ML20196G444

Application for Amends to Licenses DPR-77 & DPR-79,to Revise TS to Be Consistent with Rev to ISTS Presently Submitted to NEI TSTF for Submittal as Rev to NUREG-1431

ML20196G444
Person / Time
Site:	Sequoyah
Issue date:	06/24/1999
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20196G449	List: ML20196G444 ML20196G470
References
RTR-NUREG-1431 TVA-SQN-TS-99, TVA-SQN-TS-99-0, NUDOCS 9907010165
Download: ML20196G444 (8)

Text

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TA Tennessee Valley Authorny Post Office Box 2'100, Soddy-Daisy. Tennessee 37379 l

i June 24, 1999 l l

TVA-SQN-TS-99-05 10 CFR 50.90 i

U.S. Nuclear Regulatory Commission l ATTN: Document Control Desk l Washington, D. C. 20555 l

Gentlemen: '

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 I

1 SEQUOYAH NUCLEAR PLANT (SQN) - UNITS 1 AND 2 - TECHNICAL SPECIFICATION (TS) CHANGE No. 99-05, " CLARIFICATION OF ICE CONDENSER ICE WEIGHING REQUIREMENTS" In accordance with the provisions of 10 CFR 50.4 and 50.90, TVA is submitting a request for an amendment to SON's Licenses DPR-77 and 79 to change the TSs for Units 1 and 2.

The proposed change revises the Units 1 and 2 TSs to be consistent with the revision to the Improved Standard Technical Specifications (ISTS) presently submitted to the Nuclear Energy Institute Technical Specification Task Force (TSTF) for submittal as a revision to NUREG-1431. This proposed change was developed in coordination with the Westinghouse Owners Group - Ice Condenser Mini-Group (ICMG).

The ICMG represents all five domestic Westinghouse Ice Condenser Plants: Catawba, D. C. Cook, McGuire, Sequoyah, and Watts Bar Nuclear Stations. SON is considered to be the '

lead plant for the implementation of these revisions.

TVA has determined that there are no significant hazards /

considerations associated with the proposed change and that /

the change is exempt from environmental review pursuant to the provisions of 10 CFR 51.22 (c) (9) . The SON Plant of 9907010165'990624 PDR ADOCK 05000327 l P PDR

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U.S. Nuclear Regulatory Commission Page 2 June-24, 1999 l

Operations Review Committee and the SQN Nuclear Safety Review Board have' reviewed this proposed change and determined that operation of SON Units 1 and 2,.in accordance with the proposed change, will not endanger the health and safety of the public. Additionally, in accordance.with 10 CFR

50. 91 (b) (1) , TVA is sending a copy of this letter to.the Tennessee State Department of Public Health.

~ Enclosure 1 to this letter provides the description and evaluation-ofEthe proposed change. 7his includes TVA's determination that the proposed change does not involve a significant hazards consideration, and is exempt from envircnmental review. Enclosure 2 contains copies of the appropriate TS pages from Units 1 and 2 marked up to show the proposed change. Enclosure 3 forwards the revised TS pages for Units 1.and 2 which incorporate the proposed change.

TVA requests that the revised TS be made effective within 45 days of NRC approval. If you have any questions about this

-change, please telephone me at (423) 843-7170 or J. D. Smith i

at (423) 843-6672.

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) as Li e ing and Industry Affairs Manager i

scribed a d sworn t fore me i on his 84 - day of /n. yL l

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My Commission Expires October 9, 2002 Enclosures cc: -See page 3 i

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U.S.' Nuclear Regulatory Commission Page 3 June 24, 1999 cc (Enclosures):

Mr. R. W. Hernan, Project Manager Nuclear. Regulatory Commission One White Flint, North 11555-Rockville Pike Rockville, Maryland 20852-2739 Mr. Michael H. Mobley, Director (w/o Enclosures)

Division of Radiological-Health Third Floor L&C Annex 401 Church Street Nashville, Tennessee 37243-1532 NRC Resident Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator U.S. Nuclear Regulatory Commission

' Region II Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303-3415 I

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ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY l SEQUOYAH NUCLEAR PLANT (SQN)

^ UNITS 1 AND 2 l

l DOCKET NOS. 327 AND 328 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE 99-05 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE I. DESCRIPTION OF THE PROPOSED CHANGE A change is requested to the current SON Units 1 and 2 TSs to provide for consistency with the revision to the Improved Standard Technical Specifications (ISTS) submitted to the Nuclear Energy Institute Technical Specification Task Force (TSTF) for submittal as a revision to NUREG-1431. This proposed change was developed in coordination with the Westinghouse Owners Group - Ice Condenser Mini-Group (ICMG). The ICMG represents all five domestic Westinghouse Ice Condenser Plants: Catawba, D. C. Cook, McGuire, Sequoyah, and Watts Bar Nuclear Stations. SON is considered to be the lead plant for the implementation of these revisions.

Specifically, the requested change reformats the discussion 1 in Surveillance Requirement (SR) 4.6.5.1.d.2, addressing the actions required if the ice baskets selected for weighing in a single ice condenser bay falls below the minimum required value, into a note at the beginning of the SR. The note further' clarifies that only 20 additional  ;

baskets should be weighed even if more than one ice j condenser basket in a bay falls below the minimum required '

value. The proposed change also moves the ice basket  ;

selection methodology in SR 4.6.5.1.d.2 from the TS SR to '

the bases. The final requested revision to SR 4.6.5.1.d.2 adds a statement clarifying that the total ice weight described in the limiting condition of operation (LCO) is applicable to the beginning of each operating cycle.

Revisions to the associated bases of this SR are also proposed to more accurately reflect the Improved Standard Technical Specification Bases as proposed in TSTF submittal.

II. REASON FOR THE PROPOSED CHANGE The purpose of making the proposed change is to provide for  !

consistency between the SQN TS related to weighing ice baskets in the ice condenser and the proposed revision to the ISTSs. These changes implement the methodology agreed upon by the Ice Condenser Mini Group in accordance with the i El-1

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. industry initiative related to ice condenser plants. The reformatting of the note to the TS SRs to address the actions required if one or more ice baskets selected for weighing in a single ice condenser bay falls below the minimum required value ensures a consistent interpretation of the requirements of the TSs. The proposed change to move the ice basket selection methodology from the TS SR to I the bases is consistent with the ISTS format that provides for required values to be addressed in the SR and descriptions or methodologies to be a part of the bases.

Providing a clarification in the TS SR and the associated bases that the ice condenser ice weight criteria is for the beginning of an operating cycle ensures consistent interpretation of the required weight since the overall ice weight in the ice condenser may fall below the specified value over an operating cycle due to sublimation. ,

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III. SAFETY ANALYSIS The proposed change provides for consistency between the SON TS related to weighing ice baskets in the ice condenser and the proposed revision to the ISTSs described in the submittal from the TSTF. Reformatting the note to the TS SRs that addresses the actions required if one or more ice baskets selected for weighing in a single ice condenser bay falls below the minimum required value ensures a consistent interpretation of the requirements of the TSs and does not impact the intent or implementation of the TSs. The proposed change to move the ice basket selection i methodology from the TS SR to the bases is consistent with i the ISTS format that provides for required values to be addressed in the SR and descriptions or methodologies to be j a part of the bases. This revision does not affect the I implementation of the TS at SON since the procedural  :

requirement will not be affected. Providing a clarification in the TS SR and the associated bases that the ice condenser ice weight criteria is for the beginning of an operating cycle ensures consistent interpretation of q the required weight since the overall ice weight in the ice j condenser may fall below the specified value over an operating cycle due to sublimation. This proposed revision does not affect the intent or implementation of the TSs at ,

SON. The revisions proposed above will not result in any l change in the design, maintenance, or operation of the ice i condenser and its associated support equipment. Nor does this revision result in deviation from the actions )

presently approved by the staff for response to the j associated LCO; therefore, it can be safely implemented at )

, SON.

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• IV .

• NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION TVA has concluded that operation of SQN Units 1 and 2,

'in accordance with the proposed change to the technical  ;

specifications (TSs), does not involve a significant j hazards consideration. TVA's conclusion is based on its evaluation, in accordance with 10 CFR 50.91(a) (1), of the three standards set forth in 10 CFR 50.92 (c) .

A. The proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

The proposed TS amendments discussed below cannot increase the probability of occurrence of any analyzed accident because they are not the result or cause of l any physical modification to the ice condenser l structures, and for the current design of the ice condenser, there is no correlation between any credible failure and the initiation of any previously analyzed accident.

l Regarding the consequences of analyzed accidents, the preposed amendment provides for consistency with the ISTSs by: (1) requiring the actions if one or more ice condenser ice baskets are determined to weigh l below the minimum specified value to be made a part of the TS surveillance requirement (SR) instead of being located in the bases, and (2) relocating the Lce l basket selection methodology into the bases, 1his ensures consistent interpretation of the reqbirements  ;

of the TS in accordance with the ISTSs. The clarification of the response required if one or more i ice baskets in a given bay are determined to be underweight ensures sufficient ice is maintained in each bay to prevent early meltout in a local zone following a design basis accident (DBA) and that the required overall ice weight is maintained in the ice condenser. The relocation of the ice basket selection methodology to the bases does not result in any change to the intent or implementation of this portion of the TSs since plant procedures ensure the requirements of the bases of the TSs are correctly implemented.

Additionally, the clarification that the weight requirement is applicable to the beginning of the cycle does not change the present intent of the TS, but ensures there is no confusion, since the weight at the end of the operating cycle may be less than that specified in the SR due to sublimation. This does not result in a change to the intent or implementation of l the TS since a sublimation allowance was provided in the original SR weight requirement. These clarifications do not result in any affect on plant El-3

equipment or operation and the actions taken during the implementation of the revised TS will be the same as' prior to the revision. Therefore, the clarification of these requirements will not increase the consequences of any accident previously evaluated.

B. The proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

The inclusion of the action required for an underweight ice basket in the TS SR, instead of in the bases of the TS, provides for the consistent interpretation of the requirement. The clarification  ;

of the response required if one or more ice baskets in !

a given bay are determined to be underweight ensures sufficient ice is maintained in each bay to prevent early meltout in a local zone following a DBA and that the required overall ice weight is maintained in the ice condenser. The relocation of the ice basket selection methodology to the bases does not result in any change to the intent or implementation of this portion of the TSs since plant procedures ensure the requirements of the bases of the TSs are correctly implemented. Additionally, the clarification that the weight requirement is applicable to the beginning of the cycle does not change the present intent of the TS, but ensures there is no confusion, since the ,

weight at the end of the operating cycle may be less I than that specified in the SR due to sublimation.

This does not result in a change to the intent or implementation of the TS since a sublimation allowance was provided in the original SR weight requirement.

The operation, design and maintenance of the ice condenser and its associated equipment will not change as a result of these clarifications. Therefore, the implementation of these clarifications will not create the possibility of accidents or equipment malfunctions of a new or different kind from any previously evaluated.

C. The proposed amendment does not involve a significant reduction in a margin of safety.

The proposed amendment allows for the consistent interpretation of the required actions if an ice basket is determined to weigh less than the required minimum. The inclusion of these actions in the TS SR instead of in the TS bases assures the correct actions will be taken as intended by the TSs. The clarification of the response required if one or more ice baskets in a given bay are determined to be El-4

underweight ensures sufficient ice is maintained in each bay to prevent early meltout in a local zona following a DBA and that the required overall ice weight is maintained in the ice condenser. The relocation of the ice basket : election methodology to the bases does not result in any change to the intent or implementation of this portion of the TSs since plant procedures ensure the requirements of the bases of the TSs are correctly implemented. Additionally, the clarification that the weight requirement is applicable to the beginning of the cycle does not change the present intent of the TS, but ensures there is no confusion, since the weight at the end of the operating cycle may be less than that specified in the SR due to sublimation. This does not result in a change'to the. intent or implementation of the TS since a sublimation allowance was provided in the original SR weight requirement. The proposed clarifications do not result in or have any affect on the operation, design, or maintenance of any plant equipment. Thus the design limits for the continued safe function of the containment structure following a DBA are not exceeded due to this change; therefore, the proposed amendment does not involve a reduction in a margin of safety.

V. ENVIRO!OENTAL IMPACT CONSIDERATION The proposed change does not involve a significant hazards consideration, a significant change in the types of or significant increase in the amounts of any effluents that may be released offsite, or a significant increase in individual or cumulative occupational radiation exposure. Therefore, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9) .

Therefore, pursuant to 10 CFR 51.22 (b) , an environmental assessment of the proposed change is not required.

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