ML20206S006

TS Change 98-09 for Licenses DPR-77 & DPR-79,relocating TS 3.3.3.3, Seismic Instrumentation & Associated Bases from TS to Plant Technical Requirements Manual

ML20206S006
Person / Time
Site:	Sequoyah
Issue date:	01/15/1999
From:	Salas P TENNESSEE VALLEY AUTHORITY
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20206S010	List: ML20206S006 ML20206S013
References
TVA-SQN-TS-98, TVA-SQN-TS-98-0, NUDOCS 9901270156
Download: ML20206S006 (7)

Text

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. 1 Tennessee Vahey Authonty Post Office Box 2000 Soddv-Daisy. Tennessee 37379 i

1 1

January 15, 1999 l i

l TVA-SON-TS-98-09 10 CFR 50.90 i

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. 98-09, " RELOCATION OF SEISMIC INSTRUMENTATION" 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 3.3.3.3, " Seismic /

Instrumentation," and the associated bases from the TS to the SON Technical Requirements Manual (Tmi) . This change does /

not alter the current requirements for operability or surveillance testing of the seismic instrumentation, and future revisions of these requirements will require an pg 7gf evaluation in accordance with 10 CFR 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 SQN 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 CFR 50. 91 (b) (1) , TVA is sending a copy of this letter to the Tennessee State Department of Public Health.

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9901270156 990115 PDR ADOCK 05000327 P PDR' -

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l l l l U.S. Nuclear Regulatory Commission Page 2

,. January 15, 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. 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 l

! for Units 1 and 2, which incorporate the proposed change. I L

l NRC review and approval of the proposed TS change is l requested prior to August 2, 1999. This date is the i

projected start date for field work associated with a plant ,

upgrade for SON's seismic instrumentation. j TVA requests that the revised TS be made effective within 45 days of NRC approval. If you have any questions about this change, please telephone me at (423) 843-7170 or J. D. i Smith at (423) 843-6672.

Sincerely, f

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Pe as Manager of Licensing Subscribed d sworn before me n -his ./ day of ()/y 7-. /1/2 M y l

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My Commission Expires October 9, 2002 Enclosures l cc: See page 3 l i 1

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! U.S. Nuclear Regulatory Commission Page 3

,, January 15, 1999 1

cc (Enclosures): l 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 1

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

ENCLOSURE 1 I I TENNESSEE VALLEY AUTHORITY ,

SEQUOYAH NUCLEAR PLANT (SQN) l UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328 PROPOSED TECHNICAL SPECIFICATION (TS) CHANGE TS-98-09 DESCRIPTION AND EVALUATION OF THE PROPOSED CHANGE l

l I. DESCRIPTION OF THE PROPOSED CHANGE The proposed change will remove the seismic instrumentation i requirements and the associated Bases from the TSs for l Units 1 and 2. TVA will relocate the seismic instrumentation requirements to the SON Technical ,

Requirements Manual (TRM). In addition, the appropriate TS l index pages have been revised to reflect this change. i II. REASON FOR THE PROPOSED CHANGE TVA requests the proposed change to remove requirements from the SON TSs that do not meet the criteria in 10 CFR 50.36. TVA's proposed change is provided in j accordance with the guidance in NRC Generic Letter (GL) - 95-10, " Relocation of Selected Technical Specifications Requirements Related to Instrumentation," dated December 15, 1995. NRC GL 95-10 refers to the Commission's Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors, published in the Federal Register, (58 FR 39132). The NRC Final Policy Statement 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 revisions to the seismic instrumentation, in accordance with 10 CFR 50.59, without requiring a License Amendment Request and adds flexibility to processing necessary changes.

TVA is planning to upgrade SON's seismic instrumentation starting in August 1999. The proposed upgrade includes l replacement of the current analog seismic recorders and central recording and playback units with a new digital i system.

III. SAFETY ANALYSIS SON's seismic instrumentation is designed to record data on seismic ground motion and provide data on the frequency and amplitude relationship of the response of major structures and systems. SON's system is designed for compliance with NRC Regulatory Guide 1.12, Revision 1, " Instrumentation for Earthquakes."

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,- , Currently, SON TSs provide the limiting conditions of operation (LCO) and surveillance requirements (SRs) to verify the operability of seismic instrumentation. The operability of the seismic instrumentation ensures that sufficient capability is available to promptly determine the magnitude of a seismic event and evaluates the response of those features important to safety. This capability is required to permit comparison of the measured response to that used in the design basis for the facility to determine if plant shutdown is required pursuant to Appendix "A" of 10 CFR Part 100. The current SRs include the conduct of periodic channel checks, channel calibrations, and channel functional tests. The TS Bases contains the basis for requiring seismic instrumentation.

TVA's proposed TS change is consistent with the guidance of NRC GL 95-10 and Standard TS (NUREG-1431). In NUREG-1431, there are no seismic instrumentation TS requirements because this instrumentation does not meet the criteria in 10 CFR 50.36. NRC GL 95-10 provides guidance for relocating selected instrumentation requirements that do not meet the criteria from 10 CFR 50.36. In addition, TVA evaluated SON's current seismic instrumentation TS requirements against the criteria of 10 CFR 50.36. The following discussions address the applicability of the 10 CFR 50.36 criteria to SON's TS for seismic instrumentation:

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.

Seismic instrumentation is used to record data for use in evaluating the effect of a seismic event. The instrumentation is not used to mitigate a design basis accident (DBA) or transient. SQN's seismic instrumentation is not installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal j degradation of the reactor coolant pressure boundary. I Accordingly, the SON seismic instrumentation does not j satisfy Criterion 1. l Criterion 2: A process variable, design feature or operating restriction that is an initial condition of a l Design Basis Accident (DBA) or Transient that either assumes the failure of or presents a challenge to the  ;

integrity of a fission product barrier.

SON's seismic instrumentation is not a process variable, design feature, or operating restriction that is an initial condition of a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. Therefore, the SQN seismic instrumentation does not satisfy Criterion 2.

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,. , 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.

SQN's seismic instrumentation is not assumed to function in  !

the safety analysis. The instrumentation is not a

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structure, system or component that is part of the primary I success path for accident mitigation. In addition, seismic  !

instrumentation does not 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. Accordingly, seismic instrumentation does not satisfy Criterion 3. 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.

Operational experience or probabilistic safety assessment l have not shown the SON seismic instrumentation to be i significant to the public health and safety. Therefore,  ;

the instrumentation does not satisfy Criterion 4.

The proposed relocation of the seismic instrumentation f requirements to the SQN TRM is acceptable based of the  :

above discussions. In accordance with 10 CFR 50.59, the  !

relocated requirements will be controlled to ensure changes i are not implemented that would reduce the functionality or testing of SQN's seismic instrumentation without prior NRC review.

IV. NO SIGNIFICANT HAEARDS CONSIDERATION DETERMINATION TVA has concluded that operation of SQN Units 1 and 2, in accordance with the proposed change to the TS, does not involve a significant hazards consideration. TVA's conclusion is based on its evaluation, in accordance with i 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 1 accident previously evaluated. I l

The proposed revision to the TS relocates the  !

requirements for SON seismic instrumentation without )

changing the current requirements. TVA does not '

consider the instrumentation to be the source of any accident; therefore, this administrative relocation of the requirements will not increase the possibility of El-3

I i an accident. The capability of the seismic

, ,- ,- instrumentation will continue to provide the same function for data collection. Changes to the i relocated requirements will be processed, in

! accordance with 10 CFR 50.59, to ensure the seismic instrumentation functions will be properly maintained.

Therefore, the proposed relocation of the seismic instrumentation requirements will not increase the consequences of an accident.

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

The SON seismic instrumentation is used to record data ,

for use in evaluating the effect of a seismic event.

This instrumentation is 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 SON's seismic instrumentation; 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 seismic instrumentation are unchanged by the proposed relocation of the requirements to the SON TRM. The function of the seismic instrumentation and SRs to ensure operability of the instrumentation 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 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 j may be released offsite, or a significant increase in

individual or cumulative occupational radiation exposure. l 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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