ML20154H720

Supplemental Application for Amends to Licenses DPR-77 & DPR-79,changing TS to Add CRMP to Administrative Controls Section & Bases of TS

ML20154H720
Person / Time
Site:	Sequoyah
Issue date:	10/08/1998
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20154H724	List: ML20154H720 ML20154H725
References
NUDOCS 9810140303
Download: ML20154H720 (4)

Text

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Tenr'essee Valley Authonty. Post Omce Du 2000. Stdy Daisy Tennessee 37379 October 8, 1998 TVA-SQN-TS-96-08, Revision 1 Supplement 10 CFR 50.90 U.S. Nuclear Begulatory 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. 96-08, REVISION 1 -

CONFIGURATION RISK MANAGEMENT PROGRAM (CRMP)

Reference:

TVA letter to NRC dated August 27, 1998, "Sequoyah Nuclear Plant (SQN) - Units 1 and 2 -

Technical Specification (TS) Change No. 96-08, Revision 1, Section 3.8.1, 'A.C. Sources' and Response to Request for Additional Information" In accordance with the provisions of 10 CFR 50.4 and 50.90, TVA is submitting a supplemental change to the referenced request. The proposed change adds a CRMP to the ,

Administrative Controls section and bases of TSs. The CRMP l provides a probabilistic risk-informed assessment process to l evaluate the overall impact of plant activities on plant risk with an emergency diesel generator (EDG) out-of-service. The proposed CRMP satisfies the Tier 3 recommendations in Regulatory Guide 1.177 for a risk-informed extension of the EDG allowed outage time (AOT). This change supersedes the discussions in.the referenced TS change regarding TVA's i intent to not include a CRMP based on the pending Maintenance Rule change. This supplemental change is an administrative ,

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. October 8, 1998 change that does not affect the results of TVA's Tier 1 or Tier 2 analysis for the proposed 7-day EDG AOT.

On September 30, 1998, TVA met with NRC to present the key elements of the proposed CRMP for SON. Agreements were made during this presentation for including additional procedural controls associated with potential external events within documents that implement SON's CRMP. The following is a description of the additional controls:

• Ensure that the EDG limiting condition for operation action will not be voluntarily entered when severe weather is expected.

• Ensure that switchyard activities are controlled to minimize the potential impact to offsite power sources when an EDG is out-of-service.

• Ensure that safety systems in the same train of the same unit associated with an EDG are not scheduled for removal from service when the EDG is scheduled to be out-of-service. The redundant safety systems of the opposite train are required to be operable in accordance with SQN's j TS requirements in Specification 3.0.5 when the associated EDG is inoperable. l l

During this meeting, NRC also requested additional information regarding the EDGs that were evaluated with respect to the core damage frequency (CDF) and large early l' release frequency (LERF) analysis. In particular, NRC wanted to know if the risk calculations considered the opposite unit's EDGs for these evaluations. Calculations have been performed considering the loss of the opposite unit's EDG.

These calculations have determined that the increase in CDF is bounded by loss of an EDG on the primary unit. This is because of the numerous safety systems that are supported by the primary unit's 6.9 kV Shutdown Board, which is dependent on the primary unit's EDG. The calculations were performed during the development of the plant risk matrix for the 10 CFR 50.65 Maintenance Rule program and remains applicable for the proposed AOT extension. For the LERF calculations, the opposite unit EDGs were not specifically considered; however, similar to the CDF effort, the primary unit evaluations are considered to be more limiting and would bound the impact.

This is also based on the minimal impact of the functions supported by the opposite unit EDGs that includes only one train of some common systems.

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l f U.S. Nuclear Regulatory Commission i Page 3 October 8, 1998.

TVA has determined that the significant hazards consideration associated with the proposed change in_the referenced letter is still valid and that the change continues to be exempt from environmental review pursuant to the provisions of 10 CFR 51.22 (c) (9) . These evaluations are not resubmitted in this supplemental' request. 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 provides a description, reason, and safety analysis for the supplemental change. , Enclosure 2 contains

marked-up copies of the appropriate TS pages from Units 1 and L 2 to show-the supplemental changes. Enclosure 3 forwards the l revised TS pages for Units 1 and 2 that incorporate the  !

l supplemental changes.

l l TVA requests that the supplemental TS changes be made l effective within 45 days of NRC approval. If you have.any l questions about this change, please telephone me at (423) i 843-7170 or J. D. Smith at (423) 843-6672.

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.. October 8, 1998 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 1

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