ML20083D667

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Provides Justification for Proposed Amend to Licenses DPR-77 & DPR-79 Re Completion on Mods Associated w/post-accident sampling,NUREG-0737,Item II.B.3.Approval Requested by 840106 to Preclude Possible Impact on Cycle 2 Refueling Outage
ML20083D667
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 12/21/1983
From: Mills L
TENNESSEE VALLEY AUTHORITY
To: Adensam E
Office of Nuclear Reactor Regulation
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM NUDOCS 8312280189
Download: ML20083D667 (3)


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TENNESSEE VALLEY AUTHORITY d

CHATTANOOGA. TENNESSEE 374ol 400 Chestnut Street Tower II December 21, 1983 Director of Nuclear Reactor Regulation Attention:

Ms. E. Adensam, Chief Licensing Branch No. 4 Division of Licensing U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Ms. Adensam:

In the Matter of

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Docket No.

50-327 Tennessee Valley Authority

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50-328 By my November 23, 1983 letter to you, we requested NRC approval of a proposed license amendment for the Sequoyah Nuclear Plant, units 1 and 2.

l The proposed license amendment would allow completion of the modification associated with Postaccident Sampling (PAS) in order to comply with the operating licensa conditions, 2.C.(23).F for unit 1 and 2.C.(16).g for unit 2 and the requirements of Item II.B.3 of NUREG-0737 The details of the design and compliance with the design criteria of NUREG-0737 were provided in the November 23, 1983 letter. Enclosed is the justification for approval of the proposed license amendment along with the significant hazards consideration determination pursuant to 10 CFR 50.92.

NRC approval is needed on or before January 6,1984 to preclude a possible j

impact on the unit 1, cycle 2 refueling outage.

If you have any questions concerning this matter, please get in touch with Jerry Wills at FTS 858-2683 Very truly yours, TENNESSEE VALLEY AUTHORITY g

L. M. Mills, Ma' nager Nuclear Licensing Sworn d subscrib before me d

this ay of A. 1983 as/A %. ')MJk Notiary Public

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My Commission Expires 7 Enclosures U.S. Nuclear Regulatory Commission (Enclosures) cc:

Region II Attn:

Mr. James P. O'Reilly Administrator Mg 101 Marietta Street, NW, Suite 2900 1

Atlanta, Georgia 30303 1

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B312280189 831221 1983-TVA SOTH ANNIVERSARY DR ADOCK 05000 2 An Equal Opportunity Employer

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ENCLOSURE JUSTIFICATION FOR PROPOSED LICENSE AMENDMENT SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 POSTACCIDENT SAMPLING The operating license conditions, 2.C.(23).F for unit 1 and 2.C.(16).g for unit 2, require TVA to " complete the corrective actions" necessary for Postaccident Sampling, Item II.B.3 of NUREG-0737. The details of the design, and of compliance with the NRC criteria specified in NUREG-0737, were provided in the November 23, 1983 letter from L. M. Mills to E. Adensam.

The facility is capable of obtaining designated liquid samples and gas samples from the reactor coolant system, both during and after a postulated accident. The facility is designed to protect employees assigned to collect and handle the samples taken from the reactor coolant system. The system has been designed in accordance with the applicable design criteria and standards. The system is designed so that operation of the system will not degrade existing plant and equipment. The effects of a postulated accident, which would result in release to the PAS area, would be mitigated by the PAS ventilation system which is similar to the Auxiliary Building gas treatment system (ABGTS). The PAS lines which penetrate the containment are provided with redundant containment isolation valves.

Because installaticn of the PAS systen is a condition of amch unit's operating license, because the PAS system has been designed and installed in accordance with the applicable design criteria and standards, and because the operation of the PAS system doec not represent a significant hazards consideration, utilization of this system is justified. A copy of the significant hazards consideration determination is attached.

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SIGNIFICANT HAZARDS CONSIDERATIONS 1.

Is the probability of an occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report significantly increased?

The addition of the Postaccident Sampling (PAS) system required by NUREG-0737 requires installation of equipment that has not been previously analyzed in the Final Safety Analysis Report (FSAR). The system is designed such that operation will not degrade existing plant and equipment. The PAS ventilation design is consistent with and similar to other ventilation systems which mitigate the effects of any release from a TID-14844 source, and therefore, there is no significant increase ia probabili.ty of occurrence or consequences of an accident.

2.

Is the possibility for an accident or malfunction of a different type than evaluated previously in the safety analysis report created?

The PAS system has been designed in accordance with the applicable design criteria and standards. The effects of a postulated accident which would result in release to the PAS area would be mitigated by the PAS ventilation system which is similar to the auxiliary building gas treatment system (ABGTS).

The PAS lines which penetrate containment are provided with redundant containment isolation valves. A postulated break in a sampling line can be isolated, and the effects would be mitigated by the PAS ventilation system. Due to these considerations, the addition of the PAS system should not significantly increase the probability of an accident or malfunction not previously described in the FSAR.

3 Is the margin of safety as defined in the basis of any technical specification significantly reduced?

The PAS system is a backfit requirement and is not currently described in the FSAR and/or the technical specifications. The design of the e stem is such that there is not a significant probability of loss of -

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containment isolation capability or of a release of radioactive material and, as such, the net impact of the PAS is to increase the margin of safety.

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