ML20245F672

Proposed Tech Spec Limiting Condition for Operation 3.5.1.1 Re Cold Leg Injection Accumulator

ML20245F672
Person / Time
Site:	Sequoyah
Issue date:	08/07/1989
From:	TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20245F670	List: ML20245F665 ML20245F672
References
NUDOCS 8908150034
Download: ML20245F672 (9)

Text

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ENCLOSURE 1

., ~ PROPOSED TECHNICAL SPECIf1 CATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS i AND 2 DOCKET NOS. 50-327 AND 50-328

. (TVA-SQN-TS-89-37)

LIST OF AFFECTED PAGES Unit 1 3/4 5-1 Unit 2, 3/4 5-1

)

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8908150034 890007 PDR ADDCK 05000327/

P PNU

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._3/4.5 ENERGENCY CORE COOLING' SYSTEMS (ECCS) 3/4.5.1 ACCUMULATORS -

COLD LEG INJECTION-ACCUMULATORS LIMITING CONDITION FOR OPERATION ..

3.5.1.1 -- -

a.

Each cold leg injection accumulator shall'be with:

OPERABLE The isolation valve open, b.

-borated water,A contained borated watergallons volume of of between 7 c.

Between 1900 and 2100 ppm of boron, and

d. ,

A nitrogen. cover pressure of between 385 psig.

and 447 APPLICABILITY: MODES 1, 2 and 3.*

ACTION: _

a.

With one cold leg injection accumulator inoperable

, except as a result OPERABLE status within one hour u ator to or be in at le

b. the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT SHUTDOWN owing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, within the foll DBY within

/y fB With one cold leg. injection accumulator inoperable d

,, tion valve being closed, either immediately ue toopen the i the isola-solation valve jh --

or the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

) be in HOT STANDBY within one hour within and be in HO ,41/

. SURtfEILLANCE RE0VIREMENTS y y 4.5.hl.1 -a.

Each cold leg injection accumulator shall be demo nstrated OPERABLE: '

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by:

1. Verifying and pressu,resby the absence of alarms or by measurement .

s ofNBleve cover pressure, the contained in the tanks, and borated water volume and nitrogen R16

2. Verifying that  ;

valve is open. each cold leg injection accumulator isolation

^^ Pressurizer pressure above 1000 psig. .

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5 SEQUOYAH '- UNIT.1 3/4 5-1 m:,

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Amendment No. 12 a.

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EO*d 9EIL U'3 ST9 311 311SMllG 3113 IOPm"

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_3/4.5 EMERGENCY CORE COOLING SYSTEMS

_3/4.5.1 ACCUMULATORS COLD LEG INJECTION ACCUMULATORS LIMITINGCONDITk'ONIOROPERATION 3.5.1.1 Eac cold leg injection accumulator shall be OPERABLE with:

a.

The isolation valve open, b.

'A contained borated water, borated water volume of between 7857 and 8071 gallons o .

s c.

Between 1900 and 2100 ppm of boren, and d.

A nitrogen cover pressure of between 385 and 447 psig. '

APPLICABILITY: _

MODES 1, 2 and 3.* .

ACTION:

a.

With one cold leg injection accumulator inoperable, except as a l result of a closed isolation valve, restore the inocerable STANOBY following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in H b.

With one cold leg injection accumulator inoperable due to the p d pf8 Og valve or be in HOT STANDBY within one hour an -

8 within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

M # pf - % W .

% S_ SURVEILLANCE REQUIREMENTS -

c 4.6.1.1.1 Each cold leg injection accumulator shall be demonstrated OPER a.

At least once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> by:

1.

Verifying, by the absence of alarms or by measurement of levels coverpressures, and pressure in the contained the tanks, and barated water volume and nitrogen

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2.

valve is open.Ver1fying that each cold leg injection accumulator isolati

" Pressurizer pressure above 1000 psig.

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SEQUOYAH - UNIT 2 3/4 5-1 o '

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Attachment 1

c. With less than two pressure or water level channels OPERABLE per l accumulator, return the inoperable channel (s) to OPERABLE status within l 30 days or be in at least. HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in HOT )

SHUTOOWN within the following 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. j

d. With less than one pressure or water level channel OPERABLE per l accumulator, immediately declare the affected accumulator inoperable. ,

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ENCLOSURE 2 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1-AND 2 DOCKET NOS, 50-327 AND 50-328

. (TVA-SQN-TS-89-37)

DESCRIPTION AND JUSTIFICATION FOR ADDITION OF ACTIO!4 STATEMENTS FOR INOPERABLE

- COLD LEG ACCUMULATOR LEVEL AND PRESSURE MONITORING INSTRUMENTATION l

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F ENCLOSURE 2 i

t Description of Change Tennessee Valley Authority proposes;to modify the Sequoyah Nuclear Plant'(SQN)

, - Units 1 and 2 technical specifications (TSs) to add action statements to address the failure to meet surveillance' requirement (SR) 4.5.1.1.2 for the r.old leg accumulator TSs.

,, - Reason for Change

. TVA has reviewed TS 3.5.1.1 and has determined that the TS is not' internally consistent in that it contains SRs for determining operability of the

. instruments used to. monitor water level and pressure of each accumulator (SR 4.5.1.1.2) but provides no actions to be taken when the water level or pressure channels become inoperable.

The absence of action statements that address inoperability of the accumulator water level or pressure monitoring instrumentation requires the. operator to interpret TSs 3.0.3 and 4.0.3 to determine if and what out-of-service times apply. Application of either of these TSs would lead to a response to an 4 out-of-service monitoring instrument that-is as restrictive as the response to an inoperable cold leg accumulator. This restrictive time period is insufficient to adequately plan, schedule, and effect repairs for monitoring equipment located inside lower containment. As a result, this condition would lead to unnecessary plant transients and plant shutdowns for the simple loss of. redundancy in monitoring equipment. The loss of redundancy in monitoring

- equipment in no way affects the ability of the cold leg accumulator to perform its intended safety function.

Justification for Change The addition of.the proposed action statement c provides requirements that specifically address the loss of redundancy for the instrumentation used to monitor' accumulator water level and pressure. The requirement to return the out-of-service instrument (s) to OPERABLE status within 30 days is consistent with the SR presently contained in TS 3.5.1.1 for determination of operability of the instrumentation channels. Thirty days is also a reasonable period of time to plan, schedule, and perform work inside lower. containment. The-thirty-day period is also. appropriate for a Regulatory Guide 1.97, Category D2, variable. It should be noted that separate operability requirements are imposed on Regulatory Guide.l.97, Category Al, variables through TS 3.3.3.7, but no separate operability requirements are specified for the other categories of variables. With up to one water level and one pressure channel per accumulator out of service, operability of the accumulator is still ensured by performance of 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 /> using the redundant instrument (s). The addition of the proposed action statement d provides requirements to declare the affected accumulator inoperable with the complete loss of monitoring for water level or

. pressure on an accumulator.

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In summary, the addition of the proposed action statements will have no impact on the availability or operability of the cold leg accumulators. The addition of the proposed action statements also corrects an inappropriate TS that did not adequately distinguish between the equipment being monitored (the subject of the limiting condition for operation) and the equipment used to monitor.

Correcting this problem will preclude possible plant shutdowns or transients

.. caused solely by inoperable monitoring equipment.

Environmental Impact Evaluation The proposed change request does not involve an unreviewed environmental question because operation of SQN Units 1 and 2 in accordance with this change would not:

1. Result in a significant increase in any adverse environmental impact previously evaluated in the Final Environmental Statement (FES) as modified by the Staff's testimony to the Atomic Safety and Licensing Board, supplements to the FES, environmental impact appraisals, or in any decisions of the Atomic Safety and Licensing Board, i

2. Result in a significant change in effluents or power levels.

3. Result in matters not previously reviewed in the licensing basis for SQN that may have a significant environmental impact.

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), b' ENCLOSURE 3 PROPOSED TECHNICAL SPECIFICATION CHANGE SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328

> (TVA-SQN-TS-89-37)

DETERMINATION OF NO SIGNIFICANT HAZARDS CONSIDERATIONS i

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t ENCLOSURE 3

' - Significant Hazards Evaluation TVA has evaluated the proposed.TS change and has determined that it does not represent a significant hazards. consideration based on criteria established in 10 CFR 50.92(c). Operation of SQN in accordance with the proposed amendment

. will not:

1. Involve a significant increase in the probability or consequences of an accident previously evaluated.

- The proposed change to add action statements to address the operability of monitoring instrumentation for the cold leg accumulator pressure and level instrument channels will have no effect on the operabili.ty or availability-of the cold leg accumulators themselves. The proposed change corrects an inappropriate TS that did not adequately distinguish between the equipment being monitored and the equipment used to monitor. Correcting this i problem will preclude possible plant shutdowns or transients caused solely by inoperable monitoring equipment. This change does not affect the probability or consequences of an accident previously evaluated.

'2. Create the possibility of a new or different kind of accident frcm-any previously analyzed.

The proposed change to add action statements to address the operability of monitoring instrumentation for the cold leg accumulator pressure and level {

instrument channels will have no effect on the operability or availability  ;

of the cold leg accumulators themselves. The proposed change corrects an I inappropriate TS that did not adequately distinguish between the equipment being monitored and the equipment used to monitor. Correcting this problem will preclude possible plant shutdowns or transients caused solely by inoperable monitoring equipment. This change does not create the possibility of a new or different kind of accident from any previously analyzed.

3. Involve a significant reduction in a margin of safety.

The proposed change to add action statements to address the operability of monitoring instrumentation for the cold leg accumulator pressure and level <

instrument channels will have no effect on the operability or availability l of the cold leg accumulators themselves. The proposed change corrects an -l inappropriate TS that did not adequately distinguish between the equipment l being monitored and the equipment used to monitor. Correcting this 3 problem will preclude possible plant shutdowns or transients caused solely {

by inoperable monitoring equipment. This change does not cause a j reduction in any margin of safety. l l

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