ML20082B008

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Forwards Summary of 831109 Meeting W/Util & PA Dept of Environ Resources Re NRC SER on Steam Generator Repair. Issues Resolved
ML20082B008
Person / Time
Site: Crane Constellation icon.png
Issue date: 11/14/1983
From: Phyllis Clark
GENERAL PUBLIC UTILITIES CORP.
To: Harold Denton
Office of Nuclear Reactor Regulation
References
5211-83-340, NUDOCS 8311180322
Download: ML20082B008 (3)


Text

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.4 GPU Nuclear Corporation a sipp y.New Je sey 07054 201 263-6500 TELEX 136-482 Writer's Direct Dial Number:

November 14, 1983 5211-03-340 Office of Nuclear Reactor Regulation Attn: Harold R. Denton, Director U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Sir:

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

Operarting License No. DPR-50 Docket No. 50-289 Commonwealth of Pennsylvania Comments on TMI-l Steam Generators Attached is a summary of a November 9 meeting with GPUN personnel and T.

Gerusky and W. Dornsife, Pennsylvania Department of Environmental Resources, to discuss the Comonwealth's comments on the NRC Staff's SER on steam genera-tors (Ref. Commonwealth Letter:

T. Gerusky to Secretary of the Ccamission dated September 26,1983). The summary describes the discussion and resolu-tion reached on the concerns raised by the Commonwealth in their September 26 letter to the staff. We do not believe any issues remain unresolved between GPUN and the Comenwealth.

Sincerely,

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&L!v P. R. Clark Executive Vice President

/mt Attachment cc:

J. F. Etolz Ca2 8311180322 831114 PDR ADOCK 05000289 P

PDR GPU Nuclear Corporation is a subsidiary of the General Public Utahties Corporation

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a s ppany.New Je sey 07054 201 263-6500 TELEX 136-482 Writer's Direct Dial Number:

November 14, 1983 Department of Environmental Resources Attn: Thomas Gerusky, D! rector Bureau of Radiation Pro'.ection Bcx 2063 Harrisburg, PA 17120

SUBJECT:

November 9 Steam Generator Meeting On November 9, 1983, we met with you and a member of your Staff to discuss concerns raised in the Comonwealth's September 26 letter to the NRC, com-menting on the Commission's evaluation of the TMI-1 steam generators. The issues discussed were the following:

1.

itonitoring of routine releases.

2.

Redundant monitoring of condenser off-gas for primary-to-secondary leak rate determination.

3.

Tube rupture procedures.

This letter is provided to sumuarize agreement reached on these issues, l

With respect to the first two items, your representatives indicated that suf-l ficient technical information had already been provided in our May 21 response to your questions on the GPUN Topical Report 008 on steam generators. He l

understand that the intent of your comment was to request an augmented i

discussion in the NRC SER of total secondary plant releases as they may be effected by the cperation cf the OTSG, as well as the capability of monitoring l

release points. We will encourage the NRC Staff to expand or supplement the Staff SER to meet your request.

l As a side issue, the Comonwealth expressed one concern related to the second item, redunoant monitoring of the condenser off-gas monitor, Rif-A5 Low. The r

higher ~ range monitors, R!l-A5 High and Ril-G25, while providing backup indica-tion of leak rate increases in the event Rit-A5 Low is inoperable, do not provide alarms at the same low leak rate levels. At the Commonwealth's l

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l GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation

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. request, GPUN agreed to review the bases for the RM-A5 High and RM-G25 alarm setpoints to determine whether they can be lowered. GPUN will inform you of the results of this review when complete.

Regarding the Commonwealth comments on tube rupture procedures, we understand your concerns center on the flexibility afforded in deciding when to isolate a faulted steam generator, and the potential offsite doses associated with such a decision. As we discussed with you, the major objective of the procedure is to minimize offsite radiation exposure in a manner consistent with minimizing overall risk. The arocedure is intended to provide detailed guidance for the operators to meet t1at objective during the first hour or so of the event. As written, the procedures assure that a faulted steam generator producing exces-sive offsite releases would be isolated, but that if releases are not exces-sive, the steam generator will be left in service, thereby retaining as many options as possible to respond to the event.

After an hour, the emergency organization wi1*. be in place. As you are aware, one of its functions is to evaluate the suitability of continuing to use procedures as written in light of the actual plant situation, and to provide formal changes to procedures or additional procedures as necessary.

In addi-tion, the Emergency Plan explicitly provides the Emergency Director the authority to violate any procedure as necessary in an emergency, thus allowing him the flexibility to order isolation of the affected steam generator at any release rate that he determines appropriate. Minimizing offsite releases while maintaining overall safety would be a major consideration in making any decision to deviate from the procedures, as written. Recommendations from the Commonwealth or any other offsite agency would certainly be considered and acted upon as appropriate to the situation at hand. We understand that this l

clarificaton on the flexibility in applying guidelines addresses the concerns l

in your letter to the NRC, and that the Commonwealth has no further objections to the tube rupture procedures as written.

l We would like to thank you for the opportunity to discuss your concerns and questions. If there is any additi:nal information needed which we can pro-vide, please feel free to contact us.

Sincerely,

' r?

nt h P. R. Clark Executive Vice President

/mt 1

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