ML20085M158
| ML20085M158 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/14/1995 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20085M141 | List: |
| References | |
| NUDOCS 9506290065 | |
| Download: ML20085M158 (6) | |
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q p-4 UNITED STATES I*j NUCLEAR REGULATORY COMMISSION y
WASHINGTON, D.C. 20565-0001
- / }AFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 204 TO FACILITY OPERATING LICENSE NO. DPR-77 l
AND AMENDMENT NO.194 TO FACILITY OPERATING LICENSE NO. DPR-79 j
TENNESSEE VALLEY AUTHORITY SE000YAH 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 l
Sequoyah Nuclear Plant (SQN) Units 1 and 2.
The requested changes would delete TS 3/4.9.7, " Crane Travel - Spent Fuel Pool Area," Figure 3.9-1 that is 1
referenced by TS 3.9.7, Surveillance Requirements (SRs) 4.9.7.1 and 4.9.7.2, and associated ~ Bases. The information and controls provided by the specifications would be relocated to administratively controlled procedures.
r TS 3.9.7 contains restrictions for moving heavy loads over the fuel assemblies in the spent fuel pool (SFP).
It is applicable whenever fuel assemblies are in the SFP or in the cask loading area of the cask pit and specifies that whenever the specifications are not satisfied, the crane load be placed in a safe condition.
SR 4.9.7.1 contains requirements for testing crane interlocks and physical stops. SR 4.9.7.2 addresses administrative requirements concerning the impact shield.
2.0 BACKGROUND
4 Section 182a of the Atomic Energy 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 Federal Register (FR) 39132 (July 22, 1993), in which the Commission indicated that compliance with the Final Policy Statement satisfies fl82a 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 ENCLOSURE 3 9506290065 950614 PDR ADOCK 05000327 P
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Doctric Co. (Trojan Nuclear Plant), ALAB-531, 9 NRC 263, 273 (1979).-- In that
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- 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."
i Consistent with this approach, the Final Policy Statement identified four
- criteria to be used in determining whether a particular matter is required to i
be included in the TS, as follows:
(1) installed instrumentation that. is used j
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-or presents a challenge.to the integrity of a fission product barrier; (3) a 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 a fission product barrier; and (4) a structure, system, or component which operatingexperienceorprobabilisticsa[etyassessmenthasshowntobe-l significant to public health and safety.
As a result, existing TS-requirements which fall within or satisfy any of the criteria in the Final-t f
j Policy Statement must be retained, while those TS requirements which do not
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fall within or satisfy these criteria may' be relocated to other, licensee-controlled documents.
3.0 EVALUATION i
3.1-TS 3.9.7 Control of Heavy Loads A potential release of radioactive material from fuel may occur during the refueling process as a result of fuel-cladding failures, mechanical damage l
caused by the dropping of fuel assemblies, or the dropping of objects onto fuel assemblies. The restriction of movement of loads in excess of 2100 pounds over fuel assemblies ensures that, in the event the load is.
dropped, the potential activity released will be limited to that contained in a single fuel assembly and that any distortion of fuel in the SFP racks will i
not result in a critical configuration.. This TS applies to the prevention of J
a heavy-load-drop accident and ensures that the damage caused by the load is i
limited to the equivalent of one fuel assembly. This assumption is consistent with the activity released that is assumed in the design basis accident analysis for a fuel handling accident.
'The Commission recently promulgated a proposed change to 10 CFR 50.36, f
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 1
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 j
pending rulemaking.
. 3.2 SR 4.9.7.1 Crane Interlocks and Physical Stoos TS'4.0.1 requires that SRs be met during the operational modes or other conditions specified for the limiting conditions for operation unless otherwise stated in the individual SR. During implementation of Amendment Numbers 167 and 157 for SQN Units 1 and 2 respectively, dated April 28, 1993, to increase the capacity of the SFP by replacing the existing fuel storage racks with those of a different design, an inconsistency was determined to exist with TS 4.9.7.1.
This SR requires the crane interlocks and physical stops that prevent crane hook travel over the storage pool be demonstrated operable within 7 days prior to crane use and at least once per 7 days thereafter during crane operation. However, with the interlocks and physical stops functioning, all loads are prevented from traveling over the SFP, regardless of weight, since the interlocks are activated only by crane position near the SFP, ngardless of the magnitude of the load. Therefore, in j
order to use the crane to modify the SFP racks, it was necessary to issue i
Amendment Numbers 194 and 185 for SQN Units 1 and 2, respectively, dated January 24, 1995, to allow the crane interlocks and physical stops to be bypassed under administrative controls.
This resolved the issue of crane operation for the SFP reracking modification.
However, the crane is also designed to serve other needs for both Units 1 r
1 and 2, such as handling fuel casks, placement of new fuel in the new fuel storage vault, movement of the new fuel from the new fuel storage vault to the-fuel elevator, removal of the shield plugs at the equipment access doors of the reactor building, and movement of large components into or out of the reactor building by way of the auxiliary building.
In addition, the crane is used to maneuver equipment needed for fuel inspections and gate relocation. A literal application of the surveillance requirements would prevent performance of any of these evolutions.
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3.3 CONCLUSION
The staff evaluated the proposed amendment against the four Final Policy Statement criteria given in Section 2 above and determined that each of the four criteria are satisfied as follows:
(1)
The crane travel and load limit TS do not apply to instrumentation used to detect, and indicate in the control room, significant degradation of the reactor coolant pressure boundary.
(2)
Even though a fuel handling event is considered to be a design basis accident, Criterion 2 does not apply.
For the Chapter 15 (SRP Section 15.7.4) fuel handling accident analysis, one of the initial conditions is that only one fuel assembly is involved in the accident. The crane interlocks are a design feature that are in place to prevent exceeding this initial condition, not a design feature that is an initial condition in and of itself, and the load limit is an operational feature that is meant to prevent exceeding the initial condition (damage to more than one fuel assembly). Therefore, the load limit and interlocks are provided to prevent operation in a condition that could result in an unanalyzed event or accident if a load drop were to occur. As specified
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in SRP Section 15.7.4, the movement of heavy loads (loads greater than the specified limit) are not covered by the Chapter 15 accident analysis.
(3)
The crane travel and load limit TS do not apply to a structure, system, or component that is part of the primary success path and do not function or actuate to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge in the integrity of a fission product barrier.
(4)
The auxiliary building crane and associated equipment, and the load limitations, were not included in the SQN Individual Plant Evaluation, nor is it known to be significant based on any other individual plant evaluations or operating experience.
Where necessary, SQN has addressed the requirements of NUREG-0612 that prevent the movement of heavy loads over fuel assemblies in the SFP as described in the SQN Updated Final Safety Analysis Report Section 9.1.2, " Spent Fuel Storage," in various plant procedures. The procedural administrative controls are contained in Administrative Instruction-41, " Auxiliary Building Crane Travel Interlocks," which governs the bypassing of the interlocks that prevent the crane bridge from traveling over the SFP when the hook is aligned to travel over the SFP. This procedure requires documentation of the description, of the work to be performed, a certified crane operator / relief operator be provided, and permission from the shift supervisor be obtained.
Upon approval of this amendment, the licensee will relocate the existing TS requirements to the administrative procedures that govern crane operation, and j
the crane design is described in the Updated Final Safety Analysis such that future changes to these procedures can be made pursuant to 10 CFR 50.59.
In order to avoid any confusion regarding the relationship between the crane load limits and the surveillance requirements for the interlocks and physical stops, the staff suggests that the crane operation procedures clearly identify the loads over the spent fuel pool that have been specifically analyzed under the existing licensing basis to permit the crane interlocks and physical stops to be defeated. Different operation or loading conditions in the future will have to be evaluated to determine whether such differences involve an increase in the probability or consequences of a load drop accident, or a reduction in the margin of safety in accordance with 10 CFR 50.59.
On this basis, the staff concludes that these requirements do not need to be controlled by TS and adequate procedural controls will be in effect. Changes to these procedures, should they be required in the future, will be adequately controlled by 10 CFR 50.59. The staff has concluded, therefore, that relocation of the crane operation requirements described above is acceptable since their inclusion in the TS is not specifically required by 10 CFR 50.36 or other regulations and the requirements governing the auxiliary crane movement in relation to the SFP are not required to avert an immediate threat to the public health and safety.
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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
i 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 and a surveillance requirement. 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 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 20529). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth i
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.
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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 14, 1995
s Mrc Oliver D. Kingsley, Jr.
. Tennessee Valley Authority SEQUOYAH NUCLEAR PLANT cc:
Mr. O. J. Zeringue, Sr. Vice President TVA Representative Nuclear Operations Tennessee Valley Authority Tennessee Valley Authority 3B Lookout Place 11921.Rockville Pike 1101 Market Street Suite 402 Rockville, MD 20852 Chattanooga, TN 37402-2801 Dr. Mark 0. Medford, Vice President Regional Administrator Engineering & Technical Services U.S. Nuclear Regulatory Commission Tennessee Valley Authority Region II 3B Lookout Place 101 Marietta Street, NW., Suite 2900 1101 Market Street Atlanta, GA 30323 Chattanooga, TN 37402-2801 Mr. William E. Holland Mr. D. E. Nunn, Vice President Senior Resident Inspector New Plant Completion Sequoyah Nuclear Plant Tennessee Valley Authority U.S. Nuclear Regulatory Commission 3B Lookout Place 2600 Igou Ferry Road 1101 Market Street Soddy Daisy, TN 37379 Chattanooga, TN 37402-2801 Mr. Michael H. Mobley, Director Mr. R. J. Adney, Site Vice President Division of Radiological Health i
Sequoyah Nuclear Plant 3rd Floor, L and C Annex Tennessee Valley Authority 401 Church Street
-P.O. Box 2000 Nashville, TN 37243-1532 Soddy Daisy, TN 37379 County Judge General Counsel Hamilton County Courthouse Tennessee Valley Authority Chattanooga, TN 37402-2801 ET 11H 400 West Summit Hill Drive Knoxville, TN 37902 Mr. P. P. Carier, Manager Corporate Licensing Tennessee Valley Authority 4G Blue Ridge 1101 Market Street Chattanooga, TN 37402-2801 Mr. Ralph H. Shell Site Licensing Manager Sequoyah Nuclear Plant Tennessee Valley Authority P.O. Box 2000 Soddy Daisy, TN 37379
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