ML19344E659
| ML19344E659 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/22/1980 |
| From: | Sweeney L JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Vollmer R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8009020421 | |
| Download: ML19344E659 (19) | |
Text
.
e Jersey Central Power & Ught Conioany Madison Avenue at Punch Bow! Road Mornstown, New Jersey 07960 (201)455-8200 August 22, 1980 Mr. Richard H. Vollmer Director, Three Mile Island-2 Support Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Co=missien 7920 Norfolk Avenue Bethesda, MD 2001h Re: NRC Docket No. 50-289 - TMI-1 Restart Proceeding
Dear Mr. Vollmer:
By your letter dated September 21, 1979, to R. C. Arnold, and Mr. J. C.
Petersen's data requests sent to C. W. Smyth on November 9,1979, you requested us to keep the NRC informed of significant regulatory developments affecting the GPU compenies. Accordingly, the enclosed material (8 copies) has been sent for that purpose.
Enclosed are exhibits JC-G and JC-H and an index of exhibits which vere filed on August 20 and 21 in Docket No. 807 h88.
Very truly yours, W
Lawrence E. Sweeney h
Rate Department rc Enclosure ec:
L. P. Gentieu (v/o ene)
M. Karlovic:: (w/ene)
J. C. Petersen (w/ene) 0$
0 1
game.
THIS DdCUMENT CONTAINS POOR QUAUTY-PAGES
//
8 0 09020 8j at Jersey Central Power & L:gnt Comoany is a Member of the General Puche Utilittes System
Exhibit No.
JC-G Witness:
Date:
8/20/30 Page 1 of 11 JERSEY CENTRAL POWER & LIGHT COMPANY NJ BPU Docket No. 807-488 LEAC Increase Request Filed 7/21/80 This exhibit provides a short summary of the status of TMI-1, as requested by the parties at the discovery meeting held at GPU on July 24, 1980.
The summary is in two parts. Part One reviews the regulatory status of the unit, and Part Two the technical and procedr ral modifications that must be made before the unit returns to service.
As the st.mmary indicates, the July 1, 1931 TMI-l return date assumed in the LEAC filing is likely to slip to September 1981.
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Page 2 of 11 TilREF. MILE ISI.ANI) UNIT.'O.
I STATUS REVIEW (as of August 1960) gg PaRT ONE - REGULATORY STATUS The TM1-1 r,estart proceeding (NRC Docket No. 50-289) represents the most extensive evaluation of a licensed nuclear power plant in history. The initial Order by the NRC Commissioners to maintain the TMI-l reactor in a shutdown condition was issued on July 2, 1979. Approximately one month later on August 9,1979, the NRC issued a second Order detailing the issues which had to be satisfactorily addressed to assure that the public's heOlth and safety would not be jeopardized by the operation of TMI-1.
In that Order, the NRC assigned an Atomic Safety and Licensing Board ( ASL3) to conduct a full public
- r. caring to develop a co.splete record on these issues, as well as other issues submitted by intervenors.
In the August 9 Order, the NRC also recognized the A
need to conduct the hearing expeditiously and provided a suggasted schedule for consideration by the ASLB.
This schedule is shown on Attachment A.
The scope of the August 9 Order was unprecedented.
In addition to those items that were required of all Babcock and Wilcox reactor owners as well as other reactor owners, the order required a number of significant issues unig to TMI-l to also be examined. These issues include a complete re-evaluation of the management and resources available to operate TMI-1, the radioactive waste management capabilities at TMI-1, and the financial capabilities of the TMI-l owners, all of which are no rmally addressed prior to the initial granting of a nuclear unit's operating; license. Additional issues to be addressed include functional separation of TM1-1 f rom TMI-2 and the adequacy of TMI-l's emergency plans and. preparedness.
The totality of these issues, as well as the specific content of each issue, were beyond the scope of the original licensing f=s proceedings for either TMI-l or TMI-2.
Page 3 of 11 A
The participation of the public and other parties as intervenors has also had a significant impact on the scope of the proceeding. As summarized in At tachment B, initially there were twelve parties who col-lectively proposed 123 contentions with approximately 273 identifiable parts for consideration by the ASLB..
Additionally, four Commonwealth of Pennsylvania and county agencies, as well as the SRC, expressed active interest in the proceeding. The sheer number of parties and the number and scope of proposed contentions luve created a substantial delay in the original schedule proposed by the SRC.
The discovery process has been extensive.
At tac hme nt C summarices the extent of discovery by the parties through June 1980. The prehearing, legal and discovery processes love narrowed, consoli-
.:ated or climinated issues to some extent, and as of mid-June, the original
. umber of contentions had been reduced to 48 with 14 still pending. As the I
prehearing activities continue, this number has been reduced further.
The final number of contentions is expected to be about 50 when the hearings begin, with several still pending in the areas of nuclear accidents more severe than design basis, and psychological stress.
The net ef fect of the intervenors on the scope of the hearings has been to raise several significant and unique issues beyond those outlined by the NRC in its August 9 Order. There are challenges to SRC regulations in the area of post-accident hydrogen generation, the general concept of design basis accidents and the value of considering general population psychological stress as an ele:nent of environmental impact.
The interpretation of technical regulations applied by the SRC Staf f has also been challenged in several areas that, although not unique to TM1-1, will be litigated in this proceeding.
A
Page 4 of 11 m
The net result of the NRC's restart proceeding on the TMI-l restart schedule has been to significantly extend the TMI-l shutdown. At present, the ASLB has yet to convene its first evidentiary hearing session.
The expanded scope of the issues and the number of parties will quite possibly result in a doubling of the original 335 day schedule envisioned by the.,RC Commissioners.
If the contentions to be addressed average only two days or' hearing time each, the latest estimated ccmpletion date shown on Attachment A ( April 15, 1981) would be extended to July 15, 1981. The extent to which tha merits of and facts relating to each contention will be developed on a two-day average will depend largely on the ability of the ASLB to keep the parties focused on the central issues.
Finally, the SRC regulatory process has never been a static process.
It
'~'
has constantly evolved as the number of reactors and their complexity have inc re ased. The TMI-2 accident has accelerated the process.
New requirements continue to be imposed on all reactors as the lessons learned f rom the accident are sorted out, prioritized and applied. These new requirements are being imposed on TMI-l and, depending on the implementation schedule required by the SRC, may further delay the restart of TMI-1.
A
Page 5 of 11 O
PART TUO - TECllNICAL STATUS The NRC Order and Notice of Hearing of August 9th directed that specific actions be completed prior to TMI-l's restart, including equipment modifications, development of, operating procedures, operator retraining and emergency prepared-ness. The following sections summarize the status of the actions required by the NRC Order.
Schedule for Restart The scheduling objective for TML-1 is to mec: all restart requirements and to be fully ready for initial heatup by the date that the NRC hearings are completed and ready for initial criticality when the NRC decision for restart is announced. The following milestones tuve been established to support this schedule:
\\
,as 3-10-81 c aplete secondary system modifications and draw condenser vacuum.
3-21-81 Fill and vent the Reactor Coolant System.
4-01-81 Preliminary heatup and cooldown for testing.
6-30-81 Integrated leak rate test of Reactor Building.
7-24-81 11catup for operation 8-21-S1 Initial criticality.
8-30-81 Close breakers for power generation Plant Modific tions The plar,t modifications planned for completion prior to the restart of TML-1 have been generated from the NRC August 9th Order, and from GPU's internal recommendations of modifications as a result of lessons learned from the TM1-2 Accident.
The NRC Order contains several sections relating to ecdifications. These sections cover the following source areas:
Section 1, O
items addressed by all B&'.i plants in their initial post-TMI-2 modification
Page 6 of 11 orders;.Section 2, items address 'in the NRC Of fice of Inspection and Enforce-
.A ment Bulletin Series 79-05; Section 3, emergency preparedness issues; Section 4; separation of TMI-152 to insure the unique recovery activities do not impact on' TMI-1; Section 5, issues related to the adequacy of waste management in light ' f the *TM1-2 Accident; and Section 8, issues derived from the NRC o
Lessons Learned Task Force report (NUREG 0578). NUREG 0578 separated the modifications into Category A, or modifications to be implemented prior to January'1,1980 and Category B, or modifications to be implemented by January 1, 1981. Since the restart of TMI-l will be delayed beyond January 1, 1981, all of the Category A and 3 modifications are presently considered restart prerequisites by the NRC.
Based on current engineering, material procurement and estimated construction schedules it is believed the majority of the longer term ' modifications could be completed during the first refueling following startup. This 'till be a subject of review with the NRC.
f.s The more significant plant modifications that will be completed prior to
. restart are as.follows:
A. - Upgrading ' of Decay Heat Removal System This modification will increase th'e reliability of the system should radioactivity from a reactor accident cause the system to be.
difficult to operate and maintain. Remote pump lubrication facilities and the ability _ to remotely vent the pumps will be provided.
B.
- Diverse Containment Isolation Signals Modification Additional signals will be provided.to help assure that radioactive materia 1Lis not tr.insferred out of the building following a nuclear
- )
8, m
L.
Page / ot 11 la the reac t.er t ri p, high raillat ion accident. These signals are with A
rei.ctor buildin3;, inittation of sataty injection colneident ecoling water support services line break, and low reactor coolant Various containment pressure or high reactor building pressure.
penetration lines will be automatically isolated depending on the initiating signal received.
Installation of High Speed Computer Printers C.
This will provide plant operators with more rapid access to alarm information by precluding alarm backlogging.
Power Operated Relief Valve (PORV) and Safety Valve Position Indica-D.
tion Modification This acdification replaces existing valve position indicators with more positive position indicators located in the Control Room.
E.
Hydrogen Recombiner of The purpose of this modification is to permit rapid employment the recombiners as a means of controlling combustible gas concentra-following a loss of coolant accident.
tions in containment Lipgrading of Emergency Feedwater System (EFW)
F.
This system is being modified so that:
Both of the motor driven CFW pumps automatically start upon loss 1.
of both.nain feedwater pumps or loss of all four reactor coolant pumps.
The motor driven KFW pumps are automatically loaded on the 2.
diesel generator during loss of of fsite power.
A
Page 8 of 11 n
3.
Indication of EFW flow to each steam generator is available in the control room.
4 Mapual control of the EFW flow to each steam generator independent of the plant Integrated Control System (ICS) is available to the operator in the control room.
G.
Pressurizer Heaters - Emergency Power Redundant emergency power will be supplied for the minimum number of pressurizer heaters required to maintain reactor coolant system pressure for natural circulation in the event of loss of offsite power.
H.
Saturation Pressure (PSAT) Margin Indicator and Alarm A
An instrument will be added in the control room to display the cargin between the actual primary system pressure and that lower pressure which could result in primary coolant boiling.
This meter and a coupled alarm will aid the operator in detecting conditions that could possibly lead to inadequate core cooling.
In addition to modifications to the facility, the NRC August 9th Order also required that certain non-modification (sof tware) changes be made and t ha t the management capability and financial capability be evaluated against new c ri teria tha t lave developed in the post-TML-2 period.
O,
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i-Page 9 of 11 L
M Sbnagerial Capability-(
l Amendment No. 20- to the ' Report in Response 'to NRC Staff Recommended Requirements for Restart of Three Mile Island Nuclear Station, Unit 1"'(The Restart Report) was filed with the NRC'on Friday, August 8,1980. This amendment updates the'TMI Station Organization and the TMI Station Support Organization, both of which are parts of the interim GPU Nuclear Group, and l
which will become the GPU Nuclear Corporation when all regulatory approvals are obtained. This organizational structure will significantly enhance the I
numbers of highly qualified _ staff members available ' to support TMI-I and will enhance the means of providing safety reviews and operational advice.
I i
Operator' Training The NRC has reviewed the modified training program now in place at TM1-1, and found it_ to be in compliance with the requirements of its August 1979 Order and'Nctice of Hearing.
l The operators of TMI-l'are currently preparing for the NRC's relicensing j
examinations, and will be scheduled for such examinations just prior to TMI-l's l-restart.
t i
Emergency Planning
'The new requirements - for emergency planning in the post-TMI-2 period are i
j contained in the proposed emergency planning rule recently promulgated by the F
NRC..
In addition,' _ further guidance is provided in NUREG 0654, " Criteria' Fo r
- Preparation and an Evaluation Of Radiological Emergency Response Plans And Preparedness.lu Support Of Nuclear Power Plants." The purpose of this l
i-r
[I e
i*an.
10 ut 11 galth line i ?.
to a id NHC I.i cennes. and rt.it e nid loca l goverinnent s in developing w
radiological emergency plans and improving emergency preparedness.
The guideline is the produc t of a joint Federal Emergency Management Agency (FEMA) and NRC Steering Committee established to coordinate the agency's work i'n nuclear pJ ant emergency preparedness. The cetailed criteria address organizational control, emergency response support and resources noti-fication methods and procedures, emergency classification systems, emergency communications, public information, emergency f acilities and equipment, accident assessment, protective response, exposure control, medical and public health su ppo r t, training and test exercises.
Metropolitan Edison submitted a revised emergency plan to the NRC for its review La June 1980.
Emergency plan implementing procedures have been developed, and training and test exercises are currently progressing. Planning for an A
emergency exercise to be conducted jointly with federal, state and local agencies is also underway.
The required upgradings of facilities for communicating with of fsite organizations and agencies has been completed.
Improvements to onsite communication facilities are being identified and scheduled for implementa-tion.
Onsite and of fsite technical and logistic support centers have been established with direct communication capabilities with plant operating personnel. Computer links and other improvements will be installed uoth before and af ter restart.
O
4 Page 11 of 11 gmy Radiological Controls Compliance with the portion of NRC's Order and Notice of Hearing pertaining
- o radiological controls has' been achieved except for certain plant modifica-tions and relatqd procedural changes identified 'in the Restart Report, which are in the process of being implemented.
2 1
Procedures Improvements Ef forts are continuing to upgrade TMI-l's operating and emergency pro-i cedures to incorporate the " lessons learned" f rom the TMI-2 accident, and to 4
_ provide the unit's operators with appropriate guidance for understanding and operating the plant improvements. There are approximately 1000 procedures to be developed Lor reviewed, and this -work is scheduled to be completed far enough in advance of restart to permit operator training in the new procedures.
A Radwaste Management i
All of the TMI-2 waste water stored at TMI-1 af ter the TMI-2 accident has been returned to TMI-2'for processing.
Some TMI-1 piping and storage tanks continue to be used as a path for transfer of routinely generated low activity waste water from,TMI-2 to the Epicor-1 treatment system. The transfers will continue until the TMI-l radwaste evaporators are returned to service. following minor modifications.
It is expected that by October 1980 the radwaste systems of the two units will-be separated. This will effectively complete the functional' separation of the units.
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PSYC010GICAL SIRESS, AND CtASS 9 ISSill S
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PETITIOdS'TO Ii1TEltVE!)E AtID COtlTE!1TIO!1S Early Contention Status'.
Current Contentlon Status Party Proposed Adini t ted Pending
- Admitted, Aar.odt
'12 (12)
-5 ( 5) 5 ( 5)
At:GRY 6
(34)
.4 '( 27) 4 (27).
.CI'A 15 ( 15 )
8 ( 8) 2 (2) 6 ('6)
L, EC::P 22 (67) 7 (27) 4 (20)
LD;IS 11 (11) 1 ( 1) l' ( 1) tiewherry 3
(48) 3 (40) 2 (2) 1 (38)
PA!!E 3
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Sholly' 17:
(49) 17 (47) 5 (5) 11 (41)
Ti1I A
.8
( 8) 7 ( 7) 2 (2)-
3 ( 3)
UCS 20 (20) 14 (14) 1 (1) 13 (13)-
-10 1]7 (267) 68 (178) 14.(14) 48 (134)
Rejected Partios Jane Lee
.2 Derryhill 4
Pa r t i c ij!an ts - - (Othe r s) 1
!!RC PaPilC PA Consumer Advocate Commonwealth of Pennsylvania Dauphin County
!!o te :
ilumbers in parenthesis reflect numbers of contentions when multiple subject con-
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tentions are broken into discrete components.
Most contentions were confined or reduced in scope between the proposed and admitted versions.
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h DISCOVERY RE00ESTS Valid Pa r tiy Questions Depositions Responses Objections GPU Interrogatories Aa mod t~-
72 0
49.
23-
- 8 43 A t1G R Y -
21 0
21 CEA 94 0
51*
43 20 ECNP.
0-
.0 0
0 97 '
LEWIS.
36 0
36 0
0 Newberry 44 0
44 25 0
PANE 18 0
18 Sholly 264-0 219 45 50 TMIA 133 23 (23) 113 20 65 UCS 188 1 ( 7) 159 29 34 PaPUC 11 0
11 0
0-Totals 881 24 721 160 342 Documents placed into the Discovery Heading Room total approximately 1/2 million pages.
- Partial objections filed Numbers in parentheses reflect personnel deposed.
IIEARING RECOI<D TO DATE:
800 individual filings amounting to about 10,000 pages.
3 50 ASLB. Orders and Memorandums.
6 Commission Orders.
32 r.
1N.
' Exhibit No.
JC-H Witness:
R. E. Steger Date:
8/20/80
- /"$ -
Page 1 of 2 JERSEY CENTRAL POO R & LICHT COMPANY JU BPU Docket No. 807-488 "LEAC Increase Request Filed'7/21/80 EFFECT OF PJM.SPECIAL PRICING ON JCP&L LEAC PERIOD SEPTEMBER,1980 - AUGUST,1981 From 3-21-80 FERC Submission:
PJM Prod. Cost Actual Adder Special Adder Special Benefit
~
Month S/MWH S/MWH S />ST S/5'M 7-79 25.9 11.2 2.6 8.6 c-79 31.0 11.0 3.1 7.9 9-79 33.5 10.7 3.4 7.3
("%
10-79 38.1 11~3 3.8 7.5 11-79 35.8 13.9 3.6 10.3 12-79 35.5 14.6 3.6 11.0 1-80 41.4 15.5 4.1 11.4 2-80 44.6 14.4 4.5 9.9
' Assume PJM'Special Benefit of $10/MWH Assume that the PL purchase, which ends when the PJM special begins, continues to flow'to CPU at the PJM rate of cost plus 10%
Ef fect on Jersey Central for LEAC period (see next page for monthly ef fect):
L PJM Special Savings
-341.8'CWH x S10/MWH = S3,418,000
.S1,678,000
/"%.
.PL Offset
.S16,781,000 x 107.
' =
Net Benefit to Jersey Central S1,740,000
Page 2 of 2 m
EFFECT OF PJM SPECIAL PRICING ON JCP&L LEAC PERIOD SEPTEMBER, 1980 - AUGUST, 1981 PL Purchase PL Purchase Net PJM Purch.
PJM Special Per Budget Savings @ S10/MWH Increase 0 10%*
Savings Month'
. GJH
' $1,000 GWH
$1,000
$1,000 S1,000 (1)
(2)
(3)
.(4)
(5)
(6)
(7)=(3)-(6) l 9-80 0
0 41.2-2201 220 (220) l' 10-80 66.6 666 41.2.
2201 220 446 11-80 10.5 105 41.2 2201 220 (115) 12-60 3.2 32 41.2 2201 220 (188) 1-81 90.2 902' 41.1 2659 266 636 2-81 69.1
'691 41.1
-b659 266 425 A
r 3-81 24.9 249 41.1 2659 266
( 17)
.4-81 0.7 7'
0 0
0 7
5-61 0
0 0
0 0
0 6 0 0
0 0
0 0
l 7-81 0-0 0
0 0
0 8-81 76.6 766 ~
.0 0
0 766 TOTAL 341.8 3,418 288.1 16,781
'1,678 1,740-C-Assumes PL Purchase ends and that the same energy -is transferred at the PJM
. rate of cost ~ lus 10%.
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~ JERSNY ' CENTRAL POWER & LIGilT COMPANY NJ BPU Docket.No. 807 488 LEAC Increase Requent Filed July 21, 1980 Index of Exhibits Distributed Prior to Initial llearing on August 20, 1980
-Energy Costs Exhibit JC-A
- Energy Cost Forecast..on'Which LEAC Filing is Based, July 1980 - August 1981 (filed with Petition).
JC-A.1
- ' Energy Cost Comparison, Actual vs. Forecast Energy _
Costs, April-June 1980 (superseded by Exhibit JC-A.1(a)).
JC-A.1(a)
- Energy Cost. Comparison, Actual vs. Forecast Energy Costs, April-July 1980.
JC-A.2
- PJM Running. Rates Estimated for the LEAC Period, Based on PJM Study Dated 7/22/80.
-JC-A.2(a)
- Oil: Cost Assumptions of the PJM Companies Based on a Sample of Typical. PJM Oil-Fired Units.
JC-A.3
- LEAC Period Oil Costs by Type and Sulfur Content; Actual vs. Forecast Comparison of 011_ Costs,
/m%
April-June 1980.
JC-A.3(a)
- Oil Cost Comparison, Actual vs. Forecast Cost of 011 Purchases by Fuel Type and Sulfur Content, April-July 1980.
-JC-A.3(b)
- 011 Cost Comparison, Actual vs. Forecast Cost of 011 as Burned by Fuel Type and Sulfur Content, April-July'1980.
JC-A.3(c)
- Actual and Projected Cost. of 011 Purchases by Fuel Type and. Sulfur Content, Year 1980 by Months.
JC-A.4
- Cas Costs and Quantities Forecast for the LEAC Period (Before Adjustments).
JC-A.4(a)
- Derivation.of Adjustments to Cas Costs and Quan-tities Forecast for the LEAC Period.
JC-A.4(b)
- Cas Cost Comparison, Actual vs. Forecast Cost-and Quantities of Gas Burned, April-June 1980.
l
~.
l Energy Costs (Continued)-
~
Exhibit JC-A.4(c)
-. Gas Cost Comparison, Actual vs. Forecast Cost
.fs and Quantities of Gas Burned, July 1980 and 4
~
Months - April-July 1980.
,JC-A.4(d)
- - - Gas Costs and Quantities Forecast for the LEAC Period as Adjusted; Estimated Energy Cost Savings Associated with Cas Adjustments by Months and Generating Stations.
JC-A.5
- Derivation of Energy Cos't Reductions Associated with LEAC Period-Sales Adjustments.
LEAC Increase D' termination e
Exhibit JC-B
- Derivation of Requested LEAC Increase (filed with Petition)
Charges to' Customers Comparisons Exhibit C-C
- Charges to Customers Comparisons, LEAC Currently in Ef fect vs. Proposed Increase; Rate Compari-sons, Jersey Central vs. Neighboring Utilities
- (filed with Petition).
JC-C.1
- Revision to Exhibit JC-C to Correct Error Affect-ing Determination of Overall % Increase in Charges
- r-N to Customers if LEAC Increase were Granted in Full.
Deferred Energy Costs Exhibit JC-D
- Projected Deferred Energy Cost Balances, With6and Without Requested LEAC Increase (filed with Petition).
JC-D.1-
- Actual vs. Forecast Deferred Energy Cost Balance, July 1980.
Sales Exhibit JC-E
- - Sales and_ Customers by FERC Classes, and Residential Use per Customer, Years 1980 and 1981 by Months.
l'
~
Oil Costs
-Exhibit JC-F
' - - Oil Suppliers, Delivery Locations, Contract Terms and Quantities, Forecast Methods, s
e s
8/19/80
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