Text

Technical Specification Change No. 07-05, Emergency Core Cooling System (Eccs).
	ML091120193
Person / Time
Site:	Sequoyah
Issue date:	04/21/2009
From:	Cleary T; Tennessee Valley Authority
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	TVA-SQN-TS-07-05
	Download: ML091120193 (86)
	v • d • e

Tennessee Valley Authority Post Office Box 2000 Soddy Daisy, Tennessee 37384-2000 Timothy P. Cleary Site Vice President Sequoyah Nuclear Plant April 21, 2009 TVA-SQN-TS-07-05 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-001 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority (TVA) ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) - UNITS 1 AND 2 - TECHNICAL SPECIFICATION (TS) CHANGE NO. 07-05, "EMERGENCY CORE COOLING SYSTEM (ECCS)"

Pursuant to 10 CFR 50.90, Tennessee Valley Authority (TVA) is submitting a request for a TS change (TS Change 07-05) to Licenses DPR-77 and DPR-79 for SQN Units 1 and 2.

The proposed TS change upgrades ECCS requirements to be more consistent with the Improved Standard TS for Westinghouse plants contained in NUREG-1431, Revision 3.

The upgrade revises SQN TS Sections 3.5.2, "ECCS Subsystems - Tavg greater than or equal to 350°F," and 3.5.3, "ECCS Subsystems - Tavg less than 350°F." The proposed upgrade is considered by TVA to be a TS improvement for aligning SQN's requirements with standard industry requirements, TVA has determined that there are no significant hazards considerations associated with the proposed change and that the change is exempt from environmental review pursuant to the provisions of 10 CFR 51.22(c)(9). The SQN Plant Operations Review Committee and the SQN Nuclear Safety Review Board have reviewed this proposed change and determined that operation of SQN Units 1 and 2, in accordance with the proposed change, will not endanger the health and safety of the public. Additionally, in accordance with 10 CFR 50.91 (b)(1), TVA is sending a copy of this letter to the Tennessee State Department of Public Health.

printed on recycled paper

U.S. Nuclear Regulatory Commission Page 2 April 21, 2009 This is not a risk informed TS change request and no TVA commitments are associated with the proposed request. TVA requests approval of this TS change by the end of November 2009.

In addition to upgrading the ECCS specifications to be consistent with the Improved Standard TS content, this change will allow for resolution of a nonconforming condition.

TVA requests that the revised TS be made effective within 60 days of NRC approval.

If you have any questions about this change, please contact Beth A. Wetzel at (423) 843-7170.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 21st day of April 2009.

Sincerely, Timothy P. Cleary Site Vice President

Enclosure:

Evaluation of the Proposed Changes

U.S. Nuclear Regulatory Commission Page 3 April 21, 2009 Enclosure cc (Enclosure):

Mr. Tracy J. Orf, Senior Project Manager U.S. Nuclear Regulatory Commission Mail Stop 08G-9a One White Flint North 11555 Rockville Pike Rockville, Maryland 20852-2739 Mr. Lawrence E. Nanney, Director Division of Radiological Health Third Floor L&C Annex 401 Church Street Nashville, Tennessee 37243-1532

ENCLOSURE TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)

UNITS 1 AND 2 DOCKET NOS. 327 AND 328 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE 07-05 EVALUATION OF THE PROPOSED CHANGE 1.0.

SUMMARY

DESCRIPTION TVA is submitting a proposed revision to the SQN TSs for Units 1 and 2 to upgrade Specification 3/4 5.2, ECCS Subsystems - Tavg greater than or equal to 350F, and Specification 3/4 5.3, ECCS Subsystems - Tavg less than 350F, to the Improved Standard TSs (ISTS) for Westinghouse plants (NUREG-1431, Revision 3). The proposed conversion provides TS improvements to SQNs current TSs and updates the current requirements to be consistent with industry standard TS requirements.

Additionally, this proposed revision resolves a non-conforming condition associated with Surveillance Requirement (SR) 4.5.2.f. SR 4.5.2.f contains specific pump discharge pressure requirements for emergency core cooling system (ECCS) quarterly minimum flow recirculation testing. The discharge pressure values for the safety injection pumps and the centrifugal charging pumps are non-conservative to ensure that the performance of the ECCS pumps is consistent with the minimum performance credited by the plant safety analyses and ASME Section XI test criteria. Although compliance with SR 4.5.2.f is being met, surveillance testing of the ECCS pumps is being performed in accordance with ASME Section XI inservice inspection requirements, in accordance with TS 4.0.5. The in-service inspection program testing acceptance criteria are based on the more rigorous performance requirements assumed in the plant safety analyses. Compliance with the inservice testing criteria ensures that the safety analyses minimum performance requirements are met. The proposed change will resolve this non-conforming condition.

2.0. DETAILED DESCRIPTION TVAs proposed change updates SQNs current ECCS TS SR 3/4 5.2 and 3/4 5.3. The proposed change replaces the existing ECCS requirements with the ISTS requirements while retaining existing format and style of the SQN TSs. The proposed conversion includes administrative changes (i.e., title changes, editorial changes, and format changes),

relocation of existing TSs information (relocation of information to the TS Bases or other licensing basis documents), and incorporation of standard TS requirements. Each of the proposed changes is described below.

TVA has evaluated each change for determining significance and impact to SQNs existing design basis and licensing basis requirements. The revisions are categorized below and are described as being more restrictive, less restrictive, or neutral.

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The following provides a description of the changes associated with SQN TS 3.5.2.

1) Title Change for TS 3/4 5.2 TVAs proposed change replaces the current title (ECCS Subsystems - Tavg greater than or equal to 350F) with the standard title (ECCS - Operating). The proposed change is administrative in nature and is considered neutral because it does not affect existing ECCS requirements or other related specifications. In addition to the title changes for TS 3/4 5.2, associated TS index pages are revised to reflect the title change.

2) Limiting Condition for Operation (LCO)

SQN LCO 3.5.2 currently reads as follows:

3.5.2 Two independent ECCS subsystems shall be OPERABLE with each subsystem comprised of:

a. One OPERABLE centrifugal charging pump,

b. One OPERABLE safety injection pump,

c. One OPERABLE residual heat removal heat exchanger,

d. One OPERABLE residual heat removal pump, and

e. An OPERABLE flow path capable of taking suction from the refueling water storage tank on a safety injection signal and automatically transferring suction to the containment sump during the recirculation phase of operation.

TVAs proposed change replaces the current LCO with the standard LCO language that reads:

3.5.2 Two ECCS trains shall be OPERABLE.

TVAs proposed change replaces two independent subsystems with the standard language two ECCS trains. In addition, the plant components that are listed in SQNs LCO and comprise a subsystem are removed. The description of components is no longer part of the LCO but is relocated to the proposed ECCS TS Bases section. The components that make up a standard ECCS train are described in the LCO section of the standard TS Bases and comprise the same set of components that currently exist in SQNs LCO. TVAs proposed relocation of the ECCS components and the adoption of the standard language for these components remains consistent with the standard requirements. Accordingly, TVAs proposed change to the LCO provides the appropriate level of detail. Because TS Bases information is a licensee controlled document, the proposed change to the LCO is considered to be less restrictive.

The notes for LCO 3.5.2 are being revised to be consistent with NUREG-1431. Note 1 is being added to allow for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to perform pressure isolation valve testing per SR 4.4.6.3. This change is considered to be less restrictive. Note 2 adds the (350°F) low temperature overpressure protection (LTOP) arming temperature to the note to be consistent with standard ISTS language. This change is considered to be neutral.

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The notes are:

1. In MODE 3, both safety injection (SI) pump flow paths may be isolated by closing the isolation valves for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to perform pressure isolation valve testing per SR 4.4.6.3.

2. In MODE 3, ECCS pumps may be made incapable of injecting to support transition into or from the APPLICABILITY of LCO 3.4.12, Low Temperature Overpressure Protection (LTOP) System, for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or until the temperature of all RCS cold legs exceeds LTOP arming temperature (350°F) specified in the PTLR plus 25°F, whichever comes first.

3) Applicability The applicability of SQN TS 3.5.2 is equivalent to the ISTS and thus there is no proposed change in applicability.

4) Action The SQN TS action requirement currently reads as follows:

With one ECCS subsystem inoperable, restore the inoperable subsystem to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

TVAs proposed change replaces the above action with two actions that state:

a. With one or more trains inoperable, and with at least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available, restore the inoperable train(s) to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

b. With less than 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available, immediately enter LCO 3.0.3.

TVAs proposed change replaces SQNs current single action with two separate standard action requirements. In action a., language from SQNs current action (i.e.,

subsystem) is replaced with standard language (i.e., one or more trains). These changes to the standard requirements provide an improvement in the level of detail over SQNs current action requirement. The change to one or more trains expands the application of the action to include additional ECCS trains that may be determined to be inoperable. As ECCS trains involve diverse subsystems with multiple components, there may be different components, each in a different train that may be inoperable; however, the ECCS function is not lost. Consequently, when the ECCS function for a single OPERABLE ECCS train is available, an allowed outage time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is applied for restoring the inoperable ECCS train. It is this clarification that provides increased flexibility in plant operations when components in opposite trains (i.e., one or more trains) are rendered inoperable. In addition to these changes, action (a) provides for plant shutdown in the event a single OPERABLE ECCS train cannot be rendered operable within the allowed outage time. In the ISTS, to achieve plant shutdown, the plant must be brought to Mode 3 (Hot Standby) within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to Mode 4 (Hot Shutdown) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (i.e., the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months ). The standard E-3

shutdown time is equivalent to SQNs current shutdown time and is appropriate for the proposed action (a).

TVAs proposed change adds action (b) that provides measures for immediate entry into LCO 3.0.3 when less than 100 percent of the ECCS flow equivalent to a single OPERABLE ECCS train is not available. This action ensures that plant operation does not continue outside the accident analyses. This action provides an improvement over SQNs current action requirements. Accordingly, TVA considers this proposed change to be less restrictive.

5) Surveillance Requirements (SRs)

The SQN SR 4.5.2 currently is:

Each ECCS subsystem shall be demonstrated OPERABLE:

TVAs proposed change to SR 4.5.2 is:

Each ECCS train shall be demonstrated OPERABLE:

TVAs proposed change replaces the term subsystem with the term train. This change, as previously discussed, is editorial in nature because the term train is being clearly defined in the TS Bases section. Accordingly, TVA considers this proposed change to be neutral.

TVAs propose changes to SR 4.5.2 (b) through (h) are described below:

The current SR 4.5.2.b. is:

At least once per 31 days by:

1. Verifying that the ECCS piping is full of water by venting the ECCS pump casings and accessible discharge piping high points, and

2. 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.

TVAs proposed change to SR 4.5.2.b states:

At least once per 31 days by:

1. Verify ECCS piping is full of water by venting the ECCS pump casings and accessible piping high points, and

2. Verify each ECCS manual, power operated and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, is in the correct position.

SQNs existing SR 4.5.2.b provides venting requirements for ECCS discharge piping and components. TVA is upgrading SQN SR 4.5.2.b to the ISTS requirements to address the suction piping of ECCS by deleting the word discharge from the SR.

Additionally, SR 4.5.2.b.2 is being revised to adopt ISTS language. Accordingly, TVA E-4

considers these proposed changes to be more restrictive.

The current SR 4.5.2.c is:

c. By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall be performed:

1. For all accessible areas of the containment prior to establishing CONTAINMENT INTEGRITY, and

2. Of the areas affected within containment at the action of each containment entry when CONTAINMENT INTEGRITY is established.

TVAs proposed change relocates this surveillance from SQN TSs to existing plant procedures. The surveillance for performing a visual inspection when establishing containment integrity has been removed from ISTS. This surveillance is typically controlled in the nuclear industry by plant procedures that establish and maintain containment integrity. Accordingly, this SR is no longer in the ISTS for ECCS. TVAs proposed change for relocating this SR to existing plant procedures is consistent with the ISTS and TVA considers this change to be a less restrictive change.

SQNs current SR 4.5.2.d is:

d. At least once per 18 months by:

1. Deleted.

2. A visual inspection of the containment sump and verifying the subsystem suction inlets are not restricted by debris and that the sump components (trash rack, screens, etc.) show no evidence of structural distress or corrosion.

TVAs proposed change to SR 4.5.2.d states:

d. At least once per 18 months perform a visual inspection of the containment sump and verify the suction inlets are not restricted by debris and that the sump components (strainers, screens, etc.) show no evidence of structural distress or corrosion.

TVA proposes to revise SR 4.5.2.d to incorporate the standard SR for sump inspection. The standard surveillance provides a description of the sump components required to be visually inspected (i.e., trash racks and screens). TVAs proposed change deletes the word subsystem and replaces the term trash racks with strainers. This change in terminology is editorial in nature and reflects recent plant modifications that were performed to install strainers over the opening of SQNs containment sump. SQNs containment sump was originally designed with a mesh screen framework that covered the sump opening. Following issuance of NRC Generic Letter 2004-02, plant modifications were performed to replace the screen design with a strainer design.

Note that the term trash racks has never been a part of SQNs sump design history.

This term was used during SQNs application for full power license and was standard E-5

TS language at that time. It may be noted that the term screen remains applicable within SR 4.5.2.d because the opening of the ECCS suction inlet piping (located inside the containment sump) is covered with a meshed screen and must be visually inspected. Therefore, TVA considers this change to be neutral.

The current SR 4.5.2.e is:

e. At least once per 18 months, during shutdown by:

1. Verifying that each automatic valve in the flow path actuates to its correct position on a safety injection test signal and automatic switchover to containment sump test signal.

2. Verifying that each of the following pumps start automatically upon receipt of a safety injection signal:

a) Centrifugal charging pump b) Safety injection pump c) Residual heat removal pump TVAs proposed change to SR 4.5.2.e states:

e. At least once per 18 months by:

1. Verifying that each automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to its correct position on an actual or simulated actuation signal.

2. Verifying that each ECCS pump starts automatically on an actual or simulated actuation signal.

TVAs proposed change to SR 4.5.2.e adds ISTS language that provides clarification to SQNs existing SR.

The first proposed change removes the language during shutdown from the 18 month frequency description. The standard Bases states the reasons for performing surveillances during plant shutdown conditions. Consequently, this level of detail is not necessary for inclusion in the TSs and is removed. Changes to the Bases are controlled in accordance with administrative controls and 10 CFR 50.59 that ensure that any changes are appropriately reviewed. Accordingly, this proposed change is considered less restrictive.

The second proposed change is to SR 4.5.2.e.1 and involves the addition of ISTS language; that is not locked, sealed, or otherwise secured. Addition of this phrase is an improvement that defines those ECCS valves in the flow path that must be verified to actuate to their correct post-accident position. In addition, it may be noted that the addition of this phrase provides consistency with other portions of the SQN TSs (i.e.,

Containment, Section 6.0) that already utilize the standard language. The addition of ISTS language does not alter the selection of automatic ECCS valves required to be verified by SQNs SR. The population of valves within the flow path remains unchanged. Accordingly, TVA considers the addition of this ISTS language to be an E-6

improvement that is neutral.

The third change provides a revision to SQN SR 4.5.2.e.1 that incorporates ISTS language associated with the ECCS actuation signal. The ISTS language verifies that each ECCS automatic valve in the flow path actuates to the correct position on an actual or simulated actuation signal. SQNs SR 4.5.2.e.1 accomplishes actuation of ECCS by initiating a manual safety injection signal. This is accomplished through manual hand switches in the main control room. In conjunction with the safety injection signal, SQNs SR calls for initiation of a containment swap-over signal to verify that certain automatic ECCS valves realign from the refueling water storage tank (RWST) to the containment sump. The containment swap-over signal is initiated by actuation of bistables in the instrument racks that make up the proper logic for initiation of this signal. TVA considers the proposed change to be neutral because the test methodology remains unchanged for actuation of an ECCS signal.

The fourth change provides a revision to SQN SR 4.5.2.e.2 that incorporates ISTS language associated with the ECCS automatic start and eliminates the pump listing.

TVA considers the proposed change to be neutral because the test methodology remains unchanged for the ECCS pumps.

The current SQN SR 4.5.2.f is:

f. By verifying that each of the following pumps develops the indicated discharge pressure on recirculation flow when tested pursuant to Specification 4.0.5:

1. Centrifugal charging pump Greater than or equal to 2400 psig

2. Safety Injection pump Greater than or equal to 1407 psig

3. Residual heat removal pump Greater than or equal to 165 psig TVAs proposed change to SR 4.5.2.f states:

f. By verifying that each ECCS pumps developed head at the test flow point is greater than or equal to the required developed head when tested in accordance with the Inservice Test Program of Specification 4.0.5.

TVAs proposed upgrade to SR 4.5.2.f is an improvement that provides consistency with the ISTS. The proposed change eliminates the listing of ECCS pumps with their associated discharge pressures and the specific requirement to test the ECCS pumps on recirculation flow (miniflow). TVAs proposed change adopts the standard SR for pump testing at the test flow point that is greater than or equal to the required developed head. Pump performance may be verified with more accuracy at the required developed head or at higher flows. As such, TVAs proposed change allows the American Society of Mechanical Engineers (ASME) Inservice Test (IST) Program to determine and specify the test methods and flow(s) required to verify pump performance. Accordingly, the current list of ECCS pumps with their associated discharge pressures is relocated from the TSs to SQNs IST Program as referenced in SQN TS 4.0.5. TVA considers the proposed change to be less restrictive.

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SQNs current SR 4.5.2.g is:

g. By verifying the correct position of each mechanical stop for the following ECCS throttle valves:

1. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months following action of each valve stroking operation or maintenance on the valve when the ECCS subsystems are required to be OPERABLE.

2. At least once per 18 months.

Charging Pump Injection Safety Injection Cold Safety Injection Hot Throttle Valves Leg Throttle Valves Leg Throttle Valves

1.63-582 1.63-550 1.63-542

2.63-583 2.63-552 2.63-544

3.63-584 3.63-554 3.63-546

4.63-585 4.63-556 4.63-548 TVAs proposed change to SR 4.5.2.g states:

g. At least once per 18 months verify the correct position of each mechanical stop for the following ECCS throttle valves.

Charging Pump Injection Safety Injection Cold Safety Injection Hot Throttle Valves Leg Throttle Valves Leg Throttle Valves

1.63-582 1.63-550 1.63-542

2.63-583 2.63-552 2.63-544

3.63-584 3.63-554 3.63-546

4.63-585 4.63-556 4.63-548 TVAs proposed change relocates SQN SR 4.5.2.g.1 to plant procedures. The requirement for verifying ECCS throttle valve stop position after valve stroking or maintenance is to be governed by plant procedures consistent with ISTS. At SQN, the ECCS throttle valves are manual needle valves that are locked in position and do not realign on a safety injection signal. As such, it is sufficient to control these valves via maintenance procedures and the locked valve program. In the ISTS, post-maintenance test requirements have been removed from the TSs. Plant procedures govern the restoration of plant equipment after maintenance and must specify the appropriate post-maintenance testing. TVA considers this proposed change to be less restrictive.

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TVAs current SR 4.5.2.h is:

h. By performing a flow balance test during shutdown following action of modifications to the ECCS subsystem that alter the subsystem flow characteristics and verifying the following flow rates:

1. For safety injection pump lines with a single pump running:

a. The sum of the injection line flow rates, excluding the highest flow rate is greater than or equal to 443 gpm, and

b. The total pump flow rate is less than or equal to 675 gpm.

2. For centrifugal charging pump lines with a single pump running:

a. The sum of the injection line flow rates, excluding the highest flow rate is greater than or equal to 309 gpm, and

b. The total pump flow rate is less than or equal to 555 gpm.

3. For all four cold leg injection lines with a single RHR pump running a flow rate greater than or equal to 3931 gpm.

TVAs proposed change relocates SQN SR 4.5.2.h to plant procedures. The requirement for performing a flow balance test following ECCS modifications is no longer required as part of the ISTS and is relocated from SQNs TSs. The proposed change is consistent with ISTS in that post-maintenance testing is more appropriately governed by plant procedures. The restoration of equipment after maintenance is specified by the appropriate post-maintenance test procedure. Accordingly, TVA considers the proposed change to be less restrictive.

TVAs proposed changes to SQN TS 3.5.3 are summarized below:

1) Title Change for TS 3/4 5.3 TVAs proposed change replaces the current title (ECCS Subsystems - Tavg less than 350F) with the standard title (ECCS - Shutdown). The proposed change is administrative in nature and does not affect existing ECCS requirements or other related specifications. In addition, associated TS index pages are revised to reflect the title change for TS 3/4.5.3.

2) Limiting Condition for Operation (LCO)

SQNs current LCO 3.5.3 reads as follows:

As a minimum one ECCS subsystem comprised of the following shall be OPERABLE:

a. One OPERABLE centrifugal charging pump,

b. One OPERABLE residual heat removal heat exchanger,

c. One OPERABLE residual heat removal pump, and

d. An OPERABLE flow path capable of taking suction from the refueling water storage tank upon being manually realigned and automatically transferring suction to the containment sump during the recirculation phase of operation.

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TVAs proposed change replaces the current LCO with the standard LCO language that states:

3.5.3 One ECCS train shall be OPERABLE.

TVAs proposed revision to the LCO remains consistent with ISTS requirements for ECCS. For SQN, as with the standard, only one train of ECCS is required in Mode 4 such that single failure is not considered. A train of ECCS consists of a centrifugal charging subsystem and an residual heat removal (RHR) subsystem. Due to the stable conditions associated with Mode 4, and the reduced probability of occurrence of a Design Basis Accident (DBA), SQNs ECCS operational requirements are reduced for this mode of plant operation. It is noted that full ECCS capability may not be available and manual operator action may be utilized to initiate ECCS, as required. This is discussed in Section 6.3.1.4 of the SQN Updated Final Safety Analysis Report (UFSAR). Manual actuation of ECCS is recognized by the ISTS in the applicable Safety Analyses section of the standard Bases. Accordingly, TVAs proposed change is considered acceptable for conversion to standard requirements. TVA considers the proposed change to be neutral.

The note for LCO 3.5.3 is being added to be consistent with NUREG-1431. The note for the LCO is An RHR train may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned to the ECCS mode of operation. This change is considered to be neutral.

3) Applicability The applicability of SQN TS 3.5.3 is equivalent to the ISTS and thus there is no proposed change in applicability.

4) Action The SQN TS action requirements currently are:

a. With no ECCS subsystem OPERABLE because of the inoperability of either the centrifugal charging pump or the flow path from the refueling water storage tank, restore at least one ECCS subsystem to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in COLD SHUTDOWN within the next 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months . LCO 3.0.4.b is not applicable.

b. With no ECCS subsystem OPERABLE because of the inoperability of either the residual heat removal heat exchanger or residual heat removal pump, restore at least one ECCS subsystem to OPERABLE status or maintain the Reactor Coolant System Tavg less than 350F by use of alternate heat removal methods.

TVAs proposed change replaces the current action requirements with the following standard action requirements:

a. With the required ECCS residual heat removal (RHR) subsystem inoperable, immediately initiate action to restore required ECCS RHR subsystem to OPERABLE status.

b. With the required ECCS centrifugal charging subsystem inoperable, within one hour, restore required ECCS centrifugal charging subsystem to OPERABLE status, or be in COLD SHUTDOWN within the next 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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TVAs proposed change adopts ISTS action requirements and language that address either of two conditions; an inoperable RHR subsystem or an inoperable centrifugal charging subsystem. For the condition involving an inoperable RHR subsystem (SQNs current action [b]), the standard incorporates immediate action for restoring a required RHR subsystem. This change is considered a TS improvement that provides a level of urgency for ensuring prompt action is taken to restore required cooling capacity. In addition, SQNs current action (b) provides an option for maintaining the Reactor Coolant System Tavg less than 350F by use of alternative heat removal methods, if at least one ECCS subsystem is not restored. TVAs proposed change removes this option from the action requirement. Although this option is no longer part of the action, TVAs proposed change adopts the ISTS Bases for ECCS 3.5.3 (refer to Bases Section A.1) that describes the option to the operator for an alternate method of heat removal (i.e., use of steam generators). Accordingly, TVAs proposed change to SQNs action (b) provides the level of detail consistent with standard requirements.

TVAs proposed change to SQNs current action (a) adopts the equivalent actions provided by the standard action requirements. The action requires the operator to restore the required centrifugal charging subsystem to operable status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months .

In addition, provisions for plant shutdown to Mode 5 are changed to have the action time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . This provision provides an additional 3 hours3.472222e-5 days 8.333333e-4 hours 4.960317e-6 weeks 1.1415e-6 months to be in Mode 5 and is consistent with ISTS. Accordingly, TVAs proposed changes to the actions provide improvements over existing action requirements and are considered less restrictive.

The note for the ACTIONS is LCO 3.0.4b is not applicable to ECCS centrifugal charging subsystem. The note is being relocated from the specific action to a note that applies to the action and is consistent with standard formatting.

A second note being added is The required ECCS residual heat removal (RHR) subsystem may be inoperable for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for surveillance testing of valves provided that alternate heat removal methods are available via the steam generators to maintain reactor coolant system Tavg less than 350 degrees F and provided that the required subsystem is capable of being manually realigned to the ECCS mode of operation.

The second note was added to allow the required ECCS RHR subsystem to be inoperable because of surveillance testing of RCS pressure isolation valve leakage.

This allows testing while RCS pressure is sufficient to obtain valid leakage data and following valve closure for RHR decay heat removal path. The condition requiring alternate heat removal methods ensures that the RCS heatup rate can be controlled to prevent Mode 3 entry and thereby ensure that the reduced ECCS operational requirements are maintained. The condition requiring manual realignment capability ensures that in the unlikely event of a DBA during the one hour of surveillance testing, the RHR subsystem can be placed in ECCS recirculation mode when required to mitigate the event. This note for LCO 3.5.3.a is consistent with TVAs Watts Bar TSs.

The relocation of the note concerning LCO 3.0.4 applicability and the note allowing one hour for surveillance testing are considered to be neutral.

E-11

5) Surveillance Requirement (SR)

The current SQN SR 4.5.3 is:

The ECCS subsystem shall be demonstrated OPERABLE per the applicable Surveillance Requirements of 4.5.2.

TVAs proposed change states:

The ECCS train shall be demonstrated OPERABLE per the following applicable Surveillance Requirements of 4.5.2: 4.5.2.b.1, 4.5.2.d, 4.5.2.f, 4.5.2.g.

The proposed change is administrative in nature and does not affect existing TS ECCS requirements or other related specifications. The change replaces subsystem with train and defines the applicable SRs of 4.5.2. TVAs proposed change is considered acceptable for conversion to standard requirements. TVA considers the proposed change to be neutral.

In summary, TVAs proposed changes remain consistent with the requirements provided by Specifications 3.5.2 and 3.5.3 of NUREG-1431, Revision 3. A proposed TS markup of the changes is provided in Attachment 1. In addition, associated revisions proposed for the TS Bases sections are provided in Attachment 2.

3.0 TECHNICAL EVALUATION

The ECCS at SQN consists of three separate subsystems: centrifugal charging (CC) (high head), SI (intermediate head) and RHR (low head). Each of these subsystems consists of two independent and redundant 100 percent capacity trains.

The function of the ECCS is to provide core cooling and negative reactivity to ensure that the reactor core is protected after any of the following accidents:

a) Loss of coolant accident (LOCA), coolant leakage greater than the capability of the normal charging system, b) Rod ejection accident c) Loss of secondary coolant event, including uncontrolled steam release or loss of feedwater, and d) Steam generator tube rupture (SGTR).

The analyses and acceptance criteria for the consequences of each of these accidents is described in the respective accident analyses sections of the SQN UFSAR, Chapter 15.

The analysis specified by 10 CFR 50.46 "Acceptance Criteria for Emergency Core Cooling Systems for Light Water Nuclear Power Reactors," is presented in Section 15.4.1 and shows compliance with the acceptance criteria; that is,

1. The calculated peak fuel element clad temperature provides margin to the requirement of 2200°F, based on an Fq value of 2.32.

2. The amount of fuel element cladding that reacts chemically with water or steam does not exceed 1 percent of the total amount of zirconium alloy in the reactor.

3. The clad temperature transient is terminated at a time when the core geometry is still amenable to cooling. The clad oxidation limits of 17 percent are not exceeded during or after quenching, and, E-12

4. The core temperature is reduced and decay heat is removed for an extended period of time, as required by the long-lived radioactivity remaining in the core.

In addition to compliance with 10 CFR 50.46, the SQN ECCS is designed to comply with General Design Criteria 35 of the 10 CFR 50, Appendix A and is discussed in Section 3.1 of the SQN UFSAR. Suitable redundancy in components and features, and suitable interconnections, leak detection, isolation, and containment capabilities are provided to assure that for onsite electric power system operation (assuming offsite power is not available) and for offsite electric power system operation (assuming onsite power is not available) the system safety function can be accomplished, assuming a single failure. It is noted that during plant shutdown conditions, full ECCS capability may not be available.

Operator action is utilized to initiate ECCS as required. The manual action is consistent with the ISTS for ECCS and is described in the standard ECCS TS Bases for ECCS (refer to the Applicable Safety Analysis portion of Bases Section 3.5.3).

The SQN ECCS TSs were developed from standard requirements available in the early 1980s at the time SQN received approval for a full power license. SQNs ECCS TSs have provided the operability requirements for ECCS components during plant operation (Modes 1, 2, and 3) and during plant shutdown (Mode 4). The current TS for plant operation (TS 3/4.5.2) entitled ECCS SUBSYSTEMS - Tavg greater than or equal to 350°F, requires two independent ECCS subsystems OPERABLE with each subsystem comprised of the following components:

1) one OPERABLE centrifugal charging pump

2) one OPERABLE safety injection pump

3) one OPERABLE RHR heat exchanger

4) one OPERABLE RHR pump

5) an OPERABLE flow path capable of taking suction from the RWST on a SI signal and automatically transferring suction to the containment sump during the recirculation phase of operation.

Similarly, SQNs current TS for plant shutdown (TS 3/4.5.3), entitled ECCS SUBSYSTEMS

- Tavg less than 350F, requires as a minimum, one ECCS subsystem to be OPERABLE.

The same components listed in the LCO for TS 3/4.5.2 are required for TS 3/4.5.3 with the exception of item 2 above (one OPERABLE safety injection pump) that is not required for Mode 4.

TVAs proposed upgrade of SQNs ECCS specifications provides equivalent operability requirements for SQNs ECCS components. TVA has evaluated SQNs ECCS design and licensing basis against the proposed ECCS TS changes and has determined that the proposed changes provide an overall improvement to SQN TSs with continued assurance that SQNs ECCS satisfies existing operability requirements for SQNs ECCS components.

In addition, SQNs ECCS design requirements remain in compliance with 10 CFR 50, Appendix A, and 10 CFR 50.46.

4.0 REGULATORY EVALUATION

TVA is proposing to update the current TS requirements of SQN TS 3/4.5.2, entitled ECCS SUBSYSTEMS - Tavg greater than or equal to 350F and TS 3/4.5.3 entitled ECCS SUBSYSTEMS - Tavg less than 350F. TVAs proposed change will provide a general TS improvement that standardizes the existing requirements for SQNs ECCS.

E-13

TVA has concluded that operation of SQN Units 1 and 2 in accordance with the proposed change to SQN TSs 3/4.5.2 and 3/4.5.3 does not involve a significant hazards consideration. TVA's conclusion is based on its evaluation, in accordance with 10 CFR 50.91(a)(1), of the three standards set forth in 10 CFR 50.92(c).

4.1 Applicable Regulatory Requirements/Criteria Section 182a of the Atomic Energy Act requires applicants for nuclear power plant operating licenses to include TSs as part of the license. The Commission's regulatory requirements related to the content of the TSs are contained in Title 10, Code of Federal Regulations (10 CFR), Section 50.36.

The TS requirements in 10 CFR 50.36 include the following categories:

(1) safety limits, limiting safety systems settings and control settings, (2) limiting conditions for operation, (3) surveillance requirements (SRs), (4) design features, and (5) administrative controls. Regulatory requirements associated with SQNs emergency core cooling system (ECCS) are based on 10 CFR 50.46 and General Design Criteria (GDC) 35 of Appendix A from 10 CFR 50.

The ECCS is designed in accordance with accepted engineered safety feature design practices.

As stated in 10 CFR 50.59(c)(1)(i), a licensee is required to submit a license amendment pursuant to 10 CFR 50.90 if a change to the TSs is required.

Furthermore, the requirements of 10 CFR 50.59 necessitate that U.S. Nuclear Regulatory Commission (NRC) approve the TS changes before the changes are implemented. TVAs submittal meets the requirements of 10 CFR 50.59(c)(1)(i) and 10 CFR 50.90.

4.2 Precedent TVAs proposed change is similar in nature to previous license amendments that were approved for Vogtle and Catawba Nuclear Plants by NRC letters dated September 25, 1996, and September 30, 1998, respectively. The license amendments for Vogtle and Catawba modified their respective TSs to upgrade the ECCS requirements to the ISTS requirements provided in NUREG-1431.

4.3 Significant Hazards Consideration

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

TVAs proposed change is not considered to be a significant departure from the current requirements and is considered an upgrade for Sequoyah Nuclear Plants (SQNs) emergency core cooling system (ECCS) technical specification (TS) requirements. The ECCS is qualified and designed to provide core cooling and negative reactivity to ensure the reactor core is protected in the event of a loss of coolant accident (LOCA), rod ejection accident, loss of secondary coolant accident, and steam generator tube rupture (SGTR). The proposed change does not alter qualification or design features associated with SQNs ECCS. The probability of occurrence of an accident is not increased as the changes do not affect the systems capability for performing ECCS operation during injection, cold leg recirculation, and hot leg recirculation. The proposed changes continue to ensure that SQNs ECCS satisfies 10 CFR 50.46 and E-14

10 CFR 50, Appendix A requirements. Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

The possibility for a new or different kind of accident from any accident previously evaluated does not exist as a result of the proposed changes.

The upgrade of SQN TSs to industry Improved Standard TS (ISTS) requirements provide an overall improvement and ensures that SQNs ECCS is capable of performing the design functions under accident conditions. The system design associated with injection, cold leg recirculation, and hot leg recirculation, remain unchanged. Accordingly, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

The proposed upgrade of SQNs ECCS TSs to the ISTS does not affect existing safety margins. The system requirements continue to require that ECCS components are operable for plant operation (Modes 1, 2, and 3) and during plant shutdown (Mode 4). In addition, the proposed change does not increase the risk for an accident because no physical changes to the plant are being made and design features associated with ECCS continue to satisfy 10 CFR 50.46 requirements. Accordingly, TVA concludes that the margin of safety has not been reduced.

4.4 Conclusions In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed change does not involve a significant hazards consideration, a significant change in the types of or significant increase in the amounts of any effluents that may be released offsite, or a significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b) and TVAs environmental review process, an environmental assessment of the proposed change is not required.

E-15

ATTACHMENT 1 TENNESSEE VALLEY AUTHORITY SEQUOYAH PLANT (SQN)

UNITS 1 AND 2 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE MARKED PAGES I. AFFECTED PAGE LIST Unit 1 Unit 2 Index Page VII Index Page VII Index Page XIII Index Page XIII 3/4 5-3 3/4 5-3 3/4 5-4 3/4 5-4 3/4 5-5 3/4 5-5 3/4 5-6 3/4 5-6 3/4 5-7 3/4 5-7 3/4 5-8 3/4 5-8 3/4 5-9 3/4 5-9 3/4 5-10 3/4 5-10 3/4 5-11 3/4 5-11 3/4 5-12 3/4 5-12 3/4 5-13 3/4 5-13 II. MARKED PAGES See attached.

A1-1

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3/4.5.1 ACCUMULATORS - Operating Cold Leg Injection Accumulators ........................................................................................... 3/4 5-1 Deleted 3/4 5-3 3/4.5.2 ECCS SUBSYSTEMS - Tavg greater than or equal to 350oF............................................. 3/4 5-4 3 3/4.5.3 ECCS SUBSYSTEMS - Tavg less than 350oF .................................................................... 3/4 5-8 5 3/4.5.4 DELETED .................................................................................................................. 3/4 5-10 6 3/4.5.5 REFUELING WATER STORAGE TANK......................................................................... 3/4 5-11 7 3/4 5.6 SEAL INJECTION FLOW ................................................................................................ 3/4 5-12 8

- Shutdown 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT Containment Integrity............................................................................................................. 3/4 6-1 Secondary Containment Bypass Leakage ............................................................................ 3/4 6-2 Containment Air Locks........................................................................................................... 3/4 6-7 Internal Pressure.................................................................................................................... 3/4 6-9 Air Temperature ................................................................................................................... 3/4 6-10 Containment Vessel Structural Integrity .............................................................................. 3/4 6-11 Shield Building Structural Integrity....................................................................................... 3/4 6-12 Emergency Gas Treatment System (Cleanup Subsystem)................................................. 3/4 6-13 Containment Ventilation System.......................................................................................... 3/4 6-15 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS Containment Spray Subsystems ......................................................................................... 3/4 6-16 Lower Containment Vent Coolers...................................................................................... 3/4 6-16b August 4, 2000 SEQUOYAH - UNIT 1 VII Amendment No. 67, 69, 116, 140, 150, 176, 259 A1-2

INDEX BASES SECTION PAGE 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE ..................................................................B 3/4 4-4b 3/4.4.7 CHEMISTRY (Deleted) .................................................................................................. B 3/4 4-4r 3/4.4.8 SPECIFIC ACTIVITY ......................................................................................................B 3/4 4-5 3/4.4.9 RCS PRESSURE AND TEMPERATURE (P/T) LIMITS ...................................................B 3/4 4-6 3/4.4.10 STRUCTURAL INTEGRITY (Deleted)...........................................................................B 3/4 4-13 3/4.4.11 REACTOR COOLANT SYSTEM HEAD VENTS (Deleted) .......................................... B 3/4 4-13 3/4.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM ...............B 3/4 4-14 3/4.5 EMERGENCY CORE COOLING SYSTEMS ECCS - Operating 3/4.5.1 ACCUMULATORS ............................................................................................................B 3/4 5-1 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS...............................................................................B 3/4 5-1 2 3/4.5.4 BORON INJECTION SYSTEM (Deleted) .................................................................B 3/4 5-2 15 3/4.5.5 REFUELING WATER STORAGE TANK ....................................................................B 3/4 5-3 15 3/4.5.6 SEAL INJECTION FLOW............................................................................................B 3/4 5-4 16 3/4.5.3 ECCS - Shutdown. B 3/4 5-12 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT ..............................................................................................B 3/4 6-1 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS .........................................................B 3/4 6-3 3/4.6.3 CONTAINMENT ISOLATION VALVES ............................................................................B 3/4 6-3 3/4.6.4 COMBUSTIBLE GAS CONTROL .....................................................................................B 3/4 6-4 3/4.6.5 ICE CONDENSER ............................................................................................................B 3/4 6-4 3/4.6.6 VACUUM RELIEF LINES..................................................................................................B 3/4 6-6 3/4.7 PLANT SYSTEMS 3/4.7.1 TURBINE CYCLE..............................................................................................................B 3/4 7-1 3/4.7.2 STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION (Deleted) ..............B 3/4 7-3 3/4.7.3 COMPONENT COOLING WATER SYSTEM .................................................................B 3/4 7-3a December 28, 2005 SEQUOYAH - UNIT 1 XIII Amendment No. 157, 197, 259, 294, 297, 305 A1-3

EMERGENCY CORE COOLING SYSTEMS (ECCS)

DELETED LIMITING CONDITION FOR OPERATION This Specification is deleted.

Delete page and repaginate the section May 11, 1990 SEQUOYAH - UNIT 1 3/4 5-3 Amendment No. 28, 86, 140 A1-4

- Operating EMERGENCY CORE COOLING SYSTEMS (ECCS) 3/4.5.2 ECCS SUBSYSTEMS - Tavg Greater Than or Equal to 350°F trains LIMITING CONDITION FOR OPERATION 3.5.2 Two independent ECCS subsystems shall be OPERABLE.* with each subsystem comprised of:

a. One OPERABLE centrifugal charging pump,

b. One OPERABLE safety injection pump,

c. One OPERABLE residual heat removal heat exchanger,

d. One OPERABLE residual heat removal pump, and

e. An OPERABLE flow path capable of taking suction from the refueling water storage tank on a safety injection signal and automatically transferring suction to the containment sump during the recirculation phase of operation.

APPLICABILITY: MODES 1, 2 and 3.

and with at least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available, ACTION: or more trains With one ECCS subsystem inoperable, restore the inoperable subsystem to OPERABLE status a.

within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months . train(s) train SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the following valves are in the indicated positions with power to the valve operators removed:

b. With less than 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available, immediately enter LCO 3.0.3.

NOTES----------------------------------------------------------

1. In MODE 3, both safety injection (SI) pump flow paths may be isolated by closing the isolation valves for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to perform pressure isolation valve testing per SR 4.4.6.3.

2. In MODE 3, ECCS pumps may be made incapable of injecting to support transition into or from the APPLICABILITY of LCO 3.4.12, Low Temperature Overpressure Protection (LTOP) System, for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or until the temperature of all RCS cold legs exceeds LTOP arming temperature (350°F) specified in the PTLR plus 25°F, whichever comes first.

In MODE 3, ECCS pumps may be made incapable of injecting to support transition into or from the APPLICABILITY of LCO 3.4.12, Low Temperature Overpressure Protection (LTOP) System, for up to four hours or until the temperature of all RCS cold legs exceeds LTOP arming temperature specified in the PTLR plus 25°F, whichever comes first.

March 9, 2005 SEQUOYAH - UNIT 1 3/4 5-4 3 Amendment No. 36, 140, 276, 299 A1-5

EMERGENCY CORE COOLING SYSTEMS (ECCS)

SURVEILLANCE REQUIREMENTS (Continued)

Valve Number Valve Function Valve Position

a. FCV-63-1 RHR Suction from RWST open

b. FCV-63-22 SIS Discharge to Common Piping open valve

b. At least once per 31 days by:

and

1. Verifying that the ECCS piping is full of water by venting the ECCS pump casings and accessible discharge piping high points, and ECCS

2. 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.

c. By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall be performed: the

1. For all accessible areas of the containment prior to establishing CONTAINMENT INTEGRITY, and

2. Of the areas affected within containment at the completion of each containment entry when CONTAINMENT INTEGRITY is established.

d. At least once per 18 months by:

Deleted

1. Deleted. strainers perform a

2. A visual inspection of the containment sump and verifying that the subsystem suction inlets are not restricted by debris and that the sump components ( trash racks, screens, etc.) show no evidence of structural distress or corrosion.

e. At least once per 18 months, during shutdown, by:

1. Verifying that each automatic valve in the flow path actuates to its correct position on a safety injection test signal and automatic switchover to containment sump test signal.

that is not locked, sealed or otherwise secured in position, an actual or simulated actuation signal.

May 11, 1990 Correction Letter: 5/16/90 SEQUOYAH - UNIT 1 3/4 5-5 Amendment Nos. 92, 139, 140 A1-6

Move SR to previous page on an actual or simulated actuation signal.

EMERGENCY CORE COOLING SYSTEMS (ECCS)

SURVEILLANCE REQUIREMENTS (Continued)

2. Verifying that each of the following pumps start automatically upon receipt of a safety injection signal:

a) Centrifugal charging pump ECCS pump starts b) Safety injection pump c) Residual heat removal pump

f. By verifying that each of the following pumps develops the indicated discharge pressure on recirculation flow when tested pursuant to Specification 4.0.5:

1. Centrifugal charging pump Greater than or equal to 2400 psig

2. Safety Injection pump Greater than or equal to 1407 psig

3. Residual heat removal pump Greater than or equal to 165 psig

g. By verifying the correct position of each mechanical stop for the following Emergency Core Cooling System throttle valves:

1. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months following completion of each valve stroking operation or maintenance on the valve when the ECCS subsystems are required to be OPERABLE.

2. At least once per 18 months, Charging Pump Injection Safety Injection Cold Safety Injection Hot Throttle Valves Leg Throttle Valves Leg Throttle Valves Valve Number Valve Number Valve Number

1. 63 - 582 1. 63 - 550 1.63-542

2. 63 - 583 2. 63 - 552 2.63-544

3. 63 - 584 3. 63 - 554 3.63-546

4. 63 - 585 4. 63 - 556 4.63-548

f. By verifying that each ECCS pumps developed head at the test flow point is greater than or equal to the required developed head when tested in accordance with the Inservice Testing Program of Specification 4.0.5.

May 11, 1990 SEQUOYAH - UNIT 1 3/4 5-6 Amendment No. 140 A1-7

EMERGENCY CORE COOLING SYSTEMS (ECCS)

SURVEILLANCE REQUIREMENTS (Continued)

h. By performing a flow balance test during shutdown following completion of modifications to the ECCS subsystem that alter the subsystem flow characteristics and verifying the following flow rates:

1. For safety injection pump lines with a single pump running:

a. The sum of the injection line flow rates, excluding the highest flow rate is greater than or equal to 443 gpm, and

b. The total pump flow rate is less than or equal to 675 gpm.

2. For centrifugal charging pump lines with a single pump running:

a. The sum of the injection line flow rates, excluding the highest flow rate is greater than or equal to 309 gpm, and

b. The total pump flow rate is less than or equal to 555 gpm.

3. For all four cold leg injection lines with a single RHR pump running a flow rate greater than or equal to 3931 gpm.

Delete page and repaginate the section May 11, 1990 SEQUOYAH - UNIT 1 3/4 5-7 Amendment No. 50, 140 A1-8

EMERGENCY CORE COOLING SYSTEMS (ECCS) - Shutdown 3/4.5.3 ECCS SUBSYSTEMS - Tavg Less Than 350°F Replace colon with a period train LIMITING CONDITION FOR OPERATION One 3.5.3 As a minimum, one ECCS subsystem comprised of the following shall be OPERABLE:.

a. One OPERABLE centrifugal charging pump,

b. One OPERABLE residual heat removal heat exchanger,

c. One OPERABLE residual heat removal pump, and

d. An OPERABLE flow path capable of taking suction from the refueling water storage tank upon being manually realigned and automatically transferring suction to the containment sump during the recirculation phase of operation.

APPLICABILITY: MODE 4.

ACTION:

a. With no ECCS subsystem OPERABLE because of the inoperability of either the centrifugal charging pump or the flow path from the refueling water storage tank, restore at least one ECCS subsystem to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in COLD SHUTDOWN within the next 20 hours2.314815e-4 days 0.00556 hours 3.306878e-5 weeks 7.61e-6 months . LCO 3.0.4.b is not applicable.

b. With no ECCS subsystem OPERABLE because of the inoperability of either the residual heat removal heat exchanger or residual heat removal pump, restore at least one ECCS subsystem to OPERABLE status or maintain the Reactor Coolant System Tavg less than 350°F by use of alternate heat removal methods.

a. With the required ECCS residual heat removal (RHR) subsystem inoperable, immediately initiate action to restore required ECCS RHR subsystem to OPERABLE status.

b. With the required ECCS centrifugal charging subsystem inoperable, within one hour, restore required ECCS centrifugal charging subsystem to OPERABLE status, or be in COLD SHUTDOWN within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

NOTE-----------------------------------------------------------------------

1) LCO 3.0.4b is not applicable to ECCS centrifugal charging subsystem.

2) The required ECCS residual heat removal (RHR) subsystem may be inoperable for up to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months for surveillance testing of valves provided that alternate heat removal methods are available via the steam generators to maintain reactor coolant system Tavg less than 350°F and provided that the required subsystem is capable of being manually realigned to the ECCS mode of operation.

NOTE---------------------------------------------------------------------

An RHR train may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned to the ECCS mode of operation.

April 11, 2005 SEQUOYAH - UNIT 1 3/4 5-8 Amendment No. 36, 140, 276, 301 A1-9

EMERGENCY CORE COOLING SYSTEMS (ECCS)

SURVEILLANCE REQUIREMENTS train 4.5.3 The ECCS subsystem shall be demonstrated OPERABLE per the applicable Surveillance Requirements of 4.5.2:

SR 4.5.2.b.1 SR 4.5.2.d following SR 4.5.2.f SR 4.5.2.g This SR will be moved to the previous page and this page will be deleted.

May 11, 1990 SEQUOYAH - UNIT 1 3/4 5-9 Amendment No. 140 A1-10

EMERGENCY CORE COOLING SYSTEMS (ECCS) 3/4.5.4 DELETED LIMITING CONDITION FOR OPERATION This Specification is deleted.

May 11, 1990 SEQUOYAH - UNIT 1 3/4 5-10 Amendment No. 140 A1-11

EMERGENCY CORE COOLING SYSTEMS (ECCS) 3/4.5.5 REFUELING WATER STORAGE TANK LIMITING CONDITION FOR OPERATION 3.5.5 The refueling water storage tank (RWST) shall be OPERABLE with:

a. A contained borated water volume of between 370,000 and 375,000 gallons,

b. A boron concentration of between 2500 and 2700 ppm of boron,

c. A minimum solution temperature of 60°F, and

d. A maximum solution temperature of 105°F.

APPLICABILITY: MODES 1, 2, 3 and 4.

ACTION:

With the RWST inoperable, restore the tank to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or be in at least HOT STANDBY within 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 4.5.5 The RWST shall be demonstrated OPERABLE:

a. At least once per 7 days by:

1. Verifying the contained borated water volume in the tank, and

2. Verifying the boron concentration of the water.

b. At least once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months by verifying the RWST temperature.

May 11, 1990 SEQUOYAH - UNIT 1 3/4 5-11 Amendment No. 12, 140 A1-12

EMERGENCY CORE COOLING SYSTEMS (ECCS) 3/4.5.6 SEAL INJECTION FLOW LIMITING CONDITION FOR OPERATION 3.5.6 Reactor coolant pump seal injection flow shall be within the limits of Figure 3.5.6-1.

APPLICABILITY: MODES 1, 2, and 3.

ACTION:

With reactor coolant pump seal injection flow not within limits, adjust manual seal injection throttle valves to give a flow within limit in accordance with Surveillance Requirement 4.5.6 within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months . 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 HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

SURVEILLANCE REQUIREMENTS 4.5.6 At least once per 31 days* verify manual seal injection throttle valves are adjusted to give a flow within the emergency core cooling system safety analysis limits in Figure 3.5.6-1.

This surveillance is not required to be performed until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after the reactor coolant system pressure stabilizes at 2215 psig and 2255 psig.

August 4, 2000 SEQUOYAH - UNIT 1 3/4 5-12 Amendment No. 259 A1-13

FIGURE 3.5.6-1 Seal Injection Flow Limits 250 Differential Pressure (between PT 62-92 and pressurizer)

ACCEPTABLE REGION 200 R263 150 100 50 25 30 35 40 45 50 Seal Injection Flow (gpm)

August 4, 2000 SEQUOYAH UNIT 1 3/4 5-13 Amendment No. 259 A1-14

INDEX LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS SECTION PAGE 3/4.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3/4.5.1 ACCUMULATORS Cold Leg Injection Accumulators ............................................................................... 3/4 5-1

- Operating Deleted ....................................................................................................................... 3/4 5-3 3/4.5.2 ECCS SUBSYSTEMS - Tavg greater than or equal to 350°F ............................................ 3/4 5-4 3 3/4.5.3 ECCS SUBSYSTEMS - Tavg less than 350°F ....................................................................... 3/4 5-8 5

- Shutdown 3/4.5.4 DELETED .......................................................................................................................... 3/4 5-10 6 3/4.5.5 REFUELING WATER STORAGE TANK .......................................................................... 3/4 5-11 7 3/4.5.6 SEAL INJECTION FLOW.................................................................................................... 3/4 5-12 8 3/4.6 CONTAINMENT SYSTEMS 3/4.6.1 PRIMARY CONTAINMENT Containment Integrity ................................................................................................... 3/4 6-1 Secondary Containment Bypass Leakage................................................................... 3/4 6-2 Containment Air Locks ................................................................................................ 3/4 6-7 Internal Pressure.......................................................................................................... 3/4 6-9 Air Temperature ......................................................................................................... 3/4 6-10 Containment Vessel Structural Integrity..................................................................... 3/4 6-11 Shield Building Structural Integrity ............................................................................. 3/4 6-12 Emergency Gas Treatment System - EGTS - Cleanup Subsystem .......................... 3/4 6-13 Containment Ventilation System................................................................................ 3/4 6-15 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS Containment Spray Subsystems................................................................................ 3/4 6-16 Lower Containment Vent Coolers ............................................................................ 3/4 6-16b August 4, 2000 SEQUOYAH - UNIT 2 VII Amendment Nos. 59, 61, 131, 140, 167, 250 A1-15

INDEX BASES SECTION PAGE 3/4.4.6 REACTOR COOLANT SYSTEM LEAKAGE ......................................................................B 3/4 4-4 3/4.4.7 CHEMISTRY (Deleted).................................................................................................... B 3/4 4-4r 3/4.4.8 SPECIFIC ACTIVITY ........................................................................................................B 3/4 4-5 3/4.4.9 RCS PRESSURE AND TEMPERATURE (P/T) LIMITS.....................................................B 3/4 4-7 3/4.4.10 STRUCTURAL INTEGRITY (Deleted)..............................................................................B 3/4 4-14 3/4.4.11 REACTOR COOLANT SYSTEM HEAD VENTS (Deleted) ..............................................B 3/4 4-14 3/4.4.12 LOW TEMPERATURE OVERPRESSURE PROTECTION (LTOP) SYSTEM.................B 3/4 4-15 3/4.5 EMERGENCY CORE COOLING SYSTEMS ECCS - Operating 3/4.5.1 ACCUMULATORS..............................................................................................................B 3/4 5-1 3/4.5.2 and 3/4.5.3 ECCS SUBSYSTEMS ...................................................................................B 3/4 5-1 2 3/4.5.4 BORON INJECTION SYSTEM ..............................................................................................B 3/4 5-2 3/4.5.5 REFUELING WATER STORAGE TANK............................................................................B 3/4 5-2 3/4.5.6 SEAL INJECTION FLOW.......................................................................................................B 3/4 5-4 3/4.6 CONTAINMENT SYSTEMS 3/4.5.3 ECCS - Shutdown.B 3/4 5-12 3/4.6.1 PRIMARY CONTAINMENT ...................................................................................................B 3/4 6-1 3/4.6.2 DEPRESSURIZATION AND COOLING SYSTEMS...........................................................B 3/4 6-3 3/4.6.3 CONTAINMENT ISOLATION VALVES ..............................................................................B 3/4 6-3 3/4.6.4 COMBUSTIBLE GAS CONTROL.......................................................................................B 3/4 6-4 3/4.6.5 ICE CONDENSER ..............................................................................................................B 3/4 6-4 3/4.6.6 VACUUM RELIEF VALVES................................................................................................B 3/4 6-6 3/4.7 PLANT SYSTEMS 3/4.7.1 TURBINE CYCLE ...............................................................................................................B 3/4 7-1 3/4.7.2 STEAM GENERATOR PRESSURE/TEMPERATURE LIMITATION (Deleted) .................B 3/4 7-3 3/4.7.3 COMPONENT COOLING WATER SYSTEM...................................................................B 3/4 7-3a December 28, 2005 SEQUOYAH - UNIT 2 XIII Amendment No. 147, 188, 250, 284, 295 A1-16

EMERGENCY CORE COOLING SYSTEMS DELETED LIMITING CONDITION FOR OPERATION This Specification is deleted.

Delete page and repaginate the section October 29, 1990 SEQUOYAH - UNIT 2 3/4 5-3 Amendment No. 17, 95, 131 A1-17

- Operating EMERGENCY CORE COOLING SYSTEMS 3/4.5.2 ECCS SUBSYSTEMS - Tavg Greater Than or Equal to 350°F trains LIMITING CONDITION FOR OPERATION 3.5.2 Two independent emergency core cooling system (ECCS) subsystems shall be OPERABLE. with each subsystem comprised of:

a. One OPERABLE centrifugal charging pump,

b. One OPERABLE safety injection pump,

c. One OPERABLE residual heat removal heat exchanger,

d. One OPERABLE residual heat removal pump, and

e. An OPERABLE flow path capable of taking suction from the refueling water storage tank on a safety injection signal and automatically transferring suction to the containment sump during the recirculation phase of operation.

APPLICABILITY: MODES 1, 2 and 3.

and with at least 100% of the ECCS flow equivalent to a ACTION: or more trains single OPERABLE ECCS train available,

a. With one ECCS subsystem inoperable, restore the inoperable subsystem to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 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 in HOT SHUTDOWN within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months .

train(s) train SURVEILLANCE REQUIREMENTS 4.5.2 Each ECCS subsystem shall be demonstrated OPERABLE:

a. At least once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months by verifying that the following valves are in the indicated positions with power to the valve operators removed:

b. With less than 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available, immediately enter LCO 3.0.3.

NOTES----------------------------------------------------------------

1. In MODE 3, both safety injection (SI) pump flow paths may be isolated by closing the isolation valves for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to perform pressure isolation valve testing per SR 4.4.6.3.

2. In MODE 3, ECCS pumps may be made incapable of injecting to support transition into or from the APPLICABILITY of LCO 3.4.12, Low Temperature Overpressure Protection (LTOP) System, for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or until the temperature of all RCS cold legs exceeds LTOP arming temperature (350°F) specified in the PTLR plus 25°F, whichever comes first.

In MODE 3, ECCS pumps may be made incapable of injecting to support transition into or from the APPLICABILITY of LCO 3.4.12, Low Temperature Overpressure Protection (LTOP) System, for up to four hours or until the temperature of all RCS cold legs exceeds LTOP arming temperature specified in the PTLR plus 25°F, whichever comes first.

March 9, 2005 SEQUOYAH - UNIT 2 3/4 5-4 Amendment No. 28, 131, 203, 267, 288 A1-18

EMERGENCY CORE COOLING SYSTEMS SURVEILLANCE REQUIREMENTS (Continued)

Valve Number Valve Function Valve Position

a. FCV-63-1 RHR Suction from RWST open

b. FCV-63-22 SIS Discharge to Common open Piping valve ECCS the and

b. At least once per 31 days by:

1. Verifying that the ECCS piping is full of water by venting the ECCS pump casings and accessible discharge piping high points, and

2. 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.

c. By a visual inspection which verifies that no loose debris (rags, trash, clothing, etc.) is present in the containment which could be transported to the containment sump and cause restriction of the pump suctions during LOCA conditions. This visual inspection shall be performed:

1. For all accessible areas of the containment prior to establishing CONTAINMENT INTEGRITY, and

2. Of the areas affected within containment at the completion of each containment entry when CONTAINMENT INTEGRITY is established.

d. At least once per 18 months by: Deleted perform a

1. DELETED. strainers

2. A visual inspection of the containment sump and verifying that the subsystem suction inlets are not restricted by debris and that the sump components (trash racks, screens, etc.) show no evidence of structural distress or corrosion.

e. At least once per 18 months, during shutdown, by:

1. Verifying that each automatic valve in the flow path actuates to its correct position on a safety injection test signal and automatic switchover to containment sump test signal.

that is not locked, sealed or otherwise secured in position, an actual or simulated actuation signal.

October 29, 1990 SEQUOYAH - UNIT 2 3/4 5-5 Amendment No. 82, 128, 131 A1-19

on an actual or simulated actuation signal.

EMERGENCY CORE COOLING SYSTEMS ECCS pump starts SURVEILLANCE REQUIREMENTS (Continued)

2. Verifying that each of the following pumps start automatically upon receipt of a safety injection signal:

a) Centrifugal charging pump b) Safety injection pump c) Residual heat removal pump

f. By verifying that each of the following pumps develops the indicated discharge pressure on recirculation flow when tested pursuant to Specification 4.0.5:

1. Centrifugal charging pump Greater than or equal to 2400 psig

2. Safety Injection pump Greater than or equal to 1407 psig

3. Residual heat removal pump Greater than or equal to 165 psig

g. By verifying the correct position of each mechanical stop for the following ECCS throttle valves:

1. Within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months following completion of each valve stroking operation or maintenance on the valve when the ECCS subsystems are required to be OPERABLE.

2. At least once per 18 months, Charging Pump Injection Safety Injection Cold Safety Injection Hot Throttle Valves Leg Throttle Valves Leg Throttle Valves Valve Number Valve Number Valve Number

1. 63 - 582 1. 63 - 550 1.63-542

2. 63 - 583 2. 63 - 552 2.63-544

3. 63 - 584 3. 63 - 554 3.63-546

4. 63 - 585 4. 63 - 556 4.63-548

f. By verifying that each ECCS pumps developed head at the test flow point is greater than or equal to the required developed head when tested in accordance with the Inservice Testing Program of Specification 4.0.5.

October 29, 1990 SEQUOYAH - UNIT 2 3/4 5-6 Amendment No. 131 A1-20