ML20204H399

TS Change 99-01 to Licenses DPR-77 & DPR-79,relocating TS Associated with Electrical Equipment Protective Devices to Technical Requirements Manual

ML20204H399
Person / Time
Site:	Sequoyah
Issue date:	03/19/1999
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20204H406	List: ML20204H399 ML20204H408
References
CON-TVA-SQN-TS-99-01, CON-TVA-SQN-TS-99-1 NUDOCS 9903290069
Download: ML20204H399 (10)

Text

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HM Tennessee Vahey Autnonty Pest Ottee Box 2000 oddy-Daisy. Tennessee 37379 l

March 19, 1999 l l

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TVA-SON-TS-99-01 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) - UNITS 1 AND 2 - TECHNICAL SPECIFICATION (TS) CHANGE NO. 99-01, " RELOCATION OF SPECIFICATIONS ASSOCIATED WITH ELECTRICAL EQUIPMENT PROTECTIVE DEVICES" In accordance with the provisions of 10 CFR 50.4 and 50.90, TVA is submitting a request for an amendment to Licenses DPR-77 and DPR-79 to change the TSs for Units 1 and 2. The proposed change relocates TS 3.8.3.1, " Containment Penetration Conductor Overcurrent Protective Devices,"

TS 3.8.3.2, " Motor Operated Valves Thermal Overload Protection," TS 3.8.3.3, " Isolation Devices," and the associated Bases from the TS to the SQN Technical Requirements Manual (TRM). This change does not alter the current requirements for operability or surveillance testing of these protective devices and future revisions to these requirements will require an evaluation in accordance with 10 CFP 50.59.

TVA has determined that there are no significant hazards considerations associated with the proposed change and that the change is exempt from environmental review pursuant to the provisions of 10 CFR 51.22 (c) (9) . The SON Plant Operations Review Committee and the SQN Nuclear Safety Review Board have reviewed this proposed change and determined that operation of SON Units 1 and 2, in accordance with the proposed change, will not endanger the health and safety of the public. Additionally, in accordance with 10 CE R 50.91 (b) (1) , TVA is sending a copy of this letter to l the Tennessee State Department of Public Health.

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990329bO69 N O'319 PDR ADOCK 05000327; P PDR ,,

l U.S. Nuclear Regulatory Commission I Page 2 March 19, 1999 Enclosure 1 to this letter provides the description and evaluation of the proposed change. This includes TVA's determination that the proposed change does not involve a significant hazards consideration, and is exempt from environmental review. Epclosure 2 contains copies of the j appropriate TS pages from Units 1 and 2 marked-up to show the proposed change. Enclosure 3 forwards the revised TS pages for Units 1 and 2, which incorporate the proposed change.

l TVA requests that the revised TS be made effective within i 45 days of NRC approval. If you have any questions about

! this change, please telephone me at (423) 843-7170 or J. D.

Smith at (423) 843-6672.

Since 1, s _

l a P alas Manager of Licensing Subscribed gpd sworn to fore te on this ,/ 9 - day of , , , d///)/ )

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Notar9'F'ublic /

l My Commission Expires October 9, 2002 Enclosures cc: See page 3 4

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U.S. Nuclear Regulatory Commission Page 3 March 19, 1999 j cc (Enclosures):

Mr. R. W. Hernan, Project Manager Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 Mr. Michael H. Mobley, Director (w/o Enclosures)

Division of Radiological Health Third Floor L&C Annex 401 Church Street Nashville, Tennessee 37243-1532 NRC Resident 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 l

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ENCLOSURE 1 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT (SQN)

UNITS 1 AND 2 ,

DOCKET NOS. 50-327 AND 50-328 l PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE 99-01 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE l

I. DESCRIPTION OF THE PROPOSED CHANGE r

The proposed change will remove TS 3.8.3.1, " Containment \

Penetration Conductor Overcurrent Protective Devices,"

TS 3.8.3.2, " Motor Operated Valves Thermal Overload Protection," TS 3.8.3.3, " Isolation Devices," and the associated Bases for Units 1 and 2. TVA will relocate these TS requirements to the SON Technical Requirements Manual -(TRM) . In addition, the appropriate TS index pages have been revised to reflect this change. l II. REASON FOR TH2 PROPOSED CHANGE TVA requests the proposed change to remove requirements from the SQN TSs that do not meet the criteria in 10 CFR 50.36. TVA's proposed change is provided in accordance with the NRC Final Policy Statement, which states that TS requirements that do not meet any of the screening criteria for retention may be proposed for removal from the TS and relocated to licensee-controlled documents, such as the Final Safety Analysis Report or TRM.

TVA's proposed change will allow for any future revisions to be controlled under 10 CFR 50.59 to ensure maintenance of the licensing basis.

III. SAFETY ANALYSIS SQN TS 3/4.8.3 is entitled, " Electrical Equipment Protective Devices," and contains requirements for three sets of electrical protective devices. These devices consist of circuit breakers, fuses, and motor-operated valve (MOV) thermal overload devices that are integral with the motor starter. These devices open the control and/or power circuit whenever the load conditions exceed the rated current demands. SON TSs separate the requirements for these devices into three limiting condition of operations (LCOs). A description of each LCO is provided below:

A. LCO 3.8.3.1, " Containment Penetration Conductor

Overcurrent Protective Devices" l

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4 SQN's containment electrical penetrations and penetration conductors are protected by either de-energizing circuits not required during reactor operation or by primary and backup overcurrent protection circuit brsakers and fuses. These circuit breakers and fuses are designed to minimize the potential for a fault in a component inside containment or in cabling which penetrates containment. These devices prevent an electrical penetration from being damaged f.n such a way that the containment structure is breached.

B. LCO 3.8.3.2, " Motor-Operated Valve Thermal Overload Protection Devices" SON's MOV thermal overload protection devices are designed to minimize the potential for an improper setting of L thermal overload. An improper thermal overload setting would prevent a vital piece of equipment from performing its intended function.

C. LCO 3.8.3.3, " Isolation Devices" SQN's isolation devices are circuit breakers and fuses that protect the 1E busses from current faults generated by non-qualified loads powered by the 1E busses. These isolation devices are designed to open upon receipt of a fault current generated by non-qualified loads on the 1E busses. These circuit breakers and fuses ensure that safety-related loads function under design basis accident and transient I conditions.

l The above LCOs contain operability requiremGnts and surveillance requirements (SRs) to ensure these electrical equipment protective devices remain operable in Modes 1, 2, i 3, and 4, or in the case of thermal overload protection i devices, whenever the MOV is required to be operable. The l current SRs include the conduct of periodic channel calibrations and channel functional tests. In addition, l the current SRs associated with SQN's containment penetration conductor overcurrent protective devices and isolation devices include inspections and preventive maintenance that are performed in accordance with l manuf acturer's recommendatione . The current SON TS Bases provide a description and basis for each LCO.

TVA's proposed TS change relocates the current LCOs and SRs to the SQN TRM. TVA's proposed TS change is consistent with the guidance of the Westinghouse Standard TS (NUREG-1431). In NUREG-1431, there are no requirements associated with electrical mquipment protective devices because these devices do not meet the criteria in 10 CFR 50.36. TVA has evaluated SON's current TS requirements I

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l against the criteria of 10 CFR 50.36. The following I discussions address the applicability of the 10 CFR 50.36 l criteria to SQN's TS for electrical equipment protective devices: l Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

LCO 3.8.3.1:

SON's containment penetration conductor overcurrent protective devices are not installed instrumentation that ,

is used to detect and indicate in the control room a l significant abnormal degradation of the reactor coolant pressure boundary. Therefore, this specification does not satisfy Criterion 1.

LCO 3.8.3.2:

SON's MOV thermal overload protection devices are not installed instrumentation that is used to detect and indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary.

Therefore, this specification does not satisfy criterion 1.

LCO 3.8.3.3:

SQN's isolation devices are not installed instrumentation that is used to detect and indicate in the control room a significant abnormal degradation of the reactor coolant pressure boundary. Therefore, this specification does not satisfy Criterion 1.

Criterion 2: A process variable, design feature or operating 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.

LCO 3.8.3.1:

SQN's containment penetration conductor overcurrent protective devices help to preserve the assumptions of the safety analysis by enhancing proper equipment operation; however, they are not a process variable, design feature i or operating restriction that is an initial condition for i a DBA or Transient Analysis that either assumes the failure of or presents a challenge to the integrity of a t fission product barrier. Therefore, this specification does not satisfy Criterion 2.

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LCO 3.8.3.2:

SON's MOV thermal overload protection devices help preserve the assumptions of the safety analysis by enhancing proper equipment operation; however, the MOVs thermal overload protection devices are not a process variable, design feature or operating restriction that is i an initial condition of a DBA or Transient Analysis that l either assumes the failure of or presents a challenge to  !

the integrity of a fission product barrier. Therefore, th s specification does not satisfy Criterion 2. 1 I

LCO 3.8.3.3.

SON's circuit breakers used for isolation devices help to preserve the assumptions of the safety analysis by ,

enhancing proper equipment operation; however, the l isolation devices are not a process variable, design i feature or operating restriction that is an initial condition of a DBA or Transient Analysis that either l assumes the failure of or presents a challenge to the integrity of a fission product barrier. Therefore, this specification does not satisfy Criterion 2.

Criterion 3: A structure, system or component that is part of the primary success path and which functions or actuates to mitigate a DBA or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

LCO 3.8.3.1:

SQN's containment penetration conductor overcurrent protective devices provide equipment and distribution system protection-from faults or improper operation of other protective devices in addition to that provided by the design of the SON's distribution system. However, these devices are not a structure, system or component that is part of the primary success path and which function or actuate to mitigate a DBA or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. In the event of failure of a protective device to trip the circuit, the upstream protective device is expected to operate and isolate the faulty circuit. Thus, the protective devices that provide coordination against losing the redundant power source are at'a much higher level in the power system. Backup devices assure that in the tvent of a single failure loss of the primary device, there is still a_ backup device to protect the penetration. Under a j worst-case fault condition, a single division of

protective i' unctions can be lost. Therefore, this specification does not satisfy Criterion 3.

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i LCO 3.8.3.2:

SQN's MOV thermal overload protection devices provide equipment and distribution system protection from faults or improper operation of other protection in addition to that provided by the design of the distribution system.

However, SQN's h0V thermal overload protection devices are not a structure, system or component that is part'of the l L primary success path and which function or actuate to  !

mitigate a DBA or Transient that either assumes the failure of or presents a challenge to the integrity of a i

fission product barrier. Therefore, this specification does not satisfy Criterion 3.

LCO 3.8.3.3: 1 SQN's isolation devices help to preserve the assumptions of the safety analysis by enhancing proper equipment operation; however, the isolation devices are not a j structure, system or component that is part of the primary '

success path and which function or actuate to mitigate a l DBA or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product l barrier. Therefore, this specification does not satisfy i Criterion 3. l l

Criterion 4: A structure, system or component, which operating experience or probabilistic safety assessment has shown to be significant to public health and safety.

LCO 3.8.3.1:

SON's containment penetration overcurrent devices are not l involved in risk dominant sequences that lead to either core melt or releases to the environment. Failure of the overcurrent devices is an insignificant contributor to the total failure probability of the equipment / components fed by the circuit. Failure of the overcurrent devices could result in loss of integrity in a particular electrical penetration; however, penetration overcurrent device ,

failures are not risk significant. Accordingly, these

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j devices are not considered prime importance for risk. l LCO 3.8.3.2:

SON's MOV thermal overload protection devices are not involved in risk dominant sequences. Thermal overload l protection. failure is an insignificant contributor to the l l

total' failure probability for the associated MOV.

Consequently, thermal overload protection is not considered prime importance to risk.

LCO 3.8.3.3:

SON's isolation devices protect against the loss of a 1E bus. Although the isolation device failure can lead to the El-5

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loss of a 1E bus, the isolation devices are insignificant contributors to the total failure probability of the bus.

A current review of SQN's periodic test history and operating experience shows good performance relative to the trip function of these 1E to non-1E isolation devices and the protection of the bus. Accordingly, these devices are l

not considered prime importance to risk. 1 Based on the above discussion, SQN's electric equipment i protective devices are not considered significant to the public health and safety and do not satisfy Criterion 4.

In accordance with 10 CFR 50.36, the proposed relocation of SQN's TS requirements for electrical equipment protective devices to the SQN TRM is acceptable based of the above l criteria evaluation. In accordance with 10 CFR 50.59, the l relocated requirements will be controlled to ensure changes are not implemented that would reduce the functionality or testing of these devices without prior NRC review.

IV. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION i

TVA has concluded that operation of SON Units 1 and 2, in i accordance with the proposed change to the technical '

specification (TS), does not involve a significant hazards )

consideration. TVA's conclusion is based on its

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evaluation, in accordance with 10 CFR 50.91(a) (1) , of the  :

three standards set forth in 10 CFR 50.92(c).

A. The proposed amendment does not involve a significant increase in the probability or consequences of an

, accident previously evaluated.

The proposed revision to the TS relocates the requirements for SON's electrical equipment protective devices without changing the current requirements.

TVA does not concider these devices to be the source of any accident; therefore, this administrative relocation of the requirements will not increase the possibility of an accident. SQN's electrical equipment protective de. vices will continue to provide fault protection for circuits and equipment. Changes to the relocated requiri.ments will be processed, in accordance with 10 CFR 50.59, to ensure changes are not implemented that would reduce the functionality or introduce an unreviewed safety question to SQN's electrical equipment devices. Therefore, the proposed

! relocation of the TS requirements for electrical

! equipment protective devices will not increase the consequences of an accident.

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B. The proposed amendment does not create the possibility of a new or different kind of accidedt from any accident previously evaluated.

SQN's electrical equipment protective devices ensure proper operation of plant equipment. These devices are not associated with accident mitigation or previously evaluated accidents and would not be the initiator of any new or different kind of accident.

The proposed change does not alter the current functions of these devices, therefore, this proposed change will not create the possibility of a new or different kind of accident.

C. The proposed amendment does not involve a significant reduction in a margin of safety.

The requirements for SON's electrical equipment protective devices are unchanged by the proposed relocation of the requirements to the SQN Technical Requirements Manual. The function of these devices and the surveillance testing to ensure operability of these devices remains unchanged. Any future changes to these requirements will be evaluated, in accordance with 10 CFR 50.59, to ensure acceptability and NRC review as required. Accordingly, the proposea change will not result in a reduction in a margin of safety.

V. ENVIRONMENTAL IMPACT CONSIDERATION The proposed change does not involve a significant hazards consideration, a significant change in the types of or significant increase in the amounts of any effluents that may be released offsite, or a significant increase in individual or cumulative occupational radiation exposure.

Therefore, the proposed change meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22 (c) (9) . Therefore, pursuant to 10 CFR 51.22(b), an environmental assessment of the proposed change is not required.

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