ML20245F665

Application for Amends to Licenses DPR-77 & DPR-79, Consisting of Tech Spec Change 89-37,revising Tech Spec 3.5.1.1 to Address Failure to Meet Surveillance Requirements for Cold Leg Accumulator Level & Pressure Instrumentation

ML20245F665
Person / Time
Site:	Sequoyah
Issue date:	08/07/1989
From:	Michael Ray TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20245F670	List: ML20245F665 ML20245F672
References
NUDOCS 8908150033
Download: ML20245F665 (3)

Text

- _ - -

TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401 SN 1578 Lookout Place AUS 071988 TVA-SQN-TS-89-37 10 CFR 50.90

~U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555 Gentlemen:

In the Matter of ) Docket Nos. 50-327 Tennessee Valley Authority ) 50-328 SEQUOYAH NUCLEAR PLANT (SQN) - TECHNICAL SPECIFICATION (TS) CHANCE 89-37 In accordance with 10 CFR 50.90, we are enclosing a requested amendment to licenses DPR-77 and DPR-79 to change the TSs of SQN Units 1 and 2. The.

proposed change adds an action statement to address the failure to meet the surveillance requirements for cold leg accumulator level and pressure instrumentation. ,

1 The proposed TS change is identified in Enclosure 1. The justification for the proposed TS change is provided in Enclosure 2. A proposed determination of no significant hazards consideration performed pursuant to 10 CFR 50.92 is provided in Enclosure 3.

The possibility of multiple interpretations for the actions to be taken when either or both of the redundant cold leg accumulator level or pressure instruments are out of service has been identified as a problem with TS 3.5.1.1. The action statements presently contained in TS 3.5.1.1 do not address out-of-service instruments. Consequently, the operator is required to interpret TSs 3.0.3 and 4.0.3 to determine if and what out-of-service times apply. As part of our commitment in the June 1989 enforcement conference, TVA agreed to promptly and expeditiously address such problems.

TVA has made a good faith effort with respect to the development and implementation of the TSs, as evidenced by the current conformance to the NRC's standard TSs. TVA has also made a good faith effort to promptly address potential interpretation problems raised by interested parties. Therefore, TVA requests that this proposed change be given emergency processing priority. TVA also requests a waiver of compliance for the period of time required to process this change to preclude the potential for unit derating or enforcement action caused by interpretation problems with the timeframes available to correct equipment problems. It should be noted that the cold leg accumulators have been verified capable of performing their intended safety function through performance of surveillance requirement (SR) 4.5.1.1.1 at least once every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

s908150033 890007 7 I

[l l ADOCK 0500 gDR An Equal opportunity Employer L_ _- . _ _

. o . . 1 l

U.S. Nuclear Regulatory Commission I

As a result of inconsistencies noted with the treatment of compliance instruments in the SQN TSs and the differences in treatment of the cold leg accumulator instruments by the industry (e.g., Callaway, McGuire, and Catawba Nuclear Plants and Westinghouse Owners Group Merits), TVA intends to submit a long-term solution to this problem as a separate licensing action.

Please direct questions concerning this issue to 8. S. Schofield at (615) 843-6172. j Very truly yours, TENNESSEE VALLEY AUTHORITY M!4. Ray, Ma er Licensing Project Management Sworn t nd subs bed b fore me this 7 day of 1989 0kfl Notary Public

' ~

My Commission Expires h -

Enclosures cc: See page 3

g ,

U.S. Nuclear Regulatory Commission AU807 m

(

.cc: Ms. S. C. Black, Assistant Director (Enclosures) for Projects TVA Projects Division-U.S.: Nuclear Regulatory Commt ssion One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Assistant Director (Enclosures) for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II

.101 Marietta-Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr.' Michael H. Mobley, Director-Division of Radiological Health T.E.R.R.A. Building 150 9th Avenue, N Nashville, Tennessee 37203 NRC Resident Inspector (Enclosures)

Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379 American' Nuclear-Insurers (Enclosures)

Attention: Librarian The Exchange, Suite 245 270 Farmington Avenue Farmington, Connecticut 06032

_ __- - - _-