ML20054G581

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Notice of Issuance of Amend to NRR 800211 Order & Motion for Formal Mod of Tech Specs to Conform to 820517 Amend of Order.Amend Allows Movement of One Control Rod Drive Mechanism to Obtain Info on Core.Certificate of Svc Encl
ML20054G581
Person / Time
Site: Crane Constellation icon.png
Issue date: 06/18/1982
From: Wilcove M
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To:
Atomic Safety and Licensing Board Panel
References
ISSUANCES-OLA, NUDOCS 8206220084
Download: ML20054G581 (3)


Text

06/18/82 UNITED STATES OF AMERICA NUCLEAR REGULATORY COP 911SSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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METROPOLITAN EDISON COMPANY, ET AL.

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Docket No. 50-320 OLA

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(Three Mile Island Nuclear Station,

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Unit 2)

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NRC STAFF NOTICE OF ISSUANCE OF AMENDMENT OF ORDER AND MOTION TO CONFORM PROPOSED TECHNICAL SPECIFICATION IN ACCORDANCE HEREWITH The Director of the NRC Office of Nuclear Reactor Regulation (Director) has issued the attached Amendment of Order, pursuant to his authority under 10 C.F.R % 2.717(b).

This amendment permits movement of one control rod drive mechanism at a time for the purpose of obtaining more information on the condition of the core and to prepare the reactor vessel for head removal.

The revised Technical Specification and Staff's Safety Evaluation Report are attached.

Pursuant to an Order of the Commission, dated May 12, 1980, this Licensing Board has been designated to conduct the proceeding with respect to the proposed formal license amendment incorporating the Technical Specifications proposed in the February 11, 1980 Order.

In order to conform the proposed Technical Specifications with the actions taken by the Director, the NRC Staff hereby moves that the proposed Technical Specifications be formally modified to conform to the Amendment of Order dated May 17, 1982, subject to the authority which 10 C.F.R s 2.717(b) explicitly preserves in the Licensing Board for purposes of f DESIGNATED CRIGDIAD {

Cor$1 fled I jN om s206220004 8206ie DR ADOCK 05000 q

2-this proceeding.

Formal amendment of the license will, of course, await the outcome of the prospective hearing.

Respectfully submitted, hl%(

~ %kwm Michael N. Wilcove Counsel for NRC Staff Dated at Bethesda, Maryland this 18th day of June 1982

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of

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METROPOLITAN EDIS0N COMPANY, ET AL.

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Docket No. 50-320 OLA

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(Three Mile Island Nuclear Station,

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Unit 2)

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CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF NOTICE OF ISSUANCE OF A'1E'lP'ENT OF ORDER AND MOTION TO CONFORM PROPOSED TECHNICAL SPECIFICATION IN ACCORDANCE HEREWITH" 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 through deposit in the Nuclear Regulatory Commission's internal mail system, this 18th day of June 1982:

John F. Wolf, Esq., Chairman, Dr. Judith H. Johnsrud Administrative Judge Environmental Coalition on 3409 Shepherd Street Nuclear Power Chevy Chase, MD 20015 433 Orlando Avenue State College, PA 16801 Dr. Oscar H. Paris, Administrative Judge George F. Trowbridge, Esq.

Atomic Safety and Licensing Board Panel Shaw, Pittman, Potts and U.S. Nuclear Regulatory Commission Trowbridga Washington, D.C.

20555*

1800 M. Street, N.W.

Washington, D.C.

20036 Mr. Frederick J. Shon, Administrative Judge Atomic Safety and Licensing Board Atomic Safety and Licensing Board Panel Panel U.S. Nuclear Regulatory Commission,

U.S. Nuclear Regulatory Commiss. ion Washington, D.C.

20555*

Washington, D.C.

20555*

Karin W. Carter Atomic Safety and Licensing Appeal Assistant Attorney General Panel 505 Executive House U.S. Nuclear Regulatory Commission P. O. Box 2357 Washington, D.C.

20555*

Harrisburg, PA 17120 l

Secretary Mr. William A. Lochstet U.S. Nuclear Regulatory Commission 119 E. Aaron Drive ATTN:

Chief, Docketing & Service Br.

State Co'llege, PA 16801 Washington, D.C.

20555*

r wki h \\~Q.kl Michael N. Wilcove Counsel for NRC Staff

Docket No. 50-320 MAY 17 1982 Mr. John J. Barton Acting Director of TMI-2 GPU Nuclear Corporation p.0. Box 480 Middletown, PA 17057

Dear Mr. Barton:

The Nuclear Regulatory Comission has fslued the"eri5losid En~dI5'ni of

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Order for the Three Mile Island Nuclear Station Unit 2 This Amendment of Order changes the Recovery Mode Proposed Technical Specifications to allow for operations-necessary to prepare for future recovery mode activities.

The changed requirements had been imposed by the Order.'

of the Director of the Office of Nuclear Reactor Regulation on February 11, 1980 These changes are being made in response to your request of April 8,1982. This Amendment of Order is effective upon issuance.

Copies of the related Safety Evaluation and revised pages for the pro-posed Technical Specifications and their associated bases are enclosed.

Sincerely.

[

Bernard J. Snyder, Program Director 2,

TMI Program Office l

Office of Nuclear Reactor Regulation l

Enclosures:

1.

Amendment of Order 2

Safety Evaluation j

3 Proposed Technical Specification Page Changes cc W/ encl:

See next page L. King J. Larson O

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UNiica STATI3 0F AMERICA s

NUCLEAR REGULATORY COMMISSION r'

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Dr. Judith H.:Johnsrud John F. Wolf, Esq., Chate. nan,

' Environmental Coalition on Administrative Judge

~M Nuclear Fewer 3409 Shepherd Street 433 Orlando Avenue Ch;vy Chase, MD 20015 State College, PA 15501 Or. Oscar H. PaMs, Acministrative George F. TrewoMdge, !"ic.

Judge At:mic Safety and Liesnsing 5 card Panel f5 haw, Pi =an, Potts anc TFevar'dge U.S. Nuclear Regulat:ry C: mission 1800 M. Street, N.W.

Wasnington, D.C.

20555" Washingt:n, D.C.

20025 Mr. FredeM ck J. Shon, Administrative At:mic Safety and Licensing Scar <

Judge Panei...

Atcmic Safety and Licensing 5 card Panel U.S. Nuclear Regulat:ry C:mtssi U.S. Nuclear Regulator / Comissicn Wasningu n, D.C.

20555' Washing =n, D.C.

20555" At:mic Safety anc Licensing '::e KaMn W. Car ar Panei Assistan: At:Or ey General U.S. Nuclear :lequia::rf ::.m : -

505 E.xect:ive Hausa Wasning :n, J.C.

20555" P. O. Sox 2257

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..ar-is:urg, A

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U.S. Nucl ear :.egui a::r/ ::=i s:-

Mr. William A. ' :enstat A i :1:

Ihie'. ::cxet-~? i Eer" H 9 5. 'a-n Or"ve Wasning::n, I.^.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION In the Matter of METROPOL[TANEDISONCOMPANY,et.al.

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Docket No. 50-320 OLA

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(Three Mile Island Nuclear Station,

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Unit 2)

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AMENDMENT OF ORDER I.

GPU Nuclear Corporation, Metropolitan Edison Company, Jersey Central Power and Light Company and Pennsylvania ElgcQQmpany (collectively, the Licensee) are the holders of Facility Operating License No. DPR-73, which had authorized operation of the Three Mile Island Nuclear Station, Unit 2 (TMI-2) at power levels up to 2772 megawatts thennal. The facility, which is located in Londonderry Township, Dauphin County, Pennsylvania, is a pressurized water reactor previously used for the consnercial generation of electricity.

By Order for Modification of License, dated July 20, 1979, the Licensee's a thority to operate the facility was suspended and the Licensee's authority was limited to maintenance of the facility in the present shutdown cooling mode (44 Fed. Reg. 45271).

By further Order of the Director, Office of Nuclear Reactor Regulation, dated February 11, 1980, a new set of formal license requirements was imposed to reflect the post-accident condition of the facility and to ahsure the continued maintenance of the current safe, e stable, lo'og-term cooling condition of the facility (45 Fed. Reg.11282)

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Although these requirements were imposed on the licensee by an Order of the Director of Nuclear Reactor Regulation, dated February 11, 1980, the TMI-2 license has not been formally amended. The requirements are reflected in the proposed Recovery Mode Technical Specifications presently pending before the Atomic Safety and Licensing Board.

Hereafter in this Amendment of Order, the requirements in question are identified by the applicable proposed Technical Specification.

II.

By letter dated April 8,1982, the licensee requested changes to the Proposed Technical Specifications, Appendix A for Three Mile Island, Unit 2 (TMI-2).

The licensee has requested NRC staff approval to allow the movement of an individual control rod (CR) or axial pougweshaping rod (APSR) for the purpose of gathering additional information on the condition of the core and to prepare the reactor vessel for head removal.

The staff agrees with the licensee that by moving an individual control rod or axial power shaping rod, more information on the core condition may be obtained.

Also, prior to This can head removal, it will be necessary to decouple the APSR lead screws.

most easily be accomplished if the rods are first fully inserted.

Therefore l

inserting the APSR's at this time on an individual basis is a step that must be perfomed sometime during the cleanup.

The licensee has requested to do this step now and the staff concurs.

Presently section 3.1.3.1 of the Proposed Tecnnical Specifications does not allow any movement and requires that all control rod drive breakers be open.

The staff has analyzed wnat the shutdown margin of the TMI-2 core would be assuming that there is no control material or poison in tne core and concluded that by maintaining a 3000 ppm baron concentration, there is enough conservatism to assure that Keff will be less than 0.944 Further analysis has shown that with a boron concentration of 3500 ppm, the core will remain subcritical with K,ff <0.90 in any physically reasonable rearrangement of the fuel, even in the absence of all control material and burnable poisons.

Even though proposed Technical Specification 3.1.1.2 requires a minimum boron concentration of 3,000 ppm, the licensee has shown by sampling that the reactor coolant system has been consistently maintained at approximately 3800 ppm boron.

Therefore it is the staff's opinion that by moving a control rod or axial power shaping rod the shutdown margin will not be significantly affected.

It should also be noted that the change incorporates the requirement that all procedures that could result in CR or APSR movement will be reviewed and approved by NRC staff.

.. % 9 Therefore, it is the staff's opinion that with the present baron concentration in the reactor coolant system, and the basis for which the 3000 ppm lower limit was derived in addition to all procedures for rod movement being approved by NRC staff, the proposed amendment of section 3.1.3.1 of the Proposed Technical Specifications is acceptable.

This change will not result in a significant increase in the probability or consequence of accidents previously considered nor a significant reduction in a margin of safety and does not therefore involve a significant hazards consideration.

The staff's safety assessment of this matter is set forth in the concurrently issued Safety Evaluation.

This evaluation concluded, in material part, that the modification does not involve a significant hazards consideration and that there is reasonable assurance that the health and safety of the public will not be endangered by operation in the modified manner.

Prior public

. notice of this Amendment of Order is therefore not required and the action is effective upon issuance.

It was further determined that the modification does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact.

In light of this determination, it was concluded that the instant action is insignificant from the standpoint of environmental impact and, pursuant to 10 CFR 351.5 (d)(4),

that an environmental impact statement or environmental impact appraisal need not be prepared herewith.

Accordingly, pursuant to the Atomic Energy Act of 1954, as amended, the Director's Order of February 11, 1980, igegeby revised to incorporate the For deletions, additions, and modifications set forth in Attachment A hereto.

further details with respect to this action, see (1) Letter to B. Snyder, USNRC, from R. Arnold, Met-Ed/GPU, Technical Specification Change Request No. 37 dated April 8,1982 and (2) The Director's Order of February 11, 1980.

All of the above documents are available for inspection at the Commission's Public Document Room, 1717 H Street, N.W., Washington, D.C., and at the Comission's Local Public Document Room at the State Library of Pennsylvania, Government Publications Section, Education Building, Commonwealth and Walnut Streets, Harrisburg, Pennsylvania 17126.

FOR THE NUCLEAR REGULATORY COMMISSION MYY w

Harold R. Denton, Director Office of Nuclear Reactor Regulation Effective Date:__May 17. Topp Dated at Bethesda, Maryland

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION GPU NUCLEAR CORPORATION METROPOLITAN EDISON COMPANY PENNSYLVANIA ELECTRIC COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY DOCKET NO. 50-320 THREE MILE ISLAND NUCLEAR STATION, UNIT NO. 2 Introduction By letter dated April 8,1982, (Reference 1) the licensee requested changes to the proposed Technical Specifications Appendix A, for Three Mile Island, Unit 2 (TMI-2).

The proposed amendment would allow for the movement of individual control or axial power shaping rods for the purpose of obtaining information on core conditions.

Presently all red megaments are prohibited by the require-ments of Proposed Technical Specification Section 3.1.3.1 which states that all control rod drive breakers shall be open.

This section provided assurance that no reactivity changes would be made as a result of rod motion.

However, recovery operations have progressed to the point that more information is needed that can be used to infer the condition of the core for planning subsequent cleanup and recovery operations.

In addition, the axial power shaping rods must be fully inserted into the core and decoupled before the reactor vessel head is removed.

If full insertion cannot be made, special tooling and procedures must be developed before the head can be lifted.

Planning for these special conditions should begin early in the recovery process.

Summary The licensee has requested NRC staff approval to allow for the movement of l

individual control rods or axial power shaping rods under the requirements of NRC approved operating procedures.

The purpose of the movement is to gain

advanced information on core conditions that may aid in planning the methodology to be used for future recovery efforts. Also, prior to head removal, it will be necessary to decouple the APSR lead screws.

This can most easily be accomplished if the rods are first fully inserted.

Therefore inserting the APSR's at this time on an individual basis is a step that must be performed sometime during the cleanup.

The licensee has requested to do this step now and the staff concurs.

The staff has reviewed the potential effects on the core by this movement and finds that reactivity changes are insignificant and will not affect the demonstrated shutdown status of the core.

Therefore we find the proposed change acceptable.

Evaluation

~ e e.A By Order of the Director, Office of Nuclear Reactor Regulation, dated February 11, 1980 a new set of formal license requirements were imposed to reflect the post accident condition of the TMI-2 facility.

The order required in section 3.1.3.1 that all control rod drive breakers remain open to prevent rod drive movement.

NRC analysis (Reference 2) has shown that by maintaining a baron concentration of at least 3,000 ppm, which is currently required in Proposed Technical Specifi-cation section 3.1.1.2, that the maximum Keff would be 0.944, providing an adequate shutdown margin.

Even more conservatively, Reference 3 shows that with a boron concentration of 3500 ppm, the core will remain subcritical with References 2 eff <0.90 in any physically reasonable rearrangement of the fuel.

K and 3 assume the absence of all control rods and burnable poisons when calcu-lating the Keff values.

As verified by reactor coolant system sampling, the licensee has consistently been maintaining a baron concentration of approximately 3800 and thereby rissuring even more shutdown margin than required by the recovery

technical specifications.

Therefore the staff concludes that any single rod movement will have a minimal effect on the required boron concentration and shutdown margin.

All control rod mechanism energizing and subsequent movement will be controlled by NRC approval of procedures and accompanying safety reviews for specific tasks being performed.

The procedures will limit one mechanism being energized at a time and require upgraded surveillance to assure that no unexpected change in core conditions occurs.

Environmental Considerations Wa have determined that the change does not authorize a change in effluent types or total amounts nor an increase in power *44thi and will not result in any significant environmental impact.

Having made this determination, we have further concluded that the change involves an action which is insignificant from the standpoint of environmental impact and, pursuant to 10 CFR 51.5 (d)(4),

that an environmental impact statement or negative declaration and environmental impact appraisal need not be prepared in connection with the issuance of this change.

Conclusion Based upon our analysis of the shutdown margin for the TMI-2 core relative to the present and required baron concentration, the staff finds that the modifi-cation of proposed Technical Specification Section 3.1.3.1 is acceptable.

The associated base: have also been modified as requested by the issuance.

We have also concluded, based on the considerations discussed above, that:

(1) because the change does not involve a significant increase in the probability or consequences of accidents previously considered and does not involve a significant decrease in a safety margin, it does not involve a significant hazards consideration, (2) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed daaner, and (3) such activities will be conducted in compliance with the Commission's regulations and the implementation of this change will not be inimical to the common defense and security or to the health and safety of the public.

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REFERENCES GPU Nuclear letter from R.C. Arnold to B.J. Snyder, Director, TMI 1)

Program Office; April 8,1982.

Memorandum from Charles R. Marotta. Sr. Criticality and Shielding 2)

Engineer, Division of Fuel Cycle and Material Safety. Office of Nuclear Material Safety and Safeguards, to Norman Haller, Director and Program Analysis; Nonconservative Reference Office of Management K eff of TMI-2 Core as Given in Special Task Force Report," Evaluation of the Cleanup Activities at Three Mile Island, April 1,1980.

Memorandum from Raymond DiSalvo Probabilistic Analysis Staff, RES, to 3)

Robert Bernero. Director, Probabilistic Analysis Staff RES; TMI-2 Hazard Evaluation, April 4,1980.

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FACILITY OPERATING LICENSE NO.

OPR-73 DOCKET NO.

50-320 Replace the following pages of Appendix "A" Proposed Technical Specifications with the enclosed pages as indicated.

The revised pages contain vertical lines indicating the area of change.

Pages 3.1-3 B3/4 1-1 1

Y,I

l LIMITING CONDITIONS FOR OPERATION 3.1.3 CONTROL ASSEMBLIES MECHANISM (ENEFGIZATION) 3.1. 3.1 All control rod drive mechanisms shall be deenergized except that one mechanism at a time may be energized as allowed by procedure (s) approved by the NRC staff in accordance with Technical Specification 6.8.2.

APPLICABILITY:

When fuel is in the reactor pressure vessel.

ACTION:

None except as provided in Specification 3.0.3.

3.1-3 May 17,1982 THREE MILE ISLAND - UNIT 2

3/4.1 WATER INJECTION COOLING AND REACTIVITY CONTROL SYSTEMS BASES 3/4.1.1 BORATION CONTROL The limitation on minimum boron concentration ensures that the core will 7

remain subcritical under all possible conditions which may exist during the long-term cooling mode.

The maximum boron concentration is provided to ensure that precipitation of boron will not occur in the reactor coolant system and thereby cause possible flow restrictions.

The specification requiring the OPERABILITY of two systems capable of injecting borated cooling water into the Reactor Coolant system are provided to ensure that makeup water can be injected into the reactor coolant system and that the reactor coolant will be maintained within the required boron concentration limits.

The required volume of borated water in the BWST provides sufficient water to cool the core via low pressure injection for at least three days, during which time alternate cooling means could be provided.

3/4.1.3 CONTROL ASSEMBLIES Normally maintaining the control rod drive mechanisms deenergized provides assurance that the rods will not be inadvertently withdrawn.

Preparation of specific procedure (s) to allow energizing individual mechanisms and obtaining NRC approvals ensures sufficient evaluation and attention has been paid to assure the health and safety of the public.

THREE MILE ISLAND - UNIT 2 B 3/4 1-1 May 17,1982

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