ML20040F007
| ML20040F007 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/04/1982 |
| From: | Baxter T METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| Shared Package | |
| ML20040E999 | List: |
| References | |
| NUDOCS 8202080198 | |
| Download: ML20040F007 (3) | |
Text
_______ _
{gTED
'62 EB -5 gC y4/82 c:
U~iITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
/
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S REPLY TO THE NRC STAFF COMMENTS ON IMMEDIATE EFFECTIVENESS WITH RESPECT TO PLANT-DESIGN AND PROCEDURES ISSUES Pursuant to the Commission's Orders, the Staff, on January 28, 1982, submitted its comments with respect to the immediate effectiveness of the Licensing Board's Partial Initial Decision of December 14, 1981 on plant design and procedures, separation and emergency planning issues.
Included in the Staff's comments was its response to the Licensing Board's directive that the Staff report to the Commission on Licensee's compliance with CLI-80-21 relating to the radiation qualification of safety equipment to function in a TMI-2 type environment.
I.D.,
11162.
By way of reply to the Staff's report and in order that the Commission may have a full understanding of the issue in question, Licensee herewith submits the following comments supplemental to the report provided by the Staff.
8202080198 820204 PDR ADOCK 05000289 G
As noted in the Staff's report, Licensee has submitted additional information to the Staff regarding the radiation qualification of Class IE equipment at Three Mile Island Unit No. 1.
The Staff's Safety Evaluation Report (SER) of March 24, 1981 (attached to the Staff's Immediate Effectiveness Comments) requested Licensee to provide addi-tional information regarding the radiation qualification of certain equipment for which the Staff had noted deficiencies and to provide justification of certain values utilized by Licensee.
See SER, Sections 3.8, 4.2.
By letter of August 28, 1981, Licensee submitted three volumes of revised information on the specific component open items identified in the SER.
Included in that submittal was an explanation of the radiation qualification criteria utilized by Licensee for each specific component including, as necessary, the backup calculations for radiation source terms.
In order to assist the Staff in its review of the equipment qualification for TMI-1, Licensee, on January 25, 1982, provided the Staff with a summary of the criteria utilized for radiation qualification of Class IE equipment.
(See attached GPU Nuclear letter to John F. Stoltz, Division of Licensing.)
The Staff review of equipment qualification at TMI-l is proceeding in accord with the review schedule for all operating reactors.
Based upon its review 1/ to date of the 1/
In view of the date of Licensee's submittal (January 25, 1982), the Staff may not have had the opportunity to review this summary prior to preparing its report to the Commission..-
C information provided by Licens-the Staff has identified no outstanding items with respect to the radiation qualification of Class IE equipment which ould negatively impact the restart of Unit 1.
Further, as noted in the attached letter, all Class IE equipment at TMI-l is in compliance with or is being modified to meet the criteria set forth in Licensee's January 25, 1982 submittal (the criteria utilized by Licensee are those set forth in the DOR guidelines, which, as stated in the Staff's report, specify radiation levels in excess of those experienced at TMI-2).
In summary then, Licensee believes that the informa-tion regarding equipment radiation qualification provided to the Staff and the Staff's review of that information supports a finding by the Commission that the immediate effectiveness of the Licensing Board's Partial Initial Decision should not be stayed.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE Thomas A.
Baxter
?
Counsel for Licensee 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 l
l l l
l
GPU Nuciaar
- i
).
Q g{
P.O. Box 480 Middletown, Pennsylvania 17057 717-944-7621 Writor's Direct Dial Number January 25, 1982 82-020 Office of Nuclear Reactor Regulation Attn:
John F. Stolz, Chief Division of Licensing Operating Reactors Branch No. 4 U. S. Nuclear Regulatory C-4 ssion Washington, D.C.
20555
Dear Sir:
Three Mile Island Nuc3 ear Station, Unit 1 (Dil-1)
Operating License No. DPR-50 Docket No. 50-289 Environmental Qualification of Safety-Related Electrical Equipment As discussed hatween Mr. R. Jacobs (NRC) and E. Wallace (GPU) on January 11, 1982, enclosed please find a copy of the criteria for Class IE radiation qualification for harsh environments at TMI-1.
All Class IE eqtiiptnent evaluated to date in connection with IE Bulletin 79-01B and the DiI-l environmental qualification SER date March 24, 1981 are in or are currently being modified to be in co=pliance with the enclosed radiation criteria.
Sincerely, I
w
.Eukill))
u Dir cror, DiI-l HDH: CWS:vj f Attachment ec:
R. Jacobs R. C. Haynes Cyril J. Crane 7
vD GPU Nuclear is a cart of Ine General Pc:: lit Utilities System
~
Criteria for Clasa IE Equipment - Radiation Qualification Fcr Harsh Environments at D'I-1 Source Terms and Dose Rates
- The gamma and beta dose used for a LOCA inside con:=4n =nt was 2 x 10 Rads in general arean.
The DOR Guidelines (Section 4.12) permit the use of a dose of 2 x 107 Rads integrated dose for gm radiation in lieu of a detailed plant specific ca.lculation. Ve have no: included the integ-rated dose associated with beta radiation since safety related equipment in the TMI-1 Cont = 4 n=r is in metal enclosures or conduit.
The enclosures and conduit, vnile not necessarily gas tight, do shield the sensitive materials from essentially all of the beta source ter=s which is external to the enclosures / conduit.
The beta dose from gases potentially within the enclosures / conduit was considered so insignificant as to not affec environmental qualifica:ics (i.e. several orders of magnitude lower than 2 x 107 Rads).
- The ga==a dose used for High Energy Line Break (w:~ 5) inside containment was 2 x 106 Rads in general areas.
This is in accordance with Appendix B of the DOR Guidelines.
The accident gam =a and beta dose rates outside of containment were obtained in accordance with the guidelines of NURIG 0578 and NUREG 0737 for plant specific areas.
No letdown was assu=ed to the makeup and purification system.
Nor=al plant operating radiation levels were obtained from plant l.,
operating rTeords and health physics data.
i Enen necessary detailed localized radiation analyses were made.
Exa=ples of this are the shielding review outside of containment and the analysis for Rosemount trans=1::ers inside of containwnt.
The exposure time used is that which is required for the component to-function af ter the initiation of the accident plus one hour.
Ecuiument Oualification The radiation threshholds from Table C-1, Appendix C, of the DDR Guidelines were used.
Radia: ion effects were evaluated as non synergistic.
The co=ponents qualified were:
those required for hot shutdown and those required for the one identified path the cold shutdown.
Additionally, the display instrumentation no qualified for harsh environ =ents and required by the emergency procedures were evaluated to ensure that f.iilure of this instrumentation would not mislead the operators.
4
- Th3. preferred methtd of qualification ustd w s to obtain esquential typ2 test data.
Other methods used were separate function test data.-
engineering analysis, and a combination of the methods.
- The qualification data was detailed on individual System Component Evaluation Worksheets. When an engineering analysis was performed, a Materials Evaluation Worksheet was generated. 7nen necessary, Engin-eering Calculation Sheets were prepared.
All of the required reference inferration to support the evaluation is in the central file.
1 S
-4
{
i g
e
_