ML18283A520

Licensee'S Motion for an Order Authorizing Control Rod Drive System Tests

ML18283A520
Person / Time
Site:	Browns Ferry
Issue date:	07/20/1976
From:	Dunker W, Dawn Powell, Sanger H Tennessee Valley Authority
To:	Atomic Safety and Licensing Board Panel
References
Download: ML18283A520 (18)

Text

UK%ED STATES OF AMERICA NUCLEAR REGULATOHX COMMISSION Before the Atomic Safety and Licensing Board In the Matter of )

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TENNESSEE VAIZZlX AUTHORITX ) Docket Nos. 50-259

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(Bro>ms Ferry Nuclear Plant, )

Units 1 and. 2) )

LICENSEE'S MOTION FOR AN ORDER AUTHORIZING CONTROL ROD DRIVE SXSTEM TESTS Licensee Tennessee Valley Authority moves that this Atomic Safety and Licensing Board authorize the Licensee to conduct Control Rod Drive System tests, on the grounds that:

(1) Granting the motion wi13. not affect the Intervenor's rights in this proceeding; (2) It is in the public interest to authorize the requested tests; and

(3) There is reasonable assurance that conducting the tests under the conditions set out in TVA's affidavit will not endanger the health and safety of the public.

Respectfully submitted, Herbert S. Sanger, Jr.

General Counsel Tennessee Valley Authority Knoxville, Tennessee David G. Powell Assistant General Counsel g/&Id ia William L. Dunker Attorneys for Licensee Chattanooga, Tennessee July 20, 1976

UNITED STATES .OF &1ERICA NUCLEAR. REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Hatter of TENNESSEE VALLEY AUTHORITY Docket Nos. 50-259 50-260 (Browns, Ferry Nuclear Plant, Units 1 and 2)

LICENSEE'S BRIEF IN SUPPORT OF MOTION TO CONDUCT CONTROL ROD DRIVE SYSTEM TESTS STATE'KNT This proc'ding concerns the. proposed issuance nf amendments to facility operating Licenses Nos. DPR-33 and DPR-52 for Browns Ferry Nuclear Plant units 1 and 2, as set forth in 40 Fed. Reg. 46365 (1975).

In its Order of Hay 21, 1976, regarding fuel loading, the Board"deter-mined that "fi]fthe Intervenor's contentions are relevant to the activity asked to be authorised, the Board must make findings in the'orm of an initial decision on each matter specified in 5 50.57(a) which is in controversy with respect to the amendment and for which a hearing has been requested" (at 4) .

TVA is requesting the Board to authorize Control Rod Drive System tests from the startup retest program. Several significant points should be emphasized concerning these tests. The tests are subcritical testing, and no power operation is involved; all control rods except the one being tested will be fully inserted, valved out, and'electrically disarmed; none of the systems necessary to conduct the tests on unit 2 were damaged or modified as a result of the fire; while some of the systems necessary for the tests on unit l were Sire-affected and have been restored, no credit is taken for such systems in the worst-case accident analysis; and the worst accident that could happen, i.e.,

failure of the one operational control rod in the fully .withdrawn position, will have no adverse consequences and the reactors will remain subcritical.

Intervenor's contentions do not relate to the tests on unit

2. Contention l has been withdrawn by the Intervenor. Contention 2 alleges that TVA personnel are not technically qualified ox competent to satisfactorily complete fire-related modifications. Contention 3 alleges that NRC's inspection program is insufficient in regard to fire-related modifications. Since the tests on unit 2 require no systems damaged ox modified as a result of the fire, and no operation is involved, it is not necessary for the Board to P

make the findings in section 50.57.

Systems needed to conduct the tests are the Source Range Monitoring System, Control Rod Drive Hydraulic System, and the Reactor

Manual Control System. All of these systems have been preoperationally tested and shown to be functioning properly. Por the unit 2 tests, none of these systems were damaged or modified as a result of the fire.

Por unit 1, no credit is taken for these systems in the accident analysis.

The worst accident that could happen would result in failure of the one operational control rod in the fully withdrawn position. Under these conditions, the reactor will remain subcritical, and the shutdown margin required by the technical specifications would not be reduced. Under these circumstances, Intervenor's. contentions are not relevant to the actions requested. In any event, the Board can readily find on the basis of the attached affidavit of Jack R. Calhoun, that there is reasonable assurance that conducting the Control Rod Drive System tests will not endanger the health and safety of the public.

It is TVA's position that, under, these circumstances, (1) granting the motion. will not affect'he Intervenor's rights in this proceeding, (2) the public interest requires that this much progress be made at the present time without waiting until completion of the forthcoming evidentiary proceeding, and (3) there is reasonable assurance that conducting the tests as set forth under the'onditions specified by Jack R. Calhoun will not endanger the health and safety of the public.

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4 Grantin the Motion Hill Not Affect Intervenor's Ri hts in This Proceedin I

Contentions 2 and 3 allege that TVA personnel are not competent to sati'sfactorily complete the fire-related modifications necessary to provide adequate protection against the loss of redundant components of engineered safeguards equipment from fire, and that NRC's inspection and surveillance program is insufficient to -assure that TVA satisfactorily completes the fire-related work necessary to provide 'adequate protection .

against the loss of redundant components of engineered safeguards equip-ment from fire. Contention 1 has been withdrawn by the Intervenox.

As shown by Mr. Calhoun's affidavit, the tests to be con-du ted on uni>' do not involve any systems damaged by the fire or modified as a result of the fire. Thus the Intervenor's content'ions do not relate to these activities and his xights are not affected.

Indeed, it can be argued that in regard to unit 2, the Board has no jurisdiction over any testing that does not involve fire-related matters or operation.

As to unit 1 tests, Mr. Calhoun points out that this is subcritical testing. The Board in its May 21 Order held that

[T]he contentions of Intervenor Garner are relevant power. . . [at 6; emphasis added].

e Since the tests do not involve even partial opexation,of the units, the Intervenor's rights will not be affected by granting the motion'.

Although systems for conducting the tests on unit 1 were damaged or modified as a result of the fire, for the worst case accident no credit is taken for these systems. Mr..Calhoun's accident analysis shows that under these conditions the reactor remains subcritical. Thus Intervenor's rights axe not affected.

Authorizim These Tests Is In the Public Interest.

As shown by TVA's motion, brief, and affidavits filed on

'April 22, 1976, the electrical power from the Hrowns Perry units is urgently needed for power demands on the TVA system. Hr. Calhoun's affidavit shows that by conducting these tests, the reactor vessel head and upper internals can be installed and the startup retesting period can thereby be reduced by 10 days when operation is ultimately authorized. Every day that is saved in xeturning these units to service is essential to system reliability and the cost of power to the public.

Accordingly, it is in the public interest to authorize TVA to conduct these tests.

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XXX There Xs Reasonable Assurance That Conductin the Tests Hill Not Endan er the Health and Safet of the Public.

The accident analysis set out in 1fr. Calhoun's affidavit shows that the worst accident that can happen is the failure of the analytically strongest control rod in the fully withdrawn position.

Both units 1 and 2 sould remain subcritical for this accident. Thus there would be no adverse consequences whatsoever to the public health and safety. should the worst accident happen in regard to these tests.

CONCLUSXON For the foregoing reasons, the Board should grant the, motion.

he Licensee requests that the Board decide this motion on an expedited b"sis. A proposed form of order is attached.

Respectfully submitted, 4...>-.< S.S Herbert S. Sanger, J General Counsel Tennessee Valley Authority Knoxville, Tennessee

.~A 8 David G. Powell Assistant General Counsel Hilliam L. Dunker Attorneys for Licensee Chattanooga, Tennessee July 20, 1976

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of TENNESSEE VALLEY AUTHORITY Docket Nos. 50-259 50-260 (Browns Ferry Nuclear Plant, Units 1 and 2)

PROPOSED FORM OF ORDER By Motion dated July 18, 1976, Tennessee Valley Authority (Licensee or TVA) has moved that this Atomic Safety and Licensing Boaxd (Board) issue an order authorizing Control Rod Drive System tests for Brogans Ferry Nuclear Plant units 1 and 2. As shown by the affidavit of Jack R. Calhoun accompanying the motion, the reactors would remain subcritical throughout the tests; the accident analysis demonstrates that in the case of the worst accident that could happen, i.e., failure of the analytically strongest control rod in the fully'withdrawn position, the reactors will remain subcritical; and granting the motion will reduce startup retest time by 10 days.

The affidavit further shows that no systems damaged or modified as a result of the fixe will be used to conduct the unit 2 tests; and

r that no credit is taken in the worst-case accident on unit 1 for systems that were damaged or modified as a result of the fire.

Based on the foregoing, the Board finds that:

(1) granting the motion will not affect the Intervenor's rights in this proceeding, (2) it's in the public interest to authorize the requested tests, and (3) there is reasonable assurance that conducting the tests under the conditions set out in TVA's affidavit will not endanger the health and safety of the public.

TE1E ATOiEXC SAPETY AND LICENSING BOARD Thomas H. Reilly, Esq., Chairman Bethesda, Maryland July , 1976

UNITED STATES OF AMERICA NUCLEAR REGULATORY COiiQfISSION Before the Atomic Safety and Licensing Board In the Matter of TENNESSEE VALLEY AUTHORITY Docket Nos. 50-259 50-260 (Browns Ferry Nuclear Plant, Units l and 2)

CERTIFICATE OF SERVICE I hereby certify that I have served the original and 20 conformed copies of the following document on the Nuclear Regulatory Commission by depositing them in the United States mail, postage pre-paid .and addressed to Secretary, U.S. Nuclear Regulatory Commission, Uashington, D.C. 20555, Attention: Chief, Docketing and Service Section.

Licensee's Notion for an Order Authorizing Control Rod Drive System Tests and that I have served a copy of the above document upon the persons listed below by depositing it in the United States mail, postage pre-paid and addressed:

r Thomas W. Reilly, Esq., Chairman Dr. Frederick P. Cowan Atomic Safety and Licensing Board 22 Browns Lane U.S. Nuclear Regulatory Commission Bellport, New York 11713 Washington, D.C. 20555 William E. Garner, Esq.

Dr. Hugh C. Paxton Route 4, Box 354 Los Alamos Scientific Laboratory Scottsboro, Alabama 35768 P.O. Box 1663 Los Alamos, New Mexico 87544 Atomic Safety and Licensing Appeal Board James R. Tour tellotte, Esq. U.S. Nuclear Regulatory Commission Lawrence Brenner, Esq. D.C. 20555 'ashington, Office of the Executive Legal Director U.S. Nuclear Regulatory Commission Washington, D.C. 20555 This ~ 1 day of July, 1976.

David G. Powell Attorney for Licensee Tennessee Valley Authority