ML20215H723

Discusses Concerns Re NRC 870608 Decision to Require Addl Design Verification for Facility.Action Could Result in Delay of Restart Schedule W/O Improvement in Plant Safety

ML20215H723
Person / Time
Site:	Sequoyah
Issue date:	06/12/1987
From:	Dean C, Waters J TENNESSEE VALLEY AUTHORITY
To:	Zech L NRC COMMISSION (OCM)
Shared Package
ML20215H706	List: ML20215H703 ML20215H723
References
NUDOCS 8706240195
Download: ML20215H723 (2)

Text

. . - - .

g TENNESSEE VALLEY AUTHORITY H NOXVILLE. T Ef 4N ESSE E 379')2 OFFlCE OF THE BOARD OF DIRECTon's

' June 12, 1987 The Honorable Lando Zech, Chairman U.S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Zech:

The decision on June 8,1987, by KRC's Special Projects Staff to require an additions 1 design verification at TVA's Sequoyah Euclear Plant is of' profound concern. In January 1986, we' embarked on a massive program to assure ourselves, the NRC, members of Congress, and the public that whenever we were ready to restart the operation of one of our nuclear plants, it would be with.the utmost assurance that it was safe.

Throughout this period, the NRC has been kept fully aware of all of our actions. Now, to have the NRC at this late date direct that an additional independent design verification must be done is obviously perplexing.

To our knowledge, no other licensed operational nuclear plant in the This unprecedented country has ever been subjected to this requirement. i action could certainly result in a delay in the plant's restart schedule, without any improvement in the safety of the plant.

-As you know, in the past NRC has accepted three approaches to These doing were an l

-independent design verification on new construction plants. "

performed by:

1. an Engineering Assurance organization

2. a third party subcontracted by the utility

3. the NRC 1

once having received your request that such an additional verification l' would be performed, TVA proposed that it be done by the Engineering Assurance organization approach (option 1), using an independent review team within TVA's Office of Nuclear power. This would lessen the probable impact on startup while at the same time provide the NRC with additional safety assurance being sought. This group is familiar with TVA and, therefore, would have had the advantage in delivering not only an independent review but also a timely one, both of which are important We believe to TVA. We invited overview by the NRC of this, upfront.

that the NRC staff's decision to reject our proposal was not based on a fair analysis of our position. -

~

8706240195 870612 PDR CDPWH3 NRCC CDRRESPONDENCE PDR

._ ____a

i '14 s

< i June 12, 1987 TheHonorableLapoZech I l We are particularly concerned that TVA is being singled out from the rest )

of the industry and being required to participate in a verification j program that has not'been required of any other operating .r.2 clear plant, l Since this type of independent analysis has not been accomplished on a J licensed operating plant before, it is difficult to assess the length of-time it will take. However, based on industry experience, if TVA used a third party (option 2) to accomplish the design review under subcontract ]

l as sussested by the NRC, it would take at least nine months with obvious i impact on'our ratepayers. You can understand why we support Steve White's position that TVA did not want to do the review with a third party under subcontract.

Therefore, the only option remaining was to agree to NRC proceeding with

~

the review. ' Based on the fact that this type of review has not been done before, we hope that Mr. Keppler's estimate of three and one-half months is accurate.

f Now that the decision has been made, we will cooperate fully with the NRC I in this effort, and we hope you will monitor the situation closely because of its vital importance to the ratepayers in our seven-State region.

We were encouraged by Mr. Keppler's comments in his June 2, 1987 letter to us which indicated that, if this design review raised no new major  ;

concerns, he would be in a position to recommend the restart of Sequoyah j unit 2.

j We share NRC's commitment to the safe operation of our nuclear f acilities.

Sincerely, l

\

C. H. Dean, Jr.

Chairman f

{ ,

,To n B. Waters ,

)

[Di ctor 1

k

.il.i