ML13329A717

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Technical Specifications Conversion to NUREG-1431, Rev. 4.0 (SQN-TS-11-10)
ML13329A717
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 11/22/2013
From: James Shea
Tennessee Valley Authority
To:
Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML13329A881 List:
References
NUREG-1431, Rev 4
Download: ML13329A717 (5)
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Text

Errclostrre 4 contains proprietary infortnal iorrI and should bc rvithlrcld fiorn public discf osure undcr 10 CFR 2.390. Upon rerno\val ol the proprietary intbrntation. tltis letter is decont ro I lcd.

Tennessee Valley Authority, 1 101 Market Street, Chattanooga, Tennessee 37402 Novernber 22,2013 10 cFR 50.90 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D C. 20555-0001 Sequoyah Nuclear Plant, Units 1 and 2 Facility Operating License Nos. DPR-77 and DPR-79 NRC Docket Nos. 50-327 and 50-328

Subject:

Sequoyah Nuclear Plants, Urits 1 and 2 Technical Specifications Gonversion to NUREG-1 431, Rev. 4.A (SAN-TS-1 1-1 0)

Reference:

TVA letter to NRC, "Third Status Update of Planned Actions to Facilitate Maintenance of 6.9 Kilovolt and 480 Volt Shutdown Boards at Sequoyah Nuclear Plant, Units 1 and 2:' dated September 30, 2013 In accordance with the provisions of 10 CFR 50.90, "Application for amendment of license, construction permit, or early site perrnit," the Tennessee Valley Authority (TVA) is submitting a request for an amendment to Facility Operating License Nos. DPR-77 and DPR-79 for the Sequoyah Nuclear Plant (SQN), Units 1 and 2, respectively. This amendment request would revise SQN's current Technical Specifications (CTS) to lmproved Technical Specifications (lTS) consistent with the lmproved Standard Technical Specifications (ISTS) described in NUREG-1431, "Standard Technical Specifications - Westinghouse Plants,"

Revision 4.0. The guidance of Nuclear Energy Institute (NEl) 96-06, "lmproved Technical Specifications Conversion Guidance," dated August 1996, and Nuclear Regulatory Commission (NRC) Administrative Letter 96-04, "Efficient Adoption of lmproved Standard Technical Specifications," oated October 9, 1996, were used in preparing this submittal, The detailed descriptions and justifications to support the proposed changes are provided in , "SQN ITS Submittal, Volumes 1 through 16."

The following Enclosures are also included to assist the NRC in the review of this subrnittal:

Enclosure 1, "Contents of the Sequoyah Nuclear Plant, Units 1 and 2,lmproved Technical Specifications (lTS) Submittal," describes the organization and content of the submittal, including each of the votumes in Enclosure 2.

Enciosure 3, "Licensee ldentified Changes That May Require a Formal Technical Branch Review," provides a list and description of the changes included in the ITS submittal that differ from both the CTS and ISTS as described in NUREG -1431, Revision 4.0.

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U. S. Nuclear Regulatory Commission Page 2 November 22,248 Enclosure 4, 'Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) Instrumentation Completion Times, Bypass Times, and Surveillance Test Interval Extensions Based on WCAP-10271, WCAP-14333, and WCAP-15376,' provides the evaluations that justfi adoption of the changes to the RTS and ESFAS instrumentation completion times, bypass times, and surveillance test interval extensions.

Enclosure 5, 'Risk Informed Evaluation of Extensions to Containment lsolation Valve Completion Times WCAP-15791),' provides the evaluations that ju$ify adoption of the chargesto the extension of containment isolation valve completion times.

Enclosure 6, 'Disposition of Existing Licenee Amendment Requests," provides the disposition of other, cunently docketed license amendment requests (LARs), as they relateto this lAR.

Enclosure 7, 'Disposition of Generic Changes to NUREG-1431, Revision 4.0,' lists the NRc-approved changes to NUREG-1431, Revision 4.0, as of March 6, 2011, and summartzes the disposition of each of these changes in this LAR.

Enclosure 8, 'Regulatory Commitments," lists the commitmentrs made in this submittal. The commitments in this submittal arc only those contained in Enclosure 8.

Enclosure 9, "L:st of Required Final Safety Analysis Report (FSAR) Descriptions For TSTF-500," provide a summary of the FSAR desoiptions required as part of the adoption of Technical Specification Task Force Traveler CISTR-500.

Enclosure 10, "Relocate Surveillance Frequencies to Licensee Gontrol RITS-TF Initiative 5b C[STF-425),'provides documentation of SQN's Probabilistic Risk Assessment (PRA) technicaladequacy reguired as part of the adoption of TSTF.425.

Included In Enclosure 2 are the Bases for the proposed lTS. However, the Bases are not part of the technical specifications but are maintained consistent with the SQN Updated Final Safety Analysis Repoil (UFSAR). contains, as noted attachments, the following Westinghouse proprietrary and non-proprietary documents that were attachments to Westinghouse letter LTR-RAM-!-13-032, Rev. 1:

1) Summary Report Revision 1,'Sequoyah Nuclear Plant, Units 1 and 2, lmplementation of Master and Slave Relays Technical Specification Charges Justified in WCAP-14333-P-A, Rev. 1 and WCAP-15376-P-A, Rev. 1,'dated Septem ber 26, 2013, ( Proprietary).

U. S. Nuclear Regulatory Commission Page 3 November 22,2013 2\ Summary Report Revision 2,'Sequoyah Nuclear Plant, Unite 1 and2,

. lmplementation of TechnicalSpecification Changes Justified in WCAP-14333-P-A, Rev. 1 and WCAP-15376-P-A, Rev. 1,'dated September 26, 2013, (ProPrietary).

3) Summary Report Revision 1,'Sequoyah Nuclear Plant, Units 1 and2, lmplementation of Master and Slave Relays Technical Speciftcation Changes Justified in WCAP-1433$P-A, Rev. 1 and WCAP-15376-P-A, Rev. 1," dated September 26, 2013, (Non-Propr'tetary).

4l Summary Report Revision 2, "Sequoyah Nuclear Plant, Units 1 and 2, lmplementation of Technical Specification Changes Justified in WCAP-143:13-P-A, Rev. 1 and WCAP-15376-P-4, Rev. 1,' dated September 26, 2013, (Non-Proprietary).

Also contained In Enclosure 4 as Attachment 5 is the Westlnghouse Application for Wthholding Proprietary Information from Public Disclosure CAW-I3-3823, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice. Because Attachments 1 and 2 of Westinghouse letter LTR-RAM-l-13-032, Rev. 1 corilain information proprietary to Westinghouse Electric Company LLC, they are supported by an affidavit signed by Westinghouse, the olvner of the information. The affidavit sets forth the basis on which the information may be withheld from public disclosure by the Commiseion and addreeses with specificity the considerations lleted in paragraph (b)(4) of Seclion 2.390 of the Commission's regulations.

Accordingly, it is respectfully requested that the information which is proprietary to Westirghouse bE withheld ftom public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Conespondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-13-3823 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Wetinghouse Elec'tric Gompany, Suite 310, 1000 Westinghouse Drive, Cranberry Tornship, Pennsylvania 16066.

Attachments 3 and 4 to Enclosure 4 provide the non-proprietary vercions of this information.

Please note that the CTS marked-up pages do not include NR0-approved Amendments 278 and 289 for Unit 1 and Amendments 269 and279 for Unit 2. These amendments are notto be implemented until start up from the outage where SQN inserts tritium-producing bumable absorber rods in the core. At this time, the production of tritium in the SQN readorc has been delayed indefinitely. Therefore, the changes associated with these amendments are not included in the ITS submittal.

As described in the referenced letter, several changes are needed at SQN to permit the scheduling of preventive maintenance on the SQN 6.9 Kilovolt (kV) and 480 Volt (V)

Shutdown Boards. These changes include: 1) An IAR to allow operation with one essential

U. S. Nuclear Regulatory Cornmission Page 4 November 22,2013 raw cooling water (ERCW) pump operable per loop, 2) An LAR to allow operation with one 6.9 kV and associated 480 V shutdown boards inoperable for seven days, and 3) A plant modification to the Auxiliary ControlAir System. The LAR that will allow operation with one ERCW pump per loop has been submitted as listed in Enclosure 6. This submittal proposes the change that will allow operation with a 6.9 kV and associated 480 V shutdown boards inoperable for seven days.

TVA requests approval of the proposed license amendment by November 30, 2O14, to support irnplementation prior to the 2015 spring outage. Approval by the proposed date would also accommodate initial license operator training for the class of March 2015. TVA requests an implementation period of 180 days to accommodate completion of implementation activities.

Based on the information provided in Enclosure 2, TVA has determined that there is no significant hazards consideration associated with the proposed change and that the change is exempt from environmental review pursuant to the provisions of 10 CFR 51.22(cXg).

The SQN Plant Operations Review Committee has reviewed this proposed change and determined that operation of SQN in accordance with the proposed change will not endanger the health and safety of the public.

Additionally, in accordance with 10 CFR 50.91(bX1), WA is sending a copy of this letter and the enclosures to the Tennessee State Department of Environment and Gonservation.

lf there are any questions or if additional information is needed, please contact Mr. Clyde Mackaman at 423-7 51 -2834.

I declare under penalty of perjury that the foregoing is true and correct. Executed on this 22nd day of November 2013.

Res lly, il.w/{Kea Vic$ flresident, Nuclear Licensing Enclosures cc: see page 5

U. S. Nuclear Regulatory Commission Page 5 November 22,2013 Encfosure 1 - Contents of the Sequoyah Nuclear Plant, Units 1 and 2, I m proved Technical Specifications (lTS) S ubmlttal Enclosure 2 - SQN ITS Submittal, Volumes 1 through 16 Enclosure 3 - Licensee ldentified Changes That May Require a Formal Technical Branch Review Enclosure 4 - Reactor Trip System (RTS) and Engineered Safety Features Actuation System (ESFAS) Instrumentation Completion Times, Bypass TimBS, and Surveillance Test Interval Ertensions Based on WCAP-1 0271 , WCAP-14333, and WCAP-1 5376 Enclosure 5 - Risk Informed Evaluation of Extensions to Containment lsolation Valve Completion Times WCAP-1 5791)

Enclosure 6 - Disposition of Existing License Amendment Requests Enclosure 7 - Disposition of Generic Changes to NUREG-1431, Revision 4.O Enclosure 8 - Regulatory Commitments Enclosure 9 - List of Required Final Safety Analysis Report (FSAR)

Descriptions For TSTF-500 Enclosure 10 - Relocate Surveillance Frequencies to Llcensee Control RITS-TF Initiative 5b OSTF425) cc (Enclosures):

NRC Regional Administmtor - Region ll NRC Senior Resident Inspector- Sequoyah Nudear Plant Director, Division of Radiological Health - TennesEee State Department of Environment and Conservation

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