ML19347D059

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Requests Response to ACRS Re Proposed Restart Status Review.Response Should Be Submitted within 30 Days
ML19347D059
Person / Time
Site: Crane Constellation icon.png
Issue date: 02/11/1981
From: Reid R
Office of Nuclear Reactor Regulation
To: Hukill H
METROPOLITAN EDISON CO.
References
NUDOCS 8103100642
Download: ML19347D059 (5)


Text

,;ei.v,([g UNITED STATES g

NUCLEAR REGULATORY COMMISSION

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February 11, 1981

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fir. Henry D. Hukill, Vice President t,,+p< /1/g[k and Director - TMI-l 78 g7 Q

Metropolitan Edison Company A

P. O. Box 480 c,'

Middletewn, Pennsylvania 17057 A

Dear Mr. Hukill:

p The Advisory Committee on Reactor Safeguards (ACRS) stated the results of its review of the status of the proposed restart of the Three Mile Island Nuclear Station, Unit No.1 (TMI-1) in its letter dated Decem-ber 11,1980 (Enclosed). The subject matter c' this review was covered during the 248th meeting, December 4-6, 1980 o. the ACRS with repre-sentatives of your. company, the Babcock and Wilcox Company and members of the NRC staff.

.The ACRS letter lists five connents based on its review. We request that you address these comments within thirty (30) days of the receipt of this letter.

Sincerely

, x, jN l l f. :2r-u Robert W. Reid, Chief Operating Reactors Branch #4 Division of Licensing

Enclosure:

12/11/80 ACRS Letter

'cc w/ enclosure:

See next 3 pages-4

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Metropolitan Edison Company,

.cc w/ecciosure(s):

Mr. Marvin I. Lewis Dr. Walter H. Jordan 6504 Bradford Terrace 881 W. Outer Drive Philadelpnia, Pennsylvania 19149 Oak Ridge, Tenressee 37830 Walter W. Conen, Consumer Advocate Dr. Linda W. Littl4 Department of Justice 5000 bermitage Drive Strawberry Square, 14th Floor Raleigh, ihrth Carolina 27612 Harrisburg, Pennsylvania 17127 Holly S. Keck Robert L. Knupp, Esq.

Anti-Nuclear Group Representing Assistant 5olicitor

't ork Knapp and Andrews 245 W. Philadelphia Street P. O. Box P Ycrk, Pennsylvania 17404 407 N. Front Street Harrisburg, Pannsylvania 17108 John Levin, Esq.

t Pennsylvania Public Utilities Comm.

John E. Minnich, Chairman Box 3265 Dauphin Co. Board of Commissioners Harrisburg, Pennsylvania 17120 Dauphin County '.ourthouse Front and Markt t Streets Jordan D. Curningham, Esq.

Harrisburg, Pennsylvania 17101 Fox, Farr and Cunninghan 2320 North 2nd Street

  • Atomic Safety and Licensing Appeal Board Harrisburg, Pennsylvania 17110 U.S. - Nuclear Regulatory Commission Washington, D. C.

20555 Theodore A. Adler, Esq.

WIDOFF REAGER SELK0WITZ & ADLER

  • Atomic Safety and Licensing Board Panel P. O. Box 1547 U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17105 Washington, D. C.

20555 Ms. Marjorie M. Aamodt -

  • Docketing and Service-Section R.D. #5 U.S. Nuclear Regulatory Commission-Coatesville,_ Pennsylvania 19320 Washington, D. C.

20555 Ms. Karen Sheldon Robert:Q. Pollard Sheldon, Harmon & Weiss 609 Montpelier Street 1725 I Street, N.W.

Suite 506 Baltimore, Maryland 21218 Washington, D. C.

20006 Chauncey Kepford

. Earl B. Hoffman

-Judith H. Johnsrud

. Dauphin County Commissioner Environmental Coalition on Nuclear. Power Dauphin. County Courthouse 433 Orlando Avenue.

Front and Market Streets

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State College, Pennsylvania 16801 Harrisburg, Pennsylvania 17101 Ms. Frieda Berryhill, Chairman

-Ms. Ellen R. Weiss, Esq.

J Coalition for Nuclear Power Plant -

Sheldon, Harmon & Weiss

.Pcitponement 1725 I Street, N.W.

2610 Grendon Drive Suite 506 Wilmington,. Delaware 19508 Washington, D. C.

20006 Mrs. Rhoda D. Carr Mr. Steven C. Sholly-1402 Marene Drive 304 South Market Street' Harrisburg, Pennsylvania 17109-

.Mechanicsburg,. Pennsylvania 17055

s Metropolitan Edison Company,

Mr.ThomasGe.uski Ms. Jane Lee Bureau of Radiation Protection R.D. 3, Box 3521 Department of Environmental Resources Etters, Pennsylvania 17319 P. O. Box 2063 Harrisburg, Pennsylvania 17120 Karin W. Carter, Esq.

505 Executive House P. O. Box 2357 Mr. G. P. Miller Harrisburg, Pennsylvania 17120 Mr. R. R. Wilson.

Metropolitan Edison Company Honorable Mark Cohen

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P. O. Box 480 512 D-3 Main Capital Building Middletown, Pennsylvania 17057 Harrisburg, Pennsylvania 17120 G. F. Trowbridge, Esq.

Dauphin County Office Emergency Shaw, Pittman, Potts & Trowbridge Preparedness 1800 M Street, N.W.

Court House, Room 7 Washington, D. C.

20036 Front & Market Streets Harrisburg, Pennsylvania 17101 Mr. E. G. Wallace Licensing Manager Department of Environmental Resources GPU Service Corporation ATTN: Director, Office of Radiological 100 Interpace Parkway Health 1

Parsippany, New Jersey 07054 P. O. Box 2063 4

Harrisburg, Pennsylvania 17105 r

Mr. R. W..Conrad Vice President, Generation Director, Criteria and Standards Pennsylvania Electric Company Division 1007 Broad Street-Office of Radiation Prograns (ANR-460)

Johnstown, Pennsylvania 15907 U. S. Environmental Protection Agency Washington, D. C.

20460 Miss Mary V. Southard, Chairperson Citizens for a Safe Environment P. O. Box 405 Harrisburg, Pennsylvania 17108 Mr. Robert B. Borsu, Babcock & Wilcox Government Publications Section Nuclear Power Generation Division State Library of Pennsylvania Suite 420, 7735 Old Georgetown Road

- Box 1601 (Education Building)

Bethesda, Maryland 20014 Harrisburg, Penneylvania 17126

  • Ivan W. Smith, Esq.

Mr. David D. Maxwell, Chairman Atomic Safety &' Licensing Board Panel Board of Supervisors U.S. Nuclear Regulatory Commission f'

Londonderry Township Washington, D. C.

20555 RFD#1 - Geyers Church Raod Middletown, Pennsylvania 17057-

.Ms. Kathy Mv!aughin Three Mile Island Alert, Inc.

U. S. Environmental Protection Agency 23 South 21st street Region'III Office Harrisburg, Pennsylvania 17104 ATTN: EIS C0ORDINATOR' Curtis Building (Sixth Floor)

Mr. L. W. Harding 6th and Walnut Streets Supervisor of Licensing Philadelphia, Pennsylvania 19106 Metropolitan Edison Company P. O. Box 480 Mr. J. G. Herbein Middletown, Pennsylvania 170'7 5

Director, Nuclear Assurance Metropolitan Edison Company P. O. Box 480' Middletown, PA 17057'

Metropolitar. Edison Company Mr. R. J. Toole Allen R. Carter, Chairman Manager, TMI-l Joint Legislative Committee on Energy Metropolitan Edison Company P. O. Box 142 P. O. Box 4B0 Suite 513 Middletown, Pennsylvania 17057 Senate Gressette Building Columbia, South Carolina 29202 Mr. W. E. Potts Radiological Controls Manager, TMI-l Daniel M. Pell, Esq.

Metropolitan Edison Company ANGRY P. O. Box 480 32 South Beaver Street Middletown, Pennsylvania 17057 York, Pennsylvania 17401 Mr. I. R. Finfrock, Jr.

William S. Jordan, III, Esq.

Jersey Central Power & Light Company Harmon & Weiss Madison Avenue at Punch Bowl Raod 1725 I Street, NW, Suite 506 Morristown, New Jersey 07950 Washington, DC 20006 J. B. Liebennan, Esq.

General Counsel Berlock, Israel & Liberman Federal Emergency Management Agency 26 Broadway ATTN: Docket Clerk New York, NY 10004 1725 I Street, NW Washington, DC 20472 Mr. J. J. Colitz Mr. J. J. Barton-Plant Engineering Manager, TMI-l Manager, Site Operations TMI-2 Metropolitan Edison Company P. O. Box 480 15etropolitan Edison Compar.y P. O. Box 480 Middletown, Pennsylvania 17057 Middletown, Pennsylvania 17057 York College of Pennsylvania Mr. E. D. Fuller Country Club Road TMI-2 Licensing Supervisor 17.05 York, Pennsylvania 4

Metropolitan Edison Compa.y P. O. Box 480 Mr. G. K. Hovey

.Middletown, Pennsylvania 17057 Director, TMI-2 Metropolitan Edison Company

!!r. Tony Fasano, Chief, Onerations Sec.

P.-0. Box 480 U. S. N. R.

C., T"I Site Middletown, Pennsylvania 17057 P. O. Box 311 Middletown, Pennsylvania 19475 Mr. B. Elam Manager, Plant Engineering, Unit 2 Mr. Donald Haverkamp ampany U. S. N. R. C. TMI Site Metropolitan Edison c P. O. Box 480 P. 0. Box 311 Middletown, Pennsylvania 17057 Middletoun, Pennsylvania 19475 7

Mr.' Richard Roberts The Patriot 812-Market Street Harrisburg, Pennsylvania 17105 Governor's Of fice of State Planning and Development Mr. R. W. Heward.

ATTN: Coordinator, Pennsylvania Manager, Radiological Control, Unit 2 Metropolitan Edison Company State Clearinghouse P. O. Box 480 P. O. Box 1323 Middletown, Pennsylvania 17057 Harrisburg, Pennsylvania 17120

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/9 NUCLEAR REGULATORY COMMISSION fQ' ADVlsORY COMMITTEE ON REACTOR SAFEGUARDS N

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c Honorable John F. Ahearne Chaiman U.S. Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

STATUS REPORT ON RESTART OF THE THREE MILE ISL*ND NUCLEAR STATION, UNIT 1

Dear Dr. Ahearne:

During its 248th meeting, December 4-5, 1980, the Advisory Committee on Reactor Safeguards continued its review of the status of the proposed restart cf the Three Mile Island Nuclear Station, Unit 1 (TM1-1) with representatives of the Metropolitan Edison Company (Licensee), General Public Utilities Nuclear Group, the Babcock and Wilcox Company (B&W), and members of the NRC Staff.

This matter was also the subject of Subcommittee meetings in Middletown, PA, on January 31 -

February 1,1980, and in Washington, DC, on November 28 and 29,1980.

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One of the primary results of these reviews is an indication of the need for a statement of policy by the NRC on how and when the various components of the Action Plan, the NTCL list, and items in the NRC order of August 9,19D, are to be applied in the evaluation of the TMI-1 restart.

There is also a need for the NRC Staff to prepare a concise summary of the issues that remain open on the TMI-1 review, a statement as to the status of each, the degree to which each is considered significant from the standpoint of health and safety and an indication as to which items must be resolved prior to restart.

For those items whose resolution c5n-be delayed until after restart, there is a need for the specification of a date when their associated review and implementation must be completed. Because of the importance the Committee attaches to this subject, we requested at'our meeting on December 4, 1980, that the NRC Staff complete and submit such a summary to the Committee.

In terms of the response of the Licensee, the ACRS was encouraged by.their V

actions in several areas. These include:

(a) the qualifications of management

-personnel who have been brought into the organization; (b) the thorough, in-depth training program they have established for their operators and plant support personnel;- (c),the program they have developed for keeping up to date on operat;ng experiences elsewhere

. thin the nuclear power industry; (d) the degree to which-human ' factors considerations have.been used in modifying and upgrading the TMI-1 control room; and (e) the commitment of the Licensee to a restart testing program,'which includes confirmation of natural circulation.

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Honorable John F. Ahearne Decemb'er 11, 1980

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On the basis of its review, the Committee offers the following comments:

1.

In accordance with our previous recommendations, we believe that the Licensee should conduct reliability assessments of the plant as modified.

Such assessments should accelerate the acquisition of potentially significant safety info"9ation and would expedite the development of the basis for further changes, should they be t

necessa ry. They would also provide the Licensee with additional technical insight into the safety of the plant.

In addition, we believe the Licensee should examine the plant from the standpoint of systems interactions that may degrade safety.

Although both of these studies should be conducted on a timely basis, their completion should not be a condition for restart.

2.

The Committee has previously recommended that a means be cons'd-l ered which would provide an unambiguous indication of water level in the reactor pressure vessel.

Although we do not believe.that installation of such a system should be a requirement for restart, we,believe the Licensee should give additional. consideration to j

this matter on a timely basis.

3.

The Committee believes there is a need for instrumentation to mon-i itor the position (i.e., opened or closed) of the pressurizer PORV and safety valves in an unambiguous manner.

The sensitivity of the currently proposed method to monitor valve position remains an open issue between the Staff and the Licensee.

This matter should be resolved in a manner acceptable to the Staff prior to restart.

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4.

The Licensee reported on.the thermal / mechanical effect of high pres-l sure injection on reactor pressure vessel integrity for a small break LOCA with no emergency feedwater flow.

This concern, raised by the Bulletins and Orders Task Force' showed a possible conflict between the need for keeping-the fuel cool during bleed-and-feed cooling versus keeping the vessel within 10 CFR 50, Appendix G limits.

Although B&W personnel have performed calculations relative to this

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matter, their calculations were limited to the small break LOCA bleed-and-feed procedure. There may be certain accident combina-tions which result in much more severe chilling of the pressure vessel coincident with vessel repressurization.

The Committee be-11 eves that the Licensee should review a broader spectrum of accident scenarios to assure better bounding of the range of possibilities.

r Although these studies should be completed on a timely basis, they need not be a condition for restart.

5.

The Licensee has discussed the consequences of DC power failure at l

TMI-l'and has evaluated them in a manner similar to that outlin'ed in NUREG-0305, " Technical Report On D.C. Power Supplies In Nuclear Power Pl ants." The Licensee is performing additional studies to identify possible events which might lead to the loss of both battery trains.

l We encourage completien of these studies on a timely basis.

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Honorable John F. Ahearne December 11, 1980 '

We will schedule follow-up Subcommittee meetings as seen as practicable and will arrange for the Licensee and NRC Staff to meet with the full Committee when progress warrants, Additienal comments by~ Messrs. D. Moeller and O. Okrent are presented below.

Sincerely,

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Milten S. plesset Chairman Additional Cements by Messrs. D. Meeller and D. Okrent In its letter dated Dececber 13, 1979 entitled, " Report on TMI-2 Lessons Learned Task Force Final Repert," concerning the topic entitled " Design Features for Core-Damage and Core-Melt Accidents," the ACis said, "The ACRS supports this recomnendation.

However, the Committee believes that the recom endation should be augmented to require concurrent design studies by each licensee of possible hydrogen control and filtered venting systems which have the potential for mit-igation of accidents involving large scale core damage or ccre melting, in-ciuding an estimate of the cost, the possible schedule and the potential for reduction in risk."

In its letter dated September 8,1980 entitled " Additional ACRS Comments on Hydrogen Control and Improvement Of Containment Capability," the ACRS reit-erated this recem.endation, stating its belief that it, "should be adopted and given priority by the NRC."

We believe that this recommendation is.especially applicable to a higher popu-lation density site such as TM!, and that the prior history of an accident at this she reinforces the desirability of examining design measures which have the potential for reducing significantly the quantity of radioactive material J

released for a range of postulated serious accidents leading to severe ccre damage or a molten core. We recommend that the restart of Tnree Mile Island Nuclear Station,. Unit -1 be made contingent on a co.m.m.itment by the Licensee to perform, within a reasonable period following restart, a study such as that recommended'in the ACRS letter of December 13, 1979 referred to above.

References:

Metropolitan Edison Company, " Report in Response to NRC Staff Recom-1.

mended Requirements for Restart of-Three Mile Island Nuclear Station

. Unit 1," Volumes 1-3, and Amendments 1-22.

2.

U.S. Nuclear Regulatory Commission, "TMI-1 Restart, Evaluation of Licensee's Compliance with the Short-and Long-Term Items of Section II-of the'NRC Order Dated August 9,1979,~ Metropolitan Edison Company, et al., Three Mile Island Nuclear Statien Unit 1, Docket 50-289,"

NUREG-0680, June 1980.

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Hent.able John F. Ahearne 4-December 11, 1980 References Cont'd:

3.

U.S. Nuclear Regulatory Commission, "TMI-Related Requirements for New Operating Licenses," NUREG-0694, June 1980.

4 4.

U.S. Nuclear Regulatory Commission, " Clarification of TMI Action Plan Re-quirements," NUREG-0737, November 1980.

5.

U.S. Nuclear Regulatory Commission, "NRC Action Plan Developed as a Result of the TMI-2 Accident" NUREG-0660, Volumes 1 and 2, May 1980 (Revised:

August 1980).

6.

Letter from Marvin Lewis, member of the public, to Richard Major, ACRS Staff, regarding the restart of the Three Mile Island Nuclear Station Unit 1, dated November 16, 1980.

7.

Letter from B. Leh..an, GPU Service Corpcration, to Richard Maji, ACRS Staff, transmitting Testimony outlines - TMI-1 Restart Proceeding, dated October'29, 1980.

8.

Letter from H. Dieckamp, President, General Public Utilities Corporation, to J. Ahearne, Chairman, U.S. Nuclear Regulatory Commission, regarding request,that the Commission reconsider and modify its Orders of July 2, 1979 and August 9,1979 dealing with the restart of Three Mile Island Unit No. 1, dated December,1, 1980.

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