ML20052C739
| ML20052C739 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/30/1982 |
| From: | Trowbridge G METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| ISSUANCES-OLA, NUDOCS 8205050450 | |
| Download: ML20052C739 (8) | |
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April 30, 1982
? OiY -3 pp yp UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-320 0 9
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(Three Mile Island Nuclear
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Station, Unit No. 2)
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LICENSEE'S RESPONSE TO STAFF'S MOTIO g'jd
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IN ACCORDANCE WITH AMENDMENTS OF ORDER
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By Order of the Director, Office of Nuclear i
Regulation, dated February 11, 1980, the Commission established a set of formal license requirements reflecting the post-accident condition of the TMI-2 facility and assuring the continued main-tenance of the current safe, stable, long-term cooling condition of the facility.
The February 11 Order further provided that the requirements of the proposed Technical Specifications (attached to the Order) were immediately effective, with an opportunity for hearing prior to the effectiveness of the proposed formal license amendment.
At the time the February 11 Order was issued, both the Staff and Licensee anticipated that, during the pendency of this matter, changes in the proposed Technical Specifications might be necessary as the facility status evolves as a result of ongoing recovery efforts, d
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4 On April 1, 1982, and on April 7, 1982, the Director of the NRC Office of Nuclear Reactor Regulation issued Amendments of Order.
The April 1, 1982 Amendment of Order eliminates the requirements for operability of the Long Term B steam generator cooling system and its associated electrical busses 2-31 and 2-41, 4
imposed pursuant to the Director's Order of February 11, 1980.
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Under the terms of the April 1 Amendment of Order, the presently used~" loss to ambient" cooling mode will continue to be the primary mode for core cooling, with the Mini-Decay Heat Removal System and the Decay Heat Removal System as alternatives.
The April 7, 1982 Amendment of Order eliminates various measurement instrumentation and/or surveillance requirements for equipment no longer required to be operable.
The operability requirement for the differential pressure transmitters used to measure reactor coolar' G3ctem flow was deleted, as it no longer set.as a function *-
ry: 9se with the reactor. coolant system in its present conf 24uracao, and the' remaining instrumentation used to monitor the shutdown condition of the reactor (e.g., pressure
.and temperature transmitters, reactor coolant system boron sampling, and two operable sourco range neutron instruments) is adequate.
The operability requir.ements and associated surveillance requirements for Core Flood Tank Level and Reactor Building Spray Pump Flow Instrument,ation were also' eliminated, since those inatruments are
"'not required to monitor the reactor coolant system in its present condition.
In addition, the requirement for automatic. initiation
. of the Deluge System water spray at the Hydrogen Purge Exhaust Filter and the Reactor Building Purge Exhaust Filter has been deleted, since the fire hazard attendant to the filters has been significantly reduced by the removal of charcoal from the filters.
The Deluge System has been placed in a manual mode, preventing spurious actuation; the audible fire detector alarms are not affected.
Further, the operability requirements for fire detection instrumentation for the Balance of Plant Diesel have been eliminated, since the diesels are located outside the restricted area fence, are not located near any vital equipment, and are no longer re-
. quired to perform a safety function.
Finally, a requirement that containment air locks be operable with a specified maximum leak rate has been modified, as has the associated surveillance require-ment, since the June 28, 1980 purge significantly decreased airborne contamination levels (greatly reducing concern over containment atmosphere leakage), and since verification of compliance with the requirement involved unacceptably high personnel exposures.
The footnote indicating that S 4.6.1.3(a) represents an exemption to Appendix J has also been removed, since Appendix J has been amended and now requires the same leak rate testing specified in S 4.6.1.3(a).
The April 7 Amendment of Order also deletes requirements for certain systems and structures no longer required to be operable or maintain their original design criteria.
The Hydrogen Purge Cleanup System has been deleted (as well as the associated sur-veillance requirement), since its purpose was fulfilled upon the
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. completion of the June 29, 1980 purge and the use of the system will not be required to maintain the containment building in a safe condition for the remainder of the Recovery Mode.
The requirements.for operability of high pressure water pumps for fire suppression capability have also been modified.
Now only 2 of 4 high pressure pumps are required to be operable.
Two pumps will provide the necessary combined capacity and will not impair the Fire Suppression System.
In addition, occupational exposure considerations have been added to the requirement to l
maintain a specified maximum internal pressure and a spor.ified maximum internal temperature design.
This limits maintenance inside containment if radiological conditions would pose a hazard 7
to personnel.
The specified maximum internal pressure has also been reduced from 60 psig to 2 psig.
The April 7 Amendment of Order also adds and/or. modifies certain system or structure requirements.
Operability requirements have been imposed for the control room air inlet radiation monitor, since a failure of that monitor could prevent the automatic shifting of the control room emergency air cleanup system to the recirculation mode in the event of an accident.
In addition, the requirements of the Plant Operations Review Committee (PORC) and the Generation I
Review Committee (GRC) have been re9ised,to provide for a broader range of disciplines and' experience on the Committees.
Finally, the April 7 Amendment of Order clarifies certain ambiguities in the Proposed Technical Specifications.
The require-ments have been modified to clarify the fuel handling building l
' and the auxiliary building air cleanup systems are independent of one another, and that the inoperability of one of the two systems should not affect any radioactive movements in the building solely associated with the other operating system.
Further, the containment isolation requirements have been clarified to properly reflect the Staff's intent that, when one containment isolation valve per penetration is open or inoperable, containment isolation must be maintained by either (a) at least one deactivated automatic valve secured in the isolation condition cg; (b) at least one closed manual valve or blind flange.
In addition, the surveillance require-ments have been modified to identify by more accurate system termi-nology which tanks are to be sampled to verify that they contain borated water.
In addition, a footnote has been added to the Surveillance Requirement specifying sampling to confirm a stated dissolved gas concentration, to specifically state where the most representative sample should be taken for water being added to the reactor coolant system via the Standby Pressure Control System.
By the April 19, 1982 "NRC Staff Notice of Issuance of Amendment of Order and Motion To Conform Proposed Technical Specifi-cations In Accordance Therewith," the Staff has moved that the proposed Technical Specifications and Surveillance Requirements attached to~the February 11, 1980 Order be formally modified in accordance with the Amendments of Order of April 1 and April 7,
- 1982, subject to the duthority which 10 C.F.R.
S 2.717 (b) reserves to the Licensing Board in this proceeding.
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i As Licensee understands the Staff's motion, it is simply 4
a request by the Staff that the Board issue an order notifying all parties that the proposed Technical Specifications under considera-tion in the prospective hearing requested in this proceeding are revised in accordance with the April 1 and April 7, 1982 Amendments of Order (i.e., the document before the Board is revised in accordance with pages 3.3-8, 3.3-9, 3.3-11, 3.6-1, 3.6-2, 3. 7 -1,
- 3. 7-4, 3. 7-5, 3.7-7, 3.8-4, 3.9-1, 5-1, 6-3 and 6-6 attached to the April 1 and April 7, 1982 Amendments of Order), and the Recovery Operations
.f Plan is revised in accordance with the pages 4.1-2, 4.3-7, 4.3-8, 4.6-1, 4.6-2 and 4.6-3 attached to the April 1 and April 7, 1982 Amend-ments of Order.
Revised " overleaf" pages (which provide the bases
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for, but are not considered a part of, the technical specifications, pursuant to 10 C.F.R. 50.36) are also attached to the Staff's motion; i
pages B 3/4 6-2, B 3/4 4-1, and B 3/4 7-1 and E 3/4 7-2 are revised j
in accordance.with the corresponding pages attached to the April 1 and April 7, 1982 Amendments of Order.
The formal license amendment incorporating the proposed Technical Specifications, as amended, would await the outcome of l
j the prospective hearing.
With this understanding, Licensee does 1
- not oppose the motion.
Respectfully submitted,
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SHAW, PI N, PO OWBRIDGE j
By:
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/, %dorg6 F. - Trowbridge, /P.C.
Delissa A. Ridgway
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Counsel for Licensee 1800'M Street, N.W.
Washington, D.C.
20036 (202) 822-1000 Dated: April 30, 1982
April 30, 1982 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No. 50-320 OLA
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(Three Mile Island 14uclear
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Station, Unit No. 2)
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CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Response To Staff's Motion To Conform Proposed Technical Specifications In Accordance With Amendments of Order" were served upon those persons on the attached Service List by deposit in the United States mail, postage prepaid, this 30th day of April,1982.
nAL plieor'ge F!' Trowbridge, P.C.
Dated:
April 30, 1982 i
a e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
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METROPOLITAN EDISON COMPANY
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Docket No 50-32Q OLA g
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(Three Mile Island Nuclear
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Station, Unit No. 2)
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4 SERVICE LIST John F. Wolf, Esq.
Karin W. Carter, Esq.
3409 Shepherd Street Assistant Attorney General Chevy Chase, Maryland 20015 505 Executive House P.O.
Box 2357 Dr. Oscar H. Paris Harrisburg, Pennsylvania 17120; U.S. Nuclear Regulatory Commission l
Atomic Safety and Licensing Board Docketing and Service Section(3-Panel Office ~of the Secretary Washington, D.C.
20555 U.S. Nuclear Regulatory
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Commission Mr. Frederick J.
Shon Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Panel Washington, D.C.
20555
. Lawrence J. Chandler, Esq. (1)
Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C.
20555 J.H. Johnsrud Environmental Coalition on Nuclear Power 433 State College, Pennsylvania 16801 State College, Pennsylvania 16801 William A. Lochstet 119 E. Aaron Drive State College, Pennsylvania 16801
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