ML20134K947

Discusses NRC Denial of Certain Relief Requests for TMI-1 Inservice Testing Program for Pumps & Valves.Meeting Has Been Scheduled for 850904-05 to Discuss Overall Program & Technical Basis for Appeal

ML20134K947
Person / Time
Site:	Three Mile Island
Issue date:	08/16/1985
From:	Harold Denton Office of Nuclear Reactor Regulation
To:	Hukill H GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 8508300525
Download: ML20134K947 (5)

Text

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August 16, 1985 ))k h O Docket No. 50-289 DISTRIR11TinN Qocket Fild JPartlow FCherny NRC PDR ACRS-10 JPage L PDR Ringram Mr. Henry D. Hukill, Vice President ORB #4 Rdg 0 Thompson and Director - TMI-1 HThompson JThoma GPU Nuclear Corporation OELD Gray File P. O. Box 480 EJordan EBrach Middletown, Pennsylvania 17057 BGrimes H0rnstein WRussell R80snak

Dear Mr. Hukill:

In your letter dated March 19, 1985, you appealed the staff's denial of certain relief requests for the TMI-1 inservice testing program (IST) for pumps and valves. You claimed that the staff's positions are, at least in part, backfits. We arranged an appeal meeting and then, as stated in our April 20, 1985 letter, mutually agreed to postpone the meeting because of staff's plans to discuss individual leak test requirements for pressure isolation valves (PIVs) with the Committee for Review of Generic Requirements (CRGR); some of your issues involve PIVs.

The CRGR discussion is still pending and, at this time, we consider the PIV issues to be potential backfit issues. You are not required to adopt the staff's position on the PIV issues until a generic backfit determination has been made. For the other issues identified in your March 19 letter, the staff has reviewed the issues in accordance with draft Manual Chapter 0154 and has determined that the remaining issues are not backfits. All the remaining issues are associated with 10 CFR 50.55a(g). Paragraph 053 of the Manual Chapter states that applicable regulatory staff positions which have already been imposed upon or committed to by a licensee are not backfits. It continues by specifically stating that 10 CFR 50.55a has automatic update features as described in the regulations. Licensees cannot claim backfit because these automatic update features require plant changes. Additional discussion for each issue is provided in the enclosure.

Although, we have declared some items not to be backfits and therefore applicable for enforcement, you may still appeal these issues based on their technical merit. To this end, a meeting has been scheduled between our ,

staffs for September 4 and 5, 1985 to discuss your overall IST program and -

your technical basis for any appeal on these issues.

Sincerely, engM ages ny B508300525 850816 N. it. Sentes gDR ADOCK 05 289 Harold R. Denton, Director Office of Nuclear Reactor Regulation

Enclosure:

As Stated cc w/ enclosure:

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Mr. Henry D. Hukill Three Mile Island Nuclear Station GPU Nu: lear Corporation Unit No. I cc:

Mr. R. J. Toole Mr. Richard Conte OtM Director, TMI-1 SeniorResidentInspector(TMI-1)

GPU Nuclear Corporation U.S.N.R.C.

Middletown, Pennsylvania 17057 P.O. Box 311 Middletown, Pennsylvania 17057 Richard J. McGeey Manager, PWR Licensing GPU Nuclear Corporation Regional Administrator, Region I 100 Interpace Parkway U.S. Nuclear Regulatory Comission Parsippany, New Jersey 70754 631 Park Avenue King of Prussia, Pennsylvania 19406 Mr. C. W. Smyth THI-l Licensing Manager Mr. Robert B. Borsum GPU Nuclear Corporation Babcock & Wilcox P. O. Box 480 huclear Power Generation Division Middletown, Pennsylvania 17057 Suite 220, 7910 Woodmont Avenue Bethesda, Maryland 20814 G. F. Trowbridge, Esq.

Shaw, Pittman, Potts & Trowbridge Governor's Office of State Planning 1800 M Street, N.V. and Development Washington, D.C. 20036 ATTN: Coordinator, Pennsylvania State Clearinghouse Ivan W. Smith, Esq., Chairman P. O. Box 1323 Atomic Safety ar.d Licensing Board Harrisburg, Pennsylvania 17120 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. Earl 8. Hoffman Dauphin County Commissioner Sheldon J. Wolfe, Esq., Chairman Dauphin County Courthouse Atomic Safety and Licensing Roard Front and Market Streets U.S. Nuclear Regulatory Commission Harrisburg, Pennsylvania 17101 Washirgton, D.C. 20555 Dauphin County Office of Emergency Mr. Gustave A. Linenberger, Jr. Preparedness Atomic Safety and Licensing Board Court House, Room 7 U.S. Nuclear Pegulatory Commission Front and Market Streets Washington, D.C. 20555 Harrisburg, Pennsylvania 17101 Dr. James Lamb, III Mr. David D. Maxwell, Chairman Administrative Judge Board of Supervisors 313 Woodhaven Road Londonderry Township Chapel Hill, North Carolina 17514 FRD#1 - Geyers Church Road Middletown, Pennsylvania 17057 Mr. David Hetrick Administrative Judge Mr. Thomas M. Gerusky, Director Professor of Nuclear Energy Bureau of Radiation Protection University of Arizona Pennsylvania Department of Tucson, Arizona 85721 Environmental Resources P. O. Box 2063 Harrisburg, Pennsylvania 17120

GPU Nuclear Corporation Three Mile Island, Unit I cc:

Thomas Y. Au, Esq. Sen. Allen R. Carter, Chairman Office of Chief Counsel Joint Legislative Committee on Energy Department of Environmental Resources P. O. Box 142 505 Executive House Suite 513 P. O. Box 2357 Senate Gressette Building Harrisburg, Pennsylvania 17120 Columbia, South Carolina 29202 Mr. Bob Stein, Director of Research Ms. Frieda Berryhill, Chairman Comittee on Energy Coalition for Nuclear Power Plant P. O. Box 11867 Postponement 104 Blatt Building 2610 Grendon Drive Columbia, South Carolina 29211 Wilmington, Delaware 19808 Ms. Jane Lee William S. Jordan, III, Esq.

183 Valley Road Harmon, Weiss & Jordan Etters, Pennsylvania 17319 20001 S Street, N.W.

Suite 430 lis. Marjorie M. Aamodt Washingter., D.C. 20009 Mr. Norman Aamodt 200 North Church Street Lynne Bernabei Esq.

Parkesburg, Pennsylvania 19365 Government Accountability Project 1555 Connecticut Ave. , N.W.

Ms. Louise Bradford Washington, D.C. 20009 TMIA 1011 Green Street Michael W. Maupin, Esq.

Harrisburg, Pennsylvania 17102 Hunton & Williams 707 East Main Street Mr. Marvin I. Lewis P. O. Box 1535 6504 Bradford Terrace Richmond Virginia 23212 Philadelphia, Pennsylvania 19149 Jordan D. Cunningham, Esq.

Mr. Chauncey Kepford Fox, Farr and Cunningham Ms. Judith H. Johnsrud 2320 North 2nd Street Environmental Coalition on Nuclear Power Harrisburg, Pennsylvania 17110 433 Orlando Avenue State College, Pennsylvania 16801 Ms. Ellyn R. Weiss Harmon, Weiss & Jordan Mr. Bruce Molholt 2001 S Street, N.W.

Haverford College Suite 430 Haverford, Pennsylvania 19041 Washington, D.C. 20009 Mr. Donald E. Hossier Michael McBride, Esa.

501 Vine Street LeBoeuf, Lamb, Leiby & McRae Middletown, Pennsylvania 17057 Suite 1100 1333 New Hampshire Avenue, N.W.

Mr. Ad Crable Washington, D.C. 20036 Lancaster New Era 8 West King Street Lancaster, Pennsylvania 17602

GPU Nuclear Corporation Three Mile Island, Unit I cc:

Atomic Safety & Licensing Board Panel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Atomic Safety & Licensing Appeal Board Panel (8)

U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Docketing and Service Section Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555

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. Backfit Determinations Three Mile Island Unit 1 (TMI-1)

Licensee Letter Dated March 19, 1985 Inservice Testing Program Requirements The following item designations for open issues correspond to items in the licensee's letter and the staff's supplemental safety evaluation dated October 23, 1984.

! Item A.2(b). CA-PIA /B (Boric Acid Pix Pumps)

The licensee's letter provides additional information that is under staff review. Therefore, this is not a backfit issue at this time.

4 Items B.I. pressure Isolation Valves

! The staff's position is that individual leak rate testing of pressure isolation valves is required in the IST program. The licensee claims this is beyond IST requirements as they presently exist and would require costly plant modifications before the testing could be done.

fio staff action will be taken on the following valves in question pending a generic backfit determination. Therefore the licensee is not recuired to [

i follow the staff's recommendations until the backfit determination has been made. ,

(a) CF-V4A/R (Core Flood Discharge Check Valves) i (b) RC-V4, pC-V23 (MOV and Check Velve in Decay Heat Aux. Spray Line)

(c) MU-V107A/8/C/0, MU-V86A/B,!N-V95 (Makeup System Check Valves) i (d) DH-V1, DH-V2 (Decay Heat Pump Suction Valves from Loop B to Hot Leg)

I Item R.2(d). MS-V9A/B (Main Steam Supply Check Valves to Steam Driven Erergency Feedwater Pumps) l The licensee disagrees with the staff's technical position on this issue and

! recuests relief from ASME Section XI testing required by 10 CFR 50.55a(g).

The Code requires that these valves be periodically full-stroke tested. It j is the staff's position that, in lieu of full-stroke testing, the valves should be periodically disassembled and inspected. The licensee has proposed partial stroke testing without disassembly. The licensee may chose to appeal this issue to flRC management.

Item B.3(a). EF-V3 (Emergency River Water Source Check Valve)

The licensee is evaluating the feasibility of removing the valve internals.

j The staff is awaiting the licensee's follow-up and therefore this is not a

backfit issue at this time.

4 J

These backfit determinations were made by J. Page, Mechanical Engineering ,

j Granch, Division of Engineering, i Dated July 8, 1985

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