ML19323C418
| ML19323C418 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/05/1980 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0667, RTR-NUREG-667 E&L-2364, NUDOCS 8005150506 | |
| Download: ML19323C418 (4) | |
Text
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8005150 366 GPU Service Corporation eWke 100 Interpace Parkway t.-
Parsippany, New Jersey 07054 201 263-6500 TELEX 136-482 Wnter's Direct Dial Number:
File: 2259.10 May 5, 1980 E&L-2364 Mr. Harold R. Denton Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Denton:
SUBJECT:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Docket Number 50-289 Operating License Number DPR-50 Comments on NUREG-0667 Enclosed are comments on the twenty-two recommendations made by the B&W Reactor Transient Response Task Force in NUREG-0667. These comments were presented orally at a meeting with the Task Force on April 23, 1980.
As a general comment, we believe that these recommendations should be part of an overall action plan and schedule which establishes integrated priori-ties for accomplishing these and other actions. The schedules should re-flect the risk reduction potential of each item with respect to all other items and recognize the extent of manpower and materials necessary and available to accomplish them.
Very truly yours,
/
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P. R. Clark Vice President - Nuclear Activities PRC:CWS:bjo Enclosure cc:
R. A. Capra D. Dilanni R. L. Tedesco N
H. Silver ON l
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GPU Service Corocration is a subscary of General Pubhc Utahties Corporation
O 1.
Comment Met-Ed has committed to upgrade the TMI-l Emergency Feedwater (EFW)
System to meet the requirements of NUREG-0578, Section 2.1.7.a.
The IMI-l Restart Report, Supplement 1, Part 3, Response to Question 4 provides a conceptual description and best effort schedule for upgrading this system.
In order to achieve a coordinated system, it is important that the EFW System be upgraded as a package rather than on a piecemeal basis. There-fore, Met-Ed plans to accomplish resolution of Recommendations 2 and 4 as part of the overall upgrading. We encourage the NRC Staff not to force upgrading on a piecemeal basis.
It should be noted that it may not be necessary to require full up-grading to SRP 10.4.9 in order to achieve high reliability for the EFW system.
In some instances, it may be necessary to exclude reliable equip-ment and choose less reliable equipment in order to meet an arbitrary schedule or to purchase " qualified" equipment. This is particularly true for control valves where a less desirable on/off rather than modu-lating control may be selected in order to meet some special qualification requirement. We request that the NRC Staff consider this in developing schedules and requirements for all plants.
2.
Comment See comments on Recommendation No. 1 above.
3.
Comment Not applicable to TMI-1.
4.
Comment See comments on Recommendation No. 1 above.
1 5.
Comment Met-Ed is addressing this recommendation as described in our responses to Crystal River incident (Met-Ed letters dated March 13 and March 17, 1980).
In addition, we understand " gross failures" in control systems to be loss of power supplies or failures that may cause opening of the PORV or other simi-lar major disturbances.
6.
Comment Met-Ed agrees with the philosophy of establishing a set of principle parameters to be used by the operator to respond to accidents and major transients.
It should be recognized that the existing instruments at many plants, including TMI-1, are already of high quality and are extremely reliable (once the power source is improved). Adding an additional safety grade set of instruments to the control room would not significantly im-prove reliability and would serve to further complicate the control room.
The need to make these instruments safety grade should, therefore, be con-sidered on a case-by-case basis.
6
o.
7.
Comment Met-Ed has already improved the usability of the incore thermocouples by providing computer readout trending and saturation margin computation.
Adding another input to the Saturation Indicator is unnecessary and unde-sirable.
8.
Co.mment This recommendation is overly prescriptive. Other methods to isolate containment vent and purge are available, and are more reliable than high radiation signals. The NRC should recommend criteria to be met rather than engineer fixes.
The TMI-1 vent and purge is isolated on all reactor trips (manual or automatic) at 4 psi Reactor Building Pressure and by control grade high radiation signal. We believe this system is more reliable and would meet the NRC Staff's criteria.
9.
Comment We concur with this recommendation; however, this recommendation and Recommendations 11 and 19 should be considered as a package. Recommenda-tion 19 should be pursued first and then Recommendations 9 and 11 can be resolved logically.
10.
Comment We believe the best approach to this recommendation would be to con-duct a review of operating experience on a plant-by-plant basis and make improvements as indicated to reduce the number of transients and reactor trips and to eliminate other abnormal performance. Experience could also be used from other B&W plants to the extent that it is applicable.
Sen-sitivity studies would not be necessary if experience were continuously reviewed for areas for improvement considering that the performance cri-teria of Recommendation 19, if met, would provide acceptable performance.
11.
Comment See comments on Recommendations 9 and 10.
12.
Comment This recommendation should be considered in light of the similar re-commendations of NUREG-0654. A technician on duty would be unlikely to be able to identify and correct a malfunction rapidly, unless, it was a result of I6C testing or maintenance activities. Therefore, having a technican available on short notice (but not necessarily on shif t), except during maintenance activities, would provide adequate coverage.
- 13.
Comment Operator training on the CR-3 event and ICS/NNI Emergency Procedures will be complete before restart of TMI-1.
14.
Comment It is unlikely that B&W can develop guidelines on a generic basis for its plants, since there are so many differences between the plants' ICS/NNI systems.
In addition, TMI-l and other B&W plants have, or soon will have, the necessary procedures in place.
15.
Comment At least one week of simulator training will be accomplished as part of the normal requalification program for the TMI-l operators.
Comment NRC Staff action.
17.
Comment NRC Staff action.
18.
Comment NRC Staff action.
19.
Comment We are interested in participating in the development of the performance criteria. We believe that the NRC Staff should give this high priority.
Also see comments on Recommendations 9 and 10.
20.
Comment We concur with this recommendation.
21.
Comment We have studied the effect of EFW injection, both high and low, in the Steam Generator using our TMI-l RETRAN model. We have concluded that plant performance in unaffected by the EFW injection point, except that natural circulation is reduced by bottom injection. We understand that B&W has reached the same conclusion using their computer model. Based on this, this recommendation need not, and should not, be further pursued so that other important studies can be conducted.
22.
Comment NRC Stuff action.
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