ML20073N208
| ML20073N208 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/15/1983 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Eisenhut D Office of Nuclear Reactor Regulation |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 5211-83-118, GL-82-33, NUDOCS 8304220404 | |
| Download: ML20073N208 (17) | |
Text
{{#Wiki_filter:. l GPU Nuclear Corporation Ly U duclear astogS B 480. 1e Middletown, Pennsylvania 17057 717 944-7621 TELEX 84-2386 Wer"s Duect Dial Number: April 15, 1983 5211-83-118 Office of Nuclear Reactor Regulation Attn: Darrell G. Eisenhut, Director Division of Licensing 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 Emergency Response Capabilities Supplement 1 to NUREG 0737 This letter documents our response to the information requested in Generic Letter 82-33 which is a schedule for implementing the requirements of Supplement I to NUREG 0737. The current licensing status of TMI-1 has dictated the implementation of nany of the requirements of the original NUREG 0737 as a condition for restart. GPUN Management has initiated modifications that significantly upgrade the emergency response capability of TMI-1. Since many or the implemented and planned modifications to TMI-1 were initiated prior to Supplement 1, our current endeavors are oriented toward completing these activities. Our schedule for final implementation on page I-3 outlines these activities. We intend to meet the goals of Supplement I while concurrently relying on the NRC commitment stated in Generic Letter 82-33 that makes allowances for the work already done in good faith. Based on restart commitments and our progress demonstrated to date I addressing emergency response, we are confident GPU Nuclear can respond A quickly and successfully to any emergency situation. We feel this /fDO response capability will be further enhanced as our implementation h!JO Y schedule nears completion. Supplementing the operational and modification program stated above, GPU Nuclear is an active member of the Nuclear Utility Task Action Committee on Emergency Response Capabilities (ERC NUTAC). This group consists of over 40 utilities and is administrative 1y supported by INPO. The NUTAC provides a forum for exchange of ideas and methods to meet the stated goals of Supplement 1. 8304220404 830415 PDR ADOCK 05000289 F PDR GPU Nuclear Corporation is a subsidiary of the General Pubhc Utilities Corporation t
Mr. Darrell G. Eisenhut 5211-83-118 GPU Nuclear is also a member of the B&W Owners Group whose standing committees and task forces are formulating a generic approach for B&W plants on several key phases of emergency response. The following attachment contains the status, description and proposed schedule of the primary phases identified in Supplement 1. S ncerely, s i 1 Ilukill IIDH:PJD:vj f cc: J. Van Vliet R. Conte Sworn and Subscribed to before me this 15th day of April, 1983. ~ N DAHL!. JEA% BEH 4Y NOTANY FubuC Yl001ETOWN PGPO. C AUPt ;N COUNTY 4 MY COMMiS510N EXPIEIS JUNE 17.1985 Memoe. Penawivaau Assonatmo of NNwn
F r-: k Status and Scheiule for Meetirs the Eequirements for Frergency Response Capabilities - Generic Letter E2-!! - 1 GFJ Ihclear's 3ree Mile Icland ~ Unit 1 April 15,1953 p Ba f 4; r l-p
Contents +. 4 l 1 I. SPDS I-1 A. Current Status of SEDS I-1 B. TI-1 SPDG Subittal Schedule I-2 C. Integrated Schedule for Implementation I-2 II. Detailed Control Rocm Design Review II-1 s A. Current Status of DCRDR II-1 E. Subittal of Prog cm Plan and Su ary DCRDR Report II-2 III. Reg. Guide 1 97 III-1 A. Status GFE! Compliance with R.G.1 97 3. Schedule for Impicmenting the Requirements of R.G. 1 97. C. Meteorological Collection System III-2 IV. Up6rade of-Ibergency Operating Procedures IV-1 A. Status of TI-1 IDP Upgrade IV-1 r E. Sub ittal Date for Generic Technical Guidelines IV-2 E C. Subittal Date for Procedure Generation Package IV-2 ' D. Date for Implementing IDP's IV-2 V. Fmer6ency Response Facilities V-1 A. Projected Completion Date for Fully Functicrr1 TSC, and ICF. V-1 ~ 3. CSC Inyout Schematic 7-! r .h t. W'
I. Safety Parameter Display System (SPDS) A. Current Status of SPDS i ~ GPUN is designing the SPDS as a subset of the Plant Co:puter System (PCS). The Unit 1 PCS consists of a state of the art ModCc p Classic Miniccmputer connected in tander te the cricinal Plant Eailey 855 Co=puter Sy. stem. Aydin color CRT's. provide the human cc:=unication interface in the control. room for the ModCcep Classic. Currently, there are about 2500 points in the data base to aid the operator to safely and efficiently operate the power plant. Multi-color video displays and printed reports present this infomation to the operator with automatic elarming of those plant parameters that exceed preset limits. One SPDS display curre'ntly exists at TMI-1 in the fort of a pressure-temperature plot used to evaluate core cooling and heat re= oval following a reactor trip. This display supports the use of symptem-oriented e=ergency procedures developed frce the ATCG progrc=. Operators and Shift Technical Advisors are taught how to interpret this display by a cceputer aided instruction course. Althou6h the Modec=p is powered frcs ICF electrical busec, a loss cf offsite power will result in the interruption of data until the diesel 6eneratcrs assume the load. Planned improvements in redundancy and reliability include: Che replacement of the Eailey with a new ModCo=p thereby providir6 two fully cc=patibic and redundant cceputer systers. '"he installation of an uninterruptable power supply for the Modcanp to assure a high degree of reliabilty on pceer switching. Currently GPUN will develop, integrate and implement the SPDS into the PCS as well as into the other initiatives i.e. IDPS, CRDR, RC.1-97 and ERF. SPDS safety functions and parsmeters necessary for full implccer.tation will be defined and a safety evalution perforced at the beginning of the program. An SPDS incorporating the existing d *
- e and cc:puter hardware will be operational at the end of the first refueling cutage follovire restart. Upgrades will be cade later to incorocrate arrf additionaldata points which nay be identified during the perforrance of the safety analysis and to provide inprovements in computer hardware redundancy and reliability.
GPUN is currently developirc the details and refinirs the schedules for achieving these major milestonen. 1-1
E. '3*I-1 CES Schedule - Date' for subittal of Safety Analysis to IEC: 4 months after . restart Date for subittal of EPDS Imple entation 2 conths after Plan to IEC: acceptance of-Safety Analyzes by IBC. _ Date when initial SPDS incorporating exist-Eeginning of Cycle 6 ing. data base and. hardware will be operational 1 l Since GPUN has made significant progress in the planning and en6 neering of the 211-1 EPDS, we do not request a pre-implementation i review by the 130 Staff. However, we do request frcn the :3C, timely responses to the 3:1-1 SES Safety Analysis in order to proceed with any final upgrading following initial installation. C. Integrated Ochedule for Implementatien See following diagram (I-3) g-- i 4 m 4 p e I-2 t p b... w L
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L E 1 E ~II. Detailed Control Roce Design Review (DC?lS) >F A. Current Status of DCDR In Varch 1930, GPUI! corducted a detailed Control Roce Eecisn review cf the 3:1-1 control roem and issued a repcrt in Dece=ber 1920. GFUli then corrected the identified deficiencies by i=plementing changes to t the control rcce during 1981 and 19o2. In addition to this detailed study, GPUN has integrated human facters review into the GPUI! design lE process. In the future this approach vill insure: "Le maintenance of present high standards for all future =odifications to the control roc =. ~ The correct integration of i=portant changes to the control rocc such as the new process cc=puter interfaces. The correct integration of functions such as the DFDS. In parallel with the. above activities, the 130 Ruman Factors 3 ranch conducted a hucan factors review of the TMI-1 control roc = in July 1980. As a result of this review, the I?RC issued !URIG 0752 in Decc=ber 1980 describing the review and listing the deficiencies identified by the review tea =s. GPU'! corrected =ost of the HR0 noted deficiencies du-ing its control roo= =cdification program as noted above during 1981-82. GPUH will resolve'<the re=aining deficiencies and document these resolutions in the Cu==ary Report of Detailed Control Roc = Design Review. "he remaining ite=s include: i (Ite=s in parentheses refer to section of :;LE 0752) - Evaluation of alam syste= deficiencies (1.0.a) Standardisation of color codes en CRC displays (2.0.a) I;on-locking set point knobs en Bailey Controllers (!.0.b) Interchangeability-of legend switch covers (3 0.d) Display la=p status for burned cut bulbe (3 0.e). Color standard for labels and =i=ics (5.0.a) ~' labelling and demarcation of re=sining RVAC controls (10.0.b&c) k NRC Inspection Report 50-289/82-17 docu=ented the final resolution cf E the items listed in I;UPIG 0752. c 1 GPUli also presented the CEDR report as testi=cny in the ASI3 hearire for restart in January 1931. In its review of the hearin6 record, the E ASI2 noted that the review and proposed =cdifications were adequate for restart of T.I-1. y B. Ouhittal of Program Plan and Eu==ary D~Fl3 Report r Cince GPUU essentially cc=pleted the Contrcl Roc = Design Review in Decc=ber 19BO, the following re=aining ite s need to be addressed: II-1~
Resolution of outstanding items identified by 13C review. Coordination of symptom oriented Frergency Procedure Guidelines with validation and verification in the Control Rocc. Comparison of CRDR as completed to HRC require =ents and identificaticn of additional work items. Submittal of a su= nary DCRDR report that describes the review perfor=cd, and the changes scheduled and implemented as a result c L of the review. L GPU'i will sab=it 2 conths after restart a surnary Control Room Design i Review Report for all canpleted items required in Generic Letter 82 ~3 With this submittal, GPUN will include a detailed progra: plan addressing the remaining inecxnplete items. 7ne Final Detailed Control Rocm Design Review Report en all remaining ite=s identified in Program Plan Cub:ittal will be sub:itted prier te the end of the first outage after restart. L [ l l. L E 'r i k F i; f b [. 1 II-2 L. l L_
b 3 III. Reg. Guide 1 97 A. Status of GFUIi Ccepliance with R. G.1 97 GFUI! has conducted preliminary studies en instrumentation relative to R. G. 1 97 using the suggested for:at presented durire the 130 IRC c Regional 15ectings. As a result of this first review and discussion ' with other MW.0wners, it became evident that an Owner's Orcup task ~ force to address R. G.197 would be apprcpriate. Eeveral of the EU Owners met March 10 and 11 during the ERO !!U'A0 meetire in Atlanta and for=ulated a charter and R. G. 1 97 prc6 ram. The Task Force beca e official at the March 22 MW CG Eteering Cc==ittee meetire and its first workin6 meeting was held on April 4 and 5 The Task Force members recognize the one element in develeping a eczprehensive R. G. 1 97 program is the use of Iner6cncy Operating Procedures (EOPs). Because AT00 (The EU Sytptcmatic approach to e=ergency procedures) is a primary Owners Grcup activity, a generic 3 effort would insure the emplete integraticn of the goals of R. G.1.T with the final upgrade of IDP's. E 3. Schedule for Implementin6 the Require =ents of Reg. Guide 1 97 The EW Cwner's Group R. G.1 97 Tack Force has adopted a fcur phase program to address the requirenents of R. G. 1 97 They are: I 1. Define a set of Class A variables using input from the ATOG and each plant. , Schedule - ec=plete prior to restart. 2. Once the Task Force has established a definition of Type A ~ variables from Phase 1, initiate a plant specific inventory and [i cate6crization of instrumentaton of Type 3 through I variables. Tne p Task Force will develop the criteria and format for the E cate6orization during Phase 1. h Schedule - complete during firct part cf Cycle 5 p.:. [ 3 'With the infor=ation derived during Phases 1 and 2, prepare a L generic R. G.1.W Report. Bis document will contain a plant by f plant listin6 of instrumentation, categorization and areas of non compliance. The key ele =ent of thie report will provide f justification of non-compliance as well as alternatives to E cc pliance for each utility. GPUI! will include a proposed schedule h' for implementation of instrumentation where alternatives cr s justification of non-compliance are not appropriate. r k Schedule - cmplete prior to end of Cycle 5 t u t III-1 6-d i'
i a 4 d 4 Ecview and resolve coc=ents with the 20 en the co:pleted R. G. 1 97 report and firmly establish a plant-specific schedule of implementation of recocmended instrumentation. Schedule - prior to Cycle 6 startup. C. Meteorological Collection Syste: The existing on-site meteorological data collection system has historically provided reliable indicatien of meteorological para =eters 1 necessary for esti=atin6 atmosphereic transport a.d diffusion of plant l releases. Daring 1932,' the meteorolegical data availability rate free the on-site meteorological station was greater than 95%. An agreement with the I;ational Weather Cervice to provide backup meteorological information frcn several locations in the vicinity of SC!S further increases the availability of meteorolcgical data and provides a source of regional inforcation. GPU I!uclear also sabscribes to a Weather Infcmation Cervice which can be accessed via eccputer teminal. and can provide meteorological data I-instantaneously frc= local and regicnal sources. f GPU Isuelcar has recently detected a faulty viring connector at the on-site meteorological station which reculted in two station failurcs i during December of 1982. In order that the facility =ny continue to i operate reliably, the facility's wiring will be rencvated during 1953 The viring. renovation will include the replacement of the faulty connector and provide independent source of conitored parameters to each units' control room. We anticipate that these codifications will further enhance qstem availability rate. p i I.. i: e L t L. !r ? III-2 ?.- m_,
F E i IV. Upgrade of Tne76cncy Operatin6 Procedures (IOP's) {g A. Status of TI-1 IDP's Upgrade - Following the issuance of NURIG -0575 en July 18, 1979, the TMI-2 f Subco::=ittee of the BS! Owners Group cet with the IEC and described the s Abnor=al "ransient Operating Guidelines (AT03) program. A draft set of-ATC3 guidelines were delivered to the 120 cn Au6ust 21,19S0. On April 3,1931, Ihke Power docketed the Ocence draft ATOG-Guidelines. GPUN -and other utilities subnitted letters indicatire that these guidelines should becc=e the base docu=ent for IGO review (Generic Guidelines). GPUN first used D'I-1 draft guidelines en the Lynchburg siculator in June, 1981. Trainin6 department and operaticns parsennel participated in the evaluation. l ? As docu=ented in NURIG 0680, 4/17/S1, Supple =cnt ?, Table 2-1, GPUN is in cc=pliance with the short ter: Z=ergency procedure require =ents of WRIG G737 ite: 1. C.1.1. Concerning the 1cng ter: Emergency procedure require =ents, the NRC has determined in IE 06S0 that " reasonable progress" is being cade en the ICO/ transient & analysis (0737 ite=s 1.C.1.2.a & 1.C.3.a), and that the resultirg procedures charges (0737 items 1.C.1.2.b & 1.C.1 3.b) will be i=ple=ented during the first refueling after 1/1/82. Again, in late 1952 the 120 reviewed cur AT03 i=ple=entatien progress and in this 10/26/E2 letter, confir=ed that " reasonable progress" was being cade. f GPUN aleo initiated an ATCG I=ple=entatien Cubec=ittee to review ATCG and issued cc==ents on the draft 3:I AT03 guidelines. Cc==ent i resciution was reached by January 5,1933, and the TI-1 plant specific guidelines will be eccpleted in April, 1933 E Various technical i=provecents identifis 3 in ATOG have already been incorporated into the plant procedures. ~nese include: ~ ' HPI initiation and throttling based upon subecoling tarG n i 2 and 1 css of heat sink, i ' RC pa=p restart criteria, ' 03 G 1evel centrol at 955 when sub ccling is lost, ' Improved feedvater control to prevent evercooling, ' ECS pressure /te=perature licits, i ' OTSG steaming and isolation requirc=ents drin6 tube rupture
- events, T
' Inadequate Core Coolirs Criteria. In addition, the following ATOG recc= endations are presently in the process of being i=ple=ented: I ' RO pu=p trip on loss of subcooling =argin, E' ' A sy=pton-oriented reactor trip precedre and ' Additional tube rupture precedure i=prevements. Introductory classroo= trainin6 en the technical guidelines has already been given to the operators. Si=ulater trainirc on the TI-1 plant specific guidelines and en tube rupture precedures will be provided in IV-1
June, 1933. Additional classroc: and siculator trainin6 Will be provided when plant procedures are developed frc= the technical Euidelines. E. Subittal Date for. Generic Technical Guidelines Dubitted on April 3,1961 under the Cconec docket. 130 endorec ent of sy=ptom oriented approach used in AOCG wr.c given en March 3,19S2. C. Cubittal Date for Procedures Generation Pac 1rac The 2 1-1 Procedures Generation Package will be subitted to the 130 e l six cenths after restart of 21I-1. D. Date for Implementing iDP's Cne IDP's will be implemented at 1111-1 prior to Cycle 6 startup. 9 i au. r L. E b: = er 1 ~ = m
V. Frer6cncy Response Facilities A. Projected completion dates for fully functional Technical Oupport Center (TSC), Fnvironmental Assesement Control Center (IlsCC), and Fmergency Operations Facility (EOF). TSC - The existing "SC facility will be codified as indicated below and on the diagra cn page V-3 The fo11owin6 will need to be 4 modified: - Recove the existira TSC enclosure, halen system, and the lighting conduits. Provide'a new TSC structure i Make the east wall and the ceiling of the new office space, located en the north cide of the existire 290, removable. Provide fluorescent lighting in both roc =s. - Provide louvers and air fan for adequate ventilation. - Delete the halen rystem. - Anchor devn the existing five file cabinets to the concrete floor near the west netalclad fire wall. - Relocate the emer6ency liS tira to its new location, h shown in plan. Relocate the key tox for cooldown keys, shown in plan. - Relocate the radiation conitor pump to the next roc =, as chown in plan. - Provide power for the radiation tenitor pa p and core the wall for air sampling hoses. Tne above modifications shall be seiczically designed to saticfy the requirements in Regulatory Guide 1.29. Tne cc=pletion date for the fully op rational and permanent TEC will be 6 =cnths after restart. ECF - Cince the existing TF.I-1 20F's do not strictly cc ply with Option I of Eupplement 1, GFIF.i =cnagement has decided tc pursue an ICF in strict compliance with Option 2. Tne existire near-site EOF is located in the Training Building apprcximately 1/2 nile frem the site. However, the near site EOF needs significant physical upgradire cach as chielding and habitability codifict.tient tc nect the requirments of Supplement I. Likewice, the far site IDF, located in Reading, ic 42 miles frcm the site. Therefore,- an 20F will be established within a 10-20 mile l radius of TF.I and will serve as the primary offsite facility. ~ Options being considered are to lease, purchase or build a facility. The primary censiderations are that (1) the facility should be located at a distance greater than 10 miles frca the plant but as close to the 10 mile radius as possible and (2) should be readily . accessible to a major thorou6hfare. Once the facility if operaticnal, the exieting EOF operations will be shifted to the new location. Cnic ctructure will fully comply with the requirements of Cupplement 1. The construction schedule V-1
= for the new EOF will be provided as soon as it is available. (approximately 30 days). However, we expect the facility to ' be operational in the third quarter of 1983. It should be noted that via the ca: cuter terminals the SPm R. G. 1.97 infomation will be available in the TSC and E& as identified in the integrated imple entation schedule. EACC - The EACC function currently located at the.Farrisburg International Airport will relocate to the new EOF facility. OSC - The OSC will remain in its current location. The OSC satisfies supplement 1 requirements. 9 Senffing for the above facilities will reet the requirements of Table 2 of the supp1 ment. .q i 3 i l [ l I ~ I s V-2 I F t = h ~ ~ . ~ -.
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