ML20207D594

Application for Amend to Licenses DPR-77 & DPR-79,relocating TS 3.7.6, Flood Protection Plan & Associated Bases from TS to Plant TRM

ML20207D594
Person / Time
Site:	Sequoyah
Issue date:	02/26/1999
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20207D599	List: ML20207D594 ML20207D601
References
TVA-SQN-TS-98, TVA-SQN-TS-98-0, NUDOCS 9903100022
Download: ML20207D594 (7)

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Temessee Valley Authonty Pos10thce Box 2000. Soddy-Daisy Tennessee 37379 February 26, 1999  !

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TVA-SON-TS-98-08 10 CFR 50.90  !

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

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

SEQUOYAH NUCLEAR PLANT (SQN) - UNITS 1 AND 2 - TECHNICAL l SPECIFICATION (TS) CHANGE NO. 98-08, " FLOOD PROTECTION PLAN" 1

In accordance with the provisions of 10 CFR 50.4 and 50.90, TVA is submitting a request for an amendment.to Licenses j DPR-77 and DPR-79 to change the TSs for Units 1 and 2. The  !

proposed change relocates TS 3.7.6, " Flood Protection Plan,"

and the associated bases from the TS to the SON Technical l Requirements Manual (TRM). This change does not alter the l current requirements for implementation or surveillance testing of the Flood Protection Plan and future revisions of  ;

these requirements will require an evaluation in accordance with 10 CFR 50.59. .

l TVA has determined that there are no significant hazards l considerations associated with the proposed change and that  :

the change is exempt from environmental review pursuant to t he provisions of 10 CFR 51.22 (c) (9) . The SON Plant Operations Review Committee and the SON Nuclear Safety Review Board have reviewed this proposed change ahd determined that l//

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 jf 10 CFR 50. 91 (b) (1) , TVA is sending a copy of this letter to the Tennessee State Department of Public Health.

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9903100022 990226 PDR A)G P

ADOCK 050003279 q ryg _mq v 4

U.S. Nuclear Regulatory Commission

-Page<2 February 26,'1999 Enclosure 1 to this letter'provides the description and evaluation of the proposed change. This. includes TVA's determination that the proposed change does not involve a significant hazards. consideration, and is exempt from ,

environmental review. Enclosure 2 contains copies of the  !

appropriate TS pages from Units 1 and 2 marked-up to show the ,

proposed change. Enclostre'3' forwards the revised TS pages '

-for Units 1'and ? which incorporate the proposed change. i TVA requests that the revised TS be made effective within  !

45 days of NRC approval. If you have any questions about i this change, please telephone me at (423) 843-7170 or'J. D. [

Smith at- (423)l 843-6672.

Sipcerely, s

ed 'a as Mr.oger of Licensing Subscribed apd sworn to bpfore me this h/nt day of br]>w a/W PM[ jL D'/1 1 1) /

Notaff Public

/ j' My Commission Expires October 9, 2002  !

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Enclosures cc: See page 3 r

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U.S. Nuclear Regulatory Commission j Page 3 F.ebruary 26, 1999 cc (Enclosures):

Mr. R. W. Hernan, Project Manager Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike l Rockville, Maryland 20852-2739 '

l Mr. Michael H. Mobley, Director (w/o Enclosures)

Division of Radiological Health )

Third Floor 1 L&C Annex 401 Church Street Nashville, Tennessee 37243-1532 NRC Resident l Sequoyah Nuclear Plant l 2600 Igou Ferry Road E

Soddy-Daisy, Tennessee 37379-3624 I

Regional Administrator i 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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l ENCLOSURE 1 l TENNESSEE VALLEY AUTHORITY l-SEQUOYAH NUCLEAR PLANT (SQN)

UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE 98-08 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE I. DESCRIPTION OF THE PROPOSED CHANGE The proposed change will remove the flood protection requirements and the associated Bases from the TSs for Units 1 and 2. TVA will relocate the flood protection requirements to the SON Technical Requirements Manual (TRM). In addition, the appropriate TS index pages have been revised to reflect this change.

II. REASON FOR THE PROPOSED CHANGE TVA requests the proposed change to remove requirements from the SQN TSs that do not meet the criteria in 10 CFR 50.36. TVA's proposed change is provided in accordance with the guidance in the Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, published in the Federal ,

Register, (58 FR 39132). The NRC Final Policy Statement l states that TS requirements that do not meet any of the j screening criteria for retention may be proposed for removal from the TS and relocated to licensee-controlled i documents, such as the Final Safety Analysis Report or TRM. I TVA's proposed change will allow revisions to the Flood Protection Plan,_in accordance with 10 CFR 50.59, without i requiring a License Amendment Request and adds flexibility l to processing necessary changes.  ;

1 III. SAFETY ANALYSIS l l

SON's Flood Protection Plan is designed to minimize impact i of floods above plant grade on safety-related facilities. j Procedures _for predicting rainfall floods, arrangements to warn of upstream dam failure floods, and lead times available and types of action to be taken to meet related safety requirements for both sources of flooding are described therein. Currently SQN's TSs provide the limiting conditions of operation (LCO) and surveillance requirements to verify the implementation of the Flood Protection Plan to minimize the consequences of floods, i

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i TVA's proposed TS~ change.is consistent with the guidance in  !

, . the Commission's Final Policy Statement on Technical ,

Specifications-Improvements for Nuclear Power Reactors and  !

with Standard TS (NUREG-1431). In NUREG-1431, there are no Flood Protection Plan TS requirements because this plan )

does not meet the criteria in 10 CFR 50.36. In addition, l TVAl evaluated SON's current flood protection TS l requirements against the criteria of 10 CFR 50.36. The following discussions address the applicability of the l10 CFR 50.36 criteria to SON's TS for the Flood Protection 1 Plan.

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Criterion 1: Installed instrumentation that is used to  !

detect, and indicate in the control room, a significant l abnormal ~ degradation of the reactor coolant pressure 8 boundary.

SON's Flood Protection Plan is designed to minimize impact {

of floods above plant grade on safety-related facilities. i Procedures for predicting rainfall floods, arrangements to warn of upstream dam failure floods, and lead times l available and types of action to be taken to meet related safety requirements for both sources of flooding are features of the plan. SON's Flood Protection Plan is not installed instrumentation that is used to detect and indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary.

Accordingly, the SON Flood Protection Plan does-not satisfy Criterion 1.

Criterion 2: A process variable, design feature or operating restriction that is an initial condition of a l Design Basis Accident (DBA) or Transient that either l assumes the failure of or presents a challenge to the i integrity of a fission product barrier. l.

SQN's Flood Protection Plan is not a process variable that is an initial condition of a DBA or transient that either assumes the failure of or presents a challenge to the-integrity of a fission product barrier. Therefore, the SON Flood Protection Plan does not satisfy Criterion 2.

-Criterion 3: A structure, system or com.ponent that is part

- of the primary success path and which functions or actuates to' mitigate a DBA or Transient that either assumes'the i failure of or presents a challenge to the integrity of a fission product barrier.

SON's Flood Protection Plan is not a structure, system or l component that is part of the primary success path for i

accident mitigation. In addition, the Flood Protection LPlan'does not function or actuate to mitigate a DBA or

. Transient that either assumes the failure of or presents a i challenge-to the integrity of a fission product barrier.

l Accordingly, the Flood Protection Plan does-not satisfy

' Criterion 3.

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. Criterion 4: A structure, system or component, which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

Operational experience and deterministic safety assessment evaluation as identified in the SON Generic Letter 88-20 l response has not shown the SON Flood Protection Plan to be significant to_the public health and safety. Therefore,  !

the Flood Protection Plan does not satisfy Criterion 4.  !

The proposed relocation of flood protection requirements to the SON TRM is acceptable based on the above discussions. l The relocated requirements will be controlled in accordance with those established for the TRM. These requirements include appropriate administrative controls and reviews and  ;

a 10 CFR 50.59 evaluation which will ensure changes are not i implemented that would reduce the functionality of or introduce an unreviewed safety question to SON's Flood Protection Plan.

IV. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION TVA has concluded that operation of SON Units 1 and 2, in I accordance with the proposed change to the technical l specification (TS), does not involve a significant hazards )

consideration. TVA's conclusion is based on its l evaluation, in accordance with 10 CFR 50.91(a) (1), of the i three standards set forth in 10 CFR 50.92 (c) .

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

1 The proposed revision to the TS relocates the l requirements for SQN flood protection without changing the current requirements. This administrative relocation of the requirements will not increase the possibility of an accident. The capability of the i Flood Protection Plan will continue to provide the I same function. Changes to the relocated requirements l will be processed, in accordance with 10 CFR 50.59, to  ;

ensure the Flood Protection Plan will be properly maintained. Therefore, the proposed relocation of the l flood protection requirements will not increase the  !

probability or consequences of an accident previously 1 evaluated.

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

! accident previously evaluated.

l The SON Flood Protection Plan is used to mitigate the effects of a flooding event at SON. This plan would not be the initiator of any new or different kind of El-3

e-j accident. The capability of the Flood Protection Plan ,

will continue to provide the same function. Changes l

to the relocated requirements will be processed, in l accordance with 10 CFR 50.59, to ensure the Flood i Protection Plan will be properly maintained. The proposed change does not alter the current functions of SON's Flood Protection Plan; therefore, this proposed change will not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

The requirements for SON's flood protection are unchanged by the proposed relocation of the requirements to the SON TRM. The function of the Flood Protection Plan and surveillance requirements to ensure implementation of the plan remains unchanged.

Any future changes to these requirements will be evaluated, in accordance with 10 CFR 50.59, to ensure acceptability and NRC review as required.

Accordingly, the proposed change will not result in a reduction in a margin of safety.

V. ENVIRONMENTAL IMPACT CONSIDERATION  !

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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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