ML20073R254
| ML20073R254 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/28/1982 |
| From: | Baxter T METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| NUDOCS 8305030591 | |
| Download: ML20073R254 (6) | |
Text
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s' April 28, 1983 e
UNITED STATES OF AMERICA g;;g g NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAUYB AI@l:20 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'S PROPOSED OPINION, FINDINGS OF FACT, AND CONCLUSIONS OF LAW IN THE REOPENED HEARING In accordance with the schedule estat'ished by the Appeal Board during the reopened hearing on decay heat removal capabi-lity, the Staff filed its " Proposed Opinion, Findings of Fact and Conclusions of Law.
(hereaf ter "Staf f Findings")
on April 12, 1983.
Although the Appeal Board provided no express authorization for the filing of replies to the parties' April 12, 1983 submittals, Licensee is compelled to respond to one aspect of the Staff Findings which to some extent represents a new proposal unavailable for previous comment by Licensee.
The Staff has proposed that a license condition be imposed on TMI-l requiring that an auxiliary operator be dispatched to the EFW flow control valve location on auto-start of the EFW pumps and that the auxiliary operator have as his only duty the manipulation of the flow control valves.-1/
Staff 1/
This license condition would be required pending the full upgrade of the TMI-l EFW system during the Cycle 6 refueling outage.
Staff Findings at 6.
8305030591 830428 PDR ADOCK 05000289
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Findings at 6.
Licensee does not object to a license condition requiring the dispatch of an auxiliary operator to the EFW flow control valves upon auto-start of the EFW pumps.
The station emergency operating procedures currently require this action.
See ALAB-708, 16 N.R.C.
slip op. at 13 (Dec. 29, 1982); Licensee's Response to Appeal Board Memorandum and Order of November 5, 1982 at 14, 15 (Nov. 22, 1982); Tr. 337 (Judge Edles).
Licensee does object, however, to the apparently open-ended nature of the Staff's proposed condition, which could be read to limit the flexibility of the operating staff by prohibiting the auxiliary operator from subsequently performing any other duties.
It is not desirable to require the auxiliary operator to remain stationed at the flow control valves indefinitely during an event if EFW flow has been established via the ICS or the manual control station in the control room.
Then the operator may usefully perform other functions after assuring i
EFW flow and, as with the initiating event, the operator is subject to recall to the valves if the need arises.
Licensee would not oppose a license condition limiting the auxiliary operator's responsibilities to being available for manipulation of the EFW flow control valves until such time that EFW flow to the steam generators is verified by the control room operators.
Thus, Licensee proposes that the Staff's proposed license condition be modified as follows:
Upon any EFW pump auto-start condition prior to the Cycle 6 refueling outage, an auxiliary-operator shall be dispatched to the EFW flow i
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control valve area and shall not be required to perform any other duties until the control room operators verify that EFW flow is being delivered to the steam generators under ICS control or control through the manual control station in the control room.
Licensee submits that the above proposed condition will satisfy the Appeal Board's concern raised in its Memorandum and Order of November 5, 1982, while allowing the licensed control room operators to direct the auxiliary operator to undertake other necessary actions following verification of EFW system performance.
The undersigned has discussed the substance of this reply with counsel for the Staff, who has authorized the undersigned to represent that the Staff has no objection to Licensee's suggested qualification to the Staff's proposal.
Respectfully submitted, i
SHAW, PITTMAN, POTTS & TROWBRIDGE s
1 Thomas-A. Baxter, P.C.
Counsel for Licensee i
1800 4 Street, N.W.
Washington, D.C.
20036 (202) 822-1090
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
'l In the Matter of
)
}
}
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. -1)
)
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Reply to the NRC Staff's Proposed Opinion, Findings of Fact, and Conclusions of Law in the Reopened Hearing" were served this 28th day of April, 1983, by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.
-i i
Thomas A.
Baxter, P.C.
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UNITED STATES OF AMERICA
~
NUCLEAR REGULATORY COMMISSION i
BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD i
In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
T SERVICE LIST 2
Gary J. Edles, Esquire James M. Cutchin, IV, Esquire Chairman Office of the Executive Iagal Director Atomic Safety and Licensing Appeal U.S. Nuclear Regulatory Cmeniasion Board Washington, D.C.
20555 U.S. Nuclear Regulatory Cmrniasion Washington, D.C.
20555 Docketing and Service Secticn Office of the Secretary i
Dr. John H. Buck U.S. Nuclear Regulatory Ca mission Atcmic Safety and Licensing Appeal Washington, D.C.
20555 l
Board j
U.S. Nuclear Regulatory Comission John A. Levin, Esquire Washington, D.C.
20555 Assistant Counsel l
Pennsylvania Public Utility Ccmmission
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Dr. Beginald L. Gotchy P.O. Box 3265 Atcmic Safety and Licensing Appeal Harrisburg, Pennsylvania 17120 Doard U.S. Nuclear Regulatory nrmniacion Bobert Adler, Esquire Washington, D.C.
20555 Assistant Attorney General 505 Executive House l
Ivan W. Smith, Esquire P.O'. Box 2357-1
@ni man Harrisburg, Pennsylvania 17120 Atomic Safety and Licensing Board U.S. Nuclear Reculatory Comissicn Ms. Iouise Bradford i
Washington, D.C.-
20555
'IMI AIE1C 1011 Green Street Dr. Walter H. Jordan Harrisburg, Pennsylvania 17102 Atcmic Safety and Licensing Board Panel Ellyn R. Weiss, Esquire 881 West Outer Drive Harmon & Weiss Oak Ridge, Tennessee 37830 1725 Eye Street, N.W., Suite 506 Washington,'D.C.
20006-Dr. Linda W. Little 8
Atcmic Safety and Licensing Board Steven C. Sholly-Panel Union of Concerned Scientists-5000 Hermitage Drive 1346 Connecticut Avenue,-N.W., Suite 1101 i
Raleigh, North Carolina -27612 Washington, D.C.
20036 9
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. Jordan D. Cunrungham, Esquire 2320 North Second Street Harrisburg, Pennsylvania 17110 ANGRY /'IMI PIIC 1037 Maclay Street Harrisburg, Pennsylvania 17103 William S. Jordan, III, Esquire Hamon & Weiss 1725 Eye Street, N.W., Suite 506 Washington, D.C.
20006 01auncey Kepford Judith H. Johnsrud Envirormental Coalition on Nuclear Power 433 Orlando Avenue State (bilege, Pennsylvania 16801 Marjorie M. Aamodt R. D. 5 Coatesville, Pennsylvania 19320 i