ML20216F702

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Proposed Tech Spec Change 87-25,revising Limiting Conditions for Operation 3.3.3.9 & 3.3.3.10 to Delete Refs to Nonexistent Section 6.9.1.13.b from Action Statement C. Description of Change & NSHC Determination Encl.Fee Paid
ML20216F702
Person / Time
Site: Sequoyah  
Issue date: 06/19/1987
From:
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20216F687 List:
References
TAC-R00191, TAC-R00192, TAC-R191, TAC-R192, NUDOCS 8706300924
Download: ML20216F702 (11)


Text

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. ENCLOSURE 1 PROPOSED TECHNICAL SPECIFICATION CHANGES SEQUOYAM NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328

.(TVA-SQN-TS-87-25)

PROPOSED AMENDMENT TO LIMITING CONDITIONS FOR OPERATION (LCOs) 3.3.3.9 and 3.3.3.10 LIST OF AFFECTED PAGES-Unit i l

3/4 3-69.

I 3/4 3-74 Unit 2 3/4 3-68 3/4 3-76

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l 8706300924 870619 PDR ADDCK 05000327 p

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INSTRUMENTATION:

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TRADI0 ACTIVE-LIQUID EFFLUENT MONITORING INSTRUMENTATION vW

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LIMITING CONDITION'FOR OPERATION' 3.3.3.9 -The; radioactive' liquid effluent monitoring instrumentation channels L.m.

'shown in Table 3.3-12 shall be OPERABLE with their alarm / trip setpoints set to

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ensure that the limits of Specification 3.11.1.1 are not exceeded.

The alarm /-

Ltrip setpoints of theseLchannels'shall'be determined in accordance with the-methodology and the parameters in the OFFSITE DOSE CALCULATION MANUAL (ODCM).

APPLICABILITYi

.During releases via'these' pathways.

' ACTION:

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ia.,.With a' radioactive liquid effluent monitoring instrumentation' channel

. alarm / trip-setpoint less conservative than required by the above ic..

specification,1without delay suspend the release of radioactive liquid P46-effluents monito' red by the affected channel or declare-the channel inoperable, or change the setpoint so it'is acceptably conservative, m

b.

Witholess than the' minimum number of radioactive liquid effluent 4

monitoring instrumentation channels OPERABLE take the ACTION'shown in Table ~3.3-12.

Exert best effort to return the instruments to-i OPERABLE status within 30 days and, if unsuccessful, explain'in the 4

next Semi-Annual Radioactive Effluent Release Report why.the inopera-bility could not be corrected within'30 days.

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avid The provisions of Specifications 3.0.3x 3. 0. 43 and 5.9.1. W b are.

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not applicable.

E SURVEILLANCE REQUIREMENTS l'

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,y 4.3.3.9'.Each' radioactive liquid effluent monitoring instrumentation channel shall'be demonstrated.0PERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table 4.3-8.

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b.m a y l',

1986

-SEQUOYAH - UNIT 1-3/4 3-09

^ = =: nt %. ' 2-

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A INSTRUMENTATION, RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.10 The radioactive gaseous effluent monitoring instrumentation channels shown in Table 3.3-13 shall be 0PERABLE with their alarm / trip setpoints set to ensure that the limits of Specification 3.11.2.1 are not exceeded.

The alarm /

itrip setpoints of these channels shall be determined in accordance with the methodology and parameters in the ODCM.

R46 APPLICA!!ILITY:

As shown in Table 3.3-13 ACTION:

With a radioactive gaseous effluent monitoring instrumentation chan-a.

i nel alarm / trip setpoint less conservative than required by the above

'l Specification, without delay suspend the release of radioactive gas-lR46 j

eous effluents monitored by the affected channel, declare the channel inoperable, or change the setpoint so it is acceptably conservative.

lR46 b.

With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-13.

Exert best efforts to return the instrument to OPERABLE status within 30 days and, if unsuccessful, explain in the y

R4C next Semi-Annual Radioactive Effluent Release Report why the opera-(

bility could not be corrected within 30 days.

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and c.

The ' provisions of Specifications 3.0.3, 3.0.4 cand-6e9,-b1Ab. are not applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.10' Each radioactive gaseous effluent monitoring instrumentation channel shall be demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE i

CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST operations at the frequencies shown in Table 4.3-9.

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i(w January-44 ;-4986-SEQUOYAH - UNIT 1 3/4 3-74 Amendmentr-Nov-42 i

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JNSTRUMENTATION I,-

- p RADIOACTIVE LIQUID EFFLUENT MONITORING INSTRUMENTATI 4

LIMITING CONDITION FOR_0PERATION=

z 3.3.3.9'.The radfoactive liquid effluent monitoring ins;trumentation cha

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shown in Table 3.1-12 shall be OPERABLE with their alarm / trip setp ensure that the lidts of Specification 3.11.1.1 are not exceeded.

methodology and paramete,>s in the OFFSITE D The~ alarm /.

- l 33 APPLICABILITY:

During releases via these pathways.

ACTION:

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With'a radioactive liquid effluent monitoring instrumentation chan I

a.

alarm / trip setpoint less conservative than required by the above sp cification, without delay, suspend the release of radioactive liquid R3 effluents monitored by the affected channel or declare the channel inoperable, or change the setpoint so it.is acceptably conservative.

With less than the minimum' number of radioactive liquid effluent-o..

monitoring instrumentation channels-OPERABLE take the ACTION shown in Table 3.3-12.

Exert best effort to return the instruments'to OPERA 8LE status within 30 days and, if unsuccessful, explain:in the' ability could 'not be corrected within 30 days.next' Semi-A nnd The provisions of Specifications 3.0.3 c.

3.0.4 = d 5.0.1.13.5 are not i

applicable.

SURVEILLANCE REQUIREMENTS 4.3.3.9 shall be demonstrated OPERABLE by performance ~of the

' CHECK,.' CHANNEL CALIBRATION'and CHANNEL FUNCTIONAL TEST operat frequencies shown in Table 4.3-8.

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SEQUOYAH - UNIT 2

-denuary 14, 1 ^

3/4 3-68

~ Amendment--N.

INSTRUMENTATION RADIOACTIVE GASEOUS EFFLUENT MONITORING INSTRUMENTATION LIMITING CONDITION FOR OPERATION 3.3.3.10 shown in Table 3.3-13 shall be OPERABLE with their alarm / tri l

ensure that the limits of Specification 3.11.2.1 are not exceeded.

The j

alarm / trip setpoints of these channels.shall be determined in accordance with i

the CDCM.

a I

' APPLICABILITY:.As shown in Table 3.3-13 ACTION:

With a radioactive gaseous effluent monitoring instrumentation channel a.

alarm / trip setpoint less conservative than required by the above Spe-cification, without delay suspend the release of radioactive gaseous effluents monitored by the affected channel or declare the channel inoperable, or change the setpoint so it is acceptably conservative.

R34 j

b.

With less than the minimum number of radioactive gaseous effluent monitoring instrumentation channels OPERABLE, take the ACTION shown in Table 3.3-13.

Exert best efforts to return the instrument to OPERABLE status within 30 days and,-if unsuccessful, explain in the next Semi-Annual Radioactive Effluent Release Report why the opera-bility could not be corrected within 30 days.

s R34 GM The. provisions of Specifications 3.0.3y^3.0.4, end-6v9.1.13.-b. are not c.-

applicable, SURVEILLANCE REQUIREMENTS

' 4.3.3.10 Each radioactive gaseous effluent monitoring instrumentation channel.

shall be' demonstrated OPERABLE by performance of the CHANNEL CHECK, SOURCE CHECK, CHANNEL CALIBRATION and CHANNEL FUNCTIONAL TEST at the frequencies shown in Table 4.3-9.

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SEQUOYAH - UNIT 2 3/4 3-76 Amende^^t " W v

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ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGES SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2'

DOCKET NOS. 50-327 AND 50-328 (TVA-SQN-TS-87-25)

DESCRIPTION AND JUSTIFICATION FOR PROPOSED AMENDMENT TO LIMITING CONDITIONS FOR OPERATION (LCOs) 3.3.3.9 and 3.3.3.10 l

1 ENCLOSURE 2 Description of Change

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The proposed amendment to the technical specifications of unit 1 and unit 2 would effect the following changes:

References to a now nonexistent section 6.9.1.13.b would be deleted j

from both Limiting Condition for Operation (LCO) 3.3.3.9, Action "c,"

j and LCO 3.3.3.10, Action "c."

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Reason for Change

.l In January 1984~, NRC issued a rula change concerning Licensee Event j

Reports (LERs).

Technical specification amendments 36 and 28, issued to TVA for Sequoyah unit 1 and unit 2, respectively, on November 23, 1984, effected changes to the technical specifications to implement the NRC rule-change regarding LERs. One of the requested changes to the technical-specifications was the deletion of section 6.9.1.13.b.

Because of an oversight committed in the preparation of the technical specification change package,_ references to section 6.9.1.13.b were not deleted from LCO 3.3.3.9, Action "c," or LCO 3.3.3.10, Action "c," in amendments 36 and 28.

The proposed amendment to the unit 1 and unit 2 technical specifications would correct that oversight by deleting references to the nonexistent section 6.9.1.13.b in both LCOs 3.3.3.9 and 3.3.3.10.

Justification for Change Before amendments 36 and 28'for units 1 and 2, respectively, section 6.9.1.13.b of the technical specifications identified requirements for writing LERs. On January 1, 1984, NRC made effective 10 CFR 50.72, governing requirements for immediate notification of NRC, and 10 CFR 50.73, governing requirements for LERs. The requirements of the l

two sections superseded and made' obsolete any possible. conflicting requirements between the Code of Federal Regulations (CFR) and the technical specifications. To provide for both incorporation and implementation of the subject CFR sections into the license, TVA submitted a proposed amendment to the technical specifications to NRC by letter dated April' 20, 1984. NRC reviewed the proposed amendment and on i

November 23, 1984, notified TVA of their approval of the proposed amendments.

Amendments 36 and 28 of units 1 and 2, respectively, deleted requirements for issuing LERs from the technical specifications as given in section 6.9.1.13.b and all references to those requirements.

References to section 6.9.1.13.b were overlooked, however, in Action "c"'of LCO 3.3.3.9 l

and_ Action "c" of LCO 3.3.3.10.

The subject action statements granted relief from writing. extraneous LERs when manual radioactive offluent sampling was used as an alternative to automatic sampling.

. I Because section.6.9.1.13.b no longer exists in the techn,1 cal specifications, references to this section are meaningless and could cause j

unnecessary confusion on the part of the plant operators. The proposed i

amendment would delete the references to section 6.9.1.13.b in LCO 3.3.3.9 and LCO 3.3.3.10.

l Also, the requirements of 10 CFR 50.73 do not require an LER to be written for those instances when manual radioactive effluent sampling is used as 1

an alternative to automatic sampling.

Thus, the relief granted by i

reference to section 6.9.1.13.b is no longer required.

Therefore, the proposed amendment causes no conflict with the requirements of either the technical specifications nor the CFR.

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. ENCLOSURE 3 PROPOSED TECHNICAL SPECIFICATION CHANGES

.SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2:

DOCKET NOS. 50-327 AND 50-328 i

(TVA-SQN-TS-87-25)-

i

't, DETERMINATION.0F NO SIGNIFICANT HAZARDS CONSIDERATIONS FOR 1

PROPOSED AMENDMENT TO LIMITING CONDITIONS FOR OPERATION (LCOs) 3.3.3.9 and 3.3.3.10 s

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ENCLOSURE 3 SIGNIFICANT HAZARDS EVALUATION 1.

' Does the propcfod amendment involve a significant increase in the probability'or consequences of an accident previously evaluated?

No.

Before amendments 36 and 28 for units 1 and 2, respectively, section 6~.9.1.13.b identified the reporting requirements for LERs.

On January 1, 1984. NRC made effective the requirements of 10 CFR 50.73, " Licensee. Event Report (LER) System," which superseded the requirements of section 6.9.1.13.b.

The subject amendments deleted section 6.9.1.13.b to allow the technical specifications to conform to the reporting requirements of 10 CFR 50.73.

Because of an oversight in preparing the request for the subject amendments, references to this section were not deleted from either Limiting Condition for Operation (LCO) 3.3.3.9 or LCO 3.3.3.10.

The proposed amendment would correct that oversight.

Actirn "c" to LCOs 3.3.3.9 and 3.3.3.10 grants relief from writing extraneous LERs during manual sampling of radioactive liquid and gaseous effluents, respectively, as opposed to. automatic sampling.

However, 10 CFR 50.73 does not require an LER to be written for such instances.

Thus, the proposed amendment causes no conflict with the requirements of the technical specifications or the CFR.

The proposed amendaent is editorial in nature and does not effect changes to plant equipment, operating setpoints or limits, or operating procedures. Therefore, the proposed amendment involves no significant increase in either the probability or consequences of an accident previously,ovaluated.

j 2.

Does the proposed amendment create the possibility of a now or different kind of accident from any accident previously evaluated?

No.

As related noove, the change advanced by the proposed amendment deletes a reference to a now nonexistent section of the technical i

specifications. The proposed amendment is editorial in nature and does not effect changes to plant equipment, operating setpoints or limits, or operating procedures.

Therefore, the proposed amendment would not create the probability of a new or different kind of accident previously evaluated.

3.

Does the proposed amendment involve a significant reduction in a margin of safety?

No.

Again, the. proposed amendment is editorial in nature and does l

not effect changes to plant equipment, operating setpoints or limits,

.or operating procedures. Therefore, the proposed amendment involves s

no reduction in margin of safety.

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-2 The proposed, amendment deletes a reference to a now nonexistent.

- section of.the technical specifications that has previously been superseded by the' regulations of 10 CFR 50.73.

This deletion would eliminate's potentia 1' source of confusion to the operators. Thus, the proposed amendment would provide for an' improvement in the margin of safety in, operating the plant.

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