ML19346A248

Forwards Hd Hukill 810506 Ltr to NRC Describing Tests of Power Operated Relief Valves & Block Valves Re Ucs Motion to Reopen Record on Testing

ML19346A248
Person / Time
Site:	Three Mile Island
Issue date:	06/01/1981
From:	Baxter T METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Cutchin J, Smith I, Weiss E HARMON & WEISS, Atomic Safety and Licensing Board Panel, NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
References
NUDOCS 8106050471
Download: ML19346A248 (5)

Text

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Ivan W. Smith, Esquire -

Ellyn R. Weiss, E'squirek .

Chairman . Harmon & Weiss Atomic Safety and Licensing Board 1725 Eye Street, N.W.

U.S. Nuclear Regulatory Commission Suite 506-Washington, D.C. 20555 Washington, D.C. 20006

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James M. Cutchin, IV, Esquire Office of the Executive Legal Director U.S. Nuclear Regulatory Commission l Washington, D.C. 20555 In the Matter of Metropolitan Edison Company Docket No. 50-289 (Restart)

(Three Mile Island Nuclear Station, Unat No. 1)

Dear Chairman Smith,

Ms. Weiss and Mr. Cutch,n: 3 on May 26, 1981, the Board initiated a telephone 950 S conference in connection with its consideration of the out-

! standing UCS motion to reopen the record on PORV block valve fl testing. The purpose of the conference was for the Board to pose a request to Licensee for information on any block valve testing to be performed at TMI-l prior to restart. The Licensee participants in the conference were unable to provide the infor-mation sought, so we were invited te initiate another telephone conference as soon as the information was assembled.

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SHAW, PITTMAN, POTTS & TROWBRIDGE Ivan W. Smith, Esquire Ellyn R. Weiss, Esquire James M. Cutchin, IV, Esquire June 1, 1981 Page Two By letter of May 6, 1981 (LIL 134) from Mr. Hukill of Metropolitan Edison Company to Mr. Stolz of the NRC, Licensee described its low power test program for the restart of TMI-1.

I have enclosed a copy of that letter, and the portion of the Restart Test Planning Specification (two pages of a thirty-five page attachment to the letter) which describes the tests of the PORV and its block valve.

The Restart Test Planning Specification indicatas that the block valve will be cycled with the PORV open to confirm its ability to close against flow. There is no intent to pass solid water /two phase steam.

I have decided that the provision of this available written material would be more efficient than an attempt by me to describe the test in another telephone conference. I trust the Board will inform us, howaver, if it has further questions.

Sincerely, Thomas A. Baxter Counsel for Licensee TAB:jah Enclosures cc: per Certificate of Service attached l

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f/etropolinn Edison Cornpany

.f g [e- '.*, Post Office Box 480 E=~- Middletown. Pennsytvania 17057 writer i cirect oiai Numme May 6 , 19 * (c ,

LlL 134 4 Office of Nuclear Reactor Regulation j g Attn: John F. Stolz, Chief g %J Operating Reactors 3 ranch No. 4 E MAy 2 6198l >

U. S. Nuclear Regulatory Cc =tission - =-9' Washington, D.C. 20555 S. P. P. & T.

Dear Sir:

I *- 6 Three Mile Island Nuclear Station, Operating License No. DPR-50 Unit 1 (T h Y Docket No. 50-289 Special Low Power Test Program By letter dated January 23, 1981, your office recuested that we describe our low power test program for the restart of TMI-1. In response to your letter we proposed to submit our Restart Test Planning Specification which includes the low power test program. The Restart Test Planning Specification is attached. r The source of the NRC's requirement for a pre-operational and special low power test program is identified in NUREG 0660 and NUREG 0694. No detailed guidance is contained in either NUREG 0660 or NUREG 0694 concerning the expected scope of the program. Early discussions with the NRC staff indicated that we should review the programs proposed by TVA for Sequoyah and by VEPCO for North Anna-2. It was further indicated to us

• hat the focus of NRC interest was primarily for operator training and plant perfor=ance demonstrations durbg natural circulation. This guidance is incorporated in the TMI-1 Restart Program.

On April 22, 1981, we met with = embers of the NRC staff's Procedures and Test Branch. At this =eeting we provided a description of our restart test program, and we explained that our Restart Program has three major aspects. The first aspect is our Preventative Maintenance Program. A full-time staff now conducts this on-going program which assures that equipment is maintained and surveilled while shutdown, during operation, and for startap. Equipment and systems beyond that covered by the plant Technical Specificatiens is included in this program. During the current extended shutdown, a heavy emphasis has been placed on maintaining all plant equip =ent in a proper layup condition and ready for return to operating service at any ti=e. For example, during the shutdown, plant systems have been operated within the restrictions of the shutdown order and Technical Specifications. All Reactor Coolant Pumps have been run, Control Rods have been exercised and the secondary system (condensate, condenser, and circulating water systems, etc.) have been run to permit equipment check out and coerator training. Primary and secondary plant water chemistry procedures and limits that consider long term shutdown conditions have also been used to mini =ine chemistry related degradation of systa=s and components.

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\J ohn F. Stolz, Chief :LlL 134 s

The second aspect of the Restart Program is the Technical Specifications -

surveillance program. During the shutdown,-this program has centinued and checks of systems required for the shutdown mode have been performed. During restart, the operability of systems and components required to be operable will be confirmed in accordance with Technical Specifications by conducting ,

the approved surveillance precedures.

The above two programs are not unique to this restart; rather they have been and will continue to be an integral part of the operation of TMI-1. Furthe r=o re ,

we anticipate -that these programs will continue to be modified as reasonable i=provements arm identified. The NRC Regional Office of Inspection and Enforce-ment has observed and-inspected these programs from time to ti=e since TMI-l was initially started in 1974 and will continue to do so.

The third aspect of the overall Restart Program is summarized by the attached Restart Test Planning Specification (RTPS) . The RTPS does not include a listing of the elements of the above two programs unless the timing.of the surveillance or maintenance is important to the sequence of the restart or testing and surveillance can be conducted in unison. The RTPS is a controlling tect listing for the third aspect of restart. Detailed acceptance criteria are defined in the-actual test procedures. The RTPS may be changed from time to time and an up-to-date copy will be maintained available to the NRC onsite.

As explained in our meeting of April 22, 1981, each of the tests to be conducted for the restart will be conducted in accordance with the approved Master Test Index (MTX) and specific Test Procedure (TP) . Many of these procedures will be adapted from procedures conducted as part of the original scartup of IMI-l in 1974. At this time we do not believe that any of the tests to be conducted, constitute an unreviewed safety question or involve changes to tha Technical Specifications except 'for the natural circulation tests done at power (3-4%

i power) and those related to modifications which are discussed in Section 11.0 of the TMI-l Restart Report. Final determination of unreviewed safety questions and Technical Specification Changes will be made as the TP and MIX are approved.

NRC approval will be obtained if needed, as required by Technical Specifications.

Tha RTPS tables contain one column which requires some clarification. This column is entitled " Commitment Source". For each test in the RTPS ve have attempted to identify the source of GPUN's Co=mitment to perform the' test and/or the NRC source document which specifies the test. In the absence of any external documented commitment / requirement "Startup requires" is inserted in this column raflecting our own management asssessment and commitment.

Part III, Item 14 of the RT?S sjecifies the natural circulation tests to be per-formed. The tests are furth2r clarified in the attached test abstracts. The safety analyses necessary to justify these tests have not yet been completed.

On the basis that similar tests have been conducted at Sequoyah and Davis-

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L 3 esse-1, we anticipate that adequate justitication can be provided to demonstrate that these tests can be safely conducted. We will make available .che necessary safety analyses and supporting Technical Specifications for NRC review and approval.

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sonn :. stolz, Chief Lit 134 a . ]

s Tha overall rastart program hoc b0in r;vicw;d end davalopsd in light of tacts .

perfor=ed as part of the original startup program prototypical tests at other B&W reae: ors, TMI-2 Lessons Learned and other source documents. Unless an identified need existed such as =odifications, need for training, need for reference data to substantiate operational analyses, and/or to exercise revised procedures, tests conducted for the original startup have not been repeated.

Other fac: ors which influenced the selec: ion of tests were the value of the test and the need to minimize unnecessary cycling of :he plant or plant systems.

In =any instar.ces plant components are designed fcr a limited number of cycles.

For exanple, the number of EFW actuations under hot conditions has been minimized to as few as possible by. carefully planning the tests and test sequences of the emergency feedwater modifications and natural circulation training tests.

In conclusion, we believe that the above program is comprehensive and vill assure that TMI-l is restarted in a prudent and acceptable manner.

Sincerely,

. s I .

H. D. kill Director, TMI-l HDH : L'4:l=a A::achments ,

cc: R. Jacobs w/o Enclosure H. Silver w/o Enclosure D. Fischer w/ Enclosure .

D. DiIanni w/o Enclosure L. Barrett w/ Enclosure

3. Grier w/ Enclosure -

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, Section 1 - Trit #1 Restart Test Planning Specification Table ,

Plant Comnittment , .

ikid / System /Subj ec t Status Source Test Scope Acceptance Criteria Remarks R11- Pre-op Startup Computer Group to Checkr.ut Printer operates satis- No Startup Involvement or Computer trods- .equires operation of high-speed factorily, procedures planned.

Ill gh-si.m :' printer.

Printer Rt! Raise Pre-op Startup Calibrate per liet-Ed SP per SP tict-Ed SP .

S team Cenc ra toi requires I.evel Trans-mitter lilt Startup Compare OTSG level indicators Indicators are within NNI Ilot op Cal - TP 657/1, requires during heatup. acceptable tolerance. HTX 152.5.3.6.

Pre-op Startup Calibrate PORV per liet-Ed Setpoint is within h Rti-9 - Raise Setpoint of requires Procedure acceptable tolerance Power Operated of 2450 psig.

Relief Valve (PORV)

Rti PORV lilt Restart Re- f.ift PORV at hot functional 1).PORV Flow Indication and Safety port, Sect. conditions to: Functional Test -

Valve Position 2.1.1.2.3, TP 664/1,FifX 195.5.1.6.

1) verify adequate response 1) PORV lift & rescat Indication und Amand. 18 f accoustic monitor is atlequately dis-1.t!- flanual played by the ac-Operation of 12/11/80 c ustic monitor, I'ORV f rom Con- Ictter ACRS trol Room and to NRC Com- 2) Elbow tap range and

2) verify adequate response Pfl PORV missioners

>w w tap n sensiti d y are ade-Tailpipe Temp. and lack of response on quate to determine s code safety valve elbow PORV lift /rescat &

taps. Interference with code safety elbow taps is at accept-ably low level.

Page 6 of 35

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, Section 1 - TML #1 Restart 'lest Planning Specification Table .

Plant Committment .- .

tkid/ Syst em/Subj ec t Status Source Test Scope Acceptance Criteria Remarks Ril-10, contfd. 3) verify acceptable temp- 3) Temperature response erature response of PORV of PORV tailpipe tailpipe thermocouple and tem,serature is with-magnitude of interference in the allowable res,,nse of code safety band on the tempera-valve ta11 pipe thermo- ture response curver couples. Compare responso in Restart Report of thermocouples during and TDR 238, an?

valve opening and after effect on code closure against curve safety tailpipe referenced in kestart thermocouples is at Report, Sup. 1, Part 2, an acceptably low Question 36, and contain- level, ed in TDR #238.

. 4) Observe response of RCDT 4) RCDT and tailpipo

and tailpipe thermo- thermocouple instru-l couples during/after PORT mentation can be lif t; document sensitivity used to indicate of RCDT and tailpipe . PORV/ safety valve thermocouples instru- leakage.

mentation to detect PORV lift / leakage.

5) Verify operability of 5) Hanual switch func-manual switch to open/cis tions acceptably. ,

PORV from control room.

6) Verify ability of PORV 6) Block valve closes Block Valve to close, tiles against an open PORV open against an open PORV RM Pre-op Startup llydrogen Re- requires Functionally test the recom- liydrogen Recombiner Functiona 4

! combiner biner to verify proper opera- . Test, TP 243/1 Llon of: 'ItTX 285.5.1.6.

Page 7 of 35

LIC 6/1/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

) .

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear ) ,

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing letter from counsel for Licensee dated June 1, 1981,with attachment, were served this 1st day of : Tune, 1981 by deposit in the U.S.

mail, first class, postage prepaid, to the parties identified on the attached Service List.

9

.=

Thomas A. Baxter e

UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSIliG BOARD In the Matter of )

)'

METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esquire John A. Iavin, Esquire Chaiman Assistant Counsel Atmic Safety and Licensing Pennsylvania Public Utility Cmmission i Board P.O. Box 3265 U.S. Nuclear Pegulatory Cmnussion Harnsburg, Pennsylvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Robert Mler, Esquire Atmic Safety and Licensing Assistant Attorney General .

Board Panel 505 Executive House-881 West Outer Drive P.O. Box 2357 Oak Ridge, Tennessee 37830 Harrisburg, Pennsylvania 17120 Dr. Linda W. Little John E. Minnich Atmic Safety and Licensing Chai-n, Dauphin Cbunty Board Board Panel of Cmmissioners-5000 Hemitage Drive Dauphin County Courthouse Raleigh, North Carolina 27612 Front and Market Streets Marrichurg, Pennsylvania 17101 James R. Tou M lotte, Esquire Office of the Executive Iagal Director Walter W. Cohen, Esquire U.S. Nuclear Regulatory cemnicsion Consuner Mvocate Washington, D.C. 20555 Office of Consuner Mvocate 1425 Strakterry Square Docketing and Service Section Marriahurg, Pennsylvania 17127 Office of the Secretary U.S. Nuclear Regulatory C mission Washington, D.C. 20555

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1 Jordan D. Cunningham, Esquire Ibbert Q. Pollard 2320 North Second Street 609 Mantpelier Street E rrinburg, Pennsylvania 17110 Baltimore, Maryland 21218 Ms. Iouise Bradford Chauncey Kepford D E'ALEIE Judith H. Johnsrud 315 Peffer Street Envircrunental rnalition cm Nmlaar Power j Harr4=hurg, Pennsylvania 17102 433 Orlando Avenue State College, Pennsylvania 16801 El'.yn R. Weiss, Esquire Harmon & Weiss Marvin I. Iawis ~

-1725 Eye Street, N.W., Suite 506 6504 Bradford Terrace Washington, D.C. 20006 PhilaAal @ , Pennsylvania 19119 Steven C. Sho11y Marjorie M. Aamodt Unicn of ConmM Scientists R. D. 5 1725 Eye Street, N.W., Suite 601 Coatesville, Pennsylvania 19320 Washington, D.C. 20006 2 xmas J. remim, Esquire Gail Bradford Deputy At*wrney General ANGE Division of Law - Pocxn 316 245 West Philadelphia Street 1100 Paymond Boulevard York, Pennsylvania 17404 Newark, New Jersey 07102 William S. Jordan, III, Esquire Ha m & Weiss

4 1725 Eye St.seet, N.W., Seite 506 Washington, D.C. 20006 .

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