ML20247R170

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Requests Temporary Waiver for Compliance W/Surveillance Requirement 4.4.11.a to Ensure Avilability of Flow Paths for Venting Noncondensibles or Steam from Reactor Vessel Head Until Emergency Tech Spec Amend Can Be Processed
ML20247R170
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 07/28/1989
From:
TENNESSEE VALLEY AUTHORITY
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 8908070377
Download: ML20247R170 (2)


Text

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TENNESSEE VALLEY AUTHORITY 5N 157B Lookout Place July 28, 1989 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.

20555 Gentlemen:

In the Matter of

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Docket Nos. 50-327 Tennessee Valley Authority

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50-328

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SEQUOYAH NUCLEAR PLANT (SQN) - WAIVER OF COMPLIANCE FOR SURVEILLANCE' REQUIREMENT (SR) 4.4.11.a l

i As discussed with NRC on July 28, 1989, it has been determined that SQN Units 1 and 2 are not in compliance with SR 4.4.11.a because the upstream manual isolation valves for the reactor coolant system (RCS) head vent valves have not been verified to be locked open. This technical specification (TS) was recently icsued while both units were at power. Verification.that these valves are locked cannot be performed with the units at power because of their proximity to th: reactor vessel head and the high radiation levels in that area.

The intent of SR 4.4.11.a is to ensure the availability of flow paths for venting noncondensibles or steam from the reactor vessel head in Modes 1, 2, and 3.

The verification that the upstream mamtal isolation valve is open ensures the availability of the flow paths. The verification that the valves are locked provides additional assurance that the flow paths remain available.

TVA has verified that the valves were open during the last refueling outage of each unit. SQN's configuration control process provides assurance that the J

valves have not been closed. Additional assurance can be drawn from the location of these valves and the access controls to lower containment.

To prevent the forced shutdown of SQN Units 1 and 2, TVA is preparing an emergency TS change to revise SR 4.4.11.a.

This revision will defer verification that these valves are locked open until the next Mode 5 outage of sufficient duration on each unit to perform this verification.

TVA has taken action to coniply with action statement a.

However, TVA believes i

it is prudent to make the head vent systems available by restoring power.

l TVA, therefore, requests a temporary waiver of compliance for SR 4.4.11.a for SQN Units 1 and 2 until the emergency TS change can be processed. The 8908070377 890728

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July 28, 1989 emergency change will be submitted by' August 1, 1989. TVA is also requesting this time to review' valve test data to determine if additional evidence is available to' confirm the configuration log status..In-the event:this data is

'not available, TVA is evaluating the' feasibility and prudency of' conducting a test to verify flow at power. This information will be included in the emergency TS change request.

Very truly yours, TENNESSEE VALLEY AUTHORITY'

/f huner uclear VI ensing d

Reg lhtory Affairs cc:

Ms. S. C. Black, Assistant Director for Projects

~TVA Projects Division.

U.S. Nuclear Regulatory Commission One White Flint', North 11555 Rockville Pike Rockville, Maryland 20852 Mr. B. A. Wilson, Assistant Director for Inspection Programs TVA Projects Division U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323 NRC Resident Inspector Sequoyah Nuclear Plant 2600 Igou Ferry Road Soddy Daisy, Tennessee 37379

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