift monitoring at SQN and WBN in accordance with AMS-TR-0720R2-A. The steps described in this section are repeated at each operating cycle at SQN and WBN to identify the transmitters that should be scheduled for a calibration check using data from periods of startup, normal operation, and shutdown. Additional details regarding the OLM Program Implementation discussed in this section are contained in the AMS report on OLM Drift Monitoring Program (References 7 and 8).

AMS-TR-0720R2-A Section 11.1.2 identifies eleven steps that must be followed each operating cycle to identify the transmitters that should be scheduled for a calibration check at the ensuing outage. Table 1 provides a mapping between AMS-TR-0720R2-A Section 11.1.2 and the license amendment request (LAR) section where the item is addressed. Implementation of

Enclosure CNL-24-014 E11 of 22 these steps is performed using the AMS Bridge and the AMS Calibration Reduction System (CRS) software programs that were developed by AMS under their 10 CFR Part 50 Appendix B software Quality Assurance (QA) program.

Table 1: Mapping to AMS-TR-0720R2-A Section 11.1.2 Item Step Step Number in Section 11.1.2 of AMS-TR-0720R2-A LAR Section 1

Retrieve OLM Data 9

3.2.1 2

Perform Data Qualification 10 3.2.2 3

Select Appropriate Region of Any Transient Data 11 3.2.3 4

Perform Data Analysis 12 3.2.4 5

Plot the Average Deviation for Each Transmitter 13 3.2.5 6

Produce a Table for Each Group That Combines All Results 14 3.2.6 7

Determine OLM Results for Each Transmitter 15 3.2.7 8

Address Uncertainties in the Unexercised Portion of Transmitter Range 16 3.2.8 9

Select Transmitters to Be Checked for Calibration as a Backstop 17 3.2.9 10 Perform Dynamic Failure Mode Assessment 18 3.2.10 11 Produce a Report of Transmitters Scheduled for Calibration Check 19 3.2.11 3.2.1 Retrieve OLM Data The first step in performing transmitter drift monitoring is to retrieve the OLM data. OLM data must be retrieved during periods of startup, normal operation, and shutdown. The method of data acquisition, data collection duration, sampling rate, and list of sensors whose data will be retrieved have been established as described in Section 3.1 of this document. The OLM data for SQN and WBN will be retrieved using the AMS Bridge software which will retrieve data from the TVA data historian and produce binary data files that are compatible with the AMS CRS software or as text files from the TVA data historian or other data sources at each plant site, as applicable. AMS procedure OLM2201, Procedure for Online Monitoring Data Retrieval, has been developed for performing the data retrieval using the AMS Bridge software (Reference 9).

3.2.2 Perform Data Qualification OLM data retrieved from plant historians sometimes contains anomalies such as spikes, missing data, stuck data, and saturated data. The portion of data containing these anomalies should be excluded, filtered, and/or cleaned prior to analysis. The AMS CRS software provides functionality for these tasks and will be used to perform data qualification. AMS procedure OLM2202, Procedure for Performing Online Monitoring Data Qualification and Analysis, has been developed for performing data qualification and analysis using the AMS CRS software (Reference 10).

Enclosure CNL-24-014 E12 of 22 3.2.3 Select Appropriate Region of Any Transient Data The AMS CRS software provides means to select the regions of transient data as described in Step 11 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform these selections.

This activity is part of OLM data analysis and is addressed in the data qualification and analysis procedure.

3.2.4 Perform Data Analysis There are several tasks that must be performed in OLM data analysis for startup, normal operation, and shutdown data including:

1. Calculate the process estimate,
2. Calculate the deviation of each transmitter from the process estimate and plot the outcome,
3. Partition the deviation data into region(s) by percent of span,
4. Calculate and plot the average deviation for each region versus percent of span,
5. Select appropriate process estimation techniques, filtering parameters, and remove any
outliers,
6. Determine if average deviations exceed OLM limits for any region, and
7. Review, document, and store the details and results of analysis.

The AMS CRS software provides functionality for performing these tasks and will be used to perform OLM data analysis. Detailed steps for performing OLM data analysis are provided in the data qualification and analysis procedure.

3.2.5 Plot the Average Deviation for Each Transmitter The AMS CRS software provides functionality for plotting the average deviation for each transmitter as described in Step 13 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

3.2.6 Produce a Table for Each Group That Combines All Results The AMS CRS software provides functionality for producing a table for each group of redundant transmitters that combines all results as described in Step 14 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

3.2.7 Determine OLM Results for Each Transmitter OLM results must be produced by the OLM analyst upon completion of data analysis for a complete operating cycle. The AMS CRS software provides functionality for producing these results as described in Step 15 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

3.2.8 Address Uncertainties in the Unexercised Portion of Transmitter Range The AMS CRS software provides functionality for addressing uncertainties in the unexercised portion of the transmitter range as described in Step 13 of Section 11.1.2 of AMS-TR-0720R2-A and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

Enclosure CNL-24-014 E13 of 22 3.2.9 Select Transmitters to Be Checked for Calibration as a Backstop The AMS procedure OLM2202 is also used for maintaining the backstops for OLM. It provides detailed steps for selecting transmitters to be checked for calibration as a backstop as described in Step 17 of Section 11.1.2 of AMS-TR-0720R2-A.

3.2.10 Perform Dynamic Failure Mode Assessment As described in Step 18 of Section 11.1.2 of AMS-TR-0720R2-A, dynamic failure mode assessment must be performed using the noise analysis technique to cover dynamic failures that are not detectable by the OLM process for transmitter drift monitoring. Details on how this will be addressed for SQN and WBN are described in LAR Section 3.3.

3.2.11 Produce a Report of Transmitters Scheduled for Calibration Check The results of OLM analysis must be compiled in a report and independently reviewed. The transmitters that have been flagged must be scheduled for a calibration check at the next opportunity. The AMS CRS software provides functionality for producing this report and will be used to perform this task. This activity is part of OLM data analysis and is addressed in detail in the data qualification and analysis procedure.

3.3 OLM Noise Analysis Implementation Some licensees have extended or eliminated transmitter response time testing requirements with NRC approval based, in part, on the performance of manual calibrations. Manual calibrations will not be performed, except on transmitters that are flagged by OLM. The noise analysis methodology is provided in this document to enable licensees to assess the dynamic failure modes of transmitters that are not covered by the OLM process for transmitter drift monitoring.

This section summarizes the steps that must be followed to implement the noise analysis technique for transmitter dynamic failure mode assessment at SQN and WBN in accordance with AMS-TR-0720R2-A. Additional details regarding the implementation of the noise analysis technique discussed in this section are provided in the AMS reports on Noise Analysis Program (References 11 and 12). As described in Section 11.3.3 of AMS-TR-0720R2-A, six steps must be followed to assess dynamic failure modes of pressure transmitters.

Enclosure CNL-24-014 E14 of 22 Table 2 provides a mapping of the six steps in Section 11.3.3 of AMS-TR-0720R2-A and the section where they are addressed in this document. Implementation of these steps is performed using qualified noise data acquisition equipment and software programs that were developed by AMS under their 10 CFR Part 50 Appendix B software Quality Assurance (QA) program.

For SQN and WBN, the transmitters with response time requirements have been identified in AMS reports on OLM Amenable Transmitters (References 3 and 4).

Table 2: Mapping to AMS-TR-0720R2-A Section 11.3.3 Item Step Step Number in Section 11.3.3 of AMS-TR-0720R2-A LAR Section 1

Select Qualified Noise Data Acquisition Equipment 1

3.3.1 2

Connect Noise Data Acquisition Equipment to Plant Signals 2

3.3.2 3

Collect and Store Data for Subsequent Analysis 3

3.3.3 4

Screen Data for Artifacts and Anomalies 4

3.3.4 5

Perform Data Analysis 5

3.3.5 6

Review and Document Results 6

3.3.6 3.3.1 Select Qualified Noise Data Acquisition Equipment The first step in performing noise analysis is to select qualified noise data acquisition equipment. This equipment must have a valid calibration traceable to the National Institute of Standards and Technology and meet a set of performance criteria detailed in Step 1 of Section 11.3.3 of AMS-TR-0720R2-A. The equipment used to acquire data at SQN and WBN will be the AMS OLM data acquisition system which is comprised of hardware and software that has been developed and tested using AMS 10 CFR Part 50 Appendix B hardware and software QA program.

3.3.2 Connect Noise Data Acquisition Equipment to Plant Signals AMS Procedure NPS1501, Procedure for Noise Data Collection from Plant Sensors, is used for the connection of the noise data acquisition equipment for performing noise analysis testing (Reference 13). This procedure identifies the locations for connection to process signals as well as the qualified personnel who may connect the data acquisition system at these locations. The noise data acquisition system should be connected to as many transmitters as allowed by the number of data acquisition channels and the plant procedures. Multiple transmitters (e.g., up to 32) can be tested simultaneously to reduce the test time. Each data acquisition channel must be connected to the transmitter current loop as shown in Section 11.3.3 of AMS-TR-0720R2-A.

3.3.3 Collect and Store Data for Subsequent Analysis The noise data should be collected during normal plant operation at full temperature, pressure, and flow and analyzed in real time or stored to be analyzed later. However, noise data taken at other conditions is acceptable as long as there is enough process fluctuation with sufficient

Enclosure CNL-24-014 E15 of 22 amplitude and frequency content to drive the transmitters to reveal their dynamic characteristics.

Noise data collection will be performed using AMS OLM Data Acquisition software which has been developed and tested using AMS software validation and verification program which conforms to 10 CFR Part 50 Appendix B. The use of this software for noise data acquisition is addressed in the AMS procedure for performing noise analysis testing (Reference 13).

3.3.4 Screen Data for Artifacts and Anomalies Noise data may contain anomalies that must be excluded, filtered, and/or cleaned prior to data analysis. AMS Procedure NAR2201, Procedure for Performing Dynamic Failure Mode Assessment Using Noise Analysis, is used for performing noise data analysis (Reference 14) and will be performed using AMS noise analysis software.

3.3.5 Perform Data Analysis Noise data analysis will be performed as described in Section 11.3.3 Step 5 in AMS-TR-0720R2-A using AMS noise analysis software. General data analysis steps for the analyst as well as detailed steps for performing noise data analysis are also provided in the AMS procedure for performing noise data analysis (Reference 14).

3.3.6 Review and Document Results Results of noise data analysis will be reviewed and approved by qualified personnel and documented in a report. This process is detailed in the AMS procedure for performing noise data analysis (Reference 14).

3.4 Application Specific Action Items from AMS OLM TR The NRC approval of the AMS OLM TR required implementation of the ASAIs in Section 4.0 of its safety evaluation. Five ASAIs were identified, and each is addressed below.

ASAI 1 - Evaluation and Proposed Mark-up of Existing Plant Technical Specifications When preparing a license amendment request to adopt OLM methods for establishing calibration frequency, licensees should consider markups that provide clear requirements for accomplishing plant operations, engineering data analysis, and instrument channel maintenance. Such TS changes would need to include appropriate markups of the TS tables describing limiting conditions for operation and surveillance requirements, the technical basis for the changes, and the administrative programs section.

Response to ASAI 1: The proposed changes to the SQN and WBN TS are identified in Section 2.4 and shown in Attachments 1 and 2. The proposed changes modify applicable Definitions and add a new program for OLM in the Administrative Controls. No changes to the TS tables describing Limiting Conditions for Operation or Surveillance Requirements were necessary.

ASAI 2 - Identification of Calibration Error Source When determining whether an instrument can be included in the plant OLM program, the licensee shall evaluate calibration error source in order to account for the uncertainty due to multiple instruments used to support the transfer of transmitter signal data to the data collection system. Calibration errors identified through OLM should be attributed to the transmitter until testing can be

Enclosure CNL-24-014 E16 of 22 performed on other support devices to correctly determine the source of calibration error and reallocate errors to these other loop components.

Response to ASAI 2: Calibration error is evaluated as part of the calculation of OLM limits as described in Section 3.1.8. The calculation of OLM limits is based on combining uncertainties of components of each instrument channel from the transmitter in the field to the OLM data storage. The OLM data assessment methods described in Section 3.2.7 include guidance to consider calibration errors identified through OLM as coming from the transmitter until testing can be performed on other support devices to correctly determine the source of calibration error and reallocate errors to these other loop components.

ASAI 3 - Response Time Test Elimination Basis If the plant has eliminated requirements for performing periodic RT testing of transmitters to be included in the OLM program, then the licensee shall perform an assessment of the basis for RT test elimination to determine if this basis will remain valid upon implementation of the OLM program and to determine if the RT test elimination will need to be changed to credit the OLM program rather than the periodic calibration test program.

Response to ASAI 3: SQN and WBN previously eliminated requirements for performing periodic response time testing based on the periodic calibration of transmitters that are proposed to be included in the OLM program (Reference 15 for SQN Units 1 and 2 and Reference 16 for WBN Unit 1. The changes to the WBN Unit 1 TS in Reference 16 were reflected in the initial WBN Unit 2 TS in Reference 17). SQN and WBN propose to change the basis for response time test elimination to the methodology described in Section 3.3, which is based on the noise analysis methodology described in Section 11.3 of the AMS OLM TR.

ASAI 4 - Use of Calibration Surveillance Interval Backstop In its application for a license or license amendment to incorporate OLM methods for establishing calibration surveillance intervals, applicants or licensees should describe how they intend to apply backstop intervals as a means for mitigating the potential that a process group could be experiencing undetected common mode drift characteristics.

Response to ASAI 4: The TVA OLM programs for SQN and WBN adopt the calibration surveillance interval backstop methods described in Section 3.2.9, which is based on the backstop methodology described in Section 13 of the AMS OLM TR.

The Updated Final Safety Analysis Reports (UFSAR) for SQN and WBN will be modified to add the use of AMS-TR-0720R2-A. The use of OLM to switch from time-based calibration frequency of pressure, level, and flow transmitters to a condition-based calibration frequency based on OLM results will be added to the appropriate parts of UFSAR Chapter 7, including a list of transmitters included in the OLM program. The appropriate parts of UFSAR Chapter 7 will also be changed to describe the use of OLM to assess dynamic failure modes of pressure-type sensing systems using the noise analysis technique to support the continued elimination of transmitter response time testing.

ASAI 5 - Use of Criteria other than in AMS OLM TR for Establishing Transmitter Drift Flagging Limit In its application for a license or license amendment to incorporate OLM methods for establishing calibration surveillance intervals, applicants or licensees should describe whether they intend to adopt the criteria within the AMS OLM TR for flagging transmitter drift or whether they plan to use a different methodology for determining this limit.

Enclosure CNL-24-014 E17 of 22 Response to ASAI 5: The TVA OLM program for SQN and WBN adopt the two averaging techniques (i.e., simple average and parity space) described in Section 6 of the AMS OLM TR for flagging transmitter drift.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements and Criteria 4.1.1 10 CFR 50.36 Technical Specifications 10 CFR 50.36 Technical Specifications. Part (3) of this regulation sets the governing requirements for the inclusion of Surveillance Requirements in the Technical Specifications included in the Operating License for a commercial nuclear power plant.

(3) Surveillance requirements. Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.

TVA proposes to use the AMS OLM methodology for SQN and WBN as the technical basis to support plant-specific TS changes to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results.

4.1.2 General Design Criteria SQN Units 1 and 2 were designed to meet the intent of the "Proposed General Design Criteria for Nuclear Power Plant Construction Permits published in July 1967. The Sequoyah construction permit was issued in May 1970. The UFSAR, however, addresses the NRC General Design Criteria (GDC) published as Appendix A to 10 CFR 50 in July 1971.

WBN Units 1 and 2 were designed to meet the intent of the "Proposed General Design Criteria for Nuclear Power Plant Construction Permits" published in July 1967. The WBN construction permit was issued in January 1973. The dual-unit UFSAR, however, addresses the Nuclear Regulatory Commission GDC published as Appendix A to 10 CFR 50 in July 1971.

Each criterion listed below is followed by a discussion of the design features and procedures that meet the intent of the criteria.

Criterion 21, Protection System Reliability and Testability. The protection system shall be designed for high functional reliability and in-service testability commensurate with the safety functions to be performed. Redundancy and independence designed into the protection system shall be sufficient to assure that (1) no single failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the required minimum redundancy unless the acceptable reliability of operation of the protection system can be otherwise demonstrated. The protection system shall be designed to permit periodic testing of its functioning when the reactor is in operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred.

Enclosure CNL-24-014 E18 of 22 Compliance TVA proposes to use the AMS OLM methodology for SQN and WBN as the technical basis to support plant-specific TS changes to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The OLM methodology is also proposed to be used to assess dynamic failure modes of pressure sensing systems. This change does not change the compliance with General Design Criterion 21 described in the SQN and WBN UFSARs.

4.1.3 Institute of Electrical and Electronics Engineers (IEEE) Standard 338 Compliance with IEEE Standard 338-1971, IEEE Trial-Use Criteria for the Periodic Testing of Nuclear Power Generating Station Protection Systems, is described in Chapter 7 of the SQN and WBN UFSARs.

IEEE Standard 338-1971 contains the following requirements related to sensor testing:

5. Testing 5.1 General Considerations. The periodic testing program shall be designed such that:

(1) The operancy (sic) of each channel and each subsystem of the protection system can be independently verified during reactor operation, except as noted in Section 5.2.

(2) Credible failures which cause functional interaction between channels can be detected.

(3) The test circuits and equipment shall not negate the protective function. The effects of any test-induced nonredundancy (sic) must be acceptable in terms of the reliability goals.

5.2 Test Intervals. An initial test interval shall be developed on the basis of the items outlined in Section 4.3.

Information derived from operational data and test results (especially failure rates, MTTR, and test duration) shall be used to verify or correct the initial interval selections. During the life of the equipment, the test interval may be increased or decreased consistent with maintaining the reliability goals of the subsystem (See Appendix A).

Where it is not possible to test certain devices in the system during operation, the interval between major scheduled reactor shutdowns may be used as the test interval. The designed reliability of such devices should be consistant (sic) with the test interval and the subsystem reliability goal.

Compliance with IEEE Standard 338-1971 for SQN and WBN is augmented with the use of AMS-TR-0720R2-A for the condition-based calibration of transmitters in the OLM program. The AMS OLM methodology is consistent with IEEE Standard 338-2012 IEEE Standard for Criteria for the Periodic Surveillance Testing of Nuclear Power Generating Station Safety Systems, which contains the following requirements related to sensor calibration:

5.3.3.2 On-line monitoring. On-line monitoring (OLM) techniques enable the determination of portions of an instrument channels status during plant operation. This methodology is an acceptable input for establishing calibration

Enclosure CNL-24-014 E19 of 22 frequency of those monitored portions of instrument channels without adversely affecting reliability.

Continuous monitoring shall be employed, e.g., through the plant computer.

Periodic manual testing is either a maintenance or surveillance task and is not on-line monitoring.

On-line monitoring shall ensure that setpoint calculation assumptions and the safety analysis assumptions remain valid.

4.2 Precedent This LAR is similar to the NRC-approved LAR for Vogtle Electric Generating Plant Units 1 and 2 to extend calibration intervals of nuclear plant pressure transmitters using AMS-TR-0720R2-A (References 1 and 18).

4.3 No Significant Hazards Consideration Determination Analysis In accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) 50.90, Application for amendment of license, construction permit, or early site permit, Tennessee Valley Authority (TVA) is submitting a request for an amendment to Renewed Facility Operating License Nos. DPR-77 and DPR-79 for Sequoyah Nuclear Plant (SQN), Units 1 and 2, and Facility Operating License Nos. NPF-90 and NPF-96 for Watts Bar Nuclear Plant (WBN), Units 1 and 2.

The proposed amendment revises the SQN and WBN Technical Specifications (TS) to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The proposed change is based on the Nuclear Regulatory Commission (NRC)-approved Analysis and Measurement Services Topical Report AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

TVA has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below.

1. Does the proposed amendment involve a significant increase in the probability or consequence of an accident previously evaluated?

Response: No The proposed change uses OLM methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. Switching from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency will not create any physical changes to the plant. The use of the NRC-approved OLM methodology ensures that plant safety is maintained by demonstrating that transmitters are functioning correctly.

The proposed changes do not adversely affect accident initiators or precursors, and do not alter the design assumptions, conditions, or configuration of the plant or the way the plant is operated or maintained.

Enclosure CNL-24-014 E20 of 22 Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. Existing calibration methods will be used when the need for transmitter calibration is determined. The change does not alter assumptions made in the safety analysis but ensures that the transmitters operate as assumed in the accident analysis. The proposed change is consistent with the safety analysis assumptions.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The change does not involve a physical alteration of the plant (i.e., no new or different type of equipment will be installed) or a change in the methods governing normal plant operation. The change does not alter assumptions made in the safety analysis but ensures that the transmitters operate as assumed in the accident analysis. The proposed change is consistent with the safety analysis assumptions.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, TVA concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released

Enclosure CNL-24-014 E21 of 22 offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Analysis and Measurement Services Corporation letter to NRC, Submittal of -A Version of Analysis and Measurement Services Corporation Topical Report AMS-TR-0720R2, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (Docket No. 99902075), dated August 20, 2021 (ML21235A493)
2. NRC Form 896, AMS Topical Report -A Verification, dated September 22, 2021 (ML21237A490)
3. AMS Report SYA2307R0, "OLM Amenable Transmitters Report for Sequoyah Units 1 and 2
4. AMS Report WBR2302R0, "OLM Amenable Transmitters Report for Watts Bar Units 1 and 2
5. AMS Report SYA2308R0, OLM Analysis Methods and Limits Report for Sequoyah Units 1 and 2
6. AMS Report WBR2303R0, OLM Analysis Methods and Limits Report for Watts Bar Units 1 and 2
7. AMS Report SYA2309R0, OLM Drift Monitoring Program Report for Sequoyah Units 1 and 2
8. AMS Report WBR2304R0, OLM Drift Monitoring Program Report for Watts Bar Units 1 and 2
9. AMS Procedure OLM2201R0, Procedure for Online Monitoring Data Retrieval, December 2022
10. AMS Procedure OLM2202R1, Procedure for Performing Online Monitoring Data Qualification and Analysis, August 2024
11. AMS Report SYA2310R0, OLM Noise Analysis Program Report for Sequoyah Units 1 and 2
12. AMS Report WBR2305R0, OLM Noise Analysis Program Report for Watts Bar Units 1 and 2
13. AMS Procedure NPS1501R0, Procedure for Noise Data Collection from Plant Sensors, March 2015
14. AMS Procedure NAR2201R1, Procedure for Performing Dynamic Failure Mode Assessment Using Noise Analysis, August 2024
15. NRC letter to TVA, Sequoyah Nuclear Plant, Units 1 and 2 - Issuance of Amendments Regarding Elimination of Instrumentation Response Time Testing from Technical Specifications (TAC Nos. MA6498 AND MA6499) (TS 99-08), dated February 29, 2000 (ML003687946)
16. NRC letter to TVA, Watts Bar Nuclear Plant, Unit 1 - Issuance of Amendment Regarding Elimination of Response Time Testing (TAC No. MA6768), dated June 13, 2000 (ML003724116)

Enclosure CNL-24-014 E22 of 22

17. NRC letter to TVA, Issuance of Facility Operating License No. NPF-96, Watts Bar Nuclear Plant Unit 2, dated October 22, 2015 (ML15273A064)
18. NRC letter to Southern Nuclear Operating Company, "Vogtle Electric Generating Plant, Units 1 and 2 - Issuance of Amendments Regarding Revision to Technical Specifications to Use Online Monitoring Methodology (EPID L-2022-LLA-0190)," dated June 15, 2023 (ML23115A149)

Enclosure CNL-24-014 Proposed Technical Specification Changes (Mark-Up) for SQN Units 1 and 2

Definitions 1.1 SEQUOYAH - UNIT 1 1.1-1 Amendment 334, 347, 1.0 USE AND APPLICATION 1.1 Definitions

NOTE-----------------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux signals (AFD) between the top and bottom halves of a two section excore neutron detector.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

Definitions 1.1 SEQUOYAH - UNIT 1 1.1-3 Amendment 334, 352, 362, 1.1 Definitions ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from FEATURE (ESF) RESPONSE when the monitored parameter exceeds its actuation TIME LEAKAGE setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

LEAKAGE shall be:

a.

Identified LEAKAGE 1.

LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank; 2.

LEAKAGE into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or 3.

Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);

b.

Unidentified LEAKAGE All LEAKAGE (except RCP seal water injection or leakoff) that is not identified LEAKAGE; and c.

Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a fault in an RCS component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

Definitions 1.1 SEQUOYAH - UNIT 1 1.1-5 Amendment 334, 352, 1.1 Definitions QUADRANT POWER TILT RATIO (QPTR)

RATED THERMAL POWER (RTP)

REACTOR TRIP SYSTEM (RTS) RESPONSE TIME SHUTDOWN MARGIN (SDM)

QPTR shall be the ratio of the maximum upper excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RTP shall be a total reactor core heat transfer rate to the reactor coolant of 3455 MWt.

The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level.

SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing all slave relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required slave relay.

The SLAVE RELAY TEST shall include a continuity check of associated required testable actuation devices. The SLAVE RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

Programs and Manuals 5.5 SEQUOYAH - UNIT 1 5.5-18 Amendment 358, 5.5 Programs and Manuals 5.5.18 Risk Informed Completion Time Program (continued) 2.

For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3.

Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or 2.

Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

e.

The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.

5.5.19 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

Programs and Manuals 5.5 SEQUOYAH - UNIT 1 5.5-19 Amendment 5.5 Programs and Manuals 5.5.19 Online Monitoring Program (continued) a.

Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.

1)

Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check, 2)

Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance, 3)

Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and 4)

Documentation of the results of the online monitoring data analysis.

b.

Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.

c.

Performance of calibration checks for transmitters at the specified backstop frequencies.

d.

The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

Definitions 1.1 SEQUOYAH - UNIT 2 1.1-1 Amendment 327, 341, 1.0 USE AND APPLICATION 1.1 Definitions

NOTE-----------------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux signals (AFD) between the top and bottom halves of a two section excore neutron detector.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping, or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

CHANNEL CHECK A CHANNEL CHECK shall be the qualitative assessment, by observation, of channel behavior during operation. This determination shall include, where possible, comparison of the channel indication and status to other indications or status derived from independent instrument channels measuring the same parameter.

Definitions 1.1 SEQUOYAH - UNIT 2 1.1-3 Amendment 327, 346, 356, 1.1 Definitions ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from FEATURE (ESF) RESPONSE when the monitored parameter exceeds its actuation TIME LEAKAGE setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

LEAKAGE shall be:

a.

Identified LEAKAGE 1.

LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank; 2.

LEAKAGE into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or 3.

Reactor Coolant System (RCS) LEAKAGE through a steam generator to the Secondary System (primary to secondary LEAKAGE);

b.

Unidentified LEAKAGE All LEAKAGE (except RCP seal water injection or leakoff) that is not identified LEAKAGE; and c.

Pressure Boundary LEAKAGE LEAKAGE (except primary to secondary LEAKAGE) through a fault in an RCS component body, pipe wall, or vessel wall. LEAKAGE past seals, packing, and gaskets is not pressure boundary LEAKAGE.

Definitions 1.1 SEQUOYAH - UNIT 2 1.1-5 Amendment 327, 346, 1.1 Definitions QUADRANT POWER TILT RATIO (QPTR)

RATED THERMAL POWER (RTP)

REACTOR TRIP SYSTEM (RTS) RESPONSE TIME SHUTDOWN MARGIN (SDM)

QPTR shall be the ratio of the maximum upper excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RTP shall be a total reactor core heat transfer rate to the reactor coolant of 3455 MWt.

The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and methodology for verification have been previously reviewed and approved by the NRC, (including transmitters in the Online Monitoring Program) or the components have been evaluated in accordance with an NRC approved methodology.

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level.

SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing all slave relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required slave relay.

The SLAVE RELAY TEST shall include a continuity check of associated required testable actuation devices. The SLAVE RELAY TEST may be performed by means of any series of sequential, overlapping, or total steps.

Programs and Manuals 5.5 SEQUOYAH - UNIT 2 5.5-18 Amendment 352, 5.5 Programs and Manuals 5.5.18 Risk Informed Completion Time Program (continued) 2.

For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.

3.

Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d.

For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1.

Numerically accounting for the increased possibility of CCF in the RICT calculation; or 2.

Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.

e.

The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods approved for use with this program, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundaries require prior NRC approval.

5.5.19 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

Programs and Manuals 5.5 SEQUOYAH - UNIT 2 5.5-19 Amendment 5.5 Programs and Manuals 5.5.19 Online Monitoring Program (continued) a.

Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.

1)

Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check, 2)

Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance, 3)

Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and 4)

Documentation of the results of the online monitoring data analysis.

b.

Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.

c.

Performance of calibration checks for transmitters at the specified backstop frequencies.

d.

The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

Enclosure CNL-24-014 Proposed Technical Specification Changes (Mark-Up) for WBN Units 1 and 2

Definitions 1.1 (continued)

Watts Bar-Unit 1 1.1-1 Amendment 156, 1.0 USE AND APPLICATION 1.1 Definitions

NOTE------------------------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE AFD shall be the difference in normalized flux signals between (AFD) the top and bottom halves of a two section excore neutron detector.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. THE CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or the thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

Definitions 1.1 1.1 Definitions (continued)

(continued)

Watts Bar-Unit 1 1.1-3 Amendment 24, 141, 146, 159, ENGINEERED SAFETY The ESF RESPONSE TIME shall be that time interval from FEATURE (ESF) RESPONSE when the monitored parameter exceeds its ESF actuation TIME setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC, (including transmitters in the Online Monitoring Program) or the components have been evaluated in accordance with an NRC approved methodology.

La The maximum allowable primary containment leakage rate, La, shall be.25% of primary containment air weight per day at the calculated peak containment pressure (Pa).

LEAKAGE LEAKAGE shall be:

a.

Identified LEAKAGE 1.

LEAKAGE, such as that from pump seals or valve packing (except reactor coolant pump (RCP) seal water injection or leakoff), that is captured and conducted to collection systems or a sump or collecting tank; 2.

LEAKAGE into the containment atmosphere from sources that are both specifically located and known to not interfere with the operation of leakage detection systems; or

Definitions 1.1 1.1 Definitions (continued)

(continued)

Watts Bar - Unit 1 1.1-5 Amendment 24, 31, 141, PHYSICS TESTS a.

Described in Chapter 14, Initial Test Program of the (continued)

FSAR; b.

Authorized under the provisions of 10 CFR 50.59; or c.

Otherwise approved by the Nuclear Regulatory Commission.

PRESSURE AND TEMPERATURE LIMITS REPORT QUADRANT POWER TILT RATIO (QPTR)

RATED THERMAL POWER (RTP)

REACTOR TRIP SYSTEM (RTS) RESPONSE TIME SHUTDOWN MARGIN (SDM)

The PTLR is the unit specific document that provides the RCS pressure and temperature limits for heatup, cooldown, low temperature operation, criticality, and hydrostatic testing as well as heatup and cooldown rates for the current reactor vessel fluence period. These pressure and temperature limits shall be determined for each fluence period in accordance with Specification 5.9.6. Plant operation within these operating limits is addressed in LCO 3.4.3, "RCS Pressure and Temperature (P/T) Limits," and LCO 3.4.12, "Cold Overpressure Mitigation System (COMS)."

QPTR shall be the ratio of the maximum upper excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RTP shall be a total reactor core heat transfer rate to the reactor coolant of 3459 MWt.

The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage.

The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC (including transmitters in the Online Monitoring Program), or the components have been evaluated in accordance with an NRC approved methodology.

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

Procedures, Programs, and Manuals 5.7 Watts Bar-Unit 1 5.0-25c Amendment 132, 5.7 Procedures, Programs, and Manuals 5.7.2.23 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a.

The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b.

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c.

The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

5.7.2.24 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a.

Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.

1)

Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check, 2)

Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance, 3)

Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and 4)

Documentation of the results of the online monitoring data analysis.

b.

Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.

Procedures, Programs, and Manuals 5.7 Watts Bar-Unit 1 5.0-25d Amendment 132, 5.7 Procedures, Programs, and Manuals 5.7.2.24 Online Monitoring Program (continued) c.

Performance of calibration checks for transmitters at the specified backstop frequencies.

d.

The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

Definitions 1.1 (continued)

Watts Bar - Unit 2 1.1-1 Amendment 64, 1.0 USE AND APPLICATION 1.1 Definitions

NOTE----------------------------------------------------------

The defined terms of this section appear in capitalized type and are applicable throughout these Technical Specifications and Bases.

Term Definition ACTIONS ACTIONS shall be that part of a Specification that prescribes Required Actions to be taken under designated Conditions within specified Completion Times.

ACTUATION LOGIC TEST An ACTUATION LOGIC TEST shall be the application of various simulated or actual input combinations in conjunction with each possible interlock logic state required for OPERABILITY of a logic circuit and the verification of the required logic output. The ACTUATION LOGIC TEST, as a minimum, shall include a continuity check of output devices.

AXIAL FLUX DIFFERENCE (AFD)

AFD shall be the difference in normalized flux signals between the top and bottom halves of a two section excore neutron detector.

CHANNEL CALIBRATION A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel so that it responds within the necessary range and accuracy to known values of the parameter that the channel monitors. The CHANNEL CALIBRATION shall encompass all devices in the channel required for channel OPERABILITY (excluding transmitters in the Online Monitoring Program). Calibration of instrument channels with resistance temperature detector (RTD) or thermocouple sensors may consist of an inplace qualitative assessment of sensor behavior and normal calibration of the remaining adjustable devices in the channel. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION shall include an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. The CHANNEL CALIBRATION may be performed by means of any series of sequential, overlapping or total channel steps, and each step must be performed within the Frequency in the Surveillance Frequency Control Program for the devices included in the step.

Definitions 1.1 1.1 Definitions (continued)

(continued)

Watts Bar - Unit 2 1.1-3 Amendment 47, 52, DOSE EQUIVALENT XE-133 DOSE EQUIVALENT XE-133 shall be that concentration of Xe-133 (microcuries per gram) that alone would produce the same acute dose to the whole body as the combined activities of noble gas nuclides Kr-85m, Kr-85, Kr-87, Kr-88, Xe-131m, Xe-133m, Xe-133, Xe-135m, Xe-135, and Xe-138 actually present. If a specific noble gas nuclide is not detected, it should be assumed to be present at the minimum detectable activity. The determination of DOSE EQUIVALENT XE-133 shall be performed using effective dose conversion factors for air submersion listed in Table III.1 of EPA Federal Guidance Report No. 12, 1993, External Exposure to Radionuclides in Air, Water, and Soil.

ENGINEERED SAFETY FEATURE (ESF) RESPONSE TIME The ESF RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its ESF actuation setpoint at the channel sensor until the ESF equipment is capable of performing its safety function (i.e., the valves travel to their required positions, pump discharge pressures reach their required values, etc.). Times shall include diesel generator starting and sequence loading delays, where applicable. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC, (including transmitters in the Online Monitoring Program) or the components have been evaluated in accordance with an NRC approved methodology.

La The maximum allowable primary containment leakage rate, La, shall be.25% of primary containment air weight per day at the calculated peak containment pressure (Pa).

Definitions 1.1 1.1 Definitions (continued)

(continued)

Watts Bar - Unit 2 1.1-6 Amendment 42, 47, 64,.

QUADRANT POWER TILT RATIO (QPTR)

QPTR shall be the ratio of the maximum upper excore detector calibrated output to the average of the upper excore detector calibrated outputs, or the ratio of the maximum lower excore detector calibrated output to the average of the lower excore detector calibrated outputs, whichever is greater.

RATED THERMAL POWER (RTP)

RTP shall be a total reactor core heat transfer rate to the reactor coolant of 3459 MWt.

REACTOR TRIP SYSTEM (RTS) RESPONSE TIME The RTS RESPONSE TIME shall be that time interval from when the monitored parameter exceeds its RTS trip setpoint at the channel sensor until loss of stationary gripper coil voltage. The response time may be measured by means of any series of sequential, overlapping, or total steps so that the entire response time is measured. In lieu of measurement, response time may be verified for selected components provided that the components and the methodology for verification have been previously reviewed and approved by the NRC, (including transmitters in the Online Monitoring Program) or the components have been evaluated in accordance with an NRC approved methodology.

SHUTDOWN MARGIN (SDM)

SDM shall be the instantaneous amount of reactivity by which the reactor is subcritical or would be subcritical from its present condition assuming:

a.

All rod cluster control assemblies (RCCAs) are fully inserted except for the single RCCA of highest reactivity worth, which is assumed to be fully withdrawn. With any RCCA not capable of being fully inserted, the reactivity worth of the RCCA must be accounted for in the determination of SDM; and b.

In MODES 1 and 2, the fuel and moderator temperatures are changed to the nominal zero power design level.

SLAVE RELAY TEST A SLAVE RELAY TEST shall consist of energizing all slave relays in the channel required for channel OPERABILITY and verifying the OPERABILITY of each required slave relay. The SLAVE RELAY TEST shall include a continuity check of associated required testable actuation devices. The SLAVE REALY TEST may be performed by means of any series of sequential, overlapping, or total steps.

Procedures, Programs, and Manuals 5.7 5.7 Procedures, Programs, and Manuals Watts Bar - Unit 2 5.0-27c Amendment 5.7.2.24 Online Monitoring Program This program provides controls to determine the need for calibration of pressure, level, and flow transmitters using condition monitoring based on drift analysis. It also provides a means for in-situ dynamic response assessment using the noise analysis technique to detect failure modes that are not detectable by drift monitoring.

The Online Monitoring Program must be implemented in accordance with AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (proprietary version). The program shall include the following elements:

a.

Implementation of online monitoring for transmitters that have been evaluated in accordance with an NRC approved methodology during the plant operating cycle.

1)

Analysis of online monitoring data to identify those transmitters that require a calibration check and those that do not require a calibration check, 2)

Performance of online monitoring using noise analysis to assess in-situ dynamic response of transmitters that can affect response time performance, 3)

Calibration checks of identified transmitters no later than during the next scheduled refueling outage, and 4)

Documentation of the results of the online monitoring data analysis.

b.

Performance of a calibration check for any transmitter where the online monitoring was not implemented during the plant operating cycle no later than during the next scheduled refueling outage.

c.

Performance of calibration checks for transmitters at the specified backstop frequencies.

d. The provisions of Surveillance Requirement 3.0.3 are applicable to the required calibration checks specified in items a.3, b, and c above.

Enclosure CNL-24-014 Proposed Technical Specification Bases Changes (Mark-Up) for SQN Units 1 and 2 (For Information Only)

RTS Instrumentation B 3.3.1 SEQUOYAH - UNIT 1 B 3.3.1-50 Revision 67, BASES SURVEILLANCE REQUIREMENTS (continued) within the as-left tolerance of the NTSP, then the channel shall be declared inoperable.

The second Note also requires that the methodologies for calculating the as-left and the as-found tolerances be in UFSAR, Section 7.1.2.

SR 3.3.1.9 SR 3.3.1.9 is the performance of a TADOT.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

The SR is modified by a Note that excludes verification of setpoints from the TADOT. Since this SR applies to RCP undervoltage and underfrequency relays, setpoint verification requires elaborate bench calibration and is accomplished during the CHANNEL CALIBRATION.

SR 3.3.1.10 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology. The difference between the current "as-found" values and NTSP must be consistent with the drift allowance used in the setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 15). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based

RTS Instrumentation B 3.3.1 SEQUOYAH - UNIT 1 B 3.3.1-51 Revision 45, BASES SURVEILLANCE REQUIREMENTS (continued) on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable.

SR 3.3.1.10 is modified by two Notes as identified in Table 3.3.1-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value.

Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.

The second Note requires that the as-left setting for the channel be returned to within the as-left tolerance of the NTSP. Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable.

The second Note also requires that the methodologies for calculating the as-left and the as-found tolerances be in UFSAR, Section 7.1.2.

SR 3.3.1.11 SR 3.3.1.11 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux map performed above 15% RTP. The CHANNEL CALIBRATION for the source range consists of checking the discriminator voltage and adjusting if necessary. The CHANNEL CALIBRATION for the intermediate range neutron detectors consists of comparing the output of the intermediate

RTS Instrumentation B 3.3.1 SEQUOYAH - UNIT 1 B 3.3.1-52 Revision 45, BASES SURVEILLANCE REQUIREMENTS (continued) range drawer to the secondary side calorimetric and adjusting if necessary. This Surveillance is not required for the NIS power range detectors for entry into MODE 2 or 1, and is not required for the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.11 is modified by two Notes as identified in Table 3.3.1-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value.

Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.

The second Note requires that the as-left setting for the channel be returned to within the as-left tolerance of the NTSP. Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable.

The second Note also requires that the methodologies for calculating the as-left and the as-found tolerances be in UFSAR, Section 7.1.2.

SR 3.3.1.12 SR 3.3.1.12 is the performance of a TADOT of the Manual Reactor Trip and the SI Input from ESFAS. The test shall independently verify the OPERABILITY of the undervoltage and shunt trip mechanisms for the Manual Reactor Trip Function for the Reactor Trip Breakers and Reactor Trip Bypass Breakers. The Reactor Trip Bypass Breaker test shall include testing of the automatic and manual undervoltage trip.

RTS Instrumentation B 3.3.1 SEQUOYAH - UNIT 1 B 3.3.1-53 Revision 45, BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The SR is modified by a Note that excludes verification of setpoints from the TADOT. The Functions affected have no setpoints associated with them.

SR 3.3.1.13 SR 3.3.1.13 is the performance of a TADOT of Turbine Trip Functions. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. This TADOT is as described in SR 3.3.1.4, except that this test is performed prior to exceeding the P-9 interlock whenever the unit has been in MODE 3. This Surveillance is not required if it has been performed within the previous 31 days. Verification of the Trip Setpoint does not have to be performed for this Surveillance. Performance of this test will ensure that the turbine trip Function is OPERABLE prior to exceeding the P-9 interlock.

SR 3.3.1.14 SR 3.3.1.14 verifies that the individual channel/train actuation response times are less than or equal to the maximum values assumed in the accident analysis. Response time testing acceptance criteria are included in UFSAR Table 7.2.1-5. Individual component response times are not modeled in the analyses.

The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the trip setpoint value at the sensor to the point at which the equipment reaches the required functional state (i.e.,

control and shutdown rods fully inserted in the reactor core).

For channels that include dynamic transfer Functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer Function set to one, with the resulting measured response time compared to the appropriate UFSAR response time. Alternately, the response time test can be performed with the time constants set to their nominal value, provided the required response time is analytically calculated assuming the time constants are set at their nominal values. The response time

RTS Instrumentation B 3.3.1 SEQUOYAH - UNIT 1 B 3.3.1-54 Revision 62, 67, BASES SURVEILLANCE REQUIREMENTS (continued) may be measured by a series of overlapping tests such that the entire response time is measured.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g.,

vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," (Ref. 10) provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test. Alternately, the use of the allocated RTS RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," (Ref. 13) provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time.

The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.

The response time may be verified for components that replace the components that were previously evaluated in Ref. 10 and Ref. 13, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref. 14).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

RTS Instrumentation B 3.3.1 SEQUOYAH - UNIT 1 B 3.3.1-55 Revision 67, BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.14 is modified by a Note stating that neutron detectors are excluded from RTS RESPONSE TIME testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal. Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response.

REFERENCES

1.

Regulatory Guide 1.105, Revision 3, "Setpoints for Safety Related Instrumentation."

2.

UFSAR, Chapter 7.

3.

UFSAR, Chapter 6.

4.

UFSAR, Chapter 15.

5.

IEEE-279-1971.

6.

10 CFR 50.49.

7.

Calculation SQN-EEB-PL&S, Precautions, Limitations, and Setpoints for NSSS.

8.

WCAP-14333-P-A, Rev. 1, October 1998.

9.

WCAP-10271-P-A, Supplement 1, May 1986.

10.

WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," January 1996.

11.

WCAP-10271-P-A, Supplement 2, June 1990.

12.

WCAP-15376, Rev. 0, October 2000.

13.

WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," December 1995.

14. to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only)

Response Time Testing.

15.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 SEQUOYAH - UNIT 1 B 3.3.2-50 Revision 45, BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.8 SR 3.3.2.8 is the performance of a CHANNEL CALIBRATION.

CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology. The difference between the current "as-found" values and the previous test "as-left" values must be consistent with the drift allowance used in the setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 18). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable.

SR 3.3.2.8 is modified by two Notes as identified in Table 3.3.2-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value.

Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.

The second Note requires that the as-left setting for the channel be returned to within the as-left tolerance of the NTSP. Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will

Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 SEQUOYAH - UNIT 1 B 3.3.2-51 Revision 45, BASES SURVEILLANCE REQUIREMENTS (continued) ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable.

The second Note also requires that the methodologies for calculating the as-left and the as-found tolerances be in UFSAR Section 7.1.2.

SR 3.3.2.9 This SR ensures the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the accident analysis.

Response Time testing acceptance criteria are included in the Updated Final Safety Analysis Report, Section 7.3 (Ref. 13). Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip Setpoint value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g.,

pumps at rated discharge pressure, valves in full open or closed position).

For channels that include dynamic transfer functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer functions set to one with the resulting measured response time compared to the appropriate UFSAR response time. Alternately, the response time test can be performed with the time constants set to their nominal value provided the required response time is analytically calculated assuming the time constants are set at their nominal values. The response time may be measured by a series of overlapping tests such that the entire response time is measured.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g.,

vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," (Ref. 14) dated January 1996, provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test. Alternately, the use of

Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 SEQUOYAH - UNIT 1 B 3.3.2-52 Revision 62, BASES SURVEILLANCE REQUIREMENTS (continued) the allocated RTS RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," (Ref. 15) provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time.

The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.

The response time may be verified for components that replace the components that were previously evaluated in Ref. 14 and Ref. 15, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref. 16).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 842 psig in the SGs.

SR 3.3.2.10 SR 3.3.2.10 is the performance of a TADOT as described in SR 3.3.2.7, except that it is performed for the P-4 Reactor Trip Interlock, and the Frequency is once per reactor trip breaker cycle. A successful test of the required contact(s) of a channel may be performed by the verification of the change of state of a single contact. This clarifies what is an acceptable TADOT. This Frequency is based on operating experience demonstrating that undetected failure of the P-4 interlock sometimes occurs when the reactor trip breaker is cycled.

The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Function tested has no associated setpoint.

Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 SEQUOYAH - UNIT 1 B 3.3.2-53 Revision 67, BASES REFERENCES 1.

Regulatory Guide 1.105, "Setpoint for Safety Related Instrumentation," Revision 3.

2.

UFSAR, Chapter 6.

3.

UFSAR, Chapter 7.

4.

UFSAR, Chapter 15.

5.

IEEE-279-1971.

6.

10 CFR 50.49.

7.

Calculation SQN-EEB-PL&S, Precautions, Limitations, and Setpoints for NSSS.

8.

NUREG-1218, April 1988.

9.

WCAP-14333-P-A, Rev. 1, October 1998.

10.

WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

11.

License Amendment dated June 13, 1995, Issuance of Amendments to Technical Specifications - Sequoyah Nuclear Plant, Units 1 and 2 (TAC NOS. M91990 and 91991) (ML013320052).

12.

WCAP-15376, Rev. 0. October 2000.

13.

UFSAR, Section 7.3.

14.

WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," January 1996.

15.

WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," December 1995.

16. to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only)

Response Time Testing.

17.

10 CFR 50.46.

18.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

PAM Instrumentation B 3.3.3 SEQUOYAH - UNIT 1 B 3.3.3-14 Revision 71, BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.3.2 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. This SR is modified by two Notes. The first Note excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation." The second Note excludes the Containment Area Radiation Monitors detectors from a CHANNEL CALIBRATION for decade ranges above 10R/h. A CHANNEL CALIBRATION for the Containment Area Radiation Monitors detectors for decade ranges below 10R/h is performed by a single calibration check with either an installed or portable gamma source. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the Incore thermocouple sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 5). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

REFERENCES 1.

SQN-EEB-PS-PAM-0001, PAM Variable QA Data - Base.

2.

Regulatory Guide 1.97, Revision 2, December 1980.

3.

NUREG-0737, Supplement 1, "TMI Action Items."

4.

TVA Calculation RVLIS, Revision 14, RVLIS Demonstrated Accuracy Calculation 5.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Remote Shutdown Monitoring Instrumentation B 3.3.4 SEQUOYAH - UNIT 1 B 3.3.4-4 Revision 45, BASES SURVEILLANCE REQUIREMENTS (continued)

Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and readability. If the channels are within the criteria, it is an indication that the channels are OPERABLE. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.

As specified in the Surveillance, a CHANNEL CHECK is only required for those channels which are normally energized.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.4.2 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

Whenever a temperature sensing element is replaced, the next required CHANNEL CALIBRATION of the resistance temperature detectors (RTD) sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

This SR is modified by two Notes, Note 1 excludes the neutron detectors and Note 2 excludes the reactor trip breaker indication from the CHANNEL CALIBRATION.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 2). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

REFERENCES 1.

10 CFR 50, Appendix A, GDC 19.

2.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

RTS Instrumentation B 3.3.1 SEQUOYAH - UNIT 2 B 3.3.1-50 Revision 45, 67, BASES SURVEILLANCE REQUIREMENTS (continued) within the as-left tolerance of the NTSP, then the channel shall be declared inoperable.

The second Note also requires that the methodologies for calculating the as-left and the as-found tolerances be in UFSAR, Section 7.1.2.

SR 3.3.1.9 SR 3.3.1.9 is the performance of a TADOT.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

The SR is modified by a Note that excludes verification of setpoints from the TADOT. Since this SR applies to RCP undervoltage and underfrequency relays, setpoint verification requires elaborate bench calibration and is accomplished during the CHANNEL CALIBRATION.

SR 3.3.1.10 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology. The difference between the current "as-found" values and NTSP must be consistent with the drift allowance used in the setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 15). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based

RTS Instrumentation B 3.3.1 SEQUOYAH - UNIT 2 B 3.3.1-51 Revision 45, BASES SURVEILLANCE REQUIREMENTS (continued) on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable.

SR 3.3.1.10 is modified by two Notes as identified in Table 3.3.1-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value.

Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.

The second Note requires that the as-left setting for the channel be returned to within the as-left tolerance of the NTSP. Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable.

The second Note also requires that the methodologies for calculating the as-left and the as-found tolerances be in UFSAR, Section 7.1.2.

SR 3.3.1.11 SR 3.3.1.11 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range neutron detectors consists of a normalization of the detectors based on a power calorimetric and flux map performed above 15% RTP. The CHANNEL CALIBRATION for the source range consists of checking the discriminator voltage and adjusting if necessary. The CHANNEL CALIBRATION for the intermediate range neutron detectors consists of comparing the output of the intermediate

RTS Instrumentation B 3.3.1 SEQUOYAH - UNIT 2 B 3.3.1-52 Revision 45, BASES SURVEILLANCE REQUIREMENTS (continued) range drawer to the secondary side calorimetric and adjusting if necessary. This Surveillance is not required for the NIS power range detectors for entry into MODE 2 or 1, and is not required for the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.11 is modified by two Notes as identified in Table 3.3.1-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value.

Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.

The second Note requires that the as-left setting for the channel be returned to within the as-left tolerance of the NTSP. Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable.

The second Note also requires that the methodologies for calculating the as-left and the as-found tolerances be in UFSAR, Section 7.1.2.

SR 3.3.1.12 SR 3.3.1.12 is the performance of a TADOT of the Manual Reactor Trip and the SI Input from ESFAS. The test shall independently verify the OPERABILITY of the undervoltage and shunt trip mechanisms for the Manual Reactor Trip Function for the Reactor Trip Breakers and Reactor Trip Bypass Breakers. The Reactor Trip Bypass Breaker test shall include testing of the automatic and manual undervoltage trip.

RTS Instrumentation B 3.3.1 SEQUOYAH - UNIT 2 B 3.3.1-53 Revision 45, BASES SURVEILLANCE REQUIREMENTS (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

The SR is modified by a Note that excludes verification of setpoints from the TADOT. The Functions affected have no setpoints associated with them.

SR 3.3.1.13 SR 3.3.1.13 is the performance of a TADOT of Turbine Trip Functions. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. This TADOT is as described in SR 3.3.1.4, except that this test is performed prior to exceeding the P-9 interlock whenever the unit has been in MODE 3. This Surveillance is not required if it has been performed within the previous 31 days. Verification of the Trip Setpoint does not have to be performed for this Surveillance. Performance of this test will ensure that the turbine trip Function is OPERABLE prior to exceeding the P-9 interlock.

SR 3.3.1.14 SR 3.3.1.14 verifies that the individual channel/train actuation response times are less than or equal to the maximum values assumed in the accident analysis. Response time testing acceptance criteria are included in UFSAR Table 7.2.1-5. Individual component response times are not modeled in the analyses.

The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the trip setpoint value at the sensor to the point at which the equipment reaches the required functional state (i.e.,

control and shutdown rods fully inserted in the reactor core).

For channels that include dynamic transfer Functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer Function set to one, with the resulting measured response time compared to the appropriate UFSAR response time. Alternately, the response time test can be performed with the time constants set to their nominal value, provided the required response time is analytically calculated assuming the time constants are set at their nominal values. The response time

RTS Instrumentation B 3.3.1 SEQUOYAH - UNIT 2 B 3.3.1-54 Revision 62, 67, BASES SURVEILLANCE REQUIREMENTS (continued) may be measured by a series of overlapping tests such that the entire response time is measured.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g.,

vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," (Ref. 10) provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test. Alternately, the use of the allocated RTS RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," (Ref. 13) provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time.

The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.

The response time may be verified for components that replace the components that were previously evaluated in Ref. 10 and Ref. 13, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref. 14).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

RTS Instrumentation B 3.3.1 SEQUOYAH - UNIT 2 B 3.3.1-55 Revision 62, 67, BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.14 is modified by a Note stating that neutron detectors are excluded from RTS RESPONSE TIME testing. This Note is necessary because of the difficulty in generating an appropriate detector input signal. Excluding the detectors is acceptable because the principles of detector operation ensure a virtually instantaneous response.

REFERENCES 1.

Regulatory Guide 1.105, Revision 3, "Setpoints for Safety Related Instrumentation."

2.

UFSAR, Chapter 7.

3.

UFSAR, Chapter 6.

4.

UFSAR, Chapter 15.

5.

IEEE-279-1971.

6.

10 CFR 50.49.

7.

Calculation SQN-EEB-PL&S, Precautions, Limitations, and Setpoints for NSSS.

8.

WCAP-14333-P-A, Rev. 1, October 1998.

9.

WCAP-10271-P-A, Supplement 1, May 1986.

10.

WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," January 1996.

11.

WCAP-10271-P-A, Supplement 2, June 1990.

12.

WCAP-15376, Rev. 0, October 2000.

13.

WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," December 1995.

14. to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only)

Response Time Testing.

15.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 SEQUOYAH - UNIT 2 B 3.3.2-50 Revision 45, BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.8 SR 3.3.2.8 is the performance of a CHANNEL CALIBRATION.

CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the unit specific setpoint methodology. The difference between the current "as-found" values and the previous test "as-left" values must be consistent with the drift allowance used in the setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 18). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable.

SR 3.3.2.8 is modified by two Notes as identified in Table 3.3.2-1. The first Note requires evaluation of channel performance for the condition where the as-found setting for the channel setpoint is outside its as-found tolerance but conservative with respect to the Allowable Value.

Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.

The second Note requires that the as-left setting for the channel be returned to within the as-left tolerance of the NTSP. Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures (field setting), the as-left and as-found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will

Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 SEQUOYAH - UNIT 2 B 3.3.2-51 Revision 45, BASES SURVEILLANCE REQUIREMENTS (continued) ensure that sufficient margin to the Safety Limit and/or Analytical Limit is maintained. If the as-left channel setting cannot be returned to a setting within the as-left tolerance of the NTSP, then the channel shall be declared inoperable.

The second Note also requires that the methodologies for calculating the as-left and the as-found tolerances be in UFSAR Section 7.1.2.

SR 3.3.2.9 This SR ensures the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the accident analysis.

Response Time testing acceptance criteria are included in the Updated Final Safety Analysis Report, Section 7.3 (Ref. 13). Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip Setpoint value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g.,

pumps at rated discharge pressure, valves in full open or closed position).

For channels that include dynamic transfer functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer functions set to one with the resulting measured response time compared to the appropriate UFSAR response time. Alternately, the response time test can be performed with the time constants set to their nominal value provided the required response time is analytically calculated assuming the time constants are set at their nominal values. The response time may be measured by a series of overlapping tests such that the entire response time is measured.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g.,

vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," (Ref. 14) dated January 1996, provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test. Alternately, the use of the allocated RTS RESPONSE TIME for transmitters in the Online

Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 SEQUOYAH - UNIT 2 B 3.3.2-52 Revision 62, BASES SURVEILLANCE REQUIREMENTS (continued)

Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," (Ref. 15) provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time.

The allocations for sensor, signal conditioning, and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.

The response time may be verified for components that replace the components that were previously evaluated in Ref. 14 and Ref. 15, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref. 16).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note that clarifies that the turbine driven AFW pump is tested within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after reaching 842 psig in the SGs.

SR 3.3.2.10 SR 3.3.2.10 is the performance of a TADOT as described in SR 3.3.2.7, except that it is performed for the P-4 Reactor Trip Interlock, and the Frequency is once per reactor trip breaker cycle. A successful test of the required contact(s) of a channel may be performed by the verification of the change of state of a single contact. This clarifies what is an acceptable TADOT. This Frequency is based on operating experience demonstrating that undetected failure of the P-4 interlock sometimes occurs when the reactor trip breaker is cycled.

The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Function tested has no associated setpoint.

Engineered Safety Feature Actuation System (ESFAS) Instrumentation B 3.3.2 SEQUOYAH - UNIT 2 B 3.3.2-53 Revision 62, 67, BASES REFERENCES 1.

Regulatory Guide 1.105, "Setpoint for Safety Related Instrumentation," Revision 3.

2.

UFSAR, Chapter 6.

3.

UFSAR, Chapter 7.

4.

UFSAR, Chapter 15.

5.

IEEE-279-1971.

6.

10 CFR 50.49.

7.

Calculation SQN-EEB-PL&S, Precautions, Limitations, and Setpoints for NSSS.

8.

NUREG-1218, April 1988.

9.

WCAP-14333-P-A, Rev. 1, October 1998.

10.

WCAP-10271-P-A, Supplement 2, Rev. 1, June 1990.

11.

License Amendment dated June 13, 1995, Issuance of Amendments to Technical Specifications - Sequoyah Nuclear Plant, Units 1 and 2 (TAC NOS. M91990 and 91991) (ML013320052).

12.

WCAP-15376, Rev. 0. October 2000.

13.

UFSAR, Section 7.3.

14.

WCAP-13632-P-A, Revision 2, "Elimination of Pressure Sensor Response Time Testing Requirements," January 1996.

15.

WCAP-14036-P, Revision 1, "Elimination of Periodic Protection Channel Response Time Tests," December 1995.

16. to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only)

Response Time Testing.

17.

10 CFR 50.46.

18.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

PAM Instrumentation B 3.3.3 SEQUOYAH - UNIT 2 B 3.3.3-14 Revision 45, BASES SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.3.2 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. This SR is modified by two Notes. The first Note excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation." The second Note excludes the Containment Area Radiation Monitors detectors from a CHANNEL CALIBRATION for decade ranges above 10R/h. A CHANNEL CALIBRATION for the Containment Area Radiation Monitors detectors for decade ranges below 10R/h is performed by a single calibration check with either an installed or portable gamma source. Whenever a sensing element is replaced, the next required CHANNEL CALIBRATION of the Incore thermocouple sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

SQN-EEB-PS-PAM-0001, PAM Variable QA Data - Base.

2.

Regulatory Guide 1.97, Revision 2, December 1980.

3.

NUREG-0737, Supplement 1, "TMI Action Items."

4.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Remote Shutdown Monitoring Instrumentation B 3.3.4 SEQUOYAH - UNIT 2 B 3.3.4-4 Revision 45, BASES SURVEILLANCE REQUIREMENTS (continued)

Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including indication and readability. If the channels are within the criteria, it is an indication that the channels are OPERABLE. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.

As specified in the Surveillance, a CHANNEL CHECK is only required for those channels which are normally energized.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.4.2 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

Whenever a temperature sensing element is replaced, the next required CHANNEL CALIBRATION of the resistance temperature detectors (RTD) sensors is accomplished by an inplace cross calibration that compares the other sensing elements with the recently installed sensing element.

This SR is modified by two Notes, Note 1 excludes the neutron detectors and Note 2 excludes the reactor trip breaker indication from the CHANNEL CALIBRATION.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 2). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

REFERENCES 1.

10 CFR 50, Appendix A, GDC 19.

2.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Enclosure CNL-24-014 Proposed Technical Specification Bases Changes (Mark-Up) for WBN Units 1 and 2 (For Information Only)

RTS Instrumentation B 3.3.1 Bases (continued)

Watts Bar-Unit 1 B 3.3-49 Revision 34, 90, 185, Amendment 24, 68, 156, SURVEILLANCE SR 3.3.1.10 REQUIREMENTS (continued)

CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the Watts Bar setpoint methodology. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 18). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable.

For channels with a trip time delay (TTD), this test shall include verification that the TTD coefficients are adjusted correctly.

SR 3.3.1.11 SR 3.3.1.11 is the performance of a CHANNEL CALIBRATION, as described in SR 3.3.1.10. This SR is modified by a Note stating that neutron detectors are excluded from the CHANNEL CALIBRATION. The CHANNEL CALIBRATION for the power range neutron detectors consists of a normalization of the detectors based on a power calorimetric performed above 15% RTP. The CHANNEL CALIBRATION for the source range and intermediate range neutron detectors consists of obtaining the detector plateau or preamp discriminator curves, evaluating those curves, and comparing the curves to the manufacturer's data.

This Surveillance is not required for the NIS power range detectors for entry into MODE 2 or 1, and is not required for the NIS intermediate range detectors for entry into MODE 2, because the unit must be in at least MODE 2 to perform the test for the intermediate range detectors and MODE 1 for the power range detectors.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.1.12 SR 3.3.1.12 is the performance of a COT of RTS interlocks. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable CHANNEL OPERATIONAL TEST of a relay. This is acceptable

RTS Instrumentation B 3.3.1 Bases (continued)

Watts Bar-Unit 1 B 3.3-51 Revision 34, 90, Amendment 24, 68, SURVEILLANCE SR 3.3.1.15 REQUIREMENTS (continued)

SR 3.3.1.15 verifies that the individual channel/train actuation response times are less than or equal to the maximum values assumed in the accident analysis.

Response time testing acceptance criteria are included in Technical Requirements Manual, Section 3.3.1 (Ref. 8). Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the trip setpoint value at the sensor to the point at which the equipment reaches the required functional state (i.e.,

control and shutdown rods fully inserted in the reactor core).

For channels that include dynamic transfer Functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer Function set to one, with the resulting measured response time compared to the appropriate FSAR response time. Alternately, the response time test can be performed with the time constants set to their nominal value, provided the required response time is analytically calculated assuming the time constants are set at their nominal values. The response time may be measured by a series of sequential tests such that the entire response time is measured.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from: (1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g. vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements (Reference 11), provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test.

Alternately, the use of the allocated RTS RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

RTS Instrumentation B 3.3.1 Bases Watts Bar-Unit 1 B 3.3-52a Revision 13, 34, 60, 90, 104, 170, Amendment 24, 47, 68, 82, 141, REFERENCES 7.

WCAP-10271-P-A, Supplement 1, and Supplement 2, Rev. 1, (continued)

"Evaluation of Surveillance Frequencies and Out of Service Times for the Reactor Protection Instrumentation System," May 1986 and June 1990.

8.

Watts Bar Technical Requirements Manual, Section 3.3.1, "Reactor Trip System Response Times."

9.

Evaluation of the applicability of WCAP-10271-P-A, Supplement 1, and Supplement 2, Revision 1, to Watts Bar, Westinghouse Letter WAT-D-10128.

10.

ISA-DS-67.04, 1982, "Setpoint for Nuclear Safety Related Instrumentation Used in Nuclear Power Plants."

11.

WCAP-13632-P-A Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements, January 1996 12.

WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests, October 1998.

13.

WCAP-16067-P, Rev. 0, RCS Flow Measurement Using Elbow Tap Methodology at Watts Bar Unit 1, April 2003.

14.

WCAP-14333 P-A, Revision 1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, October 1998.

15.

WCAP-15376-P-A, Revision 1, Risk Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times, March 2003.

16.

WCAP-12472-P-A,BEACON Core Monitoring and Operations Support System, August 1994.

17. to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing.

18.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

EFAS Instrumentation B 3.3.2 BASES (continued)

Watts Bar-Unit 1 B 3.3-97 Revision 26, 162, Amendment 17, 132, SURVEILLANCE SR 3.3.2.9 (continued)

REQUIREMENTS CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the Watts Bar setpoint methodology.

The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 23). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable. For channels with a trip time delay (TTD), this test shall include verification that the TTD coefficients are adjusted correctly.

SR 3.3.2.10 This SR ensures the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the accident analysis. Response Time testing acceptance criteria are included in Technical Requirements Manual, Section 3.3.2 (Ref. 8). Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the Trip Setpoint value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g., pumps at rated discharge pressure, valves in full open or closed position).

For channels that include dynamic transfer functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer functions set to one with the resulting measured response time compared to the appropriate FSAR response time. Alternately, the response time test can be performed with the time constants set to their nominal value provided the required response time is analytically calculated assuming the time constants are set at their nominal values. The response time may be measured by a series of sequential tests such that the entire response time is measured.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from: (1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g. vendor) test measurements, or (3) utilizing vendor engineering specifications.

WCAP-13632-P-A Revision 2, Elimination of Pressure Sensor Response

EFAS Instrumentation B 3.3.2 BASES Watts Bar-Unit 1 B 3.3-98 Revision 20,30, 162, 177, 185, Amendment 13,23,132, 148, 156, SURVEILLANCE SR 3.3.2.10 (continued)

REQUIREMENTS Time Testing Requirements (Reference 15), provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test. Alternately, the use of the allocated RTS RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests (Reference 16), provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for sensor, signal conditioning and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.

The response time may be verified for components that replace the components that were previously evaluated in Ref. 15 and Ref. 16, provided that the components have been evaluated in accordance with the NRC approved methodology as discussed in Attachment 1 to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only) Response Time Testing, (Ref. 21).

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR is modified by a Note indicating that the SR should be deferred until suitable test conditions are established. This deferral is required because there may be insufficient steam pressure to perform the test.

There is an additional note pertaining to this SR on Page 3 of Table 3.3.2-1 of the Technical Specification, which states the following (Ref. 14):

Note h: For the time period between February 23, 2000 and prior to turbine restart (following the next time the turbine is removed from service), the response time test requirement of SR 3.3.2.10 is not applicable for 1-FSV-47-027.

SR 3.3.2.11 SR 3.3.2.11 is the performance of a TADOT as described in SR 3.3.2.8, except that it is performed for the P-4 Reactor Trip Interlock, and the Frequency is once per RTB cycle. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is

EFAS Instrumentation B 3.3.2 BASES (continued)

Watts Bar-Unit 1 B 3.3-99 Revision 96, 170, 176, Amendment 75, 141, 143, SURVIELLANCE SR 3.3.2.11 (continued)

REQUIREMENTS (continued) acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. This Frequency is based on operating experience demonstrating that undetected failure of the P-4 interlock sometimes occurs when the RTB is cycled.

The SR is modified by a Note that excludes verification of setpoints during the TADOT. The Function tested has no associated setpoint.

SR 3.3.2.12 SR 3.3.2.12 is the verification that the SBMFWP channel is in the trip status when a TDMFWP is supplying feedwater to the steam generators (SGs). The Frequency is once within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> during startup after the first TDMFWP is supplying feedwater to the steam generators and in accordance with the Surveillance Frequency Control Program thereafter. This SR is accomplished by verification of the SBMFWP breaker interlock hand switch (WBN-1-HS-003-0200D, Standby Feedwater Pump Breaker Interlock) is in the trip position. This SR ensures that the SBMFWP breaker interlock hand switch is in the correct position when a TDMFW pump is supplying FW to the SGs.

REFERENCES 1.

Watts Bar FSAR, Section 6.0, "Engineered Safety Features."

2.

Watts Bar FSAR, Section 7.0, "Instrumentation and Controls."

3.

Watts Bar FSAR, Section 15.0, "Accident Analyses."

4.

Institute of Electrical and Electronic Engineers, IEEE-279-1971, "Criteria for Protection Systems for Nuclear Power Generating Stations," April 5, 1972.

5.

Code of Federal Regulations, Title 10, Part 50.49, "Environmental Qualification of Electrical Equipment Important to Safety for Nuclear Power Plants."

6.

WCAP-12096, Rev. 7, "Westinghouse Setpoint Methodology for Protection System, Watts Bar 1 and 2," March 1997.

7.

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 System," and "Evaluation of Surveillance Frequencies and Out of Service Times for the Engineered Safety Features Actuation System." May 1986 and June 1990.

8.

Watts Bar Technical Requirements Manual, Section 3.3.2, "Engineered Safety Feature Response Times."

9.

DELETED

EFAS Instrumentation B 3.3.2 BASES (continued)

Watts Bar-Unit 1 B 3.3-100 Revision 96, 170, 176, Amendment 75, 141, 143, REFERENCES 10.

Evaluation of the applicability of WCAP-10271-P-A, Supplement 1, and (continued)

Supplement 2, Revision 1, to Watts Bar, Westinghouse letter to TVA WAT-D-10128.

11.

DELETED 12.

DELETED 13.

DELETED 14.

TVAs Letter to NRC dated February 25, 2000, WBN Unit 1 Request for TS Amendment for TS 3.3.2 - ESFAS Instrumentation.

15.

WCAP-13632-P-A Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements, January 1996.

16.

WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests, October 1998.

17.

WCAP-14333-P-A, Revision 1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, October 1998.

18.

DELETED 19.

Westinghouse letter to TVA, WAT-D-11248, Revised Justification for Applicability of Instrumentation Technical Specification Improvements to the Automatic Switchover to Containment Sump Signal, June 2004.

20.

Letter from John G. Lamb (NRC) to Mr. Preston D. Swafford (TVA) dated March 4, 2009, Includes Enclosures (a) Amendment No. 75 to Facility Operating License No. NPF-90 for Watts Bar Nuclear Plant, Unit 1 and (b) NRC Safety Evaluation (SE) for Amendment No. 75.

21. to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (Fore Westinghouse Plants only) Response Time Testing.

22.

Code of Federal Regulations, Title 10, Part 50.46, Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Reactors.

23.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

PAM Instrumentation B 3.3.3 BASES (continued)

Watts Bar-Unit 1 B 3.3-116 Revision 94, 162, Amendment 72, 132, SURVEILLANCE SR 3.3.3.1 (continued)

REQUIREMENTS Agreement criteria are determined by the unit staff, based on a combination of the channel instrument uncertainties, including isolation, indication, and readability. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit. If the channels are within the criteria, it is an indication that the channels are OPERABLE.

As specified in the SR, a CHANNEL CHECK is only required for those channels that are normally energized.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.3.2 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. This SR is modified by two Notes.

Note 1 excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, "Reactor Trip System (RTS)

Instrumentation." Note 2 indicates that Function 11 and 16 (valve position indicators) are excluded from the CHANNEL CALIBRATION. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 5). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

SR 3.3.3.3 SR 3.3.3.3 is the performance of a TADOT. The test checks operation of the containment isolation valve position indicators and AFW valve position indicators.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR has been modified by two Notes. Note 1 excludes verification of setpoints for the valve position indicators. Note 2 indicates that this SR is only applicable to Functions 11 and 16, which are the only Functions with valve position indicators.

PAM Instrumentation B 3.3.3 BASES Watts Bar-Unit 1 B 3.3-117 Revision Amendment REFERENCES 1.

NUREG-0847, Safety Evaluation Report, Supplement Number 9, June 16, 1992, Section 7.5.2, "Post Accident Monitoring System."

2.

Regulatory Guide 1.97, Revision 2, December 1980, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident."

3.

NUREG-0737, "Clarification of TMI Action Plan Requirements,"

Supplement 1, January 1983.

4.

Submittal from John H. Garrity to U.S. Nuclear Regulatory Commission dated January 24, 1992, "Watts Bar Nuclear Plant (WBN) Units 1 and 2 -

NUREG 0737, Item II.F.2 - Instrumentation for Detection of Inadequate Core Cooling (ICC) - Proposed License Condition 3 (TAC Numbers M77132 and M77133).

5.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Remote Shutdown System B 3.3.4 BASES (continued)

Watts Bar-Unit 1 B 3.3-122 Revision 162, Amendment 132, SURVEILLANCE SR 3.3.4.1 (continued)

REQUIREMENTS Agreement criteria are determined by the plant staff, based on a combination of the channel instrument uncertainties, including indication and readability. If the channels are within the criteria, it is an indication that the channels are OPERABLE. If a channel is outside the criteria, it may be an indication that the sensor or the signal processing equipment has drifted outside its limit.

As specified in the Surveillance, a CHANNEL CHECK is only required for those channels which are normally energized.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.4.2 SR 3.3.4.2 verifies each required Remote Shutdown System control circuit and transfer switch performs the intended function. This verification is performed from the auxiliary control room and locally, as appropriate. Operation of the equipment from the remote shutdown panel is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the plant can be placed and maintained in MODE 3 from the auxiliary control room and the local control stations. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.4.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 5). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

Remote Shutdown System B 3.3.4 BASES Watts Bar-Unit 1 B 3.3-123 Revision 162, 185, Amendment 132, 156, SURVEILLANCE SR 3.3.4.4 REQUIREMENTS (continued)

SR 3.3.4.4 is the performance of a TADOT. This test should verify the OPERABILITY of the reactor trip breakers (RTBs) open and closed indication on the remote shutdown panel, by actuating the RTBs. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

REFERENCES 1.

Title 10, Code of Federal Regulations, Part 50, Appendix A, "General Design Criteria 19, "Control Room."

2.

Watts Bar FSAR Section 7.4, "Systems Required for Safe Shutdown."

3.

TVA Calculation WBN-OSG4-193, "Auxiliary Control System Required Equipment per GDC 19."

4.

Design Criteria WB-DC-40-58, "Auxiliary Control System."

5.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

RTS Instrumentation B 3.3.1 BASES (continued)

Watts Bar - Unit 2 B 3.3-57 Revision 34, 64, Amendment 36, 64, SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.1.9 SR 3.3.1.9 is the performance of a TADOT and the Surveillance Frequency is controlled under the Surveillance Frequency Control Program. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay is verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions.

The SR is modified by a Note that excludes verification of setpoints from the TADOT. Since this SR applies to RCP undervoltage and underfrequency relays, setpoint verification requires elaborate bench calibration and is accomplished during the CHANNEL CALIBRATION.

SR 3.3.1.10 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the Watts Bar setpoint methodology. The difference between the current "as found" values and the NTSP or previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 19). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

SR 3.3.1.10 is modified by a Note stating that this test shall include verification that the time constants are adjusted to the prescribed values where applicable. For channels with a trip time delay (TTD), this test shall include verification that the TTD coefficients are adjusted correctly.

RTS Instrumentation B 3.3.1 BASES (continued)

Watts Bar - Unit 2 B 3.3-61 Revision Amendment SURVEILLANCE REQUIREMENTS SR 3.3.1.15 (continued)

Individual component response times are not modeled in the analyses.

The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the trip setpoint value at the sensor to the point at which the equipment reaches the required functional state (i.e., control and shutdown rods fully inserted in the reactor core).

For channels that include dynamic transfer Functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer Function set to one, with the resulting measured response time compared to the appropriate FSAR response time. Alternately, the response time test can be performed with the time constants set to their nominal value, provided the required response time is analytically calculated assuming the time constants are set at their nominal values. The response time may be measured by a series of sequential tests such that the entire response time is measured.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g. vendor) test measurements, or (3) utilizing vendor engineering specifications.

WCAP-13632-P-A Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements (Ref. 11), provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test. Alternately, the use of the allocated RTS RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests (Ref. 12), provides the basis and methodology for using allocated signal processing and actuation logic response times in the overall verification of the protection system channel response time. The allocations for sensor, signal conditioning and actuation logic response times must be verified prior to placing the component in operational service and re-verified following maintenance that may adversely affect response time. In general, electrical repair work does not impact response time provided the parts used for repair are of the same type and value. Specific components identified in the WCAP may be replaced without verification testing. One example where response time could be affected is replacing the sensing assembly of a transmitter.

RTS Instrumentation B 3.3.1 BASES Watts Bar - Unit 2 B 3.3-63 Revision 46, Amendment 47, REFERENCES (continued) 10.

Deleted 11.

WCAP-13632-P-A Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements, January 1996 12.

WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests, October 1998.

13.

Deleted.

14.

WCAP-14333 P-A, Revision 1, Probabilistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, October 1998.

15.

WCAP-15376-P-A, Revision 1, Risk Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times, March 2003 16.

WCAP-12472-P-A, BEACON' Core Monitoring and Operations Support System, August 1994 (Addendum 2, April 2002).

17.

TVA Calculation WBPE0689009007, Demonstrated Accuracy Calculation for Reactor Coolant Pump Undervoltage.

18. to TSTF-569, Methodology to Eliminate Pressure Sensor and Protection Channel (for Westinghouse Plants only)

Response Time Testing.

19.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

ESFAS Instrumentation B 3.3.2 BASES (continued)

Watts Bar - Unit 2 B 3.3-117 Revision 34, 64, Amendment 36, 64, SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.9 SR 3.3.2.9 is the performance of a CHANNEL CALIBRATION.

CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter within the necessary range and accuracy.

CHANNEL CALIBRATIONS must be performed consistent with the assumptions of the Watts Bar setpoint methodology. The difference between the current "as found" values and the previous test "as left" values must be consistent with the drift allowance used in the setpoint methodology.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 24). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

This SR is modified by a Note stating that this test should include verification that the time constants are adjusted to the prescribed values where applicable. For channels with a trip time delay (TTD), this test shall include verification that the TTD coefficients are adjusted correctly.

SR 3.3.2.9 is modified by two Notes as identified in Table 3.3.2-1. The first Note requires evaluation of channel performance for the condition where the as found setting for the channel setpoint is outside its as found tolerance but conservative with respect to the Allowable Value.

Evaluation of channel performance will verify that the channel will continue to behave in accordance with safety analysis assumptions and the channel performance assumptions in the setpoint methodology. The purpose of the assessment is to ensure confidence in the channel performance prior to returning the channel to service. For channels determined to be OPERABLE but degraded, after returning the channel to service the performance of these channels will be evaluated under the plant Corrective Action Program. Entry into the Corrective Action Program will ensure required review and documentation of the condition.

The second Note requires that the as left setting for the channel be returned to within the as left tolerance of the NTSP. Where a setpoint more conservative than the NTSP is used in the plant surveillance procedures (field setting), the as left and as found tolerances, as applicable, will be applied to the surveillance procedure setpoint. This will ensure that sufficient margin to the Safety Limit and/or Analytical Limit is

ESFAS Instrumentation B 3.3.2 BASES (continued)

Watts Bar - Unit 2 B 3.3-118 Revision Amendment SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.2.9 (continued) maintained. If the as left channel setting cannot be returned to a setting within the as left tolerance of the NTSP, then the channel shall be declared inoperable.

SR 3.3.2.10 This SR ensures the individual channel ESF RESPONSE TIMES are less than or equal to the maximum values assumed in the accident analysis.

Response Time testing acceptance criteria are included in Technical Requirements Manual, Section 3.3.2 (Ref. 8). Individual component response times are not modeled in the analyses. The analyses model the overall or total elapsed time, from the point at which the parameter exceeds the NTSP value at the sensor, to the point at which the equipment in both trains reaches the required functional state (e.g.,

pumps at rated discharge pressure, valves in full open or closed position).

For channels that include dynamic transfer functions (e.g., lag, lead/lag, rate/lag, etc.), the response time test may be performed with the transfer functions set to one with the resulting measured response time compared to the appropriate FSAR response time. Alternately, the response time test can be performed with the time constants set to their nominal value provided the required response time is analytically calculated assuming the time constants are set at their nominal values. The response time may be measured by a series of sequential tests such that the entire response time is measured.

Response time may be verified by actual response time tests in any series of sequential, overlapping or total channel measurements, or by the summation of allocated sensor, signal processing and actuation logic response times with actual response time tests on the remainder of the channel. Allocations for sensor response times may be obtained from:

(1) historical records based on acceptable response time tests (hydraulic, noise, or power interrupt tests), (2) in place, onsite, or offsite (e.g., vendor) test measurements, or (3) utilizing vendor engineering specifications. WCAP-13632-P-A Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements (Ref. 15), provides the basis and methodology for using allocated sensor response times in the overall verification of the channel response time for specific sensors identified in the WCAP. Response time verification for other sensor types must be demonstrated by test. Alternately, the use of the allocated RTS RESPONSE TIME for transmitters in the Online Monitoring Program is supported by the performance of ONLINE MONITORING using the 'noise analysis' technique to detect dynamic failures modes that can affect transmitter response time.

ESFAS Instrumentation B 3.3.2 BASES Watts Bar - Unit 2 B 3.3-121 Revision 58, Amendment 55, REFERENCES (continued) 10.

Evaluation of the applicability of WCAP-10271-P-A, Supplement 1, and Supplement 2, Revision 1, to Watts Bar, Westinghouse letter to TVA WAT-D-10128.

11.

Deleted 12.

Deleted 13.

Deleted 14.

Not Applicable for Unit 2 15.

WCAP-13632-P-A Revision 2, Elimination of Pressure Sensor Response Time Testing Requirements, January 1996.

16.

WCAP-14036-P-A, Revision 1, Elimination of Periodic Protection Channel Response Time Tests, October 1998.

17.

WCAP-14333-P-A, Revision 1, Probablistic Risk Analysis of the RPS and ESFAS Test Times and Completion Times, October 1998 18.

Deleted 19.

Westinghouse letter to TVA, WAT-D-11248, Revised Justification for Applicability of Instrumentation Technical Specification Improvements to the Automatic Switchover to Containment Sump Signal, June 2004.

20.

Letter from John G. Lamb (NRC) to Mr. Preston D. Swafford (TVA) dated March 4, 2009, Includes Enclosures (a) Amendment No. 75 to Facility Operating License No. NPF-90 for Watts Bar Nuclear Plant, Unit 1 and (b) NRC Safety Evaluation (SE) for Amendment No. 75.

21.

Deleted 22.

WCAP-13878-P-A, Revision 2, Reliability Assessment of Potter &

Brumfield MDR Series Relays.

23.

Code of Federal Regulations, Title 10, Part 50.46, "Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Reactors."

24.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

PAM Instrumentation B 3.3.3 BASES Watts Bar - Unit 2 B 3.3-136 (continued)

Revision 34, Amendment 36, SURVEILLANCE REQUIREMENTS SR 3.3.3.1 (continued)

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.3.2 CHANNEL CALIBRATION is a complete check of the instrument loop, including the sensor. The test verifies that the channel responds to measured parameter with the necessary range and accuracy. This SR is modified by two Notes. Note 1 excludes neutron detectors. The calibration method for neutron detectors is specified in the Bases of LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation." Note 2 indicates that Functions 11 and 16 (valve position indicators) are excluded from the CHANNEL CALIBRATION. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 4). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

SR 3.3.3.3 SR 3.3.3.3 is the performance of a TADOT. The test checks operation of the containment isolation valve position indicators and AFW valve position indicators. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

This SR has been modified by two Notes. Note 1 excludes verification of setpoints for the valve position indicators. Note 2 indicates that this SR is only applicable to Functions 11 and 16, which are the only Functions with valve position indicators.

PAM Instrumentation B 3.3.3 BASES (continued)

Watts Bar - Unit 2 B 3.3-137 Revision Amendment REFERENCES 1.

NUREG-0847, Safety Evaluation Report, Supplement Number 9, June 16, 1992, Section 7.5.2, "Post Accident Monitoring System."

2.

Regulatory Guide 1.97, Revision 2, December 1980, "Instrumentation for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions During and Following an Accident."

3.

NUREG-0737, "Clarification of TMI Action Plan Requirements,"

Supplement 1, January 1983.

4.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

Remote Shutdown System B 3.3.4 BASES (continued)

Watts Bar - Unit 2 B 3.3-142 Revision 34, 64, Amendment 36, 64, SURVEILLANCE REQUIREMENTS (continued)

SR 3.3.4.2 SR 3.3.4.2 verifies each required Remote Shutdown System control circuit and transfer switch performs the intended function. This verification is performed from the auxiliary control room and locally, as appropriate. Operation of the equipment from the remote shutdown panel is not necessary. The Surveillance can be satisfied by performance of a continuity check. This will ensure that if the control room becomes inaccessible, the plant can be placed and maintained in MODE 3 from the auxiliary control room and the local control stations. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.3.4.3 CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor. The test verifies that the channel responds to a measured parameter within the necessary range and accuracy.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. Alternately, the CHANNEL CALIBRATION Frequency for pressure, level, and flow transmitters may be determined in accordance with the Online Monitoring Program implemented in accordance with AMS-TR-0720R2-A (Ref. 5). In cases where ONLINE MONITORING cannot be performed during the monitoring period, the transmitter would need to be calibrated within the interval specified based on the Surveillance Frequency Control Program measured since the last valid Online Monitoring Program assessment.

SR 3.3.4.4 SR 3.3.4.4 is the performance of a TADOT. This test should verify the OPERABILITY of the reactor trip breakers (RTBs) open and closed indication on the remote shutdown panel, by actuating the RTBs. A successful test of the required contact(s) of a channel relay may be performed by the verification of the change of state of a single contact of the relay. This clarifies what is an acceptable TADOT of a relay. This is acceptable because all of the other required contacts of the relay are verified by other Technical Specifications and non-Technical Specifications tests at least once per refueling interval with applicable extensions. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

Remote Shutdown System B 3.3.4 BASES (continued)

Watts Bar - Unit 2 B 3.3-143

Revision, Amendment, REFERENCES 1.

Title 10, Code of Federal Regulations, Part 50, Appendix A, "General Design Criteria 19, "Control Room."

2.

Watts Bar FSAR Section 7.4, "Systems Required for Safe Shutdown."

3.

TVA Calculation WBN-OSG4-193, "Auxiliary Control System Required Equipment per GDC 19."

4.

Design Criteria WB-DC-40-58, "Auxiliary Control System."

5.

AMS-TR-0720R2-A, "Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters."

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