ML20207D625

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Application for Amends to Licenses DPR-77 & DPR-79,revising TS to Provide for Consistency When Exiting Action Statements Associated with EDG Sets
ML20207D625
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 02/26/1999
From: Salas P
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20207D630 List:
References
NUDOCS 9903100029
Download: ML20207D625 (6)


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IUA Tennessee Valley Authonty. Post Offee Box 2000, Soddy-Darsy. Tunnessee 37379 February 26, 1999 TVA-SON-TS-99-02 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN:

Document Control Desk Washington, D.

C.

20555 Gentlemen:

In the Matter of

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Docket Nos. 50-327 Tennessee Valley Authority

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50-328 SEQUOYAH NUCLEAR PLANT (SQN) - UNITS 1 AND 2 - TECHNICAL SPECIFICATION (TS) CHANGE NO. 99-02, " REVISION TO DIESEL GENERATOR (D/G) ASSOCIATED ACTION STATEMENTS" 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 SON Units 1 and 2 TSs to provide for consistency when exiting the action statements associated with the emergency D/Gs sets.

TVA inadvertently l

omitted revising Action Statements c, d,

and e associated with TS 3.8.1.1 in Revision 1 to TS Change 96-08, addressing

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the D/G seven-day allowed outage time, submitted to the staff on October 8, 1998.

TVA has determined that there are no significant hazards i

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 D

Operations Review Committee and the SON Nuclear Safety Review o$

q Board have reviewed this proposed change and determined that g

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ration of SON Units 1 and 2, in accordance with the 7

proposed change, will not endanger the health and safety of the public.

9903100029 990226 T

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PDR ADOCK 05000327 P

PDR(

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~ U.S. Nuclear. Regulatory Commission l

Page 2 l

February 26, 1999 l

Additionally, in accordance Oith 10 CFR 50.91(b) (1), TVAis sending a copy of:this letter to the Tonnessee State-Department of Public. Health.

-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

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significant hazards consideration, and is exempt from

- environmental review. contains' copies of the appropriate TS pages from Units 1 and-2 marked-up to show the l

proposed change. forwards the revised TS pages-j for Units 1 and-2 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 this change, please telephone me at (423) 843-7170.or J. D.

Smith at (423) 843-6672.

S h-O a mt r

Pe ro Salas Licensing and. Industry Affairs anager Subscribed agd sworn to before me this rQln day af w i/1M/)ALI 0'

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Notar'y# P6blic'

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My Commission-Expires

_ October 9, 2002 Enclosures cc:

See page 3 l

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U.S. Nuclear Regulatory Commission Page 3 l

February 26,11999 cc (Enclosures) :

Mr. R. W.-Hernan, Project-Manager Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike i

Rockville, Maryland 20852-2739 j

Mr. Michael H. Mobley, Director (w/o Enclosures) l Division of Radiological Health Third Floor L&C Annex

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401 Church Street i

Nashville, Tennessee 37243-1532

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NRC Resident i

Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 i

Regional Administrator U.S. Nuclear Regulatory Commission Region II i

Atlanta Federal Center (1 Forsyth St.,

SW, Suite 23T85 Atlanta, Georgia 30303-3415 I

ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)

UNITS 1 A4E 2 DOCKET NOS. 327 AND 328 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE 99-02 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE I.

DESCRIPTION OF.THE PROPOSED CHANGE A change is requested to the current SON Units I and 2 TSs to provide for-consistency between the action statements associated.with TS 3.8.l'.1, "A.C.

Sources."

Specifically,.

Action c is being revised to delete the sentence associated with restoring at least two offsite circuits and four diesel generator (D/G) sets to operable status.

Action d

.is being revised to delete the sentence associated with restoring at least two offsite circuits to operable status and Action e is being revised to delete the sentence associhted with restoring at-least four D/G sets to operable status.

In each of these cases,. the sentence being deleted is the last sentence in the specified action statement and the requirements of the specified action is already addressed in Action a and/or Action b of the same TS.

II.

REASON FOR THE PROPOSED CHANGE The purpose of making the proposed changes is to provide for consistency between the action statements associated with TS 3.8.1.1.

The present wording of the last sentence of Action Statements c, d, and e either repeats the wording in Action Statements a and b or requires entering a more restrictive condition than specjfied in Action Statement b.

For example,. Action Statement d requires restoration of two offsite power sources within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in 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 cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

This requirement is a repeat of the requirement located in Action Statement a.

Additionally, Action! Statement e requires restoration of at least 4 D/G sets within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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 cold shutdown.within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

This requirement contradicts the requirement provided in Action Statement b that allows 7 days for restoration of the 4 D/G sets.

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i III.

SAFETY ANALYSIS The proposed change provides for consistency and removes contradictions within the action statements associated with TS 3.8.1.1.

The deletion of the defined portion of the requirements associated with the restoration of offsite power sources in Action Statements c and d does not result in any change to SONS response to the stated condition since this requirement remains unchanged in Action Statement'a.

The deletion of the defined portion of the requirements associated with the restoration of 4 D/G sets within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from Action Statements c and e provides for a consistent. allowed outage time of 7 days for the loss of a D/G set.-

The change from the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> provided for in Actions c and e to the 7 days provided for in Action Statement b was previously approved by the staff in a safety evaluation issued on December 16, 1998.

This proposed revision will not result in any change in the maintenance and operation of the associated plant equipment nor will it result in deviation from the actions presently approved by the staff for response to the associated limiting conditions of operations (LCOs), therefore it can be safely implemented at SON.

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, does not involve a significant 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.

This proposed revision provides for consistency and removes' contradictions within the action statements

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associated with TS 3.8.1.1.

Additionally, the proposed revision will not result in any change in the design, maintenance or operation of the associated plant equipment nor will it result in deviation from the actions presently approved by the staff for SONS response to the associated LCOs.

The deletion of the i

defined portion of the requirements associated with the restoration of offsite power sources in Action Statements e and d does not result in any change to SONS response to the stated condition since this l

. requirement remains unchanged in Action Statement a.

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The deletion of the requirements associated with the restoration of 4 diesel generator (D/G) sets within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from Action Statements c and e provides for a 1

consistent allowed outage time of 7 days for the loss

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of a-D/G' set as.previously approved by the staff in a safety evaluation issued on December 16, 1998.

Therefore, the proposed amendment does not involve an increase in the probability or consequences of an

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accident previously evaluated.

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 proposed change provides for consistency and removes contradictions within the action statements i

associated with TS 3.8.1.1.

Additionally, the proposed revision will not result in any change in the design, maintenance or operation of the associated plant equipment nor will it result in deviation from the actions presently approved by the staff for SONS response to the associated LCOs.

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

i C.

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

The proposed change provides for consistency and removes contradictions within the action statements associated with TS 3.8.1.1.

Additionally, the proposed revision will not result in any change in the design, maintenance or operation of the associated l

plant equipment nor will it result in deviation from the actions presently approved by the staff for SONS i

response to the associated LCOs.

Therefore, the l

proposed amendment does not involve a reduction in a margin of safety, i

V.

ENVIRONMENTAL IMPACT CONSIDERATION The proposed change does not involve a significant

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hazards consideration, a significant change in the types of or significant increase in the amounts of any

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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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