ML20141M485
| ML20141M485 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah |
| Issue date: | 08/21/1992 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20141M484 | List: |
| References | |
| NUDOCS 9208310205 | |
| Download: ML20141M485 (11) | |
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4 ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION (TS) CilANGE 1
SEQUOYAll NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (IVA-SQN-TS-92-09 )
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i LIST OF AFFECTED PAGES Unit _I
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3/4 6-28 3/4 7-17 Uni.t_2 j
3/4 6-29 3/4 7-17 i
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CONTAINMENT SYSTEMS ICE BED TEMPERATURE MnNITORING SYSTEM LIMITING CONDITION FGR OPERATION 3.6.5.2 The ice bed temperature monitoring system shall be OPERABLE with at least 2 OPERABLE RTD chat.nels in the ice bed at each of 3 batic elevations (10'6", 30'9" and 55' above the floor of the ice condenser) for each one third j
of the ice condenser.
APPLICABILITY: MODES 1, 2, 3 and 4.
ACTION:
With the ice bed temperature indication not available in the main 7
a.
i control room, determine the ice bed temperature at th cQ condenurdamperatureanon' g_Sant ~.e 2 hou
. Tut h visio Ni l
SPtt.l F i c h Ts o su 3.01 IIR.E or Af PLic66LE.
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b.
W ht i c e le~dTe &iiiR3 tuNng 5FTE e m~~~OI6iieTi6e_a n d u n a b l e 1
to determine the ice bed temperatures by alternate means, POWER i
OPERATION may continue for up to 6 days provided the ice compartment
{93 lower inlet doors, intermediate deck doors, and top deck doors are closed and the last recorded mean ice bed temperature was less than or equal to 15 F and steady; otherwise, 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 SHUTOOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
SURVEILLANCE RE0VIREMENTS 4.6.5.2 The ice bed temperature monitoring system shall be determined OPERABLE by performance of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
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1 SEQUOYAH - UNIT 1 3/4 6-28 Amendment No.13, 89 October 14, 1988
PLANT SYSTEMS 3/4.7.7 CONTROL ROOM EMERGENCY VENTILAT16N SYSTEM
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LIMITING CONDITION FOR OPERATION 3.7.7 Two independent control room emergency ventilation systems shall be OPERABLE.
R16 APPLICABILITY:
ALL MODES ACTION:
MODES 1, 2, 3 and 4 With one controi room emergency ventilation system inoperable, restore the inoperable system 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 COLD SHUT 00WN wit.hin the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
MODES 5 and 6 With one control room emergency ventilation system inoperable.
a.
restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the control room emergency ventilation system in the recirculation mode.
b.
With both control room emergency air ventilation systems inoperable, suspend all operations involving CORE AL1ERATIONS or positive reactivity changes.
(.cghcAro%sionn.QJ 5pacifdpt4on-Lo--3%r.p-tie i
plicab-n MODE 6.
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SURVTTCTMCt--REQUfREMENTW
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p 4.7.7 Each control room emergency ventilation system shall be demonstrated OPERABLE:
R16 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 control room a.
air temperature is less than or equal to 104 F.
b.
At least once per 31 days on a STAGGERED TEST BASIS by.
Initiating, f rom the control room, flow through the HEPA filters and charcoal adsorbers and verifying that the system operates for at least 15 minutes, At least once per 18 months or (1) af ter any structaral maintenance c,
on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system by:
MAR 261982 SEQUOYAH - UNIT 1 3/4 7-17 Amendment No.12
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I CONTAINMENT SYSTEMS 1
ICE BED 1EMPERATURE MONITORING SYSTEM ~
1 LIMITING CONDITICN FOR OPERATION 1
3.6.5.2 The ice bed temperature monitoring system shall be OPERABLE with at least 2 OPERABLE RTO channels in the ice bed at each of 3 basic elevations (10'6", 30'9", and 55' above the floor of the ice condenser) for each one third j
of the ice condenser.
APPLICABILITY:
MODES 1, 2, 3 and 4 ACTION:
a.
With the ice bed temperature indication not available in the main i
control room, determine the ice bed temperature at the c @e tensec lemnerAtga40nilotjpq-pane.1-perg ? ho rs THr PR.ovisiom a
secu rQt mon; 3. 0,4 AP.c Nor Af rut A B LE.
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r b.
W Tice DedMtuNtTri7trTyne noperable and unable to determine the ice bed temperatures by alternate means, POWER g73l OPERATION may continue for up to 6 days provided the ice compartment lower inlet doors, intermediate deck doors, and top deck doors are closed and the last recorded mean ice bed temperature was less than l
or equal to 15 F and steady; otherwise, be in at least HOT STANDBY i
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 1
30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />, SURVEILLANCE REQUIREMENTS 1
4.6.5.2 The ice bed temperature monitoring system shall be determined OPERABLE by performanca of a CHANNEL CHECK at least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
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$EQUOYAH - UNIT 2 3/4 6-29 Amenament No. 4, 76 October 14,'1988
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N ANI M 51 EMS 3/4, 7. 7 CONTROL ROOM [MERGU.C di,; ;i. A! I ON b 51[ M L'MITINC CCNDITION FOR OPERATION 3.7.7 Two independent control room emergency ventilation systems <. hall be OPERABLE.
APPLICABillTY: ALL MODES ACTICN:
MODES 1, 2, 3 and 4:
With one control roon emergency ventilation system ino erable, restore the inoperable system to OPERABLE status within 7 days or be in at least HOT STAT 1DBY 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 SHUTDOWil within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
MODES 5 and 6:
a.
With one control room emergency ventilation system inoperable, restore the inoperable system to OPERABLE status within 7 days or initiate and maintain operation of the control room emergency ventilation system in the recirculation mode, b.
With both control rocm emergency air ventilation systems inoperable, suspend all operations involving CORE ALTERAT10t45 or positive reactivity changes h p W nnn n fJr# c_ilj c,t i on MJ in MODE 6.
c.
a d.
THE Paovisions Ce Sect.i rit ATioru 3,0 4 Aes Mor Artucnetr, SURVE L/ TTCf'RE@NUttth A-4.7.7 Lach control room emergency ventilation system shall be demonstrated OPERABl.E:
a.
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 control room air temperature is less than or equal to 104 F.
b.
At least once per 31 days on a STAGGERED TEST BASIS by initiating, fro'a the control room, flow through the HEPA filters and_ charcoal adsorbers and verifying that the system operates for at least 15 minutes.
c.
At least once per 18 months or (1) af ter any structural maintenance on the HEPA filter or charcoal adsorber housings, or (2) following painting, fire or chemical release in any ventilation zone communicating with the system by:
SEQUOYAH - UNIT 2 3/4 7-17
ENCLOSURE 2 PROPOSED TECllNICAL SPECIFICATION (TS) Cl!ANGE SEQUOYAll NUCLEAR PIANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (IVA-SQN-TS-92-09 )
DESCRIPTION AND JUSTIFICATION FOR TS 3.0.4 EXCLUSION t
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5 DescriplicItoLChange TVA proposes to modify the Sequoyah Nuclear Plant (SQN) Units 1 and 2 technical specificaticas (TSs) to revise Action a, of TS 3.6.5.2, and the Mode 5 and 6 actions of TS 3.7.7 to ado an exclusion to TS 3.0.4.
The proposed change to TS 3.6.5.2 will allow changes in modes up to and including Mode 1 with the control room indication of ice bed temperatures inoperable, but local temperature monitoring available and obtainable on at least a 12-hour frequency. The exclusion would only apply to Action a, of TS 3.6.5.2, such that the loss of all ice bed temperature monitoring, as covered by Action b, will still require compliance with TS 3.0.4.
Changes in modes between Modes 5 and 6 will also be allowed when tne control room emergency ventilation system (CREVS) is inoperable. The exclusion for TS 3.7.7 will only apply when entering Modes 5 and 6 and TS 3.0.4 will remain applicable for operational modes above Mode 5 with CREVS inoperable.
Reason _LotChange The TS 3.0.4 requirement unnecessarily prevents plant start-up for the condition where the remote main control room indication is not available, but temperatures can still be monitored with local ice bed temperature monitoring instrumentation. The requirement to monitor ice bed temperatures locally every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> provides an acceptable level of safety for continued operation or entry into a higher operational mode.
For this reason the proposed exclusion to the requirements of TS 3.0.4 is requested for TS 3.6.5.2, Action a.
The TS 3.0.4 requirement for CREVS currently restricts mode changes between Modes 5 and 6, when one or both trains of CREVS are inoperable.
The required actions for these conditions are the same for both modes and allow continued operation for an indefinite period of time. The restriction on mode changes between Modes 5 and 6 could impact outage
-activities and the subsequent restart of the unit. The actions provide an acceptable level of safety for continued operation or entry into Modes 5 or 6.
For this reason, the proposed exclusion to the requirements of TS 3.0.4 is requested for the TS 3.7.7 actions applicable to Modes 5 and 6.
JuatiLicationlotChange Providing an exclusion to the requirements of TS 3.0.4 for the ice bed temperature monitoring system without control room indication operability and CREVS inoperability in Modes 5 and 6 is justified by the NRC position documented in Generic Letter 87-09, " Sections 3.0 and 4.0 of the Standard Technicel Sp.cifications (STS) on the Applicability of Limiting Conditions for Operation and Surveillance Requirements." This position states that when an. acceptable level of safety is provided for continued operation by the action requirements TS 3.0.4 unduly restricts facility operation. This position is considered valid for a limiting condition of operation that has action requirements permitting continued operation for an unlimited period of time. For the ice bed temperature msnitoring system specification, Action a, allows for indefinite unit operation when the main control room indication is inoperable and temperatures can be monitored every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> at the local-monitoring panel.
For'CREVS, the Mode 5 and 6 actions allow for indefinite unit operation with one train inoperal:le provided that train is restored to operable status within
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seven days or the CREVS is placed in the recirculation inode. With both j
trains of CREVS inoperable, indefinite unit operation is allowed in j
Modes 5 and 6 provided all operations involving core alterations or j
positive reactivity changes are suspended.
These requirements are
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consistent with the staff position that entry.nto an operational mode should be permitted in accordance with those action requirements.
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Therefore, this exclusion to the provisions of TS 3.0.4 is acceptable.
l Enrironmen.taL1mpacLEvaluation i
i The proposed change request does not involve an unreviewed environmental question because operation of SQN Units 1 and 2 in accordance with this change would nots i
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Result in a significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as i
modified by the staffis testimony to the Atomic. Safety and Licensing Doard, supplements to the FES, environmental impact appraisals, or decisions of the Atomic Safety and Licensing Board.
2.
Result in a significant change in effluents or power Jevels.
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3.
Renuit in matters not previously reviewed in the licensing basis for-SQN that may have a sl nificant environrnental impact.
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PROPOSED TECHNICAL SPECIFICATION (TS) CilANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-92-09 )
DETERMINATION OF NO SIGNIFICANT liAZARDS CONSIDERATION
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Significant Hasards Evaluation TVA has evaluated the proposed technical specification (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 (SQN) in accordance with the proposed amendment will not:
1.
Involve a significant increase in the probability or consequences of 4-an accident previously evaluated.
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This addition of an exclusion to TS 3.0.4 for ice bed temperature monitoring will continue to provide a level of temperature monitoring l
capability that will verify the operability of the ice condenser and j
thereby ensure its ability to mitigate the consequences of an accident.
Loss of all ice bed temperature monitoring capability will require unit shutdown within an acceptable time interval that ensures the availability of the ice condenser safety functions for accident l
mitigation.
For the inoperability of control room emergency ventilation system (CREVS) in Modes 5 and 6, the exclusion to TS 3.0.<, will not remove the actions to return the inoperable train to operable status or place the unaffected-train in operation.
Similarly, with both trains inoperable, suspension of core alterations or positive reactivity changes will still be required.
4 For operation la Modes 5 and 6, these actions are acceptable based on i
postulated accidents and are unchanged by the proposed change; I
therefore, the allowance to change between Modes 5 and 6 while maintaining these positions does not reduce the ability of the CREVS to perform the accident mitigation safety functions assumed in the analysis. Therefore, the TS 3.0.4 exclusion as applied in this a
proposed change to TSs 3.6.5.2 and 3.7.7 will not increase the consequences of an accident previously evaluated.
4 The allowance to change operational modes while maintaining the required actions as described will not reduce the availability or functionality of the ice bed temperature monitoring system or CREVS.
l This continues to ensure that the unit is maintained within the j
assumptions used in the safety analysis.
These systems provide monitoring and accident mitigation functions,'and these changes will not increase their potential to create accidentr because they are not considered the source of any accident.
Therefore, the proposed changes will not increase the probability of an accident previously evaluated.
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Create the possiaility of a new or different kind of accident from any previously analyzed.
As discussed above, the systems affected by this change provide monitoring and accident mitigation f t.ictions a-S are not postulated to be the source of any accident. This change only provides the allowance to change modes while maintaining the required actions that allow continued operation for indefinite periods of time. Therefore, this change cannot contribute to the initiation of an accident or create the possibility of a new or different accident.
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Involve a significant reduction in a margin of safety.
l This change does not alter any functions of the ice bed temperature monitoring system or CREVS, and' maintains the same-action i
requirements for system inoperability. These systems will continue j
to provide the same level of ice condenser temperature. indication and control room environment control as assumed in the safety analysis.
Therefore, the margin of safety is not reduced as a result of adding an exclusion to TS 3.0.4-for TSs 3.6.5.2 and 3.7.7.
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