ML20247A806
| ML20247A806 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/17/1989 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C311-89-2001, NUDOCS 8907210318 | |
| Download: ML20247A806 (10) | |
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' Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX M 2386 3/'C Writer's' Direct Dial Number:
July 17,1989 C311-89-2001
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US Nuclear Regulatory Commission Attn: Document Control Desk
. Washington,.DC -20555
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Status of TMI-1 Conditions of Operation
'By letter dated June 16, 1988 concerning the TMI-2 Leak Rate Hearing Decision, the NRC requested that GPUN review the TMI-1 Corlitions of Operation contained
.in Mr. H. Denton's letter of October 2, 1985 and report their current status.
'The Conditions of Operation resulted from an assessment of the TM1-1 Restart
. Hearing' record for co mitments, requirements or agreements with which GPUN must comply. 'Since all important commitments, requirements, and agreements have been extracted, the hearing record-is considered to reflect important history; but not to contain other commitments or conditions with which GPUN must comply, or.' continue to track or maintain. GPUN has completed its review and Enclosure
'l'contains the status of each condition in the October 2, 1985 letter.
01 ease advise if'the status of any of the conditions as presented is contrary to your. understanding.
Sincerely,
. D. H ill Vice President & Director, TMI-1 HDH/SM0/spb:2001 Enclosures -
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GPU Nuclear Corpo.ation is a subsidiary of the General Public Utilities Corporation
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ENCLOSURE 1 STATUS OF TMI-1 CONDITIONS OF QPERATION Condition 1(a)
During any Unit 2 fuel movements in the fuel htndling building, GPU Nuclear Corporation'shall suspend work in the' Unit 1 area of that building, unless GPU Nuclear Corporation has submitted to the NRC for its review specific written proce&es for the' planned movemerds of Unit 2 fuel and an evaluation of the potential impacts of those fuel movements on personnel working in the Unit 1 area of the building and the NRC has agreed that the potential impacts of the planned Unit 2 fuel movements on personnel working in the Unit 3 area of the building do not require that work in the Unit 1 area of the building be suspended - LBP-82-27, 15 NRC 747, 755 (1982).
Status TMs condition has been satisfied. The GPUNC Safety Evaluation on the TMI-2 Canister Handling and Preparation for Shipment (CHAPS) which was appr ved by the NRC on June 20, 1986, stetes that the activities involved would have no adverse impact on the operat',cn of TMI-1. Also, on July 7, 1986 in a letter from the' NRC to H. D. Hukill, the NRC specifically stated that in consideration of this condition, the SER concluded that the CHAPS program would have no adverse impact on the operation of TMI-1. No changes have been made in the methods used for TMI-2 fuel movements since the issuance of the CHAPS SER, and none are envisioned.
Condition 1(b)
Unit I solid waste handling capabilities shall not be relied upon for decontamination or restoration of Unit 2.
LBP-81-59, 14 NRC 1211, 1454 (1981);
LBP-82-27, 15 NRC at 757.
Status This condition has been satisfied. Unit i solid waste handling capabilities have not been relied upon for Unit 2 activities.
Condition 1(c)
After the restart of Unit 1 and prior to the movement within the Unit i fuel handling' building of any irradiated Unit i fuel, GPU Nuclear Corporation shall install, and have operable, an engineered safety features (ESF) filtration system for the Unit i fuel handling building. The ESF filtration system for i
Unit 1 shall be operable whenever irradiated Unit i fuel is moved within the Unit i fuel handling building.
LBP-82-27, 15 NRC at 756. __
Status l
This condition has been completed. The TMI-1 ESF ventilation system was L
installed and operational prior to Cycle 6 operation. NRC approved the system design and operation in TMI-1 Tech. Spec. Amendment 122, dated December 12, l
1986. Amendment 122 approved TS 3.15.4 which requires that prior to fuel 1
movement, two ESF ventilation trains shall be operable, and one train shall be 1
operating continuously whenever TMI-1 irradiated fuel handling operations in the Unit 1 fuel handling building are in progress.
Condition 1(d)'
Isolation of liquid transfer line interconnections between Units 1 and 2 shall be maintained.
LBP-81-59, 14 NRC at 1432-33; LBP-82-27, 15 NRC 747.
Status This condition has been satisfied. The isolation of liquid transfer lines was imposed as a condition to prevent "... the ready movement of contaminated water from one unit to the other...".
Isolation has been achieved and demonstrated since 1980.
Isolation has been assured through TMI Unit 1 Surveillance Procedure 1303-11.48 " Unit 1/ Unit 2 Isolation Verification."
Condition 1(e)-1(j)
(e) At all times when the plant temperature is above 200*F (cold shutdown), GPU Nuclear Corporation will man all shifts at TMI-1 with a minimum of one NRC-licensed SRO, who will act as Shift Supervisor; a second individual, either NRC-licensed as an SRO or NRC-licensed as an R0 and trained as an SRO, who will act as Shift Foreman; and a minimum of two NRC-licensed R0s who will act as Control Room Operators.* LBP-81-32, 14 NRC 381, 580 (1981).
(f) GPU Nuclear Corporation shall employ all reasonable efforts to ensure personnel will be scheduled on a six-shift rotation, so long as there is a sufficient number of qualified individuals who normally stand shift watches to man six shifts, each of which meets condition (1)(e), above (6 SR0s and 18 R0s, recognizing that SR0s may act as either SR0s or R0s)* LBP-81-32, 14 NRC at 580.
(g) In the event there is an insufficient number of qualified personnel who i
normally stand shift watches available to meet condition (1)(f), above, GPU Nuclear Corporation shall schedule its normally on-shift plant operating personnel on a five-shift schedule, each of which meets condition (1)(e),
above, unless additional relief is granted pursuant to condition (1)(j),
below.* LBP-81-32, 14 NRC at 580.
(h) In the event there is an insufficient number of qualified operators who normally stand shift watches available to meet condition (1)(g), above, GPU Nuclear Corporation may employ on shift qualified and licensed individuals from its organizations who do not normally stand shift watches, in addition to those operators who do normally stand shift watches, to meet condition (1)(g), above.* LBP-81-32, 14 NRC at 580. _ - _ - _.
(1)Intheevent.thereisaninsufficientnumberofqualifiedoperatorsinGPU Nuclear Corporation's organization to meet condition (1)(h), above, for any
' period longer than ten consecutive days, GPU Nuclear Corporation 'shall inform the Commonwealth of Pennsylvania and the NRC staff and seek from the NRC staff their concurrence to man TMI-1 shifts and operate TMI-1 for a limited period of time with available qualified and licensed personnel, specifically bearing in mind the then current and applicable NRC criteria or guidance on overtime policies.* LBP-81-32, 14 NRC at 580-81.
(j) At all times when TMI-1 is operating at power levels above 20% rated power and there.is only one licensed SR0 on shift, the SRO-licensed individual on shift shall remain within the control room (including the shift supervisor's office) or within the plant at a location from which the control room is accessible in less than five minutes. Further, at all times when TMI-1 is operating at power levels above 20% rated power and the SRO-licensed individual on shift is not in the control room (including the shift supervisor's office), GPU Nuclear Corporation shall ensure that the control room (including the shift supervisor's office) is manned by a minimum of two R0s, acting as Control Room Operators, a third individual with an R0 license and SRO-trained, and by the on-shift Shift Technical Advisor (STA).* LBP-81-32, 14 NRC at 581.
Conditions (1)(e) through (j) are minimum conditioni imposed by the Licensing Board based on the evidentiary record. The requirements of NRC regulations on shift manning, which in some respects are more restrictive than these conditions, are also applicable.
Status These conditions have been satisfied. The origin of the conditions was an agreement between the Counsel for the Commonwealth of Pennsylvania and GPUN as documented on July 7,1981 in a letter from Shaw, Pittman, Potts and Trowbridge, Counsel for Licensee, to the Assistant Attorney General, Commonwealth of Pennsylvania. The agreement stated that staffing commitments 1(e)-1(j) were to be in effect until the NRC imposed the requirement to man operating shifts with two SR0s.
10CFR50.54(m)(2)(1) required that by January 1, 1984, the minimum staffing for a unit such as TMI-1 would be two SR0s and two R0s while the unit was operating (above cold shutdown conditions).
f Condition 1(k)
GPU Nuclear Corporation 5%)1 employ all reasonable efforts to maintain at all times sufficient numbers of indviduals in training to become licensed i
operators in order to account for possible future attrition of licensed operators. To this end, GPU Nuclear Corporation shall employ all reasonable efforts to maintain in training at all times that number of trainees which, i
when combined with the actual number of NRC-licensed SR0s and R0s in GPU l
Nuclear Corporation's organization, will total at least 30. GPU Nuclear Corporation shall report to the Commonwealth of Pennsylvania and the NRC staff
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at least annually whenever this condition is not met, and shall describe to the NRC staff the corrective actions being employed by GPU Nuclear Corporation to achieve compliance.
LBP-81-32, 14 NRC at 581.
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Status This condition has been and continues to be met. Operation Surveillance OPS-S286 assures that this condition is met.
Condition 1(1)
At the time of restart, GPU Nuclear Corporation shall provide and shall thereafter maintain a management system to perform the following functions:
(i)
Review operating experience information originating both within and outside the facility; (ii) Promptly supply information pertinent to plant safety, including proposed procedural changes and plant modifications, to operators and other appropriate plant personnel; and (iii) Assure that such information is incorporated into training and requalification programs.
Status This condition has been satisfied.
FSAR Section 12.1.2.1 a defines the management organization responsible for item (i). The TMI-1 Licensed Operator Requalification Training Program, which was certified in accordance with the requirements of 10CFR55.59(c) on May 19, 1988 addresses item (ii). The training program is cyclic, with each shift in training for a week every six weeks. Therefore, information can be disseminated promptly.
Item (iii) is also addressed in the training program.
Condition 1(m)
Any participation of Gary P. Miller in the start-up, testing or operation of TMI-1 shall be under the direct supervision of an appropriately qualified official of GPU Nuclear Corporation. LBP-82-56, 16 NRC 281, 384 (1982).
Status This condition has been satisfied and will continue to be met.
Condition 1(n)
GPU Nuclear Corporation shall preserve all records pertaining to the investigation recommended at Partial Initial Decision 2312-14 pertaining to the false c ratification of an employee.
LBP-82-56, 16 NRC at 384.,
Status This condition has been completed. The investigation recommended in the PID for which records were to be preserved was conducted by the NRC Office of
. Investigations and ultimately led to the indictment and conviction of a former employee. On appeal, the conviction was affirmed on January 2, 1986. j
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Condition 1(o)
L Until-the backup display system for the incore thermocouple is made fully safety-grade (including environmental qualification), the TMI-liemergency -
, procedures shall direct that operators rely on the redundant indication closest to saturation in determining if the criteria to permit throttling of High
. Pressure Injection (HPI) have been met. ALAB-729, 17 NRC 814, 894-(1983).
Status This~ condition has'been completed. The necessary modifications were completed as stated in GPUN letters dated May 21, 1985 and June 28, 1985. NRC TMI-1 Inspection 85-19 documented the NRC acknowledgement that this condition had been met.
Condition 1(p)
Until the emergency feedwater (EFW) system is made fully safety-grade, an auxiliary operator shall be dispatched to the EFW flow control valve area, upon any EFW auto-start condition, in order to take normal control of the valves, if needed; that person shall not be required to perform any other. duties until the control room operators verify that EFW flow is being delivered to the steam generators and the EFW system is controlled by the Integrated Control System (ICS) or through the manual station in the control room. ALAB-729, 17 NRC at 894.
Status This condition has been completed. The NRC approved the design and operation of the Emergency Feedwater System in TMI-1 License Amendment 124, dated April 9, 1987; SER "TMI-1 EFW System," dated February 18, 1987; and SER "TMI-1 Main Steam Line Rupture Detection System," dated April 18, 1988.
Condition'1(q)
Before the pressurizer heaters are connected to the emergency power supply at TMI-1, the reactor shall be suberitical or in a hot standby condition.
ALAB-729, 17 NRC at 894.
Status This condition has been satisfied and continues to be met. This condition is addressed in procedures 1202-29 " Pressurizer System Failure" and 1202-2
" Station Blackout" as verified in IR 85-19.
Changes to these procedures are governed by the requirements of 10CFR50.59 and the associated NRC reporting requirements.
Condition 1(r)
GPU Nuclear Corporation shall modify its emergency plan to address changing capabilities of. plant instrumentation. CLI-79-8, 10 NRC 141, 145 (1979);
LBP-81-59, 14 NRC at 1702. l
status
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This condition has been completed.
10 CFR 50 Appendix E, Section G requires that provisions be employed to ensure the Emergency Pirn and Emergency Planning Implementing Procedures are maintained up to date. Thus, changes to plant instrumentation are required to be reflected in the Emergency Plan and procedures. The Corporate Emergency Plan, Section 8.2 describes the process of changing the plan and procedures.
Condition 1(s)
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No pre-accident TMI-2 operator, shift supervisor, shift foreman, or any other individual both in the operating crew and on shift for training as a licensed operator at TMI-2 prior to the accident shall be employed at TMI-1 in a responsible management or operational position without specific NRC approval.
" Operational position" as used here includes any position involving actual operation of the plant, the direction or supervision of operators, or independent oversight of operations.
This condition shall also apply to the pre-accident Vice-President, Generation; TMI-2 Station Manager; TMI-2 Supervisor of Technical Support (from January 1977 to November 1978); TMI-2 Superintendent of Technical Support (from December 1978 to the accident); and YNI-2 Supervisor of Operations.
CLI-85-02, 21 NRC 282, 341-342 (1985).
Status This condition was modified in NRC Commission Order CLI-88-02 dated April 28, 1988 as follows:
The pre-accident TMI-2 Supervisor of Operations, James R. Floyd, shall not be employed at TMI-1 in a responsible management or operational position without specific NRC approval.
" Operational Position" as used here includes any position involving actual operation of the plant, the direction or supervision of operations, or independent oversight of operations.
This condition as modified has been and continues to be met.
Condition 1(t)
GPU Nuclear Corporation, in the absence of NRC authorization to the contrary, is to retain its expanded Board of Directors and its Nuclear Safety and Compliance Committee. CLI-85-02, 21 NRC at 342.
Status This condition has been and continues to be met.
1 Condition 1(u)
GPU Nuclear Corporation is to notify the NRC before returning either Mr. Robert Arnold or Mr. Edward Wallace to responsible positions at TMI-1.
CLI-85-02, 21 NRC at 323.
Status In CLI-86-09 " Advisory Opinion and Notice of Hearing," dated May 15, 1986, the restriction on Mr. Arnold was continued based on no objection to this by Mr. Arnold and a hearing was established for Mr. Wallace. Subsequently, the
' Administrative Law Judge terminated that proceeding and removed tne restriction on Mr. Wallace. The Appeal Board Decision (ALAB-850) which affirmed the Administrative Law Judge's Order became final NRC action on November 26, 1986 when the Commist.ioners declined to review it. On October 13, 1987, the U.S.
Court of Appeals for the Third Circuit dismissed the Commonwealth of Pennsylvania's Petition for Review of the NRC action.
The only remaining restriction applies to Mr. Arnold which GPUN will continue to meet.
Condition 2(a)-(f) j Power Escalation Test Requirements for Initial Restart After Lifting Immediately Effective Shutdown Order of July 2, 1979 (a)
Prior to operation above 5% power, GPU Nuclear Corporat'on shall complete the Special Low Power Test Program in accordance with GPU Nuclear Corporation's Restart Test Specification (letter of April f.
1983 or NRC-approved later submittal) and Item I.G.1 of NUREG-06W.
LBP-82-27, 15 NRC at 757.
(b)
Prior to operation above 48% power, GPU Nuclear Corporation shall demonstrate automatic initiation of EFW pumps upon loss of both feedwater pumps. CLI-85-09, 21 NRC 1118, 1157 (1985).
(c)
Prior to operation above 5% power, GPU Nuclear Corporation shall demonstrate that EFW system initiation and operation is assured independent of any AC source for at least two hours. CLI-85-09, 21 NRC at 1157.
(d)
Prior to completion of the Power Escalation Test Program, GPU Nuclear Corporation shall demonstrate safety-grade automatic anticipatory reactor scram on loss of feedwater and upon turbine trip.
CLI-85-09, 21 NRC at 1157.
(e)
Prior to completion of the Power Escalation Test Program, GPU Nuclear Corporation shall demonstrate performance of the saturation meter, the incore thermocouple, and the wide range hot leg temperature instrumentation systems installed to recognize inadequate core cooling.
CLI-85-09, 21 NRC at 1157. - _ - _ _ _ _ _ - _ _ _ - _ - _ _ _ -
(f)
Prior to completion of the Power Escalation Test Program, GPU Nuclear Corporation shall demonstrate EFW initiation on loss of all four reactor coolant pumps. CLI-85-09, 21 NRC at 1157.
Status These conditions have been completed. The Power Escalation Program was completed with the achievement of 100% power operation on January 6, 1986.
Condition 3(a)
Prior to startup following Cycle 6 refueling, GPU Nuclear Corporation shall upgrade the EFW system to provide safety grade automatic control and to provide other system improvements to include redundant control and block valves, automatic start on once through steam generator (OTSG) low level, and upgrades of the main steam rupture detection system and the condensate storage tank low-low level alarm to safety grade.
LBP-82-27, 15 NRC at 747.
Status This condition has been completed. Modifications were completed during the Cycle 6 refueling outage. The NRC approved the system design and operation in NRC SER "TMI-1 Emergency Feedwater System" dated February 18, 1987; TMI-1 License Amendment 124 dated April 9, 1987; and NRC SER "TMI-1 Main Steam Line Rupture Detection System," dated April 18, 1988.
Condition 3(b)
GPU Nuclear Corporation shall correct the human factors deficiency in TMI-1 control room design that is identified in Item 4c of NUREG-0752 and its Supplement 1 prior to startup following Cycle 6 refueling, and GPU Nuclear Corporation shall address final resolution of the human factors design deficiencies that are identified in Items 3b, 3e, 39, and 10b of NUREG-0752 and/or its Supplement 1 in dis detailed control room design review (DCRDR) report for TMI-1. LBP-81-52, 14 NRC at 1320-24; LBP-82-27, 15 NRC at 751-52.
Status This condition has been completed. NRC SER " Detailed Control Room Design Report for TMI-1" dated April 8,1985 concluded the requirements for NUREG-0737 Item I.D.1, Control Room Design Review were completed and deficiencies identified in NUREG-0752 had been corrected.
i Condition 4(a)
Within the first two years after any restart authorization, GPU Nuclear Corporation's qualification and requalification testing and training program shall be subjected to an in-depth audit by independent auditors, approved by the NRC Director of Nuclear Reactor Regulation, such auditors to have had no role in the TMI-1 restart proceedings.
LBP-82-56, 16 NRC at 384. _ _ _ _ _ - _ _ _
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l Status l
This condition has been completed. GPUN submitted the results of the independent audit on May 15, 1987.
Condition 5(a)
Annually, in October of each year, GPU Nuclear Corporation shall provide to the NRC reports on progress toward installation of a TMI-1 exact replica simulator.
GPU Nuclear Corporation shall make reasonable and diligent efforts to have such simulator installed by the end of 1985.
LBP-81-32, 14 NRC at 578-79.
Status This condition has been completed. Our last status report was provided September 11, 1986. Operator training on the TMI-1 Replica Simulator began in December 1986.
Condition 5(b)
Following availability of a basic principles trainer, GPU Nuclear Corporation shall provide for each operator as a part of annual requalification training at least one week training per year on this trainer in addition to the week each year at Babcock and Wilcox's simulator, at least until GPU Nuclear Corporation's exact replica simulator is available.
LBP-81-32, 14 NRC at 578-79.
Status This condition has been completed. GPUN began using the TMI-1 Replica Simulator for operator training in December 1986.
Simulator training is included in the TMI-1 Licensed Operator Requalification Training Program.
Condition 5(c)
A program to reduce leakage from those portions of systems outside containment that could contain highly radioactive fluids during a serious transient or accident shall be implemented and maintained. LBP-82-27, 15 NRC 747.
Status This condition has been satisfied. TMI-1 Technical Specification 6.9.1.B.3 requires the results of the Leakage Reduction Program be reported annually.
The implementation and maintenance of the program is implicit in the specification, therefore, termination of the program would be subject to NRC approval.
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