ML061100408

Technical Specification Change 05-11, Revision to TS to Support Third 10-Year Interval Inservice Test Program, Rev 1

ML061100408
Person / Time
Site:	Sequoyah
Issue date:	03/30/2006
From:	Pace P Tennessee Valley Authority
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TVA-SQN-TS-05-11, Rev 1
Download: ML061100408 (9)

Text

I ennessee Valley Authority, Post Office Box 2000, Soddy-Daisy, Tennessee 37384-2000 March 30, 2006

'rVA-SQN-TS-05-11, Ri 10 CFR 50.90

'J.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SIEQUOYAH NUCLEAR PLANT (SQN) - UNITS 1 AND 2 - TECHNICAL SPECIFICATIONS (TS) CHANGE 05-11, "REVISION TO TECHNICAL SPECIFICATION TO SUPPORT THIRD 10-YEAR INTERVAL INSERVICE TEST (IST) PROGRAM," REVISION 1

Reference:

TVA letter to NRC dated December 19, 2005, "Sequoyah Nuclear Plant (SQN) - Units 1 And 2 -

Technical Specifications (TS) Change 05-11,

'Revision To Technical Specification To Support Third 10-Year Interval Inservice Test (IST)

Program'"

PDursuant to 10 CFR 50.90, Tennessee Valley Authority (TVA) is submitting two revised TS pages to supersede the pages previously provided in the referenced letter for SQN TS Change 05-11. The revision is necessary to address NRC concerns regarding Technical Specification Task Force (TSTF) 479, "Changes to Reflect Revision of 10 CFR 50.55a" and the application of the 25 percent extension to test frequencies greater than two years.

The Regulatory Safety Analysis, including the no significant hazard determination, and Environmental Considerations provided in the referenced letter are not affected by this

cevision; therefore, they are not included in this Submittal.

li~M Udo 147

U.S. Nuclear Regulatory Commission Page 2 March 30, 2006 In accordance with 10 CFR 50.91(b)(1), TVA is sending a copy of this letter and enclosures to the Tennessee State Department of Public Health.

TVA continues to request approval of this TS change to support the June 1, 2006 start date of SQN's third 10-year IST program interval.

There are no commitments contained in this submittal.

If you have any questions about this change, please contact me at 843-7170 or Jim Smith at 843-6672.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this v day of 41 tek Sincerely, P. L. Pace Manager, Site Licensing and Industry Affairs

Enclosures:

1. TVA Evaluation of the Proposed Changes

2. Proposed Technical Specifications Change (mark-up) cc: See page 3

U.S. Nuclear Regulatory Commission Page 3 March 30, 2006 Enclosures cc (Enclosures):

Framatome ANP, Inc.

P. 0. Box 10935 Lynchburg, Virginia 24506-0935 ATTN: Mr. Frank Masseth Mr. Donald L. Gillispie Grace Glens Farm 3440 Union Church Road Thaxton, Virginia 24174 Mr. Edgar D. Hux 94 Ridgetree Lane Marietta, Georgia 30068 Mr. Lawrence E. Nanney, Director Division of Radiological Health Third Floor L&C Annex 401 Church Street Nashville, Tennessee 37243-1532 Mr. Douglas V. Pickett, Senior Project Manager U.S. Nuclear Regulatory Commission Mail Stop 08G-9a One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2739 Mr. William T. Russell 400 Plantation Lane Stevensville, Maryland 21666

ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY (TVA)

SEQUOYAH NUCLEAR PLANT (SQN)

UNITS 1 AND 2

1.0 DESCRIPTION

This letter provides a revision to SQN Technical Specification (TS) Change 05-11 as originally submitted to NRC by TVA letter dated December 19, 2005. The original TS change contained a proposed change to SQN's inservice test (IST) program Surveillance Requirement (SR) 4.0.5.c that is based on Technical Specification Task Force (TSTF) 479, Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a."

One of the provisions in TSTF-479 provided a correction to the improved standard TS (NUREG-1431, Revision 3.1) regarding test frequencies in the IST program. The TSTF recognizes there may be non-standard test frequencies utilized in the IST program and applies the provisions of frequency extensions (i.e., SR 3.0.2) to IST program test frequencies.

SQN TS Change 05-11 proposed a change to SR 4.0.5.c to adopt these TSTF provisions. NRC staff has expressed concern about applying frequency extensions to test frequencies in the IST program that are greater than two years. NRC staff has requested a change to TSTF-479 to revise the provision for applying SR 3.0.2 to IST test frequencies. The staff's requested revision to the TSTF will specify frequencies two years or less in the IST program. Based on the staff's position and the proposed revision to TSTF-479, TVA is submitting revised TS pages for both units to specify frequencies two years or less in the IST program. The revised TS pages supersede the pages previously provided by TVA's December 19, 2005 letter.

2.0 PROPOSED CHANGE

TVA's proposed revision to TS Change 05-11 provides new language for SR 4.0.5.c. TVA's originally proposed SR 4.0.5.c and the proposed revision to SR 4.0.5.c are provided below:

TVA's originally proposed 4.0.5.c reads:

c. "The provisions of SR 4.0.2 are applicable to the above required Frequencies and other normal and accelerated frequencies specified in the Inservice Testing Program for performing inservice testing activities."

The proposed revision to 4.0.5.c reads:

El-l

c. "The provisions of SR 4.0.2 are applicable to the above required Frequencies and other normal and accelerated frequencies specified as 2 years or less in the Inservice Testing Program for performing inservice testing activities."

In summary, TVA is submitting a revision to SQN TS Change 05-11 as previously provided by letter dated December 19, 2005. Two revised TS pages (one TS page for each unit) are provided and include a change in language that specifies test frequencies two years or less for application of SR 4.0.2.

This change in language will provide consistency with the NRC staff recommended changes to TSTF-479.

3.0 BACKGROUND

TSTF-479 is entitled "Changes to Reflect Revision of 10 CFR 50.55a." This TSTF was implemented into the improved standard TS in NUREG-1431, Revision 3;1, to provide consistency between the standard TS and the 10 CFR 50.55a(f)(4) for pumps and valves classified as American Society of Mechanical Engineers (ASME) Code Class 1, 2, and

3. By letter dated December 19, 2005, TVA submitted SQN TS Change 05-11 to adopt the provisions from TSTF-479 into the SQN TSs. A February 28, 2006 posting on the Excel website, indicates the industry and NRC have agreed to reconsider a change to TSTF-479 to address an NRC concern regarding the application of frequency extensions to the IST program. The proposed change to TSTF-479 will require SQN TS Change 05-1L be' modified to incorporate the proposed TSTF change.

Accordingly, TVA is submitting two revised TS pages to supersede TS pages previously provided by TS Change 05-11.

4.0 TECHNICAL ANALYSIS

By letter dated December 19, 2005, TVA submitted TS Change 05-11 for SQN to update the improved standard TS 4.0.5 to reflect changes in 10 CFR 50.55a. The need to update TSs to reflect changes to 10 CFR 50.55a is recognized by the Nuclear Industry in TSTF-479, Revision 0. TVA TS Change 05-11 is based on TSTF-479 and provides reference to ASME Code for SQN's IST program that are consistent with the code requirements referenced in 10 CFR 50.55a(f)(4).

One of the provisions in TSTF-479 provided a correction to the improved standard TS (NUREG-1431, Revision 3.1) regarding the IST program. A provision in the TSTF recognizes there may be non-standard test frequencies utilized in the IST program and applies the provisions of SR 3.0.2 to IST program E1-2

test frequencies for frequency extensions. SQN TS Change 05-11 proposed a change to SR 4.0.5.c to adopt these TSTF provisions. NRC staff has expressed concern about applying frequency extensions to test frequencies in the IST program that may be greater than two years. NRC staff has requested a change to TSTF-479 to revise the provision for applying SR 3.0.2 to IST test frequencies. The requested TSTF revision would specify frequencies two years or less in the IST program. Based on the staff's position regarding TSTF-479, TVA is submitting revised TS pages for both units to specify frequencies two years or less in the IST program..

The revised TS pages supersede the pages previously provided in TVA's December 19, 2005 letter.

5.0 REFERENCES

1. 10 CFR 50.55a(f), "Inservice testing requirements."

2. American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants, 2001 Edition through 2003 Addenda.

3.. Technical Specification Task Force TSTF 479, Revision 0, "Changes to Reflect Revision of 10 CFR 50.55a."

E1-3

ENCLOSURE 2 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)

UNITS 1 AND 2 Revised Technical Specification Pages I. AFFECTED PAGE LIST Unit 1 3/4 0-3 Unit 2 3/4 0-3 II. MARKED PAGES See attached.

E2 -1

V APPLICABILITY SURVEILLANCE REQUIREMENTS (Continued) 4.0.5 (Continued)

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

b. The provisions of SR 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 20-year intervals (the provisions of SR 4.0.2 are not applicable); and

d. Nothing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirement of any TS. _

Inservice Testing Program the ASME Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code) I This program provides controls for nservice testing of ASME Code Class 1, 2, and 3 components including applicable supports. The program shall include the following:

a. Provisions that inservice testi g of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance wit Gion XI of the ASME Boilor and Proesuro Voesol Codo and applicable Addenda as required by 10 CFR 50.55a; .

^ *.a. .

b. Testing Frequencies.cifeddXoction air ._ r ..

)Al of Me AWL boileor and lF-rocuro V8ool Code and applicable Addenda as folows I applicable to the ASME OM Code I ASAeoilor and Pro1curo V86'6'o 1 Code and applicable Addenda Required frequencies for terminoloav for inservice Derformina inservice testing activities testing activities and oth er normal and acc,elerated Weekly At least once per 7 days frequen icies Monthl) At least once per 31 days specifiEed as 2 Quarter ly or every 3 months At least once per 92 days years or less in the Semiar Irually or every 6 months At least once per 184 days Inservicce Testing Every 9I nonths At least once per 276 days Prograr n Yearly iOxannually At least once per 366 days BienniaIly or every 2 years At least once per 731 day

c. The provisions of SR 4.0.2 are applicable to the above required Frequencies or performing inservice testing activities;

d. The provisions of SR 4.0.3 are applicable to inservice testing and activities; and

e. Nothing in the ASME Bioilr and Proccuro VAssel Code shall be construed to supersede the requirements of any April 11, ;'005 SEQUOYAH - UNIT 1 3/4 0-3 Amendment No. 78, 162, 202, 208, 274, 280, 293 E2 -2

APPLICABILITY SURVEILLANCE REQUIREMENTS (Continued) 4.0.5 (Continued)

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

b. The provisions of SR 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 20-year intervals (the provisions of SR 4.0.2 are not applicable); and

d. No:hing in the ASME Boiler and Pressure Vessel Code shall be construed to supersede the requirement of any TS. I . _ _ _ ..

the ASME-Code for Operation and Maintenance of Nuclear Power Plants (ASME OM Code)

Inservice Testing Program I

This program provides controls for i service testing of ASME Code Class 1, 2, and 3 components including applicable supports. The ogram shall include the following:

a. Pmovisions that inservice testi g of ASME Code Class 1, 2, and 3 pumps and valves shall be performed in accordance with Section Xi of thR ASME Boilor and Procsure Vocsol Codo and applicable Addenda as required by 10 CFR 50.55a;

b. Testing frequencies pf i tionX of the ASME goilor and Pressuro-Vese! Code-and applicable Addenda as A Oapplicable to the ASME OM Code (MlbrBr-InoArrlln\

ILZJ 1A.DIVIEZ B r Code and applicable Addenda Required frequencies for terminology for inservice performing inservice testing activities testing activities and other rormal and accele ated Weekly At least once per 7 days frequencies MDnthly At least once per 31 days specified as 2 Quarterly or every 3 months At least once per 92 days years or less in Semiannually or every 6 months At least once per 184 days the Inservice Test Every 9 months At least once per 276 days Program Yearly or annually At least once per 366 days Bi9nnially or every 2 years At least once per 731 days

c. Th.e provisions of SR 4.0.2 are applicable to the above required Frequencies Or performing inservice testing activities;

d. TI-e provisions of SR 4.0.3 are applicable to inservice testing and activities; and

e. Nothing in the ASME Rl Code shall be construed to supersede the RirnPeu requirements of any TS.

April 1'1. 2005 SEQUOYAH - UNIT 2 3/4 0-3 Amendment No. 69, 152, 198, 263, 271, 283 E2-3