ML20154D407

Provides Background Info on Evaporator Sys to Be Used to Dispose of Accident Water at Facility & on Addl TMI-2 Project Decisions for Which Expenditure of Funds Required Prior to NRC Approval for Implementing Task

ML20154D407
Person / Time
Site:	Three Mile Island
Issue date:	05/13/1988
From:	Standerfer F GENERAL PUBLIC UTILITIES CORP.
To:	Morris A LANCASTER, PA
References
4000-88-S-138, NUDOCS 8805190179
Download: ML20154D407 (8)

Text

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GPU Nuclear Corporation a Nuclear o

= e m a n'*o Middletown. Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:

(717)948-8400 May 13, 1988 4000-88-S-138 The Honorable Arthur E. Morris Mayor of Lancaster P. O. Box 1599 120 North Duke Street Lancaster, PA 17603

Dear Mr. Morris,

At the Panel meeting on April 14, 1988 I discussed the evaporator system we plan to use at THI-2 to dispose of the "accident water". (As you know, the NRC action on our recommendation to dispose of this water by evaporation is currently a subject being addressed in an ALSB hearing.) Further I discussed our decision in February of this year to proceed with the procurement of the evaporator. This procurement decision was questioned in the meeting and there was a request that the Panel vote to object to this action by GPU Nuclear.

In preparation for discussing this subject at the next Panel meeting the Chairman asked me to provide background on this and other THI-2 project decisions which have required the expenditure of funds before there was NRC approval to implement the particular task. The purpose of this letter is to provide that background.

It is the exception that we will have NRC approval prior to committing significant project expenditures for work and procurements of hardware. In some cases the subsequent approvals are routine, in some cases revisions are l required to completed plans and equipment, in some cases a task is implemented in some other way, and in some cases the approval is not obtained. I have l

1 attached several example cases which illustrate this process.

I also want to take this opportunity to summarize the GPU Nuclear actions that have been taken in the evaporator case in question. It is a case in which considerably more NRC agreement was obtained prior to committing funds for procurement than occurs in the typical project decision.

1. In January 1986 the NRC Commissioners requested GPU .

Nuclear make a disposal recommendation for the THI-2 accident water.

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• Advisory Panel Members May 13, 1988 4000-88-S-138 Page 2

2. In July 1986 we made that recommendation to the NRC.

Even though this water could be discharged to the Susquehanna River under current regulatory limits, we rejected that option and recommended evaporation.

3. In December 1986 the NRC issued for public comment an environmental impact analysis for this recommendation and reached the preliminary conclusion that evaporation was environmentally acceptable.

4. In January 1987 we issued a request for bids to provide the evaporation equipment and services to several qualified companies.

5. In January. February and March 1987 this Panel held pubile meetings on this evaporation proposal.

6. In July 1987 the NRC issued its final environmental

- analysis report which supported the acceptability of .

this proposal.

7. In July 1987 the NRC Staff concluded "...llcensee proposal to evaporate accident-generated water is an acceptable disposal plan." and stated " . the Staff will recommend Commission approval of the licensee's proposal."

8. In July 1987 the NRC Commission deferred a decision on the NRC Staff recommendation to approve the proposal and offered the opportunity for a hearing on this question.

9. In August 1987 GPU Nuclear selected a contractor and signed a contract for the evaporation services. The contract specified that work would not be started until GPU Nuclear authorized it.

10. Since then it has become clear that the hearing process will be protracted rather than expeditious and we have recognized that the overall completion of the Cleanup Program could be delayed if action was not taken to authorize work on the water disposal system equipment in parallel with the hearing process. Further, detailed questions concerning the evaporation system were being asked by the Joint Intervenors in the hearing discovery process which could not be answered without proceeding with the work under the contract for the evaporator.

.- Advisory Panel Members May 13, 1988 4000-88-S-138 Page 3

11. In February 1983 GPU Nuclear authorized the work to be started by the contractor for the evaporat'or. This authorization committed to the expenditure of $800,732.

and provided that if the evaporator is not used, the contractor would buy the equipment back from GPU Nuclear for $410,000.

To summarize, on the evaporator equipment:

The request for bids from qualified companies was issued after the NRC's Draft Environmental Impact Statement was issued.

The selection of contractor for the evaporator was made after the NRC's Final Environmental Impact Statement was issued and the NRC Staff recommended that the evaporator process be approved.

(Note: Work was not authorized to start under the

__ contract.) .

Work under the evaporator contract was authorized six months later after it was recognized that the ALSB hearing process was protracted, the cleanup schedule could be delayed without going ahead, and detailed evaporator equipment questions were being asked in the hearing process which could not be answered without tne final design.

New consideration which supported proceeding with work under the contract was the developing short supply of stainless steel in the country due to import restrictions causing delivery schedules under the contract to lengthen.

I hope this background assists you in your deliberations on this issue.

Very Truly Yours,

/

F. R. Standerfer Director, THI-2 amt Attachment cc: . Advisory Panel Members bH. T. Masnik '

I Susquehanna Valley Alliance Three Mlle Island Alert 4

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Advisory Panel Members Attachment 1 4000-88-S-138 Page 1 May 13,1988 TITLE: SUBMERGED DEMINERALIZER SYSTEM (SDS)

SCOPE: Early in the cleanup project we neaded a new ion exchange system which could process water that contained very high concentrations of cesium and strontium. GPU Nuclear authorized the design and installation of such a system at a time when there was some question as to how well it would work. We were a long way from obtaining NRC approval to operate the SDS.

SYSTEM COST: $11 Million STARTED WORK: May 1979 SYSTEM READY FOR USE: Pay 1981 NRC APPROVAL TO USE: June 1981 COMMENTS: To date, 4.5 million gallons of water have been processed through SDS.

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, Advisory Panel Members Attachment 1 4000-88-S-138 Page 2 May 13,1988 TITLE: CANISTERS FOR DAMAGED FUEL SCOPE: The design and development of the canisters to contain and ship the fuel debris from TMI-2 was started before the defueling system was designed and before the fuel shipping cask was designed. Further, the procurement of the canisters needed to be placed long before there was NRC approval.to use or ship the canisters.

CANISTER COST: (Includesdesign, development,testingand procurement) $20 Million STARTED WORK: May 1983 NRC APPROVAL TO USE: November 1985 FIRST CANISTER USE: November 1985 COMMENTS: Design and fabrication changes were recuired by 00E to increase conservatism with respect to nuclear criticality by modifying the type and configuration of neutron absorption material. Also, load drop tests were required by the NRC after the first canisters were delivered to demonstrate structural integrity.

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Advisory Panel Member; Attachment 1 4000-88-S-138 Page 3 May 13,1988 TITLE: PLASMA ARC TORCH SCOPE: In order to defuel the bottom of the reactor vessel we needed a method to cut the stainless I

steel structural plates in the lower core support structure. A number of methods were evaluated. One cutting method chosen for

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i development was the underwater plasma arc torch. There were several developmental questions that needed to be solved long before any NRC approval could be obtained.

SYSTEM COST: $3 Million STARTED WORK: March 1986  ;

! SYSTEM READY FOR USE: November 1987 l

NRC APPROVAL TO USE: April 1988 COMMENTS: The first use of this cutting torch in the reactor vessel was on May 11, 1988

Advisory Panel Members Attachment 1 4000-88-S-138 Page 4 May 13, 1988 TITLE: POLAR CRANE REQUALIFICATION SCOPE: The cleanup program required the use of the polar crane inside the containment building.

Early in the project this polar crane refurbish-ment and requalification was started at considerable cost and prior to an NRC approval to reuse the crane. The work involved extensive repairs to existing damaged parts, the procurement and installation of many new parts and the subsequent testing prior to NRC approval for reuse.

COST: $4 Million STARTED WORK: July 1981 CRANE READ ( FOR USE: February 1984 NRC APPROVAL TO USE: July 1984 COP.MENTS: GPU Nuclear had identified early after the initial Reactor Building entries in the Spring of 1981 that the polar crane would require extensive rework.

Because of the damage to the crane there existed a high degree of uncertainty and financial risk as to whether any refurbishment efforts could adequatelj requalify the polar crane for head lift and plenum removal. GPUN made a decision and company comitment to complete requalification of the crane including construction of a completely new electrical power system for both the crane and trolley system, redesign and fabrication of a new pendant station, replace-ment of all hoisting brakes, and refurbishment of all other major components of the crane structure and lifting devices. These decisions and financial comitments were made, based on engineering analyses and management judgements to move forward into plant cleanup.

A'dvisory Panel Members Attachment 1 4000-88-S-138 Page 5 May 13,1988 3

E TITLE: DEFUELING SYSTEM SCOPE: The design and development of defueling system equipment which is now being used was initiated long before NRC approval.

Midway through its development we made a major change in the conceptual approach.

That is from (1) the flooded canal / remote concept to (2) the dry canal /long handled tool approach.

SYSTEM COST: $40 Million STARTED WORK: December 1981 SYSTEM READY FOR USE: October 1985 NRC FIRST APPROVAL TO USE: October 1985 COMMENTS: Even at this late stage of defueling, it is likely that certain future deployments of defueling system components will require additional NRC review and approval as defueling progresses.

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