ML20151E504
| ML20151E504 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 07/14/1988 |
| From: | Partlow J NRC OFFICE OF SPECIAL PROJECTS |
| To: | TENNESSEE VALLEY AUTHORITY |
| Shared Package | |
| ML20151E506 | List: |
| References | |
| NUDOCS 8807260098 | |
| Download: ML20151E504 (5) | |
Text
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of TENNESSEE VALLEY AUTHORITY
)
Docket No. 50-327
)
'(SequoyahNuclearPlant,ynit1)
)
EXEMPTION l
I.
The Tennessee Valley Authority (the licensee) is the holder of Facility
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Operating License No. DPR-77 which authorizes operation of the Sequcyah Nuclear Plant (SQN), Unit 1.
This license provides that, among other things, the facility is subject to all rules, regulations, and orders of the Consission now cr hereaf ter in effect.
The Sequoyah Unit 1 facility is a pressurized water reactor located at the licensee's site in Hamilton County, Tennessee.
II.
i Sections III.D.2(a) and III.D.3 of Appendix J to 10 CFR Part 50, require Type B and C leakage tests on contaircent penetrations and isolation valves, respectively, at intervals in no case greater than two years.
8807260098 880714 T PDR ADOCK 05000327f PNUig_
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. Sequoyah Unit I was shut down for refueling on August 22, 1985. During refueling from late August 1985 to late November 1985 all Unit 1 Type B and C tests were performed.
Since that time, Unit I has remained in cold shutdown (Mode 5).
The end of the,two year test interval for Type B and C tests expired in late August to November 1987.
Because the Unit 1 outage had extended past August 1987, the licensee in its letter dated August 5, 1987, requested that the Type B and C tests be deferred on a one-time basis until before Unit 1 enters Mode 4 in its return to power from this outage.
The licensee contended that an exemption from the Type B and C test frequency requirements is warranted on the following bases:
1.
NRC proposed amendments to 10 CFR Part 50, Appendix J (reference pages 9 and 10 of the October 1986 Draft Regulatory Document prepared under Task MS 021-5) would supplement the two-year Type B and C test schedule with the following sentence:
"If the two-year interval ends while primary containmentintegrityisnotrequired,thetestintervalmaybeextendg i
provided all deferred testing is successfully completed before containment integrity is required in the plant."
2.
SQN Unit 1 Technical Specifications 3.6.1.1 and 3.6.1.2 require that primary containment integrity be maintained only when in Modes 1, 2, 3 and 4.
In these modes, Type B and C tests are required for maintaining containment integrity.
m
. 3.
Relief from testing is warranted under 10 CFR 50.12(a)(2)(iii) because compliance with the two-year test requirement would "result in undue hardship and costs that are significantly in excess of those contemplated l
when the regulation was adopted." The licensee also considers 10 CFR l
50.12(a)(2)(v) to be applicable because this exemption would "provide only temporary rel ? f from the applicable regulation."
The staff has considered the Appendix J exen.ption request from the Type B and C tests and has concluded that it is justified en a one-tiae basis since Unit I has been in Mode 5 (cold shutdown) for this period and containment integrity is not required when the reactor is in the cold shutdown condition.
Furthermore, prior to entering Pcde 4 (Heatup at Power), the licensee will conduct the Type B and C leakage tests in order to ensure containment integrity. Accordingly, 1,he staff concludes that this Appendix J exemption is justified.
111.
The Commission has evaluated the requested exemption and determined that the application of the regtilations in these particular circumstances is not necessary to achieve the underlying purpose of the rule in that the licensee's proposed Type B and C testing schedule meets the underlying intent of Appendix J which is to provide containment integrity during reactor operating modes when the containment is required to mitigate the consequences of a Design Basis Accident.
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. Because the plant has remained in Mode 5 since August 1987 and primary containment integrity has not been required, conducting the Type B and C tests at that time was not necessary to achieve the underlying purpose of the rule which is to demodstrate that the containnent has integrity for operatio' (i.e., reactor Modes 1 to 4).
Such integrity will be assured through conducting the Type B and C tests prior to entry into Modes 1 to 4.
Therefore, application of the rule in these particular circumstances is not necessary to achieve the underlying purpose of the rule and the proposed exemption meets 10 CFR 50.12(a)(2n11).
IV.
Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12, the exemption is authorized by law, will not present an undue risk to public health and safety, and is consistent with the common defense and security. The Commission further determines that special circumstances provided in 10 CFR 50.12(a)(2)(ii) justify granting the exemption.
The Commission hereby grants a one-time exemption from the schedular i
requirements of Appendix J to 10 CFR Part 50. Paragraphs III.D.2.(a) and III.D.3, to the licensee for operation of the Sequoyah Nuclear Plant, Unit 1, based on the condition that the required testing be conducted prior to entry into Pode 4.
.e-
. Pursuant to 10 CFR 51.32, the Commission has determined that the issuance of this exemption will not have a significant adverse impact on the cuality of the human environment (53 FR 23706, June 23, 1988),.
t This exemption is effective upon issuance, Dated at Rockville, Maryland, this lL{dbday of $hd-g
, 1988, FOR THE NUCLEAR REGULATORY COMMISSION wm Jame : G. Partlow, Director Offi:e of Special Projects
July 14, 1986 Docket No. 50-327 Distribution i
Dockot File EJordan BCliaw 2NCR POR h JPartlow FMcCoy Mr. S. A. White Local PDR ACRS (10)
FMiraglia Senior Vice President, Nuclear PowerJPartlow GPA/PA GPA/CA Tennessee Valley Authority JAxelrad SQN Rdg.
ARM /LFMB 6N 38A Lookout Place SPlack Projects Rdg. OGC 11C1 Market Street MSims JRutberg TRotella Chattanooga, Tennessee 37402-2801 J00nohew TVA-Rockville SRichardson TBarnhart(4)
Dear Mr. White:
SUBJECT:
EXEMPTION FROM 10 CFR Part 50, APPENDIX J, TYPE B AND C LEAK PATE TESTING (TAC R00219) - SEQUOYAH NUCLEAR PLANT, UNIT i
In its letter dated August 5, 1987, the Tennessee Valley Authority (TVA) stated that Unit I was shut dcwn on August 22, 1985, and, in August to November 1985, the Type B and C tests were perfortned. Since then, Unit 1 has remained in cold shutdown and the two-year test interval for the Type B and C tests expired in August to November 1987. Because Unit I ha,s remained in cold shutdown (Mode 5),
where containment integrity has not been required, since August 1987, TVA requested that the Type B and C tests be deferred for Unit 1 until before the unit enters Mode 4 when containment integrity is required.
The Comission has issued the enclosed one-time sctedular exemption for Unit 1 from the two-year frequency requirement for Type B and C testing in Appendix J of 10 CFR Part 50, paragraphs III.D.2.(a) and 111.D.3. These paragraphs state i
that the tests shall be performed during each reactor shutdown for refue' ling but j
in no case at intervals greater than 2 ycars. These tests will be perfortned before the containment is required to be operable during the return to power frem this extended outage.
Sincerely, original Signed by Suzanne Black, Assistant Director for Projects TVA Project Division Office of Special Projects
Enclosure:
Exemption cc w/ enclosure:
See next page k*
- SEE PREVIOUS CONCURRENCE OSP:TVA:PM*
OSP:TVA:A/LA*
OGC*
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TVA:A/DIR*
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i Mr. S. A. White Tennessee Valley Authority Sequoyah Nuclear Plant CC:
General Counsel Regional Administrator, Region II Tennessee Valley Authority U.S. Nuclear Regulatory Comission 400 West Summit Hill Drive 101 Marietta Street, N.W.
E11 B33 Atlanta, Georgia 30223 Knoxville. Tennessee 37902.
Resident Inspector /Sequoyah NP Mr. R. L. Gridley c/o U.S. Nuclear Regulatory Commission Tennessee Valley Authority
?600 Igou Ferry Road EN 1578 Lookout Place Soddy Daisy, Tennessee 37379 Chattanooga, Tennessee 37402-2801 Mr. H. L. Abercrombie Mr. Michael H. Mobley, Director Tennessee Valley Authority Division of Radiolchical Health Sequoyah Nuclear Plant T.E.R.R.A. Building, 6th Floor P.O. Box 2000 150 9th Avenue North Nashville, Tennessee 37219-5404 Soddy Da'isy, Tennessee 37379 Mr. M. R. Harding Dr. Henry Myers, Science Advisor i
Tennessee Valley Authority comittee on Interior Sequoyah Nuclear Plant and Insular Affairs P.O. Box 2000 U.S. House of Representatives Soddy Daisy, Tennessee 37379 Washington, D.C.
20515 Mr. D. L. Williams Tennessee Valley Authority 400 West Sumit Hill Drive W10 385 Knoxville, Tennessee 37902 County Judge Hamilton County Courthouse Chattanooga, Tennessee 37402 l
T e-
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
TENNESSEE VALLEY AUTHORITY
)
Docket No. 50-327
)
(Sequoyah Nuclear Plant, ynit 1)
)
3 EXEMPTION I.
The Tennessee Valley Authority (the licensee) is the holder of Facility Operating License No. OPR-77 which authorizes operation of the Sequcyah Nuclear Plant (SQN), Unit 1.
This license provides that, among other things, the facility is subject to all rules, regulations, and orders of the Concission now l
cr hereaf ter in effect.
The Sequoyah Unit 1 facility is a pressurized water reactor located at the licensee's site in Hamilton County, Tennessee.
II.
Sections III.D.2(a) and III.D.3 of Appendix J to 10 CFR Part 50, require Type B and C leakage tests on containment penetrations and isolation valves, respectively, at intervals in no case greater than two years.
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)
t Sequoyah Unit I was shut down for refueling on August 22, 1985. During refueling from late August 1985 to late November 1985 all Unit 1 Type B and C tests were performed.
Since that time, Unit I has remained in cold shutdown (Mode 5). The end of the,two year test interval for Type 8 and C tests expired in late August to November 1987.
Because the Unit 1 outage had extended past August 1987, the licensee in its letter dated August 5, 1987, requested that the Type B and C tests be deferred on a one-time basis until before Unit 1 enters Mode 4 in its return to power from this outage.
The licensee contended that an exemption from the Type B and C test frequency requirements is warranted on the following bases:
j 1.
NRC proposed amendments to 10 CFR Part 50, Appendix J (reference pages 9 and 10 of the October 1986 Draft Regulatory Document prepared under Task MS 021-5) would supplement the two-year Type B and C test schedule with the following sentence:
"If the two-year interval ends while primary containment integrity is not required, the test interval may be extended provided all deferred testing is successfully completed before containment integrity is required in the plant."
2.
SQN Unit 1 Technical Specifications 3.6.1.1 and 3.6.1.2 require that primary containment integrity be maintained only when in Modes 1, 2, 3 and 4.
In these modes, Type B and C tests are required for maintaining containment integrity.
s e l 1
3.
Relief from testing is warranted under 10 CFR 50.12(a)(2)(iii) because compliance with the two-year test reouirement would "result in undue l
hardship and costs that are significantly in excess of those' contemplated when the regulation was adopted." The licensee also considers J.FR 50.12(a)(2)(v) to be applicable because this exemption would "provide only temporary relief from the opplicable regulation."
The staff has considered the Appendix'J exemption request from the Type B and C tests and has concluded that it is justified en a one-time basis since Unit 1 has been in Mode 5 (cold shutdown) for this period and containment integrity is not required when the reactor is in the cold shutdown condition.
Furthermore, prior to entering Mede 4 (Heatup at Power), the licensee will conduct the Type B and C leakage tests in order to ensure containment integrity. Accordingly, the staff concludes that this Appendix J exemption is justified.
III.
The Comission has evaluated the requested exemption and determined that the application of the regulations in these particular circumstances is not necessary to achieve the underlying purpose of the rule in that the licensee's proposed Type B and C testing schedule meets the underlying intent of Appendix J which is to provide containment integrity during reactor operating modes when the containment is required to mitigate the consequences of a Design Basis Accident.
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a Because the plant has remained in Mode 5 since August 1987 and primary containment integrity has not been required, conducting the Type B and C tests at that time was not necessary to achieve the underlying purpose of the rule which is to demodstrate that the containnent has integrity for operation (i.e., reactor Modes 1 to 4).
Such integrity will be assured through conducting the Type B and C tests prior to entry into Modes 1 to 4.
Therefore, application of the rule in these.particular circumstances is not necessary to achieve the underlying purpose of the rule and the proposed exemption meets 10 CFR 50.12(a)(2)(ii).
IV.
Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12, the exemption is authorized by law, will not present an undue risk to public health and safety, and is consistent with the common defense and security. The Commission further determines that special circumstances provided in 10 CFR 50.12(a)(2)(ii) justify granting the exemption.
The Commission hereby grants a one-tine exemption from the schedular requirements of Appendix J to 10 CFR Part 50, Paragraphs III.D.2.(a) and III.D.3, to the licensee for operation of the Sequoyah Nuclear Plant, Unit 1, based on the condition that the required testing be conducted prior to entry into Mode 4
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t Pursuant to 10 CFR 51.32, the Comission has determined that the issuance of this exemption will not have a significant adverse impact on the cuality of the human environment (53 FR 23706, June 23,1988).-
i e
This exemption is effective upon issuance.
i O
Dated at Rockville, Maryland, this ld day of 39%
1988.
FORTHkNUCLEARREGULATORYCOMMISSION J
ws Jame 5 G. Partlow, Director Offi:e of Special Projects e
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'bocketNo.30-327 Distribution i
Docket File EJordan BCliaw NCR PDR JPartlow FPcCoy Mr. S. A. White A l3calMPOR^
ACRS (10)
FMiraglia Senior Vice President, Nuclear PowerJPartlow GPA/PA GPA/CA Tennessee Valley Authority JAxelrad SQN Rdg.
ARM /LFMB 6N 38A Lookout Place SPlack Projects Rdg. OGC 1101 Market Street MSims JRutberg TRotella Chattanooga, Tenriessee 37402-2801 JDonohew TVA-Rockville SRichardson TBarnhart(4)
Dear Mr. White:
SUBJECT:
EXEMPTION FROM 10 CFR Part 50, APPENDIX J, TYPE B AND C LEAK RATE TESTING (TAC R00219) - SEQUOYAH NUCLEAR PLANT, UNIT 1 In its letter dated August 5, 1987, the Tennessee Valley Authority (TVA) stated
)
that Unit I was shut dcwn on August 22, 1985, and, in August to November 1985, the Type B and C tests were performed.
Since then, Unit I has remained in cold shutdown and the two-year test interval for the Type B and C tests expired in August to November 1987.
Because Unit I ha,s remained in cold shutdown (Mode 5),
)
where containment integrity has not been required, since August 1987. TVA requested that the Type B and C tests be deferred for Unit I until before the unit enters Mode 4 when contair. ment integrity is required.
The Comission has issued the enclosed one-time schedular exemption for Unit 1 from the two-year frequency requirement for Type B and C testing in Appendix J of 10 CFR Part 50, paragraphs III.D.2.(a) and III.D.3. These paragraphs state that the tests shall be performed during each reactor shutdown for refueling but in no case at intervals greater than 2 years. These tests will be performed before the containment is r: quired to be operable during the return to power frem this extended outage.
Sincerely, original Signed by Suzanne Black, Assistant Director for Projects TVA Project Division Office of Special Projects
Enclosure:
Exemption cc w/ enclosure:
See next page hk
- SEE PREVIOUS CONCURRENCE OSP:TVA:PM*
OSP:TVA:A/LA*
OGC*
TVA:AD/P*
TVA:A/DIR*
JDonohew:dw MSimi Stewis SBlack SRichardson 6/28/E8 6/28/CR 6/24/88 6/29/88 6/29/88
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//,//. /88 7/A/88 W
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Mr. S. A. White Tennessee Valley Authority Sequcyah Nuclear Plant cc:
General Counsel Regional Administrator, Region Il Tennessee Valley Authority U.S. Nuclear Regulatory Commission 400 West Summit Hill Drive 101 Marietta Street, N.W.
E11 B33 Atlanta, Georgia 30323 Knoxville, Tennessee 37902 Resident Inspector /Sequoyah NP Mr. R. L. Gridley c/o U.S. Nuclear Regulatory Commission Tennessee Valley Authority 7600 Igou Ferry Road Eh 1573 Lookout Place Seddy Daisy, Tennessee 37379 Chattanooga, Tennessee 37402-2801
.. Abercrombie Mr. Michael H. Mobley, Director Mr. H Tennessee Valley Authority Division of Radiolchical Health Sequoyah Nuclear Plant T.E.R.R.A. Building, 6th Floor P.O. Box 2000 150 9th Avenue North Soddy Daisy, Tennessee 37379 Nashville, Tennessee 37219-5404 Mr. M. R. Harding Dr. Henry Myers, Science Advisor Tennessee Valley Authority Committee on Interior Sequoyah Nuclear Plant and Insular Affairs P.O. Box 2000 U.S. House of Representatives Soddy Daisy, Tennessee 37379 Washington, D.C.
20515 Mr. D. L. Williams Tennessee Valley Authority 400 West Summit Hill Drive W10 B85 Knoxville, Tennessee 37902 County Judge Hamilton County Courthouse Chattanooga, Tennessee 37402
t.
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
TENNESSEE VALLEY AUTHORITY
)
Docket No. 50-327
)
(Sequoyah Nuclear Plant, ynit 1)
)
EXEMPTION I.
The Tennessee Valley Authority (the licensee) is the holder of Facility Operating License No. OPR-77 which authorizes operation of the Sequoyah Nuclear Plant (SQN), Unit 1.
This license provides that, among other things, the facility is subject to all rules, regulations, and orders of the Comission now cr hereafter in effect.
The Sequoyah Unit 1 facility is a pressurized water reactor located at the licensee's site in Hamilton County, Tennessee.
II.
Sections III.D.2(a) and 111.D.3 of Appendix J to 10 CFR Part 50, require Type B and C leakage tests on containment penetrations and isolation vahes, respectively, at intervals in no case greater than two years.
,A gr
i Sequoyah Unit I was shut down for refueling on August 22, 1985. During refueling from late August 1985 to late November 1985 all Unit 1 Type B and C tests were performed.
Since that time, Unit 1 has remained in cold shutdown (Mode 5).
The end of the,two year test interval for Type B and C tests expired in late August to November 1987.
Because the Unit 1 outage had extended past August 1987, the licensee in its letter dated August 5, 1987, requested that the Type 8 and C tests be deferred on a one-time basis until before Unit 1 enters Mode 4 in its return to power from this outage.
The
'.ensee contended that an exemption from the Type B and C test frequencyrequirementsiswYrrantedonthefollowingbases:
1.
NRC proposed amendments to 10 CFR Part 50, Appendix J (reference pages 9 and 10 of the October 1986 Draft Regulatory Document prepared under Task MS 021-5) would supplement the two-year Type B and C test schedule with the following sentence:
"If the two-year interval ends while primary containment integrity is not required, the test interval may be extended provided all deferred testing is successfully completed before containment integrity is required in the plant."
2.
SQN Unit 1 Technical Specifications 3.6.1.1 and 3.6.1.2 require that primary containment integrity be maintained only when in Modes 1, 2, 3 and 4.
In these modes, Type B and C tests are required for maintaining containment integrity.
l I 3.
Relief from testing is warranted under 10 CFR 50.12(a)(2)(iii) because compliance with the two-year test recuirement would "result in undue hardship and costs that are significantly in excess of those contemplated when the regulation was adopted." The licensee also considers 10 CFR 50.12(a)(2)(v) to be applicable because this exemption would "provide only temporary relief from the applicable regulation."
The staff has considered the Appendix'J exemption request from the Type B and C tests and has concluded that it is justified on a one-time basis since linit 1 has been in Mode 5 (cold shutdown) for this period and containment integrity is not required when the reactor is in the cold shutdown condition.
Furthermore, prior to entering Fede 4 (Haatup at Power), the licensee will conduct the Type B and C leakage tests in order to ensure containment integrity. Accordingly, the staff concludes that this Appendix J exemption is justified.
III.
The Commission has evaluated the requested exemption and determined that the application of the regulations in these particular circumstances is not necessary to r.chieve the underlying purpose of the rule in that the licensee's proposed Type B and C testing schedule meets the underlying intent of Appendix J which is to provide containment integrity during reactor operating modes when the containment is required to mitigate the consequences of a Design Basis Accident.
a i
, 1 Because the plant has remained in Mode 5 since August 1987 and primary containment integrity has not been required, conducting the Type B and C i
tests at that time was not necessary to achieve ther underlying purpose of j
the rule which is to demonstrate that the containrent has integrity for operation (i.e., reactor Modes 1 to 4).
Such integrity will be assured through conducting the Type B and C tests prior to entry into Modes 1 to 4.
f Therefore, application of the rule in these,particular circumstances is not l
necessary to achieve the underlying purpose of the rule and the proposed exemption meets 10 CFR 50.12(a)(2)(ii).
IV.
Accordingly, the Comission has determined that, pursuant to 10 CFR 50.12, the exemption is authorized by law, will not present an undue risk to public health and safety, and is consistent with the common defense and security.
The Comission further determines that special circumstances provided in 10 CFR 50.12(a)(2)(ii) justify granting the exemption.
The Comission hereby grants a one-time exemption from the schedular requirements of Appentlix J to 10 CFR Part 50, Paragraphs III.D.2.(a) and III.D.3, to the licensee for operation of the Sequoyah Nuclear Plant, Unit 1, based on the condition that the required testing be conducted prior to entry into Pode 4.
'd
, g '. ' -
s Pursuant to 10 CFR 51.32, the Coninission has determined that.he issuance of this exemption will not have a significant adverse impact.. the oJality of the human environment (53 FR 23706, June 23, 1988).
t This exemption is effective upon issuance.
Dated at Rackville Maryland, this ld day of 39%
, 1988.
FOR.THSNUCLEARPEGULATORYCOMMISSION ws Jame i G. Partlow Director Offi:e of Special Projects l
1 7
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