ML043130006

Emergency Amendment, Extend Implementation Period for License Amendment No. 294

ML043130006
Person / Time
Site:	Sequoyah
Issue date:	11/09/2004
From:	Robert Pascarelli NRC/NRR/DLPM/LPD2
To:	Singer K Tennessee Valley Authority
Pascarelli,R J,NRC/NRR/DIPM,415-1245
Shared Package
ML043130024	List: ML043130006
References
TAC MC5041
Download: ML043130006 (12)

Text

November 9, 2004 Mr. Karl W. Singer Chief Nuclear Officer and Executive Vice President Tennessee Valley Authority 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT UNIT 1 ISSUANCE OF EMERGENCY AMENDMENT TO EXTEND IMPLEMENTATION PERIOD FOR LICENSE AMENDMENT NO. 294 (TAC NO. MC5041)

Dear Mr. Singer:

The Commission has issued the enclosed Amendment No. 297 to Facility Operating License No. DPR-77 for the Sequoyah Nuclear Plant (SQN), Unit 1. This amendment is in response to your application dated November 4, 2004. You submitted the proposed changes for SQN Unit 1 and requested that the proposed changes be considered on an emergency basis.

The proposed amendment extends the implementation period for Technical Specification Change 00-14 to May 15, 2005, from the original implementation period of the completion of the 2004 Cycle 13 refueling outage (License Amendment 294 for SQN Unit 1). There are no actual changes to the Technical Specifications. Tennessee Valley Authority requested the change in the implementation date on an emergency basis based on unforseen difficulties associated with the calibration of the low-temperature overpressure protection system setpoints.

A copy of the Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Robert J. Pascarelli, Project Manager, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-327

Enclosures:

1. Amendment No. 297 to License No. DPR-77

2. Safety Evaluation cc w/enclosures: See next page

ML043130006 NRR-058 OFFICE PDII-2/PM PDII-2/LA OGC PDII-2/SC NAME RPascarelli BClayton HMcGurren MMarshall DATE 11/8/04 11/8/04 11/9/04 11/9/04 DISTRIBUTION FOR: SEQUOYAH NUCLEAR PLANT, UNIT 1 ISSUANCE OF EMERGENCY AMENDMENT TO EXTEND IMPLEMENTATION PERIOD FOR LICENSE AMENDMENT NO. 297 (TAC NO. MC5041)

Dated: November 9, 2004 DISTRIBUTION:

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RidsOgcRp TBoyce JUhle WBateman KKavanaugh MMitchell SPeters

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-327 SEQUOYAH NUCLEAR PLANT, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 297 License No. DPR-77

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by Tennessee Valley Authority (the licensee) dated November 4, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. DPR-77 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 297, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of its date of issuance and shall be implemented by May 15, 2005.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Michael L. Marshall, Jr., Chief, Section 2 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: November 9, 2004

ATTACHMENT TO LICENSE AMENDMENT NO. 297 FACILITY OPERATING LICENSE NO. DPR-77 DOCKET NO. 50-327 Replace the following pages of the Appendix A and B Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain a marginal line indicating the area of change.

REMOVE INSERT I I II II VI VI XIII XIII 1-5 1-5 1-6 1-6 1-7 1-7 3/4 4-23 3/4 4-23 3/4 4-24 3/4 4-24 3/4 4-25 3/4 4-25 3/4 4-26 3/4 4-26 3/4 4-29 3/4 4-29 3/4 4-30 3/4 4-30 3/4 4-31 -----------

B 3/4 4-6 B 3/4 4-6 B 3/4 4-7 B 3/4 4-7 B 3/4 4-8 B 3/4 4-8 B 3/4 4-9 B 3/4 4-9 B 3/4 4-10 B 3/4 4-10 B 3/4 4-11 B 3/4 4-11 B 3/4 4-12 B 3/4 4-12 B 3/4 4-13 B 3/4 4-13 B 3/4 4-14 B 3/4 4-14

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B 3/4 4-15

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B 3/4 4-16

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B 3/4 4-17

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B 3/4 4-18

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B 3/4 4-19

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B 3/4 4-20

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B 3/4 4-21

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B 3/4 4-22

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B 3/4 4-23 6-13a 6-13a

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 297 TO FACILITY OPERATING LICENSE NO. DPR-77 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNIT 1 DOCKET NO. 50-327

1.0 INTRODUCTION

By letter dated November 4, 2004, Tennessee Valley Authority (TVA, the licensee) requested an extension to the implementation period for Technical Specification (TS) Change 00-14 to May 15, 2005, from the original implementation period of the completion of the 2004 Cycle 13 refueling outage (License Amendment No. 294 for Sequoyah Nuclear Plant (SQN) Unit 1).

Tennessee Valley Authority (TVA) requested the change in implementation date on an emergency basis based on unforseen difficulties associated with the calibration of the low-temperature overpressure protection (LTOP) system setpoints. There are no proposed changes to the TSs.

2.0 BACKGROUND

By letter dated September 15, 2004, U. S. Nuclear Regulatory Commission (NRC) issued License Amendment Nos. 294 and 284 for SQN TS Change 00-14 (Units 1 and 2, respectively).

The amendments revised the TS reactor coolant system (RCS) pressure-temperature limits and the LTOP setpoints for each unit. These amendments were requested by TVA letter dated September 6, 2002. The implementation period for each amendment states:

This license amendment is effective as of its date of issuance, to be implemented by the completion of the 2004 Sequoyah Unit 1 Cycle 13 Refueling Outage.

TVA requested that implementation requirements of SQN Unit 1 Amendment 294 be amended as follows:

This license amendment is effective as of its date of issuance, to be implemented by May 15, 2005.

TVA has encountered unforeseen difficulties associated with calibration of the electronic modules that control the new Unit 1 LTOP system setpoints as provided in TS Change 00-14.

In addition, TVA discovered that a spare module would not calibrate to the new LTOP setpoints and must be shipped back to the vendor for refurbishment. Refurbishment of the spare module will not be available from the vendor in time to support TVAs schedule for startup from the ENCLOSURE

Unit 1 Cycle 13 refueling outage. In addition, implementation of the LTOP setpoints is not required during an outage.

3.0 EVALUATION The proposed change extends the implementation period from that stated in Amendment No. 294. This change has no technical or safety aspects. In issuing an amendment to an operating license, the NRC staff states when the amendment is effective and when the amendment must be implemented. These dates are given in Enclosure 1 of the amendment and are part of the operating license. As such, a change to the implementation date is a change to the operating license for the plant. Although there are no regulatory requirements on the implementation date specified in an amendment, the licensee is required by the operating license to fully implement the amendment by the date specified (i.e., by a date no later than that specified) or be in violation of its operating license.

The staff has reviewed the licensees regulatory and technical analyses in support of its proposed license amendment, which are described in Sections 4.0 and 5.0 of the licensees submittal of November 4, 2004. TVA has concluded that the change is not a technical issue as the implementation of this amendment during a refueling outage is not required.

The NRC staff concludes that, based on the considerations discussed above, the proposed change is acceptable.

4.0 EMERGENCY CIRCUMSTANCES In its letter of November 4, 2004, the licensee requested that this amendment be treated as an emergency amendment. In accordance with 10 CFR 50.91(a)(5), the licensee provided information regarding why this emergency situation occurred and how it could not be avoided.

By letter dated September 6, 2002, TVA requested a license amendment (TS Change 00-14) to implement new updated RCS pressure-temperature limits and LTOP setpoints for each unit.

Implementation involved calibration of the LTOP instrumentation. TVAs preferred schedule for performing the calibration of the LTOP setpoint instrumentation was to stage this work during plant shutdown for each unit. The Unit 1 Cycle 13 refueling outage provided the first opportunity for performing this calibration following NRC approval of the new limits.

Accordingly, during the Unit 1 Cycle 13 refueling outage, the LTOP system calibration activities were started. TVA encountered unforeseen difficulties associated with calibration of the electronic LTOP modules. These difficulties substantially extended the schedule in the outage to calibrate one module. TVA also discovered that a spare module would not calibrate to the new LTOP setpoints and had to be shipped back to the vendor for refurbishment. A refurbished spare module will not be available from the vendor in time to support TVAs schedule for startup from the Unit 1 Cycle 13 refueling outage and these modules are not readily available from other sources. Based on the hardships encountered with the calibration of one of two required modules, the time estimate to complete the calibration from the current condition would extend the time to resumption of full power. Further, the second required module may not be capable

of calibration to the new LTOP setpoints. Accordingly, TVA was not able to avoid the hardships associated with implementation of SQN Unit 1 TS Change 00-14.

The NRC staff concludes that an emergency condition exists, in that failure to act in a timely way would prevent resumption of operation of SQN Unit 1. In addition, the staff has assessed the licensee's reasons for failing to file an application sufficiently in advance to preclude an emergency, and concludes that the licensee promptly notified the staff of the deficiency, and promptly proposed this amendment to remedy the situation. The NRC staff concludes that the licensee has not abused the emergency provisions by failing to make timely application for the amendment. Thus, the conditions needed to satisfy 10 CFR 50.91(a)(5) exist, and the amendment is being processed on an emergency basis.

5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION The Commission's regulations in 10 CFR 50.92(c) state that the Commission may make a final determination that a license amendment involves no significant hazards consideration if operation of the facility in accordance with the amendment would not:

(1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or, (2) Create the possibility of a new or different kind of accident from any previously evaluated; or, (3) Involve a significant reduction in a margin of safety.

The following analysis was provided by the licensee in its letter of November 4, 2004.

A. The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed emergency license amendment extends the implementation period specified in License Amendment 294. The extension will allow TVA to complete the necessary refurbishment of control modules for the LTOP system prior to implementation. The proposed amendment is purely administrative and has no technical or safety aspects. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

B. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The proposed emergency license amendment extends the implementation period specified in SQN Unit 1 License Amendment 294. The extension will allow TVA to complete the necessary refurbishment of control modules for the Unit 1 LTOP system prior to implementation. The proposed amendment is purely administrative and has no technical or safety aspects. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

C. The proposed amendment does not involve a significant reduction in a margin of safety.

The proposed emergency license amendment extends the implementation period specified in SQN Unit 1 License Amendment 294. The extension will allow TVA to complete the necessary refurbishment of control modules for the Unit 1 LTOP system prior to implementation. The proposed amendment is purely administrative and has no technical or safety aspects. Therefore, the proposed change does not involve a significant reduction in a margin of safety.

6.0 STATE CONSULTATION

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

7.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has made a final no significant hazards finding with respect to this amendment.

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

8.0 CONCLUSION

The Commission has concluded, based on the nature of the proposed change, that: (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 Commissions regulations, and (3) the issuance of these amendments will not be inimical to the common defense and security or to the health and safety of the public.

Additionally, the Commission has concluded, based on the considerations discussed above, that (1) the amendment does not: (a) involve a significant increase in the probability or consequences of an accident previously evaluated; or, (b) create the possibility of a new or different kind of accident from any previously evaluated; or, (c) involve a significant reduction in a margin of safety and therefore, the amendment does not involve a significant hazards consideration; (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (3) such activities will be conducted in compliance with the Commission's regulations, and (4) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: R. Pascarelli Date: November 9, 2004

Mr. Karl W. Singer SEQUOYAH NUCLEAR PLANT Tennessee Valley Authority cc:

Mr. Ashok S. Bhatnagar, Senior Vice President Mr. Paul L. Pace, Manager Nuclear Operations Licensing and Industry Affairs Tennessee Valley Authority ATTN: Mr. James D. Smith 6A Lookout Place Sequoyah Nuclear Plant 1101 Market Street Tennessee Valley Authority Chattanooga, TN 37402-2801 P.O. Box 2000 Soddy Daisy, TN 37384-2000 Mr. Michael J. Lorek, General Manager Nuclear Engineering Mr. David A. Kulisek, Plant Manager Tennessee Valley Authority Sequoyah Nuclear Plant 6A Lookout Place Tennessee Valley Authority 1101 Market Street P.O. Box 2000 Chattanooga, TN 37402-2801 Soddy Daisy, TN 37384-2000 Mr. Randy Douet Mr. M. Scott Freeman Site Vice President Sequoyah Nuclear Plant Sequoyah Nuclear Plant U.S. Nuclear Regulatory Commission Tennessee Valley Authority 2600 Igou Ferry Road P.O. Box 2000 Soddy Daisy, TN 37379 Soddy Daisy, TN 37384-2000 Mr. Lawrence E. Nanney, Director General Counsel Division of Radiological Health Tennessee Valley Authority Dept. of Environment & Conservation ET 11A Third Floor, L and C Annex 400 West Summit Hill Drive 401 Church Street Knoxville, TN 37902 Nashville, TN 37243-1532 Mr. John C. Fornicola, Manager County Mayor Nuclear Assurance and Licensing Hamilton County Courthouse Tennessee Valley Authority Chattanooga, TN 37402-2801 6A Lookout Place 1101 Market Street Chattanooga, TN 37402-2801 Mr. Frederick C. Mashburn Senior Program Manager Nuclear Licensing Tennessee Valley Authority 4X Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801