ML19224D799
| ML19224D799 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 07/11/1979 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 7907170058 | |
| Download: ML19224D799 (3) | |
Text
TENNESSEE VALLEY AU1 HORITY CH ATT ANCOG A. TENNESSEE 27401 400 Chestnut Street Tower II July 11, 1979 D! rector of Nuclear Feactor Regulation Attention:
Mr. Thomas A. Ippolito, Chief Branch No. 3 Division of Operating Reactors U.S. Nuclear Reguictory Commission Washington, DC 20555
Dear Mr. Ippolite:
In the Matter of ehe
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Docket Nos. 50-259 Tennessee Valley Authority
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50-260 50-296 Pursuant to 10 CFR 50 Section 50.55a(g), Browns Ferry Nuclear Plant units 1, 2, and 3 are subjected to inservice inspection and testing in accordance with the requirements of Section XI of the ASHE Boller and Pressure Vessel Code. Strict compliance with Federcl regulations results in programs of inservice inspection and testing which are unwieldy with respect to development, review, and implementation.
This situation imposes a burden on both TVA and NRC and results in unnecessary delays in progrem development by TVA and review by NRC.
Enclosed is a proposal which u. 1 amend this situation by allowing TVA to conduct the programs at Browns Ferry us'.ng concurrent start dates for all three units.
All details of the proposal and justification are cc
'a the enclosure.
Expeditious approval of this proposal by NRC will result in a more judicious use of time by both TVA nnd NRC.
This has the potential for improving safety by allowing valuatte manpower to be utilized in more urgent matters.
This proposal helps to create a condition of standardization among the three units of the Browns Ferry Nuclear 21 ant, a condition which NEC has considered advrntagecus.
If we can be of any assistance to your staff in their review of this proposal, please get in touch with us.
Very truly yours, TENNESSEE VALLEY AUTEORITY m_ /
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g L. M. Mills, Manager Nuclear Regulation and Safety ly Enclosure
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An E;ual CCoortumty Employer
ENCLOSURE BROWNS FERRY NUCLEAR PLANT UNITS 1-3 DOCKET NOS. 50-259, 50-260, AND 50-296 CONCURRENT CYCLES OF IhSERVICE INSPECYIONS AND TESTING - COMPLIANCE WITH 10 CFR 50.55a(g)
Proposal Pursuant to 10 CFR 50 Section 50.55a(g), inservice inspection and testing is performed at the three-unit Browns Ferry Nuclear Plant in accordance with Section XI of the ASME Boiler and Pressure Vessel Code.
Strict compliance with 10 CFR 50.55a(g) requires that each unit follow its own sen-ate schedule of 40-=onth and 20-month inspection periods.
It is proposed to perform future inservice inspection and testing at Browns Ferry according to a program of concurrent periods for the enree units, i.e.,
have all three units begin 40-month and 20-month inspection periods on the same date.
It is proposed to have all three units begin the next 40-month and 20-month period on January 1, 1980.
The date for start of the next 40-month periods for Browns Ferry units 1, 2, and 3 are June 1, 1979, December 15, 1979, and July 1, 1980, respectively.
The concurrent cycle-start date of Jan tary 1,1980, is proposed because it involves approximately equal and cpposite shif ts in time for the start dates of units 1 and 2 and a negligible sh'f t in that for unit 2.
In addition, 1c is prcposed to submit a single program description to describe each of the proposed programs of inservice inspection, inservice pump and valve testing, and hydrostatic pressure testing for all three units.
Differences among t he three units would be addressed in the program description.
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. Justitication 1.
There would be no decrease in the assured level of safety if the dates for start of the inspection and test periods were shif ted at this time.
All inspection and tests to be perf ormed over a 40- or 20-month period would be performed as required.
2.
All three units are basically identical in design with only minor differences in installed equipment. Consequently, a single document could be used to describe a program proposed for all three units.
Reasons 1.
Although unlikely, under the present requirements of 10 CFR 50.55a(g)(4),
a potential exists for each unit to be required to per'.orm tests and innpections in accordance with different ASME code edition sad addenda.
It is, however, quite likely that one of the units would be equired to follow an edition and addenda dif ferent f rom the other two.
Such an arrangement would cause complications in program development and impler.entation. Review of the program by the NEC staf f would also be made more complicated creating a potential 'or delay in completion of NRC review. Any significant delay in completion of program review and issuance of approval creates problems for both TVA and NRC.
2.
Pursuant to 10 CFR 50 Section 50.55a(g)(4) the inservice inspectfon and testing programs must comply with the ASME code edition and addenda in effect 6 months before the start of each 40-month or 20-nor.ch inspection A
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period. Consequently, these programs are noc finalized until this time.
Therefore, even provided that all three units are to comply with the same code edition and addenda, three separate and distinct programs will exist, at least in theory. Although act a true triplication of effort, this regulation does result in some additional work, both by TVA in program development and implementation and by NRC in review of the program.
Strict compliance with tae regulation requires that a
separate submittal be ende for each unit for each of the three program descriptions.
Summary The requirements of 10 CFR 50 Section 50.55a(g)(4) are inherently complicated and inefficient to t<me extent when applied to a multiple-unit facility. We believe that strict co=pliance with these regulations yields no increase in the assured level of safety of the facility but rather that a potencial exists for safety to be compromised because of the numerous complications involved.
These complications can be eliminated and the efficiency of inservice inspection and *.esting in reased by implementing the program outlined in this proposal.
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