ML20217B365

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Safety Evaluation Supporting Amends 247 & 238 to Licenses DPR-77 & DPR-79,respectively
ML20217B365
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 10/06/1999
From:
NRC (Affiliation Not Assigned)
To:
Shared Package
ML20217B364 List:
References
NUDOCS 9910120218
Download: ML20217B365 (4)


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NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555 0001 S

%4.....p SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 247 TO FACILITY OPERATING LICENSE NO. DPR-77 AND AMENDMENT NO. 238 TO FACILITY OPERATING LICENSE NO. DPR-79 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT. UNITS 1 AND 2

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DOCKET NOS. 50-327 AND 50-328

1.0 INTRODUCTION

By application dated February 26,1999, the Tennescee Valley Authority (TVA, the licensee) proposed amendments to the Techni' al Specifications (TS) for Sequoyah Nuclear Plant (SON) c Units 1 and 2. The requested changes would relocate TS 3/4.7.6, " Flood Protection Plan," from the SON TS to the SQN Technical Requirements Manual (TRM). In addition, the appropriate TS Bases sections and index pages would be revised to reflect this change.

2.0 BACKGROUND

SON's Flood Protection Plan is designed to minimize impact of floods above plant grade on safety-related facilities. Currently, the SON's TS 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. The TS also include an LCO for occurrence of a seismic event or recognizable seismic activity in the east Tennessee region. 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.

TVA requests the proposed change W remove requirements associated with tha F! cod Protection from the SON TS on the basis that they do not meet the criteria in Title 10, Code of Federal Reaulations (10 CFR), Section 50.36. TVA's position is that the proposed change is consistent with the U.S. Nuclear Regulatory Commission's (NRC's) " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors," published in the Federal Reaister on July 22,1993 (58 FR 39132). The NRC Final Policy Statement states that TS requiremt.nts that do not meet any of the screening criteria for retention may be proposed for removal from the TS and reloc sted to Ikansee-controlled documents, such as the Final Safety Analysis Report or TRM. TVNs proposed change would allow revisions to the Flood Protection Plan, in accordance with 10 CFR 50.59, without requiring a license amendment request and adds flexibility to processing necessary changes.

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f 3.0. EVALUATION The Commission requires that LCOs meeting one or more of the four criteria stated in 10 CFR 50.5S(c)(2)(ii) must be included in the plant's TS. The NRC staff has reviewed TVA's proposed TS change and concludes that it is consistent with the guidance in the Commission's Final Policy Statement on Technical Specifications, as discussed above, and with NUREG-1431, Revision i, " Standard Technical Specifications, Westinghouse Plants," dated April 1995.

NUREG-1431 does not include Flood Protection Plan TS requirements because tnis plan does not meet the criteria in 10 CFR 50.36. In addition,'IVA evaluated SON's current flood protection TS requirements against the criteria of 10 CFR 50.36. The following discussions address the applicability of the 10 CFR 50.36 criteria to SON's TS for the Flood Protection Plan.

Criterion 1: Installedinstrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation Jf the reactor coolant pressure boundary.

SON's Flood Protection Plan is designed to minimize the impact of floods above plant grade on safety-related facilities. 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 features of the plan. SON's Flood Protection Plan is not instaihd instrumentation that is used to detect and indicate, in the control room, a significant abnotmal degradation of the reactor coolant pressure boundary.

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

l Criterion 2: A process variable, design feature or operatir;g restriction that is an initial condition of a Design Basis Accident (DBA) or Transient that either assumes the failure of or presents a challenge to the 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 j

product barrier. Therefore, the SON Flood Protection Plan does not satisfy Criterion 2.

l Criterion 3: A structure, system or component that is part of the primary success path and which l

l'inctions or actuates to mitigate a DBA or Transient :nat either assumes the failure of or l

presents a challenge to the integrity of a fission prodact barrier.

SON's Flood Protection Plan is not a structure, system or component that is part of the primary success path for accident mitigation. In addition, the Flood Protection Plan does not function or actuate to miligate a DBA or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Accordingly, the Flood Protection Phn does not satisfy Criterion 3.

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Criterion 4: A structure, system or component, which operating experience orprobabilistic l

safety assessment has shown to be significant to public health and safety.

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Operational experience and deterministic safety assessment evaluation as identified in the SON Generic Letter 88-20 response have not shown the SON Flood Protection Plan to be significant I

to the public health and safety. Therefore, the Flood Protection Plan does not satisfy Criterion 4.

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. The proposed relocation of the flood protection requirements to the SON TRM is acceptable based on the above discussions. Therefore, the staff finds the amendments, as proposed by TVA to be acceptable. 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 50.50 evaluation which will ensure changes are not implemented that would reduce the functionality of or introduce an unreviewed safety question to SON's Flood Protection Plan.

4.0 STATE CONSULTATION

in accordance with the Commission's regulations, the Tennessee State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC 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 occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (64 FR 14286). 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 or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the l

Commission's regulations, and (3) the issuance of the amendments will not be inimical to the l

common defense and security or to the health and safety of the public.

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l Principal Contributor: Richard J. Laufer, NRR

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Dated: October 6, 1999 l

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Mr. J. A. Scalice -

Tennessee Valley Authority.

SEQUOYAH NUCLEAR PLANT cc:

Mr. Karl W. Singer, Senior Vice President Mr. Pedro Salas, Manager Nuclear Operations Licen. sing and Industry Affairs Tennessee Valley Authority Sequoyah Nuclear Plant 6A Lookout Place Tennessee Valley Authority 1101 Market Street P.O. Box 2000 Chattanooga, TN 37402-2801 Soddy Daisy, TN 37379 Mr. Jack A. Bailey Mi D. L. Koehl, Plant Manager i

Vice President Sequoyah Nuclear Plant Engineering & Technical Services Tennessee Valley Authority Tennessee Valley Authority P.O. Box 2000 6A Lookout Place Soddy Daisy, TN 37379 1101 Market Street Chattanooga, TN 37402-2801 Mr. Melvin C. Shannon Senior Resident inspector Mr. Masoud Bajestani Sequoyah Nuclear Plant Site Vice President U.S. Nuclear Regulatory Commission Sequoyah Nuclear Plant 2600 Igou Ferry Road Tennessee Valley Authority Soddy Daisy, TN 37379 P.O. Box 2000 Soddy Daisy, TN 37379 Mr. Michael H. Mobley. Director TN Dept. of Erivironment & Conservation General Counsel Division of Radiological Health Tennessee Valley Authority 3rd Floor, L and C Annex ET 10H 401 Church Street

400 West Summit Hill Drive Nashville, TN 37243-1532 Knoxville, TN 37902 County Executive Mr. N. C. Kazanas, General Manager Hamilton County Courthouse

-Nuclear Assurance Chattanooga, TN 37402-2801 Tennessee Valley Authority SM Lookout Place 1101 Market Street Chattanooga, TN 37402-2801

' Mr. Mark J. Burzynski, Manager l

Nuclear Licensing Tennessee Valley Authority I

4X Blue Ridge I

1101 Market Street Chattanooga, TN 37402-2801 b