ML20085G581
| ML20085G581 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/13/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20085G578 | List: |
| References | |
| NUDOCS 9506200280 | |
| Download: ML20085G581 (6) | |
Text
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uq p uo UNITED STATES y-E NUCLEAR REGULATORY COMMISSION f
WASHINGTON, D.C. 2056H001
\\*****/SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 203 TO FACILITY OPERATING LICENSE N0. DPR-77 AND AMENDMENT NO.193 TO FACILITY OPERATING LICENSE NO. DPR-79 TENNESSEE VALLEY AUTHORITY i
SE0V0YAH NUCLEAR PLANT. UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328
1.0 INTRODUCTION
By application dated April 6, 1995, the Tennessee Valley Authority (the licensee) proposed an amendment to the Technical Specifications (TS) for Sequoyah Nuclear Plant (SQN) Units 1 and 2.
The requested changes would delete Tables 3.6-1, 3.6-2, and 3.8-2 and references to them, incorporate related guidance and justification, and modify the specification related to electrical equipment protective devices. The information and controls provided by the tables and the specifications that reference them would be relocated to administrative 1y controlled procedures in accordance with Generic Letter (GL) 91-08.
2.0 BACKGROUND
Section 182a of the Atomic Energy Act (the "Act") requires applicants for nuclear power plant operating licenses to state TS to be included as part of the license. The Commission's regulatory requirements related to the content of TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific categories, including (1) safety limits, limiting safety system settings and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TS.
The Commission has provided guidance for the contents of TS in its " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (" Final Policy Statement"), 58 Fed. Reg. 39132 (July 22,1993), in which the Commission indicated that compliance with the Final Policy Statement satisfies $182a of the Act.
In particular, the Commission indicated that certain items could be relocated from the TS to licensee-controlled documents, consistent with the standard enunciated in Portland General Electric Co.
(Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979).
In that case, the Atomic Safety and Licensing Appeal Board indicated that " technical specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety."
9506200280 950613 PDR ADOCK 05000327 P
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, Consistent with this approach, the Final Policy Statement identified four l
criteria to be used in determining whether a particular matter is required to be included in the TS, as follows:
(1) installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary; (2) a process variable, design feature, or operating restriction that is an initial condition of a Design Basis Accident or Transient analysis that either assumes the failure of i
or presents a challenge to the integrity of a fission product barrier; (3) a l
structure, system,'or component that is part of the primary success path and which functions or actuates to mitigate a Design Basis Accident or transient that either assumes the failure of or presents a challenge to the integrity of j
l a fission product barrier; and (4) a structure, system, or component which operatingexperienceorprobabilisticsa[etyassessmenthasshowntobe significant to public health and safety.
As a result, existing TS requirements which fall within or satisfy any of the criteria in the Final Policy Statement must be retained in the TS, while those TS requirements which do not fall within or satisfy these criteria may be relocated to other, licensee-controlled documents.
3.0 EVALUATION The licensee has proposed the following TS changes:
(1)
Replace the reference to Table 3.6-2 from Definition 1.7.a.2 for Containment Integrity and delete the reference to Table 3.6-1 from Technical Specification 3.6.1.2.
The staff concludes that these proposed changes are administrative or editorial in nature since they reflect the TS changes evaluated below.
In addition, they provide clarification to the TS and represent no technical change to the current requirements and are consistent with GL 91-08. Therefore, they are acceptable.
(2)
Replace the reference to Table 3.6-2 from Surveillance Requirement (SR) 4.6.1.1 with phrases that will allow the valves to be opened under administrative control.
As pointed out in GL 91-08, the design of the applicable penetrations includes positive control features to ensure that they are maintained closed. Therefore, in the absence of this provision, the opening of these locked or sealed closed valves would be contrary to the operability requirements for these valves that are currently listed in
'The Commission recently promulgated a proposed change to 10 CFR 50.36, pursuant to which the rule would be amended to codify and incorporate these criteria (59 FR 48180). The Commission's Final Policy Statement specified that only limiting conditions for Reactor Core Isolation Cooling, Isolation Condenser, Residual Heat Removal, Standby Liquid Control, and Recirculation Pump Trip, meet the guidance for inclusion in the TS under Criterion 4 (58 FR 39137).
The Commission has solicited public comments on the scope of Criterion 4, in the
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pending rulemaking.
I I the TS table of containment isolation valves. With the removal of the TS list of valves, the operability requirements will apply to all containment isolation valves that have the locked or sealed closed feature. Therefore, this change is consistent with the guidance of GL 91-08, does not change the intent of the current TS and is acceptable.
(3)
Delete Table 3.6-1, " Bypass Leakage Paths to the Auxiliary Building --
Secondary Cohtainment Bypass Leakage Paths."
A phrase would be added to indicate that the pages are intentionally deleted.
As pointed out in GL 91-08, the Final Safety Analysis Report defines the penetrations that are secondary containment bypass leakage paths.
This definition is adequate such that the TS do not require further clarification and removal of the TS list is satisfactory.
(4)
Revise Specification 3.6.3 to delete the reference to Table 3.6-2, add a phrase to take exception to the containment vacuum isolation valves, and add an action statement to indicate that Specification 3.0.4 does not apply to this specification.
In addition, TS 3.6.3 would be changed to indicate that each containment isolation valve shall be operable and add a reference to a new footnote that indicates that the penetration flow path (s) may be unisolated intermittently under administrative controls.
These changes are consistent with GL 91-08 and are, therefore, acceptable.
(5)
Delete SR 4.6.3.1 that requires the isolation valves in Table 3.6-2 to be demonstrated operable prior to returning the valve to service after maintenance, repair or replacement.
This proposed change, while not addressed in GL 91-08, is consistent with NUREG-1431.
In addition, post maintenance testing is performed to ensure that the equipment meets all surveillance requirements prior to j
restoring equipment to an operable status. Therefore, the requirement 1
to perform such tests is implicit in the definition and determination of operability.
Therefore, it does not need to be an explicit TS requirement, and its removal is acceptable.
t f
(6)
Delete references to Table 3.6-2 in Specifications 4.6.3.2 and 4.6.3.3 and add additional wording to indicate that the specifications apply to automatic containment isolation valves.
The staff concludes that these proposed changes are administrative or editorial in nature since they reflect the TS changes evaluated below.
In addition, they provide clarification to the TS and represent no technical change to the current requirements.
Therefore, they are acceptable.
(7)
Delete Table 3.6-2, " Containment Isolation Valves" and add a note to the page indicating that the information has been intentionally deleted.
In addition, the two footnotes contained in the table pertaining to TS
, the TS table of containment isolation valves. With the removal of the TS list of valves, the operability requirements will apply to all i
containment isolation valves that have the locked or sealed closed I
feature. Therefore, this change is consistent with the guidance of GL 91-08, does not change the intent of the current TS and is acceptable.
(3)
Delete Table 3.6-1, " Bypass Leakage Paths to the Auxiliary Building --
Secondary Cohtainment Bypass Leakage Paths."
A phrase would be added to indicate that the pages are intentionally deleted.
As pointed out in GL 91-08, the Final Safety Analysis Report defines the penetrations that are secondary containment bypass leakage paths. This definition is adequate such that the TS do not require further clarification and removal of the TS list is satisfactory.
(4)
Revise Specification 3.6.3 to delete the reference to Table 3.6-2, add a phrase to take exception to the containment vacuum isolation valves, and l
add an action statement to indicate that Specification 3.0.4 does not l
apply to this specification.
In addition, TS 3.6.3 would be changed to i
indicate that each containment isolation valve shall be operable and add a reference to a new footnote that indicates that the penetration flow path (s) may be unisolated intermittently under administrative controls.
These changes are consistent with GL 91-08 and are, therefore, acceptable.
(5)
Delete SR 4.6.3.1 that requires the isolation valves in Table 3.6-2 to be demonstrated operable prior to returning the valve to service after maintenance, repair or replacement.
This proposed change, while not addressed in GL 91-08, is consistent l
with NUREG-1431.
In addition, post maintenance testing is performed to ensure that the equipment meets all surveillance requirements prior to restoring equipment to an operable status. Therefore, the requirement to perform such tests is implicit in the definition and determination of operability.
Therefore, it does not need to be an explicit TS requirement, and its removal is acceptable.
(6)
Delete references to Table 3.6-2 in Specifications 4.6.3.2 and 4.6.3.3 and add additional wording to indicate that the specifications apply to automatic containment isolation valves.
The staff concludes that these proposed changes are administrative or editorial in nature since they reflect the TS changes evaluated below.
In addition, they provide clarification to the TS and represent no technical change to the current requirements. Therefore, they are acceptable.
(7)
Delete Table 3.6-2, " Containment Isolation Valves" and add a note to the page indicating that the information has been intentionally deleted.
In addition, the two footnotes contained in the table pertaining to TS j
- o 3 3.0.4 would be deleted.
These proposed changes are consistent with the guidance given in GL 91-08. The necessary requirements covered by the footnotes has been incorporated into the proposed change to TS 3.6.3.c.
Therefore, these changes are acceptable.
'(8)
Revise Specification 3.8.3.1 to specify that the Limiting Condition for Operation applies to primary and backup containment penetration conductor overcurrent protective devices associated with each containment electrical penetration shall be operable, add a phrase to indicate that the scope of these protective devices excludes those circuits for which credible fault currents would not exceed the electrical penetration design rating, and delete the phrase that references appropriate plant instructions in the action statement.
These proposed changes incorporate the guidance of GL 91-08 and are, therefore, acceptable.
(9)
Delete the phrase from SR 4.8.3.1.a.3 that indicates that a complete listing of all fuses to be verified in accordance with the requirement will be maintained in appropriate plant instructions.
The need to maintain a list of fuses is inherent in the TS requirement to perform the tests.
Therefore, deleting the requirement to maintain such a list is within the intent of GL 91-08 and is acceptable.
j l
(10) Replace the phrase " appropriate plant instructions based on" with
" procedures prepared in conjunction with" in SR 4.8.3.1.b.
This will clarify that the procedures used to perform the 60-month circuit breaker inspection and preventive maintenance are prepared in accordance with manufacturer's recommendations.
This proposed change is clerical in nature and does not change the TS requirements. Therefore, it is acceptable.
(11) Delete Table 3.8-2, " Motor Operated Valves Thermal Overload Protection,"
and replace it with a note that indicates that the pages are intentionally blank.
Replace the reference to Table 3.8-2 in Specification 3.8.3.2 with a phrase that indicates that the Requirement is applicable to valves used in safety systems.
These changes are consistent with the guidance of GL 91-08 and do not change the intent of the current TS.
They are, therefore, acceptable.
(12)
Incorporate appropriate changes to the Bases to reflect these changes.
The proposed change would add information that is consistent with GL 91-08, plus additional clarifying information that recognizes use of controls that are located in the control room. The change is appropriate and, therefore, acceptable.
1 4.0
SUMMARY
The staff reviewed the proposed changes and determined that the removal of these tables and the related requirements do not eliminate the requirements for the licensee to ensure that the system, structure, or component is capable of performing its safety function. Although these tables are removed from the TS and incorporated into the Sequoyah administratively controlled documents, since they are controlled documents described in the Final Safety Analysis Report, the licensee must evaluate any changes that affect these components and procedures in accordance with 10 CFR 50.59.
Should the licensee's determination conclude that an unreviewed safety question is involved, due to either (1) an increase in the probability or consequence of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or malfunction of a different type than any evaluated previously, or (3) a reduction in the margin of safety, NRC approval and a license amendment would be required prior to implementation of the change.
NRC inspection and enforcement programs also enable the staff to monitor facility changes and licensee adherence to Updated Final Safety Analysis commitments and to take any remedial action that may be appropriate.
Based on this review, the staff concluded that 10 CFR 50.36 does not require these tables to be retained in the TS.
Requirements related to operability, applicability, and surveillance requirements, including performance of testing to ensure operability, are retained due to their importance in mitigating the consequences of an accident.
However, the staff determined that the inclusion of these tables is an operational detail related to the licensee's safety analysis, which are adequately controlled by the requirements of 10 CFR 50.59.
Therefore, the continued processing of license amendments related to revisions of the affected tables, where the revisions to those requirements do not involve an unreviewed safety question under 10 CFR 50.59, would afford no significant benefit with regard to protecting the public health and safety.
The staff has concluded, therefore, that removal of these tables and references to them is acceptable because (1) their inclusion in the TS is not specifically required by 10 CFR 50.36 or other regulations, (2) the tables have been incorporated into the Sequoyah administrative 1y controlled document, and (3) changes that are deemed to involve an unreviewed safety question will require prior NRC approval in accordance with 10 CFR 50.59(c).
4.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Tennessee State official was notified of the proposed issuance of the amendment.
The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes 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 amendment involves 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
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. significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (60 FR 24919). Accordingly, the amendment meets 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 amendment.
6.0 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 amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
David E. LaBarge Dated: June 13, 1995
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