ML20031A896
| ML20031A896 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 09/22/1981 |
| From: | Hukill H METROPOLITAN EDISON CO. |
| To: | Stolz J Office of Nuclear Reactor Regulation |
| References | |
| L1L-262, NUDOCS 8109280365 | |
| Download: ML20031A896 (14) | |
Text
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Metropolitan Edison Company Post Office Box 480 II L
Middletown, Pennsylvania 17057 Writer's Direct Dial Number September 22, 1981 LlL 262 Office of Nuclear Reactor Regulations Attn: John F. Stolz, Chief Operating Reactors Branch No. 4 U. S. Nuclear Regulatory Commission Washington, D.C.
20555
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Restart Test Program The purpose of this letter is to document our responses to discussion items identified by your staff at a meeting concerning the Restart Test Program.
These answers were previously provided in draft form to Sam McKay, R. Jacobs and others at the above mentioned meeting held on July 23, 1981.
Sincerely
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- 1. D. Hu,ill Director, TMI-1 HDH:CWS:vj f Enclosures 1
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R. Jacobs
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810928036S 810922 PDR ADOCK 05000289
.P PDR Metropohtan Ed: son Company is a Member of the General Pubhc Utilities System
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ENCLOSURE 1 Item 640.1 in consideration of the possibility of a steam line break or loss of coolant accident during the preliminary heatup planned for July 27, 1981, state the boron concentration that will be maintained and state the operability conditions of ECC Systems.
Show how the Restart Testing Program or Technical Specifications will require that the necessary conditions will be maintained throughout Hot Functional Testing during the preliminary heatup.
Discussion 640.1 Startup & Test Procedure TP 600/1 (Controlling Procedure for HFT Functional Testing) requires that the boron concentration be maintained at greater than or equal to 1800 PPM during the preliminary heatup which is sufficient to maintain the reactor greater than 1% shutdown with all control rods withdrawn from the core under the most reactive Reactor Coolant System temper-ature and pressure conditions.
Instrumentation and safeguards system channels will be maintained operable during the preliminary heatup as required by Table 3.5-1 of the plant Technical Specifications.
Surveillance will be per-formed as required by Table 4.1-1 of the Plant Technical Specif-ications.
Each morning and af ternoon throughout Hot Functional Testing (and subsequent integrated plant testing), a meeting will be held to coordinate performance of all plant operations, maintenance and test activities.
Item 640.2 Your Restart Test Specification does not include calibration or checking of Radiation Monitoring Systems.
Show how your restart l
program provides assurance that all radiation monitoring equipment, including the monitoring associated with emergency planning, will be properly calibrated and fully operational for the restart of TMI-1.
l Discussion 640.2-Radiation monitors installed as part of the modification program.
(such as LM-25, LM-29, LM-23) are calibrated in accordance with:
TP 366/3 (Containment Post Accident High Range Radiation Monitor - Calibration)
TP 366/4 (Post Accident High Range Effluent Monitors - Cali-bration)
TP 401/1 (High Radiation Alarm System Functional Test) c.
. Following Restart, RM-5B will be incorporated into the plant to provide for containment isolation on high radiation. This modif-ication is tested by:
TP 366/1 (Containment Isolation on High Radiation - Calibration)
TP 366/2 (Containment Isolation on High Radiation - Valve Func-tional Test)
All other Radiation Monitoring Systems are checked weekly, tested monthly and calibrated quarterly (except for area radiation monitor RM-G6, G7 and G8 which are located in high radiation areas of the
(
Reactor Building which are only done quarterly if the reactor is shutdown) in accordance with plant Technical Specification Table 4.1-1, Item 28.
Item 640.3 Provide the safety analyses supporting the performance of special low power tests involving cooling by natural circulation.
Discussion 640.3 The safety analysis supporting performance of the special low power tests involving natural circulation will be submitted to the NRC by Cetober 16, 1981 Item 640.4 Your Restart Test Specification and sequence documents do not show that all Safety Related Systems will be tested prior to Restart.
Show that the systems that meet the following criteria vill be tested or that testing is not necessary based on the maintenance or surveillance performed during the extended shutdown period.
Verify the performance capabilities, as delineated in Appendix A to 10CFR Part 50, of structures, system 2, and components that:
a.
Will be used for shutdown and cooldown of the reactor under l
i normal plant conditions and for maintaining the reactor in a safe condition for an extended shutdown period.
b.
Will be used for shutdown and cooldown of the reactor under transient (infrequent or moderately frequent events) conditions l
and postulated accident conditions and for maintaining the reactor in a safe condition for an extended shutdown period following l
such conditions.
c.
Will be used for establishing conformance with safety limits or limiting conditions for operation that will be included in the facility Technical Specifications.
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d.
Are classified as engineered safety features or will be relied f
on to support or ensure the operations of engineered safety features within design limits.
1
Discussion 640.4 All Safety Related Systems have been an' n.1 continue to be checked, tested and calibrated in accordance wich the requirements and fre-quency indicated in the Plant Technical Specifications, except for those specific cases that Met-Ed has requested and received waivers from the Nr.C.
For those Safety Related Systems that have been modified during shutdown, modifications testing will be performed prior to criticality followed bjr performance of the revised Sur-veillance Procedure that incorporates the modification features.
Some examples of Nuclear Safety Related Systems that have been modified and the schedule for performance of Surveillance and Modifications Testing on these systems since March 28, 1979 are:
A) High Pressure Injection Normal Surveillance Modifications Revised Surveillance Testing Testing Testing SP 1303-11.8 High and TP 655/1 - High SP 1303-11.8 done following Low Pressure Injection Pressure Iajection performance of TP 655/1
- performed 3/26/79 System Functional during preliminary heatup.
(requires RCS pressur-Test - Performed ized).
during preliminary heatup.
B) Diesel Testing Normal Surveillance Modifications Revised Surveillance Testing Testing Testing SP 1303-11.0 ES Sys-TP 622/1-Diesel SP 1303-11.10 done concur-tem Emergency Loading Generator Load rent with TP 622/1 during Sequence and Power Test - Performed preliminary heatup.
Transfer Test - Per-during preliminary formed 2/17/80.
heatup.
o C) Emergency Feedwater System Normal Surveillance Modifications Revised Surveillance Testing Testing Testing
- 1) SP 1300-3F Motor
- 1) TP 233/1 -
- 1) SF 1300-3F and G are Driven Emergency Feed-Emergency Feed-done concurrently with mod-water Pump Functional water Pumps Func-ification testing.
and Valve Operability tional Test - Tests l
Test - Performed 7/9/81. auto start, control 2) SP 1303-11.53 - Emergency l
valves failure pos-Feedwater Flow (Monthly) -
l ition and flow Performed after modifications indication.
testing.
4 C)
Emergency Feedwater System (Cont'd.)
Normal Surveillance Modifications Revised Surveillance Testing Testing Testing
- 2) SP-1300-3G Turbine
- 2) TP 233/2 -
- 3) SP 1302-6.3 - Calibrate Driven Emergency Feed-Emergency Feed-EFW Flow Channel Performed water Pump Functional water Pumps 48 after modificaticms testing.
and Valve Operability Hour Run.
Test - Performed 7/31/81.
- 4).SP 1303-11.39 -- Emergency
- 3) TP 700/2 -Low Feedwater Initiation Test Power Natura1 Cir-(Quarterly) - Performed af ter culation Test ver-modifications testing.
ifies level con-trol independent
- 5) SP 1302-6.17 - Emergency of ICS power and Feedwater Calibration (Refuel-backup air supply ing Interval) - Performed after modifications testing.
Performed prior to startup from refueling.
D)
Reactor Protection System Normal Surveillance Modifications Revised Surveillance Testing Testing Testing
- 1) SP 1302-5.1 thru
- 1) TP 376/1-RPS
- 1) SP 1302-5.34 - Reactor 5.11 - Calibrates Trip on Turbine /
Trip on Loss of Main Feed-RPS Sensors - Performed Feedwater - Calibra-water / Main Turbine - Per-5.1 -- 3/15/80; 5.2 -
tion and Logie ver-formed after modification 12/12/80; 5.3 - 12/12/80; ification.
testing.
5.4 - 2/21/81; 5.5 -
3/15/80; 5.6 - 12/29/80; 2) TP 376/2 - RPS
Trip on Turbine /
Test - Performed after 3/3/79; 5.9 - Cancelled; Feedwater - Input modifications testing.
5.10 - 12/6/80; 5.11 - Test.
11/29/80.
- 3) TP 800/2 - Reactor
4.1A - 7/22/81; 4.1D - Loss of Feedwater is 1/9/81, from 40% reactre power and turbine trip is form 100%
reactor power.
. Item 640.5 Show how the status of all plant modifications are accounted for and result in adequate precautions and prerequisites in the Test Procedures.
Dis cu$- - '.on '
6'+ C Plant modifications are' initiated by GPU Nuclear Project Engineering.
They are listed and tracked through completion of engineering (ECM's and DCN's and FQ's, etc.).
GPU Nuclear Project Engineering sends the modification package to the GPU Construction Group's " Modification Controls Department",
Mods Control initiates a " Work Sequence" document, which seoks input frem Plant Operations Department and Startup Department en the best method and coordination required for installation and checkout.
Mods Control also gets Radiation Work Permit (RWP) approvals, ALARA review, if required, etc.
When all activities and approvals required to begin construction have been obtained, Mods Control issues a Work Authorization Notice (under which work will be performed in accordance with the Work Sequence Document).
The Work Authorization Notice gets the component, cystem or systems involved with the modification tagged out in accordance with Mat-Ed Operation's normal safety tagging and work request procedure and turned over to Construction, who then tracks the mod until it is released back to Plant Operations (after Startup & Test Group construction testing and usually af ter functional testing).
At this point in time, Operations (Manager of Plent Operations) has full control of any evolution regarding the modified system, i
so any functional testing or system operation for other reasons is performed using licensed operators and responsibility for
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system operation is no different than for normal plant operation.
All safety re.'.ated functional and integrated Test Procedures are revieved and approved by a " Test Working Group", consisting of representatives from:
1)
Plant Operations
- 2) NSSS Supplier i
I
- 3) Engineering
- 4) Startup & Test
- 5) Quality Assurance The Plant Operations representative to the TWG submits each Test Procedure to the Plant Operations Review Committee (PORC) for Lbeir review and input prior to approval of the procedure by the TWG.
Therefore, the TWG verifies that adequate prerequisities and pre-cautions are included in Test Procedures. Most systems are oper-ated to support testing in accordance with their Normal Operating Procedures (approved by Plant Operations and containing their own set of limits and precautions).
Additionally, a Prerequisite List is generated for each major. mile-stone event, such as HFI, PET, etc.
Finally, the Manager of Plant Operations must always operate the plant within the limits and precautions contained in Tech Specs.
No test step will be performed that violates thee-limits.
Item 640.6 Show that the status of all testing required by Technical Specif-ications is accounted for and results in adequate prerequisites in the Test Procedure.
Discussion 640.6 All testing required by Tech Specs, except those tests specifically waived for this restart by NRC, are performed. If results are not satisfactory, then repairs / corrections are made and the test is repeated until satisfactory results are obtained. All tests are routinely performed on the periodic basis specified in Tech Specs oj; at a'more frequent interval.
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l Incorporation of adequate prerequisites into the Test Procedures is assured by the following:
a) Startup & Test Group has a complete file of Surveillance Procedures which are used as input to Test. Procedures.
b) Plant Operations Review Committee (PORC) reviews the TP's, c) Test Working Group (TWG) approves the TP's.
d) Plant Operations supplies licensed operators to operate the plant in accordance with Tech Specs to perform Test Procedures.
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Item 640.7 Describe the observations that will bt made to ensure that the installation of the Cavitating Venturis has not resulted in excessive piping vibrations.
Discussion 640.7 TP 655/1 (HPI Functional Test) incorporated a visual inspection for unacceptable levels of vibration for the condition where cavitation could be occurring.
In addition, the frequency and amplitude of vibration was measured during the test for evaluation against the stress calculatione and for fatigue considerations.
No adverse vibrations were identified.
Item 640.8 A source range count rate of 1/2 count per second with a signal-to-noise ratio greater than 2 is usually specified for initial startup.
If this criterion will not be met for restart, show what precautions will be taken to ensure a cautious approach to criticality.
Discussion 640.8 We have performed a complete and thorough calibration of our source range neutron detectors. We expect to exceed 0.5 CPS count rate at hot shutdown conditions. We have verified through calibration that the signal to noise ratio is greater than 2 and that the detectors are sensitive to core neutrons.
During our Preliminary Hot Functional Test Heatup, we obtained additional neutron count rate data to verify acceptacle response.
Item 640.9 We have compared your Test Planning Specification forwarded to us on May 6,1981, with the NRC Order items given in NUREG-680
- TMI-1 Restart.
For many of the items, it was found that your l
l Test Specification was adequate or that no test was necessary.
For some other items requiring a test, either a GPU test was l
l not shown or the specified acceptance criteria were not suffic-icntly complete to allow a determination of complete conformance with the Order items.
For several of the tests listed, in addi-tion to the Natural Circulation Tests, the staff recommends that the pertinent operating procedures be evaluated during the test and the operators receive planned training during the startup period.
Our specific comments are provided in Table 640.9.
-B-Discussion 640.9 New and modified plant operating and Surveillance Procedures will be verified prior to and during the Test Program. If procedure inadequacies are found, they will be corrected by either a Temporary Change Notice (TCN) or Procedure Change Request (PCR) and reverified as required.
Operators receive Simulator Training on many plant transients and failures, some of which have been included in the Test Program.
Specific training will be conducted on the Low Power Natural Circ-ulation Testing. Test briefings / dry runs are performed prior to each test.
Also, evolution sheets will be maintained on all opera-tors which require them to perform certain plant evolutions such as criticality, generator synchronization, etc.
These evolution sheets will be maintained by Plant Operations.
Comments on Specific Items in Table 640.9 Item la - 3 Auto AFW Load on Diesels Discussion la - 3 Pressurizer heaters trip off the ES bus on receipt of an ES or low bus voltage signal. This will be verified in a startup test.
After an ES diesel start, Plant Operating and Emergency Procedures require removal of sufficient load from the ES bus prior to connec-ting one bank of pressurizer heaters to the ES bus.
Item la - 4 AFW Tech Specs Discussion la - 4 No modifications have been made to the AFW System that would change the amount of flow delivered to the steam generators. This flow was verified to be greater than 500 gpm during the initial startup program. If and when any changes are made that could affect flow delivered (e.g., incorporating AFW Cavitating Venturis), then testing will be performed to verify that at least 500 gpm is deliv-ered.
Item la - 8 AFW Auto Start Annunciate Discussion la - 8 All auto start signals are as specified in NUREG-0680.
Item la - add'l 1 Redundant Instrumentation Discussion la - add'1 1 The setpoint for 20 minute supply low water level alarm for the Condensate Storage Tank is set at 60".
Item la - add'1 2 AFW Endurance Test Discussion la - add'l 2 Design limits of the AFW pumps cre:
a) Bearing temperature - 180 F b) Pump / Turbine Vibration - 2.0 mils c) AF Pump Room Temperature - 140 F d) Pump Discharge Pressure - 1108 - 1400 psig Item la - add'l 4 EFW to intact OTSG Discussion la - add'1 4 The logic that isolates the faulty steam generator is testing by exist-ing Surveillance Procedure and the sensors that provide input to that logic are calibrated by Surveillance Procedure: actual steam generator isolation at power is not performed due to the undesirable consequences of isolating a steam generator that is really not faulty.
(note:
This is not a new modification)
Item la - add'l 7 EFW Operability in Steam Environment Discussion la - add'l 7 The environmental qualification of some components can not be com-pleted prior to restart. This has been noted in the Restart Report.
The bleed and feed mode of cooling will be used if EFW is not avail -
able due to accident environment (See hearing testimony in response to UCS-2)
Item ld Small Break Analysis Discussion ld Technical Specification Table 4.1-1 requires these pressure channels to be checked each shift, tested each month and fully calibrated each refueling outage. This accomplished through performance of SP 1301-1 (Shift and Daily Checks), SP 1303-4.1 (Reactor Protection System), SP 1303-4.19 (HPI and LPI Analog Channels), SP 1302-5.2 and 5.3 (RPS High and Low RC Pressure Channel Calibration) and SP 1302-5.8 (High and Low Pressure Injection Analog Channels).
Also, a quarterly HPI and LPI Logic and Analog Channel Surveillance is performed per SP 1303-4.11.
Item 79-05A-2 Plant Transient Review Discussion 79-05A-2 Integrity of PORV discharge piping was verified by GPU Nuclear Engineering as part of the IE Bulletin 79-14 effort and no problems were identified.
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Item 79-05A-9 Transfer of Containment Liquids e
Discussion
^
79-05B-9' Acceptance criteria are in accordance with NUREG-0680.
Item 79-05B-3 PCRV Setpoint Discussion 79-15B-3 The reactor pressure trip setpoints are verified by the Surveillance Procedures listed in disucssion item Id.
The PORV setpoint is verif-ied by Surveillance Procedure 1302-6.6 (Calibration of PORV Setpoint).
z ltem 79-15B-5 Anticipatory Trips
]
Discussion 79-05B-5 to this letter presents the integrated program (surveillance and test) to check out/ calibrate the new anticipatory trips.
Item 79-05C-3C, D and E Offsite Monitoring, state, and local plans, test excercise Discussion 79-05C-3C, D and E These i; ems are being closely monitored by the NRC I&E Group.
Item 4
Separation of TMI 1 and 2 Discussion 4
The Plant Engineering Ventilation Committee is performing a comprehen-sive program of ventilation flow balancing to ensure ventilation separation.
Vendor tasting for leak tightness is specified for the ventilation isolation dampers, by CPU Nuclear Engineering.
Liquid, Solid and gaseous radwaste isolation has been verified on a process by process basis and will continue to be periodically verified by performance of Surveillance Procedure 1303-11.48 (Unit 1 and 2 Isolation Verification) in order to satisfy proposed Plant Technical Specifications (See Tech. Spec Change Request 1034 Item 5
Waste Management-Discussion 5
Radiation Monitoring instrumentation is checked. weekly, tested monthly and calibrated quarterly in accordance with surveillance procedures.
The only exception to this schedule are area radiation monitors RM-C6 7, and 8, which are located in hf.gh radiation areas of the Reactor Build-ing, are calibrated during each refueling outage rather than quarterly.
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. Item 2.1.3.b Inadequate Cors cooling Instrumentation Discussion 2.1.3.b' GPUN w'ill test all operable *_incore thermocouples; extended range of T, the saturation meter and all computer outputs asso-ciatedwitNthesemodifications.
Sixteen (16) operable incores are to be acceptable.
The quantitative acceptance criteria for the saturation meter in that T as' calculated from the steam tables, must be within 15 F oft,,sakndicatedanthemeteranddisplayedontheplantcomputer.
New instrumentation. to detect and measure' Reactor Vessel level will not be installed prior to Restart.
Item 2.1.4 Containment Isolation Discussion 4.1.4 Containment Isolation mods will be tested by TP 334/1 - ES Actuation Logic Test TP 334/2 - ES Actuation Component Test TP 334/3 - RB Isolation on Line Break Test Also, Plant Operations will perform periodic Surveillance Testing these mods in accordance with Plant Technical Specification re-e.
quirements.
Item 2.1.5.c Install Recombiners Discussion-2.1.5.c Testing will be performed to verify proper operation of the following components:
a) Heater Elements b) Positive Displacement Blower uc) Automatic Temperature Regulating Controls d) Air Blast Heat Exenanger Fan e) Isolation Valves f) Control Room Alarms and Indicators g) Recombiner Control Panel Alarms and Indicators
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Mos't acceptance criteria are yes/no the appropriate function occurs; however, the specific detailed acceptance criteria listed are:
a) Heat exchanger outlet temperature in less then or equal'to 150*F after 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.
b) The low flow recombiner trip set at 3015 CFM c) The low low flow reccabiner trip set at 20 1 5 CFM d) Normal flow to the recombiner of greater than or equal to 57CFM.
Item 2.1.6.a System Integrity Discussion 2.1.6.a The following systems are monitored by surveillance procedures in an effort to minimize leakage:
a) Makeup & Purification System b) Decay Heat Remaval c) Reactor Building Spray d) Reactor Coolant Sampling e) Liquid Waste Disposal f) Waste Gas Disposal g) Reactor Building Containment Item 2.1.8.b Radiation Monitoring Discussion 2.1.8.b See previous discussion for radiat1on monitoring surveillance and test program.
Item 3 add 4 RCS Venting Discussion 3 add 4 Only the pressurizer vent is intended prior to restart and operations of this vent will be tested.
Item 3 add 1, 2 and 3 Containment Pressure, Water Level and Hydrogen Discussion 3 add 1, 2 and 3 These instruments will be installed after restart (1/1/82) and will be tested when installed.
Enclosura 2 REACTOR IRIP ON TURBINE /FEEDWATER - IEST PROGRAM 1
PREINSTALLATION TESTS BENCH CALIBRATION OF NEW MODULES AND PRESSURE SWIT A.
2.
POST INSTALLATION TESTS A.
CABLING AND INTEGRITY CHECKS PRESSUPE SWITCH IUBING FLUSH AND LEAK IESTS B.
3.
FUNCTIONAL &~ CALIBRATION TESTS A.
CABINET IEST (1)
ESTABLISH MODULE CALIBRATION (2)
VERIFY TRIP AND BYPASS LOGIC (3)
VERIFY TIME RESPONSE B.
INPUT IEST (1)
VERIFY TRIP FROM SENSOR (PRESSURE SWITCH) INPUT TO MODULE OUTPUT
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4.
SURVEILLANCE SURVEILLANCE OF COMPLETE REACTOR PROTECTION SYSTEM U A.
REVISED PROCEDURE 5.
POWER ESCALLATION TEST FUNCTION OF-NEW TRIPS WILL A.
IURBINE - REACTOR IRIP
~ BE VERIFIED AS INITIATING B.
FEEDWATER - REACTOR IRIP EVENT FOR PROGRAM TESTS.
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