ML20137H777
| ML20137H777 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/31/1997 |
| From: | Keaton R GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20007F901 | List: |
| References | |
| 6700-97-2106, NUDOCS 9704030049 | |
| Download: ML20137H777 (12) | |
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G PU Nuclear, Inc.
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One Upper Pond Road Persippany, NJ 07054-1095 NUCLEAR Tel 201316-7000 i
ATTACHMENT 1 OF THIS LETTER CONTAINS PROPRIETARY INFORMATION IN ACCORDANCE WITH 10 CFR 2.790 March 31, 1997 6700-97-2106 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Gentlemen:
Subject:
Three Mile Island Unit No. I Nuclear Generating Station (TMI-1)
Docket No. 50).W 2.8'l Facility Operating License No. DPR-16 Request for License Amendment to Support a Design Change to Permanently Remove the Reactor Vessel Missile Shields at TM1-1
Reference:
(1) GPU Nuclear Letters, C311-95-2479," Changes to incorporate improvements from the Revised B&W Standard Technical Specifications (STS), NUREG 1430", dated August 29,1996 and 6710-96-2317, " Errata to Technical Specification Change Request No. 257", dated October 3, 1996.
GPU Nuclear has prepared an evaluation, as required under 10 CFR 50.59, to support the permanent removal of the Reactor Vessel (RV) Missile Shields from the TMI-1 design basis using the Attachment I report for analytical support. GPU Nuclear's 10 CFR 50.59 evaluation has determined that this design basis change (permanent removal of the RV Missile Shields) involves an unreviewed safety question and therefore, in accordance with 10 CFR 50.59(c), requires submittal of an application for a license amendment. Specifically, removal of the Control Rod Drive Mechanism (CRDM) from the design basis list of credible missiles, previously reviewed by the NRC Staff, is needed (Attachment 3). The NRC's review and approval of this amendment to APoii canon 1 NN LEI 5EPPPPPRE qyot(o3F M P 9 O 9 a
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6710-97-2106 Page 2 the licensing basis is necessary prior to GPU Nuclear's implementation of the design basis change.
it is GPU Nuclear's desire to permanently remove the RV Missile Shields prior to restart from the upcoming refueling outage currently scheduled to begin in September,1997.
GPU Nuclear has been a part of the B&W Owner's Group effort which has prepared FTI Document 51-1240140-00, " Reactor Vessel Missile Shield Removal Report," dated December, 1995. This report provides analyticaljustification in support of the permanent removal of the RV Missile Shields for B&W designed 177FA operating units including TMI-1. Attachment I to this letter provides a copy of this document. Please note that in accordance with 10 CFR 2.790, FTI Document 51-1240140-00, " Reactor Vessel Missile Shield Removal Report" is considered
" Proprietary." It is therefore, requested that this information be withheld from public disclosure.
An aflidavit supporting this classification signed by J. II. Taylor, Manager, Licensing Services, Framatome Technologies, Inc. is included in Attachment 1.
The technical approach used in the Attachment I report includes both Failure Modes and Effects Analysis (FMEA) and Structural Analysis and demonstrates that the CRDM is not a credible missile. These methods have not been previously reviewed by the staff for the identification of potential sources ofinternal missiles or for demonstrating the adequacy of missile protection at TMI-l. GPU Nuclear has reviewed this repon and determined that the assumptions used are applicable and conservative with respect to TMI-1. The report places some importance on chemistry control in the Reactor Coolant System (RCS) and refers to Technical Specification requirements for LCO's and surveillance requirements. By Reference 1, GPU Nuclear submitted a Technical Specification Change Request (TSCR No. 257) for TMI-l which requested deletion
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of Technical Specification (TS) 3.1.5 on RCS chemistry consistent with NUREG 1430, Revised Standard Technical Specifications. The monitoring of the concentration of oxygen, chloride and fluoride in the RCS, covered by TS 3.1.5, and the required plant responses to elevated concentrations are addressed and will be maintained in controlled plant procedures rather than TS 3.1.5.
Also included for use in the NRC Stafl's review, and in support of GPU Nuclear's request, is BAW-10190P, Addendum 1," External Circumferential Crack Growth Analysis For B&W Design Reactor Vessel Head Control Rod Drive Mechanism Nozzles," dated December,1993. to this letter provides a copy of this document. Framatome Technologies has informed GPU Nuclear by letter ESC-96-574, dated October 24,1996, that transmittal of this topical report to the NRC should be considered "Non-Proprietary." A copy of this letter supporting this "Non-Proprietary" status is included in Attachment 2.
6710-97-2106 Page 3 GPU Nuclear has determined that this license amendment, pursuant to 10 CFR 50.92(c), involves no significant hazards consideration since:
(1) The proposed amendment and subsequent removal of the RV Missile Shields would not involve a significant increase in the probability or consequences of an accident previously evaluated.
The CRDM has been determined not to be s credible missile based upon the FMEA and Structural Analysis methods used in the Attachment I report and therefore can be removed from the design basis list of credible missiles. Removal of a not credible missile (CRDM) from missile hazard consideration does not alter plant configuration, effect plant operation or change safety system function, reliability, or performance. Hence, there would be no significant increase in the probability or consequences of an accident previously evaluated.
The subsequent removal of the RV Missile Shields and resulting change to plant configuration would not involve a significant increase in the probability or consequences of an accident previously evaluated because the missile shields are not relied upon or designed to provide any design basis function other than to protect the RB liner from loss of function due to perforation from credible, internally generated, missiles originating from the RV head area. In addition, the RV Missile Shields are not considered as a potential mitigation device in any other accident scenario.
Since no credible missile would have the capacity to challenge containment integrity or prevent the RB liner from performing its containment safety function with the RV Missile Shields removed and since the function, reliability, or performance of other safety related systems are not being altered, the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.
(2) The proposed amendment and subsequent removal of the RV Missile Shields would not create the possibility of a new or different kind of accident from any accident previously evaluated.
The CRDM has been determined not to be a credible missile based upon the FMEA and Structural Analysis methods used in the Attachment I report and therefore can be removed from the design basis list of credible missiles. Removal of a not credible missile (CRDM) from missile hazard consideration does not alter plant configuration, effect plant operation or change safety system function, reliability, or performance. Hence, this would not create the possibility of a new or different kind of accident from any accident previously evaluated.
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6710-97-2106.
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The subsequent removal of the RV Missile Shields nd resulting change to plant
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configuration would not create the possibility of a new or different kind of accident from any accident previously evaluated because the missile shields are not relied upon or designed to provide any design basis function other than to protect the RB liner from loss I
of function due to perforation from credible, internally generated, missiles originating from the RV head area. In addition, the RV Missile Shields are not considered as a potential mitigation device in any other accident scenario.
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Since no credible missile would have the capacity to challenge containment integrity or prevent the RB liner from performing its containment safety function with the RV Missile Shields removed and since the function, reliability, or performance of other safety related systems are not being altered, the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated.
(3) The proposed amendment and subsequent removal of the RV Missile Shields would not involve a significant reduction in a margin of safety because there are no applicable Technical Specifications or Technical Specification Basis that address missile hazards or the placement of missile shields.
Since no credible missile would have the capacity to challenge containment integrity or i
prevent the RB liner from performing its containment safety function with the RV Missile Shields removed and since the function, reliability, or performance of other safety related systems are not being altered by the proposed amendment, there will be no significant reduction in any margin of safety.
'If you have any questions or comments on this matter, please contact Ron Zak, Corporate Regulatory Affairs at (201) 316 7035.
j Sincerely, 4S R. W. Keaten Vice President and Director Engmeenng 1
Attachments -
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6710-97-2106--
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Administrator, Region 1 (Non-Proprietary) -
- Senior Resident Inspector (Non-Proprietary)
TMI NRC Project Manager (Proprietary and Non-Proprietary Versions) l 1
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AFFIDAVIT OF JAMF3 H. TAYLOR A.
My name is James H. Taylor.
I am Manager of Licensing Services for Framatome Technologies, Inc., a participating member in the B&W Utility Owners Group (B&WOG), and as such, I am authorized to execute this Affidavit.
B.
I am familiar with the criteria applied by the Nuclear Regulatory Commission (NRC) to determine whether certain information of the B&WOG is proprietary.
C.
In determining whether a B&WOG document is to be designated as proprietary information, an initial determination is made by the Unit Manager who is responsible for originating the document as to whether it falls within the criteria set forth in Paragraph D hereof. If the information falls within any one of these criteria, it is designated as proprietary by the originating Unit Manager. This initial determination is reviewed by the cognizant manager at the next higher organizational level. If the document is designated as proprietary, it is reviewed again by me to assure that the regulatory requirements of 10 CFR Section 2.790 are met.
J D.
The following information is provided to demonstrate that the provisions of 10 CFR Section 2.790 of the Commission's regulations have been considered:
l (i)
The information has been held in confidence by the B&WOG. Copies of the document are clearly identified as proprietary.
(ii)
The following criteria are customarily applied by the B&WOG in a rational decision process to determine whether the information should be designated as proprietary.
Information may be designated as proprietary if one or more of the following criteria 4
are met.
I a.
Information reveals cost or price information, commercial strategies, i
production capabilities, or budget levels of the B&WOG or its suppliers.
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l b.-
' The information reveals data or material concerning the B&WOG research'or ;
development plans or programs of present or potential economic advantage to the B&WOG.
i c.
. The use of the information by a non-member would decrease his expenditures, l
- in time or resources, in designing, producing, or marketing a similar product.
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d..
The information consists of test data or other similar data concerning a process, method or _ component, the application of which results in an economic advantage to the B&WOG.
e.
The information reveals special aspects of a process, method, component or the like, the exclusive use of which results in an economic advantage to the
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B&WOG.
f.
The information contains ideas for which patent protection may be sought.
The document (s) listed on Exhibit "A", which is ac-ched hereto and made a part hereof, has been evaluated in accordance with the B&WOG procedures with respect to classification and has been found to contain information which falls within one or more of the criteria enumerated above. Exhibit "B", which is attached hereto and made a part hereof, specifically identifies the criteria applicable to the document (s) listed in Exhibit "A".
(iii)
The document (s) listed in Exhibit "A", which has been made available to the United States Nuclear Regulatory Commission was made available in confidence with a request that the document (s) and the information contained therein be withheld from public disclosure.
(iv)
The information is not available in the open literature and to the best of our knowledge is not known by other organizations with interests and activities similar to those of the B&WOG.
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i (v)
. Specific information with regard to whether public disclosure of the information is likely to cause economic harm to the position of the B&WOG, taking into account the value of the.information to the B&WOG; the amount of effort or money l
expended by the B&WOG developing the informa6on; and the case or difficulty with j
which the information could be properly duplicated by others is given in Exhibit "B".
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E.
I have personally reviewed the document (s) listed on Exhibit "A" and have found that it is considered proprietary by the B&WOG because it contains information which falls within one l
or more of the criteria enumerated in Paragraph D, and it is information which is customarily j
held in confidence and protected as proprietary information by the B&WOG. This report comprises information utilized by the B&WOG in its business which afford the B&WOG an opportunity to obtain an economic ad'/antage over those who may wish to know or use the information contained in the document (s).
/Wh
[ fames H. Taylor gf/
State of Virginia)
) SS. Lynchburg City of Lynchburg)
James H. Taylor, being duly sworn, on his oath deposes and says that he is the person who subscribed his name to the foregoing statement, and that the matters and facts set forth in the statement are true.
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fa'mes H. Taylo'r Subscri worn before me this#p and s$ctile r day of 1996.
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- Notary Public in and for the City of Lynchburg, State of Virginia My Commission Expiresbly 8/.Iff f
.f.7,.p EXHIBITS A & B
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EXHIBIT A r
1.
FTI Document 51-1240140-00, " Reactor Vessel Missile Shield Removal Report,"
i dated December 1995.
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l EXHIBIT B The above listed document contains information which is considered Proprietary in accordance with Criteria e of the attached affidavit.
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ATTACHMENT 1 l
" Reactor Vessel Missile Shield Removal Report",
FTl Document 51-1240140-00, dated December,1995.
This attachment contains Proprietary information as defined in 10 CFR 2.790(a)(4).
An affidavit as required by 10 CFR 2.790(b)(1) to support this determination follows.
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i ATTACHMENT 2 4
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" External Circumferential Crack Growth Analysis'For B&W Design Reactor Vessel Head Control Rod Drive Mechanism Nozzles",
i BAW-10190P, Addendum 1, dated December,1993.
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1 Frematome Technologies has informed GPU Nuclear by letter ESC-96-574, dated October 24,1996, that transmittal of this topical report to the NRC should be considered "Non-Proprietary".
A copy of the letter confirming that determination follows.
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sus F R AM ATOM E TECHHOLOG1ES October 24,1996 Integrated Nuclear Servlees ESC-96-574
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3 Mr. Harry Heilmeier Framatome Technologies, Inc.
Three Mile Island P.O. Box 480 Route 441 South Middletown PA 17057
Subject:
Release of Document " External Circumferential Crack Growth Analysis for B&W Design Reactor Vessel Head Control Rod Drive Mechanism Nozzles,"
BAW-10190, Addendum 1, December 1993.
Dear Harry:
The subject document was reviewed by the Steering Committee on October 17,1996 and it was agreed that the "B&W Owners Group Proprietary" classification could be eliminated on this document. Therefore, GPUN is free to release this document to the NRC or a third party without restriction.
When GPUN transmits this topical report to the NRC, please include the following paragraph:
When the subject topical report was originally prepared, it was considered to be
" Proprietary." The B&W Owners Group no longer believes the " Proprietary" classification isjustified. Therefore, the attached transmittal should be considered "Non-Proprietary." We do not consider it necessary to revise or reprint the subject topical but have over-stamped a "Non-Proprietary" designation on the cover of the report. Should there be any questions concerning the change in classification, please feel free to call James H. Taylor, Manager of Licensing Services, Framatome Technologies, Inc. (804-832-2817).
Ifyou have any questions, please call me at 804-832-2917.
Very truly yours, f
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Robert J. Schomaker Project Manager j
RJS/bcc B&W Owners Group Management i
3315 Old Forest Road, P.O. Box 10935, Lynchburg, VA 24506-0935 Telephone: 804-822-3000 Fax: 804-832-3663 j
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