ML20117D314

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Proposed TS 3.7.1.3 Re Condensate Storage Tank
ML20117D314
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 08/21/1996
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20117D296 List:
References
CON-TVA-SQN-TS-96-03, CON-TVA-SQN-TS-96-3 NUDOCS 9608280245
Download: ML20117D314 (22)


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I ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE SEQUOYAH NUCLEAR PLANT (SON) UNITS 1 AND 2 )

DOCKET NOS. 50-327 AND 50-328 (TVA-SON-TS-96-03)

LIST OF AFFECTED PAGES Unit 1 3/4 7-7 B 3/4 3-2 Unit 2 3/4 7-7 B 3/4 3-2 4 l

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9608280245 960821 PDR ADOCK 05000327 P PDR .

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i ENCLOSURE 2 1

PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE SEQUOYAH NUCLEAR PLANT (SON) UNITS 1 AND 2 i l

DOCKET NOS. 50-327 AND 50-328 )

(TVA-SON-TS-96-03)

DESCRIPTION AND JUSTIFICATION FOR REVISING CONDENSATE STORAGE TANK (CST) SPECIFICATION 3.7.1.3 l

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, . PLANT SYSTEMS w

CONDENSATE STORAGE TANK LIMITING CONDITION FOR OPERATION 3.7.1.3 A condensate storage tank system (CST) shall be OPERABLE with a contained water volume of at least 190,000 gallons of water.

FP APPLICABILITY: MODES 1, 2n and s,

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ACTION: '^f"* #f {S With the condensate storage tank system inoperable, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either:

a. Restore the CST to OPERABLE status 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 HOT SHUT'DOWN within the following @ l'A, hours ,,./ f, //,,,c] ,,, g#, 9 ,,,,,. d e n e N e m h
b. _ ._- -- _.. OPERABILITY of the Essential Raw Cooling g ter aMm.ad .90 System as a backup supply to the auxiliary feedwater peaund restore the condensate storage tank to OPERABLE status within days or be means 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 HOT SHUTOOWN within the following@ hours g SURVEILLANCE REQUIREMENTS 4.7.1.3.1 The condensate storage ta k system shall be demonstrated OPERABLE at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying the contained water volume is within its limits when the tank is the supply source for the auxiliary feedwater pumps.

4.7 1.3.2 'he esse tial ra cooling water sy tem sha 1 be dem nstrated OPERABL at east o ce per 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> y verif 'ng that the Esse tial Raw Cooling ater Sy tem is n opera ion whe ver the Essenti Raw Co ing Wat System is the s pply so rce for he auxi iary fee water p mps.

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12 N "rS OPERABauTY sk,H be. wlhed once Per **h v

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SEP ' 71980 R3[} SEQUOYAH - UNIT 1 3/4 7-7 Qif J

INSTRUMENTATION BASES-The measurement of response time at the specified frequencies provides assurance that the protective and ESF action function associated with each channel is completed within the time limit assumed in the accident analyses.

No credit was taken in the analyses for those channels with response times indicated as not applicable in the updated final safety analysis report. j R194 Response time may be demonstrated by any series of sequential, overlapping or total channel test measurements provided that such tests demonstrate the total channel response time as defined. Sensor response time verification may be demonstrated by either 1) in place, onsite or offsite test measurements or

2) utilizing replacement sensors with certified response times.

Action 15 of Table 3.3-1, Reactor Trip System Instrumentation, allows the breaker to 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 the purpose of performing R58 maintenance. The 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is based on a Westinghouse analysis performed in Mdr WCAP-10271, Supplement 1, which determines bypass breaker availability.

A 3/4.3.3 MONITORING INSTRUMENTATION 3/4.3.3.1 RADIATION MONITORING INSTRUMENTATION The OPERABILITY of the radiation monitoring channels ensures that 1) the radiation levels are continually measured in the areas served by the individual channels and 2) the alarm or automatic action is initiated when the radiation level trip setpoint is exceeded.

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3/4.3.3.2 MOVABLE INCORE DETECTORS The OPERABILITY of the movable incore detectors with the specified minimum complement of equipment ensures that the measurements obtained from use of this system accurately represent the spatial neutron flux distribution of the reactor core. The OPERABILITY of this system is demonstrated by irradiating each detector used and determining the acceptability of its voltage curve.

For the purpose of measuring F,(z) or FL a full incore flux map is used.

Quarter-core flux maps, as defined in WCAP-8648, June 1976, may be used in recalibration of the excore neutron flux detection system, and full incore flux maps or symmetric incore thimbles may be used for monitoring the QUADRANT POWER TILT RATIO when one Power Range Channel is inoperable.

3/4.3.3.3 SEISMIC INSTRUMENTATION The OPERABILITY of the seismic instrumentation ensures that sufficient capability is available to promptly determine the magnitude of a seismic event and evaluate the response of those features important to safety. This capability is required to permit comparison of the measured response to that used in the Amendment No. 54, 190 SEQUOYAH - UNIT I B 3/4 3-2 November 9, 1994

INSERT A The Auxiliary Feedwater (AFW) Suction Pressure-Low function must be OPERABLE in MODES 1,2, and 3 to ensure a safety grade supply of water for the AFW System to 1

maintain the steam generators as the heat sink for the reactor. This function does not have to be OPERABLE in MODES 5 and 6 because heat being generated in the reactor is removed via the Residual Heat Removal (RHR) System and does not require the steam generators as a heat sink. In MODE 4, AFW automatic suction transfer does not need to be OPERABLE because RHR will already be in operation, or sufficient time 4

is available to place RHR in operation to remove decay heat.

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i PLANT SYSTEMS

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_ , ,i CONDENSATE STORAGE TANK LIMITING CONDITION FOR OPERATION i

3.7.1.3 The condensate storage tank system (CST) shall be OPERABLE with a contained water volume of at least 190,000 gallons of water.

APPLICABILITY: MODES 1 1 2' and 3.

OC 4 ihen s4eam aerber sssrel.kdy ACTION:

With the condensate storage tank system inoperable, sithin 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either:

a. Restore the CST to OPERABLE status or be in at least HOT STANDBY gg 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 H0_T SHUTOOWN within th_e following 3,fj,e.,-f re4, ice. e<> sfc.m gener=Yor Cr 6f Mval hours, or we.T3 b v b. D:::r.:tr:t: the OPERABILITY of the essential raw c ing water system alas.aiNraf'.V 8- as a backup supply to the auxiliary feedwater pump nd restore the m a a.n y condensate storage tank to OPERABLE status within 7 days 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 HOT SHUTDOWN within the following hours.
12. L SURVEILLANCE REQUIREMENTS 4.7.1.3.1 The condensate storage tank system shall.be demonstrated OPERABLE at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying the contained water volume is within its limits when the system is the supply source for the auxiliary feedwater pumps.
4. .l.3. The essent al raw coolin water syst shal be emons ated PERAB E lea once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> y veri ying t at t esse tial aw co ling ater system is in perat n whe ever i is th supp y sou ce fo the uxili y l feedw ter pu ps. .

I shall \>e. v<rSecl once- Per 12k*"r5f*ll**)

' OMA8wTy&cd in,h) veci a.

SEQUOYAH-UNIi2 3/4 7-7

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INSTRUMENTATION BASES h"' ~*

REACTOR TRIP SYSTEM AND ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (Continued)

The measurement of response time at the specified frequencies provides assurance that the protective and the engineered safety feature actuation associated with each channel is completed within the time limit assumed in the accident analyses. No credit was taken in the analyses for those channels with response times indicated as not applicable in the updated final safety analysis report. R182 Response time may be demonstrated by any series of sequential, overlapping or total channel test measurements provided that such tests demonstrate the total channel response time as defined. Sensor response time verification may be demonstrated by either 1) in place, onsite or offsite test measurements or

2) utilizing replacement sensors with certified response times.

Action 15 of Table 3.3-1, Reactor Trip System Instrumen~tation, allows R46 ggg the breaker to be The bypassed 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />sfor up to 4 is based onhours for the purpose a Westinghouse analysisofperformed perfonsing in maintenance.

A WCAP-10271, Supplement 1, which determines bypass breaker availability.

3/4.3.3 MONITORING INSTRUMENTATION 3/4.3.3.1 RADIATION MONITORING INSTRUMENTATION

. The OPERABILITY of the radiation monitoring channels ensures that 1) the radiation levels are continually measured in the areas served by the individual i channels and 2) the alarm or automatic action is initiated when the radiation level trip setpoint is exceeded.

l 3/4.3.3.2 MOVABLE INCORE DETECTORS The OPERABILITY of the movable incore detectors with the specified minimus j complement of equipment ensures that the measurements obtained from use of l

this system accurately represent the spatial neutron flux distribution of the reactor core. The OPERABILITY of this system is demonstrated by irradiating each detector used and determining the acceptability of its voltage curve.

For the purpose of measuring F,(2) or FL a full incore flux map is used.

Quarter-core flux maps, as defined in WCAP-8648, June 1976, may be used in l

recalibration of the excore neutron flux detection system, and full incore j flux maps or symmetric incore thimbles may be used for monitoring the QUADRANT j

POWER TILT RATIO when one Power Range Channel is inoperable.

3/4.3.3.3 SEISMIC INSTRUMENTATION l The OPERABILITY of the seismic instrumentation ensures that sufficient j capability is available to promptly determine the magnitude of a seismic event j and evaluate the response of those features important to safety. This capability i

is required to permit. comparison of the measured response to that used in the t

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l Amendment No. 46, 72, 182 SEQUOYAH - UNIT 2 B 3/4 3-2 November.9, 1994 1 _ _ _. _

INSERT A The Auxiliary Feedwater (AFW) Suction Pressure-Low function must be OPERABLE in MODES 1,2, and 3 to ensure a safety grade supply of water for the AFW System to maintain the steam generators as the heat sink for the reactor. This function does not have to be OPERABLE in MODES 5 and 6 because heat being generated in the reactor is removed via the Residual Heat Removal (RHR) System and does not require the steam generators as a heat sink. In MODE 4, AFW automatic suction transfer does not need to be OPERABLE because RHR will already be in operation, or sufficient time is available to place RHR in operation to remove decay heat.

Description of Chance TVA proposes to modify the Sequoyah Nuclear Plant (SON) Units 1 and 2 technical specifications (TSs) to revise Specification 3.7.1.3, " Condensate Storage Tank." The proposed changes are described as follows:

a. The current modes of applicability are Modes 1,2, and 3. The proposed change revises the mode of applicability to include " MODE 4 when steam generator is relied upon for heat removal."
b. The current Action (a) reads:

" Restore the CST to OPERABLE status 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 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 />, or."

The proposed change would revise Action (a) to read:

" Restore the CST to OPERABLE status 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 HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> without reliance on steam generator for heat removal, or."

c. The current Action (b) reads:

" Demonstrate the OPERABILITY of the Essential Raw Cooling Water System as a backup supply to the auxiliary feedwater pumps and restore the condensate storage tank to OPERABLE status within 7 days 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 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 />."

The proposed change would revise Action (b) to read:

" Verify by administrative means OPERABILITY of the Essential Raw Cooling Water System as a backup supply to the auxiliary feedwater pumps" and restore the condensate storage tank to OPERABLE status within 7 days 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 HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> without reliance on steam generator for heat removal.

  • OPERABILITY shall be verified once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following initial verification."

Also included is a change to Action (b) for the Unit 1 TS page. A "u" is inserted into the word " pump" to correct a typographical error.

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d. The current Surveillance Requirement (SR) 4.7.1.3.2 reads:

l "The essential raw cooling water system shall be demonstrated OPERABLE at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying that the Essential Raw Cooling Water System is in operation whenever the Essential Raw Cooling Water System is the supply source for the auxiliary feedwater pumps."

The proposed change deletes SR 4.7.1.3.2 in its entirety.

e. A proposed change to the SQN TS Bases provides an insert for Section 3/4.3.2,

" Protective and Engineered Safety Features (ESF) Instrumentation." The insert contains guidance concerning the ruxiliary feedwater (AFW) suction pressure-tow function as to the modes when this function is required to be operable.

l Reason for Chanae '

The reason for the proposed TS change is to resolve a corrective action associated with a disparity that exists in SON TS. TS Change 94-06 was implemented at the site I on September 8,1995, and revised SON's AFW Specification 3.7.1.2 to incorporate I the Westinghouse Standard Technical Specifications (STS) contained in NUREG-1431. j One changc included with TS 94-06 was a revision to the mode of applicability that i was expanded from Modss 1,2, and 3, to include " MODE 4 when steam generator is

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relied upon for heat removal." As a result of this change, a disparity was created between the mode of applicability for SON's AFW Specification 3.7.1.2 and the mode of applicability for SON's CST Specification 3.7.1.3 (i. e., requires a CST to operable in Modes 1,2, and 3). SON's CST acts as a water supply source for SON's AFW pumps. The change in mode of applicability for SON's AFW TS did not recognize the need for a change to the mode of applicability for SON's CST TS. Consequently, a TS I change is needed to correct the disparity. This problem is documented in SON l Problem Evaluation Report SO960466PER. Administrative controls are currently in I place as an interim corrective action until this TS change is approved. l l

Note that additional changes to Specification 3.7.1.3 have been included with this TS I change to reflect STS requirements. These additional changes are provided as line-item improvements.

Justification for Channe I I

1. System Description

1 SON has two CSTs (one for each unit) that provide cooling water to the suction of the AFW pumps. The water source from a CST is used to remove decay heat and l to cool down the unit during normal operation. Under accident conditions, the

l AFW pumps are designed, on low suction pressure, to automatically swap to SON's essential raw cooling water (ERCW) system. SON TS 3.7.1.3 currently I requires a CST to be operable with a contained water volume of at least 190,000 gallons of water while in Modes 1,2, and 3. The operability of the CST with the I minimum water volume ensures that sufficient water is available to maintain the reactor coolant system at hot standby conditions for two hours with steam discharge to the atmosphere concurrent with a totalloss of off-site power. l

2. Justification for proposed TS Changes TVA's proposed change to SON Specification 3.7.1.3 establishes TS requirements )

that are consistent with Westinghouse STS (NUREG-1431, Revision 1). Detailed justification for each specific change is provided below.

a. Applicability TVA's proposed change revises the mode of applicability to add " MODE 4 when steam generator is relied upon for heat removal." While in Mode 4, SON's AFW system is utilized to cool down the unit until the residual heat removal (RHR) system is placed in service. While in this condition, one AFW train, which includes a motor-driven pump, is required to be operable. In conjunction with AFW operation, SON's CST should be operable to ensure that a source of water is available to the required AFW train. Accordingly, the proposed change to SON TS 3.7.1.3 will require the CST to be operable and will provide consistent mode requirements with SON's AFW TS 3.7.1.2. This ,

change is also justified based on STS requirements. j

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b. Action Requirements TVA's proposed change revises SON's action requirements to include STS language. The first change involves adding the phrase "without reliance on steam generator for heat removal." This phrase is added to the current Actions (a) and (b) for the purpose of ensuring unit cooldown to RHR entry conditions without reliance on steam generator (SG) for heat removal. The phrase provides consistency between the action requirements and the newly added mode of applicability. Included with this change is an increase in the completion time for achieving hot standby. The current completion time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is increased to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This change allows sufficient time, while in Mode 4, to transition from SGs to RHR entry conditions. The 12-hour  ;

completion time is reasonable based on operating experience to reach the i required plant condition in an orderly manner without challenging plant systems, i The second change involves a revision to the Action (b) language. Currently, Action (b) uses the phrase " Demonstrate the OPERABILITY of the Essential Raw ,

Cooling Water System . . ." The proposed change replaces this phrase with the I words " Verify by administrative mean-s OPERABILITY of the Essential Raw Cooling Water System . . ." This is justified because it is considered editorial in i nature and does not change intent with regard to the methods that are currently  !

used to show operability of SON's ERCW system. In addition, the proposed change provides consistency with STS language.

The third change involves addition of an asterisk and a footnote to Action (b).

The footnote reads as follows:

" OPERABILITY shall be verified once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following initial verification."

The footnote provides a new action requirement to SON TS 3.7.1.3, and is being added for consistency with STS action requirements. This change will ensure that SON's backup water supply to the CST (i.e., ERCW system) is verified operable on a periodic basis every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> until the CST is either restored to an operable status or a unit shutdown is initiated.

c. Surveillance Requirements (SR)

TVA's proposed change deletes SR 4.7.1.3.2. This SR demonstrated operability of SON's ERCW system at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> whenever it was used as the supply source for SON's AFW pumps. The proposed deletion of SR 4.7.1.3.2 is consistent with STS requirements and is justified based on:

(1) SON TS 3.7.4 ensures operability of SON's ERCW system by requiring two ERCW loops to be operable in Modes 1,2,3, and 4, and (2) the previously described change to the Action (b) requirement provides a new requirement' 1 identical to the SR that is deleted. The proposed change to Action (b) will {

ensure that operability of the ERCW system is verified every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> whenever the CST is inoperable. .

Environmentalimpact Evaluation The proposed change does not involve an unreviewed environmental question because i operation of SON 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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l'l ENCLOSURE 3

- PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE SEQUOYAH NUCLEAR PLANT (SON) UNITS 1 AND 2 DOCKET NOS. 50-327,AND 50-328 (TVA-SON-TS-96-03)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATION l

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Significant Hazards Evaluation TVA has evaluated the proposed TS change and has determined that it does not represent a significant hazards consideration based on criteria established in 10 CFR 50.92(c). Operation of Sequoyah Nuclear Plant (SON) in accordance with the proposed amendment will not:

1. Invcive a significant increase in the probability or consequences of an accident previously evaluated.

The proposed TS change revises SON's condensate storage tank (CST) >

Specification 3.7.1.3 to incorporate requirements from the Westinghouse Standard Technical Specification (STS) contained in NUREG-1431, Revision 1.

The proposed change is consistent with the STS for ensuring that SON's CST remains operable in Modes 1,2,3, and Mode 4 when steam generator (SG) is relied upon for heat removal, in addition, the proposed change provides a general TS improvement by incorporating STS phraseology within the action requirements. Included with this change is an increase in the completion time for achieving hot shutdown. The current completion time of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> is increased to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This change allows sufficient time, while in Mode 4, to transition from SGs to residual heat removal entry conditions. The 12-hour completion time is reasonable based on operating experience to reach the required plant condition in I an orderly manner without challenging plant systems.

TVA's proposed change also includes deletion of Surveillance Requirement (SR) 4.7.1.3.2. This SR demonstrates operability of SON's essential raw cooling water (ERCW) system every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> whenever the ERCW system is used as a supply source for the auxiliary feedwater (AFW) system. Deletion of this SR is consistent with STS requirements and is justified based on: (1) current SON TS 3.7.4 requirements ensure operability of SON's ERCW in Modes 1,2,3, and 4, and (2) newly proposed Action (b) requirements ensure that SON's ERCW system is verified operable every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> whenever the CST is inoperable.

The proposed changes provide TS requirements for SON's CST that are conservative with respect to assumptions used in SON's accident analysis as contained in the Final Safety Analysis Report (FSAR). This change does not involve a physical modification to the plant or affect any instrumentation setpoints. Accordingly, the proposed changes do not involve an increase in the probability or consequences of an accident previously evaluated.

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

The proposed changes provide TS requirements for SON's CST that are conservative with respect to assumptions used in SON's accident analysis as contained in the FSAR. No new event initiator has been created, nor has any hardware been changed. This change does not involve a physical change to SON's CST or any other system. Therefore, the proposed change will not create the potsiHlity of a new or different kind of accident from any previously analyzed.

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

TVA's proposed change replaces SON's CST TS requirements with TS I requirements from the Westinghouse STS (NUREG-1431, Revision 1). The proposed change to SQN's CST TS to add " Mode 4 when steam generator is relied upon for heat removal," provides consistency with the mode requirements  !

of SON's AFW TS and resolves a disparity that currently exists between these l TSs. The allowed outage time for an inoperable CST remains unchanged and is j consistent with the allowed outage time in STS. The proposed change to delete a 1 SR for verifying operability of the ERCW system is considered acceptable based on other existing TSs that verify operability of SON's ERCW system. Overall, similarity exists between SON's current CST specification and the STS version. l Consequently, with the exception of format, the TS requirements remain essentially unchanged.  ;

The proposed changes provide a line-item improvement for SON's CST TS that are conservative with respect to the assumptions used in SQN's accident analysis as contained in the FSAR. This changes does not involve a setpoint change or l physical modification to the plant. Accordingly, the margin of safety has not l been reduced. )

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9 - 4 6 ENCLOSURE 4 '

j PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE i

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

DOCKET NOS. 50-327 AND 50-328 l 1

I (TVA-SON-TS-96-03) ,

I RETYPED TS PAGES FOR PROPOSED TS CHANGE l

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PLANT SYSTEMS CONDENSATE STORAGE TANK LIMITING CONDITION FOR OPERATION 3.7.1.3 A condensate storage tank system (CST) shall be OPERABLE with a FP contained water volume of at least 190,000 gallons of water.

APPLICABILITY: MODES 1, 2 and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTION:

With the condensate storage tank system inoperable, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either:

a. Restore the CST to OPERABLE status 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 HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> without reliance on steam generator for heat removal, or l
b. Verify by administrative means OPERABILITY of the Essential Raw Cooling Water System as a backup supply to the auxiliary feedwater  ;

pumps

  • and restore the condensate storage tank to OPERABLE status within 7 days 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 HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> without reliance on steam generator for heat removal.

SURVEILLANCE REQUIREMENTS 4.7.1.3.1 The condensate storage tank system shall be demonstrated OPERABLE at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying the contained water volume is within its limits when the tank is the supply source for the auxiliary feedwater pumps.

  • OPERABILITY shall be verified once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following initial verification.

SEQUOYAH - UNIT 1 3/4 7-7 Amendment No.

  • 4 Q INSTRUMENTATION BASES The measurement of response time at the specified frequencies providen assurance that the protective and ESF action function associated with each channel is completed within the time limit assumed in the accident analyses.

No credit was taken in the analyses for those channels with response times indicated as not applicable in the updated final safe' , a alysis report.

lR194 Response time may be demonstrated by any series .f ,equential, overlapping or total channel test measurements provided that such tests demonstrate the total channel response time as defined. Sensor response time verification may be demonstrated by either 1) in place, onsite or offsite test measurements or 2) utilizing replacement sensors with certified response times.

Action 15 of Table 3.3-1, Reactor Trip System Instrumentation, allows the breaker to 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 the purpose of performing ,

maintenance. The 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is based on a Westinghouse analysis performed in R58 J WCAP-10271, Supplement 1, which determines bypass breaker availability.

l The placing of a channel in the trip condition provides the safety BR-9 '

function of the channel. If the channel is tripped for testing and no other condition would have indicated inoperability, the channel should not be declared inoperable.

The Auxiliary Feedwater (AFW) Suction Pressure-Low function must be OPERABLE in MODES 1, 2, and 3 to ensure a safety grade supply of water for the AFW System to maintain the steam generators as the heat sink for the reactor.

This function does not have to be OPERABLE in MODES 5 and 6 because heat being ,

generated in the reactor is removed via the Residual Heat Removal (RHR) System I and does not require the steam generators as a heat sink. In MODE 4, AFW automatic suction transfer does not need to be OPERABLE because RHR will already be in operation, or sufficient time is available to place RHR in operation to remove decay heat.

3/4.3.3 MONITORING INSTRUMENTATION 3/4.3.3.1 RADIATION MONITORING INSTRUMENTATION The OPERABILITY of the radiation monitoring channels ensures that 1) the radiation levels are continually measured in the areas served by the individual channels and 2) the alarm or automatic action is initiated when the radiation i level trip setpoint is exceeded. l 3/4.3.3.2 MOVABLE INCORE DETECTORS j The OPERABILITY of the movable incore detectors with the specified minimum complement of equipment ensures that the measurements obtained from use of this system accurately represent the spatial neutron flux distribution of the reactor core. The OPERABILITY of this system is demonstrated by irradiating each detector used and determining the acceptability of its voltage curve.

For the purpose of measuring Fn(X,Y, Z) or Fa (X,Y) a full incore flux map l is used. Quarter-core flux maps, as defined in WCAP-8648, June 1976, may be used in recalibration of the excore neutron flux detection system, and full incore flux maps or symmetric incore thimbles may be used for monitoring the QUADRANT POWER TILT RATIO when one Power Range Channel is inoperable.

SEQUOYAH - UNIT 1 B 3/4 3-2 Amendment No. 54, 190,

.-. . -- -- ~ .-

1 e . .

INSTRUMENTATION i

d BASES i

3/4.3.3.3 SEISMIC IMSTRUMENTATION J

4 The OPERABILITY of the seismic instrumentation ensures that sufficient capability is available to promptly determine the magnitude of a seismic event and evaluate the response of those features important to safety. This capability is required to permit comparison of the measured response to that used in the design basis for the facility to determine if plant shutdown is

required pursuant to Appendix "A" of 10 CFR Part 100. All specified

, measurement ranges represent the minimum ranges of the instruments. This instrumentation is consistent with the recommendations of Regulatory R85 Guide 1.12, " Instrumentation for Earthquakes," April 1974.

, J/4.3.3.4 METEOROLOGICAL INSTRUMENTATION l

The OPERABILITY cf th6 meteorological instrumentation ensures that sufficient meteorological data is available for estimating potential radiation 4 doses to the public as a result of routine or accidental release of radioactive materials to the atmosphere. This capability is reyaired to evaluate the need for initiating protective measures to protect the health and safety of the i public and is consistent with the recommendations of Regulatory Guide 1.23, 1 "Onsite Meteorological Programs," February 1972.

l j 3/4.3.3.5 REMOTE SHUTDOWN INSTRUMENTATION i The OPERABILITY of the remote shutdown instrumentation ensures that '

sufficient capability is available to permit shutdown and maintenance of HOT  !

STANDBY of the facility and the potential capability for subsequent cold shut- BR down from locations outside of the control reom. This capability is required

, in the event control room habitability is lost and is consistent with General Design Criterion 19 of 10 CFR 50.

i

3/4.3.3.6 CHLORINE DETECTION SYSTEMS s

i This specification deleted.

I R66 i

3/4.3.3.7 ACCIDENT MONITORING INSTRUMENTATION i The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and i assess these variables following an accident. This capability is consistent with the recommendations of Regulatory Guide 1.97, Revision 2, " Instrumentation R153 i i for Light-Water-Cooled Nuclear Power Plants to Assess Plant Conditions During  ;

I and Following an Accident," December 1980.

The postaccident monitoring instrumentation limiting condition for  ;

operation provides the requirement of Type A and Category 1 monitors that  !

provide information required by the control roc.n cperators to:

j Permit the operator to take preplanned manual actions to accomplish safe plant shutdown.

Determine whether systems important to safety are performing their

intended functions.

SEQUOYAH - UNIT 1 B 3/4 3-3 Amendment No. 62, 81, 149, 159 4

July 9, 1992

l PLANT SYSTEMS CONDENSATE STORAGE TANK LIMITING CONDITION FOR OPERATION 3.7.1.3 The condensate storage tank system (CST) shall be OPERABLE with a contained water volume of at least 190,000 gallons of water.

APPLICABILITY: MODES 1, 2 and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTION:

With the condensate storage tank system inoperable, within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> either:

a. Restore the CST to OPERABLE status 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 HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> without reliance on steam generator for heat removal, or l
b. Verify by administrative means OPERABILITY of the essential raw cooling water system as a backup supply to the auxiliary feedwater pumps
  • and restore the condensate storage tank to OPERABLE status within 7 days 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 HOT SHUTDOWN within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> without reliance on steam generator for heat removal.

SURVEILLANCE REQUIREMENTS 4.7.1.3.1 The condensate storage tank system shall be demonstrated OPERABLE at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by verifying the contained water volume is within its limits when the system is the supply source for the auxiliary feedwater pumps.

l

  • OPERABILITY shall be verified once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> following initial verification, t

SEQUOYAH - UNIT 2 3/4 7-7 Amendment No.

. - _ . _. - . _ - . . - . - - - - _ ~ - . ~ - - - ,. -- - ~_

e .. .

INSTRUMENTATION BASES .

REACTO'R TRIP SYSTEM AND ENGINEERED SAFETY FEATURE ACTUATION SYSTEM INSTRUMENTATION (Continued)

The measurement of response time at the specified frequencies provides assurance that the protective and the engineered safety feature actuation associated with each channel is completed within the time limit assumed in the accident analyses. No credit was taken in the analyses for those channels with response times indicated as not applicable in the updated final safety analysis report. R182 Response time may be demonstrated by any series of sequential, overlapping or total channel test measurements provided that such tests demonstrate the total channel response time as defined. Sensor response time verification may be demonstrated by either 1) in place, onsite or offsite test measurements or 2) utilizing replacement sensors with certified response times.

Action 15 of Table 3.3-1, Reactor Trip System Instrumentation, allows the breaker to 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 the purpose of performing R46 maintenance. The 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> is based on a Westinghouse analysis performed in WCAP-10271, Supplement 1, which determines bypass breaker availability.

The placing of a channel in the trip condition provides the safety function of the channel. If the channel is tripped for testing and no other BR-10 condition wou3d have indicated inoperability, the channel should not be declared inoperable.

The Auxiliary Feedwater (AFW) Suction Pressure-Low function must be OPERABLE in MODES 1, 2, and 3 to ensure a safety grade supply of water for the AFW System to maintain the steam generators as the heat sink for the reactor.

This function does not have to be OPERABLE in MODES 5 and 6 because heat being generated in the reactor is removed via the Residual Heat Removal (RER) System and does not require the steam generators as a heat sink. In MODE 4, AFW automatic suction transfer does not need to be OPERABLE because RHR will already be in operation, or sufficient time is available to place RHR in operation to remove decay heat.

3/4.3.3 MONITORING INSTRUMENTATION 3/4.3.3.1 RADIATION MONITORING INSTRUMENTATION The OPERABILITY of the radiation monitoring channels ensures that 1) the radiation levels are continually measured in the areas served by the individual channels and 2) the alarm or automatic action is initiated when the radiation level trip setpoint is exceeded.

3/4.3.3.2 MOVABLE INCORE DETECTORS The OPERABILITY of the movable incore detectors with the specified minimum complement of equipment ensures that the measurements obtained from use of this system accurately represent the spatial neutron flux distribution of the reactor core. The OPERABILITY of this system is demonstrated by irradiating each detector used and determining the acceptability of its voltage i curve.

For the purpose of measuring F n(X,Y,Z) or Fa (X,Y) a full incore flux map  !

I is used. Quarter-core flux maps, as defined in WCAP-8648, June 1976, may be

, used in recalibration of the excore neutron flux detection system, and full 4

incore flux maps or symmetric incore thimbles may be used for monitoring the QUADRANT POWER TILT RATIO when one Power Range Channel is inoperable.

SEQUOYAH - UNIT 2 B 3/4 3-2 Amendment Nos. 46, 72, 182,

, .e , 1 INSTRUMENTATION BASES .

I 3/4.3.3.3 SEISMIC INSTRUMENTATION The OPERABILITY of the seismic instrumentation ensures that sufficient capability is available to promptly determine the magnitude of a seismic event and evaluate the response of those features important to safety. This capability is required to permit comparison of the measured response to that

used in the design basis for the facility to determine if plant shutdown is required pursuant to Appendix "A" of 10 CFR Part 100. All specified R72 measurement ranges represent the minimum ranges of the instruments. The instrumentation is consistent with the recommendations of Regulatory Guide 1.12, " Instrumentation for Earthquakes," April 1974.

3/4.3.3.4 METEOROLOGICAL INSTRUMENTATION 4

The OPERABILITY of the meteorological instrumentation ensures that l 2

sufficient meteorological data is available for estimating potential radiation doses to the public as a result of routine or accidental release of radioactive i materials to the atmosphere. This capability is required to evaluate the need I for initiating protective measures to protect the health and safety of the l public and is consistent with the recommendations of Regulatory Guide 1.23, "Onsite Meteorological Programs," February 1972.

3/4.3.3.5 REMOTE SHUTDOWN INSTRUMENTATION The OPERABILITY of the remote shutdown instrumentation ensures that suf- ,

ficient capability is available to permit shutdown and maintenance of HOT l STANDBY of the facility and the potential capability for subsequent cold shut-

down from locations outside of the control room. This capability is required in the event control room habitability is lost and is consistent with General BR Design Criterion 19 of 10 CFR 50.

4 3/4.3.3.6 CHLORINE DETECTION SYSTEMS l R54 This specification deleted.

3/4.3.3.7 ACCIDENT MONITORING INSTRUMENTATION The OPERABILITY of the accident monitoring instrumentation ensures that sufficient information is available on selected plant parameters to monitor and assess these variables following an accident. This capability is consistent with the recommendations of Regulatory Guide 1.97, Revision 2,'" Instrumentation R135 i for Light-Water-Cooled Nuclear Power Plants to Assess Plant Conditions During and Following an Accident," December 1980.

1 The postaccident monitoring instrumentation limiting condition for operation provides the requirement of Type A and Category 1 monitors that R149 provide information required by the control room operators to:

Permit the operator to take preplanned manual action to accomplish safe plant shutdown 2

July 9, 1992 SEQUOYAH - UNIT 2 B 3/4 3-3 Amendment Nos. 35, 46, 54, 72, 135, 149