View source for CNL-14-150, Response to Requests for Additional Information, Developmental Revision I Technical Specification (Section 3.3) and Technical Specification Bases (Limiting Condition for Operation B 3.0.6)

{{Adams
| number = ML14295A107
| issue date = 10/21/2014
| title = Response to Requests for Additional Information, Developmental Revision I Technical Specification (Section 3.3) and Technical Specification Bases (Limiting Condition for Operation B 3.0.6)
| author name = Shea J
| author affiliation = Tennessee Valley Authority
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000391
| license number = CPPR-092
| contact person = 
| case reference number = CNL-14-150
| document type = Letter type:CNL
| page count = 14
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Tennessee Valley Authority. 1101 Market $treet, Chattanooga, Tennessee 37402 cNL- 14-1 50 October 21 .2014 10 CFR 50 36(a)
U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Watts Bar Nuclear Plant, Unit 2 Construction Permit No. CPPR-92 NRC Docket No. 50-391 Subject           Watts Bar Nuclear Plant Unit 2 - Response to RequesG for Additional I nfomtation, Developmental Revision I Tech n ical Specification (Section 3.3) and Technical Specification Bases (Limiting Condition for Operation B 3.0.6f

==Reference:==
: 1.        Electronic Mail from Michael J. Miernicki (NRC) to Gordon Arent (TVA), "Watts Bar 2- RAI - DevelopmentalTech Specs Rev 1,"
dated July 22,2014
: 2. Electronic Mailfrom Michael J. Miernicki (NRC) to Gordon Arent (TVA), "Watts Bar 2 - RAI - Developmental Tech Specs Rev l,'
dated July 15, 2014
: 3. TVA Letter to NRC, "Watts Bar Nuclear Plant Unit 2 - Submittal of Developmental Revision I of the Unit 2 Technical Specification &
Technical Specification Bases and Developmental Revision D of the Unit 2 Technical Requirements Manual and Technical Requirements Manual Bases," dated June 16, 2014 [ADAMS Accession No.
M11416945251 The purpose of this letter is to respond to requests for additional information (RAl) from the Nuclear Regulatory Commission (NRC) provided in References 1 and 2.

U.S. Nuclear Regulatory Commission cNL-14-150 Page 2 October 21,2014 On June 16,2014, the Tennessee Valley Authority submitted the Watts Bar Nuclear Plant Unit 2 Developmental Revision I of the Unit 2 Technical Specifications and Technlcal Specification Bases and Developmental Revision D of the Unit 2 Technical Requirements Manual and Technical Requirements Manual Bases to the NRC (Reference 3). to this lefter provides TVA's response to the RAI in Reference 1. to this letter provides TVA's responses to the four RAls in Reference 2.
There are no new regulatory commitments associated with this submittal. lf you have any questions, please contact Gordon Arent at (423) 365-2004.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 21st day of October, 2014.
                                      --------*
                  ./ ,
Respectfully,
                                  / '
o2'*
                                         ,/)'
,*"^/7'*/z Vice President, Nuclear Licensing Enclosures. 1. Response to NRC Request for Additional lnformation   -
Developmental Revision I for Technical Specification Bases, B 3.0.6 -
Limiting Condition for Operation 3.0.6
: 2. Response to NRC Request for Additional lnformation     -
Developmental Revision I for Technical Specification Section 3.3 cc (Enclosure):
NRC RegionalAdministrator - Region ll NRC Senior Resident lnspector - Watts Bar Nuclear Plant, Unit 2 NRC Project Manager - Watts Bar Nuclear Plant. Unit 2

ENCLOSURE 1 TEHNESSEE VALLEY AUTHORIW WATTS BAR NUCLEAR PLANT, UNIT 2 Response to HRC Request for Additional lnformation   -
Developmental Revision I Technical Specification Bases, B 3.0.G -
Limiting Condition for Operation 3.0.6 E1-1

ENCLOSURE    t TEN}.IESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UNIT 2 Response to NRC Request for Additional lnformation - Developmental Revision             I Technical Specification Bases, B 3.0.6 - Limiting Gondition for Operation 3.0.6 NRC RAI Number:      I NRC RAI:
Since the addltional parryraph on pages B 3.0-9 and B 3.0-10 dres not summarize the reason for LCO 3.0.6, but adds a new ondition to LCO 3.O6 such that LCO 3.0.6 may now be applied fo a norlS support system, please explain fhe basis for inclusion of this pangraph in the 7.S bases.
TVA Response:
Based on discussions with the Nuclear Regulatory Commission staff in regard to the subject request for additional information, the Tennessee Valley Authority agreed to revert to the previous Technical Specification (IS) Bases text for Limiting Condition for Operation (LCO) 3.0.6 wtrich had been unchanged prior to the issuance of Developmenta! Revision l. This change has been incorporated in interim Developmental Revision J.
Tte following page shows correc'ted TS LCO 3.0.6. Note 'revision bar' indicating the revised tert.
E1-2

ENCLOSURE       1 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UNIT 2 Response to NRC Request for Additional lnformation - Developmental Revision                     I Technical Specification Bases, B 3.0.6 - Limiting Condition for Operation 3.0.6 NRC RAI Number: 1(continued)
LCO Applicability B 3.0 BASES (continued)
LCO 305            LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS The sole purpose of this Specification is to provide an exception to LCO 3,0.2 (e.9.. to not comply with the applicable Required Action(s)) to allow the performance of SRs to demonstrate:
: a. The OPERABILITY of the equipment being returned to service: or
: b. The OPERABILITY of other equipment.
The administrative controls ensure the trme the equipment is returned to service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the allowed SRs. This Specification does not provide time to perform any other preventive or corrective maintenance.
An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Requrred Actions and must be reopened to perform the SRs.
An example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to prevent the trip function from occuning during the performance of an SR on another channel in the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit the logic to function and indicate the appropriate response during the performance of an SR on another channel in the same trip system.
LCO  306              LCO 3.0.6 esta0lishes an exception to LCO 3.0.2 for support systems that have an LCO specified in the Technical Specifications (IS). Ihis exception is providd because LCO 3.0.2 would require that the Conditions and Required Actions of the associated inoperable supported system LCO be entered solely due to the inoperability of the support system. fhis exception is justtfied because the actions that are required to ensure the unit is maintained in a safe condition are specified in the support system LCO's Required Acfions. Ihese Required Actions may include entering the supporfedsystem's Conditions and Required Actions or may specify other Required Actions.
(contin ued   )
Watts Bar - Unit 2                              B30-3 (developmental)                                                                               Revision J E1-3

ENCLOSURE             1 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UNIT 2 Response to NRG Request for Additional lnformation - Developmental Revision                                   I Technical Specification Bases, B 3.0.6 - Limiting Condition for Operation 3.0.6 NRC RAI Number: 1(continued)
LCO Applicability 830 BASES (continued)
LCO 3 0.6            When a supportsfstem is inoperable and there is an LCO specified for it in (continued )      fhe IS, the supported system(s) are required to be dectarcd inoperable if determind to be inoperable as a result of the support system lnoperabllity.
Howeyer, it is not necessary to enter into the suppofted systems' Conditions and Required Actions unless directed to do so by the support system's Requlred Actions. The potential contusion and inconsistency of requiremenfs related to the entry into multiple suppoft and supportd systems'LCOs' Conditions and Required Actions are eliminated by providing all the actions that are necessary to ensure the unit is maintained in a safe condition in the support system's Required Actions.
However, there are instances where a support system's Required Action may either direct a suppofted system to be declared inoperable or direct entry into Conditions and Required Actions for the supported system. This may occur immediately or after some specifid delay to perform some other Required Action. Rqardless of whether it is immediate or after some delay, when a support system's Rquired Action directs a suppofted system to be declared inaperable or directs entry into Conditions and Required Actions for a suppofted system, the applicable Conditions and Required Actr'ons shall be entered in accordance with LCA 3.0.2.
Spec ffi c ation 5.7. 2. 1 8, " S af ety F u ncti o n Determ i n ati o n P rog ra m (S F D P ),*
ensures loss of safety function is detected and appropriate actions are taken. Upon entry into LCA 3.0.6, an evaluation shall be made to determine if loss of satety function exists. Additionally, other limitations, remedial actions, orcompensatory actions may be identified as a result of the support systern inoperability and corresponding exception to entertng supportd systern Conditions and Required Actions. The SFDP implements the requirements of LCO 3.A.6.
Cross train checks to identify a /oss of safety function for those support systems that support multiple and redundant safety sysfems are required.
Ihe cross traln check verifies that the suppofted systems of the redundant OPERABLE support system are OPERABLE, thereby ensuring safety function is retained. lf this evaluation determines that a loss of safety function exists, the appropriate Conditions and Required Actions of the LCO in which tfte /oss of safety function exisfs are required to be entered.
(continued)
Watts Bar - Unit 2                                    B30-4 (developmental)                                                                                             Revlsion J E1-4

ENCLOSURE2 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UNIT 2 Response to NRC Request for Additional lnformation   -
Developmental Revision I Technical Specification Section 3.3 E2-1

ENCLOSURE2 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UHIT 2 Response to NRC Request for Additional lnformation -
Developmental Revision I Technical $pecification Section 3.3 NRC RAI Number:        1 NRC RAI:
On Table 3.3.1-1 (TS page 3.3-22), Note 2, Overpower AT equation, the sign befare KO was changed from "-" to "+", The staff needs clarificatbn from the applicanf as to the reasons for the change.
Watts Bar 2 TS, Rev l:
[ffi                  [*--*, #*
s^r,                              tr]0r,(r-r' )-nto,l]
    ^t Watts Bar 2TS, Rev A:
T   -r1 -fr(
    ^ltEU +rss )=*{
TVA Response:
The Tennessee Valley Authority confirmed that the conect sign should be '-' for the Watts Bar Nuclear Plant Unit 2 Technical Specifications, Limiting Condition for Operation (LCO) 3.3.1, Table 3.3.1-1, Note 2: Overpower AT. The equation has been conected in interim Developmental Revision J.
The following page shows conected LCO 3.3.1, Table 3.3.1-1. Note 'revision bar' indicating the revised text.
E2-2

ENCLOSURE 2 TENNESSEE VALLEY AUTHORIW WATTS BAR NUCLEAR PLANT, UNIT 2 Response to NRC Request for Additional lnformation -
Developmental Revision I Technical Specification Section 3.3 NRC RAI Number:           I (continued)
RTS lnstrumentation 3.3.1 Table 3.3.1-1 (page 8 of 9)
Reactor Trip System lnstrumentation Note 2: Ovemower.lT The Overpower AT Func{ion Allowable Value shall not exeed the following Trip Setpoint by more than 1.Aa/o of AT span.
{11'-:}                            [rl -Ke(r-r")-rr(ar)]
          ^r (1*t5s =nro [*--Kq         #*
oF.
Where:   AT is measured RCS nT, ATo is the indicated AT at RTP,       'F.
s is the Laplace transform operator, sec-1.
T is the mea$ured RCS average ternperature, "F.
T" is the indicated     T"us at RTP, < 588.2"F.
lq < 1.10        Ks  )     O.AU'F for increasing    T"w       lq > 0.00162/'F when T > T" Ol'F for decreasing   T"*               0/"F when T < T' te>Ssc rq2 3sec                                             rs(   3sec f2(Al) = 0 for all Al.
Watts Bar - Unit 2                                  3.3-3 (developmental)                                                                          Revision J E2-3

ENCLO$URE 2 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UNIT 2 Response to NRC Request for Additional lnformation -
Developmental Revision I Technical Specification Section 3.3 NRC RAI Number: 2 NRC RAI:
On Table 3.3.?1 (page 3.3-39), Function 8 (ESFAS lntedocks), b (Pressuizer Pressure P-11), (2) (Enable Manual Blrck ot Sl), the allowable value was changed from "*,1956.8 psig" to "31956.8 psig". The staff needs clarification from the applicant as to the reasons for the change.
TVA Response:
The Tennessee Valley Authority confirmed that the conect symbol is 'z'for the Watts Bar Nuclear Plant Unit 2 Technical Specifications, Limiting Condition for Operation (LCO) 3.3.2, Table 3.3.2-1, Function 8 b (2), Surveillance Requirement 3.3.2.1. The symbol has been conected in interim Developmental Revision J.
The following page shows corrected LCO 3.3.2, Table 3.3.2-1. Note'revision bar' indicating the revised text.
E2-4

ENCLOSURE2 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UNIT 2 Response to NRC Request for Additional lnformation Developmental Revision I Technical Specification Section 3.3
                                                                                    -
NRC RAI Number: 2 (continued)
ESFAS lnstrumentation 3_3.2 Table 3.3.2-1 (page 7 of 8)
Engineered Safety Feature Actuation System I nstrumentation APPLICABLE MODES OR OTHER                                                                Notrl[tAL SPECIFIED   REQUIRED                  SURVEILLANCE   ALLOWABLE TRIP FUNCTION            CONOITIONS CHANNELS CONDITIONS        REQUIREMENTS VALUE              SETPOINT 8 ESFAS lnterlocks
: a. Reac{orTrip,   P-4     1,2.3      l pertrain,      F        SR3.3.2.11          NA            NA 2ltains
: b. Pressurizer Pressure, P-1 1 (t) Unblock            1,2.3           3           L        SR 3 3.2.1     < 1975.2 psig   1970 psig (Auto Reset                                           SR 3.3.2.4 of Sl Bloclr)                                         SR 3 3-2-9
: 12)   Enable           1,2,3           3           L        SR 3.3.2.1     :1956.8  psig   1962 psig Manual                                                SR 3.3.2.4 Block of Sl                                           SR 3.3.2,9 Watts Bar - Unit 2                               3.3-5 (developmental)                                                                           Revision J E2-5

ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UNIT 2 Response to NRC Request for Additional lnformation -
Developmental Revision I Technical Specification Section 3.3 NRC RAI Number: 3 NRC RAI:
IS 3.3.8, "Auxiliary Building   Gas Treatmenf System (ABGTS) Actuation lnstrumentation,"
has severalchanges related to the elimination (from Table 3.3.8-1) af the Fuel Poal Area Monitors during movement of inadiated fuel assemblies in the spent fuel pool area.
Condition C in IS revision A has been removed (Condition D rn IS revision A is now Condition C rn IS revision H) and SR 3. 3. 8. ,, SR 3. 3. I .2 and SR 3. 3. 8. 4 in TS revision A have been removed (SR 3.3.8.3 rn IS revrsion A is now SR 3.3.8,1 in TS revision H). EICB sfaff ls not aware of the reasons for this change. Please provide an explanation of the reason for this change.
TVA Response:
On September 23, 2011, the Tennessee Valley Authority (TVA) provided their analysis of the Watts Bar Nuclear (WBN) Unit 2 selective utilization of the Alternate Source Term (AST) for the WBN Unit 2 Fuel Handling Accident (FHA) to the Nuclear Regulatory Commission (NRC) (ADAMS Accession No. M1112694064).
The NRC issued Supplemental Safety Evaluation Report (SSER) 25 to TVA's WBN Unit 2 on November 30, 2011 (ADAMS Accession No. ML12011A024). Section 15.4.5.2 of SSER 25 confirmed the acceptability of selective utilization of the AST for the WBN Unit 2 FHA.
The Main Control Room dose analysis for the FHA which is based on the AST submitted in WBN Unit 2 Final Safety Analysis (FSAR) Amendment 107, does not credit actuation of the Auxiliary Building Emergency Gas Treatment System (ABGTS) in mitigating the potential consequences of FHA. The spent fuel pool (SFP) radiation monitors were the credited instruments that initiated ABGTS in the previous Regulatory Guide 1.25 FHA dose analysis as described in the FSAR prior to Amendment 107 . The FHA is the only accident addressed in Chapter 15 of the WBN Unit 2 FSAR that credited the spent fuel pool radiation monitors for initiating the ABGTS. Amendment 107 of the FSAR, and SSER 25 were the basis for removing the requirements from TS 3.3.8.
The TVA letter to the NRC dated December 12, 2013, "Watts Bar Nuclear Plant Unit 2            -
Submittal of Developmental Revision H of the Unit 2 Technical Specification and Technical Specification Bases," (ADAMS Accession No. ML13357A048) documented the deletion of the SFP radiation monitors previously credited in the FHA, based on SSER 25.
Therefore, SSER 25 and FSAR Amendrnent 107 support the removal of the SFP radiation monitors as the initiating instrumentation for ABGTS, and subsequent Developmental Revision H, TS 3.3.8 revision.
E2-6

ENGLOSURE 2 TEN NESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UHIT 2 Response to NRC Request for Additional lnforrnation -
Developmental Revision I Technical Specification $ection 3.3 NRC RAI Number: 4 NRC RAI:
On Table 3.3.1-1 (page 3.3-18), Function 14 (Turbine Trip), a (Low Fluid Ot7 Ptessure), SR 3.3.1.10(b)(c) was added in revision G (as a con*tion of a typo). However, rf was removed in revision l, even though the page rcmains marted as revisbn G. Ihis SR is forthe
. pefiormance of a channel calibration. The staff rceds clarifrcation fram the applicant as to the reasons for the change.
TVA Response:
The Tennessee Valley Authority has confirmed that Developmental Revision G of the Watts Bar Nuclear Plant Unit 2 Technical Specifications, Limitirg Condition for Operation (LCO) 3.3,1, Table 3.3.1-1, Function 14, a. Low Fluid Oil Pressure, Surveillance Requirement (SR) 3.3.1.10wasconectasstated. ThefootnotesreferenceassociatedwithSR3.3.l.l0have been conected in interim Developmental Revision J.
Thefollowing page shows conected LCO 3.3.1, Table 3.3.1-1. Note'revision ba/ indicating the revised text.
E2-7

ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY WATTS BAR NUCLEAR PLANT, UNIT 2 Response to NRC Request for Additional lnformation -
Developmental Revision I Technical Specification $ection 3.3 NRC RAI Number: 4 (continuedl RTS lnstrurnentation 3 3.1 Table 3.3.1-1 (page 4 of 9)
Reactor Trip System lnstrumentation APPLICABLE MODES OR OTHER                                                                                             NOMINAL SPECIFIED         REQUIRED                          SURVEILLANCE              ALLOWABLE TRIP FUNCTION                 CONDITIONS CHANNELS                 CONDITIONS        REQUIREMENTS                 VALUE SETPOINT
: 13. SG Water Level       -                   1,2                                             sR 3 3.1.1
                                                                                                                        =
16.40/o al     174/a  of narrow Low-Low                                                                                  sR3.3. 17tr;Acl         narrow     range      range span sR 3.3.1 .10 to"''            span sR 3 3 1 15 Coincident with a)     Vessel tT                         1,2                                            sR 3.3.1 "7 rtixc!        Vessel \T            Vessel \T Equivalent to                                                                    sR 3-3.1 "10 tt'{''     variable input       variable input potrer                                                                                                   > 52.60/o RTP          50o/o RTP
{   50% RTP With a time                                                                                                 s 1.01 T,                Ts delay (T,) if one                                                                                           (Refer to            (Refer to steam generator                                                                                               Note 3,             Note 3, is affected                                                                                             Page 3 3-23)         Page 3 3-23) or A time delay (T*)                                                                                          -r 1-01   T,,,            T*
if two or more                                                                                             (Refer to            (Refer to steam                                                                                                        Note 3,             Note 3, generators are                                                                                           Page 3.3-23)        Page 3.3-23) affected b)      Vessel .\T                       1.2                                            sR 3 3.1 .7 t'Ittr'c)
Vessel .,\T          Vessel rT tbxci Equivalent to                                                                   sR 3 3. 1 .10           variable input       variable input power                                                                                                   t  52.60/o RTP          50% RTP
                , 50o/o RTP with no time delay (T' and T", = 0)
: 14. Turbine Tnp
: a.      Low Fluid Oil                    1
{tl sR 3.3-1 .16 {o}tc'      z 38.3 psig            45 psig Pressure                                                                        sR 3.3 1"14
: b.      Turbine Stop                     1 (t) sR 3,3 1.10               ,  la/o Open          1% open Valve Closure                                                                   sR 3.3.1  14 (continued) sfrice channelslEllb(bdrcdinoperaue Ttmthodologsusedtodeterminelhasloundandasc,ltolrancssforthNTSParespecifcdrnFSARSelrmTl2 10 Abore the P-9  (Pffi. Ragc Nsuron Fluxl rntrlock 3.3-8 Watts Bar - Unit 2 (developmental)                                                                                                                  Revision J E2-B}}