ML20136A682

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Forwards App H Exemption to Allow Facility Operation During Cycle 2 W/All Six Surveillance Capsules Removed.Refuses to Concur in Exemption Until Safety Evaluation of Thermal Surveillance & NRC Findings Are Resolved.W/O Encl
ML20136A682
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 04/22/1976
From: Mcgurren H
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
To: Treby S
NRC OFFICE OF THE EXECUTIVE LEGAL DIRECTOR (OELD)
Shared Package
ML20125B444 List: ... further results
References
FOIA-96-207 NUDOCS 7904250178
Download: ML20136A682 (2)


Text

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I April 22,1976

' STUART TREBY NOTE TO: ,

RE: TMI, UNIT NO.1 - APPENDIX H EXEMPTION

- The attached package grants Metropolitan Edison Company a $50.12 exemption ,

from 10 CFR Part 50, Appendix H (dealing with vessel wall fracture toughness surveillance) to allow operation of TMI, Unit No. I during Cycle 2 with all six of the require surveillance capsules removed. This exemption request was elicited by the recent discovery of damage to the surveiUance capsule holding tubes. The licensee has removed the surveillance cape t.'es and holding tubes

  • and anticipates replacement of the holding tubes and retas.allation of the six surveillance capsules prior to Cycle 3 operation.

In addition, this package amends the facility license technical specifications

[ dealing with vessel wall fracture toughness surveillance to conform with i

Appendix 11 (which was issued after the TMI, Unit No.1 Technical Specifi-I cations we're developed) .

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I have discussed this package at length with Bill Ross, LPM, and he has agreed

! to make the changes inidicated in pencil. I still have two concerns.

1. Concern Regarding the Safety Evaluation Discussion of Thermal Surveillance /

It is clear that the purpose of Appendix H is to require monitoring of changes in the fracture toughness properties of ferritic materials in the reactor vessel The wall caused by (a) neutron irradiation and (b) the thermal environment.

Staff's safety evaluation addresses item (a) only. The Staff's evaluation indi-l cates that the surveillance capsules have, in essence, experienced neutron -

irradiation more than the vessel wall will experience in the first three cycles of operation. The Staff's safety evaluation does not, however, address item (b), the thermal environment. I recommend that OELD not concur in this

! package until the Staff's safety evaluation addresses the follo.ving issue:

Whether during Cycle 2 operation the vessel wall might experience some.

) thermal change (due possibly to some transient) that could exceed the thermal j exposure experienced by the surveillance capsules.

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Concern Regarding the Staff's Finding Sup, porting the i 50.12 I 2.

Exemption

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O In addition, I believe that the Staff has not made the finding necessary to ,'

support the granting of a i 50.12 exemption. It is clear from the langu s s

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this section that the Staff must find that operation of TMI, Unit No. I with the l

reactor vessel surveillance capsules removed is in the public interest and' l

will not endanger life or property or the common defense and security. l Until these concerns are satisfied, I recommend that OELD not concur in this  !

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