ML20202J742

TS Change 97-04 to Application for Amends to Licenses DPR-77 & DPR-79,relocating Snubber Requirements from Section 3.7.9 of TS to Plant Technical Requirements Manual

ML20202J742
Person / Time
Site:	Sequoyah
Issue date:	02/13/1998
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20202J745	List: ML20202J742 ML20202J760 ML20202J765
References
CON-TVA-SQA-TS-97-04, CON-TVA-SQA-TS-97-4 NUDOCS 9802230210
Download: ML20202J742 (8)

Text

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Tennessee V$ ley Authority, Post offce Box 2000, Soddy-Daisy, Tennessee 37379-2000 February 13, 1998 TVA-SQN-TS-97-04 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:

In the Matter of ) Docket No(s). 50-327 Tennessee Valley Authority ) 50-328 SEQUOfAH NUCLEAR PLANT (SQN) - UNITS 1 AND 2 - TECHNICAL SPECIFICATION (TS) CHANGE NO. 97-04, " RELOCATION OF SNUBBER REQUIREMENTS" 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 the snubber requirements from Section 3.7.9 of the TS to the SON Technical Requirements Manual (TRM). This change does not alter the current requirements for operability or surveillance testing of the snubbers and fmture revisions of these requirements will require an evaluation in accordance with 10 CFR 50.59. The proposed change relocates the associated TS Bases for the snubbers. In addition to the proposed relocation, TVA proposes an editorial change to delete License Condition 2.C. (19) , for Unit 1 only. This condition is a one-time snubber-related action that was completed and does not need to be included in the SON Operating License.

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 l the provisions of 10 CFR 51.22 (c) (9) . The SQN Plant g

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Page 2 February 13, 1998 Operations Review Committee and the SON Nuclear Safety Review Board have reviewed this proposed change and determined that operation of SQN 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 CFR 50. 91(b) (1) , TVA is sending a copy of this letter to the Tennessee State Department of Public Health.

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. Enclosure 2 contains copies of the 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.

Enclosure 4 contains the SQN TRM that has been approved with the snubber requirements included.

TVA requests that the revised TS be made effective withir.

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. <

Sincerely,

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. Manager of Licensing 1;efore me Subscribe o this /0 <j,-gnd daysworn of Jtp /14&2444

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Enclosures cc: See.page 3

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l U.S. Nuclear Regulatory Commission

Page 3 i j February 13, 1998 '

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cc (Enclosures): 1 Mr. R. W. Hernan, Project Manager

_ Nuclear Regulatory Commission i

One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852-2739 i 2

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 4

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ENCLOSURE 1 TENN.SSEE VALLEY AUTHORITY SEC' \H NUCLEAR PLANT (SQN)

UNITS 1 AND 2 Dov TT NOS 50-327 AND 50-328 PROPOSED TECHNICA_ SPECIFICATION (TS) CRANGE TS-97-04 DESCRIPTION AND EVALUATION OF TFE PROPOSED CHANGE 1

I. DESCRIPTION OF THE PROPOSED CHANGE The proposed change will remove the requirements in Section 3.7.9 of the TS and the associated Bases for Units 1 and 2. TVA will relocate the snubber requirements in this section to the SQN Technical Requirements Manual (TRM). The appropriate index pages have been revAsed to reflect this change. License Condition 2.C. (19) will be deleted for Unit 1. This condition required TVA to provide a listing of mechanical snubbers within 12 months l of Jicense issuance and the performance of a comprehensive inspection program in accordance with plant instructions in the interim.

II. REASON FOR THE PROPOSED CHANGE l

TVA requests the proposed change to remove requirements from the SQN TSs that do not meet the criteria in 10 CPR 50.36 for specifications that are required to be contained in the TSs. In the Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, published in the Federal Register, Page 39132, Volune 58, Number 139, NRC stated that TSs that do not meet any of the screening crietria for retention may be proposed for remcval from the TS and relocated to licensee-controlled documents, such as the Final Safety Analysis Report or TRM. This change will allow revisions to the snubber requirements in e ordance with 10 CFR 50.59 without requiring a License Amendment Request and adds flexibility to processing necessary changes.

The License Condition deletion for Unit 1 is proposed to remove requirements from the SON License that are no longer necessary.

III. SAFETY ANALYSIS Snubbers are passive devices used for supporting piping systems. The snubbers prevent unrestrained pipe or component motion under dynamic-loads that may occur-during a seismic event, a design basis accident, or severe plant El-1 J

transient. The restraining action of the snubbers ensures that the initiating event faiture does not propagate to 4

other parts of the failed systen or to other safety systems. Snubbers also .11ow .tormal thermal expansion of piping and nozzles to eliminree excessive thermal stresses during startup and shutdown.

The current TS requirements provide actions for inoperability and surveillances to verify the operability of safety-related snubbers. The current action for an inoperable snubber is to replace ,r return the snubber to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> a..a perform an engineering evaluation of the attached component. The attached system is declared inoperable if the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> expires or the evaluation indicates that the system is inoperable. The current surveillances provide requirements for an augmented inservice inspection program including visual and functional tests. This specification also contains program allowances for inspection interval, lot size, inspection evaluation, lot composition, acceptance criteria, failure analysis, attached component analysis, service life, and exceptions from visual or functional tests.

Current TS Bases discussions contain the basis for requiring snubbers, the basis for the allowed snubber outage time, and clarifications regarding the application of the snubber surveillance requirements.

The proposed changes are consistent with Standard TS (NUREG-1431) and 10 CFR 50.36. In NUREG-1431, requirements are not included for snubbers and the criteria in 10 CFR 50.36 for features required to be retained in TS do not apply to the SQN snubbers. NRC's Final Policy Statement recommends that TSs that do not meet the screening criteria for retention may be relocated to another licensee-controlled document. The following discussior.s address the applicability to the 10 CFR 50.36 criteria:

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degladation of the reactor coolant pressure boundary.

The snubbers are not installed instrumentation or have the ability to detect abnormal degradation of the reactor coolant pressure boundary. Therefore, the SON safety-related snubbers do not satisfy Criterion 1.

Criterion 2: . A process variable, design feature, or operating restriction that is an initial condition of a c Design Basis Accident (DBA) or Transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

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The snubbers are a design feature that is associated with maintaining the integrity of safety-related piping systems during accident transients. However, the snubbers are not explicitly considered in the accident analysis and are not considered a required initial condition for a DBA or Transient to maintain the integrity of a fission product barrier. The availability of the snubbers is assured based on the performance of periodic inspections and testing.

Therefore, the SON snubbers do 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.

Safety-relaced snubbers are design features that function during accidents or transients to prevent the propagation of an event to systems that are part of the primary success path for accident mitigation. However, snubbers are not explicitly considered in the accident analysis, but are a structural design feature whose operation is assured by an inspection program. The SON snubbers are not a primary success path for accident mitigation; therefore, they do not satisfy Criterion 3.

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

Operational experience or probabilistic safety assessment have not shown the SON snubbers to be significant to the public health and safety. Therefore, the snubbers do not satisfy Criterion 4.

The proposed relocation of the snubber requirements to the SON TRM is acceptable based of the above discussions. The relocated requirements will be controlled, in accordance with 10 CFR 50.59, to ensure changes are not implemented that would reduce the functionality or testing of the snubbers without prior NRC review. TVA has approved the SON TRM, whic' includes these requirements for the snubbers.

The deletion of License Condition 2.C. (19) for Unit 1 is an '

editorial change that will not impact the function of SON safety-related features. The action to provide a listing of mechanical snubbers and an interim inspection program was satisfied previously such that this condition is no longer applicable to SON and the current requirements for safe operation.

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IV. NO SIGNIFICANT HAZARDS CONSIDERATION DETERMINATION TVA has concluded that operation of SON Units 1 and 2, in accordance with the r:oposed change to the TS, does not involve a significant hazards consideration. TVA's conclusion is based on its 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 snubbers without changing the current requirements and deletes an obsolete License Condition. TVA does not consider the snubbers to be the source of any accident; therefore, this administrative relocation of the requirements and License Condition deletion will not increase the possibility of an accident. The capability of the snubbers will continue to provide the same function in support of accident mitigation. Changes to the relocated requirements will be processed, in accordance with 10 CFR 50.59, to ensure the snubber functions will be properly maintain. Therefore, the proposed relocation of the snubber requirements and License Condition deletion will not increase the consequences of an accident.

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

The SON safety-related snubbers provide support for mitigation functions associated with previously evaluated accidents and are not the initiator of any accident. The proposed change does not alter the current functions of the snubbels; therefore, it will not create the possibility of a new or different kind of accident.

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

The requirements for SON safety-related snubbers are unchanged by the proposed relocation of the

, requirements to the SQN TRM and the License Condition deletion. The' function of the snubbers and surveillances to ensure operability will remain the same as currently required by the TS. Changes to

these requirements will be evaluated, in accordance with 10 9FR 50.59, to ensure acceptability and NRC i

review as required. Therefore, the proposed 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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