ML20207G702

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Safety Evaluation Supporting Amends 78 & 69 to Licenses DPR-77 & DPR-79,respectively
ML20207G702
Person / Time
Site: Sequoyah  
Issue date: 08/15/1988
From:
NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20207G685 List:
References
NUDOCS 8808240204
Download: ML20207G702 (3)


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UNITED STATES e

i NUCLEAR REGULATORY COMIAISSION j

WASHING TON, D. C. 20555

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SAFETY EVALUATION BY THE OFFICE OF SPECIAL PP0JECTS SUPPORTING AMENDMENT NO. 78 TO FACILITY CPERATING LICENSE NO. OPR-77 AND AMENDMENT NO. 69 TO FACILITY OPERATING LICENSE NO. OPR-79 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS 50-327 AND 50-328

1.0 INTRODUCTION

By letters dated April 28 and June 9, 1988, the Tennessee Valley Authority (TVA) proposed changes to the Sequoyah Unics 1 and 2 Technical Specifications (TS). These applications proposed changes that would (1) revise Table. 3.6-2, "Containment isolation Valves " to delete flow control valves 77-16 and 77-17 and Table 3.6-1, "Bypass Leakage Paths to the Auxiliary Building " to delete penetration X-81, and (2) rivise Surveillance Requirement 4.0.3 and 4.0.4 to incorporata the NRC Generic Letter 87-09. These applications are discussed below.

2.0 EVALUATION 2.1 Application Dated April 28, 1988 (TS 88-07)

By letter cated April 28, 1988. TVA submitted proposed changes to delete two valves and a penetration from Tables 3.6-2 and 3.6-1, respectively, of the TS.

Table 3.6-2 in the TSs list the isolation valves necessary to ensure containment integrity after a Design Basis Loss-of-Coolant Accident (LOCA). The proposed TS Change deletes from Tables 3.6-2 and 3.6-1, two valves and a penetration, which are located on the waste gas sample line of the Reactor Coolant Orain Tank (RCDT). Specifically, these components are flow control valves, FCV-77-16 and -17, and are the current containment isolation valves on penetration X-81 FCV-77-16 and -17 were determined by TVA to be environmentally unqualified as containment isolation valves. The RCDT-serves as a collection point for reuseable reactor coolant grade water and is operated with a nitrogen cover gas. The collected water is normally routed to the chemical-and volume control system (CVCS) holdup tank or the tritiated drain collector tank for processing i

as liquid radioactive wastes. The RCOT is described in Section 11.2.3.1 of the SQN Final Safety Analysis Report.

When valve replacement was analyzed by TVA, it was determined that these valves were not necessary because there are no requirements for continuously sampling the waste gas from the RCOT. Furthermore, after the removal of these valves.

TVA stated it still had the capability to sample the waste gas from the RCDT because the RCOT waste gas can also be sampled from the Pressurizer Relief Tank which is in comunication with the RCDT.

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Containment integrity for the penetration will be provided by a welded cap in the annulus on a short section of the sample line after the two valvas are removed. A local leak rate test will be performeo as a post-modification test to ensure the containn;ent leakage rates remain acceptable. The penetration will then be included in the scope of the Appendix J Type A testing required by Surveillance Requirement 4.6.1.2.

Because the penetration will be tenninated at the welded cap in the annulus, the potential for bypass leakage to the auxiliary building is eliminated.

This allows penetration X-81 to be deleted from Table 3.6-1.

The staff concludes that there are no requirements for the RCDT Waste Sample Line preventing this action and the proper measures for maintaining containment integrity will be followed after the removal of the two valves and capping the penetration. Therefore, based on the above, the hRC staff concludes that the proposed changes in TS 88-07 to the TS are acceptable.

2.2 Application Dated June 9, 1988 (TS 88-05)

By letter dated June 9, 1988, TVA requested a change concerning Section 4.0 of the TS which provides general requirements governing Surveillance Requirements (SR). Specifically, the proposed change requested that SR 4.0.3 and 4.0.4, and their associated bases, be modified in accordance with the provisions of NRC Generic Letter 87-09.

Generic Letter 87-09 proposed to licensees three TS chcnges as part of the ongoing NRC TS Improvement Program. The letter encouraged licensees to propose changes to their TS consistent with the letter's guidar.ce, but stressed that the recommended changes were voluntary. TVA's requested TS change contained only two of the three recomended changes. TVA did not request to implement the recomended modification to SR 3.0.4 because they believed that for Sequoych the current wo.* ding and fonnat of their TS are sufficiently clear and inclusive to ensure safe operetion of the plant and that the recomended modification of SR 3.0.4 may lead te confusion among SQN plant operators.

Th9 reason for the proposed changes in TVA's application dated June 9, 1988, is to improve and clarify the applicability of SR 4.0.3 and 4.0.4.

The staff has found that these changes are consistent with the provisions of Generic letter 87-09. These changes are intended to enhance operaticral safety by reducing the number of unnecessary shutdowns caused oy SR 4.0.3 when surveillance intervals are inadvertently exceeded, cnd ov revising SR 4.0.4 to allow passage through or to operational modes as required to comply with Action Requirements.

Such a reduction in unnecessary shutdowns will limit the stresses on operating personnel and plant equipment, and will result in fewer challenges to safety systems.

As part of their review, the staff evaluated the effect of the licensee's lack of a proposed change to SR 3.0.4 as a part of their response to Generic Letter 87-09. The staff concluded that, with respect to the proposals of the Generic Letter, there is no connecticn between SR 3.0.4 anc 4.0.3 and 4.0.4.

Conse-quently, TVA's omission of a proposed change to SR 3.0.4 had no impact on the proposed changes to SR 4.0.3 and 4.0.4 l

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. Therefore, based on the above, the staff finds that the proposed changes in TS 88-05 to the TS are acceptable.

The staff will request that TVA reconsider its decision not to incorporate the Generic letter's recommendations on SR 3.0.4 in the Sequoyah TS.

3.0 ENVIRONMENTAL CONSIDERATION

These amendments involve a change to a requirement with respect to the installation or use of a facility component located within the restricted area as defined in j

10 CFR Part 20 and changes to the surveillance requirements. The staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is nc significant increase in individual or cumulative c cupational raatation exposure. The Commission has previously issued a

& oposed finding that these amendments involve no significant hazards consideration and there has been no public comment on such finding.

Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement nor environmental assessment need be prepared in ccnnection with the issuance of these amendments.

4.0 CONCLUSION

We have concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the will not be endangered by operation in the proposed manner, and (2) public such activities will be conducted in compliance with the Commission's regulations, and the issuance of these amendments will not be inimical to the common defense I

and security nor to the health and safety of the public.

Principal Contributor:

P. Castleman and P. Hearn Cated: August 15, 1988

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