ML19308B971
| ML19308B971 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/03/1978 |
| From: | Silver H, Varga S Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19308B967 | List: |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001170712 | |
| Download: ML19308B971 (3) | |
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NUCt. EAR REGULATORY COMMISSION 3-l E
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SAFETY __E, VALUATION BY THE OFFICE'OF WDCLEAR REACTOR REGUIATION g
,S_UPPOICING AMENDMENT NO.170 FACILITT OPERATING LICENSE NO. DPR-73 g
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METROIOLITAN EDISON COMPANY JERSEY CENTRAL POWER & I,1 GIT COMPANY
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W PENNSYLVANIA ELECTRIC COMPANY
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DOCKET NO: 50-320 e
_7_HREE_ MILE ISLAND NUCLEAR _ STATION, UNIT,,2, Introduction
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By letter dated February 24, 1978, Metropolitan Edison Company requested a waiver of certain requirements of the Technical Specifications appended to Facility Operating License No. DPR-73 for Three Mile Island Nuclear Station, Unit 2.
The requested waiver would remove restrictions on hydrostatic hJ testing at temperatures above 180 degrees Fahrenheit and pressures up to
.x 2285 psig prior to initial criticality only.
Discussion Technical Specification 3.4.9.1 restricts hydrostatic testing of the Repctor Coolant System to combinations of temperature and pressure shown in Figure 3.4-4.
7bse values were selected to assure that fracture toughness
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capability of the reactor coolant system-would not be exceeded during the
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first five effective full power years opperation.
Hydrostatic testing of the reactor cool' ant system is required to test new pressure boundaries which have not yet.been hydrostatically tested. These
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new pressdre boundaries resulted froin' plugging 6f st'eaniTeneiator tube g
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sheets, replacement of reactor coolant pump gaskets, and installation of i
instrumentation in the steam generator as part of the tube test program.
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m Conformance with the present Technical Specifications would require being in operational Mode 4 to' attain the required temperature and pressure j
conditions.
In the interest of minimizing delays, the licensee proposes.
y that a waiver of the requirements of the Technical Specifications be granted L.c to permit performance of hydrostatic tests with temperatures no lower than 180 degrees Fahrenheit and pressures no-higher than 2285 psig prior to initial criticality. Similar tests havTpreviously been performed at higher
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- . pressures during preoperational testing,'except that no fuel was present
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For preservice hydrostatic testing ~and testing during the first few years 2
of life, the reactor vessel closure head and outlet nozzle control the h
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requirements of 10 CFR Part 50, Appendix G.
Assuming appropriate reference h
flaws and safety factors, Babcock & Wilcox performed an analysis in y
accordance with the methods of BAW-10046A,f" Methods of Compliance with Fracture
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'Ibughness and Operational Requirements of;10 CFR Part 50, Appendix G" which 5
L shows that the minimum metal temperature required for 2300 psi is 180. degrees Fahrenheit if no significant thermal stresses are present.
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...y We licensee has confirmed that the tempeFature will be ' essentially static (i.e., a very low heatup rate will be employed) which will minimize thermal We temperature will be measured on the outside of the vessel stresses.
closure head at its juncture with the flange, which is the area of highest stress.
We have reviewed the information provided by the licensee and find it acceptable and in conformance with 10 CFR Part 50, Appendix G.
We licensee also states, and we agree, that the integrity of the unirradiated fuel assemblies will not be affected by performance of hydrostatic tests at the requested conditions. he presence of the unitradiated fuel does not j
(.h affect any test parameters nor does it have an impact on the systems being 1
tested. Wus, the test considerations and acceptable safety-related margins
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for these tests without the presence of' fuel are unchanged.
Based on the above, we conclude that performance of hydrostatic testing prior to initial criticality at essentially stable temperatures as low as 180 degrees Fahrenheit and pressures up to 2285 psig is acceptable.
We J
further conclude that the facility operating license can be amended by
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adding to Attachment 2 thereof appropriat'e waiver of the. requirements of Technical Specification 3.4.9.1 to permit such testing.
Environmental Consideration
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We have determined that the amendment does not authorize a change in effluent
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types or total amounts nor an increase in power level and will not result j
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in any significant environmental impact. Having made this determination, we have further concluded that the amendment involves an action which is c
' insignificant from the standpoint of environmen'tal, inp.act and, pursuant to 10 CPR SSI.5(d)(4), that an environmental impact statenie'nt or negative J
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declaration and environmental impact appraisal need not be prepared in
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connection with the issuance of this amendment.
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.s Conclusion We have concluded, based on thTcDs'Idifatioiis discussed above, t (1) because the amendment does not-involve a significant in probability or consequences of accidents previously cons decrease in any safety margin, it does not involve a significant ha h
consideration, (2) there is reasonable assurance that the health of the public will not be endangered by operation in the proposed i i and (3) such activities will be conducted in compliance with the Co h
connon defense and security or to the healta lic.
'.c Also, we reaffirm our conclusions as otherwise stated in our Safety Evaluation Report.
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taxpayer by the~ contractor, the g'ener-;WQ p boiler water / steam system; conden-to qualify as section 38 property, the ating unit was synchronized'into the l
isate/feedwater system; condensate property mustic(ilepreciable and have taxpayer's power grid for its function ~ 3 gr f
a usefullife of 3 years or more..
in the business of generating electric'-
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' male-up system; main boiler fuel sys-Section'167(i)'of the Code pro-energy for the production of income,"
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y tem; auxiliary boiler and steam system; vides, ici part, that there shall be al-and daily operation of the generating -
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air quality control sptem; waste dis-lowed as a depreciation deduction a unit began, notwithsta l
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. posal system; main turbine system; andreasonable allowarice for the exhaus-that the generating unit would under- %:i coal handling system.
tion, wear and tear, 'and obsolescence go further testing to eliminate any de '
y' ';
g On December 11, 1975, necessary of property used in a trade or business. fects and the height of the dam would permits and licenses u, operate the Section 1.167(a)-ll(e)(1)(i) of the have to be increased for future require-3 coal. fired electric generating facility in part, that w
regulations provides, 3.0 had been approved.
property is first placed in senice when Accort' gly,in the instant case, the ments.
December 11, 1975, wu also the date of synchronization of the generat-and is available 'for a specifically as-coal-fired electric generating facility ME it is in a condition or state of readiness ing unit into the power grid of the signed function *In general, the provi-was "first placed in service" on N
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company and the date when the criti-sions of sectioE'1.463(d)(1)(ii) and ber.11,1975, for depreciation and in cr.1 testing had been completed on the (d)(2) appi 'for the purpose of deter-vestment credit purposes.
T component systems of the coal-fired mining the date on which property is clectric generat ng facility to assure placed in servi'ceN Depreciation based i
j 26 CFR 1.167(4)-11:
that the generating unit could operate Section 1.468(ki)(1) of the regula.
en class !wes and asset deprecnarson sanges s.
In tddition, the generating unit was tions provide...s, m part, that for pur-f,, p,,p,,,y g,ug i,,,,du after Duem-p i'
in its intended manner.
herJI,1970.
poses of the~ investment credit allowed W #"'i"" 46; J.4644 pitced in t' e control of the taxpayer by section 38 of the Internal Revenue Depreciation; "first placed in
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by the contractor on December 11, Code of 1954, property shall be con-service"; nuclear electric generat-1975, and daily operation of the unit sidered placed in senice in the earlier ing unit. A nuclear e However, subsequent testing ing unit is first placed in service y
of the following taxable years: (i) the began.
was performed to determine and elimi-taxable year in which, under the tax-forinvestment credit and deprecia-L ntre latent defects. if any.
payr's depreciation practice, the pe-tion purposes when the unit. is j
A substantial portion of the pro-riod for depreciation with respect to physically and legally placed in the E
jected cost of the waste disposal sprem such property begins; or (ii) the tax-control of the owners by the con-
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f was attributable to a 400-foot high able year in which the property is tractor and is fully operational, t-dam that was not completed on De-placed in a condition or state of readi. even though it is still undergoing cember 11, 1975. However, on this ness and availability for a specifically testing to elirninate any defr-ts and 1
date the dam was of sufficient height assigned function.u i. -" t to dernonstrate reliability, i-to take care of the current waste dis-Section 1.46-3(d)(2) of the regula-posal though it would have to be in.
tions provides,~in part, that equipment Rev. Rul. 76 428 creased as waste disposal requirements acquired'by~ a' taxpayer for a specifi-Advice has been requested as to
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increased. The height of the dam did cally assigned function'in his trade or nuclear electric generating T
not interfere with the generating unit's business that is operational but is un-unit (" unit") was first placed in serv-when a
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intended purpose on December 11, dergoing testing to ethninate any de-ice for depreciation and investment 1975.
fects is considered in a condition or credit purposes, under-the circum..
Thz coal. fired electric generating state of readiness and availability for a stances described below.
y unit is depreciable property and has a specifically assigned function.
The taxpayer, a segulated electric l
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useful life of more than 3 years.
Under the circu.mstances described utility company that files its Federal Section 38 of the Internal Revenue above, the generating unit in the in-income tax returns on a calendar year -
7 Cod 2 of 1954 allows a credit against stant case was in a condition or state basis, owns a unit, construct y
Federal income tax for qualified in-of readiness and availability for a spe-which commenced in September 1972!
vestment in section 38 property. The cifically assigned function on Decem-The unit was constructed for:the determination of what property quali-ber 11,1975,in that the necessary per-taxpayer pursuant to a contract..The fies as section 38 property is made in mits and licer.ses had been' approved, major co accordance with the rules provided in the critical tests for the various compo-to the operation of the unit include:
section 48.
~nents were complete,'the generating a nuclear steam supply system; a re-Section 48(a)(1) of the Code pro-
. videslin pertinent part, that in order unit was placed in the control of the NJ 47 e
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actor auxiliary system; a control and ing the class life asset depreciation the depreciation allowance for a vin-
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safety instrumentation system; a radio-range system for eligible property tage account for which the taxpayer active waste disposal system; a fuel placed in service in 1975 and adopted adopts the " half year conve ntion" handling and storage system; a tur-the half year convention set forth in shall be determined by treating all bine system; and a containment sys-section 1.167(a)-(11)(C)(2)(iii) for propertyin the account as placed in tem.1 a k% ' W g..- f - y-
, depreciation, purposes. The unit is service on the first day of the second On December 23,,1975, the unit depreciable property and has a use-half of the taxable year.
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was structurally complete in all es. " ful life of more than 3 years' Section ~1.167(a)-11(c)(1) (i) of i
L sential respects. All systems had been Section 38 of the Internal Revenue the regulations provides, in part, that proven operational du' ring the pre-Code of 1954 allows a credit against property is first placed in service when operational testing program. A full Federal income tax for qualified in.
it is in a condition or state of readi-term, full power operating license was vestment in section 38 property. The ness and is available for a specifically issued for the unit on November 19 determination of what property quali-assigned function. In general the pro-1975. All nuclear fuel assemblies were fies as section 38 property is made in visions of section 1.46 3(d)(1)(ii) loaded in the reactor on November accordance with the rules provided and (d)(2) apply for the purpose of 24,1975. Criticality of the reactor was in section 48.
determining the date on which prop-achieved on December 16,1975. Nu-Section 48(a)(1) of the Code pro.
erty is placed in service.
Under the facts and circumstances clear steam supply turbines were vides, in pertinent part, that in order operational on Decernber 18, 1975.
to qualify as section 38 property, the described above, the nuclear generat-License restnction on the mam steam property must be depreciable and have ing umt m the,mstant case. was in a condition or state of readiness and isolation valve was lifted on Decem-a useful life of 3 years or more.
availability for a specifically assigned ber 22,1975. On December 23, 1975, Section 167(a) of the Code pm-
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mitial synch r omzatmn and power vides, in part, that there shall be al-that the necessary permits and h.censes j
operation were. achieved at greater lowed as a depreciation deduction a had been approved, the entical tests j
than 17 - percent of the elecincal reasonable allowance for the exhaus-capacity of the um.t. As of December for the van.ous components had been
.I tion, wear and tear, and obsolescence 23, 1975, all construction work was completed
- the nuclear generatmg umt
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of property used.m a trade or bus. mess.
i had been placed m the control 6f the
.essentiallv complete and the only i
S*C" " I;46-3(d)(1) of the regu-taxpayer by the contractor, and the i
remaining contractor personnel on the site were in support of startup and laimns pmndes,,m part, that for pur-generating unit had been synchronized, l maintenance activities, and the com-p sn { the investment credit allowed into the taxpayer % power grid for its a '
pletion of insulation.
by section 38 of the Code, property. function in the business of generating i,
shall be cons,idered placed,m sern ce nuclear electric energy for the pro-The unit was physically in the con-trol of the owners, with all the legal
- the earhu of the following taxable -
feven though the l duction of income,ld'6ndergo further l
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attributes of ownenhlp such as title, yean: (i) the taxable year in which, generating unit wou risk of loss, and liability. The unit was under. the taxpayer's depreciatlon testing to climinate any defects. The l fully operational on December 23,
.P'.actice, the penod for depreciation unit was physically in the control of (
1975, at which time all equipment was with respect t such property begms; the owners who powessed all the legal performing its specifically assigned r (ii) the taxable year in which the attributes of ownership.
function, that is, operating as a unit pmpeyty a placed m a condition or Accordingly,in the instant case; the f readmess.and avai abihty for=' nuclear ~ electric ~ generating 66it was l
state
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even though equipment was still un-dergoing testing to eliminate any de-a speci6caUy ass,igned function.
. -..first placed in seriice"~en December,,
fects and to demonstrate reliability.
Section 1.46-3(d)(2)(iii) of the - 23, 1975, for depreciation and invest J All critical tests necessary for power reggiations provides, in part, that rnent credit purposes. Therefore, the l.
operatien were perfonned prior to De.
equipment arquired by a taxpayer for taxpayer is entitled to deduct 6 months d tation and to claim the invest- }
cember 23,1975. 'Ilere was a partial a specifically assigned function in the de shutdown of the unit on December 24, taxpayer's trade or business that is ment credit on its 1975 Federal in-l 1975, which was due to an abundance operational but is undergoing testing come tax return with respect to this '
of hydro. generated electricity rather to eliminate any defects is considered u nit.
than to any problems concerning the to be in a condition or state of readi-Compare Rev. Rul.76-256, page 46, l
u nit.
ness and availability for a specifically. this Bulletin, which concerns when a o
coal-fired electric generating unit was {
The taxpayer elected to apply the. assigned function.--
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' provisions of section 1.167(a)-11 -of Section 1.167(a)-11(c)(2)(iii) of first placed in service for depreciation,
the Income Tax Regulations concern-the regulations provides, in part, that and investment credit purposes.
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'T Q (- $Q l TESTIMONY OF HERMAN M.
DIECKA e
BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION
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9 I-79040308 et al I am President and chief operating officer of General Public Utilities Corporation and a director of each of the three public utility subsidiarir.s of GPU that are the owners of the Three Mile Island nuclear generating station.
On April 23, 1979, I presented testimony relating to the Three Mile Island Unit No. 2 accident to the Subcom-mittee on Nuclear Regulation of the U.
S.
Senate Committee on Environment and Public Works.
A copy of the prepared statement that I submitted to that U.S.
Senate Subcommittee is attached, as well as a memorandum and an attachment giving a p reliminary analysis of the time sequence of the
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accident.
I shall orally summarize the ma.terial. contained in those documents.
I should also like to comment on the allegation that has been made that THI-2 was prematurely declared to be in commercial service.
Implicit in this allegation ds the incorrect assumption that a declaration'that a nuclear generating unit is "in commercial service" governs its physical operation.
That assumption is contrary to fact.
The NRC has pointed out that the timing of beginning of physical operation of a nuclear generating unit and the circumstances of such operation are governed by the NRC l
operating license and have nothing to'do with whether the unit has been declared to be "in commercial service."
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2-In the case ol TMI-2, the k
operating license wa s issued by the NRC February 8, 1978.
The physical on opera-tions of TMI-2 were determined by that operating license and by the technical specifications which it incorporated.
The declaration of a generating unit as being "in commercial service" is an accounting and ra t ema king concept which was discussed at length with this Commission over a period of several months in 1978.
For example, en February 17, 1978, there was oral argument before the Administrative Law Judges in Met-Ed's then pending rate case at R.I.D. 434 concerning the a p'pr op ria t e criteria for a declaration of " commercial service".
There was oral. argument before the Commission itself on May 10, 1978 in that
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proceeding dealing with the same same h
subj ec t.
There was further discussion of the subject at the June 23, 1978 Annual Review meeting with the Commission concerning Me : -Ed following,the conclusion of that proceeding.
As a result of that discussion at the Annual Review, I sent the Commission a letter, dated July 19, 1978, reporting on the TMI'2 start-up and test status.
Sub-s eq uently Mr. Kuhns sent a letter, dated August 11, 1978, to the Commission pointing out that the Uniform System of Accounts and decisions applying that System defined the time for declaration of, commercial L
service as the time when 1
a unit is " ready for service",
even though clean up construc-tion has ndt been j
completed nor full capacity utilization achieved.
Copies of both of these letters are annexed.
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I dorbt that the declaration of the commercial in-service dats of a particular generating unit has ever received.as much attention from so many sourcea as was the case for THI-2.
We have sought to make clear that our view of the appropriate time for the declaration was the successful completion of a long series of tests and we invited the Commission, its Staff and the Of fice of the Consumer Advocate to witness such tests, if they desired.
Those tests were outlined in the 25-page Exhibit No. E-21 p resented by Mr.
R.
C.
Arnold in R.I.D.
626.
On November 30, 1078,' Mr. Kuhns wrote to both+your Commission and the New Jersey Board, with copies to the Consumer Advocate in both jurisdictions, giving a status
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report on the unit.
A copy of that letter is annexed.
The additional tests contemplated by that' letter were completed ou December 28, 1978, and during the next two days the, unit was brought up to approximately full power and declared to be in commercial service.
During the closing stages of the Met-Ed rate case, no one suggested that the declaration that THI-2 was in commercial service was premature or sought to exclude THI-2 from rate base.
Indeed. the Consumer Advocate had sought to exclude portions of Met-Ed's investment on the alleged ground that THI-2 should have been completed at an earlier I
date.
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- I There have also bean suggestions that income tax considerations dictated the physical cperation of the unit.
This is also not true.
As.1 previously pointed out, the physical operation of the Unit isigoverned by the NRC operating liennse; it is not afLected by the question as to e f
- whether or not depreciation deductions or investment tax tak>en credits may be for income tax purposes.
I am not an expert on the income tax laws and regu-
.q 1ations.owhich have their own special rules and. conventions.
However, I was informed, in 1978, by GPU's tax department that TMI-2 would qualify for liberalized depreciation deduc-
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tions and investment tax credits in 1978 whether or not THI-2 was declared to be in commercial service for Uniform System of Accounts purposes.
In other words, there are three separate criteria to be consid ered :
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For physical operations p u r p*o s e s, a nuclear unit may be oper..ted once an NRC operat-o ing license has been issued.
The particular power level at which the unit is operated is determined by the terms of that operating license and compli-i ance with the technical specifications which are made a part of that operating license; l
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5-l 2.
For accounting purposes, a nuclear 1
generating unit is to be declared to be in com-mercial service and to be transferred from CWIP j
to plant in s e rvic e (with the correlary that C
AFUDC accruals and capitalization of taxes and certain other costs stop) when the Unit is " ready for service" after a reasonable test period for which the FERC standcrd is not more than 120 days, unless the facts justify a longer period; and 3.
For income tax purposes, depreciation deductions may begin and investment tax credits may be taken even though the unit has not been declared to be in commercial service for Uniform System of Account purps
.s.
Satisfaction of the first criterion, namely, obtain-ing the NRC operating license, will always precede, and be indispansable to, satisfaction of the second and third criteria.
Moreover, satisfacticn of the third criterion may occur prior to satisfaction of the second criterion.
In summary, well in advance of the event, we set forth the detailed steps to be taken leading to a declara-tion of commercial service f or TMI-2.
Over a period of i
many months we sought to present to the Commission and to ll 1
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the parties to the rate proceedings of Met-Ed and Penelec
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the various considerations and factors bearing upon the transfer THI-2 i
determination of the appropriate time to in Service'an'd the accounting and i
from CWIP to Plant action.
We periodically financial consequences of that reported on the progress of testing and invited the wit-1978 declaration on December 30, nessing of tests.
The was consistent of TMI-2 as being in commercial service with the criteria that had previously been presented to i
the Commission.
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l METROPOLITAN EDISON COM P A N Y s wi.,y o, c.o.,.i eene u,inii., co,,,,,io.
Subject Amendment No. I to DPR-73 Location Three Mile Island Date December 3, 1979 To M. F. Travieso-Diaz, Esquire During my deposition taken by the NRC/TMI Special Inquiry Group on September 24, 1979, I was asked certain questions concerning Amendment No. I to the Three Mile Island Unit 2 Facility Operating License No. DPR-73 issued by the U.S. Nuclear Regulatory Commission on March 3,1978 (reference transcript pp. 127-130).
The first question (p. 127, lines 12-14) implied that the Amendment permitted the postponement of certain hydrostatic tests.
Such was not the case, the Amendment did not permit the tests to be postponed, rather it allowed the tests to be performed at temperatures and pressures other than those originally provided in the Technical Specifications.
The next question related to the delays which would have been occasioned by f ailure to obtain the change or modification in the Technical Specifications (p. 128, lines 5-7).
In this regard, adherence to the original Technical Specifications in conducting the hydrostatic testing would have required the removal of the fuel from the pressure vessel because the testing temperatures and pressures could not be met with fuel in the vessel. This would have caused a delay up to six weeks.
However, it is important to recognize the distinction between the hydrostatic test covered by ASME Section III (called for in the Technical Specifications) and the hydrostatic test contemplated by Metropolitan Edison Company for which Amendment No. I was requested.
The Section III test is an initial system test and constituted a full and complete hydrostatic test. With respect to TMI Unit II, the Section III test was completed and accepted by the inspector on June 3,1977. The test for which Amendment No. I was requested was a " leak" test which was to be performed because certain new mechanical pressure boundaries were established following the Section III test.
The new mechanical pressure boundaries are described in the
" Discussion" of the Safety Evaluation by the Office of Nuclear Reactor Regulation Supporting Amendment No. I to Facility Operating License No. DPR-73, a copy of which is enclosed.
Since the Section III test had been completed, ASME Section XI was applicable to the intended test under Amen 3 ment No. 1.
Section XI allows alternate test temperatures and pressures, lacluding the temperature and pressure permitted under knendment No. 1.
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INTER-OFFICE MEMORANDUM
I M. F. Travieso-Diaz, Esquire December 3, 1979 One of the considerations for perforring the test at a lower temperature was the ability to locate leaks, if any, more precisely in a non-steam environment.
If tests are conducted at temperatures above the boiling point, P.he leakage immediately evaporates at the point of discharge from the pressurized system. Unless the leak is sufficient to create a general steam atmosphere in the vicinity of the leak, the leak may not be able to be identified because of the absence of water accumulation. When the test is performed at a temperature lower than the boiling point, the area of the leak is easier to access and the point of discharge likewise is easier to locate.
Since the ASME Codes could be met, and Babcock & Wilcox ascertained that the tests could be performed safely within the proposed temperature and pressure i parameters, the variances from the Technical Specifications sought in Amendment No. I were appropriate.
l,s ri I(ANW R.C.prnold RCA:rt Enclosure l
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