ML20040E378
| ML20040E378 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/01/1982 |
| From: | Cutchin J NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD) |
| To: | |
| References | |
| NUDOCS 8202040253 | |
| Download: ML20040E378 (11) | |
Text
,
Staff 2/1/82 i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD L*"I g
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'CC, T In'the Matter of
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METROPOLITAN EDIS0N COMPANY, ET AL.)
Docket No. 50-2Ef 4
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(Restart)
(Three Mile Island Nuclear Station, Unit No. 1) 9
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STAFF'S RESPONSE TO LICENSING BOARD'S DIRECTIVE TO REPORT DETAILS OF ITS ENFORCEMENT PLAN IN THE FORM 0F A SUPPLEliENTAL INITIAL DECISION I.
INTRODUCTION 2029. On December 14, 1981 this Atomic Safety and Licensing Board issued a Partial Initial Decision (PID) on Plant Design and Procedures and Separation Issuss.
In Paragraph 1217 of that PID we directed the NRC
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Staff to report which of the material Licensee commitments, Staff requirements, and Board-required conditions it intends to impose as technical specifications or other forms of license conditions. We also directed the Staff to report how it intends to be assured that the Licensee will abide by any items the Staff does not plan to impose as license conditions or how it intends to be assured that the Licensee will seek relief from such items in an appropriate manner. The report was to be limited to plant design, modifications, procedures, and separation issues.
In Paragraph 1218 of that PID we listed the major commitments and conditions relied upon by us in reaching our conclusions on plant design and procedures issues and directed that the Staff's report DESIGHTED QIjIGINA{, h >
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2-address at least those items that are listed.220I In Paragraph 1326 of the PID we listed conditions relating to separation of TMI-1 and TMI-2.
In Paragraph 1327 of the PID we directed the Staff to address in its report, in addition to the items listed in Paragraph 1218, the conditions related to unit separation that are set forth in Paragraph 1326 of the PID.
2030. On February 1,1982 the Staff submitted its report.
Its plans for enforcement of Licensee commitments, Staff requirements and Board conditions are discussed in Section II.
II.
ENFORCEMENT OF LICENSEE COMMITMENTS, STAFF REQUIREMENTS AND BOARD CONDITIONS A.
LICENSE CONDITIONS / TECHNICAL SPECIFICATIONS TO BE IMPOSED AT RESTART 2031. The Staff proposes prior to restart to include in the body of the license for TMI-1 the specific license conditions listed below:
1.
Prior to operation above 5% power, the Licensee shall complete the Special Low Power Test Program in accordance with Licensee's Restart Test Specification and Item I.G.1 of NUREG-0694.
(See PID, 11132).
2.
Prior to operation above 5% power, the Licensee shall upgrade the pressurizer level instrumentation such that power can be supplied from redundant vital power supplies. The design should also assure that failure of the ICS/NNI power supply would not cause a loss of all pressurizer level instruments.
(See PID, i1001).
3.
Prior to operation above 5% power, the Licensee shall install a backup incore thermocouple display system that is powered indepe.ident of the primary display system. The backup system shall I
be capable of displaying a minimum of 16 incore thermocouple readings (four from each quadrant).
(See PID, 11867 and 914 and NUREG-0752, Supplement 1,pp.10-12).
226/ In our " Memorandum and Order Modifying Partial Initial Decision of December 14, 1981" dated January 26, 1982 we relieved the Staff of the directive in Paragraph 1218 to report on " Licensee must complete SBLOCA analysis...." listed under Section 11.0.
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4.
Prior to operation above 5% power, the Licensee shall complete the actions described in Items 4, 5 and 6 of Paragraph 1163 of the Licensing Board's Partial Initial Decision dated December 14, 1981.
5.
Prior to startup following Cycle 6 refueling, the Licensee shall upgrade the emergency feedwater system (EFW) to provide safety grade automatic control and to provide other system improvenents to include redundant control and block valves, automatic start on OTSG low level, and upgrades of the main steam rupture detection system and the condensate storage tank low-low level alarm to safety grade.
(See PID, 11 1036, 1037 and 1059; NUREG-0680, p. C8-36; and Supplement I to NUREG-0680, pp. 36-38).
6.
Prior to startup following Cycle 6 refueling, the Licensee shall correct the deficiencies in the TMI-1 control room that are identified in Items 3b, 3e, 3, 4c and 10b of NUREG-0752 and its 9
Supplement 1.
(See PID, 11 913 & 919, n. 109).
7.
During any Unit 2 fuel movements Licensee shall suspend work in the Unit 1 area of the fuel handling building.
(See PID, 11326).
8.
Unit 1 solid waste handling capabilities shall not be relied upon for decontamination or restoration of Unit 2.
(See PID, i 1326).
9.
Prior to any Unit 1 fuel movements, Licensee shall install, and have operational, an engineered safety features (ESF) filtration systen for the Unit 1 fuel handling building. The ESF filtration system for Unit 1 shall be in operation whenever Unit I fuel move-ments are in progress.
(See PID 111265 & 1326).
- 10. A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident shall be implemented and maintained.
(See PID, 11844 and 1285, and NUREG-0680, Supplement 3,
- p. 35).
11.
Isolation of liquid transfer line interconnections between Units 1 and 2 shall be maintained.
(See PID, 1 1259 and NUREG-0680 pp. C4-4 and -5).
2032. The Staff proposes prior to restart to include in the Technical Specifications for TMI-1 provisions to address the general areas listed below:
- 1.
Charcoal filters in the auxiliary and fuel hging building filter systems shall be periodically tested (See PID,1845).
2.
Other areas that are identified in NUREG-0680 and its Supplement 3.
(See NUREG-0680, pp. C2-14 to C2-16 and NUREG-0680, Supp. 3, pp. 16 and 17.)
B.
TECHNICAL SPECIFICATIONS TO BE IMPOSED AFTER RESTART 2033.
In addition to the general areas identified in Paragraph 2032 that the Staff proposes to address in Technical Specifications to be imposed prior to restart, the Staff may address in Technical Specifica-tions to be imposed after re: tart certain of the NUREG-0737 requirements.
The general areas to be addressed by those Technical Specifications cannot be identified by the Staff with certainty at the present time but will be developed generically for operating reactors.
C.
COMi1ITf1ENTS/ REQUIREMENTS TO BE C011PLETED PRIOR TO RESTART 2034. The Staff proposes that items listed by the Licensing Board in Paragraphs 1218 and 1326 of the PID that will be completed prior to restart be included among those to be certified by the Director of Nuclear Reactor Regulation to the Commission as having been completed to the Staff's satisfaction prior to restart. Those items are listed below:
227/ This Technical Specification has already been included in the license.
' 1.
We rely cn Li:ensee's commitment to install adequate shielding.228/ (See PID, 1 628.)
2.
Staff is charged with reviewing revised ATOG rogram and reporting to the Commission.
(See PID, 1721.
3.
Licensee must demonstrate reactor coolant pressure control using HPI system. (See PID, 1 755).
4.
Staff is to verify procedures for reconnecting pressurizer heaters.
(See PID, 11 764 and 771).
5.
Licensee must demonstrate connection of heaters to emergency busses.
(See PID, 1 772 and NUREG-0680,
- p. C8-8).
6.
Radio-iodine monitors must meet NUREG-0737 requirements.
(See PID, 1883 and NUREG-0680, Supp. 3, p. 42).
7.
Extended range noble gas effluent monitors must be in place by January 1,1982 (See PID,1875 and NUREG-0680, Supp. 3, pp. 41-42).
8.
Staff will review control room modifications against criteria of NUREG-0752 prior to restart.229/ (See PID, 11 913-915).
9.
We rely on Licensee's commitment to install cavitating venturis.230/ (See PID, 11208, n. 151) 228/ Shield walls between motor control centers and high pressure injection piping are to be installed prior to restart. Licensee compliance with longer term requirements of NUREG-0737, Item III.B.2, will be a license condition.
229/ Those of the NUREG-0752 requirements to be completed after restart, except the requirement related to a remote shutdown panel, are addressed in a license condition in Paragraph 2031, suara.
Installation of a remote shutdown panel is viewed by tie Staff to be required by Appendix R to 10 CFR 50 of the Commission's regulations and in the Staff's opinion need not be the subject of a specific license condition.
230/ The Staff's witness Jen e relied on cavitating venturis in the HPI lines not on cavitating venturis in the EFW lines in discussing mitigation of SBLOCA's. Nevertheless, cavitating venturis will be verified to be installed in both HPI and EFW lines prior to restart.
- 10. Licensee must propose a means for preventing feedwater isolation due to failure in rupture detection system.231/
(See PID, 1 1174.)
- 11. Staff must perform an independent review of Licensee's calculations of flood level in the containment vessel.
(See PID, 1 1174).
- 12. Staff must certify to Comission a report on Licensee's compliance with CLI-80-21 with respect to radiation levels experienced at THI-2.232/ (See PID, 11162).
- 13. Licensee must environmentally qualify a single path to cold shutdown or bring the matter to the attention of the Commission.233/ (See PID, 11180).
- 14. Six requirements for environmental qualification are a condition for restart as stated in Staff (Rosztoczy) testimony and Licensee's proposed findings.234/ (See PID, 11 1163, 1164 and 1167).
- 15. Prior to restart the Licensee shall submit to the Staff for its review and approval and shall implement to the Staff's satisfaction a program designed to test the adequacy of Licensee's phase 1 ventilation separation program. (See PID, 11 1267 and 1326.)
231/ If Licensee's proposed means for preventing feedwater isolation involves a modification, the Staff will consider the completion of this modification to be necessary to satisfy the license condition on EFW upgrading that appears in Paragraph 2031, supra.
232/ The Staff report to the Comission on compliance with CLI-80-21 was enclosed with "NRC Staff comments on Immediate Effectiveness with Respect to Licensing Board Decision on Hardware / Design Issues, Unit Separation and Emergency Planning" to the Commission, dated January 28, 1982.
233/ This matter was brought to the Comission's attention in "NRC Staff Comments on Immediate Effectiveness with Respect to Licensing Board Decision on Hardware / Design Issues, Unit Separation and Emergency Planning" to the Commission dated January 28, 1982.
234/ Requirements 1, 2 and 3 will be verified by the Staff to have been completed prior to restart. Requirements 4, 5 and 6 are addressed in a licensee condition in Paragraph 2031, supra.
- D.
OTHER COMMITMENTS / REQUIREMENTS 2035.
In addition to those items that the Staff proposes to include in the license prior to restart as Technical Specifications or other license conditions, or to include among the items to be certified to the Commission as having been completed to the Staff's satisfaction prior to restart, there are additional comitments and requirements that were relied upon by the Board and/or the Staff in reaching conclusions about restart and long-term operation of TMI-1. These commitments and requirements and the Staff's proposed methods of enforcing them are discussed below:
a.
Reactor Vessel Water Level We decided that the Licensee in the long term should install a meter to measure water level in the reactor vessel. (See PID,11673 and 1218). The Staff proposes that the method of enforcement of this requirement for B&W reactors such as TMI-1 be determined by the Commission.
In SECY-81-582A dated December 29, 1981 the staff identified to the Commission options available for ensuring compliance by owners of B&W reactors with requirements regarding additional instrumentation to detect incipient inadequate core cooling.235/
The Staff also addressed this matter in "NRC Staff Coments on Immediate Effectiveness with Respect to Licensing Board Decision on Hardware / Design Issues Unit Separation and Emergency Planning" to the Commission dated January 28, 1982.
235/ The parties to the TMI-1 restart proceeding were invited by the Comission to coment on SECY-81-582A and other papers related to the reactor vessel water level measurement issue by February 1, 1982.
I b.
Ground Water Monitoring We decided that measures currently in place to monitor radio-activity in groundwater to facilitate identification and elimination of any TMI-generated sources of contamination shall continue until the Staff determines that they are no longer required (i.e.,
discontinuance of monitoring shall not be by unilateral decision of the Licensee).
(See PID, 11315 and 1326). The staff states that personnel at the NRC TMI Program Office are following the groundwater monitoring program at THI and will ensure that the program is not discontinued without their concurrence.
c.
NUREG-0737 Requirements In addition to the NUREG-0737 items that are addressed in Paragraph 2034, supra, there are some that were specified as long-term requirements by the Commission's August 9, 1979 Order that will not be completed prior to restart. The Staff intends to make compliance with these items a condition of the TMI-1 license.
With respect to completion of NUREG-0737 items that were not specified as long-term requirements of th Commission's August 9, 1979 Order TMI-1 will be dealt with in the same manner as are other operating reactors.
d.
Systems Interaction Studies We specified in Paragraphs 1000 and 1003f that TMI-1 is to be included by the Staff in generic reviews of systems interactions. The Staff is still formulating and testing methodologies and guidance for
9 the conduct of systems interaction studies and is presently not imposing a requirement to conduct such studies generically. However, in response to recommendations by the ACRS, the Licensee has committed to perform a probabalistic risk assessment for TMI-1. The Staff will monitor Licensee's efforts to assure that this assessment is performed in accordance with Staff guidance.
E.
METHOD OF ASSURING COMPLIANCE WITH ITEMS THAT ARE NOT LICENSE C0riDITIONS 2036. The Staff does not propose to implement any special enforcement procedures for TMI-1 after it restarts. The normal enforce-ment procedures relied on by the Staff to assure compliance by all Licensees with items not specifically addressed in Technical Specifica-tions or other license conditions will be relied on by the Staff to assure that the Licensee for THI-1 operates TMI-1 safely.
III. CONCLUSION 2037. Based on our review of the enforcement plans outlined by the Staff, we conclude that they are acceptable and should be implemented.
Respectfu'.ly submitted, S G.z
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James M. Cutchin, IV Counsel for NRC Staff Dated at Bethesda, Maryland this 1st day of February,1982
.o UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of METROPOLITAN EDISON CONFANY, ET AL.)
Docket No. 50-289
)
(Restart)
(Three Mile Island, Unit 1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " STAFF'S RESPONSE TO LICENSING BOARD'S DIRECTIVE TO REPORT DETAILS OF ITS ENFORCEMENT PLAN IN THE FORM 0F A SUPPLEMENTAL INITIAL DECISION" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, or, as indicated by an asterisk, by deposit in the Nuclear Regulatory Commission's internal mail system, this 1st day of February, 1982:
- Dr. John H. Buck Dr. Linda W. Little Atomic Safety & Licensing Appeal Administrative Judge Board Panel 5000 Hermitage Drive U.S. Nuclear Regulatory Commission Raleigh, North Carolina 27612 Washington, DC 20555 George F. Trowbridge, Esq.
- Christine N. Kohl Shaw, Pittman, Potts & Trowbridge Atomic Safety & Licensing Appeal 1800 M Street, N.W.
Board Panel Washington, DC 20006 U.S. Nuclear Regulatory Comission Washington, DC 20555 Robert Adler, Esq.
505 Executive House
- Ivan W. Smith P. O. Box 2357 Administrative Judge Harrisburg, Pennsylvania 17120 Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Honorable Mark Cohen Washington, DC 20555 512 D-3 Main Capital Building Harrisburg, PA 17120 Dr. Walter H. Jordan Administrative Judge Ms. Marjorie Aamodt 881 W. Outer Drive R.D. #5 Oak Ridge, Tennessee 37830 Coatesville, PA 19320 l
Gary L. Milhollin, Esq.
Mr. Thomas Gerusky 1815 Jefferson Street Bureau of Radiation Protection Madison, WI 53711 Dept. of Environmental Resources P. O. Box 2063 Harrisburg, PA 17120 I
o w-o oJudg2 R:ginald L. Gotchy Atomic Safr.ty and Licensing Appeal Board U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Marvin I. Lewis 6504 Bradford Terrace
- Atomic Safety and Licensing Appeal Board Philadelphia, PA 19149 U.S. Nuclear Regulatory Cmmission Washington, DC 20555 Metropolitan Edison Company i
ATTN:
J. G. Herbein, Vice President
- Atomic Safety and Licensing Board Panel P. O. Box 542 U.S. Nuclear Regulatory Commission Reading, PA 19603 Washington, DC 20555 Ms. Jane Lee
- Secretary i
R.D. 3; Box 3521 U.S. Nuclear Regulatory Commission i
Etters, PA 17319 ATTN: Chief Docketing & Service Br.
Washington, DC 20555 Walter W. Cohen, Consumer Advocate Department of Justice William S. Jordan III, Esq.
Strawberry Square,14th Floor Harmon & Weiss Harrisburg, PA 17127 1725 I Street, N.W.
Suite 506 Thomas J. Germine Washington, DC 20006 Deputy Attorney General Division of Law - Room 316 John Levin. Esq.
1100 Raymond Boulevard Pennsylvania Public Utilities Comm.
Newark, New Jersey 07102 Box 3265 Harrisburg, PA 17120 Allen R. Carter, Chairman Joint Legislative Committee on Energy Jordan D. Cunningham, Esq.
Post Office Box 142 Fox, Farr and Cunningham Suite 513 2320 North 2nd Street Senate Gressette Building Harrisburg, PA 17110 Columbia, South Carolina 29202 Louise Bradford Robert Q. Pollard Three Mile Island Alert 609 Montpelier Street 1011 Green Street Baltimore, Maryland 21218 Harrisburg, PA 17102 Chauncey Kepford Ms. Ellyn R. Weiss Judith Johnsrud Harmon & Weiss Environmental Coalition on Nuclear Power 1725 I Street, N.W.
433 Orlando Avenue Suite 506 State College, PA 16801 Washington, DC 20006 Ms. Frieda Berryhill, Chairman Mr. Steven C. Sholly Coalition for Nuclear Power Plant Union of Concerned Scientists 1346 Connecticut Avenue, NW l
Postponement l
2610 Grendon Drive Dupont Circle Building, Suite 1101 Wilmington, Delaware 19808 Washington,DC 20036 Gail Phelps ANGRY 245 W. Philadelphia Street York, Pennsylvania 17401
- Judge Gary J. Edles, Chairman N+NW-Atomic Safety and Licensing Appeal Board James M. Cutchin, IV U.S. Nuclear Regulatory Commission Counsel for NRC Staff Washington, DC 20555 1
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