ML20003J273

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Responds to NRC 810312 Request for Mods to 810203 Proposed Implementation Schedule for Scram Discharge Vol long-term Mods.Provides Justification for Inability to Meet 821231 Completion Date.Requests Acceptance of Proposed Schedule
ML20003J273
Person / Time
Site: Browns Ferry  Tennessee Valley Authority icon.png
Issue date: 05/05/1981
From: Mills L
TENNESSEE VALLEY AUTHORITY
To: Harold Denton
Office of Nuclear Reactor Regulation
References
NUDOCS 8105110142
Download: ML20003J273 (2)


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TENNESSEE VALLEY AUTHORITY CH ATTANOOG A. TENNESSEE 37401 s

400 Chestnut Street Tower II lh 05.

May 5, 1981 Q /@g g d ISS>

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Cl^wn Mr. Harold R. Denton, Director O

Office of Nuclear Reactor Regulation (i "

U.S. Nuclear Regulatory Ccmission Washington, DC 20555

Dear Mr. Denton:

In the Matter of the

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Docket Nos. 50-259 Tennessee Valley Authority

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50-260 50-296 In r:ry February 3,1981 letter to you, we provided you with our propoced inplementation schedule for Browns Ferry Nuclear Plant units 1, 2, and 3 scram discharge volume (SDV) long-term modifications. Our proposed modification schedule was: unit 1 - March 1983 outage; unit 2 - March 1982 outage; and unit 3 - Ngust 1983 outage.

In a March 12, 1981 letter frcm T. A. Ippolito of your staff to H. G. P' rris a

on this subject, the staff requested that we modify our ocrmitment to emply with the following items.

1.

% e design m st include NBC's criterion on Diverse Instrumentation Safety Criterion 3 in Generic SER on BWR Scram Discharge System, December 1, 1980.

2.

%e modifications mst be emplete by D& user 31, 1982.

We will met the requirments of item 1 above (i.e., diverse and redundant instrumntation) by installing additional differential pressure trancmitters on each scram discharge instrtrnent volume (SDIV).

As a result of your request in its 2 above, we have again performed a cmprehensive review of materials ard scoped design on the long-term modifications.

Each SDIV must be instrtented with six level switches. 'ib meet the requirements of IE Dulletin 79-OlB, two of these level switches are designed to input into an analog trip panel. Wis panel is the longest lead its of the modification and has an estimated delivery date of May 1982.

other limiting material deliveries are pressure differential valves, t

l February 26, 1982; transmitters, December 1981; and float switches, December 31, 1981. In addition to these procurement problems, to trat your requested inplementation date of D& user 31, 1982 would necessitate unscheduled forced outages of approximately 1-2 weeks each on units 1 and 3.

%ese forced outages would have a detrimental effect, particularly in light of the tremendous amount of work ongoing at Browns Ferry to meet requirments regarding the torus, 'IMI modifications, etc. (as discussed with D. G. Eisenhut, et al., in a May 29,1980 'IVAAi!C meeting).

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~2-Mr. IIarold R. Denton thy 5,1981 Based upon the chove material delivery dates, and our present long-term outage plan and workload, we cannot commit to changing the following inglenentation schedule which was provided to you in our February 3,1981 letter.

Unit 1 - Refueling outage scheduled to begin in March loS3 Unit 2 - Befueling (torus) outage scheduled to begin in March 1982 Unit 3 - Refueling outage scheduled to begin in August 1983 We regret that this does not meet the requested Dece:nber 31, 1982 date.

Ibsever, we believe that procedural changes and addition of the SDV continuous level monitoring system and reactor protection systen ceram upon loss of control air provide more than adequate protection in the interim to justify the 8-month extension of the inplementation schedule.

We therefore request that you reconsider this matter in light of the above stated facts, and accept our proposed implementation schedule. Your cooperation in this matter will be greatly appreciated.

Very truly yours, TENNESSEE VALLEY AUI!10RWI L. M. Mills, Manager Nuclear Regulation and Safety

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