ML20154H725

Proposed Tech Specs Pages,Supplementing Proposed TS Change 96-08,rev 1 to Add CRMP to Administrative Controls Section & Bases of TS

ML20154H725
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Site:	Sequoyah
Issue date:	10/08/1998
From:	TENNESSEE VALLEY AUTHORITY
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ML20154H724	List: ML20154H720 ML20154H725
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NUDOCS 9810140304
Download: ML20154H725 (14)

Text

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ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)

UNITS 1 AND 2 DOCKET NOS. 327 AND 328 PROPOSED TECHNICAL SPECIFICATION (TS)

CHANGE TS-96-08, REVISION 1 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE I. DESCRIPTION OF THE PROPOSED CHANGE TVA proposes to add TS 6.8.4.i, entitled " Configuration Risk Management Program (CRMP) ," to the Administrative Controls section of SON's TSs. This addition supplements SON TS Change 96-08, Revision 1, that was submitted to NRC by letter dated August 27, 1998. TS Change 96-08, Revision 1, proposed an extension of the allowed outage time (AOT) for an emergency diesel generator (EDG) from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days, along with the deletion of unnecessary reporting requirements and a license condition. This supplement does not alter or impact these changes.

The purpose of the CRMP is to ensure that a probabilistic risk-informed assessment process is in place that assesses the overall impact of planned maintenance and unplanned i equipment inoperability on plant risk. The CRMP will j ensure that risk-significant configurations are not  ;

entered for planned EDG maintenance and provides risk j evaluations for unplanned plant configurations. The CRMP l will-be implemented whenever an EDG is out-of-service. l The programmatic elements included in the CRMP for SQN are  !

as follows:

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a. Provisions for the control and implementation of a Level 1 at-power internal events PRA-informed methodology. The assessment shall be capable of evaluating the applicable plant configuration,

b. Provisions for performing an assessment prior to entering the limiting condition for operation (LCO) action for preplanned activities.

c. Provisions for performing an assessment after entering an LCO action for unplanned entry into the LCO action.

9810140304 981000 PDR ADOCK 05000327 p PM' El-1

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.d. Provisions for assessing the need for additional actions after the discovery of additional equipment

, -out-of-service conditions while in the LCO action.

e .- Provisions for considering other applicable risk i significant contributors such as Level 2 issues and

' external events, qualitatively or quantitatively.

In addition to the. change. described above, TVA is revising l TS Bases Section 3/4.8 to include the basis for implementation of a CRMP as it applies to the TS action for removing an EDG from service.

II. REASON FOR THE PROPOSED CHANGE TVA is proposing the addition of the CRMP to the SQN TSs to support NRC's review of TS Change 96-08, Revision 1. TS Change 96-08, Revision 1, proposed an extension of SQN's EDG AOT from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 7 days. TVA's AOT extension request is based on-a three tier approach for the 1 evaluation of risk as recommended.in NRC Regulatory Guide ~(RG) 1.177. Tier 3 of this approach is a program that recommends the use.of a CRMP to ensure risk impacts

.are properly evaluated prior to performing EDG maintenance activities and for plant configuration changes when an EDG l is out-of-service. TVA did not include a CRMP as part of the proposed TS Change 96-08, Revision 1, although the Tier 1 and 2 provisions recommended by RG 1.177 were utilized.to justify the proposed change. The CRMP omission was based on existing methods for evaluating risk j L -associated with maintenance activities at SQN and NRC's l I

plans to place similar controls in the MaintenancefRule I

(10 CFR 50.65).

Based on recent staff guidance, NRC has requested that a l CRMP be included into SQN'TSs to ensure that TSs provide a j program for evaluating risk significant configurations associated with risk-informed AOT extensions. TVA's proposed supplemental TS change incorporates a CRMP into

, SON TSs to-satisfy the evaluation of risk significant l configurations and the intent of the Tier 3 program approach.

III. SAFETY ANALYSIS l

The proposed.TS' change adds a CRMP to ensure that a risk-informed process is.in place to assess the overall impact of plant maintenance and changing plant configurations on plant' risk. This program is implemented during periods when an EDG is out-of-service.

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1 l The programmatic elements of the CRMP ensure that the risk l impact of having an EDG out-of-service is appropriately

, evaluated prior to performing maintenance activities and for changing plant conditions while an EDG is inoperable.

The elements of SQN's proposed CRMP remain consistent with the guidance provided in RG 1.177. This supplement to the proposed TS change is a conservative addition of an l administrative risk-informed process to ensure that plant

risk are properly evaluated and taken into consideration.

I The risk assessments included in the CRMP will be performed in a timeframe defined by the SON's Corrective Action Program as recommended by the guidance in RG 1.177.

{

i The addition of this supplement to TS Change 96-08, l

Revision 1, does not impact the justification for the proposed 7-day EDG AOT change. This supplement l l incorporates RG 1.177 Tier 3 recommendations to further I support the AOT extension by providing risk-informed )

l assessments when-applying the 7-day provision. This addition enhances the acceptability for granting the 7-day EDG AOT and will improve the ability to maintain plant nuclear safety.

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ENCLOSURE 2 l

l TENNESSEE VALLEY AUTHORITY l SEQUOYAH PLANT (SQN) l UNITS 1 and 2 I 1

l l PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS 96-08, l REVISION 1 SUPPLEMENT l l MARKED PAGES 4

l I. AFFECTED PAGE LIST Unit 1

~

B 3/4 8-1 6-10a i l Unit 2

B 3/4 8-1 6-10 l-II. MARKED PAGES t- ,

l See attached.  !

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Insert

i. Configuration Risk Management Program The Configuration Risk Management Program (CRMP) provides a proceduralized risk-informed assessment to manage the risk associated with equipment inoperability. The program applies to technical specification structures, systems, or components for which a risk-informed allowed outage time has been granted. The program shall include the following elements:

a. Provisions for the control and implementation of a Level 1 at-power internal events PRA-informed methodology. The assessment shall be capable of evaluating the applicable plant configuration,

b. Provisions for performing an assessment prior to entering the Limiting Condition for Operation (LCO) Action for preplanned activities.

c. Provisions for performing an assessment af ter entering the LCO Action for unplanned entry into the LCO Action.

d. Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the LCO Action.

e. Provisions for considering other applicable risk significant contributors such as Level 2 issues and external events, qualitatively or quantitatively.

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3/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4.8.1 and 3/4.8.2 A.C. SOURCES AND ONSITE POWER DISTRIBUTION SYST5dS The OPERABILITY of the A.C. and D.C power sources and associated distri-bution systems during operation ensures that sufficient power will be available

to supply the safety related equipment required for 1) the safe shutdown of the I facility and 2) the mitigation and control of accident conditions within the

! facility. The minimum specified independent and redundant A.C. and D.C. power sources and distribution systems satisfy the requirements of General Design Criteria 17 of Appendix "A" to 10 CFR 50.

The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation commen-surate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the accident analyses and are based upon maintaining at least one redundant set of onsite A.C. and D.C.

power sources and associated distribution systeme OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure of the other onsite A.C. sourceyg The footnote for Action b of LCO 3.8.1.1 requires completion of a R209 determination that the OPERABLE diesel generators are not inoperable due to i common cause failure or performance of Surveillance 4.8.1.1.2.a.4 if Action b is entered. The intent is that all diesel generator inoperabilities must be investigated for common cause failures regardless of how long the diesel generator inoperability persists.

The action to determine that the OPERABLE diesel generators are not inoperable due to common cause failure provides an allowance to avoid unnecessary testing of OPERAELE diesel generators. If it can be determined that the cause of the inoperable diesel generator does not exist on the OPERABLE diesel generators, Surveillance Requirement 4.8.1.1.2.a.4 does not have to be performed. If the cause of inoperability exists on other diesel' generator (s), and the other diesel generator (s) would be declared inoperable upon discovery and Action e of LCO 3.8.1.1 would be entered as applicable.

Once the common failure is repaired, the common cause no longer exists, and the action to determine inoperability due to common cause failure is satisfied. If the cause of the initial inoperable diesel generator cannot be conformed not to exist on the remaining diesel generators, performance of Surveillance 4.8.1.1.2.a.4 suffices to provide assurance to continued OPERABILITY of the other diesel generators.

According to Generic Letter 84-15, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is reasonable to confirm that the OPERABLE diesel generators are not affected by the same problem as the inoperable diesel generator. %u,Tec L ADP0$EU fo4 De.tTl0Al &y 75 C. HAND r V0 6 AiY f.

l Additional ACTION requirements are spec fied or performance of the chemical cleaning required by Surveillance Requirement 4.8.1.1.2.f.1. The motor-driven fuel pumps for the diesel generator set with the tanks being R141 cleaned will be temporarily connected to the underground storage tanks for the eother diesel generator set with the same train designation. An additional I fuel-oil inventory of approximately 68,000 gallons will be available in one of (ftheyardstoragetankspriortothestartofthechemicalcleaningofany underground storage tank. Within practical limits, the chemical cleaning of an l

underground storage tank will be performed during a refueling or other ge for the associated unit.

June 29, 1995 SEQUOYAH - UNIT 1 B 3/4 8-1 Amendment No. 12, 137, 173, 205 r

i 4 4 w // m y x 6 Menow b qf uo 3.r.l.I, 77te f.ownsmnow tax Mwsexter fasxm De.st44ED Zu Secnod 4. 8, G. Ts As0a/4@ 'To AC 1;"h"'*'"'

- ADMINISTRATIVE CONTROLS R221 h' . Containment Leakage Rate Testino Procram A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54 (o) and 10 CFR 50 l Appendix J, Option B, as modified by approved exemptions. Visual examination and testing, including test intervals and extensions, shall be in accordance with Regulatory Guide (RG) 1.163,

" Performance-Based Containment Leak-Test Program," dated September 1995 with exceptions provided in the site implementing instructions.

l The peak calculated containment internal pressure for'the design basis loss of coolant accident, P., is 12.0 psig.

The maximum allowable containment leakage rate, L,, at P., is 0.25% of the primary containment air weight per day.

Leakage rate acceptance criteria are:

a. Containment overall leakage rate acceptance criteria is s 1.0 L.. During the first unit startup fol. lowing testing in accordance with this program, the leakage rate acceptance criteria are s 0.60 L, for the combined Type B and Type C tests, and s 0.75 L, for Type A tests; , ,

b. ' Air lock testing acceptance criteria are:

1) Overall air lock leakage rate is s 0.05 L, when tested at a P,.

2) For each door, leakage rate is s 0.01 L, when pressurized to a 6 psig for at least two minutes.

The provisions of SR 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of SR 4.0.3 are applicable to the Containment Leakage Rate Testing Program.

800 b6N February 5, 1996 SEQUOYAH - UNIT 1 6-10a Amendment No. 217 o

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3/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4.8.1 AND 3/4.8.2 A.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS The OPERABILITY of the A.C. and D.C power sources and associated distribution systems during operation ensures that sufficient power will;be available to supply the safety related equipment required for 1) the safe shutdown of the facility and 2) the mitigation and control of accident condi-tions within the facility. The minimum specified independent and redundant A.C. and D.C. power sources and distribution systems satisfy the requirements of General Design Criterion 17 of Appendix "A" to 10 CFR 50.

The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation

commensurate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the safety analyses and are based upon maintaining at least one redundant set of onsite A.C. and D.C. power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure of the other'onsite A.C. source.pf

[ The footnote for Action b of LCO 3.8.1.1 requires completion of a f determination that the OPERABLE diesel generators are not inoperable due to common cause failure or performance of Surveillance 4.8.1.1.2.a.4 if Action b is entered. The intent is that all diesel generator inoperabilities must be investigated for common cause failures regardless of how long the diesel R195 generator inoperability persists. _

The action to determine that the OPERABLE diesel generators are not  !

l inoperable due to common cause failures provides an allowance to avoid l l unnecessary testing of OPERABLE diesel generators. If it can be determined that the cause of the inoperable diesel generator does not exist on the .

OPERABLE diesel generators, Surveillance Requirement 4.8.1.1.2.a.4 does not have to be performed. If the cause of inoperability exists on other diesel generator (s), the other diesel generator (s) would be declared inoperable upon discovery and Action e of LCO 3.8.1.1 would be entered as applicable. Once the common failure is repaired, the common cause no longer exists, and the action l l to determine inoperability due to common cause failure is satisfied. If the cause of the initial inoperability diesel generator cannot be confirmed not to exist on the remaining diesel generators, performance of Surveillance l 4.8.1.1.2.a.4 suffices to provide assurance of continued OPERABILITY of the l other diesel generators. i

! According to Generic Letter 84-15, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is reasonable to confirm that ,

the OPERABLE diesel generators are not affected by the same problem as the i inoperable diesel generator.

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Additional ACTION requ remedts are specified for performance of the 123 l

, chemical cleaning required by Surveillance Requirement 4.8.1.1.2.f.1. The j l motor-driven fuel pumps for the diesel generator set with the tanks being l cleaned will be temporarily connected to the underground storage tanks for the j other diesel generator set with the same train designation. An additional fuel-oil inventory of approximately 68,000 gallons will be available in one of the yard storage tanks prior to the start of the chemical cleaning of any underground storage tank. Within practical limits, the chemical cleaning of an

. underground storage tank will be performed during a refueling or other scheduled outage _for the associated unit. - -

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WHEN Am.yern Action b Op LCO 3.S,l. lj THE CoHFMuRAttod AAM AANAbMM keAm Desct.tsBo XN SecToor) lo. t. Y.i Is REauingv To Be .hfumsv7ED.

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1 June 29, 1995 SEQUOYAH - UNIT 2 B 3/4 8-1 Amendment No. 123, 164, 195 l

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1 1

ADMINISTRATIVE CONTROLS-L ~ b' , Air lock testing acceptance criteria are:

i

1) Overall air lock leakage rate is s 0.05 L, when tested at a P. . l f  ;

[ 2) For each door, leakage rate is s 0.01 L, when pressurized to R207 l = 6 psig for at least two minutes.

I '

The provisions of SR 4.0.2 do not apply to the test frequencies spe'cified ~ '

! in the Containment Leakage Rate Testing Program.

l l The provisions of SR 4.0;3 are applicable to .the Containment Leakage Rate - 4 l Testing Program. '

g ~6 '. 9 . REPORTING REOUIREMENTS l

1 l ROUTINE REPORTS 6.9.1- In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted in accordance R64 with 10 CFR 50.4.

STARTUP REPORT

~

6.9.1.1 DELETED 6.9.1.2 DELETED R223 6.9.1.3 DELETED Aoo I m e12.7 i

l-I-

i l July 1, 1998 L SEQUOYAH - UNIT 2 -6'10 Amendment No. 28, 50, 64, 66, 134, 207, 223

ENCLOSURE 3 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)

UNITS 1 and 2 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS 96-08, REVISION 1 SUPPLEMENT REVISED PAGES I. AFFECTED PAGE LIST Unit 1 B 3/4 8-1 6-10a Unit 2 B 3/4 8-1 6-10 II. REVISED PAGES See attached.

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3/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4.8.1 and 3/4.8.2 A.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS The OPERABILITY of the A.C. and D.C power sources and associated distri-bution systems during operation ensures that eufficient power will be available to supply the safety related equipment required for 1) the safe shutdown of the facility and 2) the mitigation and control of accident conditions within the facility. The minimum specified independent and redundant A.C. and D.C. power sources and distribution systems satisfy the requirements of General Design Criteria 17 of Appendix "A" to 10 CFR 50.

The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation commen-surate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the accident analyses and are based upon maintaining at least one redundant set of onsite A.C. and D.C.

power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure of the other onsite A.C. source. When applying Action b of LCO 3.8.1.1, the Configuration Risk Management Program described in Section 6.8.4.i is required to be implemented.

The footnote for Action b of LCO 3.8.1.1 requires completion of a R209 determination that the OPERABLE diesel generators are not inoperable due to common cause failure or performance of Surveillance 4.8.1.1.2.a.4 if Action b is entered. The intent is that all diesel generator inoperabilities must be investigated for common cause failures regardless of how long the diesel generator inoperability persists.

The action to determine that the OPERABLE diesel generators are not inoperable due to common cause failure provides an allowance to avoid unnecessary testing of OPERABLE diesel generators. If it can be determined that the cause of the inoperable diesel generator does not exist on the OPERABLE die' c4 generators, Surveillance Requirement 4.8.1.1.2.a.4 does not have to be performed. If the cause of inoperability exists on other diesel generator (s), the other diesel generator (s) would be declared inoperable upon discovery and Action e of LCO 3.8.1.1 would be entered as applicable. Once the common failure is repaired, the common cause no longer exists, and the action to determine inoperability due to common cause failure is satisfied. If the cause of the initial inoperable diesel generator cannot be confirmed not to exist on the remaining diesel generators, performance of Surveillance 4.8.1.1.2.a.4 suffices to provide assurance to continued CPERABILITY of the other diesel generators.

According to Generic Letter 84-15, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is reasonable to confirm that the OPERABLE diesel generators are not affected by the same problem as the inoperable diesel generator.

SEQUOYAH - UNIT 1 B 3/4 8-1 Amendment No. 12, 137, 173, 205,

I ADMINISTRATIVE CONTROLS R221

h. Containment Leakage Rate Testino Procram A program shall be established to implement the leakage rate testing '

of the containment as required by 10 CFR 50.54(o) and 10 CFR 50 Appendix J, Option B, as modified by approved exemptions. Visual l

examination and testing, including test intervals and extensions, i shall be in accordance with Regulatory Guide (RG) 2.163, l

" Performance-Based Containment Leak-Test Program," dated September '

1995 with exceptions provided in the site implementing instructions.

The peak calculated containment internal pressure for the design basis loss of coolant accident, P., is 12.0 psig.

The maximum allowable containment leakage rate, L,, at P, is 0.25% of '

1 the primary containment air weight per day.

Leakage rate acceptance criteria are:

a. Containment overall leakage rate acceptance criteria is s 1.0 L,. During the first unit startup following testing in accordance with this program, the leakage rate acceptance  !

criteria are s 0.60 Ig for th; combined Type B and Type C tests, I and s 0. 75 Lg for Type A tests; '

b. Air lock testing acceptance criteria are:

1) Overall air lock leakage rate is s 0.05 L, when tested at a P .

2) For each door, leakage rate is s 0.01 L, when pressurized to a 6 psig for at least two minutes. j The provisions of SR 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of SR 4.0.3 are applicable to the Containment Leakage Rate Testing Program,

i. Conficuration Risk Manacement Procram l

The Configuration Risk Management Program (CRMP) provides a proceduralized risk-informed assessment to manage the risk associated with equipment inoperability. The program applies to Technical Specification structures, systems, or components for which a risk-l informed allowed outage time has been granted. The program shall l include the following elements:

a. Provisions for the control and implementation of a Level 1 at-

power internal events PRA-informed methodology. The assessment i shall be capable of evaluating the applicable plant

configuration.

! b. Provisions for performing an assessment prior to entering the Limiting Condition for Operation (LCO) Action for preplanned i

activities.

c. Provisions for performing an assessment after entering the LCO Action for unplanned entry into the LCO Action.

d. Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the LCO Action.

e. Provisions for considering other applicable risk significant contributors such as Level 2 issues and external events, qualitatively or quantitatively.

SEQUOYAH - UNIT 1 6-10a Amendment No. 217,

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

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

3/4[8 ELECTRICAL POWER SYSTEMS I l

. . i BASES I

'3/4.8.l'AND 3/4.8.2 A.C. SOURCES AND ONSITE POWER DISTRIBUTION SYSTEMS The OPERABILITY of the A.C. and D.C power sources and associated distribution systems during operation ensures that sufficient power will be available to supply the safety related equipment required for 1) the safe shutdown of the facility and 2) the mitigation and control of accident condi-tions within the facility. The minimum specified independent and redundant A.C. and D.C. power sources and distribution systems satisfy the requirements of General Design Criterion 17 of Appendix "A" to 10.CFR 50.

The ACTION requirements specified for the levels of degradation of the power sources. provide restriction upon continued facility operation commensurate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the safety l analyses and are based upon maintaining at least one redundant set of onsite  !

A.C. and D.C. power sources and associated distribution systems OPERABLE during j accident conditions coincident with an assumed loss of offsite power and single I failure of the other onsite A.C. source. When applying Action b of LCO )

3.8.1.1, the Configuration Risk Management Program described in Section 6.8.4.i is required to be implemented.

The footnote for Action b of LCO 3.8.1.1 requires completion of a I determination that the OPERABLE diesel generators are not inoperable due to common cause failure or performance of Surveillance 4.8.1.1.2.a.4 if Action b is entered. The intent is that all diesel generator inoperabilities must be l investigated for common cause failures regardless of how long the diesel R195 .)

generator inoperability persists.

The action to determine that the OPERABLE diesel generators are not inoperable due to common cause failures provides an allowance to avoid I unnecessary testing of OPERABLE diesel generators. If it can be determined I that the cause of the inoperable diesel generator does not exist on the OPERABLE diesel generators, Surveillance Requirement 4.8.1.1.2.a.4 does not have to be performed. If the cause of inoperability exists on other diesel generator (s), the other diesel generator (s) would be declared inoperable upon discovery and Action e of LCO 3.8.1.1 would be entered as applicable. Once the common failure is repaired, the common cause no longer exists, and the action to determine inoperability due to common cause failure is satisfied. If the cause of the initial inoperable diesel generator cannot be confirmed not to exist on the remaining diesel generators, performance of Surveillance 4.8.1.1.2.a.4 suffices to provide assurance of continued OPERABILITY of the other. diesel generators.

~According to Generic Letter 84-15, 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is reasonable to confirm that the. OPERABLE diesel generators are not affected by the same problem as the inoperable diesel. generator.

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SEQUOYAH - UNIT 2 B 3/4 0-1 Amendment No. 123, 164, 195, I

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4 ADMINISTRATIVE CONTROLS 12-L. Air lock teeting acceptance criteria are:

1) O';erall air lock leakage rate is s 0.05 L, when tested at a P.,

2) For each door, leakage rate is s 0.01 L, when pressurized to R207 a 6 psig for at least two minutes.

The provisions of SR 4.0.2 do not apply to the test frequencies specified in the Containment Leakage Rate Testing Program.

The provisions of SR 4.0.3 are applicable to the Containment Leakage Rate Testing Program.

i. Configuration Risk Manacement Procram The Configuration Risk Management Program (CRMP) provides a proceduralized risk-informed assessment to manage the risk associated with equipment inoperability. The program applies to Technical Specification structures, systems, or components for which a risk-informed allowed outage time has been granted. The program shall include the following elements:

a. Provisions for the control and implementation of a Level 1 at-power internal events PRA-informed methodology. The assessment shall be capable of evaluating the applicable plant configuration.

b. Provisions for performing an assessment prior to entering the Limiting condition for Operation (LCO) Action for preplanned activities,

c. Provisions for performing an assessment after entering the LCO l Action for unplanned entry into the LCO Action, l

d. Provisions for assessing the need for additional actions after I the discovery of additional equipment out of service conditions I while in the LCO Action. l

e. Provisions for considering other applicable risk significant contributors such as Level 2 issues and external events, qualitatively or quantitatively.

6.9 REPORTING REOUIREMENTS ROUTINE REPORTS 6.91 In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following reports shall be submitted in accordance R64 with 10 CFR 50.4.

STARTUP REPORT 6.9.1.1 DELETED 6.9.1.2 DELETED R223 6.9.1.3 DELETED i

l SEQUOYAH - UNIT 2 6-10 Amendment No. 28, 50, 64, 66, 134, 207, 223, t #7