ML20236N243
| ML20236N243 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/05/1987 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| TAC-R00219, TAC-R219, NUDOCS 8708110420 | |
| Download: ML20236N243 (3) | |
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. TENNESSEE VALLEY AUTHORITY 5N 157B Lookout Place
/\\US 051987 I
U.S. Nuclear Regulatory Commission ATTN: Docum, Nit Control Desk l
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Washington S.C.
20555 Gentlemen:
In the Matter of
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Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT (SQN) - REQUEST FOR RELIEF FROM 10 CFR 50, APPENDIX J, 2-YEAR FREQUENCY REQUIREMENTS FOR TYPE B AND TYPE C TESTING -
UNIT 1 The purpose of this submittal is to request for SQN unit 1 a one-time exemption from the 2-year frequency requirement contained in Appendix J of 10 CFR 50, paragraphs III.D.2.(a) and III.D.3.
These paragraphs state that type B and type C tests "shall be performed during each reactor shutdown for refueling but in no case at intervals greater than 2 years." SQN's unit 1 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 type C tests were performed.
Since that time, unit I has remained in cold shutdown (mode 5) pending NRC approval for restart. The end of the 2-year test interval for type B and type C tests will expire in August 1987.
Because the unit 1 outage is expected to extend beyond August, SQN requests that the type B and type C tests be deferred until either June 30, 1<38, or before unit 1 enters mode 4.
SQN finds the bases for this relief request to be consistent with:
1.
NRC proposed amendments to 10 CFR 50, Appendix J (reference pages 9 l
and 10 of the October 1986 Draft Regulatory Document prepared under Task MS 021-5).
This proposed amendment supplements the 2-year type B and type C test schedule with the following sentence:
"If the 2-year interval ends while primary containment integrity is not 1
required, the test interval may be extended provided all deferred testing is successfully completed before containment integrity is required in the plant."
2.
SQN technical specifications 3.6.1.1 and 3.6.1.2.
These technical specifications require that primary containment integrity be maintained only when in modes 1, 2, 3, and 4.
It is while in these modes that type B and type C tests are required for maintaining containment integrity.
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Ob An Equal Opportunity Employer
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U.S. Nuclear Regulatory Commission AUS 051987 l
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10 CFR 50.12 specific exemptions. Relief from testing is warranted I
=under 10 CFR-50.12(2)(iii) because compliance with the 2-year test.
1 requirement would " result in undue hardship and costs that are significantly in excess of those contemplated when the regulation was adopted." SQN also finds 10 CFR 50.12(2)(v) to be applicable
-because.this exemption would " provide only temporary relief from the I
applicable' regulation."
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l In addition to the_above bases, SQN is providing the following environmental assessment and finding of no significant impact.
3 ENVIRONMENTAL ASSESSMENT i
Identification of Proposed Action:
i SQN's request for a one-time' exemption from the'2-year type B and type C l
test frequency for unit 1 will defer testing until either June 30, 1988, or before unit.1 restart. Appendix J requires type B-and type C~ tests be performed during.each reactor shutdown ~for' refueling but in no case at intervals greater than 2 years. The need for exemption. arose because.of the extended l unit-1 outage: time,(over'2 years) necessary to address safety. concerns at SQN. All unit 1 type B and type C tests will be performed before unit 1 enters mode 4.
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The Need for the Proposed Action:
The proposed one-time exemption is needed for unit 1 because the type B j
and type C-tests impose undue hardships and costs with no compensating l
increase in the level of quality or safety.
Environmental' Impact'of the Proposed Action:
The proposed one-time exemption is from the 2-year frequency requirement for performance of type'B and type C tests under Appendix J.
The need for these tests is to ensure primary containment integrity is maintained while the plant is operating in modes 1, 2, 3, or 4.
SQN's technical specifications do not require primary containment integrity to be maintained during cold shutdown' conditions (mode 5).
These tests will be performed before unit i enters mode 4; therefore, the one-time exemption does not involve a significant environmental impact.
i Alternative to the Proposed Action:
1 The alternative to the proposed one-time exemption would be to perform the type B and type C tests in accordance with the 2-year test frequency l
of' Appendix J.
This alternative to the proposed exemption would have no l
environmental impact. There are, however, no apparent benefits to' l
testing during extended outages.
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'.S. Nuclear Regulatory Commission
/ UB 051987 U
Alterr.ative Use of ' Resources :-
i This one-t'ime exemption'does not involve the use of e es not previously considered in connection with the " Final
- nmental Statement Related_to the Operation of Sequoyah Nuclea.
' ant, Units 1 and 2" dated July 1974.
Finding of No Significant Impact:
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'SQN finds no basis for preparing an environmental' impact statement for the proposed one-time exemption. Based on the above environmental 4
assessment, we conclude that the proposed exemption will not have a significant ef fect on the quality of the human environment.
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'SQN requests a response to this relief request before October 1, 1987, in order.to support scheduling of unit 1-test activities.
If you have any' questions-regarding this subject, please telephone D. V. Goodin at'(615) 870-7462.-
Very truly yours, TENNESSEE VALLEY AUTHORITY
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R. Gridley, irector Nuclear Safety and Licensing cc'(Enclosure):
Mr.1G. G. Zech. Assistant Director for Inspection Programs l
Office of Special Projects U.S'. Nuclear Regulatory Commission 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 Mr.
J.'A.
Zwolinski, Assistant Director for Projects' Division of TVA Projects Office of Special Projects
- U'S. Nuclear Regulatory Commission 4350 East West Highway EWW 322 Bethesda, Maryland-20814 l
Sequoyah Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379
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