ML20083D880
| ML20083D880 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/23/1983 |
| From: | Baxter T METROPOLITAN EDISON CO. |
| To: | NRC COMMISSION (OCM) |
| References | |
| NUDOCS 8312280333 | |
| Download: ML20083D880 (9) | |
Text
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'l Dncember 23, 1983 i 1 DOCKETED UNITED STATES OF AMERICA USNRC NUCLEAR REGULATORY COMMISSION 13 DEC 27 M0 56 BEFORE THE COMMISSION OFFIE OF SEf?EM COCsETthG & SE?VJ.
A*'
In the Matter of
)
)
METROPOLITAN EDISON COMPANY
)
Docket No. 50-289
)
(Restart)
(Three Mile Island Nuclear
)
Station, Unit No. 1)
)
LICENSEE'S REPLY TO UCS RESPONSE TO GPU LETTER OF DECEMBER 6, 1983, REGARDING EMERGENCY FEEDWATER FLOW INSTRUMENTATION On December 6, 1983, Licensee distributed to the Commission and the parties to this proceeding, as information potentially relevant and material to matters under adjudication in the plant design and procedures phase of the proceeding, a letter (5211-83-346) of November 23, 1983, from GPU Nuclear to the Staff on recent testing of Emergency Feedwater flow instrumentation.
On December 9, 1983, UCS filed with the Commission, " Union of Concerned Scientists Response to GPU Letter of December 6, 1983, Regarding Emergency Feedwater Flow Instrumentation"
("UCS Response").
UCS characterizes the November 23 GPU Nuclear letter as a request for an exemption from a short-term, " lessons learned" requirement, and then urges that the request be denied.
Licensee submits this reply to the UCS Response in order to correct the serious factual errors in the UCS pleading, which otherwise might be overlooked because of the 8312280333 831223 PDR ADOCK 05000289 G
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- 4 extent and exaggerated nature of the misplaced arguments which are built upon them.
The GPU Nuclear letter of November 23 reports that recent tests performed on the EFW system in conjunction with OTSG testing indicated oscillations in the differential pressure EFW flow measuring system of greater than 10% at low flow conditions (less than approximately 100 gpm).
The tests indicated that at high flow conditions (above 400 gpm) the d/p flow instruments are within 10%.
The letter provided the bases upon which Licensee has concluded that the oscil-lations at low ficws do not affect the functional capability of the EFW system or the ability of the operator to take proper action and are, therefore, acceptable.
The first and most serious error in the UCS Response is its argument that 10% accuracy represents a performance criterion which is a part of the " lessons learned" require-ment for EFW flow instrumentation.
While UCS cites relevant portions of NUREG-0578 (TMI-2 Lessons Learned Task Force Status Report and Short-Term Recommendations), NUREG-0737 (Clarification of TMI Action Plan Requirements), and the decision of the Atomic Safety and Licensing Board in this proceeding, UCS ignores the fact that none of these refer-I ences establishes or even discusses such a performance 1/
criterion.~
In short, there is absolutely no basis for 1/
Supplement 3 to the Staff's SER (NUREG-0680) on TMI-l Restart notes that Item II.E.1.2 of NUREG-0737 contains the f
latest position and clarification for emergency feedwater flow indication.
Staff Ex. 14 at 38.
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- the UCS characterication of i10% accuracy as a " requirement" i
for EFW flow instrumentation, and no need for the fictional
" exemption request" against which UCS so vigorously argues Second, the UCS Response ignores the limited flow regime for which the oscillations occur, and proceeds to postulate the complete absence of EFW flow indication.
For example, UCS recalls the absence of EFW flow in the early minutes of the TMI-2 accident -- a situation in which flow indicati on.
might have facilitated operator action.
UCS Response at 4.
This is irrelevant to the low flow oscillations reported in the GPU Nuclear letter.
In a TMI-2 accident condition, full EFW flow would be desired, and the instrumentation install d e
would fully meet the lescon learned from the accident UCS confidently reports that Licensee has overlooked l
l the fact that the EFW pumps are cooled by EFW flow so that if the flow control valves are closed, a failure of the pump recirculation flow paths could require prompt operator action to prevent failure of the EFW pumps.
UCS Response at 4-5.
The EFW system is configured such that with the EFW flow control valves closed, recirculation flow is still provided to the EFW pumps (via locked open recirculation line valves) to prevent pump damage.
UCS apparently is not aware that Licensee has committed to lock open the EFW pump recircul a-tion line valves.
Consequently, this UCS scenario is not valid.
UCS distorts, and represents as Licensee's, the statement that during manual control of EFW flow the operator's
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-4 attention would not be on EFW flow indication. Rather, the GPU Nuclear letter states that the operator would not control flow based upon this indication alone.
Licensee is not pro-posing to limit the operator's attention to a few instruments to the ignorance of others.
Rather, UCS itself violates this " lessons learned" principle by addressing its arguments to EFW flow instrumentation in isolation from other indicators (e.g.,
steam generator level and pressure).
See UCS Re-sponse at 5.
l Finally, UCS asserts that during the TMI-2 accident, the operators did not rely on instruments which were not safety grade.
UCS Response at 5-6.
The EFW flow instrumen-tation at TMI-1, however, is safety grade.
In conclusion, the UCS Response misrepresents the NRC's requirements, mischaracterizes Licensee's report on the EFW system tests, reflects a misunderstanding of EFW system configuration, and ignores other available instrumentation.
Respectfully submitted, SHAW, PITTMAN, POTTS & TROWBRIDGE m
Thomas A.
Baxter Counsel for Licensee 1800 M Street, N.W.
Washington, DC 20036 (202) 822-1000 rt
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)
)
CERTIFICATE OF SERVICE This is to certify that copies of the foregoing
" Licensee's Reply to UCS Response To GPU Letter of December 6, 1983, Regarding Emergency Feedwater Flow Instrumentation" were served by deposit in the U.S. Mail, first class, postage prepaid, to all those on the attached Service List, this 23rd day of December, 1983.
Thomas A.
Baxter Dated:
December 23, 1983 n
9 UNIHD STAHS OF AMERICA i
NUCIDR REGUIMORY COMISSICN BEFORE 'IHE COMISSION In the Matter of
)
)
ME110POLITAN EDISCN 034PANY
)
Docket No. 50-289
)
(Restart)
('Ihree Mile Island Nuclear
)
Station, Unit No. 1)
)
SERVICE LIST Chairman Ihnzio J. Palladino Dr. Reginald L. Gotchy U.S. Nuclear Regulatory Comnission Atcmic Safety and Licensing Appeal Washington, D.C.
20555 Board U.S. Nuclear Regulatory remnission Ccanissioner Victor Gilinsky Washington, D.C.
20555 U.S. Nuclear Regulatory Ccmuission Washington, D.C.
20555 Ivan W. Smith, Esquire Chairman, Atanic Safety and Licensing Ctanissicner 'Ihamas M. Roberts Board U.S. Nuclear Regulatory Ccanission U.S. Nuclear Regulatory Ccmnission Washington, D.C.
20555 Washington, D.C.
20555 Ctanissioner James K. Asselstine Sheldon J. Wolfe, Alternate Chairman U.S. Nuclear Regulatory Cannission Atanic Safety and Licensing Board Washington, D.C.
20555 U.S. Nuclear Regulatory Ctenission Washington, D.C.
20555 Ccmmissioner Frederick M. Bernthal U.S. Nuclear Regulatory Ceniasion Mr. Gustave A. Linenberger, Jr.
Washington, D.C.
20555 Atanic Safety and Licensing Board j
U.S. Nuclear Regulatory Ccmnission
/ Docketing and Service Section Washington, D.C.
205S5 Office of the Secretary U.S. Nuclear Regulatory Ccmnission Richard J. Isson, Esquire Washington, D.C.
20555 Office of Dcecutive Iegal Director U.S. Nuclear Regulatory Ccmnission Gary J. Edles, Esquire Washington, D.C.
20555 Chalzman, Atcmic Safety and Licensing Appeal Board John A. Iavin, Esquire U.S. Nuclear Regulatory Ccanission Assistant Counsel Washington, D.C.
20555 Pennsylvania Public Utility Ccrmission P. O. Box 3265 Dr. John H. Buck Harrisburg, PA 17120 Atanic Safety and Licensing Appeal Board Marjorie M. Aamodt U.S. Nuclear Regulatory Ccmnission R. D. 5 Washington, D.C.
20555 Coatesville, PA 19320 I
6 Douglas R. Blazey, Esquire Steven C. Sholly Chief Counsel Union of Concerned Scientists Department of Envirornental Resources 1346 Connecticut Avenue, N.W.,
- 1101 514 Executive House, P. O. Box 2357 Washington, D.C.
20036 Harrisburg, PA 17120 ANGRY /D(I PIBC Ms. Iouise Bradford 1037 Maclay Street D(I ALERP Harrisburg, PA 17103 1011 Green Street Harrisburg, PA 1710Z Chauncey Kepford Judith H. Johnsrud Ellyn R. Weiss, Esquire Erwironnental Coalition on Nuclear Power Harmon & Weiss 433 Orlando Avenue 1725 Eye St., NW, Suite 506 State College, PA 16801 Washington, D.C.
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GPU Nuclear Corporation
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7 Post Office Box 480 Route 441 South
%dcletown. Pennsylvania 17057 019*.
717 944 7621 TELEX 84 2386 Writer's Direct Dia' Nur**.ber:
Nove=ber 23, 1983 5211-83-346 Office of Nuclear Reactor Regulation Attn:
J. F. Stolz, Chief Operating Reactors Branch No. 4 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D.C.
20555 bear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 EW Flow Devices (D/P) Testing
- w In our submittal of August 25, 1983 (5211-83-231), GFUN described t5e differ-ential pressure (d/p) flow measuring system using annubars for the Emergency Feedwater System.
In item III.F of the enclosure to that letter, we indicated i
that "the flow instrumentation are reliable and accurate and are designed to I
monitor the full range of system flow requirements".
Recent tests performed on the EW system in conjunction with OTSG testing indicated oscillations at low flow conditions (less than approxi=ately 100 gp=) outside the 1 10% criteria.
GPUN's preliminary evaluation concludes that cavita: ion on the outle: of the feedwater flow control valve during low flow condizions caused the oscillations.
Tests indicate that at high flow conditions (above 400 gp ) the d/p flow instru-ments are within i 10%.
We have concluded that the oscillations at low flows do not affect the functional capability of the EW system or the ability of the operator to take proper action and are, therefore, acceptable for the following reasons:
Emergency feedwater flow is initiated automatically on loss of all RCS a.
pu=ps or both feedwater pu=ps.
Should initic:ict occur, the accuracy of the instrument would be within allowable li=its for high flows to confir= that EW flow is sufficient.
For icw flow conditions the flow instru=ent confir=s the proper initiation of EW (i.e. flow is occuring).
Accuracy of flow rate is not necessary at low flovs.
In addition. ZW flow would be automatically controlled by the ICS on steam genera:or level, no: EW flow rate. Sased on this, :ne :.:n flow devices will provide indication to the operator tha: the sys:e: is fune ioning.
GDU Nuclear Corporation is a subsiciary o':he Ge. era: :u !i: U:hities Ccr:craper I
______-___--____D
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During manual takeover of the emergency feedvater syste=, the operator does not control feed flow based on this flow indicating instrument alone.
Emergency Feedwater continues te be contrelled based on CTSG level and pressure (level to prevent over/under-filling and pressure to prevent over-cooling).
The operator's attention is focused on these instruments when regulating fles. The emergency feedwater flow indication provides only one positive means of verifying t' hat flow is being delivered to the steam generators; it is not relied upon to regulate flow.
This clarification describes the EW d/p flow system as currently installed and tested. Therefore, GPUN concludes that the EFW flow indicating system is acceptable and meets the requirements of NUREG 0737 and our commitment reflected in the Partial Initial Decision of December 14, 1981. However, during the Power Esca-lation testing. data vill be collected and used to assist the operators in under-standing how the E N flow devices are expected to perform under various EW flow conditions.
Sincerely, o
H. D.
11 Director of TMI-1 EDH:LWH:vj f:jrg cc:
J. Van Vliet R. Conte y..
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