ML20125C289
| ML20125C289 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/26/1985 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | Asseltein J, Asseltine J, Bernthal F, Palladino N, Roberts T, Zech L NRC COMMISSION (OCM) |
| References | |
| CON-#285-746 5211-85-2084, OLA, NUDOCS 8506110715 | |
| Download: ML20125C289 (6) | |
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NUCIMf GPU Nuclear Corporation 100 lnterpace Parkway Parsippany. New Jersey 07054-1149.
00LXETED (201)263-6500 USNEC TELEX 136-482 Writer's Direct Dial Number:
April 26,198p3 APR 29 A11 :1fE01) 263-6797 5211-85-2084 0FFICE OF SECFt.TAfo 00CdEIlhG & SEi4VICF BRANCH Nunzio J. Palladino, Chairman Thomas M. Roberts, Comissioner James K. Asselstine, Comissioner Frederick M. Bernthal, Comissioner Lando W. Zech, Comissioner U.S. Nuclear Regulatory Comission Washington, DC 20555 Gentlemen:
Three Mile Island Nuclear Station Unit 1 (TNI-1)
Operating License No. DPR-50 Docket No. 50-2890 M Steam Generator Tube Rupture knalysis This letter is in response to your request during the pub 11c meeting of April 18,1985, to provide an estimate of the time required to perform an augmented TMI-1 steam generator tube rupture analysis.
As requested, we contacted the Union of Concerned Scientists (UCS) to obtain their view of analysis assumptions as the basis for performing such l
calculations. These assumptions are shown on the attachment. UCS indicated i
to us that the intent of their description was to define the analysis currently required by the Staff for an operating license applicant. The UCS t
analysis assumptions are not, however, consistent with those published by the Staff and used for recently issued operating licenses. To our knowledge, no U.S. nuclear plant has ever been analyzed to the UCS proposed assumptions.
I We are, therefore, unable to provide any meaningful estimate of the time to i
conduct the analysis proposed by UCS because of the lack of precedent and l
uncertainty which such pioneering analysis would entail. Furthermore, such assumptions are so unrealistic, requiring for example simultaneous loss of off-site power and unavailability or loss of both diesels, that we believe any results would be of little, if any, use regarding TMI-1 or other plants.
8506110715 850426 PDR ADOCK 05000289 l
P PDR cpu nxiear Cerate is a s@sdary of General Pm UtMbes Corporate w
i U.S. Nuclear Regulatory Commission April 26,1985 i
i Page Two I
A B&W report (Document #74-1149184-03, dated March 1985) sponsored by B&W operating plant owners has been recently submitted to the Staff. This report I
reflects steam generator tube rupture generic analyses covering all B&W oper& ting plants and includes the loss of off-site power.
The TMI-1 tube i
rupture procedures are consistent with this report and were developed to satisfy 10CFR Part 100 limits. This report provides a basis for assessing i
TMI-1, and it is suggested any additional analysis be approached only after Staff review.
i However, if a TMI-1 specific analysis were to be performed, (in i
accordance with NRC Standard Review Plan, paragraph 15.6.3 - NUREG 0800, Rev 2), approximately four to six months would be required.
I recognize that at the April 18 meeting, you had not had the opportunity to review my letter to the Commission (dated April 18, 1985, reference 5211-85-1077) responding to the April 5 UCS letter, nor the accompanying letter from the Licensee's Counsel to the Consitssion. We believe that these l
documents show there is a sound basis underlying current TMI 1 steam generator j
tube rupture procedures.
I also believe they show that to the extent the UCS allegations are considered it should be separate and apart from the restart proceeding.
j In reviewing the transcript of the April 18 meeting, I believe it would be helpful to reinforce a significant point. Underlying many of the intervenor J
allegations on this matter is the presumption that the unplugged tubes in' the TMI-1 steam generators are somehow less structurally capable than tubes in other steam generators.
In fact, the tube material in TMI-1 has been confirmed by tests to be equivalent to new as-installed material (Reference TR 008i.
These tests were performed on tubes removed from the TMI-1 steam-generators after the sulfur attack was discovered.. The tubes can withstand design basis loads with the same margins as other similar steam generators.
I would also like to confirm reasons why we adopted revised tube rupture procedural guidance for the plant.
I am aware of the UCS letter of April 18 which quotes from an internal GPUN report dated December,1983. Our assessment is perhaps best captured in the transcript of the meeting on Page 109 in which 1
Commissioner'Bernthal asked " Suppose that the steam generators were in crisp, i-new condition, would you go to this procedure anyway?"
I replied, "Yes sir, i
absolutely".
I wish to reiterate that position again.
We believe the current procedural guidance at TMI is the best we can put in place and would use the i
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U.S. Nuclear Regulatory Commission April 26,1985 Page Three same procedural guidance for a new plant.
This procedural guidance is the culmination of work started in.the 1979,1980 time frame, initiated by NUREG 0578 (July 1979) which provided the following direction: "
- Analyses, procedures, and training addressing the following are required:
(1) Small break loss-of-coolant accidents; (2) Inadequate core cooling; and (3)
Transients and accidents."... and was further discussed in NUREG 0565 (January 1980).
In summary, we believe the THI-1 steam generators are suitable for operation in every respect.
Very truly yours, b*
P. R. Clark President PRC/RFW/a1 ATT cc:
R. Conte T. Murley J. Stolz TMI-1 Service List
ATTACHMENT The following list is the Union of Concerned Scientists' assumptions to be used when performing a Steam Generator Tube Failure Analysis:*
1.
Assume plant operation in accordance with Technical Specification, i.e.,
I some safety equipment inoperable (assume the worst Technical Specification condition exists with respect to systems availability) 2.
Tube rupture accident occurs 3.
Assume loss of off-site electrical power
~ 4.
Assure single failure 5.
Evaluate whether core damage and off-site radiation doses within regulatory limits relying only on remaining safety grade equipment
Reference:
- a. Union of Concerned Scientists' response to NRC Staff comments on degraded steam generators at TMI Unit 1, April 18,1985
- b. Phone conversations between T. Baxter (Licensee Counsel) and UCS General Counsel E. Weiss, April 23, 1985 9
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-a e
SERVICE LIST I
Nunzio J. Palladino, Chairman Administrative Judge i
U.S.. Nuclear Regulatory Commission Gustave A. Linenberger, Jr.
Washington, D.C.
20555 Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Thomas M. Roberts, Commissioner Washington, D.C.
20555 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Administrative Judge Gary J. Edles James K. Asselstine, Commissioner Chairman, Atonic Safety and U.S. Nuclear Regulatory Commission Licensing Appeal Board Washington, D.C.
20555 U.S. Nuclear Regulatory Commission-Washington, D.C.
20555 Frederick Bernthal, Commissioner U.S. Nuclear Regulatory Commission Administrative Judge Washington, D.C.
20555 John H. Buck Atomic Safety and Licensing Lando W.
Zeck, Jr., Commissioner, Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission' Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Administrative Judge Ivan W. Smith Christine N. Kohl Chairman, Atomic Safety and Atomic Safety and Licensing Licensing Board Appeal Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Administrative Judge Docketing and Service Section (3)
Sheldon J. Wolfe Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C..
20555 Washington, D.C.
20555 Atomic Safety and Licensing Mr. Henry D.
Nukill Board Panel Vice President U.S. Nuclear Regulatory Commission GPU Nuclear Corporation Washington, D.C.
20555 P.
O.
Box 480 Middletown, PA.
17057 Atomic Safety and Licensing Appeal Board Panel Mr. and Mrs. Norman Aamodt U.S. Nuclear Regulatory Commission 200 North Church Street Washington, D.C.
20555 Parkesburg, PA.
19365 Jack R. Goldberg, Esquire Mrs. Louise Bradford Office of Executive Legal Director TMI ALERT U.S. Nuclear Regulatory Commission 1011 Green Street Washington,'D.C.
20555 Harrisburg,-PA.
17102
r SERVICE LIST Page 2 Thomas Y. Au, Esquire Joanne Doroshow, Esquire Office of Chief Counsel The Christic Institute Department of Environmental 1324 North Capitol Street Resources Washington, D.C.
20002 505 Executive House P. O. Box 2357 Lynne Bernabei, Esquire Harrisburg, PA.
17120 Government Accountability Project Michael F. McBride, Esquire 1555 Connecticut Avenue LeBoeuf, Lamb, Leiby & MacRae Washington, D.C.
20036 1333 New Hampshire Avenue, N.W.
Washington, D.C.
20036 Ellyn R. Weiss, Esquire Harmon, Weiss & Jordan Michael W. Maupin, Esquire 2001 S Street, N.W.,
- 430 Hunton & Williams Washington, D.C.
20009
.707 East Main Street P. O. Box 1535 William T. Russell Richacnd, VA.
23212 Deputy Director, Division of
.. Human Factors Safety Office of NRR Mail Stop AR 5200 U.S. Nuclear Regulatory Commissi@
Washington, D.C.
20555 i
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