ML20080M633
| ML20080M633 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/16/1984 |
| From: | Baxter T METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | |
| References | |
| NUDOCS 8402210209 | |
| Download: ML20080M633 (5) | |
Text
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7 te-Feb uary '16, 1984 i
UNITED STATES OF AMERICA ED NUCLEAR REGULATORY COMMISSION lNB 17 BEFORE THE COMMISSION 9l32
,, '.r In the Matter of'
)
)
METROPOLITAN' EDISON COMPANY
)-
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S COMMENTS ON PROPOSED SOLUTION TO THE MAIN STEAM LINE RUPTURE DETECTION SYSTEM In its Order of January 27, 1984 (unpchlished) in this proceeding, the Commission identified the issues on which it had decided to take review of ALAB-729, 17 N.R.C. 814
.(1983).
One of those issues is ".
. whether the Licensing Board erred in delegating to staff responsibility for approving licensee's solution to the main steam line rupture detection system problem.". Order at 3.
Noting that Licensee has already submitted its proposed solution to the Staff, which approved it, the Commission provided the opportunity to the parties to comment, within twenty days from the date of the Order, on the adequacy of that proposed solution.
Id.
The Appeal Board imposed the condition that " Licensee shall submit to the Commission prior to restart a proposed long-term solution to the steam generator bypass logic problem."
ALAB-729, 17 N.R.C.
at 895 (1983).
In response to that holding, Licensee filed its proposed solution with
.the. Commission on June 29, 1983.
(For convenience, a copy l
8402210209 840216 Q'
PDR ADOCK 05000289 Q
of that filing is attached hereto.)
Licensee is not aware of any response by another party to that June 29, 1983 filing.
As an update to its earlier submittal, Licensee advises the Commission that the Main Steam Line Rupture Detection switches located in containment will be environmentally qualified through replacement in June, 1984.-1/ Therefore, in the event of a. main steam line rupt'ure in containment, the pressure switches will be capable of performing their intended function.
All components of the Main Steam Line Rapture Detection System located inside containment will then he environmentally qualified.
Respectfully submitted, Thomas A.
Baxter,'P.C.
SHAW, "ITTMAN, POTTS & TROWBRIDGE 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1090 counsel for Licensee Dated:
February 16, 1984 1/
Letter.5211-84-2038, Hukill to Stolz (February 10, 1984).
[
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION 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 Comments on Proposed Solution to the Main Steam Line Rupture Detection System" with at tachment were served this 16th day of February, 1984, by deposit in the U.S. mail, first class, postage prepaid, upon the parties on the attached Service List.
c=
Thomas A.
Baxter, P.C.
LK
UNITED STATES OF AMERICA NUCLEAR REGUIA'IORY COMISSION BEEGRE THE COMISSIO1 In the Matter of
)
)
METROPOLITAN EDISCN CDIPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
~ Station, Unit No. 1)
)
SERVICE LIST Chairman Nunzio J. Palladino Dr. k ginald L. Gor.chy U.S. Nuclear Regulatory Ccumission Atcxrde Safety and Licensing Appeal Washington, D.C.
20555 Board U.S. Nuclear Regulatorf Ccmmission Ccar. issioner Victor Gilinsky Washington, D.C.
20555 U.S. Nuclear Regulator / Cci' mission Washington, D.C.
20555 Ivan W. Strith, Esquire CbM=n, Atanic Safety and Licensing Ccmmissioner Thcznas M. Roberts Board U.S. N'1 clear Regulatory Commission U.S. Nuclear Regulatory Ccumission Washington, D.C.
20555 Washington, D.C.
20555
& =nk sioner James K. Asselstine Sheldon J. Wolfe, Alternate Chairman U.S. Nuclear Regulatory Ccmmission Atcznic Safety and Licensing Board Washington, D.C.
20555 U.S. Nuclear Regulatory Ccmmission Washington, D.C.
20555 Cczmissioner Frederick M. Bernthal U.S. Nuclear Regulatory Ccmnission Mr. Gustave A. Linenberger, Jr.
Washington, D.C.
20555 Atanic Safety and Licensing Board U.S. Nuclear Regulatory Ccumission Docketing and Service Section Washington, D.C.
20555 office of the Secretary U.S. Nuclear Regulatory Comnission Richard J. Rawson, Esquire Washington, D.C.
20555 Office of Executive Iagal Director U.S. Nuclear Regulatrry Ccunission Gary J. Edles, Esquire Washington, D.C.
20555 Chairman, Atcmic Safety and Licensing Appeal Board John A. Iavin, Esquire U.S. Nuclear Regulatory Ccmnission Assistant Counsel Washington, D.C.
20555 Pennsylvania Public Utility Ccumission P. O. Box 3265 Dr. John H. Buck Harrisburg, PA 17120 Atcmic Safety and Licensing Appeal Board Marjorie M. Aanodt U.S. Nuclear Regulatcry Ccumission R. D. 5 Washington, D.C.
20555 Coatesville, PA 19320 l
l
Douglas R..Blazey, Esquire Steven C. Sholly Chief Counsel Union of Concerned Scientists Department of Environmental Resources 1346 Connecticut Avenue, N.W., #1101
~514 Executive House, P. O. Box 2357 Washington, D.C.
20036 Harrisburg, PA 17120 ANGRY /'IMI PIPC Ms. Iouise Bradford 1037 Maclay Street
'IMI ALERP Harrisburg, PA 17103
'1011 Green Street Harrisburg, PA 17102 Chauncey Kepford Judith H. Johnsrud Ellyn R. Weiss, Esquire Environnental Coalition on Nuclear Power Harmon & Weiss 433 Orlando Avenue 1725 Eye St., NW, Suite 506 State College, PA 16801 Washington, D.C.
20006 i
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ATTACHMENT UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of
)
)-
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S PROPOSAL IN RESPONSE TO ALAB-729, CONDITION No. 5 In its decision on design issues, the Atomic Safety and Licensing Appeal Board imposed the following. condition:
Licensee shall submit to the. Commission prior to restart a proposed long-term solution to the steam generator bypass logic problem.
See pp. 163-64, supra.
ALAB-729, 17 N.R.C.
slip op, at 176 (May 26, 1983).
Licensee herein submits its proposal in response to Condition No. 5 of the Appeal Board's decision.
The Licensing Board Cecision The reliability of the emergency feedwater ("EFW") system l
at TMI-l was.the subject of extensive inquiry through Licensing 1/
Board Question No. 6.
See LBP-81-59, 14 N.R.C.
1211', 1353-1375 (1981).
One of the Licensing Board's concerns was for inad-vertent isolation of feedwater by the steam line rupture detection system.
Therefore, the Licensing Board required D
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No party raised EFW reliability as a contested issue.
Once raised by the Licensing Board, however, UCS pursued the matter
.with cross-examination, proposed findings of fact, and appeals.
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. that prior to~ restart, the Licensee propose for Staff approval, a long-term solution to the
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steam generator bypass logic problem for imple-mentation as.soon as possible after restart.
Prior to. restart,. the Staff.shall certify to the-Commission that the Licensee has made reasonable progress in initiating its program l
for the long-term solution.
Id. at 1374 (T 1064).
In response to the Licensing Board condition, Licensee
~
submitted to the Staff on August 2, 1982, a description of the modifications made to the Main Staam Line Rupture Detection System ("MSLRDS") and to the EFW System in order to prevent an inadvertent isolation of feedwater flow to the steam generators.
See Attachment A hereto.
In short, Licensee's proposed solution was to add cavitating venturis to the EFW s
System and to delete the MSLRDS signal to the EFW system.
The Staff has reviewed Licensee's proposal and, on November 10, 1982, issued a Safety Evaluation finding that the proposed modification is acceptable and satisfies the Licensing Board condition.
See Attachment B hereto.
The Appeal Board Decision Condition No. 5 of ALAB-729, quoted above, appears to repeat the Licensing Board condition that Licensee propose a long-term solution to the steam generator bypass logic problem, but requires that Licensee submit its proposal to the Commission rather than to the Staff.
See ALAB-729, slip op. at 162-164.
Licensee hereby submits its proposed long-term solution, previously reviewed and approved by the
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Staff, to ths Commission and rcqussts that ths Commission affirm
.s the Staff's finding that the Licensing Board's condition has 2/
been satisfied.
While the condition imposed by the Appeal Board only requires Commission, rather than Staff, review of Licensee's propcsal, alsawhere in its decision the Appeal Board " recommends" that-prior. to acceptance of Licensee 's proposal, the potential for containment overpressurization as a result of MSLRDS failure be evaluated.
ALAB-729, slip op, at 36, n.59.
Of course, Licensee's proposal addresses this concern with respect to emergency feedwater isolation.
The Appeal' Board raises'for the first time, however, its concern for over-pressurization of containment if the MSLRDS fails to isolate main feedwater during a steam line break accident.
~
Id.
This concern is clearly unrelated to the Licensing Board's concern for inadvertent feedwater isolation, and 3/
goes beyond the scope of the proceeding.-
Accordingly, the Appeal Board's recommendation s'ould be left for Staff n
4/
consideration outside of the restart proceeding and 2/
In response to an exception by UCS challenging the Licensing Board's delegation to the Staff of responsibility to review Licensee's - proposal auxi certify reasonable progress to the Commission, Licensee argued that the Staff's assigned task here was-fully consistent with its designatad role in the certification process established in the Commission's August 9, 1979 Order and Notice of Hearing.
See Licensee's Brief in Opposition to the Exceptions of Other Parties to the Atomic Safety and Licensing Board's Partial Initial Decision on Plant Design and Procedures, Separation, and Emergency Plan-ning Issues, at 116-119 (May 10, 1982).
3/
The Appeal Board recognized that a main steam line break accident is outside its purview.
ALAB-729, slip op, at 88.
l 4/
For example, Licensee's probabilistic risk assessment
.for TMI-l would provide an appropriate means for evaluating the scenario posed by.the Appeal Board.
should not be a considsration for lifting the suspension of.-
^
the TMI-l license.
Conclusion Licensee has proposed, and in fact already implemented, I
a solution to the concern raised by the Licensing Board.
1 Pursuant to th'e Appeal Board's condition, Licensee submits its proposal, already approved by the Staff, to the Commission.
The Appeal Board's new recommendation for a further evaluation of the potential for containment overpressurization during a main steam line break accident should not be a condition of restart.
Respectfully submitted, f
\\
SHAW, PITTMAN, POTTS & TROWBRIDGE George F. Trowbridge, P.C.
Thomas A. Baxter, P.C.
Counsel for Licensee 1800 M Street, N.W.
Washington, D.C.
20036 (202) 822-1090 Dated:
June 29, 1983
GPU Nuticcr Nuclear
" o a "'.' Pennsylvania 1 Middletown 717-944-7621 Wnter's Direct Dial Nurnber.
August 2, 1982 5211-82-153 Offica of Nuclear Raactor Regulation Aten:
John F. Stolz Operating Raactors 3 ranch No '4 Division of Licensing U.S. Nuclear Regulatory C d=sion Washington, D.C.
20555 Daar Sir:
Three Mile Island Nuclaar Station, Unit 1 (THI-1)
Operating Li - me No. DPR-50 Dockat No. 50-289 Main St==14"a Ruptura Detection Systa= Design Changes t =1 Decision (?ID) on design (Sea PD 1060-1064) the
.._ In its Par ial Tn4 4
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tamic Safsty and Licensing Board (ASL3) required that G7UN investigate
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design changas to the Main Staamlina Eupture Detection System (MSLRDS).
The changes are to prevent unnacassary isolation of fandvatar under single failura conditions.
A description and evaluation of the changes to the MSLRDS is attached.
This is submitted for NRC approval as requested by the ASU (? D 1064).
Sinearely, I
Director, TMI-l l
HDE:CWS:vj f Attachment ec:
R. C. Haynas R. Jacobs s
"ATA"TTI' A"
LM3E'i'aC l
Main S:=-1das Rupturo Ds:cetion Systa= Design Changes
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INTRODUC""!ON The Main St=-14== Rupture Detection System (MSL3DS) is actuated on icw stem =
generator pressure (below ap.mhtaly 600 psig) and au:=na:ically closes the Emergency Teodwater (EN) and Main Tendvater (FR) control valves :o isola:e f eed flov to the depressurized stamm ganarator.
If subsequently pressure rises above 600 psig in a steam generator the Em associated vi:h that s: man genera:or ic r,estored.
This MSLIDS action prevents overpressuriza:1on of contai= ment from.
steamlina breaks in conendmm e.
The ASL3 was concerned tha: the MSL2DS vould block all feedwater, including EN, to the staam generators :.s cartain scenarios vben it should not be blocked.
II.
SOLUTION The proposed solution to the above concern.consis:s of.:he addi: ion of cavi:a:1=p venturis and the dela. ion of the MSLEDS signal to :he Emergenev Teedva:e Sys:e=.
Low OTSG pressure, which actuates the MSLEDS, can resul: from either a severa overcooling or a main st=-14n= break event.
The original design reouired opera:
cetion to bypass MSLIDS to prevent a loss of haa sink if a low OTSG pressure condition developed and, singla failure then blocked E.
The addi:icn of the cavitating venturis to the EN System and removal of the MSUDS from.he IN
.h valves =14=4aates operator action to provida m :o the intac: OTSG in the even:
of'a singla failura.
Since the venturis also 11=1: EW flow, :he MSL2DS is :o.
longar required for E N and need not be up graded to safa:v 5:ade (?IO 10374) sir.
it is =14=4==ted.
III.
SAFETT EVAIRATION Deletion of the MSLIDS from the E N valves does not affact a=y of :he 75i1 accep:.
critaria.
The basis for this judgment is as follows:
The MSLEDS was installad to preven: ovarprassurization of the con:a " en: dua a Main Stre-14a. Braak (MSL3).
Ramoval of :ha MSLRDS fro = -le E W v:1ves vil :
maka TMI-1 feedvatar isolazion functionally :he same as TMI-2 in 1:s responsa a MSL3.
The IMI-2 MSL3' analysis was reviewed and approved by :he ERC (See OT.
FSAR, Chap. 15, Appendix 3).
The DfI-2 analysis is bouniing ior 2C-1 ior tha :
following reasons:
a)
The TMI-l venturis limi: :ocal flav :o a lower flov ra:e than the TMI-2 van:uris (1150 GPM vs.1250 G?M), and b)
TMI-l-cannot have a double OTSG blevdown in con:ain=en:
(limi:ing prassurization acciden: for DC-2) because :he main s:aam isolation valves are stop check valves for TMI-1.
Delacion of the.MSU.DS from the IN valves does ne: increase :he prob-
" amili:7 of occurrence of a s==*" e break acciden:.
The consecuences
.of the accide=:, as analyzed in t e DC-2 TSAP,have so:
been increased, h
"ATTAGM OiT J
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l Reactor 3"#1M g overprescurization does not occur and ths rcquired hea: rs=cval
' capability to prevent fuel damago is providcd.
Specifically, fuci damags vill i
ns: resul:, off-si:n doses vd'1 not be increanad, and steam genera:c: tubo integri:7 vill not be compromised.
The conclusions are confirmed inJ:he Res:ar:
)
Rcport, Section 8.3.9 which raf arancas the TEI-2 TSAR, Chapter 15, Aptandix 3.
l M flow is continued throughout the raf aranced analysis.
Addi: ion of cavita:i=g van:uris to the m system li=1:s the m== m flow a M-1 and assures tha:
d the rafaranced TMI-2 analysis is bounding for TMI-1.
Tur:har= ore, the sys a=s,
corpoints and/or plant condi:1ons that are utilized in :he referenced a=alysis era applicabla to both ~TEI-1 and M-2.
(Tha 3RC was also advised of the THI-l das:!,gn meM *4 cation in Hat-Ed response to II 3u11a-d-80-04 May 9, 1980 TI2. 228).
The rafsranced TEI-2 analysis assumed 17.AX/I. shu:down =argin and demons::a ad viola:e that the cora does not return to critica11ry and that the fuel rods do no:
a DN3R of 1.0.
Other asoumptions made in the raf aranced a=aly:is are more severe than those allowed by TM2-1 Tach. Specs., most notably power level (2772. ),
W and RCS flow (100%).
The design peaking factor of 1.78 used in THI-2 analysis azcaeds the curran: design p==k%! factor for TMI-1.
The referenced ste
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break analysis also demonstrated acceptable offsi:e doses and showed tha: O!SG uba 7::assas resul:ing from ha accident are accep able.
Tube stress :cudi:i=ns vare avaluated in 3AW-1588.
The results of this evalua: ion bound :he CC-1 In system desian with the MS12DS signal delanad froc the : il valves.
Other considerations and/or questions:
Overfilling of the OTSG is.an issue which has been raised and is documan:ed in the Rastar: Rapor=, Supplement.1, Par: 2, Quas ion 2.
The analysis presente
[
in the TMI-1 TSAR did not taka credin for 5 isola: ion via the l'E.F05 signal.
The uw flow rata assumed was 1500 GPM to one (1) OTSG a: 600 ?SIG (:he.T.DS set noint), this assumed flow is 2-h time :he flev ra:e availaole to one (1)
OTSG from the TMI-1 uw system vi:h cavita:ing ven:=ris inst'" ed.
Filling of the OTSG from the 50T ' operating range took 6.6 ninutes using :hase assumptions.
Therefore, the operator would have (vi:h the venturis installed and a fully opened centrol vaiva) approximately 16 inutes to :ernina:e an overfill condition due to IN flow.
The revised design therefore allows sufficient tima for the operator to terminate I.n'.
As discussed above, deletion of the MSLRDS signal to che IF valves does no:
introduce any accident or malfunc: ions no: previously evaluz:ed, nor does i:
incrassa the 14V-14kood of occurrence or consequences of any acciden: analyzed in the TMI-1 FSAR.
In conclusion, this modification does no: in:roduce any acciden or =a'.func:1ons prevd ously evaluated, nor does 1: increase the likelihood of occurrence or no:
consequences of a=y accidan: as analy ad in the TXI-1 TSAR.
No safe:y nargins will be reduced as a result of the modification.
Turther=cre, :he revised desig-OTSG improvas the reliability of the m Systa= to deliver flov to :he in:se:
and vill not create a contai= ment overpressurizacion or CTSG overfill condi:io=.
"ATGN;T A"
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"ATDCIMNT B" v
NijCLEAR REGLLATORY COMMISSION
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s e n [4 p 'l Docket No. 50-289 s
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- q" Mr. Henry D. Hukill j",
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Vice President GPU Nuclear Corporation l
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P. O. Box 480
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Middletown, Pennsylvania 17057 l
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Dear Mr. Hukill:
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.. In ~1ts Partial Initial Decision (PID) on design issues, dated December 14,
< (1981,. the Atomic Safety and Licensing Board (ASLB) for the TMI-1 restart proceeding specified that SPUN propose for staff approval a long tem
, solu'tfon to the problem of the Main Steam Line Rupture Detection System (MSLRDS) isolatihg all EFW flow in the event of a failure g
,c (paragraph 1064). The Board also specified that the staff review your? solution and car,tify to the Commission,that you have made reasonable Y'N prosrass in initiating 'ttre solution.\\
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',,Th's staff has reviewed ybur 'sdamitta11 dated August 2,1982 wharein you
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propose the addition of 'cavitating venturis in the EFW lines and s
. 0 sbbsequent reoval of the MSLROS signal from the EFW valves..We find g
your proposed solution acgptable'.We understand that this modification has bee,n completed.
- Hence, they(ard condition as specified in paragraph t
t fl0E4 is satisfied.
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4 10ur Safety Ev'aluation is enclosed, s
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Sincerely, N
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Jo n F. Stolz, Chief 0 rating Reactors Branch #4 ivision of Licensing
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Enclosure:
Safety Evaluation
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-l-50-28, TNI-l c
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n 1r. R.'J. Toole Jordan D. Cunningham, Esq.
danager, TMI-l Fox, Farr and Cunningham GPU Nuclear Corporation 2320 North 2nd street Harrisburg, Pennsylvania 17110 P. O. Box 480 17057 Middletown, Pennsylvania Ms. Louise Bradford
- Atomic Safety and Licensing Appeal Board TMIA U. S ' Nuclear Regulatory Comissiog 1011 Green Street 20'iS5 Harrisburg, Pennsylvania 17102 Wash {ngton,.D.C.
- Atomjc Safety and Licens$ng Board Panel Ms. Marjorie M. Aamodt U.,S.' Nuclear Regulatory Comission R. D. #5 Washington,,0. C.
2.0555 Coatesville, Pennsylvania 19320 u
- Docketing tend Service :'Section Earl B. Hoffm&n U. S. Nucle ~ar Rsgulatory. Comission Dauphin County Commissioner Washington, D. C.
20555 Dauphin County Courthouse N+
Front and Market Streets Cha'uncey Kepford Harrisburg, Pennsylvania 17101 Judith H. Johnsr4 Environmental Cailition' c,p Nuclear Power Union of Concerned Scientists 433 Orlando Avent.e x c/o - Harmon & Weiss State College, Pennsy,1wnia 16801 1725 I Street, N. W.
Suite 506
/^ Mudge Gary J. Edles, Chainnan Washington, D. C.
20006 Atomic Safety and Licensino Appeal Board U. S. Nuclear Regulatory Ccmission Mr. Steven C. Sholly -
Washington, D. C.
20555 Union of Concerned Scientists 1346 Connecticut Avenue, N. W.
J. B. Lieberman, Esq.
Dupont Circle Building, Suite 1101
~
Berlock, Israel & Lieberman Washington, D. C.
20036 26 Broadway New York, New York. 10004 Dr. Walter H. Jordan 881 W. Outer Drive Oak Ridget Tennessee 37830 se Dr. Linda' Wi t.ittle t
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5000 Hermitage Drive Raleigh, North Carolina) 27612 t
s Ms. Gail O.J,Bradford Anti-kuclear' Group Representing York
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245 W. Philadelphia Street York, Pennsys1vania 17404 John Levin, Esq.
Pennsylvania Public Utilities Commission BoC3265 Harrisburg, Pennsylvania 17120
~ ' Mr. Thomas Gerusky ATTN:
Doc w t Clerk '
Bu'reau of Radiation Protection 1725 I Streat, NW l
Department of Environmental Resources Washington, DC 20472 P. O. Box 2063
,-s-Harrisburg, Pennsylvania 17120 Karin W. Carter, Esq.
505 Executive House i
P. O. Box 2357 i
j Judoe Gary L: !?ilholli n Harrisburg, Pennsylvania 17120 4412 Greenwich Parkway, TAl t
Washington, D. C.
20007 Dauphin County Office Emergency G. F. Trowbridge, Esq.
Shaw, Pittman, Potts & Trowbridge Preparedness 1800 M Street, N.W.
Court House, Room 7 -
Washington, D. C.
20036 Front & Market Streets Harrisburg, Pennsylvania 17101 Mr. E. G. Wallace
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Licensing Manager GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey 07054 William S. Jordan, III, Esq.
Ms. Lennie Prough Harmon & Weiss U. S. it. R. C. - TMI Site 1725 I Street, Mh!, Suite 505 P. O. Box 311 Washington, DC 20006 Middletown, Pennsylvania 17057
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Ms. Virginia Southard, Chairman Citi: ens for a Safe Environment 264 Walton Street a
p Lemoyne, Pennsylvania 17043 Mr. Robert B. Borsum Babcock & Wilcox Nuclear Power Generation Division Suite 220, 7910 Woodmont Avenue
't Bethesda, Maryland 20814 f
- Ivan W. Smith, Esq.
Mr. David D. Maxwell, Chainnan Atomic Safety & Licensing Board Panel Board of Supervisors U.S. Nuclear Regulatory Commi sion Londonderry Township Washington, D. C.
20555 RFD#1 - Geyers Church Road Middletown, Pennsylvania 17057 Mr. C. W. Smyth Supervisor of Licensing TF1I-1 GPU Nuclear Corporation Regional Radiation Representative P. O. Box 480 Middletown, Pennsylvania 17017 EPA Reaion III Curtis Building (Sixth Floor) 6th and Walnut Streets Philadelphia, Pennsylvania 19106 Mr. Richard Conte Governor's Office of State Planning Senior Resident Inspector (TMI-1) and Developmer.t U.S.N.R.C.
ATTN:
Coordinator, Pennsylvania P. O. Box 311 State Clearinghouse Middletown, Pennsylvania 17057 P. O. Box 1323 Harrisburg, Pennsylvania 17120
. GPU NuclWr Cd7poWMtF d'#&U. W55U
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oJudge John H. Buck Atomic Safety and Licensing Appeal Board Panel U.S. Nuclear Regulatory Commission Washington, D.C.
20555 oJudge Christine N. Kohl Atomic Safety and Licensing Appeal Board Panel
' U.S. Nuclear Regulatory Consnission Washington, D.C.
20555 oJudge Reginald L. Gotchy Atomic Safety and Licensing Appeal Board U.S. Nuclear Regulatory Commis'sion Washington, D.C.
20555 11r. Ronald C. Haynes, Regional Administrator U. S. N. R. C., Region I 631 Park Avenue King of Prussia, Pennsylvania 19406 Board of Directors i
P.A.N.E.
P. O. Box 268 Middletown, Pennsylvania 17057 z.
cDr. Lawrence R. Quarles Atomic Safety and Licensing Appeal l
Board U. S. Nuclear Regulatory Commission Mail Stop EW-529 Washington, D. C.
20555 l
1 UNITED STATES E'
i NUCLEAR REGULATORY COMMISSION-i CASHINGTcN. D. C. 20665 g
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION THREE MILE ISLAND NUCLEAR STATION,. UNIT NO. 1 DOCKET NO. 50-289 Introduction.
The TMI-l Main Steam Line Rupture Detection System (MSLRDS) which is actuated by low steam generator pressure (,below approximately 600 psig),
automatically closes valves in the Emergency Feedwater (EN) system and Main Feedwater system to isolate feed flow to the affected once through steam generator (OTSG).
Because of the Board's concern that a failure of the HSLRDS could isolate all EW flow, the Board specified that the licensee propose for staff approval, a long term solution to this problem fc.a implementation as soon as possible after restart (ASLB PID dated December 14, 1981, paragraph 1064).
The Board also specified that the staff certify to the Comission that the licensee has made reasonable progress in initiating the long term solution.
By letter cated August 2,1982, the licensee proposed its solution to the above problem.
D_iscussion and Evaluation The licensee's proposed solution to the above problem consists of the addition of cavitating venturis:in the EN lines and then removal of the MSLRDS signal to the E m isolation valves.
In order to justify removal of the MSLRDS signal from the EW isolation valves, it must be demonstrated that the protection for which this signal is needed (namely a main steam line break event) is no longer required.
Other conditions such as effect on steam generator overfill also require consideration.
It is the licensee's position that deletion of the MSLRDS signal from the EW valves does not affect any of the FSAR acceptance criteria.
The licensee provides the following basis for this position.
The MSLRDS was installed to prevent overpressurization of containment due to a Main Steam Line Break (MSLB).
Removal of the MSLRDS signal from the EW valves will make the TMI-l feedwater isolation functionally the same as TMI-2 in its response to a MSLB.
The TMI-2 MSLB analysis was previously reviewed and approved by the NRC and the TMI-2 analysis is bounding for TMI-1 for the following reasons:
a)
The TMI-l venturis limit total flow to a lower flow rate than the TMI-2 venturis (1150 GPM vs 1250 GPM), and b)
TMI-1 would not be subjected to a doule OTSG blowdown in containment (the limiting pressurization event for TMI-2) because the TMI-l main steam isolation valves are stop check valves.
~.
43 The staff recently completed a review of the licensee's ana1Ysis of a main steam line break with continued feedwater addition on TMI-1 in response to IE Bulletin 80-04 The staff's evaluation which was issued July 21, 1982, concluded that there was no potential for containment overpressu-resulting from a MSLB.with continued emergency (auxiliary) riza tion feedwater. addition because the main feedwater system isolates and-emergency feedwater flow restrictors (cavitating ven'aris) limit flow It was also conc'uded 17 tha't EFW to the affected steam generator.
pumps will not experience runout, conditions and therebyAe'dantiged,
- 2) that no return to criticality occurs and 3) the DNB.R ratio remains
- Hence, greater than 1.3 in the event of a MSLB with continued EN flow.
the staff concludes that removal of the MSLRDS signal from the EFW valves will not adversely affect the ability to withstand a MSLB.
With regard to a steam generator overfill concern, the licensee had previously provided a steam generator overfill analysis (supp.1, part 2, question 2, Restart Report) which with the conservative assumptions of 1) flow through all three EFW pumps directed to one OTSG,
- 2) no EFW flow restrictors installed, and 3) the control valve fails full.open and no credit is taken for the MSLRDS signal to isolate EFW on Icw OTSG pecssure; indicated approximately 10 minutes (assumed best estimate F.N boiloff) was available for operator action before OTSG 1evel muid' reach the top of the shroud from an initial level of 50". on the operating range.
The licensee calculated that a minimum of 6.6 minutes would be available for the operator to take action if l
a conservative rate of EFW boiloff were assumed.
f The staff reviewed this analysis and the options available to.the operator to terminate the overfill condition and concluded that operator action could bd performed in thi time available (NUREG-0680, p 1-2).
l With the addition of the cavitating venturis, maximum EW flow would be reduced by a factor of 21/2 resulting in fill times approximately 21/2 times those previously analyzed, or 25 minutes for the best estimate boiloff assumption of 16 minutes for the conser'ative boiloff assumption.
Hence, since additional time would ue available for operator action-with cavitating venturis, we conclude that the proposed modification to remove the MSLRDS signal of EFW valves will not adversely affect the ability to control an overfill transient.
Conclusion, Because the deletion of the MSLRDS signal from the EFU valves does not affect the ability to withstand a MSLB accident and because, with the addition of cavitating venturis in the EFW lines, sufficient time is, available for the operator to teminate an overfill condition due to contiiued EW addition, we conclude that the proposed modification is acceptable and satisfies the Board's condition in paragraph 1064 of the December 14, 1981 ASLB PIO.
l i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE COMMISSION In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
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CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Proposal in Response to ALAB-729, Condition No. 5" were served this 29th day of June, 1983 by deposit in the U.S. mail, first class, postage prepaid, to the parties on the attached Service List.
I l
'T$~.= k. LR Thomas A. Baxter, P.C.
t 9
s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
SERVICE LIST Cbmiman Nunzio J. Pall =Aino Dr. Reginald L. Gotchy U.S. Nuclear Regulatory em=4=sion At mic Safety and Licensing Appeal Wadlington, D.C.
20555 Board Panel U.S. Nuclear Regulatory Camission emmimmimer Victor 414mky WashingtcT1, D.C.
20555 e
U.S. Nuclear Regulatory Camissim W==himton, D.C.
20555 Ivan W. Smith, Esquire ani man emmiazioner James K. Asselstire Atmic Safety and Licensing tard U.S. Nw lear Regulatory Omnission U.S. Nuclear Regulatory Comission Washington, D.C.
20555 Washington, D.C.
20555 7
Cam 4==ier John F. Ahearne Dr. Walter H. Jordan U.S. N m1= r Regulatory Ozmission At m ic Safety and Licensing Board Washingtm, D.C.. 20555 Panel 881 hest Outer Drive Ccamissioner 'Ihmas M. Roberts Oak Ridge, Tennessee 37830 U.S. Nuclear Regulatory nm=i== ion Washington, D.C.
20555 Dr. Linda W. Little At m ic Safety and Licensing Board Docketing and Service Section Panel Office of the S h e.ary 5000 Hermitage Drive
' U.S.- Nuclear Regulatory Cm=4== ion Raleigh, North Carolina 27612 Washington, D.C.
20555 James M. Cutchin, IV, Esquire Gary J. Edles, Esquire Office of the Executive legal Director ch=4 man U.S. Nuclear Regulatory Cm mi==4mn Atmic Safety and Licensing Appeal Washington, D.C.
20555 Board U.S. Nuclear Regulatory Ca mission John A. Ievin, Esquire Washington, D.C.
20555 Assistant Counsel Pennsylvania Public Utilty Ca mission Dr. John H. Buck P.O. Box 3265 Atmic Safety and Licensing Appeal Harr4M urg, Pennsylvania 17120 h
Board Panel U.S. Nuclear Regulatory Camission Robert Adler, Esquire Washington, D.C.
20555 Assistant Attorney General 505 Executive Fruse P.O. Box 2357 Harrisburg, Pennsylvania 17120
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-2..
Jordan D. Cunninghan, Esquire l ' ',
2320 North Second Street hrv4 *h rg, Pennsylvania 17110 j
i Ms. Iouise Braiford
IMI AIEle 1011 Green Street Harrisburg, Pennsylvania 17102 Ellyn R. Weiss, Esquire Bamnri & Weiss 1725 Eye Street,.N.W., Suite 506 Washington, D.C.
20006 Steven C. Sholly thion of Concerned Scientists 1346 Cu +11mt Avenue, N.W., Suite 1101 Washington, D.C.
20036 ANGPY/'lMI PIRC 1037 Maclay Street h d =h"g, Pennsylvania 17103 Willi m S. Jordan, III, Esquire Hannon & Weiss
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1725 Eye Street, N.W., Suite 506 W==himJten, D.C.
20006 Chauncey Kepford Judith H. Johnsrud Emria.u mital Coalition on Nuclear Power 433 Orlando Avenue State College, Pennsylvania 16801 Marjorie M. Amnodt R. D. 5 Coatesville, Pennsylvania 19320
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