ML20084P948

Requests That Commission Take Jurisdiction of Petition for Show Cause Re Emergency Feedwater Sys

ML20084P948
Person / Time
Site:	Three Mile Island
Issue date:	02/13/1984
From:	Weiss E UNION OF CONCERNED SCIENTISTS
To:	Gilinsky V, Palladino N, Roberts T NRC COMMISSION (OCM)
Shared Package
ML20084P942	List: ML20084P948
References
NUDOCS 8405210035
Download: ML20084P948 (6)

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UNION OF "

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SCIFNTISTS uo c_. u u u.w. . s. uot. % moou . ym -

8405210035 840503 PDR ADOcK 05000289 February 13, 1984 P PDR Nunzio J. Palladino, Chairman .

Victor Gilinsky, Connissioner Thomas M. Roberts, Connissioner James K. Asselstine, Commissioner Frederick M. Bernthal, Commissioner 1

Gentlemen: -

i On January 20, 1984, UCS petitioned the Commission for "an order-suspending the operating license for Three Mile 1siano Nuclear Station Unit - l No.1 ('TMI-l') tinless and until the plant's Emergency Feedwater ('EFW') System complies with the NRC rul,es applicable to systems important to safety (including safety-grade, safe ty-rel ated, and engineered safety feature

, systems)." Union of.ConcerneFScientists' Petition for Show Cause Concerning TMI-1 Emergency Feedwater System,' ~ January 20, 1984, p. 1. UCS' petition was

" lodged with the Commission directly because the NRC staff has reconnended restart of TMI-1 witn full Knowledge of the EFW deficiencies discussed [in the petition] and because the Connission now has under consideration action which would allow TMI-1' to operate oy lifting the 'innediate effectiveness' of its ordars of July and August,1979." g.,p.2,emphasisadded.

ByletterdatedJanut.ry27,'1}iB4,JHarold R. Denton informed me that UCS' petition "has been referred to [his) office for treatment as a recuest for action pursuant to Section 2.20G of the Commission's regul ations. "

s I am unaware of any Connission meeting or vote by which the Conunission referred UCS' petition to the NRC staff. 'Therefore, I as writing to inquire by what i means UCS' request that the Commission itself take jurisdiction was denied I and, if in fact it was denied, to request reconsideration of that denial. l I

The NRC staff was fully aware of the deficiencies in the TMI-1 EFW system '

(and the Main Steam Line., Aupture Detection System) before UCS filed its petition. Every citationgthe EFW deficiencies discussed in UCS' petition relies upon Licensing Boar 6 or Appeal ~ Board decisions, documents which GPU vovided to the NRC staff, or report:i prepared by the staff's contractors or the staff itself. Thus, . UCS' petiton contains no new factual information previously unavailable to the NRC ^ staff. By virtue of its continued inaction,.

the staff has manifested its views on these subjects; Connission delegation of the petition to the staff will simply delay resolution.

With regard 'to tha - q'd estion 'of whether, given the documented deficiencies -

the EFW system, TEI-1 sh.mid be allowed to operate, the staff has already

. . tided an implicit answer. On December 5. -1983, the staff presented its nroposal for TMI-1 restart conditions to the Connission. The staff made no

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mention of the EFW deficiencies acknowledged by GPU Nuclear in its lettar to the staff of August 23, 1983. The staff als~o~ voiced no opposition to GPU s

, proposal to delay correcting the acknowledged EFW deficiencies until the first refuel.ing after restart. H. iL !!ukill, Director, TMI-1, .ta J F. Stolz, iE staff, "TMI-1. . . Long Tem EFH Mods," August 23, 1983. (Licensee's counse' i

sent this letter to the Commission by a cover letter dated September 15, 1983.

Another copy is enclosed for your convenience.) '

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! The NRC staff's intention to ignore the EFW system deficiencies (or, at

bast, to " decouple" ' these issues from restart) was disclosed explicitly on January 27, 1984. Immediately after the Comission meeting that day regarding l TMI-1, an i ndividual approached Robert D. Pollard in my presence and

identified himself as a member of the NRC staff. The individual congratulated Mr. Pollard on the quality of the technical content of UCS' petition even though he "would probably be the one assigned to shoot it down."

This is only the most recent example of an attitude consistently exhibited by the NRC staff, which I most recently discussed with you during the Comission meeting on November 17,'1983. As UCS told the Commission:

No matter how technically credible an intervenor may be nor what legitimate issues it raises, the Staff makes virtually no attempt to meet with intervenors, to seriously consider whether their technical concerns have validity and whht if, any corrective action should be taken. Instead, the S.taff's imediate knee-jerk response is to find some justification for opposing the intervenor's positions on all ,

substantive and procedural issues, a stance which continues during the entire licensing process. "The State of the Nuclear Industry ~ and the NRC: A Critical View," UCS, November 17, 1983, p. 15.

The fact that a member of the NRC staff expressed his belief, one week after UCS mailed the Comissio' its petition, that the purpose of the staff's review of UCS' petition is to " shoot it down," illustrates that the staff's knea-jerk opposition to even legitimate safety issues is deeply ingrained. It also demonstrates the utter futility of referring UCS' petition to the staff.

I'In sumary , we repeat our request tha't the Comission itsel f take

jurisdiction of UCS' Petition for Show Cause Concerning TMI-1 Emergency i Feedwater System. In making this request, we do not mean to imply that the i

i staff should have no role.

By letter dated January 27, 1984, the staff asked GPU Nuclear to " submit ,

a response in writing under oath or af.fimation that addresses each of the issues identified by the petition as related to Three Mile Island Nuclear Station, Unit -1 and provide a response to [the staff] as soon as practicable, but no later than February 22, 1984." UCS requests the Commission to direct the licensee to submit its response directly to the Comission. We also recuest the Comission to direct the NRC staff to provide a similar response, in writing under oath or affirmaion by the individual staff member or memoers vno prepare tne response. In addi tion, we recomend that the Commission 70ct the NRC staff to provide the following infomation:

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1. Identify each specific aspei:t of the TMI' 1 EFW system which does not I comply or is not known to comply with the regulations applicable to systems imporant to safety (including safety-grade, safety-rel ated, and engineered safety feature systems).

2. For each deficiency or potential deficiency identified in response to item 1 above, explain whether and why the . staff believes that TMI-1 can be .

' operated without undue risk to public health and safety before correction of  !

tha deficiency or potential deficiency.

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3. For each deficiency or potential deficiency which the staff believes need not be corrected before the first refueling outage after restart, explain )

why that' deficiency ever needs to be corrected. In other words., if the staff believes that the plant can be operated without undue risk to public health and safety until the first refueling, why would modifications be needed to assure public health and safety after the first refueling?

Finally, UCS requests the Comission to direct the staff to provide UCS with copies of GPU's, the staff's and any other responses to UCS' petition.

Sincerely, -

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E13yn'R. Weiss GeneN Counsel Union of Concerned Scientists

Enclosure:

As stated.

cc w/ enclosure:

Docketing and Service, NRC

'l c= w/o enclosure:

-Herzel P1aine, Esq.

Gen ral Counsel, NRC

! Harold R. Denton, Director ~

Office of Nuclear Raactor Regulation Mr. Henry D. Hukill .

l Director of TMI-1, GPU Nuclear Corp.

I Maxine Woelfling, Esq.

PA Dept. of Environmental Resources Thomas A. Baxter, Esq.

I Ccunsel for Licensee l

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REQUEST FOR ADDITIONAL INFORMATION ENVIRONMENTAL QUALIFICATION OF EFW SYSTEM ELECTRICAL EOUIPMENT RESPONSE TO UCS 2.206 PETITION OF JANUARY 20, 1984 0FFICE OF NUCLEAR REACTOR REGULATION THREE MILE ISLAND, UNIT 1 ,

DOCKET NO. 50-289 l

1. Following is a list of EFW system electrical equipment, located in a potentially harsh environment area identified by GPU.

TER Item Eouioment Manufacturer Model Taa No(s). No.

Motorized Valve Limitorque SMB-0 EF-V2A&B 11 Actuators Motorized Valve Limitorque SMB-000 EF-VIA&B 15 Pump Motors Westinghouse HP 450 EF-P2A&B 51 Cable Continental Wire 107 and Cable Co.

Cable Kerite 106 Diodes Square D JTXIN6071A Replaced 116 Terminal Block States NT 110 Flow Transmitters Foxboro NE 13DM FT-791, 799, None 782 & 788 E/P Converters Bailey RP-1211C SP-V5A&B 60 Limit Switches Namco D2400X2. LSA/MSV06 66 LSB/MSV-6 Limit Switches Namco D1200G2 LSA/MSV-13A&B 67 LSB/MSV-13A&B Limit Switches Fisher LS/EFV-30A&B None Solenoid Valves ASCO LB8201C94 SV3/EF-V-30A&B 26 SV4/EF-V-30A&B l _

1 TER Item Equipment Manufacturer Model Tac No(s). No.

Solenoid Valves ASCO 8300C6BG 'SV1/EF-V-30A&B 28 SV2/EF-V-30A&B Solenoid Valves ASCO LB83146 SV/EF-V-8A,8&C 31 D/P Switches Barton 277A FI-S-77,78&79 77 Confirm that the above is a complete list of the EFW system electrical equipment located in a harsh environment; or, if not, identify any additional equipment. For each item of additional equipment identified, provide all documentation relied upon to demonstrate qualification. The documentation should address the appropriate comments contained in the enclosure to the staff's April 25, 1984 letter to GPU. Justification for exempting from qualification of any additional equipment identified should be provided using the guidance noted below in 2.b.

2.a Justification provided by GPU for exempting certain EFW system electrical equipment from qualification is given below.

NAMC0 Limit Switches - TER Item Nos. 66 and 67 Under LOCA and MSLB sufficient flow is provided to the OTSG's by a single motor driven EFW pump. (See GPUN letter dated 3/22/83). The steam driven EFW pump is only required for station blackout which does not produce a harsh environment. Failure of the limit switch (MSB-6) with MSV-6 open may result in initially overfeeding the OTSG's which could be reduced immediately (Manually) based on qualified EFW flow and 0TSG level instrumentation.

Therefore, the EFW system will function and the operator will not be misled.

Failure of the limit switch (MSB-13) results in the inability to monitor valve position and may result in lifting reliefs but tecause of qualified EFW flow and OTSG level this will not mislead the operator.

Fisher Limit Switches - No TER Item No.

These switches are used for diagnostic purposes only. Flow indication for the emergency feedwater system is provided by the qualified redundant flow indicators sensed by FT-779, 782, 788 & 791. They have been installed in accordance with the requirements of Item II.E.1.2 of NUREG-0737. A secondary indication of emergency feedwater flow is provided by the qualified steam generator level indication system.

l ASCO Solenoid Valves - TER Item Nos. 26 and 28 l

As described in GPUN letter dated August 2,1982(82-183) GPUN has removed the EFW 1atch signal from the EFW control valves. Therefore this l solenoid is no longer required to be qualified.

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ASCO Solenoid Valves - TER Item No. 31 These EF bypass valves have been electrically disconnected and remain open.

Barton D/P Switches - TER Item No. 77

! These switches are associated with the valves, TER Item No. 31 and are no longer required to indicate valve position since the valves remain open.

b. The licensee is required to provide the following information before we can determine the acceptability of the above justifications.

NAMCO Limit Switches

1. An analysis of the effects that failure of the limit switches could have an other electrical equipment important to safety, e.g., if the switches are used in an interlock circuit for other equipment.

. 2. A discussion of the c.nergency procedures used by the operator, whether j

the operator is directed to rely on information from these limit switches for valve positions, how and when the operator will manually i and "immediately" reduce overfeeding of the OTSGs in the event the limit switches on MSV-6 fail, and why qualified EFW flow and OTSG level preclude the operator from being misled if the limit switches

, on MSV-13 fail.

3. A discussion on the desirability of the operator needing to "immediately (manually)" reduce overfeeding the OTSGs because of failure of the MSV-6 limit switches, and the desirability of relief valves lifting because of MSV-13 limit switches failing.

i Fisher Limit Switches

1. Same as 1. above for limit switches.

2. A discussion of the emergency procedures used by the operator and whether these procedures direct the operator to rely on information from these limit switches.

ASCO Solenoid Valves

1. An analysis of the effects that failure of the solenoid valves could i have on other electrical equipment. important to safety, e.g.,

! disruption of Class IE power on the circuit to which the solenoid valves are connected.

2. For TER Item No. 31, provide the justification for qualification exemption.

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Barton D/P Switches

1. Address failure of these D/P switches similar to 1. above for the limit switches.

2. A discussion of the emergency procedures used by the operator and whether these procedures direct the operator to rely on information from these D/P switches.

, 3. Provide the justification for qualification exemption.

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