ML20003G147
| ML20003G147 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/23/1981 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8104280377 | |
| Download: ML20003G147 (2) | |
Text
'
t TENNESSEE VALLEY AUTHORITY CH ATTANOOGA. TENNESSEE 37401 ' '
400 Chestnut Street Tower II 9
s April 23, 1981 Dimotor of Nuclear Remotor Regulation Attention:
Mr*. A. Johwencer, Chief Licensing Branch No. 2 Division of Licensing U.S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Schwencer:
In the Matter of the Application of
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Docket No. 50-328 Tennessee Valley Authority
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The proof and review copy of the Sequoyah Nuclear Plant unit 2 technical specifications contains a new requirement that we believe is unnecessary. Surveillance requirement 4.6.1 3.b states:
Prior to establishing CONTAINMEE INTEGRITY if opened when CONTAINME INTEGRITY was not mquired, and at least once every six months, by2 conducting an overall air look leakage test at Pa,12 lb/in a, and by verifying that the overall air look leakage mte is within its limit.
Containment integrity is not mquired in mode 5, cold. shutdown. This new mquirement would mquire us to perfrom a test before entering mode 4 if the air look was used for entry in mode 5.
The test would be requimd every time we entered mode 5.
The containment would have to be cleared of esployees during performance of this test or they would be required to remain inside containment during the test and until the plant reached mode 4.
Employee entry is mquired in modes 4 ~and 3 during heatup to perform surveillance tests such as the check valve leakage measurements.
Entry is allowed in modes 1-4 as long as the door seals are checked in socordance with surveillance requim ment 4.6.1 3.a.
A
-81043so 379 An Equal Opportunity Employer
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2' Director of Nuclear Reactor Regulation
-April 23, 1981 We believe that the additional hll; pressure-test. required by the new
. specification provides no additional assurances that the air look is
>1eak tight..The test is time consuming.and difficult to ooordinate.
We believe that as long as the "6-month" hll pressure test is still--
valid, i.e., no maintenance has been performed on the door,.and _.
- surveillance requirement 4.6.13.a is performed before entering mode 4, the air look can be considered operable. Surveillance requirement 4.6.1 3.b should be rewritten to read:
At least once,every six months,-bg conducting an overall air look leakage test at Pa,12 lb/in a, and by verifying that the overall air look leakage rate is within its limit.
Very truly yours, TENNESSEE VALLEY AUTHORITY
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L. M. Mills,-
er Nuclear Regulation and Safety Sworn to and subsorfbed before me
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this Mday of (2/124/9 1981
(){La ie MD -
NotarfPublio 77 /'
My Comunission Expires 4/ /22s M
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