ML20210S984

Forwards Proposed Rev to Unit 2 License Condition 2.C.(14) Re Implementation Schedule for Mods Necessary to Comply W/Reg Guide 1.97,Rev 2 & Basis for Change,Per 830304 Request for Rev.Unit 1 Implementation Date Needs Rev.Fee Paid

ML20210S984
Person / Time
Site:	Sequoyah
Issue date:	09/30/1986
From:	Gridley R TENNESSEE VALLEY AUTHORITY
To:	Youngblood B Office of Nuclear Reactor Regulation
References
RTR-REGGD-01.097, RTR-REGGD-1.097 NUDOCS 8610080276
Download: ML20210S984 (4)

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TENNESSEE VALLEY AUTHORITY CHATTANOOGA TENNESSEE 37401 SN 157B Lookout Place SEP 30 986 TVA SQN OL-86-01 Director of Nuclear Reactor Regulation Attention: Mr. B. Youngblood, Project Director PWR Project Directorate No. 4 Division of Pressurized Water Reactors (PWR)

Licensing A U.S. Nuclear Regulatory Conunission Washington, D.C. 20555

Dear Mr. Youngblood:

In the Matter of ) Docket Nos. 50-327 Tennossee Valley Authority ) 50-328 By the March 4, 1983 letter to E. Adensam from L. M. Mills, we requested a change in the Sequoyah Nuclear Plant (SQN) unit 2 operating license condition 2.C.(14) to revise the implementation schedule for modifications necessary to comply with Fevision 2 of Regulatory Guide 1.97. Revision of the operating license condi. tion is still requested and should reflect the basis for the implementation specified in the June 15, 1984 letter to H. G. Perris from E. Adensam regarding " Issuance of Orders Confirming Licensee Conunitments on Emergency Response Capability." As requested by J. Holonich of your staff, enclosed is a proposed revision to operating license condition 2.C.(14) and the basis for the proposed change. A significant hazards consideration determination for the proposed change as required by 10 CFR 50.92 is provided in Attachment 1 to the enclosure.

Additionally, for unit 1 at SQN the September 1987 implementation date specified in the June 15, 1984 letter is requested to be revised to unit 2 cycle 4 to reflect our previo.ts conunitment provided to NRC by the February 14, 1984 letter from L. M. Mills to E. Adensam. This change for unit 1 is necessary as n result of the extended shutdown which began on August 21, 1985.

Pursuant to 10 CFR 50.92, a determination that no significant hazards considerations are involved is also provided as an attachment to the enclosure.

In accordance with the requirements of 10 CFR 170.12, enclosed is a check for the $150 amendment application feo.

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0610000276 860930 ADOCK 05000327 l ip r3%

PDR p PDR An Equal Opportunity Employe. ,

Director of Nuclear Reactor Regulation If there are any questions, please get in touch with M. J. Burzynski at 615/870-6172.

Very truly yours, TENNESSEE VALLEY AUTHORITY R. L. Gridley, Director Nuclear Safety and Licensing Sworn to agd subscr e ,d '

this J387/Nay. of .m'pefore me 1986 ikl0Af hA N (otary Public My Commission Expires i i Enclosure cc (Enclosure):

U.S. Nuclear Regulatory Commission Region II Attn: Dr. J. Nelson Grace, Regional Administrator 101 Marietta Street, NW Suite 2900 Atlanta, Georgia 30323 Mr. Carl Stahle, Sequoyah Project Manager U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, Maryland 20814 i

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

I Division of Radiological Health l T.E.R.R.A. Building i

150 9th Avenue North Nashville, Tennessee 37203 Mr. G. G. Zech Director, TVA Projects U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 I

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e ENCLOSURE LICENSING CONDITION 2.C.(10 - COMPLIANCE WITH REGULATORY GUIDE 1.97 Existirx condition TVA shall implement modifications necessary to comply with Revision 2 of Regulatory Guide 1.97, " Instrumentation for Light Water Cooled Nuclear Power

, Plants to Assess Plant Conditions During and-Following an Accident," dated l December 1980, by June 1983.

1 l Proposed Condition TVA shall implement modifications necessary to comply with Revision 2 of Regulatory Guide 1.97, " Instrumentation for Light Water Cooled Nuclear Power l Plants to Assess Plant Conditions During and Following an Accident," dated i December 1980 by startup from the unit 2 cycle 4 refueling outage.

Justification for the Proposed Chanze -

NUREG-0737, " Clarification of TMI Action Plan Requirements," identified

., requirements associated with Regulatory Guide 1.97, Revision 2. Supplement 1

{ to NUREG-0737, " Requirements for Emergency Response Capability," also addressed requirements associated with Regulatory Guide 1.97 and was i transmitted to "All Licensees . . ." by Generic Letter 82-33 on December 17,

! 1982. Supplement 1 to NUREG-0737 did not require compliance with Regulatory i Guide 1.97, Revision 2, but allowed an implementation schedule to be determined by the NRC Project Manager by June 1983. By the March 4, 1983 letter we had requested the license condition changs to allow compliance with Regulatory Guide 1.97 on a schedule consistent with the requirements of Supplement 1 for an overall integrated approach to implementation. TVA subsequently responded to supplement 1 to NUREG-0737 on April 15, 1983 and as

! well on August 1, August 22 December 1, and December 16, 1983, as a result of I additional negotiations with the NRC staff.

l By the February 14, 1984 letter from L. M. Mills to E. Adensam, TVA submitted an implementation schedule of startup from the unit 2 cycle 4 refueling outags for compliance with Revision 2 of Regulatory Guide 1.97 for units 1 and.2 of

. SQN. As stated in the February 14, 1984 letter, the unit 2 cycle 4 refueling

[ outage was scheduled for September 2, 1987, provided that no significant l unanticipated change occurred in the scheduled outages. The implementation schedule was subsequently approved by NRC in the June 15, 1984 letter from E. G. Adensam to H. G. Parris, " Issuance of Orders Confirming Licensee

Commitments on Emergency Responsibilities Capability." However, for unit 2, l the June 15, 1984 letter specifies for the " Licensee Completion Schedule" that a " Licensee commitment to be confirmed by separate license amendment."

Therefore, revision of the license condition will satisfy and clarify the schedule requirements identified in the June 15, 1984 letter.

This proposed revision of the operating license condition has been evaluated i pursuant to 10 CFR 50.92 as shown in attachment 1 and no significant hazard I

l considerations are involved.

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F e e e ATTACHMENT 1 SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION

1. Does the proposed change involve a significant increase in the -

probability or consequences of an accident previously evaluated? No.

This change is intended to accurately reflect the implementation schedule for compliance with Regulatory Guide 1.97, Revision 2, and does not change the basis for the schedule that was approved by NRC in the June 15, 1984 letter which issued orders confirming connitments.

2. Is the possibility for an accident of a new or different type from that evaluated previously in the safety analysis report created? No.

This change involves only the schedule aspect of compliance with Regulatory Guide 1.97, Revision 2, and does not change the scope or intent of compliance previously submitted to NRC.

3. Is the margin of safety significantly reduced? No.

The scope of compliance with Regulatory Guide 1.1,, Revision 2, is not being changed and does not affect the margin of safety.

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