ML20217J846

Forwards Vols 1-12,Amend 13 to UFSAR for Sequoyah Nuclear Plant,Units 1 & 2.Amend 13 Improves UFSAR Quality by Eliminating Duplicate Info & Simplifying Ufsar.Info Removed from UFSAR Discussed in NRC Insp Repts

ML20217J846
Person / Time
Site:	Sequoyah
Issue date:	03/25/1998
From:	Bajestani M TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20217J850	List: ML20217J846
References
50-327-97-08, 50-327-97-8, 50-328-97-08, 50-328-97-8, GL-91-08, GL-91-8, NUDOCS 9804070034
Download: ML20217J846 (8)

Text

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Tennessee VaNey Authonty, Post Omce Box 2000, Soddy Daisy, Temessee 37379-2000 Masoud Bajestard Srte Vice Presioent Sequoyah Nuclear Plant March 25, 1998 10 CFR 50.71(e) (4)

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

)

50-328 SEQUOYAE NUCLEAR PLANT (SQN)

UPDATED FINAL SAFETY ANALYSIS r

REPORT (UFSAR), AMENDMENT 13

References:

1. TVA letter to NRC. dated September 4,

1997,

" Commitment Regarding the Updated Final Safety Analysis Report (UFSAR), Amendment 33" 11 2.

TVA letter to NRC dated December 6,

1996,

" Updated Final Safety Analysis Report (UFSAR),

Amendment 12 and 10 CFR 50.59 Report" This letter provides the original (Enclosure 2) and 10 complete sets of SON's Amendment 13 to the UFSAR.

Amendment 13 is a 15-month voluntary update from Amendment 12,Lwhich was submitted by TVA letter dated December 6, 1996.

The changes addressed in Amendment 13 primarily reflect the completion of the SON UFSAR Verification Program.

The main objectives of the Verification Program were to correct existing UFSAR deficiencies, improve UFSAR quality, and validate the accuracy of information contained in the UFSAR. Amendment 13

. improves the UFSAR quality by eliminating duplicate information and simplifying the UFSAR.

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' March 25,J1998 (The, updated.informationiaddressed in Amendment 13 reflects, for the most part, modifications to the facility, procedure changes,-and administrative. changes to the site through June :10, 1996.- The. June 1996 date is the same cutoff date associated with. SON's Amendment.12 UFSAR update.

Amendment 13 includes'some additional modifications since June 1996 7 However, all changes required to be described W -

pursuant to 10.CFR.50.71(e). will be submitted in

' Amendment 14. -Amendment 14 is scheduled for submittal on or before May.1,.1998, in accordance with the schedule requirements of 10 CFR 50.71(e) (4).

The changes to the facility discussed above include 10 plant

~ modifications associated with tagging abandoned equipment.

We are inLthe final. stages of tagging out the systems and equipment.

We expect to' complete the tag out of abandoned n

equipment' prior:to the UFSAR Amendment 14 update.

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'_Throughout the implementation of the SON UFSAR Verification Program, we utilized the guidance of Regulatory Guide s(RG) 1.70, " Standard Format and Content of Safety Evaluation

-Reports for Nuclear Power Plants."

RG 1.70 provided a

, baseline.for determining UFSAR content.

As.part of the review, we evaluated.UFSAR changes for Amendment 13 in accordance with_10 CFR 50.59, as appropriate.

We carefully evaluated the retention of.information.to ensure that current design. basis'information and procedural requirements are properly. reflected'within the UFSAR.

.We.have been^proactive in addressing issues in the area of UFSAR accuracy and: consistency with design bases, procedures,

' and operating procedures.

Part of this effort included e

improvements in the usefulness of our UFSAR by removing

. extraneous detail.

For example, we removed references to cindividual' drains and~ vent lines shown in piping drawings, l abandoned equipment no longer used for plant operation, and

.nonsafety-related system descriptions, such as Turbine n

Building Ventilation.. Editing such extraneous detail allowed us'to improve the;usefulnesshof the document by increasing

'the. focus.on' safety significant information.

Also,

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< simplification of the drawings has improved legibility.

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.U.S.

Nuclear Regulatory Commission

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Page.3-L March'25, 1998 y

As part of our;proactive' effort to' address UFSAR issues, we b

previously requested an opportunity to discuss the' content of

, Amendment 13 with,the NRC staff (Reference 2).

We planned to meet in December 1997 following the NRC resolution of FSAR' content issues identified within SECY-97-035, " Proposed i;

Regul'atory Guidance Related to Implementation of 10 CFR 50.59

.(Changes,. Tests, and Experiments)."

However, the NRC staff e

-indicated that such a. meeting would serve no useful. purpose in' light of continuing efforts by NRC to resolve FSAR-content issues.

Accordingly, we have proceeded to complete.our UFSAR efforts.

I y In this amendment, we have not removed a significant. level of

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'information.

We have compared the actual volume of-L information (number of text pages, number of tables,. number of figures, and total number of worde)-contained in-Amendment 12 and Amendment 13. provides a detailed graphical illustration of this ccmparison.

The reduction in the total number of text pages_is primarily due to the conversion from a Wordperfect format to a

-Microsoft Word format.

Font'and margin changes' increase the number of words-on a page, resulting in an overall decrease-in the number of text pages. This is consistent with the comparison of the total number of text words between L

. Amendment 12 and'13, which indicates a-relatively small

-reduction (less than 4 percent)..In addition, a large number of " blank" UFSAR pages were removed.

These " blank"'pages previously served as place holders to reflect that L

information.on the page had been removed during previous UFSAR amendments.

The reduction of UFSAR tables is primarily concentrated on in t

Chapters 2 and 14.

The tables removed from Chapter 2 l

contained historical-information such as soil test data L,

collected.during.the construction phase of SON. This L

information was relocated to a design basis document (CEB 97-01),1which is referenced in Chapter 2.. For' Chapter 14, the l

reduction in tables'is due to reformatting and/or b

irepagination of information that resulted in an overall reduction in'the: number of tables.-

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Nuclear Regulatory Commission Page 4 March 25, 1998 The comparison for figures shows reductions primarily in Chapters 2, 3,

6, and 9.

For Chapter 2, the reduction is due to the relocation of historical soil core dr.illing information into CEB 97-01.

For Chapter 3, the reduction is due to eliminating duplication between concrete drawings and equipment / system layout drawings.

For Chapter 6, the reduction is primarily due to eliminating excessive details contained in thermal hydraulic nodel analysis and miscellaneous mechanical penetration drawings.

For Chapter 9, the reduction is primarily due to the removal of system logic and control drawings that were not necessary to compliment the description already provided in the text.

Those figures that depict pump logic or controls have been retained.

An additional example in which information was removed from the UFSAR is discusLcd in NRC Inspection Report 50-327, 328/97-08, Inspector Followup Item 97-08-03.

This report addressed Amendment 12 to SQN's UFSAR and identified three issues described below:

1.

UFSAR Change 12-90 removed Table 3.5.2-1, which contained design information associated with missile characteristics.

1 2.

UFSAR Change 12-58 removed maximum allowable reactor coolant pump vibration limits from Section 5.5.1.2, and 3.

UFSAR Change 12-40 removed from Table 6.4.2-1 the list of " Containment Penetrations" and relocated the information by reference to a design document.

As the NRC Report indicated, the inspector follow-up item associated with the above issues was identified because NRC had not finalized guidelines for removal of information from the UFSAR.

TVA reviewed the Amendment 12 UFSAR changes for the Amendment 13 update and addressed each issue in the following manner:

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TVA has reincorporated, in Amendment 13, the information e

described in Item 1 above.

With regard to Item 2, TVA removed the UFSAR information based on level of detail.

Vendor information associated with SON's allowable reactor coolant pump vibration limits l

U. S Nuclear Regulatory Commission Page 5 March 25, 1998 is nonsafety-related information.

TVA determined this information to be below the available guidelines for UFSAR content.

With regard to Item 3, TVA removed the list of containment isolation-valves from the SON Technical Specifications (TS Change 95-05), in accordance with the guidance provided in NRC Generic Letter 91-08.

To accommodate this relocated information, Design Output Document N2-88-400 " Containment Isolation System Description Document," was created.

At that time, it was prudent to also place the list of Containment Penetrations (Table 6.2.4-1) in the same design basis document.

Rather than maintain this information in two documents, Amendment 12 to SQN's UFSAR removed the list of Containment Penetrations from SON's UFSAR and added a reference in the UFSAR to N2-88-400.

We consider that maintaining the list of Containment Penetrations (by UFSAR reference to N2-88-400) to be appropriate for the administrative control and management of this information within a single design basis document.

Throughout the conduct of our UFSAR Verification Program and the preparation of Amendment 13, we remained focused on the importance of retaining safety significant information.

The content of Amendment 13 continues to fully describe the facility, design bases, and limits of plant operation.

Accordingly, we believe that Amendment 13 provides an adequate description of SON's current licensing bases.

In conclusion, we have taken the initiative, in response to the problems discovered at Millstone and Maine Yankee Nuclear Plants, to verify the accuracy of UFSAR information.

This initiative was proactive and will continue into the future through critical self-assessments of UFSAR content and vertical slice reviews.

I certify that I am a duly authorized officer of TVA, and j

that, to the best of my knowledge and belief, the information

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contained herein is accurate; and that changes made since the previous submittal, as described in this Amendment 13 reflects information and analyses submitted to the Commission or prepared pursuant to Commission requirements.

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9 U.S. Nuclear Regulatory Commission Page'6 March 25, 1998 If'you have any questions regarding this letter, please call me at (423)843-7001 or Pedro Salas at (423) 843-7170.

Sincerely, M.8 O~

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_Masoud jestani ubs ribed efore

~ on this J5Endswornto O/?B>/me day of o

JMJ J

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Notary Public My Commission Expires /h8 f]N c2/ /ffh Enclosures cc (Enclosures):

Mr. R. W.

Hernan, Project Manager Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy-Daisy, Tennessee 37379-3624 Regional Administrator U.S.

Nuclear Regulatory Commission Region II Atlanta Federal Center 61 Forsyth St.,

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

ENCLOSURE 1 SEQUOYAH NUCLEAR PLANT COMPARISON BETWEEN AMENDMENTS 12 AND 13 IotalNo. of Text Paaan an Amendment 12 Amend.12 Amand 13 mAmendment is 2,100 1,778 300 m Reduction a 15.3%

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2 3 4 5 6 7 8 9 10 11 12 13 14 15 17 UFSAR Chapters r7e IniclNo.of Tables as Amendment 12

"' ^ 12 250 as Amendment 13 g

Reduction s 22.0%

g cs 200 J

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,3 I-150

'24 69 33 50 3.

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 17 UFSAR Chapters

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• e l 500 "2

InlalBo.of Figuma a Amendment 12 M2 hM an Amendment 13 1,828 1,081 400 Reduction = 40.9%

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200 a

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".4 le i i a l eo 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 17 UFSAR Chapters

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IolalMe m An=ndnam 12 140 m,,

Amandd2 Amand.13 m Anwndment 13 120 740210 711#2 p

Reduction = 3.9%

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60 h

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 17 UFSAR Chapters