ML20058F697
| ML20058F697 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/02/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20058F694 | List: |
| References | |
| NUDOCS 9011090069 | |
| Download: ML20058F697 (4) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION 3
8 WASHINGTON, D. C. 20566
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r ENCLOSURE 3 l
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION' SUPPORTING AMENDMENT NO.147 TO FACILITY OPERATING LICENSE NO. OPR-77 i
I AND AMEN 0 MENT NO.133 TO FACILITY OPERATING LICENSE NO. OPR-79 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-327 AND 10-328
1.0 INTRODUCTION
By letters dated May 4, 1990 and October 2, 1990,'the Tennessee Valley Authority (TVA) proposed to modify'Section 3/4.5.1, Accumulators, of the Sequoyah Nuclear Plant, Units 1 and 2 Technical Specifications (TSs).
The proposed changes are to revise the requirements in TS 3/4.5.1.1, Cold Leg Injection Accumulators, to (1) delete Action Statements "c" and "d" for Limiting Condition for Operation (LCO) 3.5.1.1 and the associated footnote and (2) add a footnote to Surveillance Requirement (SR) 4.5.1.1.2.
l In its letter dated August 11, 1989, the staff issued amendments which added Action Statements "c" and "d" to TS 3/4.5.1.1 for both units. - The staff. stated that these action statements would be effective until the restart of Unit 2 i
l from the Unit 2 Cycle 4 refueling outage and requested TVA to propose changes i
l to TS 3/4.5.1.1 before that date.
This outage began in September 1990 and is scheduled to end in early November 1990.
The purpose of TVA's letter is to propose changes to TS Section 3/4.5.1.1 to remove the need'for Action State-ments "c" and "d".
4 The proposed changes in the' letter' dated May 4, 1990 are the technical specifi-cations proposed by Westinghouse Owner's Group (WOG) to the staff through the WOG MERITS Program for the cold leg injection accumulators.
Because the Action l
Statements "c" and "d" for both units expire at the restart of Unit 2 Cycle 4
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refueling outage, approximately November 4,1990, TVA proposed to add a foot-1 note to SR 4.5.1.1.2 to remove the need for Action Statements "c" and "d "
This proposal in TVA's letter dated October 2,-1990 has the same effect on i
TS 3/4.5.1.1 as the proposed changes in the TVA's application dated May 4, l
1990.
The October 2, 1990 letter, therefore, does not affect the substance of l
the proposed action and the no significant hazards consideration finding published in the Federal Register Notice (55 FR 24005).on June 13, 1990 and does not change the staff's initial determination of no significant' hazards
_l consideration in that notice.
9011090069 902102 DR ADOCK 05000327
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1 2.0 EVALUATION TVA has proposed to add a footnote to SR 4.5.1.1.2 on the required demonstra-tion of the operability of the two water level and two pressure instrumentation i
channels for each cold leg injection accumulator.
There are four accumulators for each unit.
These four instrument channels are the only instrument channels l
for the cold leg injection accumulators.
The footnote states that each accumulator is operable if at least one level channel and one pressure channel j
are operable.
The purpose of the proposed footnote is to define the required reumber of instrumentation channels needed to be operable for the accumulators to be con--
sidered operable. With SR 4.5.1.1.2 requiring each channel to be demonstrated operable and LCO 3.5.1.1 not defining how many channels had to be operable, the
'j assumption must be that all the channels had to be operable for the accumula-tors to be considered operable.
The basis for the amendments for Units 1 and 2 which were issued on August 11, 1989 was that this was too strict an interpreta-tion of TS 3/4.5.1.1.
TVA has proposed that only one level channel and one pressure channel was required to be operable for each accumulator to be con-sidered operable.
TVA stated the proposed footnote to SR 4.5.1.1.2 is justified because (1) the accumulator level and pressure instrumentation only perform control functions
- and do not perform a protection function and (2) LCO 3.5.1.1 does not address the instrumentation monito. Ing the accumulator level and pressure. The LCO ensures the operability of the cold leg injection accumulator; it does not ensure the operability of the accumulator instrumentation because the LCO does not include this instrumentation.
The operability of the instrumentation l
is indirectly controlled by SR 4.5.1.1.1.a.1 by the required verification of accumulator level and pressure, which must be performed at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> to comply with the LCO.
TVA stated that similar situations exist in the TSs for other parameters, such as the refueling water storage tank water ~1evel and temperature, where the parameters are required in the TSs to be verified within limits but the instrumentation is not subject to a specific SR on the cor.e*>ility of the instrumentation themselves.
TVA further stated that the operability of the instrumentation is also ensured by the instrumentation l
calibration performed on the channels.
TVA also proposed to delete the Action Statement "c" and "d" for LCO:3.5.1.1 and the associated footnote which states that these action statements'are in effect until the restart of Unit 2 from the Unit 2 Cycle 4 refueling outage.
TVA stated that based on the proposed addition of a footnote to SR 4.5.1.1.2 for the level and pressure instrumentation, the Action Statements "c" and "d" of LCO 3.5.1.1 and the associated footnote should be deleted.
The proposed footnote for SR 4.5.1.1.2 would reduce requirements in TS 3/4.5.1.1 in that both pressure channels and level channels would not be required for the accumulators to meet LCO 3.5.1.1.
SR 4.0.3 states that failure to perform a surveillance requirement (e.g., not meet the surveillance requirement) i
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constitutes non-compliance with the operability requi ements of a limiting con-dition for operation; therefore, not meeting SR 4.5.1.1.2 on any of i
the accumulator pressure and level channels currently means the unit would be in noncompliance with LCO 3.5.1.1 on the operability of the accumulators and the accumulators would be considered inoperable.
The proposed footnote would allow one pressure and one level channel to be inoperable without an accumula-tor being declared inoperable.
.i The staff agrees that only one pressure channel and one level channel needs to be operable for the accumulators to be considered operable.
This is because these instrumentation channels only indicate the pressure :nd water level in an accumulator as a means to verify compliance with the LC0; the instrumentation does not take an action or perform a protective function.
This situation exists in other specifications on safety-related equipment at Sequoyah in the TSs.
Therefore, the staff concludes that adding the footnote to SR 4.5.1.1.2 is acceptable.
With the deletion of SR 4.5.1.1.2, the Action Statements "c" and "d" serve no purpose in TS 3/4.5.1.1 and should be de'eted.
Therefore, the staff concludes that deleting Action Statements "c" and "d" and the associated footnote are acceptable.
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3.0 ENVIRONMENTAL CONSIDERATION
These amendments involve a change to a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes to the surveillance requirements. The staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure.
The Commission has previously issued a proposed finding that these amendments-involve no significant hazards consideration and there has been no public comment on such finding.
Accord-ingly, the amendments meet the eligibility criteria for categorical exclusion set torth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement nor environmental assessment need be prepared in connection with the itauance of the e amendments.
4.0 CONCLUSION
i The Commission made a proposed determination that the amendment involves no significant hazards consideration which was published in.the Federal Reaister (55 FR 24005) on June 13, 1990 and consulted with the State of Tennessee.
No public comments were received and the State.of Tennessee did not have any comments.-
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- ' 's The staf f has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not ae endangered by operation in the proposed manner, and (2) such activities will be conducted in comp),ance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security nor to the health and safety of the public.
Principal Contributor:
J. Donohew Dated: November 2, 1990 i
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