ML20073S867
| ML20073S867 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/29/1994 |
| From: | Broughton T GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C311-94-2098, NUDOCS 9407070073 | |
| Download: ML20073S867 (2) | |
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GPU Nuclear Corporation EM Nuclear m :: r Middletown, Pennsylvania 17057-0480 (717) 944 7621 Writer's Direct Dial Number:
(717) 948-8005 June 29, 1994 C311-94-2098 4
U.S. Nuclear Regulatory Commission Attn:
Document P:ntrol Desk Washington, DC 20b55
Dear Sir:
Subject:
Three Mile Island Nuclear Statien, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Proposed Alternative to 10 CFR 50.55a(f)(4)(ii) - Request to Extend the Current 120 Month IST Interval by 24 Months GPU Nuclear is aware of the NRC's proposed rulemaking regarding an alternative to the 120-month update required by 10 CFR 50.55a for Inservice Inspection (151) and Inservice Testing (IST). Submittals by another utility (Enterg3?
dated October 21, 1993 and April 14, 1994 followed'by a meeting attended by representatives of the Nuclear Energy Institute (NEI) resulted in a proposed temporary alternative to meeting the requirements of 10 CFR 50.55a(f)(4)(ii) until such time as the rule beccmes final.
The purpose of this letter is to request a 24 month extension of the current 120 month IST interval. The ISI program is not affected by this request'.
The current regulations require licensees to update the ISI and IST programs to later editions and addenda of the ASME Boiler and Pressure Vessel (B&PV) Code Section XI every 120 months.
The changes proposed by the proposed-rule cluriin:ta the updating requirements based on specific intervals.
Instead, the proposed run states that each edition and addenda of the B&PV Code, and the ASME Operations and Maintenance Code (0&M Code) will become effective six months after the date of publication.
Licensees will be able, but not required, to use later editions, or portions thereof, as they became effective without further NRC approval.
We understand that the NRC will identify any changes that are safety significant and perform a back. fit analysis such that changes will be incorporated into the regulations by ru'emaking, identifying Extension of the first 10 year interval was allowed by the ASME Section XI Code for ISI due to the extended shutdown of TMI-l following the accident at THI-2. Because the extension was not allowed for IST, the 10 year intervals
/g y MI for the two programs do not coincide.
9407070073 940629 POR ADOCK 05000289 P
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GPU Nuclear Corpora >on is a subsid.ary of Genera! Pubhc Utst:es Corporation
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C311-94-2098 Page 2 of 2 the implementation schedule.
In accordance with 10 CFR 50.55a(a)(3), which allows the NRC to authorize dlternatiVes to selected requirements contained in 10 CFR 50.55a, GPU Nuclear is requesting a 24 month extension of the present 120 month IST interval which ends September 8, 1994.
IST activities will continue to be in accordance with the current NRC approved IST program as required by the TMI-l Technical Specifications (TS) until September 8, 1996.
With this relief, GPU Nuclear will be able to suspend certain of our current activities devoted to program changes which add additional burden without a commensurate safety benefit.
Considerable work toward updating the IST program to the 198f Edition of the Code has been completed.
However, the additional resources needed to complete the update by September 9, 1994 could be sparad if relief is granted.
The propt sed extensions would provide an acceptable level of quality and safety.
The current IST Program is in accordance with the 1980 Code Edition with Addenda through Winter 1980 and has been approved by the NRC. We understand J'at ASME code changes which constitute a substantial safety benefit (e.g., augmented examination of the reactor vessel) are separately addressed by the rulemaking (e.g., 50.55a(g)(6)(ii)(A)) and are unaffected by the proposed extension to the 120 month period.
Failure to extend the current 120 month periods would result in hardship at unusual difficulty without a compensating increase in the level of quality and safety and would effectively negate much of the benefit of the proposed alternative. Approval is needed by September 1, 1994 to ensure compliance with the current regulation.
Sincerely, QQL 4k-T. G. BrougHton Vice President and Director, TMI MRK cc:
Region 1 Administrator TMI-l Senior Project Manager TM1 Senior Res# dent inspector
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