Text

Revisions to the Technical Requirements Manual (TRM) (Revisions 28, 29, 30, 31, 32, 33, 34, and 35) and Technical Specification (TS) Bases (Unit 1 Revisions 25, 26, 27, and 28; Unit 2 Revisions 24, 25, 26, and 27)
	ML053250350
Person / Time
Site:	Sequoyah
Issue date:	11/04/2005
From:	Pace P; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	Download: ML053250350 (65)
	v • d • e

Tennessee Valley Authority, Post Office Box 2000, Soddy-Daisy, Tennessee 37384-2000 November 4, 2005 10 CFR 50.71 U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.C.

20555 Gentlemen:

In the Matter of

)

Docket Nos. 50-327 Tennessee Valley Authority

)

50-328 SEQUOYAH NUCLEAR PLANT (SQN) -

REVISIONS TO THE TECHNICAL REQUIREMENTS MANUAL (TRM) (REVISIONS 28, 29, 30, 31, 32, 33, 34, AND 35) AND TECHNICAL SPECIFICATION (TS) BASES (UNIT 1 REVISIONS 25, 26, 27, AND 28; UNIT 2 REVISIONS 24, 25, 26, AND 27)

The purpose of this letter is to inform NRC of changes that we have incorporated into the TRM and the TS Bases.

Specifically, TRM Revision 28 revised the requirements for seismic instrumentation in Section TR 3.3.3.3.

This revision reformatted the specification and Bases along with the deletion of the special reporting requirements.

This reporting requirement deletion was in accordance with NRC Office Instruction No. LIC-100.

Revision 29 of the TRM added TRM Section TR 3.6.4.1 for the hydrogen monitors and associated Bases.

This change was required by TS Amendments 296 for Unit 1 and 286 for Unit 2 as part of the removal of the hydrogen monitors and recombiners from the TSs.

This change was in accordance with revised requirements in 10 CFR 50.44, "Standards for Combustible Control System in Light-Water-Cooled Power Reactors."

PRed l,ecWd poe

U.S. Nuclear Regulatory Commission Page 2 November 4, 2004 Revisions 30 and 31 of the TRM staged the implementation of TRM Section TR 3.4.9.2, "Pressure Temperature Limits," and associated Bases for each unit.

This change was required by TS Amendments 294 and 297 for Unit 1 and 284 for Unit 2 that approved this relocation of the reactor coolant system pressure temperature limit requirements to the TRM.

TRM Revision 32 incorporated new provisions for Requirements TR 3.0.4 and TR 4.0.4.

This change deletes previous exceptions to TR 3.0.4 and adopts the same provisions that were approved for the TSs by Amendments 301 for Unit 1 and 290 for Unit 2. This change provides consistency in the application of requirements between the TSs and the TRM.

TRM Revision 33 corrects an omission that occurred during the implementation of TRM Revision 13.

Revision 13 was associated with boration control systems and the phrase "and every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months " was inadvertently omitted from the Surveillance TR 4.1.2.6.

This change returned the requirement to the intended wording.

TRM Revision 34 modified the actions for inoperable hydrogen monitors in Requirement TR 3.6.4.1.

The previous actions only allowed for one monitor to be inoperable.

Revision 34 added an additional action to address two inoperable hydrogen monitors with a specified duration to return at least one monitor to operable status.

The action for one inoperable monitor was not altered by this addition and the new action incorporated a more limiting duration.

This change provides an acceptable requirement for loss of all hydrogen monitors in consideration of the potential for event requiring the use of this function and will prevent unnecessary entry into TR 3.0.3.

TRM Revision 35 corrects the wording of actions in Requirements TR 3.1.2.1, TR 3.1.2.3, and TR 3.1.2.5.

These are shutdown requirements for boration control systems and include individual actions for Modes 4, 5, and 6. Previous revisions to these requirements in both the TSs (before relocation to the TRM) and the TRM had expanded these actions from a single combined action for Modes 4, 5, and 6 to the current individual actions.

In doing so, a provision to suspend core alterations was inadvertently

U.S. Nuclear Regulatory Commission Page 3 November 4, 2004 included in actions for Modes 4 and 5. Since core alterations can only occur in Mode 6 after head lift, it is not possible for this action to be performed in Modes 4 and

5. Therefore, the requirement to suspend core alterations in these modes is not necessary and the core alteration wording was removed.

Unit I TS Bases Revision 25 and Unit 2 TS Bases Revision 24 modified the Bases for 3/4.9.12 to clarify that the auxiliary building gas treatment system (ABGTS) is not intended to cover the movement of dry cask loaded with spent fuel assemblies.

Requirements for movement of these fuel casks are addressed and covered by the requirements of 10 CFR 72.

This change was necessary to provide for the adjustment of radiation monitors such that unnecessary cycling of the ABGTS would not occur.

Unit 1 TS Bases Revision 26 and Unit 2 TS Bases Revision 25 removed discussions in the TS Bases for the hydrogen recombiners and monitors in Section 3/4.6.4.

This change was in concert with TS Amendments 296 for Unit 1 and 286 for Unit 2 that removed the corresponding TS requirements for these functions.

Unit 1 TS Bases Revision 27 and Unit 2 TS Bases Revision 26 clarifies a discussion in the Bases for Section 2.1.1 that implied that the SQN design included a direct reactor trip from a high containment pressure condition.

This condition will result in a safety injection actuation that in turn initiates a reactor trip and the associated Bases discussion was enhanced to provide this clarification.

Unit 1 TS Bases Revision 28 and Unit 2 TS Bases Revision 27 incorporated changes to the Bases for Specification 4.4.12.2 to clarify acceptable pump isolation methods.

This change was necessary to implement the new low temperature overpressure provisions approved by NRC in Amendments 294 for Unit 1 and 284 for Unit 2. The change allows for alternate means of pump isolation that ensure injection capabilities are inhibited.

U.S. Nuclear Regulatory Commission Page 4 November 4, 2004 The enclosure provides the revised TRM and TS Bases pages affected by these revisions.

Many of the enclosed pages have not been revised by the above revisions, but have been included for completeness and to maintain correct pagination.

Please direct questions concerning this issue to me at (423) 843-7170 or J. D. Smith at (423) 843-6672.

Sincerel, P. L. Pace Manager, Site Licensing and Industry Affairs Enclosure

ENCLOSURE SEQUOYAH NUCLEAR PLANT (SQN)

REVISED TECHNICAL REQUIREMENTS MANUAL (TRM)

AND TECHNICAL SPECIFICATION (TS) PAGES TRM PAGES -

UNITS 1 and 2 Index Page III Index Page IV Index Page V 3/4 0-1 3/4 0-2 3/4 0-3 3/4 0-4 3/4 1-2 3/4 1-4 3/4 1-6 3/4 1-9 3/4 3-2 3/4 3-6 3/4 4-1 3/4 4-2 3/4 6-1 3/4 6-2 3/4 6-3 3/4 6-4 3/4 6-5 3/4 6-6 3/4 7-11 3/4 8-2 3/4 8-5 B3/4 0-1 B3/4 0-2 B3/4 0-3 B3/4 0-4 B3/4 0-5 B3/4 0-6 B3/4 0-7 B3/4 0-8 B3/4 0-9 B3/4 1-2 B3/4 3-2 B3/4 3-3 B3/4 3-4 B3/4 3-5 B3/4 3-6 B3/4 3-11 B3/4 3-12 B3/4 4-1 B3/4 4-2 B3/4 4-3 B3/4 4-4 B3/4 6-1 B3/4 6-2 B3/4 6-3 B3/4 6-4 B3/4 6-5 B3/4 6-6 B3/4 7-8 TS BASES PAGES -

UNIT 1 TS BASES PAGES -

UNIT 2 B 2-6a B3/4 4-22 B3/4 6-4 B3/4 9-3 B 2-7 B3/4 4-23 B3/4 6-4 B3/4 9-3 E-1

INDEX TECHNICAL REQUIREMENTS SECTION PAGE TR 3/4.0 APPLICABILITY............................................... 3/4 0-1 TR 3/4.1 REACTIVITY CONTROL SYSTEMS TR 3/4.1.1 (No current requirements)................................... 3/4 1-1 TR 3/4.1.2 BORATION SYSTEMS TR 3/4.1.2.1 FLOW PATHS -

SHUTDOWN............................... 3/4 1-2 TR 3/4.1.2.2 FLOW PATHS -

OPERATING.............................. 3/4 1-3 TR 3/4.1.2.3 CHARGING PUMP -

SHUTDOWN............................ 3/4 1-4 TR 3/4.1.2.4 CHARGING PUMPS -

OPERATING.......................... 3/4 1-5 TR 3/4.1.2.5 BORATED WATER SOURCES -

SHUTDOWN.................... 3/4 1-6 TR 3/4.1.2.6 BORATED WATER SOURCES -

OPERATING................... 3/4 1-8 TR 3/4.1.3.1 Through TR 3/4.1.3.2 (No current requirements)........... 3/4 1-11 TR 3/4.1.3.3 POSITION INDICATION SYSTEM -

SHUTDOWN.................... 3/4 1-12 TR 3/4.2 POWER DISTRIBUTION LIMITS No current requirements TR 3/4.3 INSTRUMENTATION TR 3/4.3.1 Through TR 3/4.3.3.2 (No current requirements).............. 3/4 3-1 TR 3/4.3.3 MONITORING INSTRUMENTATION TR 3/4.3.3.3 SEISMIC INSTRUMENTATION............................. 3/4 3-2 TR 3/4.3.3.4 Through TR 3/4.3.14 (No current requirements)......

3/4 3-5 TR 3/4.3.3.15 PLANT CALORIMETRIC MEASURMENT...................... 3/4 3-6 TR 3/4.4 REACTOR COOLANT SYSTEM TR 3/4.4.1 Through TR 3/4 4.9.1 (No current requirements)............... 3/4 4-1 TR 3/4 4.9.2 Pressurizer Temperature Limits............................. 3/4 4-2 TR 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS)

No current requirements TR 3/4.6 CONTAINMENT SYSTEMS TR 3/4.6.1 Through TR 3/4.6.3 (No current requirements)....

........... 3/4 6-1 TR 3/4 6.4.1 Hydrogen Monitors........................................ 3/4 6-2 TR 3/4 6.5.1 (No current requirements)................................ 3/4 6-3 TR 3/4.6.5.2 Ice Bed Temperature Monitoring System..................... 3/4 6-4 TR 3/4.6.5.3 (No current requirements)................................. 3/4 6-5 TR 3/4.6.5.4 Inlet Door Position Monitoring System..................... 3/4 6-6 SEQUOYAH -

UNITS 1 AND 2 III April 22, 2005 TECHNICAL REQUIREMENTS Revision Nos. 1, 3-5, 8-13, 16, 17, 20, 23, 29, 30, 31

INDEX TECHNICAL REQUIREMENTS SECTION PAGE TR 3/4.7 PLANT SYSTEMS TR 3/4.7.1 Through TR 3/4 7.5 (No current requirements)................ 3/4 7-1 TR 3/4.7.6 FLOOD PROTECTION............................................ 3/4 7-2 TR 3/4.7.7 Through TR 3/4.7.8 (No current requirements)................ 3/4 7-4 TR 3/4.7.9 SNUBBERS................................................... 3/4 7-5 TR 3/4.7.10 Through TR 3/4.7.13 (No current requirements)............. 3/4 7-10 TR 3/4.7.14 HVAC MAINTENANCE RULE EQUIPMENT........................... 3/4 7-11 TR 3/4.8 ELECTRICAL POWER SYSTEMS TR 3/4.8.1 Through TR 3/4.8.2 (No current requirements)................ 3/4 8-1 TR 3/4.8.3.1 CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES....................................... 3/4 8-2 TR 3/4.8.3.2 MOTOR OPERATED VALVES THERMAL OVERLOAD PROTECTION......... 3/4 8-4 TR 3/4.8.3.3 ISOLATION DEVICES......................................... 3/4 8-5 TR 3/4.9 REFUELING OPERATIONS No current requirements TR 3/4.10 SPECIAL TEST EXCEPTIONS No current requirements TR 3/4.11 RADIOACTIVE EFFLUENTS No current requirements SEQUOYAH -

UNITS 1 AND 2 TECHNICAL REQUIREMENTS IV October 13, 2004 Revision Nos. 1, 3-5, 8-13

INDEX TECHNICAL REQUIREMENTS BASES SECTION PAGE TRB 3/4.0 APPLICABILITY.............................................. B 3/4 0-1 TRB 3/4.1 REACTIVITY CONTROL SYSTEMS TRB 3/4.1.1 (No current discussions)................................. B 3/4 1-1 TRB 3/4.1.2 BORATION SYSTEMS......................................... B 3/4 1-2 TRB 3/4.1.3.1 Through TRB 3/4.1.3.2 (No current discussions)......... B 3/4 1-4 TRB 3/4.1.3.3 POSITION INDICATION SYSTEM -

SHUTDOWN.................. B 3/4 1-5 TRB 3/4.2 POWER DISTRIBUTION LIMITS No current discussions TRB 3/4.3 INSTRUMENTATION TRB 3/4.3.1 Through TRB 3/4 3.3.2 (No current discussions)........... B 3/4 3-1 TRB 3/4.3.3.3 SEISMIC INSTRUMENTATION............................... B 3/4 3-2 TRB 3/4.3.3.4 Through TRB 3/4.3.3.14................................. B 3/4 3-7 TRB 3/4.3.3.15 PLANT CALORIMETRIC MEASURMENT........................ B 3/4 3-8 TRB 3/4.4 REACTOR COOLANT SYSTEM TRB 3/4.4.1 Through TRB 3/4 4.9.1 (No current discussions)............ B 3/4 4-1 TRB 3/4 4.9.2 Pressurizer Temperature Limits.......................... B 3/4 4-2 TRB 3/4.5 EMERGENCY CORE COOLING SYSTEMS No current discussions TRB 3/4.6 CONTAINMENT SYSTEMS TRB 3/4.6.1 Through TR 3/4.6.3 (No current discussions)....

......... B 3/4 6-1 TRB 3/4 6.4.1 Hydrogen Monitors..................................... B 3/4 6-2 TRB 3/4 6.5.1 (No current discussions).............................. B 3/4 6-3 TRB 3/4.6.5.2 Ice Bed Temperature Monitoring System.................. B 3/4 6-4 TRB 3/4.6.5.3 (No current discussions)............................... B 3/4 6-5 TRB 3/4.6.5.4 Inlet Door Position Monitoring System................... B 3/4 6-6 TRB 3/4.7 PLANT SYSTEMS TRB 3/4.7.1 Through TRB 3/4 7.5 (No current discussions)............. B 3/4 7-1 TRB 3/4.7.6 FLOOD PROTECTION........................................ B 3/4 7-2 TRB 3/4.7.7 Through TRB 3/4 7.8 (No current discussions)............. B 3/4 7-3 TRB 3/4.7.9 SNUBBERS................................................ B 3/4 7-4 TRB 3/4.7.10 Through 3/4.7.13 (No current discussions)............... B 3/4 7-6 TRB 3/4.7.14 HVAC MAINTENANCE RULE EQUIPMENT......................... B 3/4 7-7 TRB 3/4.8 ELECTRICAL POWER SYSTEMS TRB 3/4.8.1 Through TRB 3/4.8.2 (No current discussions)............. B 3/4 8-1 TRB 3/4.8.3 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES.................. B 3/4 8-2 TRB 3/4.9 REFUELING OPERATIONS No current discussions SEQUOYAH -

UNITS 1 AND 2 V

April 22, 2005 TECHNICAL REQUIREMENTS Revision Nos. 1, 4, 5, 8-13, 16, 17, 20, 23, I

29, 30, 31

TR 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS TR 3/4.0 APPLICABILITY LIMITING CONDITION FOR OPERATION TR 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Requirements is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

TR 3.0.2 Noncompliance with a Requirement shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Conditions for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

TR 3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in a MODE in which the Requirement does not apply by placing it, as applicable, in:

1.

At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

2.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

3.

At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation. Exceptions to these requirements are stated in the individual Requirements.

TR 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a.

When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b.

After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Requirement are stated in the individual Requirements, or

c.

When an allowance is stated In the individual value, parameter, or other Requirement.

This Requirement shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

TR 3.0.5 When a system, subsystem, train, component, or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system(s), subsystem(s), train(s), component(s),

SEQUOYAH - UNITS 1 AND 2 314 0-1 May 27, 2005 TECHNICAL REQUIREMENTS Revision Nos. 32

APPLICABILITY SURVEILLANCE REQUIREMENTS and device(s) are OPERABLE, or likewise satisfy the requirements of this Requirement. Unless both conditions (1) and (2) are satisfied, within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months action shall be initiated to place the unit in a MODE in which the applicable Limiting Condition for Operation does not apply by placing it as applicable in:

1.

At least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ,

2.

At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and

3.

At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

This Requirement is not applicable in MODES 5 or 6.

TR 3.0.6 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.1 and 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

TR 4.0.1 Surveillance Requirements shall be met during the MODES or other specified conditions in the Applicability for individual Limiting Condition for Operation, unless otherwise stated in the individual Surveillance Requirement. Failure to meet a Surveillance Requirement, whether such failure is experienced during the performance of the Surveillance or between performances of the Surveillance, shall be failure to meet the Limiting Condition for Operation. Failure to perform a Surveillance within the specified surveillance interval shall be failure to meet the Limiting Conditions for Operation except as provided in Technical Requirement 4.0.3. Surveillances do not have to be performed on inoperable equipment or variables outside specified limits.

TR 4.0.2 Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

TR 4.0.3 If It is discovered that a Surveillance was not performed within its specified surveillance interval (including the allowed extension per Technical Requirement 4.0.2), then compliance with the requirement to declare the Limiting Condition for Operation 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 surveillance interval, 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 Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered. When the Surveillance is performed within the delay period and the Surveillance is not met, the Limiting Condition for Operation must immediately be declared not met, and the applicable ACTION(s) must be entered.

TR 4.0.4 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided SEQUOYAH - UNITS 1 AND 2 3/4 0-2 May 27, 2005 TECHNICAL REQUIREMENTS Revision Nos. 7,19, 21, 32

APPLICABILITY SURVEILLANCE REQUIREMENTS (Continued)

TR 4.0.4 (Continued) by TR 4.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with TR 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

TR 4.0.5 Surveillance Requirements for inservice inspection and testing of ASME Code Class 1, 2, and 3 components shall be as follows:

Inservice Inspection Program This program provides controls for inservice inspection of ASME Code Class 1, 2, and 3 components, including applicable supports. The program shall include the following:

a.

Provisions that inservice testing of ASME Code Class 1, 2, and 3 components shall be performed in accordance with Section Xl of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a;

b.

The provisions of Technical Requirement 4.0.2 are applicable to the frequencies for performing inservice inspection activities;

c.

Inspection of each reactor coolant pump flywheel per the recommendation of Regulation Position c.4.b of Regulatory Guide 1.14, Revision 1, August 1975 or in lieu of Position c.4.b(1) and c.4.b(2), a qualified in-place ultrasonic examination over the volume from the inner bore of the flywheel to the circle one-half of the outer radius or a surface examination (magnetic particle and/or liquid penetrant) of exposed surfaces of the removed flywheels may be conducted at approximately 10-year intervals coinciding with the Inservice Inspection schedule as required by ASME Section Xl.

Inservice Testing Program This program provides controls for inservice testing of ASME Code Class 1, 2, and 3 components including applicable supports. The program shall include the following:

a.

Provisions that inservice testing of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section Xl of the ASME Boiler and Pressure Vessel Code and applicable Addenda as required by 10 CFR 50.55a;

b.

Testing Frequencies specified in Section Xl of the ASME Boiler and Pressure Vessel Code and applicable Addenda as follows:

SEQUOYAH - UNITS 1 AND 2 3/4 0-3 May 27, 2005 TECHNICAL REQUIREMENTS Revision Nos. 7,19, 32

APPLICABILITY SURVEILLANCE REQUIREMENTS (Continued)

TR 4.0.5 (Continued)

ASME Boiler and Pressure Vessel Code and applicable Addenda terminology for inservice testing activities Weekly Monthly Quarterly or every 3 months Semiannually or every 6 months Every 9 months Yearly or annually Biennially or every 2 years Required frequencies for performing inservice testing activities At least once per 7 days At least once per 31 days At least once per 92 days At least once per 184 days At least once per 276 days At least once per 366 days

-At least once per 731 days

c.

The provisions of Technical Requirement 4.0.2 are applicable to the above-required Frequencies for performing inservice testing activities;

d.

The provisions of Technical Requirement 4.0.3 are applicable to inservice testing and activities.

SEQUOYAH - UNITS I AND 2 TECHNICAL REQUIREMENTS 3/4 0-4 March 6, 2003 Revision Nos. 7, 19

REACTIVITY CONTROL SYSTEMS TR 3/4.1.2 BORATION SYSTEMS FLOW PATHS - SHUTDOWN LIMITING CONDITION FOR OPERATION TR 3.1.2.1 As a minimum, one of the following boron injection flow paths shall be OPERABLE:

a.

A flow path from the boric acid tank via a boric acid transfer pump and charging pump to the Reactor Coolant System if only the boric acid storage tank in TR 3.1.2.5a is OPERABLE, or

b.

The flow path from the refueling water storage tank via a charging pump to the Reactor Coolant System if only the refueling water storage tank in TR 3.1.2.5b is OPERABLE.

APPLICABILITY: MODES 4, 5 and 6.

ACTION:

MODE 4 - With none of the above flow paths OPERABLE, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of Technical Specification LCO 3.1.1.1 and restore one flow path as soon as possible.

MODE 5 - With none of the above flow paths OPERABLE, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of Technical Specification LCO 3.1.1.2.

MODE 6 - With none of the above flow paths OPERABLE, suspend all operations involving CORE ALTERATIONS and suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet Technical Specification LCO 3.9.1.

SURVEILLANCE REQUIREMENTS TR 4.1.2.1 At least one of the above required flow paths shall be demonstrated OPERABLE:

a.

At least once per 7 days by verifying that the temperature of the areas containing flow path components from the boric acid tanks to the blending tee is greater than or equal to 630F when it is a required water source.

b.

Whenever the area temperature(s) is (are) less than 630F and the boric acid tank is a required water source, the solution temperature in the flow path components from the boric acid tank must be measured to be greater than or equal to 630F within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter until the area temperature(s) has(have) returned to greater than or equal to 630F.

c.

At least once per 31 days by verifying that each valve (manual, power operated or automatic) in the flow path that is not locked, sealed, or otherwise secured in position, is in its correct position.

SEQUOYAH - UNITS 1 AND 2 3/4 1-2 October 12, 2005 TECHNICAL REQUIREMENTS Revision Nos. 13, 25, 35

REACTIVITY CONTROL SYSTEMS CHARGING PUMP - SHUTDOWN LIMITING CONDITION FOR OPERATION TR 3.1.2.3 One charging pump in the boron injection flow path required by TR 3.1.2.1 shall be OPERABLE and capable of being powered from an OPERABLE shutdown board.

APPLICABILITY: MODES 4,5 and 6.

ACTION:

MODE 4 - With no charging pump OPERABLE, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of Technical Specification LCO 3.1.1.1 and restore one changing pump as soon as possible.

MODE 5 - With no charging pump OPERABLE, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of Technical Specification LCO 3.1.1.2.

MODE 6 - With no charging pump OPERABLE, suspend all operations involving CORE ALTERATIONS and suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet Technical Specification LCO 3.9.1.

SURVEILLANCE REQUIREMENTS I

I TR 4.1.2.3 The above required charging pump shall be demonstrated OPERABLE by verifying, that on recirculation flow, the pump develops a discharge pressure of greater than or equal to 2400 psig when tested pursuant to TR 4.0.5.

SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS 3/4 1-4 October 12, 2005 Revision Nos. 13, 25, 35

REACTIVITY CONTROL SYSTEMS BORATED WATER SOURCES - SHUTDOWN LIMITING CONDITION FOR OPERATION TR 3.1.2.5 As a minimum, one of the following borated water sources shall be OPERABLE:

a.

A boric acid storage system with:

1.

A minimum contained borated water volume of 5000 gallons,

2.

Between 6120 and 6990 ppm of boron, and

3.

A minimum solution temperature of 630F.

b.

The refueling water storage tank with:

1.

A minimum contained borated water volume of 55,000 gallons,

2.

A minimum boron concentration of 2500 ppm, and

3.

A minimum solution temperature of 600F.

APPLICABILITY: MODES 4, 5 and 6.

ACTION:

MODE 4 - With no borated water source OPERABLE, suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet SDM of Technical Specification LCO 3.1.1.1.

MODE 5 - With no borated water source OPERABLE, suspend operations that would cause introduction l of coolant into the RCS with boron concentration less than required to meet SDM of Technical Specification LCO 3.1.1.2.

MODE 6 - With no borated water source OPERABLE, suspend all operations involving CORE ALTERATIONS and suspend operations that would cause introduction of coolant into the RCS with boron concentration less than required to meet Technical Specification LCO 3.9.1.

SURVEILLANCE REQUIREMENTS TR 4.1.2.5 The above required borated water source shall be demonstrated OPERABLE:

a.

For the boric acid storage system, when it is the source of borated water by:

1.

Verifying the boron concentration at least once per 7 days,

2.

Verifying the borated water volume at least once per 7 days, and SEQUOYAH - UNITS I AND 2 3/4 1-6 October 12, 2005 TECHNICAL REQUIREMENTS Revision Nos. 13, 25, 35

REACTIVITY CONTROL SYSTEMS SURVEILLANCE REQUIREMENTS TR 4.1.2.6 Each borated water source shall be demonstrated OPERABLE:

a.

For the boric acid storage system, when it is the source of borated water by:

1.

Verifying the boron concentration at least once per 7 days,

2.

Verifying the borated water volume at least once per 7 days, and

3.

Verifying the boric acid storage tank solution temperature is greater than or equal to 630F at least once per 7 days by verifying the area temperature to be greater than or equal to 630F, or

4.

Whenever the boric acid tank area temperature is less than 630F and the boric acid storage system being used as the source of borated water, within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months thereafter, verify the boric acid tank solution temperature to be greater than l or equal to 630F until the boric acid tank area temperature has returned to greater than or equal to 630F.

b.

For the refueling water storage tank by:

1.

Verifying the boron concentration at least once per 7 days,

2.

Verifying the borated water volume at least once per 7 days, and

3.

Verifying the solution temperature at least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS 314 1-9 June 20, 2005 Revision Nos. 13, 33

INSTRUMENTATION SEISMIC INSTRUMENTATION LIMITING CONDITION FOR OPERATION TR 3.3.3.3 The seismic monitoring instrumentation shown in Table 3.3-7 shall be OPERABLE.

APPLICABILITY: At all times.

ACTION:

a.

With seismic monitoring instrument 0-XT-52-75B or Panel 0-R-113 inoperable for more than 30 days, initiate a non-conformance report in accordance with the Corrective Action Program.

b.

With one or more of the remaining seismic monitoring instruments inoperable for more than 60 days, initiate a non-conformance report in accordance with the Corrective Action Program.

c.

Each of the above seismic monitoring instruments actuated during a seismic event shall be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and a CHANNEL CALIBRATION performed within 10 days following the seismic event. Data shall be retrieved from actuated instruments and the data from accelerometer 0-XT-52-75B analyzed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to determine the magnitude of the vibratory ground motion. Walkdowns of accessible plant areas shall be performed within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months following the event to determine plant condition.

d.

The provisions of Technical Requirement 3.0.3 are not applicable.

SURVEILLANCE REQUIREMENTS I

TR 4.3.3.3.1 Each of the above seismic monitoring instruments shall be demonstrated OPERABLE by the performance of the CHANNEL CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table 4.3-4.

SEQUOYAH - UNITS I AND 2 TECHNICAL REQUIREMENTS 3/4 3-2 May 27, 2005 Revision Nos. 4, 6, 28, 32

INSTRUMENTATION PLANT CALORIMETRIC MEASUREMENT LIMITING CONDITION FOR OPERATION TR 3.3.3.15 The Leading Edge Flow Meter (LEFM) shall be used for the plant calorimetric measurement in the completion of Technical Specification (TS) Surveillance Requirement (SR) 4.3.1.1.1, for Power Range Neutron Flux Channel calibration by heat balance comparison (TS Table 4.3-1 Note 2).

APPLICABILITY:

MODE 1 > 15% RTP ACTION:

a.#

With the LEFM not available for the plant calorimetric measurement, restore it to available status prior to the next performance of TS SR 4.3.1.1.1, Power Range Neutron Flux Channel calibration by heat balance comparison. If this action can not be completed in time then perform Action b.

b.#

If Action a. above can not be met, then ensure thermal power is reduced to < 98.7% RTP (3411 MWt) prior to the next performance of TS SR 4.3.1.1.1 for Power Range Neutron Flux Channel calibration by heat balance comparison and perform the TS SR based on acceptable alternate methods. Maintain Thermal Power = 98.7% RTP (3411 MWt) until LEFM is restored to available status and TS SR 4.3.1.1.1 for Power Range Neutron Flux Channel calibration by heat balance comparison is performed using LEFM power calorimetric measurement.

I TECHNICAL SURVEILLANCE REQUIREMENTS TR 4.3.3.15.1 Verify availability of the LEFM, indicated by the Normal/Fail status indication not in Fail status and feedwater temperatures greater than or equal to 250 degrees F, prior to the performance of TS SR 4.3.1.1.1 for Power Range Neutron Flux Channel calibration by heat balance comparison.

Refer to COLR limits for AFD and rod insertion. Limits are more restrictive when LEFM is unavailable.

SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS 3/4 3-6 May 27, 2005 Revision Nos. 17, 32

REACTOR COOLANT SYSTEM TR 3/4.4.1 No current requirements TR 3/4.4.2 No current requirements TR 3/4.4.3 No current requirements TR 3/4.4.4.No current requirements TR 3/4.4.5 No current requirements TR 314.4.6 No current requirements TR 3/4.4.7 No current requirements TR 3/4.4.8 No current requirements TR 3/4.4.9.1 No current requirements SEQUOYAH - UNITS I AND 2 TECHNICAL REQUIREMENTS 314 4-1 October 13, 2004 Revision Nos. 30

REACTOR COOLANT SYSTEM PRESSURIZER TEMPERATURE LIMITS LIMITING CONDITION FOR OPERATION TR 3A.9.2 The pressurizer temperature shall be limited to:

a.

A maximum heatup of 1000F in anyone hour period,

b.

A maximum cooldown of 2000 F in any one hour period, and

c.

A maximum spray water temperature differential of 5600F.

APPLICABILITY: At all times.

ACTION:

With the pressurizer temperature limits in excess of any of the above limits, restore the temperature to within the limits within 30 minutes; perform an engineering evaluation to determine the effects of the out-of-limit condition on the structural integrity of the pressurizer; determine that the pressurizer remains acceptable for continued operation or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and reduce the pressurizer pressure to less than 500 psig within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS TR 4.4.9.2.1 The pressurizer temperatures shall be determined to be within the limits at least once per 30 minutes during system heatup or cooldown.

TR 4.4.9.2.2 Any occurrence of spray operation with a differential temperature greater than 320'F shall berecorded for evaluation of the cyclic limits in TS Table 5.7.1.

SEQUOYAH - UNITS I AND 2 TECHNICAL REQUIREMENTS 3/4 4-2 April 22,2005 Revision Nos. 30, 31

TR 3/4.6 CONTAINMENT SYSTEMS TR 3/4 6.1 No current requirements TR 3/4 6.2 No current requirements TR 3/4 6.3 No current requirements SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS 3/4 6-1 October 13, 2004 Revision Nos. 20, 29

CONTAINMENT SYSTEMS TR 314.6.4 COMBUSTIBLE GAS CONTROL HYDROGEN MONITORS LIMITING CONDITION FOR OPERATION TR 3.6.4.1 Two independent containment hydrogen analyzers shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTION:

a.

With one hydrogen monitor inoperable, restore the inoperable monitor to OPERABLE status within 30 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b.

With two hydrogen monitors inoperable, restore at least one inoperable monitor to OPERABLE status within 7 days or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS TR 4.6.4.1 Each hydrogen monitor shall be demonstrated OPERABLE by the performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , a CHANNEL FUNCTIONAL TEST at least once per 31 days, and at least once per 92 days on a STAGGERED TEST BASIS by performing a CHANNEL CALIBRATION using sample gas containing:

a.

One volume percent hydrogen, balance nitrogen.

b.

Four volume percent hydrogen, balance nitrogen.

SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS 3/4 6-2 June 24, 2005 Revision Nos. 29, 34

TR 3/4.6 CONTAINMENT SYSTEMS TR 3/4 6.5.1 No current requirements SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS 3/4 6-3 October 13, 2004 Revision Nos. 20

CONTAINMENT SYSTEMS TR 3/4.6.5.2 ICE BED TEMPERATURE MONITORING SYSTEM LIMITING CONDITION FOR OPERATION TR 3.6.5.2 The ice bed temperature monitoring system shall be OPERABLE with at least 2 OPERABLE RTD channels in the ice bed at each of 3 basic elevations (1 0'6", 30'9" and 55' above the floor of the ice condenser) for each one third of the ice condenser.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

a.

With the ice bed temperature indication not available in the main control room, determine the ice bed temperature at the local ice condenser temperature monitoring panel every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

I

b.

With the ice bed temperature monitoring system inoperable and unable to determine the ice bed temperatures by alternate means, POWER OPERATION may continue for up to 6 days provided the ice compartment lower inlet doors, intermediate deck doors, and top deck doors are closed and the last recorded mean ice bed temperature was less than or equal to 150F and steady; otherwise, be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS TR 4.6.5.2 The ice bed temperature monitoring system shall be determined OPERABLE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS 314 6-4 May 27, 2005 Revision Nos. 20, 32

TR 3/4.6 CONTAINMENT SYSTEMS TR 3/4 6.5.3 No current requirements SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS 3/4 6-5 October 11, 2002 Revision Nos. 20

CONTAINMENT SYSTEMS TR 3/4.6.5.4 INLET DOOR POSITION MONITORING SYSTEM LIMITING CONDITION FOR OPERATION TR 3.6.5.4 The inlet door position monitoring system shall be OPERABLE.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

With the inlet door position monitoring system inoperable, POWER OPERATION may continue for up to 14 days, provided the ice bed temperature monitoring system is OPERABLE and the maximum ice bed temperature is less than or equal to 270F when monitored at least once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months ; otherwise, restore the inlet door position monitoring system to OPERABLE status within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months or be in at least HOT SHUTDOWN within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS TR 4.6.5.4 The inlet door position monitoring system shall be determined OPERABLE by:

a.

Performing a CHANNEL CHECK at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ,

b.

Performing a CHANNEL FUNCTIONAL TEST at least once per 18 months, and

c.

Verifying that the monitoring system correctly indicates the status of each inlet door as the door is opened and reclosed during its testing per Technical Specification 4.6.5.3.1.

SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS 3/4 6-6 October 11, 2002 Revision Nos. 20

PLANT SYSTEMS TR 3/4.7.14 HEATING, VENTILATING, AND AIR CONDITIONING (HVAC) MAINTENANCE RULE EQUIPMENT LIMITING CONDITION FOR OPERATION TR 3.7.14 The HVAC components shown in Table 3.7.14-1 shall be OPERABLE.

APPLICABILITY: As shown in Table 3.7.14-1.

ACTION:

With any of the HVAC components on Table 3.7.14-1 inoperable, enter the associated LCO in the Operation narrative logs and LCO tracking logs for Maintenance Rule Unavailability tracking.

SURVEILLANCE REQUIREMENTS I

None SEQUOYAH -

UNITS 1 AND 2 TECHNICAL REQUIREMENTS 3/4 7-11 May 27, 2005 Revision Nos. 12, 22, 32

ELECTRICAL POWER SYSTEMS TR 3/4.8.3 ELECTRICAL EQUIPMENT PROTECTIVE DEVICES CONTAINMENT PENETRATION CONDUCTOR OVERCURRENT PROTECTIVE DEVICES LIMITING CONDITION FOR OPERATION TR 3.8.3.1 Primary and Backup containment penetration conductor overcurrent protective devices associated with each containment electrical penetration circuit shall be OPERABLE.

The scope of these protective devices excludes those circuits for which credible fault currents would not exceed the electrical penetration design rating.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

With one or more of the containment penetration conductor overcurrent protective devices:

a.

Restore the protective device(s) to OPERABLE status or de-energize the circuit(s) by tripping the associated backup circuit breaker within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and verify the backup circuit breaker to be tripped at least once per 7 days, or

b.

Be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS TR4831 Alcnanetpntaincnutroecretpoetv I

TR 4.8.3.1 All containment penetration conductor overcurrent protective devices shall be demonstrated OPERABLE:

a. At least once per 18 months:

1. For at least one 6.9 kV reactor coolant pump circuit, such that all reactor coolant pump circuits are demonstrated OPERABLE at least once per 72 months, by performance of:

(a) A CHANNEL CALIBRATION of the associated protective relays specified in appropriate plant instructions, and (b) An integrated system functional test which includes simulated automatic actuation of the system and verifying that each relay and associated circuit breakers and control circuits function as designed.

SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS 3/4 8-2 May 27, 2005 Revision Nos. 8, 32

ELECTRICAL POWER SYSTEMS ISOLATION DEVICES LIMITING CONDITION FOR OPERATION TR 3.8.3.3 All circuit breakers actuated by fault currents that are used as isolation devices protecting IE busses from non qualified loads shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3 and 4.

ACTION:

With one or more of the above required circuit breakers inoperable either:

a.

Restore the inoperable circuit breaker(s) to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , or

b.

Trip the inoperable circuit breaker(s), rack-out the circuit breaker(s) within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and verify the circuit breaker(s) to be racked out at least once per 7 days, or I

c.

Be in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months .

SURVEILLANCE REQUIREMENTS TR 4.8.3.3 Each of the above required circuit breakers shall be demonstrated OPERABLE:

a.

At least once per 18 months by selecting and functionally testing a representative sample of at least 10% of each type of circuit breaker.

Circuit breakers selected for functional testing shall be selected on a rotating basis.

The functional test shall consist of injecting a current input at the specified setpoint to each selected circuit breaker or relay and verifying that each circuit breaker functions as designed.

For each device found inoperable during these functional tests, an additional representative sample of at least 10% of each over current protection device of the inoperable type shall also be functionally tested until no more failures are found or all devices of that type have been functionally tested.

b.

At least once per 60 months by subjecting each circuit breaker to an inspection and preventive maintenance in accordance with procedures prepared in conjunction with its manufacturer's recommendations.

SEQUOYAH -

UNITS 1 AND 2 TECHNICAL REQUIREMENTS 3/4 8-5 May 27, 2005 Revision Nos. 8, 32

TRB 3/4.0 APPLICABILITY BASES The requirements of this section provide the general requirements applicable to each of the Limiting Conditions for Operation and Surveillance Requirements within Technical Requirements 3/4.

TRB 3.0.1 This Requirement defines the applicability of each requirement in terms of defined OPERATIONAL MODES or other specified conditions and is provided to delineate specifically when each requirement is applicable.

TRB 3.0.2 This Requirement defines those conditions necessary to constitute compliance with the terms of an individual Limiting Condition for Operation and associated ACTION requirement.

TRB 3.0.3 This Requirement delineates the ACTION to be taken for circumstances not directly provided for in the ACTION statements and whose occurrence would violate the intent of the requirement.

For example, Technical Specification 3.5.2 requires two independent ECCS subsystems to be OPERABLE and provides explicit ACTION requirements if one ECCS subsystem is inoperable.

Under the requirements of Technical Specification 3.0.3, if both of the required ECCS subsystems are inoperable, within one hour measures must be initiated to place the unit in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in at least HOT SHUDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

As a further example, Technical Specification 3.6.2.1 requires two containment spray subsystems to be OPERABLE and provides explicit ACTION requirements if one spray system is inoperable. Under the requirements of Technical Specification 3.0.3, if both of the required containment spray subsystems are inoperable, within one hour measures must be initiated to place the unit in at least HOT STANDBY within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , in at least HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

TRB 3.0.4 TR 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met.

It allows placing the unit in a MODE or other specified condition stated in that Applicability (e.g., the Applicability desired to be entered) when unit conditions are such that the requirements of the LCO would not be met, in accordance with TR 3.0.4.a, TR 3.0.4.b, or TR 3.0.4.c.

TR 3.0.4.a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time.

Compliance with required Actions that permit continued operation of the unit for an unlimited period of time in a MODE or other specified condition provides an acceptable level of safety for continued operation.

This is without regard to the status of the unit before or after the MODE change.

Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the required Actions.

TR 3.0.4.b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, SEQUOYAH UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 0-1 May 27, 2005 Revision Nos. 32

TRB 3/4.0 APPLICABILITY BASES and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities to be assessed and managed.

The risk assessment for the purposes of TR 3.0.4 (b), must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the normal 10 CFR 50.65(a)(4) risk assessment scope.

The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section 11 of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants."

These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions, and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS completion times that would require exiting the Applicability.

TR 3.0.4.b may be used with single or multiple systems and components unavailable.

NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The TR 3.0.4.b risk assessments do not have to be documented.

The Technical Requirements allow continued operation with equipment unavailable in MODE 1 for the duration of the completion time.

Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the TR 3.0.4.b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above.

However, there is a small subset of systems and components that have been determined to be more important to risk and use of the TR 3.0.4.b allowance is prohibited.

The LCOs governing-these system and components contain notes prohibiting the use of TR 3.0.4.b by stating that TR 3.0.4.b is not applicable.

TR 3.0.4.c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a note in the requirement which states TR 3.0.4.c is applicable.

These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed.

This allowance may apply to all the ACTIONS or to a specific required Action of a Requirement.

The risk assessments performed to justify the use of TR 3.0.4.b usually only consider systems and components.

For this reason, TR 3.0.4.c is typically applied to Requirements which describe values and parameters (e.g.,

Technical Specification LCO -

Reactor Coolant System Specific Activity), and may be applied to other Technical Specifications based on NRC plant-specific approval or Technical Requirements based on the plant approval process.

SEQUOYAH UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 0-2 May 27, 2005 Revision Nos. 32

TRB 3/4.0 APPLICABILITY BASES The provisions of this Requirement should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

The provisions of TR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS.

In addition, the provisions of TR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown.

In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, TR 3.0.1 and TR 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Requirement.

Surveillances do not have to be performed on the associated inoperable equipment (or on variables outside the specified limits), as permitted by TR 4.0.1.

Therefore, utilizing TR 3.0.4 is not a violation of TR 4.0.1 or TR 4.0.4 for any Surveillances that have not been performed on inoperable equipment.

However, Surveillance Requirements must be met to ensure OPERABILITY prior to declaring the associated equipment OPERABLE (or variable within limits) and restoring compliance with the affected LCO.

TRB 3.0.5 This Requirement delineates what additional conditions must be satisfied to permit operation to continue, consistent with the ACTION statements for power sources, when a normal or emergency power source is not OPERABLE.

It specifically prohibits operation when one division is inoperable because its normal or emergency power source is inoperable and a system, subsystem, train, component or device in another division is inoperable for another reason.

The provisions of this Requirement permit the ACTION statements associated with individual systems, subsystems, trains, components, or devices to be consistent with the ACTION statements of the associated electrical power source.

It allows operation to be governed by the time limits of the ACTION statement associated with the Limiting Condition for Operation for the normal or emergency power source, not the individual ACTION statements for each system, subsystem, train, component or device that is determined to be inoperable solely because of the inoperability of its normal or emergency power source.

For example, Technical Specification 3.8.1.1 requires in part that four emergency diesel generators be OPERABLE.

The ACTION statement provides for a 72-hour out-of-service time when one emergency diesel generator is not OPERABLE.

If the definition of OPERABLE was applied without consideration of Technical Specification 3.0.5, all systems, subsystems, trains, components, and devices supplied by the inoperable emergency power source would also be inoperable.

This would dictate invoking the applicable ACTION statements for each of the applicable Limiting Conditions for Operation.

However, the SEQUOYAH UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 0-3 May 27, 2005 Revision Nos. 32

TRB 3/4.0 APPLICABILITY BASES provisions of Technical Specification 3.0.5 permit the time limits for continued operation to be consistent with the ACTION statement for the inoperable emergency diesel generator instead, provided the other specified conditions are satisfied.

In this case, this would mean that the corresponding normal power source must be OPERABLE, and all redundant systems, subsystems, trains, components, and devices must be OPERABLE, or otherwise satisfy Technical Specification 3.0.5 (i.e., be capable of performing their design function and have at least one normal or one emergency power source OPERABLE).

If they are not satisfied, action is required in accordance with this specification.

As a further example, Technical Specification 3.8.1.1 requires in part that two physically independent circuits between the offsite transmission network and the onsite Class IE distribution system be OPERABLE.

The ACTION statement provides a 24-hour out-of-service time when both required offsite circuits are not OPERABLE.

If the definition of OPERABLE was applied without consideration of Technical Specification 3.0.5, all systems, subsystems, trains, components, and devices supplied by the inoperable normal power sources, both of the offsite circuits would also be inoperable.

This would dictate invoking the applicable ACTION statements for each of the applicable LCOs.

However, the provisions of Technical Specification 3.0.5 permit the time limit for continued operation to be consistent with the ACTION statement for the inoperable normal power sources instead, provided the other specified conditions are satisfied.

In this case, this would mean that for one division the emergency power source must be OPERABLE (as must be the components supplied by the emergency power source), and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE.

If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6, TR 3.0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in these MODES must be adhered to.

TRB 3.0.6 LCO TR 3.0.6 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 Requirement is to provide an exception to LCOs TR 3.0.1 and TR 3.0.2 (e.g., 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 time 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 Requirement does not provide time to perform any other preventive or corrective maintenance.

SEQUOYAH UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 0-4 February 2, 1998-A

APPLICABILITY BASES 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 Required 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 occurring 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.

TRB 4.0.1 TR 4.0.1 establishes the requirement that surveillances must be met during the OPERATIONAL MODES or other specified conditions in the Applicability for which the requirements of the Limiting Condition for Operation apply, unless otherwise specified in the individual Surveillance Requirement.

The purposes of this Specification is to ensure that Surveillances are performed to verify the operational status of systems and components and that variables are within specified limits to ensure safe operation of the facility when the plant is in a MODE or other specified condition for which associated Limiting Condition for Operation are applicable.

Failure to meet a Surveillance Requirement within the specified surveillance interval, in accordance with TR 4.0.2, constitutes a failure to meet a Limiting Condition for Operation.

Systems and components are assumed to be OPERABLE when the associated Surveillance Requirements have been met.

Nothing in this Specification, however, is to be construed as implying that systems or components are OPERABLE when:

a. The systems or components are known to be inoperable, although still meeting the Surveillance Requirements; or

b. The requirements of the Surveillance(s) are known not to be met between required Surveillance performances.

Surveillances do not have to be performed when the unit is in an OPERATIONAL MODE for which the requirements of the associated Limiting Condition for Operation do not apply unless otherwise specified. The Surveillance Requirements associated with a Special Test Exception are only applicable when the Special Test Exception is used as an allowable exception to the requirements of a specification.

Surveillance Requirements do not have to be performed on inoperable equipment because the ACTION requirements define the remedial measures that apply.

However, the Surveillance Requirements have to be met to demonstrate that the inoperable equipment has been restored to OPERABLE status.

Upon completion of maintenance, appropriate post maintenance testing is required to declare equipment OPERABLE.

This includes ensuring applicable Surveillances are not failed and their most recent performance is in accordance with TR 4.0.2.

Post maintenance testing may not be possible in the current OPERATIONAL MODE or other specified conditions in the Applicability due to the necessary unit parameters not having been established.

In these situations, the equipment may be considered OPERABLE provided testing has SEQUOYAH UNITS 1 AND 2 B 3/4 0-5 March 6, 2003-A TECHNICAL REQUIREMENTS Revision Nos. 21

APPLICABILITY BASES been satisfactorily completed to the extent possible and the equipment is not otherwise believed to be incapable of performing its function.

This will allow operation to proceed to an OPERATIONAL MODE or other specified condition where other necessary post maintenance tests can be completed.

Some examples of this process are:

a. Auxiliary feedwater (AFW) pump turbine maintenance during refueling that requires testing at steam pressures > 800 psi.

However, if other appropriate testing is satisfactorily completed, the AFW System can be considered OPERABLE.

This allows startup and other necessary testing to proceed until the plant reaches the steam pressure required to perform the testing.

b. High pressure safety injection (HPI) maintenance during shutdown that requires system functional tests at a specified pressure.

Provided other appropriate testing is satisfactorily completed, startup can proceed with HPI considered OPERABLE.

This allows operation to reach the specified pressure to complete the necessary post maintenance testing.

TRB 4.0.2 Requirement TR 4.0.2 established the limit for which the specified time interval for Surveillance Requirements may be extended.

It permits an allowable extension of the normal surveillance interval to facilitate surveillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities.

It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval.

It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages.

The limitation of TR 4.0.2 is based on engineering judgment and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements.

This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

TRB 4.0.3 TR 4.0.3 establishes the flexibility to defer declaring affected equipment inoperable or an affected variable outside the specified limit when a Surveillance has not been completed within the specified Frequency.

A delay period of 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 surveillance interval, whichever is greater, applies from the point in time that it is discovered that the Surveillance has not been performed in accordance with TR 4.0.2, and not at the time that the specified surveillance interval was not met.

This delay period provides adequate time to complete Surveillances that have been missed.

This delay period permits the completion of a Surveillance before complying with ACTION requirements or other remedial measures that might preclude completion of the Surveillance.

SEQUOYAH UNITS 1 AND 2 B 3/4 0-6 March 6, 2003-A TECHNICAL REQUIREMENTS Revision Nos. 19, 21

APPLICABILITY BASES The basis for this delay period includes consideration of the unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements.

When a Surveillance with a surveillance frequency based not on time intervals, but upon specified unit conditions, operating situations, or requirements of regulations (e.g., prior to entering MODE 1 after each fuel loading, or in accordance with 10 CFR 50, Appendix J, as modified by approved exemptions, etc.) is discovered to not have been performed when specified, TR 4.0.3 allows for the full delay period of up to the specified surveillance interval to perform the Surveillance.

However, since there is not a time interval specified, the missed Surveillance should be performed at the first reasonable opportunity.

TR 4.0.3 provides a time limit for, and allowances for the performance of, Surveillances that become applicable as a consequence of MODE changes imposed by required ACTIONS.

Failure to comply with the specified surveillance interval for the technical requirement is expected to be an infrequent occurrence.

Use of the delay period established by Surveillance Requirement 4.0.3 is a flexibility which is not intended to be used as an operational convenience to extend Surveillance intervals.

While up to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or the limit of the specified surveillance interval is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity.

The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance.

This risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance Activities at Nuclear Power Plants."

This Regulatory Guide addresses consideration of temporary and aggregate risk impacts, determination of risk management action thresholds, and risk management action up to and including plant shutdown.

The missed Surveillance should be treated as an emergent condition as discussed in the Regulatory Guide.

The risk evaluation may use quantitative, qualitative, or blended methods.

The degree of depth and rigor of the evaluation should be commensurate with the importance of the component. Missed Surveillances for important components should be analyzed quantitatively.

If the results of the risk evaluation determine the risk increase is significant, this evaluation should be used to determine the safest course of action. All missed Surveillances will be placed in the licensee's Corrective Action Program.

SEQUOYAH UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 0-7 March 6, 2003 Revision Nos. 19, 21

APPLICABILITY BASES If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specification limits and the entry into the ACTION requirements for the applicable Limiting Conditions for Operation begins immediately upon expiration of the delay period.

If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the entry into the ACTION requirements or the applicable Limiting Conditions for Operation begins immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this technical requirement, or within the Allowed Outage Time of the ACTIONS, restores compliance with Technical Requirement 4.0.1.

TRB 4.0.4 TR 4.0.4 establishes the requirement that all applicable Surveillance Requirements (SRs) must be met before entry into a MODE or other specified condition in the Applicability.

This Requirement ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit.

The provisions of this Requirement should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to Surveillance not being met in accordance with TR 3.0.4.

However, in certain circumstances, failing to meet an SR will not result in TR 4.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) are not required to be performed, per TR 4.0.1, which states that surveillances do not have to be performed on inoperable equipment. When equipment is inoperable, TR 4.0.4 does not apply to the associated SR(s) since the requirement for the SR(s) to be performed is removed.

Therefore, failing to perform the Surveillance(s) within the specified frequency does not result in an TR 4.0.4 restriction to changing MODES or other specified conditions of the Applicability.

However, since the LCO is not met in this instance, TR 3.0.4 will govern any restrictions that may (or may not) apply to MODE or other specified condition changes. TR 4.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified frequency, provided the requirement to declare the LCO not met has been delayed in accordance with TR 4.0.3.

The provisions of TR 4.0.4 shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS.

In addition, the provisions of TR 4.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown.

In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE 1 to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

SEQUOYAH UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 0-8 May 27, 2005 Revision Nos. 19, 21, 32

APPLICABILITY BASES TRB 4.0.5 This Requirement ensures that inservice inspection of ASME Code Class 1, 2, and 3 components and inservice testing of ASME Code Class 1, 2, and 3 pumps and valves will be performed in accordance with a periodically updated version of Section XI of the ASME Boiler and Pressure Vessel Code and Addenda as required by 10 CFR 50.55a.

This Requirement includes a clarification of the frequencies for performing the inservice inspection and testing activities required by Section XI of the ASME Boiler and Pressure Vessel Code and applicable Addenda. This clarification is provided to ensure consistency in surveillance intervals throughout these Technical Requirements and to remove any ambiguities relative to the frequencies for performing the required inservice inspection and testing activities.

SEQUOYAH UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 0-9 July 25, 2002 Revision Nos. 19

REACTIVITY CONTROL SYSTEMS BASES TRB 3/4.1.2 BORATION SYSTEMS The boron injection system ensures that negative reactivity control is available during each mode of facility operation. The components required to perform this function include 1) borated water sources,

2) charging pumps, 3) separate flow paths, 4) boric acid transfer pumps, and 5) an emergency power supply from OPERABLE diesel generators.

With the RCS average temperature above 3501F, a minimum of two boron injection flow paths are required to ensure single functional capability in the event an assumed failure renders one of the flow paths inoperable. The boration capability of either flow path is sufficient to provide a SHUTDOWN MARGIN from expected operating conditions of 1.6% delta k/k after xenon decay and cooldown to 200 0F. The maximum expected boration capability requirement occurs at near EOL from full power peak xenon conditions and requires borated water from a boric acid tank in accordance with Figure 3.1.2.6, and additional makeup from either: (1) the common boric acid tank and/or batching, or (2) a minimum of 26,000 gallons of 2500 ppm borated water from the refueling water storage tank. With the refueling water storage tank as the only borated water source, a minimum of 57,000 gallons of 2500 ppm borated water is required.

The boric acid tanks, pumps, valves, and piping contain a boric acid solution concentration of between 3.5% and 4.0% by weight. To ensure that the boric acid remains in solution, the air temperature is monitored in strategic locations. By ensuring the air temperature remains at 630F or above, a 50F margin is provided to ensure the boron will not precipitate out. To provide operational flexibility, if the area temperature should fall below the required value, the solution temperature (as determined by the pipe or tank wall temperature) will be monitored at an increased frequency to compensate for the lack of solution temperature alarm in the main control room.

With the RCS temperature below 3500F, one injection system is acceptable without single failure consideration on the basis of the stable reactivity condition of the reactor and the additional restrictions prohibiting CORE ALTERATIONS and operations involving positive reactivity additions that could result in loss of required SDM (Modes 4 or 5) or boron concentration (Mode 6) in the event the single injection system becomes inoperable. Suspending positive reactivity additions that could result in failure to meet minimum SDM or boron concentration limit is required to assure continued safe operation. Introduction of coolant inventory must be from sources that have a boron concentration greater than or equal to that required in the RCS for minimum SDM or refueling boron concentration. This may result in an overall reduction in RCS boron concentration but provides acceptable margin to maintaining subcritical operation. Introduction of temperature changes including temperature increases when operating with a positive MTC must also be evaluated to ensure they do not result in a loss of required SDM.

The boron capability required below 3500F, is sufficient to provide a SHUTDOWN MARGIN of 1.6% delta k/k after xenon decay and cooldown from 3500F to 2000, and a SHUTDOWN MARGIN of 1%

delta k/k after xenon decay and cooldown from 200OF to 1400F. This condition requires either 5000 gallons of 6120 ppm borated water from the boric acid storage tanks or 13,400 gallons of 2500 ppm borated water from the refueling water storage tank.

The contained water volume limits include allowance for water not available because of discharge line location and other physical characteristics. The 55,000 gallon limit in the refueling water storage tank for modes 4, 5, and 6 is based upon 22,182 gallons that is undetectable due to lower tap location, 19,197 gallons for instrument error, 13,400 gallons required for shutdown margin, and an additional 221 gallons due to rounding up.

SEQUOYAH - UNITS I AND 2 B 3/4 1-2 October 12, 2005 TECHNICAL REQUIREMENTS Revision Nos. 13, 25, 35

INSTRUMENTATION BASES TRB 3/4.3.3.3 SEISMIC INSTRUMENTATION BACKGROUND The seismic instrumentation is made up of several instruments such as accelerometers, accelerographs, recorders, etc.

These instruments are placed in several appropriate locations throughout the plant in order to provide 1) data on the seismic input to containment, 2) data on the frequency, amplitude and phase relationship of the seismic response of the containment structure, and 3) data on the seismic input to and response of other Seismic Category I structures (Ref 1).

This instrumentation is consistent with the intent of Regulatory Guide 1.12, Revision 1.

The original seismic instrumentation was replaced with state of the art digital instrumentation in order to facilitate application of EPRI OBE (i.e., 1/2 SSE for Sequoyah)

Exceedance Criteria, as delineated in References 2 and 5.

The replacement instrumentation is capable of recording a seismic event and performing appropriate analyses of the recorded data to provide a timely basis for determining whether a potentially damaging OBE exceedance has occurred.

This information must be evaluated within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after an event and a walkdown of accessible plant features must be accomplished within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months after an event.

The determination as to whether an 1/2 SSE Exceedance has occurred is made by comparing the calculated spectra for the event with the applicable site design basis spectra, which is defined at top of rock for Sequoyah (ref. 4).

Therefore, the exceedance determination for SQN will be made using uncorrected event data from accelerometer 0-XT-52-75B in the Containment annulus.

The use of uncorrected event data is known to be conservative because of the inherent response characteristics of the accelerometer.

Data from this instrument is recorded at the top of the containment foundation, which is rock-supported.

The recorder for this accelerometer is located in panel 0-R-113.

As noted above, this accelerometer and recorder are the key components used to detect and record the event in order to make a shutdown decision.

The recorder can function for up to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months from internal rechargeable batteries, which are constantly recharged from 120 VAC Instrument Power.

Panel Q-R-113also contains the computer, LCD display, and printer used to calculate and display the spectral content of the event, and the alarm panel used to annunciate in the control room.

These devices are also powered by 120VAC Instrument Power, but have no backup battery power.

Power to these devices may be manually restored in the unlikely event of loss of AC power.

SEQUOYAH -

UNITS 1 AND 2 B 3/4 3-2 May 15, 2004 TECHNICAL REQUIREMENTS Revision Nos. 4, 6, 28

INSTRUMENTATION BASES APPLICABLE SAFETY ANALYSES The OPERABILITY of the seismic instrumentation ensures that sufficient capability is available to promptly determine the magnitude of a seismic event and to determine the impact on those features important to safety.

This capability is required to permit comparison of the measured response to that used in the design basis for the unit to determine if plant equipment inspection is required pursuant to Appendix A of 10 CFR part 100 prior to restart.

Seismic risks which appear as dominant sequences in PRAs occur for very severe earthquakes with magnitudes which are a factor of two or three above the Safe Shutdown Earthquake and Design Basis Earthquake.

The Seismic Instrumentation System was not designed to function or to provide comparative information for such severe earthquakes.

This instrumentation is more pertinent to determining the need to shut down following a seismic event and the ability to restart the plant after seismic events which are not risk contributors, and is therefore not of prime importance in risk dominant sequences (Ref. 2).

TR The seismic monitoring instrumentation shown in Table 3.3-7 shall be OPERABLE.

This requirement ensures that an assessment can be made of the effects on the plant of earthquakes which may occur that exceed the design basis spectra for the Operating Basis Earthquake (Ref. 4).

APPLICABILITY Since the possibility of earthquakes is not MODE dependent, OPERABILITY of the seismic instrumentation is required at all times.

ACTIONS The determination as to whether an OBE exceedance has occurred is made by comparing the calculated spectra for the event with the applicable design basis spectra for that building and location.

For Sequoyah, this determination is to be made considering the data from instruments located on the containment foundation.

Therefore, the exceedance determination for Sequoyah will be made using event data from 0-XT-52-75B in the containment annulus. Data from this instrument is recorded at panel O-R-113, which also contains the computer used to calculate the spectral content and the alarm panel used to annunciate in the control room.

These devices are the key components used to detect the event and make a shutdown determination.

(a)

With accelerometer 0-XT-52-75B or panel 0-R-113 inoperable for more than 30 days, a non-conformance report is required to be initiated in accordance with the Corrective Action Program.

SEQUOYAH - UNITS M AND 2 TECHNICAL REQUIREMENTS B 3/4 3-3 May 15, 2004 Revision Nos. 6, 28

INSTRUMENTATION BASES ACTIONS (b)

(Continued)

With one or more of the remaining seismic instruments in Table 3.3-7 inoperable for more than 60 days, a non-conformance report is required to be initiated in accordance with the Corrective Action Program. A longer period of inoperability is allowed for these instruments since they are used only for evaluating plant condition following an event and not for input to the shutdown decision.

(c)

When one or more seismic monitoring instruments actuate during a seismic event with greater than or equal to 0.01g ground acceleration, the data retrieved from the actuated instruments must be analyzed to determine the magnitude of the vibratory ground motion.

The replacement digital instrumentation provides the capability to analyze the event data onsite and generate event spectra to be used in determining whether an 1/2 SSE exceedance has occurred. References 2 and 5 direct that this evaluation should occur within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the event. Reference 5 also requires performance of a limited scope walkdown to determine the extent of actual damage within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months following the event.

The information provided by this walkdown and the spectral analysis are to be used in making a determination as to whether to proceed with plant shutdown, if a shutdown has not already occurred.

Each actuated monitoring instrument must be restored to OPERABLE status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Within 10 days of the actuation, a CHANNEL CALIBRATION must be performed on each actuated monitoring instrument.

The completion time of 10 days to perform CHANNEL CALIBRATION is reasonable and is based on engineering judgment.

Subsequent analysis must then be performed using data from the remaining seismic monitoring instruments to evaluate the plant response in comparison with previously generated design basis spectra at the locations of those instruments.

(d)

The provisions of Technical Requirement 3.0.3 do not apply to the seismic instrumentation.

SEQUOYAH -

UNITS 1 AND 2 B 3/4 3-4 May 27, 2005 TECHNICAL REQUIREMENTS Revision Nos. 6, 28, 32

INSTRUMENTATION BASES SURVEILLANCE TR 4.3.3.3.1 REQUIREMENTS TR 4.3.3.3.1 requires performance of surveillance instructions at the frequency shown in Table 4.3-4.

A CHANNEL CHECK on seismic instrumentation once every 31 days ensues that a gross failure of instrumentation has not occurred.

A CHANNEL CHECK is a comparison of the parameter indicated on one channel to a similar parameter on other channels.

It is based on the assumption that instrument channels monitoring the same parameter should read approximately the same value.

Significant deviations between the instrument channels could be an indication of excessive instrument drift in one of the channels or of even something more serious.

CHANNEL CHECK will detect gross channel failure; thus, it.is key to verifying that the instrumentation continues to operate properly between each CHANNEL CALIBRATION.

The surveillance frequency of 31 days is based on operating experience related to channel OPERABILITY and drift, which demonstrates that failure of more than one channel of a given function in any 31 day interval is a rare event.

A CHANNEL FUNCTIONAL TEST is to be performed on each required channel to ensure the entire channel will perform the intended function. A CHANNEL FUNCTIONAL TEST is the comparison of the response of the instrumentation, including all components of the instrument except the sensor, to a known signal.

The surveillance frequency of 184 days is based upon the known reliability of the monitoring instrumentation and has been shown to be acceptable through operating experience.

A CHANNEL CALIBRATION is a complete check of the instrument loop and the sensor by comparing the response of the instrument to a known input on the sensor.

This test verifies the capability of the seismic instrumentation to correctly determine the magnitude of a seismic event and evaluate the response of those features important to safety.

The surveillance frequency of 18 months is based upon operating experience and consistency with the typical industry refueling cycle.

SEQUOYAH -

UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 3-5 May 15, 2004 Revision Nos. 6, 28

INSTRUMENTATION BASES REFERENCES

1. Regulatory Guide 1.12, "Instrumentation for Earthquakes,"

Revision 1, April 1974.

2. EPRI NP-5930, July 1988, "A Criterion For Determining Exceedance Of The Operating Basis Earthquake"

3. EPRI TR-104239, June 1994, "Seismic Instrumentation In Nuclear Power Plants For Response To OBE Exceedance:

Guideline For Implementation"

4. Sequoyah FSAR, Sections 2.5 and 3.7.1

5. EPRI NP-6695, December 1989, "Guidelines for Nuclear Plant Response to an Earthquake"

6. 10 CFR 100, Appendix A SEQUOYAH -

UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 3-6 May 15, 2004 Revision Nos. 6, 28

Plant Calorimetric Measurement B 3/4.3.3.15 BASES APPLICABILITY The requirement to use the LEFM Check for the performance of the secondary plant calorimetric measurement required by TS SR 4.3.1.1.1 for Power Range Neutron Flux Channel calibration by heat balance comparison is applicable to the unit in Mode 1 and above 15% RTP, consistent with the applicability of TS SR 4.3.1.1.1.

The greater than 15% RTP level threshold is chosen to ensure that the LEFM is within its specified operating range.

ACTIONS Action a.

If the LEFM becomes unavailable during the intervals between performance of TS SR 4.3.1.1.1 for Power Range Neutron Flux Channel calibration by heat balance comparison plant operation may continue using the power indications from the NIS system.

However, in order to remain in compliance with the bases for operation at a RATED THERMAL POWER of 3455 MWt, the LEFM must be returned to service prior to performance of TS SR 4.3.1.1.1 for Power Range Neutron Flux Channel calibration by heat balance comparison.

Action b.

If the Required Action or Completion Time of Action a. is not met (i.e.,, the LEFM has not been returned to service prior to the next performance of TS SR 4.3.1.1.1 for Power Range Neutron Flux Channel calibration by heat balance comparison),

Action b. is entered.

Action b. requires that the reactor power be reduced to, or maintained at, a power level less than or equal to *98.7% RTP (3411 MWt).

This power reduction is performed prior to TS SR 4.3.1.1.1 for Power Range Neutron Flux Channel calibration by heat balance comparison in order to remain within the plant's design bases immediately upon performance of the TS SR.

Action b. also directs the performance of TS SR 4.3.1.1.1 for Power Range Neutron Flux Channel calibration by heat balance comparison using acceptable alternate methods. At lower power levels this could include the use of RCS delta temperature indications.

At higher power levels the feedwater venturi indications for feedwater flow are used to perform the calorimetric comparison.

Once the TS SR 4.3.1.1.1 is performed using the feedwater venturi indications of feedwater flow, the required power uncertainty is 2% RTP.

In order to maintain compliance with the safety analyses, it is necessary to operate the plant at a maximum core thermal power of 3411 MWt.

Action b. also directs that the core power is to be maintained at a value less than or equal to 3411 MWt until the LEFM is returned to service and TS SR 4.3.1.1.1 for Power Range Neutron Flux Channel calibration by heat balance comparison, has been performed using the LEFM indication of feedwater flow.

Once the TS SR 4.3.1.1.1 has been performed using the LEFM, then the plant can again be operated at 3455 MWt.

SEQUOYAH -

UNITS 1 AND 2 B 3/4 3-11 May 27, 2005 TECHNICAL REQUIREMENTS Revision Nos. 17, 32

Plant Calorimetric Measurement B 3/4.3.3.15 BASES I

SURVEILLANCE REQUIREMENTS TR 4.3.3.15.1 requires that the availability of the LEFM be verified prior to it's use for the performance of TS SR 4.3.1.1.1 for Power Range Neutron Flux Channel calibration by heat balance comparison.

The self diagnostics features of the LEFM Check is used for this surveillance along with feedwater temperature indications.

If the LEFM Normal/Fail status indication is not in Fail status, it is considered operable provided feedwater temperature is greater than or equal to 250 degrees F. The LEFM status indication is displayed on the plant computer system and also may be verified on the local touch screen monitor.

REFERENCES

1.

License Amendment Request TVA-SQN-TS-01-08, increases the licensed power for operation of SQN Units 1 & 2 to 3455 Mt, Docket No. 50-327/50-328.

SEQUOYAH -

UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 3-12 May 27, 2005 Revision Nos. 17, 32

TRB 3/4.4 REACTOR COOLANT SYSTEMS BASES REACTOR COOLANT SYSTEM TRB 314.4.1 No current discussions TRB. 314.4.2 No current discussions TRB 3/4.4.3 No current discussions TRB 314.4.4 No current discussions TRB 3/4.4.5 No current discussions TRB 3/4.4.6 No current discussions TRB 3/4.4.7 No current discussions TRB 3/4.4.8 No current discussions TRB 314.4.9.1 No current discussions SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 4-1 October 30, 2004 Revision Nos. 30

Pressurizer Temperature Limits B 3.4.9.2 TR B 3.4 REACTOR COOLANT SYSTEM (RCS)

TR B 3.4.9.2 Pressurizer Temperature Limits BASES BACKGROUND The pressurizer is an ASME Section 1I1, vertical vessel with hemispherical top and bottom heads constructed of carbon steel.

The vessel is clad with austenitic stainless steel on all surfaces exposed to the reactor coolant. A stainless steel liner or tube may be used in lieu of cladding in some nozzles. The surge line nozzle and removable electric heaters are installed in the bottom head.

Spray line nozzles, relief and safety valves are located in the top head of the vessel. A small continuous spray is provided through a manual bypass valve around the power-operated spray valves.

The temperature, and hence the pressure are controlled by varying the power input to selected heater elements. The pressurizer is designed to withstand the effects of cyclic loads due to pressure and temperature changes. These loads are introduced by startup and shutdown operations, power transients and reactor trips.

During startup and shutdown, the rate of temperature change is controlled by the operator. Heatup rate is controlled by the input to the heater elements, and cooldown is controlled by spray. When the pressurizer is filled with water, i.e., during initial system heatup, and near the end of the second phase of plant cooldown, Reactor Coolant System (RCS) pressure is maintained by the letdown flow rate via the Residual Heat Removal System.

These Bases address the control of the rate of change of temperature and the effect of the thermal cycling on critical areas of the pressure boundary of the pressurizer. The Reactor Coolant Pressure Boundary, which includes the pressurizer, is defined in 10 CFR 50, section 50.2 (Ref.1). General rules for design and fabrication are provided in 10 CFR 50, section 50.55a (Ref. 2).

These design and fabrication rules are based on the ASME Boiler and Pressure Vessel Code.

APPLICABLE SAFETY ANALYSES The limits on the rate of change of temperature for the heatup and cooldown of the pressurizer and the temperature differential associated with pressurizer spray are not derived from Design Basis Accident analyses (Ref. 3). The limits are prescribed during normal operation to limit the cyclic, thermal loading on critical areas in the pressure boundary. The temperature limits have been established, using approved methodology, to preclude operation in an unanalyzed condition (Ref. 5).

SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS April 22, 2005 Revision Nos. 30, 31 B 3/4 4-2

Pressurizer Temperature Limits B 3.4.9.2 BASES LCO TR 3.4.9.2 specifies the acceptable rates of heatup and cooldown of the pressurizer and a maximum differential temperature allowed across the pressurizer spray nozzle. These limits define allowable operating regions and permit a large number of operating cycles while providing a wide margin to cyclic induced failure in the pressure boundary of the pressurizer.

APPLICABILITY The pressurizer temperature limits provide a definition of acceptable operation to limit cyclic temperature loading to analyzed conditions.

Although these limits were developed to provide rules for operation during heatup and cooldown (MODES 3, 4, and 5), they are applicable at all times.

ACTION If the rate of change of temperature or temperature differential is outside the limits, the out-of-limit condition must be restored to within limits in 30 minutes. The 30-minute Action Time reflects the urgency of restoring the parameters to within the analyzed range.

Most violations will not be severe, and the corrective actions can be accomplished in this time in a controlled manner. In addition to restoring operation to within limits, an evaluation is required to determine if operation may continue. This may require event-specific stress analyses or inspections. A favorable evaluation must be completed before continuing operation.

A Note is provided to clarify that the entire Action must be completed whenever the Action is entered. The Note emphasizes the need to perform the evaluation of the effects of the excursion outside the allowable limits. Restoration to within limits is insufficient without the evaluation of the structural integrity of the pressure boundary of the pressurizer.

SEQUOYAH-UNITS 1 AND 2 TECHNICAL REQUIREMENTS April 22, 2005 Revision Nos. 30, 31 B 3/4 4-3

Pressurizer Temperature Limits B 3.4.9.2 BASES ACTION (continued)

If the pressurizer terkpetature iimits are not restored within 30 minutes, the plant must be placed in a lower MODE and the pressure reduced. This will allow a more careful examination of the event. The 6-hour Action Time is reasonable, considering operating experience, to reach MODE 3 from full power. The additional 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months to reduce the pressure to 500 psig in an orderly manner also considers operating experience. This reduction in pressure is possible without challenging the plant systems or violating any operating limits.

SURVEILLANCE REQUIREMENTS TR 4.4.9.2.1 TR 4.4.9.2.1 verifies that the rate of heatup and the rate of cooldown are within limits. "Step wise" cooling must be avoided as discussed in Reference 4. The 30-minute Frequency is considered reasonable in view of the instrumentation available in the control room to monitor the status of the RCS.

TR 4.4.9.2.2 TR 4.4.9.2.2 verifies that any spray operation with a differential temperature greater than 3200F be recorded for evaluation of the cyclic limits provided in TS Table 5.7.1. The number of high temperature differential spray actuations must be maintained within the cyclic or transient limits provided in TS Table 5.7.1.

REFERENCES

1. 10 CFR 50.2, "Definitions."

2.

10 CFR 50.55a, "Codes and Standards."

3.

WCAP-11618, "MERITS Program-Phase II, Task 5, Criteria Application,"

including Addendum I dated April, 1989.

4. Westinghouse letter TVA-90-1130, "Reactor Coolant System Accelerated Cooldown," dated November 5, 1990.

5.

Westinghouse Equipment Specification 677234, Revision No. 4, dated January 10 1975.

SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS April 22, 2005 Revision Nos. 30, 31 B 314.4-4

TRB 3/4.6.5 CONTAINMENT SYStEMS BASES TRB 3/4 6.1 No current discussions TRB 3/4 6.2 No current discussions TRB 3/4 6.3 No current discussions I

SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 6-1 October 13, 2004 Revision Nos. 20, 29

TRB 3/4.6.5 CONTAINMENT SYSTEMS BASES TRB 3/4.6.4.1 HYDROGEN MONITORS The OPERABILITY of the equipment and systems required for the detection of hydrogen gas ensures that this equipment will be available to monitor the hydrogen concentration within containment during significant beyond design-basis accident conditions. The hydrogen monitors of TR 3.6.4.1 are part of the accident monitoring instrumentation required by 10 CFR 50.44, 'Standards for Combustible Gas Control System in Light-Water-Cooled Power Reactors," October 16, 2003.

SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 6-2 October 13, 2004 Revision Nos. 20, 29

TRB 3/4.6.5 CONTAINMENT SYSTEMS BASES TRB 3/4 6.5.1 No current discussions SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 6-3 October 13, 2004 Revision Nos. 20

CONTAINMENT SYSTEMS BASES TRB 3/4.6.5.2 ICE BED TEMPERATURE MONITORING SYSTEM The OPERABILITY of the ice bed temperature monitoring system ensures that the capability is available for monitoring the ice temperature. In the event the monitoring system is inoperable, the ACTION requirements provide assurance that the ice bed heat removal capacity will be retained within the specified time limits.

SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 6-4 October 13, 2004 Revision Nos. 20

TRB 3/4.6.5 CONTAINMENT SYSTEMS BASES TRB 3/4 6.5.3 No current discussions SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 6-5 October 11, 2002 Revision Nos. 20

CONTAINMENT SYSTEMS BASES TRB 3/4.6.5.4 INLET DOOR POSITION MONITORING SYSTEM The OPERABILITY of the inlet door position monitoring system ensures that the capability is available for monitoring the individual inlet door position. In the event the monitoring system is inoperable, the ACTION requirements provide assurance that the ice bed heat removal capacity will be retained within the specified time limits.

SEQUOYAH - UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 6-6 October 11, 2002 Revision Nos. 20

HVAC Maintenance Rule Equipment TRB 3/4.7.14 BASES (continued)

ACTIONS With any of the equipment listed in Table 3.7.14-1 inoperable, the corresponding TRM for that Unit and Train of equipment shall be entered into the Operation narrative logs and LCO tracking logs for tracking the unavailability time.

SURVEILLANCE This TRM is for tracking purposes only. There are no REQUIREMENTS Surveillance Requirements associated with this TRM.

REFERENCES

1.

SPP-6.6, "Maintenance Rule Performance Indicator Monitoring Trending and Reporting -

10 CFR 50.65."

2.

0-TI-SXX-000-004.0, Maintenance Rule Performance Indicator Monitoring Trending and Reporting -

10 CFR 50.65." Attachment 5, "Heating, Ventilation and Air Conditioning -

System 30."

3.

SQN-DC-V-21.0, "Sequoyah Nuclear Plant -

Environmental Design Criteria."

SEQUOYAH -

UNITS 1 AND 2 TECHNICAL REQUIREMENTS B 3/4 7-8 May 27, 2005 Revision Nos. 12, 22, 32

SAFETY LIMITS BASES Steam Generator Water Level calculations. This results in the requirement that the operator adjust the affected Steam Generator Water Level - Low-Low (EAM) trip setpoints to the same value as the Steam Generator Water Level -

Low-Low (Adverse) trip setpoints. Failure of the RCS loop AT channel input (failure of more than one TH RTD or failure of a Tc RTD) does not affect the TTD calculation for a protection set. This results in the requirement that the operator adjust the threshold power level for zero seconds time delay from 50%

RTP to 0% RTP, through the MMI.

The High Containment Pressure ESF trip that generates a safety injection signal and subsequent l reactor trip protects the reactor from loss of heat sink in the event of a sustained steam/feedwater flow mismatch resulting from a feedwater system pipe break inside of containment. IEEE 279 requirements are satisfied by 2/3 logic for protection function actuation, thus allowing for a single failure of a channel and still performing the protection function.

Undervoltage and Underfrequency - Reactor Coolant Pump Busses The Undervoltage and Underfrequency Reactor Coolant Pump bus trips provide reactor core protection against DNB as a result of loss of voltage or under-frequency to more than one reactor coolant pump. The specified set points assure a reactor trip signal is generated before the low flow trip set point is reached. Time delays are incorporated in the underfrequency and undervoltage trips to prevent spurious reactor trips from momentary electrical power transients. For undervoltage, the delay is set so that the time required for a signal to reach the reactor trip breakers following the simultaneous trip of two or more reactor coolant pump bus circuit breakers shall not exceed 1.2 seconds. For underfrequency, the delay is set so that the time required for a signal to reach the reactor trip breakers after the underfrequency trip set point is reached shall not exceed 0.6 seconds.

February 25, 2005 SEQUOYAH - UNIT 1 B 2-6a Amendment No. 141

LTOP System B 3/4.4.12 BASES SURVEILLANCE REQUIREMENTS (continued)

The block valve is a remotely controlled, motor operated valve. The power to the valve operator is not required removed, and the manual operator is not required locked in the inactive position. Thus, the block valve can be closed in the event the PORV develops excessive leakage or does not close (sticks open) after relieving an overpressure situation.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months frequency is considered adequate in view of other administrative controls available to the operator in the control room, such as valve position indication, that verify that the PORV block valve remains open.

4.4.12.2 and 4.4.12.3 To minimize the potential for a low temperature overpressure event by limiting the mass input capability, all safety injection pumps and all but one charging pump are verified incapable of injecting into the RCS and the accumulator discharge isolation valves are verified closed and locked out The safety injection pumps and charging pumps are rendered incapable of injecting into the RCS through removing the power from the pumps by racking the breakers out under administrative control. An alternate method of LTOP control may be employed using at least two independent means to prevent a pump start such that a single failure or single action will not result in an injection into the RCS. This may be accomplished through the pump control switch being placed in pull-to-lock and at least one valve in the discharge flow path being closed. Pump isolation may also be achieved via the following examples: closing pump discharge MOV(s) and de-energizing the motor operator(s) under administrative control, or locking closed and tagging manual valve(s) in the discharge flow path.

The frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient, considering other indications and alarms available to the operator In the control room, to verify the required status of the equipment.

4.4.12.4 The accumulator discharge isolation valves are verified closed and locked out at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to verify the required status of the equipment.

4.4.12.5 The RCS vent of 2 3.0 square inches is proven OPERABLE by verifying its open condition either:

a.

Once every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for a valve that is not locked. (valves that are sealed or secured in the open position are considered locked' in this context).

b.

Once every 31 days for other vent path(s) (e.g., a vent valve that is locked, sealed, or secured in position or a removed pressurizer safety valve or open manway also fits this category.

The passive vent path arrangement must only be open to be OPERABLE. This surveillance is required to be met if the vent is being used to satisfy the pressure relief requirements of the LCO 3.4.12.b.

April 11, 2005 SEQUOYAH UNIT I B 3/4 4-22 Amendment No. 116,133, 157, 208, 294, 297

CONTAINMENT SYSTEMS BASES 3/4.6.4 COMBUSTIBLE GAS CONTROL The hydrogen mixing systems are provided to ensure adequate mixing of the containment atmosphere following a LOCA. This mixing action will prevent localized accumulations of hydrogen from exceeding the flammable limit.

The operability of at least 66 of 68 ignitors in the hydrogen mitigation system will maintain an effective coverage throughout the containment. This system of ignitors will initiate combustion of any significant amount of hydrogen released after a degraded core accident. This system is to ensure burning in a controlled manner as the hydrogen is released instead of allowing it to be ignited at high concentrations by a random ignition source.

3/4.6.5 ICE CONDENSER The requirements associated with each of the components of the ice condenser ensure that the overall system will be available to provide sufficient pressure suppression capability to limit the containment peak pressure transient to less than 12 psig during LOCA conditions.

3/4.6.5.1 ICE BED The OPERABILITY of the ice bed ensures that the required ice inventory will 1) be distributed evenly through the containment bays, 2) contain sufficient boron to preclude dilution of the containment sump following the LOCA and 3) contain sufficient heat removal capability to condense the reactor system volume released during a LOCA. These conditions are consistent with the assumptions used in the accident analyses.

The minimum weight figure of 1145 pounds of ice per basket contains a 15% conservative allowance for ice loss through sublimation which is a factor of 15 higher than assumed for the ice condenser design. The minimum weight figure of 2,225,880 pounds of ice also contains an additional 1% conservative allowance to account for systematic error in weighing instruments. In the October 13, 2004 SEQUOYAH - UNIT 1 B 3/4 6-4 Amendment No. 4, 5, 131, 149, 224, 279

REFUELING OPERATIONS BASES 3/4.9.9 CONTAINMENT VENTILATION SYSTEM The OPERABILITY of this system ensures that the containment ventilation isolation penetrations will be automatically isolated upon detection of high radiation levels during containment purging operations. The OPERABILITY of this system is required to restrict the release of radioactive material from the containment atmosphere to the environment.

3/4.9.10 and 3/4.9.11 WATER LEVEL - REACTOR VESSEL AND SPENT FUEL PIT The restrictions on minimum water level ensure that sufficient water depth is available to remove 99% of the assumed 10% iodine gap activity released from the rupture of an irradiated fuel assembly.

The minimum water depth is consistent with the assumptions of the accident analysis.

3/4.9.12 AUXILIARY BUILDING GAS TREATMENT SYSTEM The limitations on the auxiliary building gas treatment system ensure that all radioactive material released from an irradiated fuel assembly will be filtered through the HEPA filters and charcoal adsorber prior to discharge to the atmosphere. Cumulative operation of the system with the heater on for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months over a 31 day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters.

The OPERABILITY of this system and the resulting iodine removal capacity are consistent with the assumptions of the accident analyses. ANSI N510-1975 will be used as a procedural guide for surveillance testing.

Movement of a cask with fuel assemblies is outside the scope of Technical Specification 3/4.9.12. The ABGTS is designed to mitigate the dropping of a single fuel assembly addressed in FSAR 15.5.6. Movement of a cask from the pool must comply with the requirements of the 10 CFR 72 Regulation.

April 19, 2004 SEQUOYAH - UNIT 1 B 3/4 9-3 Amendment No. 134,168

LIMITING SAFETY SYSTEM SETTINGS BASES Steam Generator Water Level (Cont'd) primary side power level, up to 50 percent RTP. Above 50 percent RTP there are no time delays for the Low-Low level trips.

In the event of failure of a Steam Generator Water Level channel, it is placed in the trip condition as input to the Solid State Protection System and does not affect either the EAM or TTD setpoint calculations for the remaining operable channels. It is then necessary for the operator to force the use of the shorter TTD time delay by adjustment of the single steam generator time delay calculation (Ts) to match the multiple steam generator time delay calculation (TM) for the affected protection set, through the MMI. Failure of the Containment Pressure (EAM) channel to a protection set also does not affect the EAM setpoint calculations. This results in the requirement that the operator adjust the affected Steam Generator Water Level - Low-Low (EAM) trip setpoints to the same value as the Steam Generator Water Level - Low-Low (Adverse). Failure of the RCS loop AT channel input (failure of more than one TH RTD or failure of a Tc RTD) does not affect the TTD calculation for a protection set. This results in the requirement that the operator adjust the threshold power level for zero seconds time delay from 50 percent RTP to 0 percent RTP, through the MMI.

The High Containment Pressure ESF trip that generates a safety injection signal and subsequent reactor trip protects the reactor from loss of heat sink in the event of a sustained steam/feedwater flow mismatch resulting from a feedwater system pipe break inside of containment. IEEE 279 requirements are satisfied by 2/3 logic for protection function actuation, thus allowing for a single failure of a channel and still performing the protection function.

Undervoltane and Underfrequencv - Reactor Coolant Pump Busses The Undervoltage and Underfrequency Reactor Coolant Pump bus trips provide reactor core protection against DNB as a result of loss of voltage or underfrequency to more than one reactor coolant pump.

The specified setpoints assure a reactor trip signal is generated before the low flow trip setpoint is reached. Time delays are incorporated in the underfrequency and undervoltage trips to prevent spurious reactor trips from momentary electrical power transients. For undervoltage, the delay is set so that the time required for a signal to reach the reactor trip breakers following the simultaneous trip of two or more reactor coolant pump bus circuit breakers shall not exceed 1.2 seconds. For underfrequency, the delay is set so that the time required for a signal to reach the reactor trip breakers after the underfrequency trip setpoint is reached shall not exceed 0.6 seconds.

Turbine Trip A Turbine Trip causes a direct reactor trip when operating above P-9. Each of the turbine trips provide turbine protection and reduce the severity of the ensuing transient. No credit was taken in the accident analyses for operation of these trips. Their functional capability at the specified trip settings is required to enhance the overall reliability of the Reactor Protection System.

February 25, 2005 SEQUOYAH - UNIT 2 B 2-7 Amendment No. 132

LTOP System B 3/4.4.12 BASES SURVEILLANCE REQUIREMENTS (continued)

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months frequency is considered adequate in view of other administrative controls available to the operator in the control room, such as valve position indication, that verify that the PORV block valve remains open.

4.4.12.2 and 4.4.12.3 To minimize the potential for a low temperature overpressure event by limiting the mass input capability, all safety injection pumps and all but one charging pump are verified incapable of injecting into the RCS and the accumulator discharge isolation valves are verified closed and locked out The safety injection pumps and charging pumps are rendered incapable of injecting into the RCS through removing the power from the pumps by racking the breakers out under administrative control. An alternate method of LTOP control may be employed using at least two independent means to prevent a pump start such that a single failure or single action will not result in an injection into the RCS. This may be accomplished through the pump control switch being placed in pull-to-lock and at least one valve in the discharge flow path being closed. Pump isolation may also be achieved via the following examples: closing pump discharge MOV(s) and de-energizing the motor operator(s) under administrative control, or locking closed and tagging manual valve(s) in the discharge flow path.

The frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient, considering other indications and alarms available to the operator in the control room, to verify the required status of the equipment.

4.4.12.4 The accumulator discharge isolation valves are verified closed and locked out at least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The frequency of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months is sufficient considering other indications and alarms available to the operator in the control room to verify the required status of the equipment.

4.4.12.5 The RCS vent of 2 3.0 square inches is proven OPERABLE by verifying its open condition either:

a.

Once everyl2 hours for a valve that is not locked. (valves that are sealed or secured in the open position are considered 'locked' in this context).

b.

Once every 31 days for other vent path(s) (e.g., a vent valve that is locked, sealed, or secured in position or a removed pressurizer safety valve or open manway also fits this category.

The passive vent path arrangement must only be open to be OPERABLE. This surveillance is required to be met if the vent is being used to satisfy the pressure relief requirements of the LCO 3.4.12.b.

March 4, 2005 SEQUOYAH UNIT 2 B 3/4 4-23 Amendment No. 106,120,147, 284

CONTAINMENT SYSTEMS BASES 314.6.4 COMBUSTIBLE GAS CONTROL The hydrogen mixing systems are provided to ensure adequate mixing of the containment atmosphere following a LOCA. This mixing action will prevent localized accumulations of hydrogen from exceeding the flammable limit.

The operability of at least 66 of 68 igniters in the hydrogen control distributed ignition system will maintain an effective coverage throughout the containment. This system of ignitors will initiate combustion of any significant amount of hydrogen released after a degraded core accident. This system is to ensure burning in a controlled manner as the hydrogen is released instead of allowing it to be ignited at high concentrations by a random ignition source.

3/4.6.5 ICE CONDENSER The requirements associated with each of the components of the ice condenser ensure that the overall system will be available to provide sufficient pressure suppression capability to limit the containment peak pressure transient to less than 12 psig during LOCA conditions.

314.6.5.1 ICE BED The OPERABILITY of the ice bed ensures that the required ice inventory will 1) be distributed evenly through the containment bays, 2) contain sufficient boron to preclude dilution of the containment sump following the LOCA and 3) contain sufficient heat removal capability to condense the reactor system volume released during a LOCA. These conditions are consistent with the assumptions used in the accident analyses.

The minimum weight figure of 1145 pounds of ice per basket contains a 15% conservative allowance for ice loss through sublimation which is a factor of 15 higher than assumed for the ice condenser design. The minimum weight figure of 2,225,880 pounds of ice also contains an additional 1 % conservative allowance to account for systematic error in weighing instruments. In the October 13, 2004 SEQUOYAH - UNIT 2 B 3/4 6-4 Amendment No. 21, 118, 135, 215, 270

REFUELING OPERATIONS BASES 3/4.9.9 CONTAINMENT VENTILATION SYSTEM The OPERABILITY of this system ensures that the containment ventilation isolation penetrations will be automatically isolated upon detection of high radiation levels during containment purging operations. The OPERABILITY of this system is required to restrict the release of radioactive material from the containment atmosphere to the environment.

3/4.9.10 and 3/4.9.11 WATER LEVEL - REACTOR VESSEL AND SPENT FUEL PIT The restrictions on minimum water level ensure that sufficient water depth is available to remove 99% of the assumed 10% iodine gap activity released from the rupture of an irradiated fuel assembly.

The minimum water depth is consistent with the assumptions of the accident analysis.

3/4.9.12 AUXLIARY BUILDING GAS TREATMENT SYSTEM The limitations on the auxiliary building gas treatment system ensure that all radioactive material released from an irradiated fuel assembly will be filtered through the HEPA filters and charcoal adsorber prior to discharge to the atmosphere. Cumulative operation of the system with the heater on for 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months over a 31 day period is sufficient to reduce the buildup of moisture on the adsorbers and HEPA filters.

The OPERABILITY of this system and the resulting iodine removal capacity are consistent with the assumptions of the accident analyses. ANSI N510-1975 will be used as a procedural guide for surveillance testing.

Movement of a cask with fuel assemblies is outside the scope of Technical Specification 3/4.9.12. The ABGTS is designed to mitigate the dropping of a single fuel assembly addressed in FSAR 15.5.6. Movement of a cask from the pool must comply with the requirements of the 10 CFR 72 Regulation.

April 19, 2004 SEQUOYAH - UNIT 2 B 3/4 9-3 Amendment Nos. 121, 158

ML053250350

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