ML18283A534

Licensee'S Motion for an Order Authorizing Control Rod Drive System and Full Core Shutdown Margin Tests

ML18283A534
Person / Time
Site:	Browns Ferry
Issue date:	06/21/1976
From:	Dunker W, Dawn Powell, Sanger H Tennessee Valley Authority
To:	Atomic Safety and Licensing Board Panel
References
Download: ML18283A534 (21)

Text

UNXTED STATES OF AMERICA NUCLEAR REGULATORY COMMISSXON Before the Atomic Safety and Licensing Board Xn the Matter of TENNESSEE VALLEY AUTHORITY Docket Nos. 50-259 60 (Brogans Ferry Nuclear Plant, Units l and 2)

LICENSEE.'S MOTiON FOR AN ORDER AUTHORIZING CONTROL ROD DRIVE SYSTEM AND FULL CORE SHUTDOMN MARGIN TESTS Licensee Tennessee Valley Authority moves, that this Atomic Safety and Licensing Board authorize the Licensee to conduct Control Rod Drive System tests and Full Core Shutdown'Margin tests, on the grounds that:

r (l) Granting the motion vill not affect the Intervenor's rights in this proceeding; (2) It is in the public interest to authorize the requested tests, and

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(3) There is reasonable assurance that conducting the tests under the conditions set out in TVA's affidavit will not endanger the health and safety of the public.

Respectfully submitted Herbert S. Sanger, Jr.

General Couns'el Tennessee Valley Authority Knoxville, Tennessee David G. Powell Assistant General Counsel William L. Dunker Attornev" for Licensee Chattanooga, Tennessee June .21, 1976

UNITED STATES OF &iERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of TENNESSEE VALLEY AUTHORITY Docket Nos. 50-259 50-260 (Browns Ferry Nuclear Plant, Units 1 and 2)

LICENSEE'S BRIEF IN SUPPORT OF MOTION REGARDING CONTROL ROD DRIVE SYSTEM AND FULL CORE SHUTDOWN MARGIN TESTS STATEMENT This proceeding concerns the propose'd issuance of amendments to facility operating Licenses Nos. DPR-33 and DPR-52 for Browns Ferry Nuclear Plant units 1 and 2, as set forth in 40 Fed. Reg. 46365 (1975).

In its Order of May 21, 1976, regarding fuel loading, the Board deter-mined that "fi]fthe Intervenor's contentions are relevant to the activity asked to be authorized, the Board must make findings in the form of an initial decision on each matter specified in 5 50.57(a) which is in controversy with respect to the amendment and for which a hearing has been requested" (at 4).

'j I at*'w TVA is requesting the Board to authorize two tests from the restart testing program Control Road Drive System tests and Full Core Shutdown Margin tests. Several significant points should be emphasized concerning these tests. Both tests are subcritical testing, thus neither test involves any power operation; no fire-affected electrical circuits or mechanical equipment will be involved on unit 2; fixe-affected electrical circuits involved on unit 1 have been sucessfully preoperationally tested and work properly; and the worst accident that could happen, i.e., all operational control rods in the fully withdrawn position, will have no adverse consequences and the reactors will remain within the technical specification shutdown margins.

Intervenor's contentions do not relate to the tests on unit

2. Contention 2 alleges that TVA personnel are not technically qualified or competent to satisfactorily complete fire-related modifications, and contention 1 alleges 'at addition 'I fire-related modifications re necessary. Contention 3 alleges that NRC's inspection program is insufficient in regard to fire-related modifications. Since the tests on unit 2 require no fire-related circuits or equipment, and no operation is involved, it is not necessary for the Board to make the findings in 5 50.57.

On unit 1, fire-affected electrical circuits necessary for the test have been successfully preoperationally tested. Moreover, the worst accident that could happen would result in two control rods in

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the. fully withdrawn position. Under these conditions, the reactor will remain subcritical, and the shutdown margin required by the technical specifications would not be reduced. Under these circumstances, Intervenor's contentions are not relevant to the actions requested.

In any event, the Board can readily find on the basis of the attached affidavit of Jack R. Calhoun, that there is reasonable assurance that conducting the Contxol Rod Drive System and Full Core Shutdown Margin tests will not endanger the health and safety of the public.

It is TVA's position that, under these circumstances. (1) granting the motion will not affect the Intervenor's rights in this proceeding, (2) the public interest requires that this much progress be made at the present time without waiting until completion of the forthcoming evidentiary proceeding, and (3) there is reasonable assur-ance that conducting the tests as set forth under the conditions specified by Jack R. Calhoun ~."Ill not endanger the health and safety of the public.

ARGUMENT Grantin the Motion Mill Not Affect Intervenor's Ri hts In This The admitted contentions allege that additional fire-related modifications are necessary to provide adequate protection against the

k loss of redundant components of engineered safeguards equipment from fire; that TVA personnel are not competent to satisfactorily complete the fixe-related modifications necessary to provide adequate protection against the loss of redundant components of engineered safeguards equip-ment from fire; and that NRC's inspection and surveillance program is insufficient to assure that TVA satisfactorily completes the fire-related work necessary to provide adequate protection against the loss of xe-dundant components of engineered safeguards equipment from fixe.

As shown by Mr. Calhoun's affidavit, the tests to be conducted on unit 2 do not involve any mechanical equipment ox electrical circuits damaged by the fire or modified as a result of the fire. Thus the Intervenor's contentions do not relate to these activities and his rights are not affected. Indeed, it can be argued that in regard to unit 2, the Board has no jurisdiction over any testing that does not involve fire-related matters or operation.

As to unit 1 tests, Mr. Calhoun points out that this is sub-critical testing. The Board in its May 21 Order held that

[T]he contentions of Intervenor Garner are relevant power. . . [at 6; emphasis added].

Since the tests do not involve even partial operation of the units, the Intervenor's rights will not be affected by granting the motion.

Some electrical circuits damaged by the fire are necessary to conduct the unit 1 tests. These circuits have been preoperationally

tested and shown to work satisfactorily. Even if they did not work, however, the reactor would remain within the technical specification shutdown margins and there would be no adverse consequences. Again, Intervenor's rights would not be affected.

Authorizin These Tests Is In the Public Interest.

As shown by TVA's motion, brief, and affidavits filed on April 22, 1976, the electrical power from the Browns Perry units is urgently needed for this summer's power demands on the TVA system. Mr. Calhoun's af-fidavit shows that by conducting these tests, the reactor vessel heads can be installed and the startup retesting period can thereby be re-duced by 10 days when operation is ultimately authorized. Every day that is saved iu returning these units to service is essential to system reliability and the cost of power to the public. Accordingly, it is in the public interest to authorize TVA to conduct these tests.

There Is Reasonable Assurance That Conductin the Tests Will Not Endan er the Health and Safet of The Public.

The accident analysis set out in Mr. Calhoun's affidavit shows that the worst accident that can happen is to have all operational control

~ y rods in the fully withdrawn position. For unit 1 this would be two rods, and for unit 2 it would be three rods. In both cases, the reactor would remain within the technical specification shutdown margins. Thus there would be no adverse consequences whatsoever to the public health and safety should the worst accident happen in regard to these tests.

CONCLUSION For the foregoing reasons, the Board should grant the motion.

The Licensee requests that the Board decide this motion on an expedited basis. A proposed form of order is attached.

Respectfully submitted, Herbert S. Sanger, Jr.

General Counsel Tennessee Valley Authority Knoxville, Tennessee David G. Powell Assistant General Counsel William L. Dunker Attorneys for Licensee Tennessee 'hattanooga, June 21, 1976

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of TENNESSEE VALLEY AUTHORITY Docket Nos. 50-259 50-260 (Browns Ferry Nuclear Plant, Units 1 and 2)

PROPOSED FORM OF ORDER By Motion dated June 21, 1976, Tennessee Valley Authority (Licensee or TVA) has moved that this Atomic Safety and Licensing Board (Board) issue an order authorizing Control Rod Drive System and Full Core Shutdown Margin Rests for Brogans Ferry Nuclear Plant units 1 and

2. As shown by the affidavit of Jack R. Calhoun accompanying the motion, the reactors would remain subcritical throughout the tests; the accident analysis demonstrates that in the case of the worst accident that could happen, i.e., two fully withdrawn control rods on unit l.and three rods on unit 2, the reactors will remain within the technical specification shutdown margins; and granting the motion will reduce startup retest time by 10 days.

The affidavit further shows that no fire damaged equipment or electrical circuits, or equipment modified as a result of the fire, will be required to conduct the unit 2 tests; and that the electrical circuits damaged by the fire and necessary for the unit 1 tests have been successfully preoperationally tested.

Based on the foregoing, the Board finds that:

(1) granting the motion will not affect the Intervenor's rights in this proceeding, (2) it is in the public interest to authorise the requested tests, and (3) there is reasonable assurance that conducting the tests under the conditions set out in TVA's affidavit will not endanger the health and safety of the public.

THE ATOMIC SAFETY AND LICENSING BOARD Thomas W. Reilly, Esq., Chairman Bethesda, Maryland June , 1976

4 UNITED STATES OF R1'KRICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of TENNESSEE VALLEY AUTHORITY Docket Nos. 50-259 50-260 (Browns Perry Nuclear Plant, Units 1 and 2)

CERTIPICATE OF SERVICE I hereby certify that I have served the original and 20 conformed copies of the following documents on the Nuclear Regulatory Commission by depositing them in the United States mail, postage pre-paid and addressed to Secretary, U.S..Nuclear Regulatory Comr Jssion, Washington, D.C. 20555, Attention: Chief, Docketing

~ and Service Section'.

Licensee's Motion For An Order Authorizing Control Rod Drive System and Full Core Shutdown Margin Tests Licensee's Brief in Support of Motion Regarding Control Rod Drive System and Full Core Shutdown Margin Tests and that I have served a copy of each of the above documents upon the persons listed below by depositing them in the United States mail, postage prepaid and addressed:

Thomas W. Reilly, Esq.', Chairman Dr. Frederick P. Cowan Atomic Safety and Licensing Board 22 Browns Lane U.S. Nuclear Regulatory Commission Bellport, New York 11713 Washington, D.C. 20555 William E. Garner, Esq.

Dr. Hugh, C. Paxton Route 4, Box 354 Los Alamos Scientific Laboratory Scottsboro, Alabama 35768 P.O. Box 1663 Los Alamos, New Mexico 87544 Atomic Safety and Licensing Appeal Board James R. Tourtellotte, Esq. U.S. Nuclear Regulatory Commission Lawrence Brenner, Esq. Washington, D.C. 20555 Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 This 21 clay of June, 1976.

David G. Powell Attorney for Licensee Tennessee Valley Authority Chattanooga, Tennessee June 21, 1976