Text

Response to Request for Additional Information Regarding License Amendment Request for a One-Time Extension of Technical Specification Surveillance Requirements for AC Sources
	ML17065A309
Person / Time
Site:	Watts Bar
Issue date:	03/06/2017
From:	James Shea; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	CAC MF8184, CAC MF8482, CNL-17-029
	Download: ML17065A309 (16)
	v • d • e

Tennessee Valley Authority, 1101 Market Street, Chattanooga, Tennessee 37402 CNL-17-029 March 6, 2017 10 CFR 50.90 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 Facility Operating License No. NPF-96 NRC Docket No. 50-391

Subject:

Response to Request for Additional Information Regarding License Amendment Request for a One-Time Extension of Technical Specification Surveillance Requirements for AC Sources Watts Bar Nuclear Plant, Units 1 and 2 (CAC Nos. MF8481 and MF8482)

Reference:

1. TVA Letter to NRC, CNL-16-164, Application to Modify Watts Bar Nuclear Plant, Units 1 and 2 Technical Specifications to Extend Surveillance Requirement Intervals for AC Sources (WBN-TS-16-024),

dated October 17, 2016 (ML16291A543)

2. NRC Electronic Mail to TVA, Watts Bar Units 1 and 2 - Request for Additional Information Regarding License Amendment Request for a One-time Extension of Technical Specification Surveillance Requirements for AC Sources (CAC Nos. MF8481 and MF8482), dated February 13, 2017

3. TVA Letter to NRC, CNL-16-110, Application to Modify Watts Bar Nuclear Plant Unit 2 Technical Specifications to Extend Surveillance Requirement Specified Intervals (WBN-TS-16-020), dated November 23, 2016 (ML16333A250)

In Reference 1, the Tennessee Valley Authority (TVA) submitted a request for an amendment to the Watts Bar Nuclear Plant (WBN) Unit 2 Technical Specifications (TS) to extend, on a one-time basis, a limited number of Surveillance Requirements (SRs) relating to AC Sources. Specifically, for WBN Unit 1, the proposed amendment would revise the TSs to allow a one-time extension of 18-month SRs 3.8.1.9, 3.8.1.10, 3.8.1.11, 3.8.1.13, 3.8.1.16, 3.8.1.18, and 3.8.1.19 to November 30, 2017. For WBN Unit 2, the proposed amendment would revise the TSs to allow a one-time extension of 18-month SRs 3.8.1.9, 3.8.1.10, 3.8.1.11, 3.8.1.12, 3.8.1.13, 3.8.1.16, 3.8.1.17, 3.8.1.18, and 3.8.1.19 to November 30, 2017. In Reference 2, the Nuclear Regulatory Commission (NRC) transmitted a request for additional information (RAI).

U.S. Nuclear Regulatory Commission CNL-17-029 Page 2 March 6, 2017 The enclosure to this letter provides the TVA response to the RAI. These responses do not change the no significant hazards considerations determination contained in Reference 1.

Based on discussions with the NRC Project Manager for WBN, TVA is revising the proposed change to SR 3.0.2 for WBN Unit 1 and WBN Unit 2, which was provided in Reference 1, as follows, in order to avoid confusion with similar changes proposed to SR 3.0.2 in Reference 3:

For WBN Unit 1from "and expires November 30, 2017' to "to be completed no later than November 30, 2017."

For WBN Unit 2, Reference 1 proposed to revise SR 3.0.2, from "and expires October 31, 2017" to "and expires November 30, 2017." This proposed change is being revised from "and expires November 30, 2017" to "to be completed no later than November 30, 2017."

Attachments 1 and 2 to Enclosure 2 provide the revised WBN Unit 1 and WBN Unit 2 TS pages marked-up to show the proposed changes. Attachments 3 and 4 to Enclosure 2 provide the revised WBN Unit 1 and WBN Unit 2 TS pages retyped to show the proposed changes. The revised TS pages in Attachments 1 though 4 supersede those submitted in Reference 1.

There.are no new regulatory commitments associated with this submittal. Please address any questions regarding this response to Ed Schrull at 423-751-3850.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 6th day of March 2017.

J. W. Shea Vice President, Nuclear Licensing Enclosures cc (see Page 3)

U.S. Nuclear Regulatory Commission CNL-17-029 Page 3 March 6, 2017

Enclosures:

1.

Response to Request for Additional Information Regarding License Amendment Request for a One-Time Extension of Technical Specification Surveillance Requirements for AC Sources Watts Bar Nuclear Plant, Units 1 and 2 (CAC Nos. MF8481 and MF8482)

2.

Revised Technical Specification Surveillance Requirement 3.0.2 for Watts Bar Nuclear Plant, Units 1 and 2 cc (Enclosures):

NRC Regional Administrator - Region II NRC Senior Resident Inspector - Watts Bar Nuclear Plant NRR Project Manager - Watts Bar Nuclear Plant CNL-17-029 E1-1 of 5 Response to Request for Additional Information Regarding License Amendment Request for a One-Time Extension of Technical Specification Surveillance Requirements for AC Sources Watts Bar Nuclear Plant, Units 1 and 2 (CAC Nos. MF8481 and MF8482)

Nuclear Regulatory Commission (NRC) Introduction By letter dated October 17, 2016 (Agency wide Document Access Management System Accession Number ML16291A543), Tennessee Valley Authority (the licensee) requested an amendment to Facility Operating License Nos. NPF-90 and NPF-96 for the Watts Bar Nuclear Plant (WBN), Units 1 and 2. The proposed amendment would revise a limited number of Technical Specification (TS) Surveillance Requirements (SRs) relating to AC Sources because of delays in the startup of WBN Unit 2. Specifically, for WBN Unit 1, the proposed amendment would revise the TSs to allow a one-time extension of 18-month SRs 3.8.1.9, 3.8.1.10, 3.8.1.11, 3.8.1.13, 3.8.1.16, 3.8.1.18, and 3.8.1.19 to November 30, 2017.

For WBN Unit 2, the proposed amendment would revise the TSs to allow a one-time extension of 18-month SRs 3.8.1.9, 3.8.1.10, 3.8.1.11, 3.8.1.12, 3.8.1.13, 3.8.1.16, 3.8.1.17, 3.8.1.18, and 3.8.1.19 to November 30, 2017.

The U.S. Nuclear Regulatory Commission staff requests the licensee to provide additional information as stated below:

Regulatory Requirement The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Part 50.36(c)(2)(i)

Limiting conditions for operation states, in part, that limiting conditions for operation (LCOs) are the lowest functional capability performance levels of equipment required for safe operation of the facility. When a limiting condition for operation is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

10 CFR 50.36(c)(3), Technical Specifications, include SRs, which 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.

The extension in SRs requested in the licensee amendment request (LAR) is to meet the requirements of LCO 3.8.1.

NRC Request for Additional Information (RAI) No. 1 In the LAR, the licensee stated that WBN Unit 1 is scheduled for a refueling outage in spring 2017. While some of the information presented in the LAR indicates that the requested extensions only apply to DGs 2A-A and 2B-B, the LAR and proposed additions to TS Table SR 3.0.2-1 are unclear regarding whether SRs 3.8.1.9, 3.8.1.10, 3.8.1.11, 3.8.1.13, 3.8.1.16, 3.8.1.18, and 3.8.1.19 will be performed on DGs 1A-A and 1B-B during the refueling outage for Unit 1.

Please clarify that SRs 3.8.1.9, 3.8.1.10, 3.8.1.11, 3.8.1.13, 3.8.1.16, 3.8.1.18, and 3.8.1.19 will be performed on DGs 1A-A and 1B-B during the refueling outage for Unit 1. Also clarify that the extension in test intervals for these SRs for WBN Unit 1 is being requested because similar SRs on DGs 2A-A and 2B-B cannot be performed until refueling of Unit 2, and to CNL-17-029 E1-2 of 5 meet the requirements of LCO 3.8.1, the completion of SRs 3.8.1.9, 3.8.1.10, 3.8.1.11, 3.8.1.13, 3.8.1.16, 3.8.1.18, and 3.8.1.19 for all four DGs needs to be current within 18 months plus the allowable 25 percent extension from the last performance of these surveillances.

Tennessee Valley Authority (TVA) Response:

SRs 3.8.1.9, 3.8.1.10, 3.8.1.11, 3.8.1.13, 3.8.1.16, 3.8.1.18, and 3.8.1.19 will be performed on diesel generators (DGs) 1A-A and 1B-B during the upcoming WBN Unit 1 R14 refueling outage scheduled to commence in March 2017. As noted in the referenced letter, the extension in test intervals for these SRs for WBN Unit 1 is being requested because similar SRs on DGs 2A-A and 2B-B cannot be performed until the first refueling outage for WBN Unit 2 and because these SRs cannot be performed during power operations. Also, in order to meet the requirements of LCO 3.8.1, the completion of SRs 3.8.1.9, 3.8.1.10, 3.8.1.11, 3.8.1.13, 3.8.1.16, 3.8.1.18, and 3.8.1.19 for all four DGs needs to be current within 18 months plus the allowable 25 percent extension from the last performance of these surveillances.

NRC RAI 2 In the LAR on Page E1-11, the licensee stated that the review of last three previous surveillances for the integrated DG testing indicates no failures.

Please provide summaries of the previous three performances (indicating dates on which performed, SR No., DG No. etc.) for SRs 3.8.1.9, 3.8.1.10, 3.8.1.11, 3.8.1.12, 3.8.1.13, 3.8.1.16, 3.8.1.17, 3.8.1.18, and 3.8.1.19 for all DGs.

TVA Response The requested information is contained in Table 1, which provides the surveillance instructions (SIs) that perform each of the requested SRs, the associated DG, the date(s) of the previous three performances of the SIs for, and the results of the SI.

NRC RAI 3 In the LAR on Pages E1-11 and E1-12, the licensee stated that other recent testing(s) also effectively performed SR 3.8.1.16. Please explain how the other recent testing(s) effectively performed SR 3.8.1.16.

TVA Response SR 3.8.1.16 verifies that each DG synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power, transfers loads to offsite power source, and returns to ready-to-load operation.

The WBN DGs are paralleled to the grid and loaded on a monthly basis. The ability to synchronize with the offsite power source while loaded and transfer loads to offsite is functionally tested. The DG voltage regulator does not distinguish between emergency loads and grid loads.

CNL-17-029 E1-3 of 5 Every six months, the DG is started in emergency mode and returned to a ready-to-load operation.

As noted in Section 3.5.3.3 of the referenced letter, the time delay relays associated with a loss of offsite power (LOOP) were functionally tested with the power ascension testing (PAT) conducted on July 7, 2016. The PAT emergency started and loaded the DGs with emergency loads and also paralleled the DGs to offsite power and restored the DG to a ready-to-load condition.

The testing described above partially satisfies the surveillance requirements of SR 3.8.1.16.

Reference TVA Letter to NRC, CNL-16-164, Application to Modify Watts Bar Nuclear Plant, Units 1 and 2 Technical Specifications to Extend Surveillance Requirement Intervals for AC Sources (WBN-TS-16-024), dated October 17, 2016 (ML16291A543)

CNL-17-029 E1-4 of 5 Table 1 Surveillance Requirement History Surveillance Instruction Surveillance Requirement(s)

Diesel Generator Dates of Previous Three Performances Acceptance Criteria Met?

0-SI-82-3 3.8.1.9 3.8.1.10 3.8.1.111 3.8.1.12 3.8.1.13 3.8.1.16 3.8.1.17 3.8.1.191 1A-A 9/17/2015 Yes 3/22/2014 Yes 9/10/2012 Yes 0-SI-82-4 1B-B 10/6/2015 Yes 4/12/2014 Yes 10/4/2012 Yes 0-SI-82-5 2A-A 9/16/2015 Yes 4/3/2014 Yes 10/7/2012 Yes 0-SI-82-6 2B-B 9/7/2015 Yes 4/15/2014 Yes 10/9/2012 Yes 1-SI-262-1-A 3.8.1.112 3.8.1.192 1A-A 10/3/2015 Yes 3/27/2014 Yes 10/3/2012 Yes 1-SI-262-1-B 1B-B 9/25/2015 Yes 4/9/2014 Yes 9/21/2012 Yes 2-SI-262-1-A 2A-A 10/2/2015 Yes 4/4/2014 Yes 10/3/2012 Yes 2-SI-262-1-B 2B-B 9/25/2015 Yes 4/7/2014 Yes 9/19/2012 Yes 1 These SIs perform parts a and c of SRs 3.8.1.11 and 3.8.1.19 and partially perform part b of these SRs.

2 These SIs perform the remaining portions of part b of SRs 3.8.1.11 and 3.8.1.19.

CNL-17-029 E1-5 of 5 Table 1 Surveillance Requirement History Surveillance Instruction Surveillance Requirement(s)

Diesel Generator Dates of Previous Three Performances Acceptance Criteria Met?

1-SI-57-1-A 3.8.1.18 1A-A 10/3/2015 Yes 4/3/2014 Yes 9/26/2012 Yes 1-SI-57-1-B 1B-B 9/24/2015 Yes 4/8/2014 Yes 9/17/2012 Yes 2-SI-57-1-A 2A-A 1/21/20163 Yes 3/30/2014 Yes 9/29/2012 Yes 2-SI-57-1-B 2B-B 11/25/2015 Yes 4/8/2014 Yes 9/16/2012 Yes 3 Based on the last performance of this SI, an extension of this SI for DG 2A-A is not needed because the SI was performed within 22.5 months (18 months + 25%) from the requested SR extension date of November 30, 2017. However, this SI is scheduled to be performed during the WBN Unit 1 refueling outage commencing in October 2017.

Revised Technical Specification Surveillance Requirement 3.0.2 for Watts Bar Nuclear Plant, Units 1 and 2 CNL-17-029 Proposed TS Changes (Mark-Ups) for WBN Unit 1

SR Applicability 3.0 (continued)

Watts Bar-Unit 1 3.0-4 Amendment XX 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR. Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3.

Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. In addition, for each of the SRs listed in Table SR 3.0.2-1 the specified Frequency is met if the Surveillance is performed on or before the date listed on Table SR 3.0.2-1. This extension of the test intervals for these SRs is permitted on a one-time basis to be completed no later than November 30, 2017.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per..." basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

Revised Technical Specification Surveillance Requirement 3.0.2 for Watts Bar Nuclear Plant, Units 1 and 2 CNL-17-029 Proposed TS Changes (Mark-Ups) for WBN Unit 2

SR Applicability 3.0 Watts Bar - Unit 2 3.0-4 (continued)

Amendment xx 3.0 SURVEILLANCE REQUIREMENT (SR) APPLICABILITY SR 3.0.1 SRs shall be met during the MODES or other specified conditions in the Applicability for individual LCOs, unless otherwise stated in the SR.

Failure to meet a Surveillance, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the LCO. Failure to perform a Surveillance within the specified Frequency shall be failure to meet the LCO except as provided in SR 3.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

SR 3.0.2 The specified Frequency for each SR is met if the Surveillance is performed within 1.25 times the interval specified in the Frequency, as measured from the previous performance or as measured from the time a specified condition of the Frequency is met. In addition, for each of the SRs listed in Table SR 3.0.2-1 the specified Frequency is met if the Surveillance is performed on or before the date listed on Table SR 3.0.2-1. This extension of the test intervals for these SRs is permitted on a one-time basis and expires to be completed no later than November 30, 2017October 31, 2017.

For Frequencies specified as "once," the above interval extension does not apply.

If a Completion Time requires periodic performance on a "once per..."

basis, the above Frequency extension applies to each performance after the initial performance.

Exceptions to this Specification are stated in the individual Specifications.

SR 3.0.3 If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or up to the limit of the specified Frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and the risk impact shall be managed.

If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

Revised Technical Specification Surveillance Requirement 3.0.2 for Watts Bar Nuclear Plant, Units 1 and 2 CNL-17-029 Proposed TS Changes (Final Typed) for WBN Unit 1