ML20080C000

Submits Summary of Background & Bases for Reiterating Request for Approval to Complete Hot Functional Test Program

ML20080C000
Person / Time
Site:	Three Mile Island
Issue date:	02/02/1984
From:	Phyllis Clark GENERAL PUBLIC UTILITIES CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
5211-84-2027, NUDOCS 8402070350
Download: ML20080C000 (3)

Text

a GPU Nuclear Corporation sippany, ew Je sey 07054 201 263-6500 TELEX 136-482 Writer's Direct Dial Number:

February 2, 1984 5211-84-2027 Office of Nuclear Reactor Regulation Attn: Harold R. Denton, Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Sir:

Three Itile Island Nuclear Station, Unit 1 (THI-1)

Operating License No. DPR-50 Docket No. 50-289 Precritical Non Nuclear Hot Functional Testing In our letter of December 21, 1983, GPU Nuclear reiterated our request for approval to complete the hot functional (non-nuclear) test program. In a subsequent telephone conversation between members of our staffs on January 23, 1984, the NRC Staff indicated that a letter summarizing the history of this situation would be helpful. It is the intent of this letter to summarize that history.

On Itarch 23, 1981, the Commission issued an order (CLI 81-03) authorizing hot testing at T!!I-l using non-nuclear heat. In August and September 1981, TMI-1 conducted hot functional testing that we addressed in our letter of June 17, 1981. Following this testing program, we discovered cracks in the tubes in the area of the upper tube sheet rendering the Once Through Steam Generators (OTSGs) inoperable. During 1982 and the first half of 1983, GPU Nuclear employed a method of kinetic expansion to repair and return the steam generators to an operable status. On May 9, 1983, GPU Nuclear declared the OTSG's operable and submitted Technical Specification Change Request #125 to permit operation with the repaired steam generators.

In the text of the May 9 submittal, GPUN requested both approval to use the repaired steam generators in performing "non-nuclear heatup of the plant using pump heat for precritical testing..." and approval for subsequent operation.

This request was noticed in the Federal Register on May 31, 1983.

By July, 1983 it became evident that the time necessary to complete the final NRC "no significant hazards considerations" determination for all modes of plant operation, would prevent GPU Nuclear from performing the hot functional 8402070350 840202 PDR ADOCK 05000289 I P PDR l GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation i

o test program on schedule. Therefore, on July 11 in a public neeting in Bethesda,Ild. (also in H. Dieckamp's letter dated July 13,1983) GPU !{uclear proposed that the Staff separate the previously noticed request into two parts. The first part requested approval "to proceed with pre-critical (non-nuclear) hot functional testing...". The second part requested approval of critical operation for the plant. In order to facilitate NRC's phased review of the operability of the steam generators, GPU Nuclear sent a letter on July 18, 1983, providing a summary of our Itay 9 discussion of "no signifi-cant hazards considerations". Additional emphasis was also placed on the insignificance of the consequences of steam generator events for a reactor that had been subcritical for more than four years.

On August 25, 1983, the NRC staff granted partial approval of our request limited to hot precritical testing of the steam generators. In publishing this partial approval, the Staff noted that the hot precritical non-nuclear testing program for the steam generators was within the scope of the !!ay 31 Federal Register notice. The Staff then made a finding of "no significant hazards considerations" for this portion of the request. Under the provisions of the revised Technical Specifications, GPU Nuclear successfully conducted hot precritical steam generator testing.

The time that has been involved in NRC's consideration of a final "no significant hazards considerations" determination for all modes of plant operation, has prolonged completion of the remainder of GPU Nuclear's hot precritical non-nuclear test program. Our restart schedule detailed in our December 1, 1983 letter, first raised this need with the Staff. On December 21, 1983, GPU Nuclear formally reiterat.ed the request for Staff approval to conduct the balance of the hot precritical test program. In that letter, Gn1 Nuclear noted that the noticed llay 9, 1983 request and the July 13, 1983 letter both sought approval of our entire hot precritical (non nuclear) test program. The December 21, 1983 letter also referred to GPUN Technical Data Report (TDR) #488 "T!!I-1 OTSG Hot Testing Result and Evaluation" (submitted on October 25,1983). This TDR confirmed that the GPUN July 18 assessment of "no significant hazards considerations" is valid for the remainder of the hot prccritical test program as well as for the portion already completed.

He are aware that the Staff recently recommended approval of a license amendment to the Commission that would have declared the repaired steam generators to be operable for all modes of plant operation. This approval would, of course, encompass precritical hot functional testing. The Commission has deferred action on this recommendation. We believe, however, that the Commission's action addressed the question of operating T!!I-l with nuclear heat and that the Commission did not intend to prevent the Staff from taking action on our pending request to complete non-nuclear hot functional testing. We also note that none of the Commission discussions in public meetings has related directly to the hot functional testing alone.

GPU Nuclear believes that it is prudent to proceed with the hot functional testing program as described in the December 16 meeting with the NRC Staff.

This is necessary in order to complete in a timely fashion the following activities commensurate with a decision to Restart by June 19M:

a a .

o Surveillance of safety related systems o Final testing of installed modifications

a. HPI flow test to determine proper flows and splits as a result of the installation of cavitating venturis (Certification Required).

b. Verification of the Incore Thermocouple Alarm System (Software Packages Certification Required).

c. PORY Testing.

d. Pressurizer heaters and spray adjustment.

e. RCS. leak rata verification test.

f. Hanger inspections related to thermal exparaion devices (spring cans, snubbers. etc.).

o Identification of any needed adjustments.

o Increased " hands on" expe-ience for operators.

As addressed in our letters of June 17, 1981 and December 21, 1983, there are no unreviewed safety questions involved in performing this plant heatup. We addressed the operability of the steam generators in the heatup mode in our submittal of September 11, 1983 and we reported the results of our test performed in September 1983 in our letter of October 25, 1983. On January 12, 1984, the Management Review (Flag 2) indicated that the plant is now ready for final heatup.

This letter has summarized the background and bases for our December 21 letter. We reiterate our pending request for approval to perform the hot testing program. We believe that the additional summary information has been provided, and request that the NRC take whatever appropriate steps are neces-sary to expedite authorization for GPU Nuclear to perform the remaining pre-critical hot functional test program.

Sincerely, ff.

P. R. Clark D U President

/mt cc: J. F. Stolz H. Silver R. Conte J. Van Vliet

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