ML20073A381
| ML20073A381 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/13/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20073A367 | List: |
| References | |
| NUDOCS 9409200237 | |
| Download: ML20073A381 (3) | |
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NUCLEAR REGULATORY COMMISSION 2 1 E
UNITED STATES N.i v 4 /
WASHINGTON, D.C. 20555-0001
....f SAFETY EVALUATION 8Y THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 186 TO FACILITY OPERATING LICENSE NO. DPR-77 AND AMENDMENT NO. 178 TO FACILITY OPERATING LICENSE NO. DPR-79 TENNESSEE VALLEY AUTHORITY SE000YAH NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328
1.0 INTRODUCTION
By application dated September 28, 1993, the Tennessee Valley Authority (the licensee) proposed amendments to the Technical Specifications (TS) for Sequoyah Nuclear Plant (SQN) Units 1 and 2.
The requested changes would clarify operability requirements regarding the fire suppression system flow path and incorporate additional guidance into a Technical Specification (TS) action requirement for spray and/or sprinkler systems inside containment.
The licensee also proposed to delete special reporting requirements for fire detection instrumentation, fire suppression systems and fire barrier penetrations and their associated bases.
2.0 DISCUSSION The TS changes proposed by TVA are as follows:
a.
Revise Limiting Condition for Operation (LCO) 3.7.ll.l.b which governs the operability requirements for the fire suppression water system flow path.
LC0 3.7.ll.1.b currently states:
"An OPERABLE flow path capable of taking suction from the forebay and transferring the water through distribution piping with OPERABLE sectionalizing control or isolation valves to the yard hydrant curb valves, the last valve ahead of the water pressure alarm device on each sprinkler or hose standpipe, and the last valve ahead of the deluge valve on each deluge or spray system required to be OPERABLE per Specifications 3.7.11.2. and 3.7.11.4."
The proposed change to TS 3.7.ll.1.b states: "An OPERABLE flow path capable of taking suction from the forebay and transferring the water through distribution piping with OPERABLE sectionalizing control or isolation valves up to the first valve off the loop header that isolate:
(1) Spray and/or sprinkler system (s) required to be OPERABLE per Specification 3.7.11.2, or (2) Hose standpipe (s) required to be OPERABLE per Specification 3.7.11.4."
In addition to these changes, the licensee proposed incorporating an exemption to TS 3.0.4 in Action Statement (b) of 3.7.11.1.
ENCLOSURE 3 9409200237 940913 PDR ADOCK 05000327 p
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.. ' b.
A change to action statement (a) of LC0 3.7.11.2 for spray and/or-
. sprinkler systems that would provide additional guidance within.the action by deleting the requirement for maintaining continuous or hourly fire watch inside containment. The proposed change would read as i
follows: "For spray and/or sprinkler systems inside containment which are j
inoperable as a result of inoperable fire detection instrumentation, a.
continuous or hourly fire watch is not required when complying with the ACTION requirements of Specification 3.3.3.8."
c.
Delete special reporting requirements from TS action statements and their associated bases for TS 3.3.3.8 (Fire Detection Instrumentation),
TS 3.3.7.11.1 (Fire Suppression Systems), TS 3.3.7.'11.2 (Spray and/or Sprinkler Systems), TS 3.3.7.11.3 (C0 Systems), TS 3.7.11.4 (Fire Hose 2
Stations), and 3.7.12 (Fire Barrier Penetrations).
3.0 EVALUATION The licensee's proposed change to LC0 3.7.11.1.b clarifies'the boundary for an operable flow path by establishing the boundary at the first valve off the header (yard loop or building loop) leading to the particular end device (s)
(spray and/or sprinkler system, or hose standpipe) rather than the last' valve; ahead of.the particular end device (s).
The licensee's proposed request'would 3
establish appropriate flow path operability boundaries that would result in a more appropriate application of TS LCOs for SQN's fire protection systems.
The change is, therefore, acceptable.
The proposed addition of the exemption to TS 3.0.4 is consistent with the guidance provided in GL 87-09, " Sections 3.0 and 4.0 of the Standard Technical Specifications (STSs) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements," June 4, 1987.
This guidance states:
"For an'LC0 that-has action requirements permitting continued operation for an unlimited period of time, entry into an operational mode or other specified condition of operation should be permitted in accordance with these action requirements." Accordingly, the proposed change is acceptable.
The licensee's proposed change to the action statement (a) of LCO 3.7.11.2.
provides the. clarification and guidance to the operators for'a specific case involving-inoperable fire detection instrumentation'inside. containment.
SQN 1
LC0 3.3.3.8 already contains the operability requirements for' fire detection instrumentation located inside and outside containment.
In the event that the fire detection instrumentation becomes inoperable, Action Statement (a)'of LC0 3.3.3.8 requires monitoring the containment air temperature at least once every hour in the affected locations and precludes the need to establish.a hourly fire watch inside containment.
The licensee's proposed change to action statement (a) of LC0 3.7.11.2 provides similar' actions for an inoperable spray and/or sprinkler-system located inside containment and is,
.i therefore, acceptable.
The licensee's request 'to delete the special reporting requirements _ related to l
fire detection instrumentation,. fire suppression systems and fire barrier penetration'was reviewed against the guidance provided in Generic Lett'r e
(GL) 86-10, " Implementation of Fire Protection' Requirements", April 24, 1986, i
and GL 88-12, " Removal of Fire Protection Requirements from Technical 6
-Specifications," August ~2,.1988.
GL 86-10 requested that the licensee incorporate the NRC approved fire protection program in its Final Safety q
a g 1 Analysis Report (FSAR) for the facility and specified a standard license (GL) condition.
GL 88-12 addressed the elements a licensee should include in a license amendment request to remove the fire protection requirements from the plant TS.
The licensee has not applied for a license amendment in accordance with GLs 86-10 and 88-12.
In addition, the special reports required by the existing TS provide some measure for the staff to (a) assess the impacts that the reportable conditions have on matters affecting the fire protection program, and (b) ensure that threats to the public health and safety as a result of fire protection program weaknesses are minimized.
Because of these reasons, the request to remove the special reporting requirements is denied.
The licensee should resubmit its proposed amendment regarding the reporting requirements with its proposal-to incorporate the fire protection program into the FSAR in accordance with GLs 86-10 and 88-12.
4.0 CONCLUSION
Based on the above evaluation, the staff concludes that the proposed changes to TS LC0 3.7.11.1.b and TS LC0 3.7.11.2 are acceptable.
However, the proposed changes to delete LC0's 3.7.11.1, 3.7.11.2, 3.7.11.3, 3.7.11.4, 3.7.12, and 3.3.3.8, concerning special reporting requirements, are not acceptable.
Therefore, this part of the licensee's request is denied.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Tennessee State official was notified of the proposed issuance of the amendments.
The State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.
The NRC 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 the amendments involve no significant hazards consideration, and.there has been no public comment on such finding (58 FR 59757). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: '(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 Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Amarjit Singh Dated: September 13, 1994
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