ML19347E841

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Reiterates Purpose & Scope of Mark I Program,Clarifies NRC Order & 810113 Forwarding Ltr.Mark I Program Defines Design Basis Loads Appropriate for Anticipated Life of Each BWR Mark I Facility
ML19347E841
Person / Time
Site: FitzPatrick 
Issue date: 04/30/1981
From: Eisenhut D
Office of Nuclear Reactor Regulation
To: Berry G
POWER AUTHORITY OF THE STATE OF NEW YORK (NEW YORK
References
NUDOCS 8105140017
Download: ML19347E841 (3)


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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

.g a E WASHfNGTON D. C. 20555 N

April 30, 1981

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s Mr. George T. Berry

'5 MAY 121981* y President and Chief Operating v.a.g,7 q Officer B

Power Authority of the State 7

of New York W

f 10 Columbus Circle New York, New York 10019

SUBJECT:

IMPLEMENTATION OF THE MARK I CONTAINMENT LONG-TERM PROGRAM

Reference:

Letter from J. P. Bayne, PASNY to H. R. Denton, USNRC, dated February 27, 1981

Subject:

Schedule - Extension Request / Hearing Request The purpose of this letter is to reiterate 'the purpose and scope of the Mark I program, to provide clarification of the NRC Order and forwarding letter of January 13, 1981, and to respond to your letter referenced above.

As you are aware, the purpose of the Mark I containment long-term program is to define the aesign basis loads that are appropriate for the anticipated life of each BWR Mark I facility and to restore the original intended design safety margins for each Mark I containment system. Extensive experimental and analytical programs conducted by the liark I Owner's Group resulted in load definition and structural assessment techniques, as set forth in the " Mark I Containment Program Load Definition Report," NEDO-21888, dated December 1978, and the " Mark I Containment Program Structural Acceptance Criteria Plant Unique Isnalysis Application Guide," NED0-24583-1, dated October 1979. The methodology in these reports as modified by the staff's Acceptance Criteria (described in NUREG-0661) provides a conservative and unifom basis for detemining if any structural or other plant modifica-tions are needed to restore the original intended margin of safety in the containment design.

Although the plant-unique analysis work has been underway for some

' time, the staff recognizes there are still analyses that must be completed before all of the plant modification designs can be confirmed. The current 1

schedules for completion of the Mark I modifications already reflects revised commitments by most licensees in anticipation of additional modifi-cations that are typically associated with supports for piping attached to the suppression chamber and the supports on internal structures. Most schedules included consideration of the amount of difficulty expected to be encountered in transferring the techniques developed in the Mark I long-tem program to the plant unique analyses.

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. April 30,1981 With due regard to these uncertainties, the schedules reflected in the Mark I Orders were already " revised" schedules and were approved by the Com-mission in order to ensure a timely completion of this program and restoration of the margins of safety in the containment design. We do not believe that it is appropriate to modify such completion dates until schedular uncertainties have been quantified and until there is a justifiable basis for establishing a new revised schedule. Every reasonable effort should be made to achieve the completion dates established by the Order before the staff will consider extensions to those completion dates.

In addition, several licensees have requested staff review of plant-specific applications of the generic Mark I criteria. We do not believe, that such reviews are necessary.

It is our opinion that the generic Mark I criteria, as described in NUREG-0661, provides sufficient guidance to conduct the plant-unique analyses and that only our post-implementation audits of the plant-unique analyses are required.

In the event that an exception to the generic criteria must be taken to achieve the completion schedule, you should advise the staff of any exceptions. by letter as soon as practical, stating your sound engineering bas ~is for that exception, and you should describe the exception in detail in the plant-unique analysis report. We intend to review such exceptions only in our post-implementation audit.

If you believe further consideration of your completion schedule is warranted after completion of the plant-unique analysis, you should formally submit a detailed schedule that includes the schedule for design, procurement, and installation of planned plant modifications, the schedule for. plant outages and fuel burnup estimates, a description of the resources devoted to Mark I-related activities, and a qualitative estimate of the relative safety significance of the modifications that have not yet been installed.

jncerely, k

Darrell

. Eisenhut, Director Division of Licensing Office of Nuclear Reactor Regulation cc:

See next page I

i

Mr. George T. Berry Power Authority of the State of New York cc:

Mr. Charles M. Pratt Director, Criteria and Standards Assistant General Counsel Division Power Authority of the State Office of Radiation Programs (ANR-460) of New York U. S. Environmental Protection Agency 10 Columbus Circle Washington, D. C.

20460 New York, New York 10019 Mr. J. Phillip Bayne U. S. Environmental Protection Senior Vice President -

Agency Nuclear Generation Region II Office Power Authority of the State ATTN:

EIS COORDINATOR of New York 26 Federal Plaza 10 Columbus Circle New York, New York 10007 New York, New York 10019 Mr. Raymond J. Pasternak Resident Inspector Resident Manager c/o V. S. NRC James A. FitzPatrick Nuclear P. O. Box 136 Power Plant Lycoming, New York 13093 P. O. Box 41 Lycoming, New York 13093 Director, Technical Development Programs State of New York Energy Office Agency Building 2 Empire State Plaza Albany, New York 12223 George M. Wilverding Manager - Nuclear Licensing Power Authority of the State of New York 10 Columbus Circle New York, New York 10019 Mr. Robert P. Jones, Supervisor Town of Scriba R. D. #4 Oswego, New York 13126 State University College at Oswego Penfield Library - Documents Oswego, New York 13126