ML20206F381

Forwards Justification for Not Revising Plant Tech Specs to Incorporate Surveillance Requirement 3.0.4 Proposed in Generic Ltr 87-09

ML20206F381
Person / Time
Site:	Sequoyah
Issue date:	11/15/1988
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
GL-87-09, GL-87-9, NUDOCS 8811210109
Download: ML20206F381 (3)

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, ', TENNESSEE VALLEY AUTHORITY CH ATTANOOG A. TENNESSEE 37401 SN 1578 Lookout Place NOV 151988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Hashington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee VaH ey Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) - TVA POSITION REGARDING TECHNICAL SPECIFICATION (TS) 3.0.4 AND GENERIC LETTER (GL) 87-09

References:

1. NRC GL 87-09 dated June 4, 1987, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Condltions For Operation and Surveillance Requirements (Generic Letter 87-09)"

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2. TVA letter to NRC dated June 9, 1988. "Sequoyah Nuclear Plant (SQN) - Technical Specification Change 88-05" i

3. NRC letter to TVA dated August 15, 1988, "Amend Tables 3.6.1 and 3.6.2, and Implement Generic Letter 87-09 (TAC R00339 R00340, R00358, R00359)(TS 88-07 and TS~88-05) - Sequoyah Nuclear Plant, Units I and 2" NRC GL 87-09 (reference 1) solicited TS changes from licensees for surveillance requirements (SR) 4.0.3, 4.0.4, and 3.0.4. TVA, by reference 2, submitted changes to SRs 4.0.3 and 4.0.4 in accordance with GL 87-09 and i provided justification for not changing SQN's TS SR 3.0.4. NRC, by

reference 3, expressed three concerns regarding TVA's justification for not 1 including the modification to SR 3.0.4. In response to the staff's oncerns, TVA has included, in the enclosure, further justification for not revising j SQN's TSs to incorporate the net SR 3.0.4 as propos In GL 87-09.

Please direct questions concerning this issue to D. V. Goodin at l

I615) 870-7734.

1 i Very truly yours, TENN SSEE VA EY AUTHORITY A

R. G idley, Ma ger Nuclear Licen ing and Regulatory Affairs g Enclosure cc: See page 2 h 1 l

l G811210109 091115

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DR ADOCK0500g7 An Equal Opportunity Employer

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2-J U.S. Nuclear Regulatory Comission NffV 151988 cc (Enclosure):

Ms. S. C. B!ack Assistant Olrector '

forProjects TVA Projects Division  :

U.S. Nuclear Regulatory Ccmisslos.

One White Flint, North 11555 Rockville Pike .

r Rockville, Maryland 2085' -

r '. F. R. McCo'y, Assistant Director '

for Inspection Program' ,

TVA Projects Olvision -

j U.S. Nuclear Regulatory Comission '

Region II i 101 Marietta Street, NW, Suite 2900 i Atlanta, Georgia 30323 -

Sequoyah Resident inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road r Soddy Laisy, Tennessee 37379 l L

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ENCLOSURE TVA's RESPONSE TO THREE NRC CONCERNS FOR H00!FYING SURVEILLANCE REQUIK! MENT (SR) 3.0.4 IN ACCORDANCE WITH GENERIC LETTER (GL) 87-09 By letter dated August 15, 1988, NRC Mpressed three concerns regarding TVA' justification for not proposing a modification _to SR 3.0.4 in accordance with GL 87-09. TVA has evaluated these concerns and provides the following responses. '

1. NRC Concern

. . without the TS 3.0.4 modification, SQN may one day undergo i unnecessary shutdowns caused by future TS changes which do not explicitly j state that the affected specifications are exempt from the provisions of i SR 3.0.4. This situation may arise as the NRC Technical Specification  !

Improvement Program progresses, during which changes proposed under the auspices of this Program may be written assuming that SR 3.0.4 has been modified per the guidance of Generic Letter 87-09." i i TVA Rosponse NRC's +echnical specification improvement program (TSIP) i s currently ,

under development. TVA will reconsider modifying S.1 3.0.4 in light of NRC's TSIP as it unfolds. Because neither NRC nor TVA knows the full scope of the TSIP at this time, SQN's current version of SR 3.0.4 rt; mains 4

acceptable. In addition, each of the TS Improvements provided by GL 87-09 -

was presented to the licensees for inclusion into.their technical  !

specifications (TSs) on a voluntary basis.

2. plRC Concern f

. . . inclusion of this modificatter, in the SQN TS, and the associated deletion of the exceptions to TS 3.0.4, would result in a clearer, easier [

j to use document, which, in turn, would enhance operational safety."

TVA Response TVA disagrees that the new SR 3.0.4 1s clearer and would enhance operational safety. SQN's operators and plant staff stated that the new i

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' SR 3.0.4 would be harder to use anc migbr lead to errors in interpretation that could, in fact, create a safety concern, t i

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3. NRC Concern f

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. . . TVA's failure to propose this change is not consistent with the  !

current NRC and nuclear industry effort to simplify and standardize '

] Technical Specifications, with the overall goal of improved plant safety." l j TVA Response The new SR 3.0.4 appears to be a simpitfication; however, TVA did not view  !

this as a simplification. The new SR 3.0.4 requires interpretation by the  !

i operator, whereas SQN's current SR 3.0 4 does not. TVA's justification ,

for not modifying SR 1.0.4 was not based on operator convenience but i rather on safety.

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