ML20072D482

Application for Amend to License DPR-79,proposing Changes to License Conditions Re post-accident Sampling.Description of Proposed Changes,Justification & Significant Hazards Determination for Proposed License Conditions Encl

ML20072D482
Person / Time
Site:	Sequoyah
Issue date:	06/16/1983
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	Adensam E Office of Nuclear Reactor Regulation
References
NUDOCS 8306230272
Download: ML20072D482 (17)

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/ TENNESSEE VALLEY. AUTHORITY CHATTANOOG A. TENNESSEE 374ot 400 Chestnut Street Tower II

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' June 16, 1983 Director of Nuclear Reactor Regulation Attention: Ms. E. Adensam, Chief Licensing Branch No. 4 Division of Licensing U.S. Nuclear Regulatory Coinnission Washington, D.C. 20555

Dear Ms. Adencan:

In the Matter of ) Docket No. 50-328 Tennessee Valley; Authority ).

In accordance with 10 CFR Part 50.90, enclosed are 40 copies ,of proposed revisions to the'Sequoyah Nuclear Plant Unit 2 Operating License, DPR-79 (Enclosure 1)'. The proposed license a&endment requests chahges in the operating license conditions as tr result of our review of the Sequoyah Nuclear Plant unit 2 work activities scheduled for the forthcoming unit 2/ cycle 1 refueling outage. Notification of our intent to submit a request for a licente amendment was made} by my April 14, 1983 letter to you. Enclosure 2 provides the justification for the proposed amendment.

Enclosure 3 provides a significant hazards determination for each of the proposed operating license., conditions. ,

6 In accordance with th'e provisions of 10 CPR Part 170, we have determined the changes-to be Class III for operating license DPR-79 This classifica-tion is based 'on the fact that the;'unendment involves a single issue for one unit. The remittance fee of $4,000 is being wired to the Nuclear Regulatory Commission, Attention: Licensing Fee Management Branch.

This requested amendment has been evaluated pursuant to 10 CFR Part 50.92 and no significant hazards considerations are involved. This license amendment request is being submitted concurrent with the review by our Nuclear Safety Review Board.

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U.S. Nuclear Re'gulatory Comission June 16, 1983 s

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'N 1 If you have any questions concerning this natfer, please get in touch with J. E. Wills'at FTS 858-2683 s

! Ypry truly yours, t i TENNESSEE VALLEY AUTHORITY L. M.' Mills, Man ger Nuclear Licensing  ;

Sworn o d subscr/ bed before me this 1 _ ' day of W h/Ll> -1983 Notary Public, g -

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Enclosures f cc: U.S. huolear Regulatory Commission'(Enclosures)

Region II Attni Mr. James P. O'Reilly Administrator 101 Marietta Street, NW, Suite 2900 Atlanty,' Georgia 30303 Michael H. Mobley, D16ector (Enclosures) > ,

. Division o" Radiological Health T.E.R.R.A. Edilding - -

150 9th Avenue North 's ,

Nashville, Tennessee 37203 i

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.Qg ENCLOSURE 1 PROPOSED LICENSE CONDITIONS SBQUOYAH NUCLEAR PLANT UNIT 2

--? OPERATING LICENSE DPR-79 License Condition 2.C(16) .m - Post Accident Samolinz s Existiam Condition At the first outage of ufficient duration, but no later than startup following first refueling outage, TVA shall complete corrective actions needed to provide the capability to promptly obtain and perform radio-isotopic and chemical analyses of reactor coolant and containment atmosphere samples under degraded core conditions without excessive n exposure, i (0

Proposed Contcition 6, 1 At the first outage of sufficient duration, but n. 1 ster than startup

-, . following second refueling outage, TVA shall complete corrective actions needed to provide the capability to pramptly obtain and perform radio-isotopic and chemical analyses of reactor coolant and containment l atmosphere staples under degraded core conditions with excessive e xpos ure. -

'Licenio Condition 2.C(16) .1.(2)( a) - Additional Accident Monitoring p t, " instrumentation Existint Condition (1) TVA shall install interim noble gas monitors at the first outage of

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(2) At the firs _t outage of sufficient duration, but no later than startup following first refueling outage, TVA shall install the f ollowing

' qualified monitoring instrumenta tion:

(a) Integrcted monitoring assembly which will accomplish partica-late, iodine and noble gas monitoring.

, . (b) Containment high range radiation monitor.

! (c) . Containment pressure monitor.

l (d) Containment water level monitor.

(c) Containment hydrogen monitor.

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Pron' sed Conditien (1) TVA shall install interim noble gas monitors at the first outage of sufficient duration.

(2) At the first outage of sufficient duration, but no later than startup following second refueling outage, TVA shall install the following qualified monitoring instrumenta tion:

(a) Integrated monitoring assembly which will accomplish partica-late, iodine and noble gas monitoring.

(b) Containment high range radiation monitor.

(c) Containment pressure monitor.

(d) Containment water level monitor.

(e) Containment hydrogen monitor.

License Condition 2.C(16) .m.(2) - Instruments for Inadeauste Core Coolina Existina Condition (1) By January 1,1982, TVA shall install a backup indication for incore therm ocoupl es. This display shall be in the control roam and cover the tamperature range of 200 F - 2000 F.

(2) At the first outage of sufficient duration, but no later than startup following first refueling outage, TVA shall install reactor vessel water level instrumentation and the system will meet seismic and environmental requirements.

Proposed Condition (1) By January 1,1982, TVA shall install a backup indication for incore

( thermocouples. This display shall be in the control room and cover l the temperature range of 200 F - 2000 F.

(2) At the first outage of sufficient duration, but no later than startup following second refueling outage, TVA shall install reactor vessel water level instrumentation which meets NRC requirements.

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Llaease Condities 2.C(16) .a.(1) - Unar-d* Emiraensy Suonert Facilities Existina Condition l l

(1) The installation of the TSC shall be completed before startup af ter the first refueling. How ev er, if an outage scheduled to last more than five weeks occurs af ter May 1,1982, installation of the necessary modifications to the control room and plant instrumentation will be completed at that time and the TSC hardware installation will be completed within eleven weeks of the start of this scheduled 1 outage. l l

(2) TVA shall maintain interim emergency support f acilities (Technical l Support Center, Operations Support Center and the Emergency Operations {

Facility) until the final f acilities are complete. l Proposed Condition (1) At the first outage of sufficient duration, but no later than startup following the second refueling outage, TVA shall update the Technical Support Facilities to meet NRC requirements.

(2) TVA shall maintain interim emergency support f acilities (Technical Support Center, Operations Support Center and the Emergency Operations Facility) until the final facilities are complete. ]

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ENCLOSURE 2 JUSTIFICATION FOR PROPOSED LICENSE AMENDNSIT SEQUOYAH NUCLEAR PLANT UNIT 2 OPERATING LICENSE DPR-79 Late in 1981 TVA set with representatives of NRC to discuss the integrated schedule concept f or Browns Ferry Nuclear Plant. The reason for the development of this schedule was that the number of modifications and magnitude of the required modification work to comply with NRC require-ments and NRC commitments was beyond the capabilities of the plant to reasonably manage. A meeting was held with the NRC in September 1982 to discuss the Sequoyah Nuclear Plant Unit 1 integrated schedule concept that was submitted to the NRC on August 6,1982. A revised integrated schedule was subsequently submitted to the NRC by my November 22, 1982, letter to you, to include the proj ected schedule and manpower levels for unit 2.

We are still encountering problems with scheduling for unit 2 similar to those encountered with unit ? . Again, the effects of proceeding with the present Sequoyah unit 2 schedule include the following:

l l 1. Extended periods of overtime worked by employees resulting in a

! deterioration in employee alertness and subsequently more personnel errors.

2. Plant staff's participation in modification-related activities places l

an additional burden on personnel to the detriment of the operation of the plant.

3. The high level of work activity imparts a near impossible procedural, l testing, and maintenance change preparation load as well as additional training.

4. Large numbers of employees result in increased security, health physics, and QA deviations as well as LERs.

The proposed integrated schedule of work activities and def erral of outstanding license conditions was submitted to NRC by my April 14, 1983 letter to you. Additional information regarding the integrated schedule was provided by my June 2,1983 letter to you. . This schedule was the result of a multistep review of all required unit 2 work activities for l this outage. This review included: (1) prioritization of the work i activity according to saf ety significance (NRC commitments were considered high priority), (2) review of each activity to determine the status of required design information, availability of materials, required manpower, etc., (3)- establishment of management limitations on the extent of work activities and manpower levels, and (4) development of a final integrated schedule based on steps 1 through 3. Attachment 1 provides additional justification for proposed license condition changes for which f actors exist over and above those described above.

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Many NRC ccdificatica requiremsnts for Ssquoych, dza to liosass require-cssts and complicase with NUREG-0737, are very extensive and rsquire extremely high manpower levels. Many of these commitments were made by IVA at a time when the requirements were poorly defined and therefore final design and procurement time estimates were extremely rough at best. The

' result of these uncertainties and procurement problems is that many major modifications will need to be delayed and will now have to be worked l concurrently with those requiring a plant outage to satisfy existing licensing conditions and commitments. The outage has been extended from 45 days required for refueling to 96 days to accommodate NRC commitment l modification work. As demonstrated by the schedule, several license

! condition modifications will require def erral beyond the existing requirmnent date. Enclosure 1 to my June 2,1983 letter provides the impact to the schedule, for the forthcoming refueling outage, as a result of having to complete the existing NRC commitments by the end of the unit 2, cycle 1 refueling outage. .

The information provided by this letter, the April 14 letter, and the June 2,1983 letter, constitute the basis for deferral of the operating license conditions. The integrated modification schedule concept is consistent with the NRC's guidelines which endorse

• the concept of l establishing implementation schedules for new and existing requirements j which reflect the importance of the saf ety requirement" and the licensee's ability to complete the necessary engineering, evaluation, design, and installa tion "

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AITACENENT 1

! ADDITIONAL JUSTIFICATIONS FOR PROPOSED LICENSE CONDITIONS I

JLQUOYAH NUCLEAR PLANT UNIT 2

• PERKf1NG

, LICENSE DPR-79 p License Condition 2.C.(16) .a Po/t Accident Samolina The current probable material delivery date for all required material for this modification is f all 1983. Any vendor delivery problems conid delay this date by several months. Lupissentation of this modification for unit 2 will require an additional 62,565 man-hours. Because of the current schedule for the unit 2 cycle 1 refueling outage, this will not allow TVA to complete this modification, without significantly affecting the unit 2 outage, until each unit's respective cycle 2 outages.

In the interim, as indicated in our response to NUREG-0578 and NUREG-0737, i

procedures have been established to evaluate the primary coolant system activity depending on the accessibility of the sampling stations for particular degraded conditions. TVA's response to NUREG-0578 contained a copy of Technical Instruction 66, Postaccident Sampling and Analysis Nethods.

License Condition 2.C.(16) .1.2(a) - Additional Accident Monitorina Instrumentation NUREG 0737 gave little guidance on the instrumentation specifications required to meet NURBG 0737, II.F.1. Because of the lack of guidance, TVA created their own specifications for the required radiation monitors.

Af ter several months of trying to procure radiation monitors, TVA discovered that they were not availhble using.TVAt s current procurement specifications. The time necessary for TVA to find an approved vendor utilizing the specifications delayed the purchase of the radiation monitors until September 1982. This resulted in delaying completion of the design natil August 1983.

TVA has not completed the final drawing revisions. These revisions were scheduled for completica Nay 31, 1983. Estimates indicate 22,000 man-hours, not including the civil building work, will be required to finish this modification with present manpower limits; ' theref ore, this modification cannot be completed as presently required without signifi-cantly affecting the unit 2 outage.

The present schedule for completion of this modification is before startup af ter the unit 2 cycle 2 refueling outage.

In the interin, Sequoyah will have installed high-range noble gas effinent j monitors as follows:

A. Monitors will be placed on the shield building vent and the condenser vacuum pump exhaust.

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B. Each eeniter will censist of two General Atcaic Company ocnitors as f ollows :

1. Model RD-1 with a range of 10[-1] to 10[+4]MR/hr,

2. Model RD-23 with a range of 10[3] to 10[7]MR/hr, i The model RD-1 and RD-23 monitors each utilize an ionization chamber f or the detector. .

C. The instrument readouts with continuous display and recording will be located in the main control room.

D. 1he source of power f or monitors will be preferred power (vital 4

ins trument bus) .

License Condition 2.C.(16) .m(2) - Instruments 'for Inadeanate Core Coolina The reactor vessel level system has been scheduled for installation during the second refueling outage due to its severe impact on work activities and because it is our understanding that the system cannot be turned on until emergency procedures utilizing the level system are developed, approved by NRC, and subsequent operator training completed. The Sequoyah Nuclear Plant procedure guidelines are being developed as a generic effort through the Westinghouse Electric Corporation Owners' Group. Based on the present owners' group schedule, we estimate the procedures cannot be in place and operator training completed before the f all of 1985. The level system th er ef or e, if installed during this outage, could not be used until very late into cycle 2 assuming an optimistic schedule. Delays in procedure development or NRC approval conid easily prevent use of the level system until cycle 3. Westinghouse has indicated that additional analyses will be necessary for plants utilizing ice condensers and/or upper head inj ection.

The magnitude of this work and the schedule f or completion has yet to be de te rmine d.

In addition. with present manpower limits, this modification cannot be completed as presently required without significantly affecting the unit 2 outage. The large maount of inside containment work on this modification requires a deferral for completion because of the large maount of inside containment work required by other NRC commitment items. The outside containment work consisting of approximately 29,800 man-hours of the j overall 49,500 man-hours will continue,between the unit outages.

License Condition 2.C.(16) .a(1) - Unarade Emermency Snooort Facilities i In response to NUREG 0694, TVA committed to installing the permanent Technical Support Center (TSC) by June 30, 1983. Subsequent license conditions were included in the unit 2 operating license to require installation by the first refueling outage or the first scheduled five-week outage af ter May 1,1982. Since these license conditions were established, equipment deliveries and design work have not kept pace with the expected schedule and will not be available to allow completion during the first refueling.

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.' Ths sof tworo prcgram fer ths ISC campster systen was supp11sd by Wostinghotso. Wastinghetss's criginal dalivery date for the ISC ce=puter

, cef tware uns Jo=zary 1,1981. Vastinghcass's delivery did not cost the originally scheduled date. Portions of the sof tware were delivered over cro years late to TVA. Modifications to this sof tware package by TVA are expected to be complete by the summer of 1984. The nonoutage portion of this modification will take 29 weeks to install. As currently scheduled, this nonoutage portion will not be completed before the unit 2, cycle 1 outage work begins. The magnitude of this cycle 2 outage unless the unit 2, cycle 1 length is significantly increased.

The ISC, which is located adjacent to the main control room, is being used at Sequoyah. The TSC meets the same habitability requirements as the main control room. The TSC communications include PAX telephones and Bell t el ephone s. Reference materials, including the Radiological Emergency Plan (REP), implementing procedures, plant drawings Final Safety Analysis Re por t (FS AR ) , and selected plant procedures are present. Therefore, the ISC is presently operational with the exception of the appropriate data sy s t em s.

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ENCLOSURE 3 SIGNIFICANT HAZARDS DETERMINATION FOR PROPOSED OPERATING LICENSE CONDITIONS SEQUOYAH NUCLEAR PLANT UNIT 2 9

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.~ Licsn2a Condition 2.C(16) .g - Post Accident Serpling SIGNIFICANT HAZARDS CONSIDERATION FOR ,

PROPOSED TECHNICAL SPECIFICATION CHANGES

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

- Delaying, t,he installation of the postaccident sampling system (PASS) for Sequoyah unit -2 until the second refueling outage does not significantly increase the probability or consequences of an accident previously evaluated. The safety analyses and emergency operating procedures do not require the use of the PASS. An interim procedure has been developed until the PASS is installed to obtain a pressurized RCS sample via hot sample room, nonpressurized RCS sample via RHR pump discharge, and upper / lower containment sample.via the containment radiation monitors.

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2. Does the proposed amendment create the probability of a new or different kind of accident from any accident previously evaluated?

~ Delaying installation of PASS does not create the probability of a ,

new or different kind of accident from any accident previously -

evaluated since it'is not now presently in any analysis or emergency operating procedures. ,

3. Does the proposed amendment involve a significant reduction in a margin of safety? '

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Delaying installation of PASS does not involve a significant reduction in a margin of safety since it is not presently used in any analysis or emergency operating procedures.

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Lictnso Condition 2.C(16).1.(2)(c) - Additicnal Accidtnt Monitsring Instrumsntation

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SIGNIFICANT HAZARDS CUNSIDERATION

.- FOR PROPOSED TECHNICALSPECIFICATION CHANCES

1. Does the proposed amendment involve a significant increase in the ,

probability or consequences of an accident previously evaluated? i Delaying the installation of the permanent high-range noble gas effluent monitors..and iodine..and particulate sampling of plant effluents at -

Sequoyah unit 2 u~ntil the second refueling outage does not significantly increase the probability or consequences of an accident previously eval-uated.

The safety analysis and plant emergency' operating procedures both do not require the use of the high-range noble gas effluent monitors nor iodine and particulate sampling of plant effluents. TVA will, however, provide the .following interim effluent sampling system at Sequoyah unit 2 during the first refueling outage.

(See attached page) i

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2. Does the proposed amendment create the probability of a new or

, different kind of accident from any accident previously evaluated?

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Delaying installation of permanent effluent moiittors does not create-

'the probability of a new or different kind of accident from any .-

accident previously evaluated since it is not now presently in any analysis or emergency operating procedures.

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. 3. Does the proposed amendment involve a significant reduction in a sargin o.f~ safety? .. . ,. . ,. _. _,_._ ,. .. .,.. .

Delaying installation of permanent effluent monitors does not involve a significant reduction in a margin of safety since it is not presently used in any analysis or emergency operating procedures.

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. Licsnes Condit; ion 2.C(16).1.(2)(c) (Continur.d)

. Continued frem first pago .

Interim High-Range Noble Gas Effluent Monitors The following notes apply to the interim noble gas monitors.

1. Each monitor consists of two General Atomic Company monitors as follows.

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a. Model RD-1 with a range of 10~ to 10 M/%

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b. Model RD-23 with a range of 10 to 10 mR/hr.

The model RD-1 and RD-23 monitors each utilize an ionization chamber for the detector. The RD-1 and RD-23 detectors are located at a position 9utside a sample pipe at which.the exposgre rate is approxi-mately 10 mR/hr when the sample pipe contains 10 microcuries per cubic centimeter (mci /cc) of Xe-133.

2. The monitored discharge paths are each shield building vent and the condenser vacuum pump exhaust for each unit.

3. The instrument readouts with continuous display and recording will be located in the main control room (MCR) .

4. Since the instrument readout will be continually available in the MCR, the required capability to obtain readings at least every 15 minutes during and following an accident will be ensured.

5. - The source of power for. the. monitors wi:11 be preferred power (vital instrument. bus).

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. Iodine and Particulate Sampling of Plant Effluents Interim procedures have been implemented at Sequoyah for obtaining a l local sample from plant effluents and analyzing for iodine.

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. - , LictnSo Canditica 2.C(16).n.(2) - Instruncats for Inadtquata Core Cooling SIGNIFICANT HAZARDS CONSIDERATION

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PROPOSED TECHNICAI,,, SPECIFICATION CHANGES

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

i Delaying the installation of the . reactor vessel level instr'ument system at Sequoyah Nuclear,, Plant unit 2 until the second refueling outage does not significantly inc'rease the probability or. consequences of an accident previously evaluated. The safety analyses do not take credit for any input from RVLIS. In addition, the present emergency procedures do not require the use of RVLIS. Function oriented emergency procedures will be developed using the Westinghouse Owners' Group (WOG) generic guidelines. TVA's schedule for completion of the effort including operator training, validation / verification and control room review is addressed in our response to NRC generic letter 82-33. We do not expect to complete this work until at least the spring of 1986. In accordance with generic letter 82-28, Inadequate Core Cooling (ICC) i Instrumentation System, the ICC instrumentation system (see attached) j -- . _ .

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2 Does the proposed amendment create the probability of a new or

.. different kind of accident from any accident previously evaluated?

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since it is not presently in an'y analysis,or emergency operating ,

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3. -Does the proposed ==andment involve a'significant reduction in a inargin

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Delaying installation of RVLIS does not involve a significant reduction in a margin of srfety since it is not presently used in any analysis or emergency operating procedures.

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Lic;nca , Condition 2.C(16).m. (2) (Continued)

ContinuId frca pags 1 (this includes RVLIS) should not be turned on until.the licensee has completed the task analysis portion of the control room review and should be used with prudence in relation to any operator actions or decisions until the specific design and installation have been approved by the staff and instructions on their..use and operation have been incorporated in accordance with the emergency operating procedure guidelines into approved emergency operating procedures. Both generic letters 82-28 and 82-33 are requiring an integration of procedures, training, ICC instru-mentation, and control room design review. Since the procedures, training and control room design review will not be completed until at least spring of 1986, we believe delaying the installation of RVLIS until the second refueling outage is acceptable. In addition, the WOG generic emergency operating procedure guideines have not been approved for use by NRC.

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. Licrmo (enditien 2.C(16).q.(1) - Upgrada Farrgency Suppsrt Facilities SIGNIFICANT HAZARDS CONSIDERATION FOR PROPOSED TECHNICAL,, SPECIFICATION CHANGES

1. Does the proposed amendment involve a'significant increase in the probability or consequences of an accident previously evaluated?

Delaying the installation of the technical support center (TSC) safety ~

parameter disp 1'ay system (SPDS) computer system at Sequoyah unit 2 until the second refueling outage does not significantly increase the probability or consequences of an accident previously ' evaluated. Neither the safety analyses nor the emergency operating procedures require the use of the TSC/SPDS computer system. Further, the system is not qualified to meet class lE standards; therefore, the emergency operating procedures cannot require its use. This is consistent with TVA's response to NRC on generic letter 82-33 for SPDS.

i A description of the TSC has been provided to NRC in our response to generic letter 81-10. The TSC is operational with the exception of the appropriate data systems.

^- 2. Does the proposed amendment create the probability of a new or different kind of accident from any accident previously evaluated?

~~ Delaying installation of TSC/SPDS computer system does not create the

. ' probability of a new or different kind of accident from any accidcat J previously evaluated since it is not presently in any analysis or emergency operating procedures. ,

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3. Does the proposed amendment involve a significant reduction in a margin of safety? . ,

Delaying installation of TSC/SPDS computer system does not involve a i significant reduction in a margin of safety since it is not presently used in any analysis or emergency operating procedures.

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