ML20082E574

Proposed Tech Specs,Adding New LCO 3.0.6 That Allows Equipment Removed from Svc or Declared Inoperable to Be Returned to Svc Under Administrative Control to Perform Testing Required to Demonstrate Operability

ML20082E574
Person / Time
Site:	Sequoyah
Issue date:	04/06/1995
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20082E565	List: ML20082E562 ML20082E574
References
NUDOCS 9504110267
Download: ML20082E574 (17)

Text

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ENCLOSURE 1 PROPOSED' TECHNICAL SPECIFICATION'(TS) CHANGE ~ 1 i

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.SEQUOYAH NUCLEAR PLANT (SON) UNITS.1 AND 2.

DOCKET NOS. 50-327 AND 50-328 (TVA-SON-TS-95-02)-

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-I LIST OF AFFECTED PAGES ' i Unit 1 j 1

3/4 0-1 3/4 3-22 i B 3/4 0-3 Unit 2 1 3/4 0-1 3/4 3-22'.

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9504110267 950406' ' T+

PDR ADOCK.05000327 -,

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3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS

-3/4.0 APPLICABILITY -

LIMITING CONDITION FOR OPERATION 3.0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a Specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Conditions for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in a MODE in which the Specification does not apply by placing it, as applicable, in:

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

PP Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Condition for Operation.

Exceptions to these requirements are stated in the individual Specifications.

3.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the conditions for the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION requirements. This provision shall not prevent passage through OPERATIONAL MODES as required to comply with ACTION requirements. Exceptions to these requirements are stated in the individual Specifications.

3.0.5 When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system (s), subsystem (s),

train (s), component (s) and device (s) are OPERABLE, or likewise satisfy the requirements of this Specification. Unless both conditions (1) and (2) are satisfied, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> action shall be initiated to place the unit in a MODE in which the applicable Limiting Condition for Operation does not apply by placing it as applicable in:

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

4 4c+f+ sat. ion-i ble in MODES 5 or 6.

& ADD .TA8Ex'r A (Amtem)

SEQUOYAH - UNIT 1 3/4 0-1 September 17, 1980

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INSERT A 3.0.6 Equipment removed from service or declared inoperable to comply-with ACTIONS may be returned to service under administrative control solely _

to perform testing required to demonstrate its OPERABILITY or the

' OPERABILITY of other equipment. This'is an exception to LCO 3.0.1 and 3.0.2 for the system returned to service under administrative control to-perform the testing required to demonstrate OPERABILITY.

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Trip. function'may be bypassedLin'this MODE below:P-11-(Pressurizer'

,- .ggPressure. Block:of Safety ~ Injection) setpoint. . . .

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- 1 Trip function automatically blockedLabove P-11 and may be' blocked below: R1'451 4- ,' - gggwhen'~ Safety: Injection _on-Steam Line Pressure-Low is not blocked.. .

The channel (s) associated with the protective functions' derived from;the.  ?

,. 2 out of service Reactor Coolant' Loop shalif be placed in the tripped: mode.  :

m. The. provisions' of Specification 3.0.4 'are not! applicable.  !

H  : ACTION STATEMENTS ACTION 15 - With the number of OPERABLE Channels one less than the Total  :

Number of Channels,'be in at least' HOT. STANDBY within'12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> *

, and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />;:however,:one .

channel may be. bypassed for up to_4 hours for_ surveillance. . R145 v testing per Specification 4.3.2.1.1 provided.the other. channel is OPERABLE. <

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' ACTION 16 - Deleted.  :

ACTION 17 - -With the number of-OPERABLE Channels'one:less than.the . .. 1 Total Number of Channels, STARTUP and/or POWER 10PERATION'may.' R145:i proceed provided'the following conditions are._' satisfied: .

a. The inoperable channel is placed in the tripped- o condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

b. The Minimum Channels OPERABLE-requirementsh is" met

• however,:the inoperable channel may be bypassed for; up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for: surveillance. testing;of.other. ,

-hanaQ ';i,pdf4qt,ien 4.'4 l ACTION 18'- With the number of OPERABLE Channels one less than the Total ,

t Number.of Channels, operation may proceed provided the I un wHeau 6  ;

inoperable channel-is.placed in the bypassed condition and.  ;

the Minimum Channels OPERABLE requirement is met; oneLaddi- R145:

tional channel may.be bypassed for'up. to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for 1 surveillance testing per Specification.4.3.2.1.1. 1 '

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ACTION 19 - With less than the Minimum Channels OPERABLE, operation may continue provided the containment purge. supply and exhaust lRi valves are maintained closed. 7; i

ACTION 20 - With the number of OPERABLE Channels one less than the Total: R Number.of Channels, restore the inoperable channel to OPERABLEF :I status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or beiin at least HOT STANDBY within the

next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30. hours.

i SEQUOYAH_- UNIT l' 3/4 3-22 Amendment No. /6r3'//yfy,168 i June 25, 1993 .)

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APPLICABILITY BASES -

i instead, provided the other specified conditions are satisfied. In this case, l this would mean that for one division the emergency power source must be '

OPERABLE (as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6, Specification 3.0.5 is not applicable, and thus the individual ACTION statements for each ap licable Limiting Condition for Operation in

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vides that surveillance activities necessary to insure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL MODES or other onditions for which the Limiting Conditions for Operation are applicable. Provisions for additional surveillance activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Requirements.

Surveillance Requirements for Special Test Exceptions need only be performed when the Special Test Exception is being utilized as an exception to an individual Specification.

4.0.2 Specification 4.0.2 establishes the limit for which the specified time I interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate surveillance sche-duling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g. , transient canditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are per ormed at >

each refueling outage and are specified with an 18 month surveillance iterval.  :

It is not intended that this provision be used repeatedly as a conven w nce to R16f extend surveillance intervals beyond that specified for surveillances that are not performed during refueling outages. The limitation of Specification 4.0.2 is based on engineering judgement and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Requirements. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

4.0.3 This specification establishes the failure to perform a Surveillance.,

Requirement within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, as a condition that constitutes a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation.

Under the provisions of this specification, systems and components are assumed to be OPERABLE when Surveillance Requirements have been satisfactorily performed within the specified time interval. However, nothing in this provision is to be construed as implying that systems or components are R82 OPERABLE when they are found or known to be inoperable although still meeting the Surveillance Requirements. This specification also clarifies that the ACTION requirements are applicable when Surveillance Requirements have not been completed within the allowed surveillance interval and that the time limits of the ACTION requirements apply from the point in time it is SEQUOYAH - UNIT 1 B 3/4 0-3 Amendment No. 78, 162 August 13, 1992

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3.0.6 LCO 3.0.6 establishes the allowance for restoring equipment to' service-

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under administrative' controls when it has been removed from service or  !

declared inoperable to comply _ with ACTIONS. The sole purpose of this -

~ Specification is to provide' an exception to LCOs 3.0.1 and 3.0.2 (e.g., to

not comply,with the. applicable Required Action [s]) to allow the ,

performance of SRs to demonstrate:

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a .= The OPERABIOTY.of the' equipment being returned'to service) or

b. The OPERABILITY of other equipment.

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Th'e administrative controls ensure the time the equipment is returned to.~

service in conflict with the requirements of the ACTIONS is limited to the time absolutely necessary to perform the' allowed SRs. This Specification does not provide time to perform any other preventive or corrective maintenance.

An example of demonstrating the OPERABILITY of_the equipment being  ;

returned to service is reopening a containment isolation valve that has - i been closed to comply with Required Actions and must be reopened to 2 perform the SRs. I An example of demonstrating the OPERABILITY of other equipment is .

taking an inoperable channel or trip system out of the tripped condition to-  :

prevent the trip function from_ occurring during _the performance of an SR on another channelin the other trip system. A similar example of demonstrating the OPERABILITY of other equipment is taking an inoperable channel or trip system out of the tripped condition to permit tiie logic to function and indicate the appropriate response during the performance of an SR on another channelin the same trip system.

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3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/41.0' APPLICABILITY LIMITING CONDITION FOR OPERATION

3. 0.1 Compliance with the Limiting Conditions for Operation contained in the succeeding Specifications is required during the OPERATIONAL MODES or other conditions specified therein; except that upon failure to meet the Limiting Conditions for Operation, the associated ACTION requirements shall be met.

3.0.2 Noncompliance with a Specification shall exist when the requirements of the Limiting Condition for Operation and associated ACTION requirements are not met within the specified time intervals. If the Limiting Conditions for Operation is restored prior to expiration of the specified time intervals, completion of the ACTION requirements is not required.

3.0.3 When a Limiting Condition for Operation is not met, except as provided in the associated ACTION requirements, within one hour action shall be initiated to place the unit in a MODE in which the Specification does not apply by placing it, as applicable, in:

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Where corrective measures are completed that permit operation under the ACTION requirements, the ACTION may be taken in accordance with the specified time limits as measured from the time of failure to meet the Limiting Conditior, for Operation. Exceptions to these requirements are stated in the individual '

Specifications.

3.0.4 Entry into an OPERATIONAL MODE or other specified condition shall not be made unless the conditions for the Limiting Condition for Operation are met without reliance on provisions contained in the ACTION requirements. This provision shall not prevent passage through OPERATIONAL MODES as required to comply with ACTION requirements. Exceptions to these requirements are stated in the individual Specifications. ,

3.0.5 When a system, subsystem, train, component or device is determined to be inoperable solely because its emergency power source is inoperable, or solely because its normal power source is inoperable, it may be considered OPERABLE for the purpose of satisfying the requirements of its applicable Limiting Condition for Operation, provided: (1) its corresponding normal or emergency power source is OPERABLE; and (2) all of its redundant system (s),

subsystem (s), train (s), component (s) and device (s) are OPERABLE, or likewise ,

satisfy the requirements of this Specification. Unless both conditions (1) and (2) are satisfied, within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> action shall be initiated to place the unit in a MODE in which the applicable Limiting Condition for Operation does not apply by placing it as applicable in:

1. At least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />,

2. At least HOT SHUTDOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, and

3. At least COLD SHUTDOWN within the subsequent 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

This S ecification is not applicable in MODES 5 or 6.

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INSERT A 3.0.6 . Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the.

OPERABILITY of other equipment. This is an exception to LCO 3.0.1 and 3.0.2 for the system returned to service under administrative control to ,

perform the testing required to demonstrate OPERABILITY.

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! TABLE. NOTATION e

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' fTrip function may be bypassed in.this MODE below P-11 (Pr.essurizer 4

, . Pressure Block of Safety-Injection)-setpoint. i

,, Trip function automatically blocked above P-11 and may be blocked below-R132-gggP-11'when Safety. Injection on Steam Line Pressure-Low is not blocked. .. ,

The channel (s) associated with the protective functions. derived from..the: 1 out of service Reactor Coolant. Loop shall. be placed in .the tripped mode. j The provisions of Specification 3.0.4 are not applicable. -!

-i ACTION STATEMENTS .

ACTION 15 - With.the number of OPERABLE Channels one less than the' Total' Number of Channels, be in HOT. STANDBY within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and in lR132 COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />; however,'one channel may be bypassed'for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing per' Specification 4.3.2.1.1 provided the'other channel lR is OPERABLE. j ACTION 16 - Deleted.

R132

' ACTION 17 - With the number of OPERABLE Channels one'1ess than the Total Number of Channels, STARTUP and/or. POWER OPERATION may a proceed provided the following conditions are satisfied: j

a. -The inoperable channel-is placed in the-tripped condition within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. j

b. The Minimum Channels OPERABLE requirements-is' met; j

-however, the inoperable channel may be' bypassed'for a

.up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for surveillance testing of other- ,

on 4.3 _

f ACTION 18 - With the number of 0PERABLE Channels-one less than the-Total .

Number of Channels, operation may proceed provided the' ' OWJN l.a l

inoperable channel is placed in the bypassed condition and Ha" '

the Minimum Channels OPERABLE' requirement is met; one addi.- R132!

tional channel may be bypassed for up to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> for )

surveillance testing per Specification 4.3.2.1.1.

ts ACTION 19 - With less than the Minimum Channels OPERABLE,. operation may continue provided-the' containment purge supply and exhaust valves are maintained closed. lRI ACTION 20 - With the number of OPERABLE Channels one less than the Total.

Number of Channels, restore the inoperable channel to OPERABLE: .

status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> or be in at least HOT STANDBY within the -

next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

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SEQUOYAH - UNIT 2 3/4 3-22 Amendment-No. 55/,/132, 158 June 25, 1993 j l

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.. _ _ _ - _ _ _ . . _ . _ _ . _ _ _ . . .J

S BASES 3.0.5 (C'ontinued) specified conditions are satisfied. In this case, this would mean that for one division the emergency power source must be OPERABLE ( as must be the components supplied by the emergency power source) and all redundant systems, subsystems, trains, components and devices in both divisions must also be OPERABLE. If these conditions are not satisfied, action is required in accordance with this specification.

In MODES 5 or 6, Specification 3.0.5 is not applicable, and thus the individual ACTION statements for each applicable Limiting Condition for Operation in se mu .

> Aco tw &

on provides that surveillance activities necessary to insure the Limiting Conditions for Operation are met and will be performed during the OPERATIONAL MODES or other conditions for which the Limiting Conditions for Operation are applicable. Provisions for additional surveil-lance activities to be performed without regard to the applicable OPERATIONAL MODES or other conditions are provided in the individual Surveillance Require-ments. Surveillance Requirements for Special Test Exceptions need only be

. performed when the Special Test Exception is being utilized as an exception to an individual specification.

4.0.2 Specification 4.0.2 establishes the limit for which the specified time interval for Surveillance Requirements may be extended. It permits an allowable extension of the normal surveillance interval to facilitate sur-veillance scheduling and consideration of plant operating conditions that may not be suitable for conducting the surveillance; e.g., transient conditions or other ongoing surveillance or maintenance activities. It also provides flexibility to accommodate the length of a fuel cycle for surveillances that are performed at each refueling outage and are specified with an 18-month surveillance interval. It is not intended that this provision be used repeatedly as a convenience to extend surveillance intervals beyond that R152 specified for surveillances that are not performed during refueling outages.

The limitation of Specification 4.0.2 is based on engineering judgement and the recognition that the most probable result of any particular surveillance being performed is the verification of conformance with the Surveillance Require-ments. This provision is sufficient to ensure that the reliability ensured through surveillance activities is not significantly degraded beyond that obtained from the specified surveillance interval.

4.0.3 This specification establishes the failure to perform a Surveillance Requirement within the allowed surveillance interval, defined by the provisions of Specification 4.0.2, as a condition that constitutes a failure to meet the OPERABILITY requirements for a Limiting Condition for Operation. Under the R69 provisions of this specification, systems and components are assumed to be OPERABLE when Surveillance Requirements have been satisfactorily performed within the specified time interval. However, nothing in this provision is to be construed as implying that systems or components are OPERABLE when they are found or known to be inoperable although still meeting the Surveillance Requirements. This specification also clarifies that the ACTION requirements are applicable when Surveillance Requirements have not been completed within the allowed surveillance interval and that the time limits of the ACTION requirements apply from the point in time it is identified that a surveillance has not been performed and not at the time that the allowed surveillance interval was exceeded. Completion of the Surveillance Requirement within the SEQUOYAH - UNIT 2 B 3/4 0-3 Amendment No. 69, 152 August 13, 1992

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1 INSERT B-3.0.61 LCO 3.0.6' establishes the allowance for restoring equipment to service:

- under administrative controls when it has been removed from service or=

, # ' declared inoperable to comply with ACTIONS.: The sole purpose of this '

Specification is to provide an' exception'to LCOs 3.0.1 and 3.0.2 (e.g'./ to-

, . not comply with the applicable Required Action [s]) to allow the--

performance of SRs to demonstrate:

- a .' The OPERABILITY of the' equipment beingl returned to service; or

' b. The OPERABILITY.of other equipment.

The administr'ative controls ensure the time the equipment is returned to <

service in conflict with the requirements of the ACTIONS is limited to the-time absolutely necessary to perform the allowed SRs. This Specification .

does not provide time to perform any other preventive or. corrective >

maintenance. .

b An example of demonstrating the OPERABILITY of the equipment being returned to service is reopening a containment isolation valve that has been closed to comply with Required Actions and must be reopened to perform the SRs.

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'An example of demonstrating the OPERABILITY of other equipment is

.. taking an inoperable channel or trip. system out of the tripped condition to- -

i- , prevent the trip function from occurring during the performance'of an SR on another channel in the other trip system. A similar example of i demonstrating the OPERABILITY of other equipment is taking an inoperable channel or' trip system out of the tripped condition to' permit

- the logic to function and indicate the appropriate response during the ,

performance of an SR on another channelin the'same trip system.

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" ENCLOSURE 2 '

PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE ,

SEQUOYAH NUCLEAR PLANT (SON) UNITS l AND 2 DOCKET NOS, 50-327 AND 50-328 -

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(TVA-SON-TS-95-02)

DESCRIPTION AND JUSTIFICATION FOR ADDITION OF PROVISIONS FOR OPERABILITY TESTING 1

AND TIME FOR ACHIEVING BYPASS CONDITIONS -

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' Description of Chanae i TVA proposes to modify the Sequo~yah Nuclear Plant:(SON).UnitsL1 and 2 -

utechnical specifications (TSs) by adding a new Limiting Condition for Operation (LCO) 3.0.6. This revision allows equipment removed from service or declared- R inoperable to be returned to service under administrative control solely to' -l 4

' perform testing required to demonstrate operability. This provision is ap'plicable ' l

- for operability testing.of the inoperable equipment or other equipment that-requires the~ inoperable feature to be in service for testing. 'This new LCO is an:

-exception to the requirements of TSs 3.0.1 and 3.0.2. -This revision makes an.

addition to the requirements of_ Action 18 of Table 3.3-3 for the time interval to place an inoperable channelin.the bypass condition. The present wording, that does not define a time to place the~ channel in_ bypass; will be revised to require l completion of this action within six hours. Bases Section 3.0.6 will be added to provide the basis for the operability testing exception described above.

Reason for Chanae The present TS requirements could be interpreted to prevent placing equipment l in service to verify operability and this requirement could create problems in performing some operability surveillances to return equipment to service. .j However,' performance of surveillances under the' proposed revision has been i utilized in the past with the understanding that the intent of TS 3.0.1 and 3.0.2 - ,

is consistent with this position. TVA is pursuing the documentation of this position as a permanent TS change to eliminate possible controversy in the ,

acceptability of utilizing this allowance in the future.

The_ addition of a specified time interval for placing a channel in the bypass condition is being requested to eliminate confusion caused by a lack of a defined i duration. TVA's understanding has been that Action 18 had been written 4 without a specified time interval because placing the channel in bypass was not necessary to ensure safety functions. TVA believes that this action was  ;

intended to allow the licensee to place the plant in a configuration that would +

, minimize the potential for equipment damage (e.g., containment spraydown or <

premature containment sump swapover), even though a slight reduction in safety function actuation may result. However, the latest version of standard TSs (NUREG-1431) indicates that the concern for maintaining the integrity.of- '

safety equipment is more important than the reduction in safety function

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actuation capability because sufficient redundancy is designed into the actuation -i functions. For this reason, as well as the benefit of defining when the bypass condition should be met, the addition of a time interval to place affected channels in bypass has been proposed.

, t The proposed changes will also provide consistency with the recommendations -

of NUREG-1431.

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- Justification for'Chanoeg

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LThe provisions of the proposed LCO_3.0.6 to' place inoperable' equipment in-

' service to facilitate TS required testing for short durations provides more benefit from an operable safety equipment consideration than the brief ' duration ~that' deviates from the TS action requirement. It would be veryLdifficult to maintain-the ' operability of TS functions without this position. This change is consistent-with the_ provisions provided in NUREG-1431,' and the bases section has been

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added to ensure' consistent compliance with the intent of this allowance.

The defined time interval for placing's channel in;the bypass condition is more-restrictive than the present requirement that is undefined. By requiring the bypass condition to be achieved within six hours, the potential for. inadvertent -

damage to. safety-related equipment is minimized. The safety functions'affected by the proposed change are the containment spray, containment isolation, and steam line iso'ation actuations on' high' containment pressure; and:the refueling water storage tank (RWST) and containment sump level channels that provide the automatic switchover from the RWST to containment sump. Implementing a specified time for achieving the bypass condition does not impact nuclear safety '

as no time is currently specified in Action 18. The reduction of channels to actuate the related functions is preferred to the equipment damage' potential because sufficient redundancy is provided by the remaining operable channels to -

ensure safety function actuation. The six-hour time limit for achieving the-bypass condition is consistent with NUREG-1431.

Environmental Imoact Evaluation The proposed change does not involve an unreviewed environmental question because operation of GON Units 1 and 2 in accordance with this change would not:

1. Result in a significant increase in any adverse environmentalimpact previously evaluated in the Final Environmental Statement (FES) as modified by NRC's testimony to the Atomic Safety and Licensing Board, supplements to the FES, environmentalimpact appraisals, or decisions of the Atomic Safety and Licensing Board.

2. Result in a significant change in effluents or power levels.

3. Result in matters not previously reviewed in the licensing basis for SON that may have a significant environmentalimpact.

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i ENCLOSURE 3 '

y PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT (SON) UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 1

2 (TVA-SON-TS-95 02)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION '

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& Significant Hazards Evaluation

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.TVA- has' evaluated.the proposed technical specification (TS)Lchange' and has. 'l determined that it does not represent a signific'antLhazards consideration based- )

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Lon criteria established in.10 CFR 50.92(c). ' Operation of Sequoyah Nuclear Plant 0 (SON)'in accordance with_ the proposed amendment will not: j j

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1. Involve a.significant increase in the probability or consequences of an- ,

accident previously evaluated. 1

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' The addition of the' exception to TSs 3.0.1 and 3.0.2 and the definition for the time to place a channel in bypass will not change plant equipment or the .

operating practices at SON.' The exception will allow testing to be performed with inoperable equipment returned to service under - 3 administrative controls, but will not change functions. The function will be j available from other redundant channels during the brief durations that the . j new provision would be utilized. The specified time interval to' achieve a  :

bypass condition will clarify the implementation of the action requirement. ,

with the affected functions remaining available through the redundant  ;

operable channels. This clarification does not change the intent of the ~  ;

action but does set the previously undefined time interval. . l The proposed change affects actions associated with the actuation of functions to mitigate accidents and are not the source of'an' accident.

-Therefore, the probability.of an accident is not increased. The affected functions provide accident mitigation functions and the proposed revisionsL  :

serve to ensure equipment can be maintained in required conditions within acceptable time intervals and administrative controls.1The brief periods -  !

. utilized for the TSs 3.0.1'and 3.0.2 exception will not significantly affect the -

accident mitigation capabilities because of the availability of redundant; equipment. In addition, the benefit of performing operabil!ty testing to . ,

return equipment permanently to service or to maintain the operability of l other equipment outweighs this' slight reduction in safety function actuation redundancy. Therefore, the proposed change will not significantly increase the consequences of an accident. .I j

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2.- Create the possibility of a new 'or different kind of accident from any previously analyzed.

~ The proposed changes affect functions utilized to mitigate an accident and are not the source of an accident. The' exception provides reasonable flexibility to maintain equipment operability and the bypass time interval reduces the potential for damage to safety related equipment. Because plant functions are not changed as a result of this request the possibility of a new or different kind of accident is not created.

3. Involve a significant reduction in a margin of safety.

The proposed change does not alter setpoints or operating considerations that maintain the margin of safety for SON. These changes provide needed flexibility to perform TS required testing and clarific~ations for implementing action requirements. These changes will slightly affect the redundancy of the affected safety functions but provide greater benefit for maintaining equipment in an operable condition. Therefore, the margin of safety-provided by the affected equipment has not changed and the proposed change will not result in a reduction.

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