ML19303C226
| ML19303C226 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Crane |
| Issue date: | 03/09/1984 |
| From: | Dircks W NRC OFFICE OF THE EXECUTIVE DIRECTOR FOR OPERATIONS (EDO) |
| To: | |
| Shared Package | |
| ML19303C227 | List: |
| References | |
| FOIA-84-148, TASK-PINC, TASK-SE SECY-84-108, NUDOCS 8404050515 | |
| Download: ML19303C226 (11) | |
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March 9, 1984 POLICY ISSUE secv-84-108 (NEGATIVE CONSENT)
FOR:
The Commissioners FROM:
William J. Dircks Executive Director for Operations
SUBJECT:
THREE MILE ISLAND UNIT 1 - PLANT HOT FUNCTIONAL TESTING PURPOSE:
To advise the Commission that on Friday, March 23, 1984, unless notified to the contrary or unless furtner review results in conclusions different from those in the Discussion below, the staff proposes to issue a license amendment which would permit declaring the TMI-1 repaired steam generators operable for the period of pre-critical non-nuclear hot functional testing.
BACKGROUND: On March 23, 1981, in CLI 81-03, the Commission authorized the licensee to perform hot functional testing using non-nuclear heat, subject to appropriate staff review. The staff reviewed the licensee's hot functional test program and approved performance of such testing, which was conducted in August and September of 1981.
Subsequently, in November 1981, a large number of cracks were discovered in the tubes near the top of the upper tube sheet, thus rendering the steam generators inoperable.
Although the authorization to perform hot functional testing still exists, the Technical Specifications preclude any operation (including hot functional testing) above 250 F with inoperable steam generators. After an extensive effort in developing and implementing En alternative repair method (kinetic expansion), on May 9, 1983 GPU Nuclear submitted Technical Specification Change Request No. 125 requesting an amendment to approve repairs to defective steam generator tubes using methods other than plugging, and requested approval of the use of the repaired steam generators to perform non-npclear heatup of the plant for pre-critical testing as well as subsequent operation. A Notice of Ccnsideration of Issuance of Amendment and Proposed No Significant Hazards Consider-ation Determination covering this rcquest appeared in the Federal
Contact:
H. Silver, NRR 49-28434 8404050515 840309 CF BECY 84-10B CF
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i Register on May 31, 1983.
Comments received on that notice did not address hot functional testing as such, but rather concentrated on the repair process and subsequent nuclear operation with the repaired steam generators.
To facilitate early hot testing of the steam generators in order to confirm the adequacy of the repairs, the licensee requested i
on July 13, 1983 that their May 9 request be split into two i
parts:
- 1) pre-critical (non-neclear) hot functional testing, I
and 2) critical operation, On August 25, 1983, the staff issued its SER on steam generator repair and return to operation.
In partial response to the I
licensee's July 13 request, the staff also issued on August 25, 1983 License Amendment No. 86 which permitted the repaired steam generators to be declared operable after repair by the kinetic expansion process, for the period of steam generator hot testing. License Amendment No. 86 addressed only the steam generator hot testing based on the staff's understanding of the licensee's July 13 request, but did not permit resumption of the full range of hot functional testing activity. The Commission was.
informed of this action in SECY-83-359. The amendment included a safety evaluation 2nd a determination of no significant hazards consideration, and its issuance was noticed. As noted in the no significant hazards determination, the Comonwealth of Pennsylvania expressed no concern over this action. The steam generator hot tests were satisfactorily completed and the plant returned to cold shutdown. A sumary of the test results was submitted by the licensee on October 25, 1983.
On November 18, 1983, the staff forwarded to the Commission SECY-83-474 which requested Commission concurrence in the staff's final no significant hazards consideration deter-mination on nuclear operation of TMI-1 with the repaired steam generators. Also included were a supplement to the staff's SER which reflected the staff's evaluation of the results of the steam generator hot testing, and a draft amendment package which would permit declaring the. repaired steam generators operable after repair by the kinetic expansion process for.all modes of operation, which would encompass the full range of hot functional testing activities previously authorized by the Comission. The Commission deferred action-on.the no significant hazards determination and directed the staff not to issue that amendment pending a decision on the matter (memorandum from the Secretary to W. J. Dircks, January 16,1984).. In the discussion relating to the Comission's action, there was no specific j
discussion regarding plant hot functional testing, and the specific issues of concern to the Commission do not appear to be relevant to activities limited to-hot functional testing.
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i The licensee, in'its letters dated December 1 and 21,-1983, noted its need for, and requested permission to proceed-with, non-nuclear hot functioral testing.
In its letter.of' t
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February 2,1984, (Enclosure 1) the licensee summarizes the history of its requests to complete the hot functional test program, points out that its request is encompassed by its original request of May 9,1983, explains the purpose of the hot functional test program, and again reiterates its request for "whatever appropriate steps are necessary to expedite author-ization to perform the remaining pre-critical hot functional test program."
Very shortly after GPU's letter of February 2, vibration problems on one reactor coolant pump necessitated disassembly for inspection of the pump internals including the pump shaft. This effort is in progress.
Repair work, if required, would precede the licensee's proposed hot ftnctional testing.
In its February 23, l
1984 letter (Enclosure 2), the licensee's schedule for conducting hot functional testing is shown as the last half of May 1984 assuming that reactor coolant pump repairs are needed.
In telephone discussions with the licensee, it was indicated that if the problem with the reactor coolant pump is not major, GPU may decide to proceed directly with hot functional testing as previously planned, after correcting the problem. The plant could be ready for such testing by mid to late March. The licensee again requested approval to perform hot functional testing in its letter of February 23, 1984.
Recent preliminary consultation with the Commonwealth of Pennsylvania indicated no objection to non-nuclear hot:
functional testing. Jane Lee, one of the Joint Intervenors in the steam generator proceedings, had previously objuted to hot functional testing in a filing dated July 26. 1983. The substance of her relevant comments had been addrnssed in the SER for Amendment No. 86 or in the staff's SER on steam generator.
repair.
-DISCUSSION: The staff has considered the documents discussed above and reached the following conclusions.
- 1. Early pre-critical non-nuclear hot functional testing is necessary to assure timely completion of activities noted in the licensee's letter of February 2,1984, commensurate with a possible restart decision in June 1984.
If such testing identifies "needed adjustments", the time prior to June 1984 could be utilized for this effort. Such testing also provides additional operator experience with the plant in a hot condition, as well as additional confidence in overall plant readiness at restart. Even if reactor coolant pump problems delay hot functional testing until May, approval-to perform such testing before any restart decision would be beneficial for thC same reasons.
. 2. A license amendment changing the Technical Specifications is required to permit declaring the steam generators operable for plant hot functional testing. The present Technical Specifi-cation page with the minor correction that would be needed is attached (Enclosure 3).
- 3. In the discussion relating to the Comission's consideration of SECY-83-474 regarding nuclear operation of TMI-1, plant hot functional testing was not specificdly mentioned, and the specific issurs of concern to the Commission do not appear relevant to such rion-nuclear testing.
- 4. Both safety and significant hazards considerations for use of repaired steam generators in non-nuclear hot functional testing are encompassed by the review performed of steam generator hot testing for License Amendment No. 86. The conclusions and determinations are expected to be the same for the amendment under discussion.
- 5. The amendment under discussion would be encompassed by the licensee's May 9,1983 request and by the original Federal Register notire of May 31, 1983. A new pre-notice would not be required.
RECOMMENDATION: That the Comission:
- 1) Consent to the issuance by the staff of a license amendment which would permit declaring the repaired steam generators operable for pre-critical non-nuclear hot functional testing, which the Comission has previously authorized and 2) Note'that the staff will proceed with issuance of the license amendment on March 23 unless advised to the contrary by the Comission or unless further review results in conclusions different from those presented in the Discussion, above.
cs William J. DIrc~ks Executiue Director for Operations
Enclosures:
1.
Letter dated; February 2, 1984 2.
Letter dated February 23, 1984 3.
Corrected Technical Specification'page
SECY NOTE:
In the absence of instructions to the contrary, SECY will notify the staff on Friday, March 23, 1984 that the Commission, by negative consent, assents to the action proposed in this paper.
DISTRIBUTION:
Commissioners OGC OPE OI OCA OIA OPA REGIONAL OFFICES EDO ELD ACRS ASLBP ASLAP l
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February 2, 1984 5211-84-2027 Office of !!uclear Reactor Regulation Attn:
Harold R. Denton, Director i
U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Dear Sir:
Three 1111e Island Nuclear Station, Unit 1 (T!!I-1)
Operating License t;o. DPR-50 Docket flo. 50-289 Precritical Non Nuclear Hot Functional Testing In our letter of December 21, 1983, GPU Nuclear reiterated our request for approval to complete the hot functional (non-nuclear) test program.
In a subsequent telephone conversation between members of our staffs on January 23, 1984, the NRC Staff indicated that a letter summarizing the history of this situation would be helpful.
It is the intent of this letter to summarire that history.
On 11 arch 23,1981, the Commission :ssued an order (CLI 81-03) authorizing hot testing at Till-l using non-nuclear heat.
In August and September 1981, Ti1I-l-conducted hot functional testing that we addressed in our letter of June 17, 1981.
Following this testing program, we discovered cracks in the tubes in the area of the upper tube sheet rendering the Once Through Steam Generators (OTSGs) inoperable.
During 1982 and the first half of 1983, GPU Nuclear employed a method of kinetic expansion to repair and return the steam generators to an operable status.
On 11ay 9,1983 GPU Nuclear declared the OTSG's operable and submitted Technical Specification Change Request #125 to permit operation with the repaired steam generators.
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In the text of the !!ay 9 submittal, GPUN requested both approval.to use the-racaired steam generators in performing "non-nuclear heatup of the plant using pump heat for precritical testing..." and approval for subsequent operation.
This request was noticed in the Fcdard Register on !!ay 31, 1983.
By July, 1983 it became evident that the time necessary to complete the? final t;RC "no significant hazards considerations" determination for all modes of-plant operation, would prevent.GPU tluclear from performing.the.htt functional
test program on schedule.
Therefore, on July 11 in a public meeting in 3ethesda, Md. (also in H. Dieckamp's letter dated July 13, 1983) 3PU Nuclear proposed that the Staff separate the previously noticed request into two parts.
The first part requested approval "to proceed with pre-critical (non-nuclear) hot functional testing...".
The second part requested approval of critical operation for the plant.
In order to facilitate NRC's phasec review of the operability of the steau generators, GPU Huclear sent a letter on July 18, 1983, providing a summary of our May 9 discussion of "no signifi-cant hazards considerations". Additional emphasis wcs also placed on the insignificance of the consequences of steam generator events for a reactor that had been subcritical for more thcn four years.
On August 25, 1983, the NRC staff granted partial approval of our request limited to hot precritical testing of the steam generators.
In publishing this partial approval, the Staff noted that the hot precritical non-nuclear testing program for the steam generators was within the scope of the May 31 Fedsral Register notice. The Staff then made a finding of "no significant i
hazards considerations" for this portion of the request.
Under the provisions of the revised Technical Specifications, GPU Nuclear successfully conducted 1
hot precritical steam generator testing.
j The time that has been involved in NRC's consideration of a final "no significant hazards considerations" determination for all modes of plant operation, has prolonged completion of the remainder of GPU Nuclear's hot precritical non-nuclear test program.
Our restart schedule detailed in our December 1, 1983 letter, first raised this need with the Staff.
On December 21, 1983, GPU Nuclear formally reiterated the request for Staff approval to conduct the balance of the hot precritical test program.
In that letter, GPU Nuclea'r noted that the noticed May 9, 1983 request and the July 13, 1983 i
letter both snught approval of our entire hot precritical (non nuclear) test program. The December 21, 1983 letter also referred to GPUN Technical Data Report (TDR) #488 "TMI-1 OTSG Hot Testing Result and Evaluation" (submitted on October 25, 1983). This TDR confirmed that the GPUN July 18 assessment of "no significant hazards considerations" is valid for the remainder of the hot precritical test program as well as for the portion already completed.
Ue are aware that the Staff recently recommended approval of a license amendment to the Commission that would have declared the repaired steam generators to be operable for all modes of plant operation.
This approval would, of course, encompass precritical hot functional testing.
The Commission has deferred action on this recommendation.
We believe, however, that the Commission's action addressed the question of operating TMI-1 with nuclear heat and that the Commission did not intend to prevent the Staff from taking action on our pending request to complete non-nuclear hot functional testing.
We also note that none of the Commission discussions in public meetings has related directly to the hot functional testing alore.
GPU Nuclear believes that it is prudent to proceed with the hot functional testing program as described in the December 16 meeting with the hRC Staff.
This is necessary in order to complete in a timely fashion the following activities commensurate with a decision to Restart by June 1984:
4 o Surveillance of safety related systems o Final testing of installed modifications
- a. HPI flow test to determine proper flows and splits as a resuit of the installation of cavitating venturis (Certification Required).
- b. Verification of the Ir'cre Thermocouple Alarm System (Software Packages Certification Required).
- c. PORY Testing.
- d. Pressurizer heaters and spray adjustment.
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- e. RCS leak rate verification test.
- f. Hanger inspections related to thermal expansion devices (spring cans, snabbers. etc.).
o Identificaticn of any needed adjustments.
Increased " hands on" experience for operators.
o As addressed in our letters of June 17, 1981 and December 21, 1983, there are no unreviewed safety questions involved in performing this plant heatup. He addressed the operability of the steam generators in the heatup mode in our submittal of September 11, 1983 and we reported the results of our test performed in September 1983 in our letter of October 25, 1983.
On January 12, 1984, the Management Review (Flag 2) indicated that the plant is now ready for final'heatup.
This letter has summarized the background and bases for our December 21 letter. We reiterate our pending request for approval to perfcrm the hot testing program. We believe that the additional summary information has been-provided, and request that the NRC take whatever apprcpriate steps are neces-sary to expedite authorization for GPU Nuclear to perform the rcmaining pre-critical hot functional test program.
Sincerely, r
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P. R. Clark President
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cc:
J. F. Stolz 6
a R. Conte J. Van Vliet I
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{fg g7 Post Office Box 480 GPU Nuclear Corporation i.
Route 441 South
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Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Nurnber:
February 23, 1984 5211-84-2041 Office of Nuclear Reactor Regulation Attn:
H. Denton, Director U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Master Restart Schedule The attached master restart schedule has been revised to include work on reactor coolant pump 1B prior to precritical non-nuclear hot functional testing.
Vibration problems necessitate inspection of the pump shaft.
This work v111~not impact our scheduled capability of June 1, 1984 criticality. We reiterate our pending request for. approval to perform the hot testing program.
In order to take best' advantage of this " precritical" period, we have scheduled the completion of the other major work items and surveillances, including containment. integrated leak rate testing. Modifications for which milestone delays are perceived will be rescheduled beyond restart.
None of the above modifications or plant activities will preclude our ability to complete precritical non-nuclear hot ' functional testing prior to June 1,1984.
1 Sincerely,
. D.
ill Director, TMI-1 HDH: RAS:vjf 1
Attachment cc:
J.,F.
Stolz sir. Silver J. Van Vliet R. Conte i
GPU Nuclear Corporation is a subsidiary of the Generci Public Utilities Corporation
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The steam generator shall be determined OPERAPLE after completing the corresponding actions (removhl from service by plugging, or repair by the kinetic expansion process *, of all tubes exceeding the repair limit and all tubes containing throustarall cracks) required by Tablu i
4.19.2.
4.19.5 Reports a.
En11owing the completion of each ina.ervice inspection of l
stesa generator tubes, the number of tubes repaired or
.,. Ip-l removed from service in each steam generator shall be reported to the NRC within 15 days.
b.
The complete results of the steam generator tube inservice d= p--tion sLall be reported to the NBC within 3 months following completion of the inspection.
This report shall include:
1.
Number and extent of tubes inspected.
, 2.
i.ocatiott and percent of unil-ch4eka==s penetration for each indication of an imperfection.
j 3.
Identification of tubes repaifed or removed from service.
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c.
Results of ser.au generator tube inspections which fall into Category C-3 and require prompt notiffemedan of'the NRC shall be rei W pursuant to Specification 6.9.2 prior to j
1-resumption of plant operation.
The written follovup of this i
report shall provide a description of investigations conducted to decaemina cause of the tube degradation sad corrective measures taken to prevent recurrence.
M The Surveillance Requirements for 4= pection of the steam generator tubes ensure that-the structural integrity of this portion of the RCS will be==4=e=4=ad.
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- The phrase "or repair by the kinetic expansin process" shall be in,"
effect only'during-the period of eseam-geneseter hot functional testing.
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