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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M0721999-10-19019 October 1999 Forwards NRC Rept Number 17, Requal Tracking Rept from Operator Licensing Tracking Sys.Rept Was Used by NRC to Schedule Requalification Exam for Operators & Record Pass Dates ML20217D8361999-10-11011 October 1999 Provides NRC with Summary of Activities at TMI-2 During 3rd Quarter of 1999 ML20217F8271999-10-0707 October 1999 Forwards Pmpr 99-13, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting Period 990828- 0924.Diskette Containing Pmpr in Wordperfect 8 Is Encl. All Variances Are Expressed with Regard to Current Plans ML20212L1831999-10-0101 October 1999 Responds to Recent Ltr to Wd Travers Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Performance of Millstone to Ensure Adequate Protection to Public Health ML20212L2081999-10-0101 October 1999 Responds to Recent Ltrs to President Wj Clinton,Chairman Jackson & Commissioners & Wd Travers,Expressing Concerns Re Millstone NPPs & Continued Lack of Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance ML20212K1241999-10-0101 October 1999 Responds to Recent Ltrs to Chairman Jackson,Commissioners & Wd Travers,Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performace of Millstone to Ensure That Public Health & Safety,Adequately Protected ML20212L1971999-10-0101 October 1999 Responds to Recent Ltr to Chairman Jackson & Commissioners Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance to Ensure Public Health & Safety ML20212J9991999-10-0101 October 1999 Responds to Recent Ltr to President Clinton,H Clinton, Chairman Jackson &/Or Wd Travers Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performance of Plant to Ensure That Public Health & Safety Adequately Protected ML20212L0061999-10-0101 October 1999 Discusses GL 97-06 Issued by NRC on 971231 & Gpu Response for Three Mile Island .Staff Reviewed Response & Found No New Concerns with Condition of SG Internals or with Insp Practices Used to Detect Degradation of SG Internals ML20212L2171999-10-0101 October 1999 Responds to Recent Ltr to President Wj Clinton,Chairman Jackson & Commissioners,Wd Travers & Ferc,Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island ML20212K8771999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Three Mile Island on 990913.No Areas Identified in Which Licensee Performance Warranted Addl Insp Beyond Core Insp Program.Provides Historical Listing of Plant Issues & Insp Schedule ML20212K8551999-09-30030 September 1999 Informs That During 990921 Telcon Between P Bissett & F Kacinko,Arrangements Were Made for Administration of Licensing Exams at Facility During Wk of 000214.Outlines Should Be Provided to NRC by 991122 ML20216J6581999-09-28028 September 1999 Provides Info as Requested of Licensees by NRC in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams ML20212J0011999-09-27027 September 1999 Forwards Insp Rept 50-289/99-07 on 990828.No Violations Noted ML20212E1971999-09-16016 September 1999 Forwards Rev 11 of Gpu Nuclear Operational QAP, Reflecting Organizational Change in Which Functions & Responsibilities of Nuclear Safety & Technical Support Div Were Assigned to Other Divisions ML20212A2101999-09-13013 September 1999 Forwards Rev 3 of Gpu Nuclear Post-Defueling Monitored Storage QAP for Three Mile Island Unit 2, Including Changes Made During 1998.Description of Changes Provided on Page 2 ML20216G4151999-09-0909 September 1999 Forwards Pmpr 99-12, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting Period 990731- 0827.All Variances Expressed with Regard to Current Operations Plans ML20211M5861999-09-0202 September 1999 Forwards non-proprietary & Proprietary Response to NRC 990708 RAI Re TS Change Request 272,reactor Coolant Sys Coolant Activity.Proprietary Encl Withheld ML20211M6591999-09-0101 September 1999 Forwards Errata Page to 990729 Suppl to TS Change Request 274,to Reflect Proposed Changes Requested by . Page Transmitted by Submitted in Error ML20211L2401999-09-0101 September 1999 Submits Response to NRC AL 99-02, Operator Reactor Licensing Action Estimates ML20211H3731999-08-27027 August 1999 Responds to NRC 990810 RAI Re TMI LAR 285 & TMI-2 LAR 77 Re Changes Reflecting Storage of TMI-1 Radioactive Matls in TMI-2 Facility.Revised License Page mark-up,incorporating Response,Encl ML20211H4001999-08-27027 August 1999 Responds to NRC 990810 RAI Re TMI-1 LAR 285 & TMI-2 LAR 77 Re Changes to Clarify Authority to Possess Radioactive Matls Without Unit Distinction.Revised License Page mark-up, Incorporating Response Encl ML20211K2391999-08-23023 August 1999 Forwards fitness-for-duty Performance Data Repts for TMI, Oyster Creek & Corporate Headquarters Located in Parsippany, Nj ML20211H5041999-08-20020 August 1999 Forwards Proprietary & non-proprietary Rept MPR-1820,rev 1, TMI Nuclear Generating Station OTSG Kinetic Expansion Insp Criteria Analysis. Affidavit Encl.Proprietary Rept Wihheld 05000289/LER-1999-007, Forwards LER 99-007-01 Re Increasing Failure Rate of ESAS Relays.Rept Supplements Preliminary Info Re Determination of Root Cause & Long Term Corrective Actions.Changes Made for Supplement Are Indicated in Bold Typeface1999-08-20020 August 1999 Forwards LER 99-007-01 Re Increasing Failure Rate of ESAS Relays.Rept Supplements Preliminary Info Re Determination of Root Cause & Long Term Corrective Actions.Changes Made for Supplement Are Indicated in Bold Typeface ML20211A4261999-08-19019 August 1999 Forwards Insp Rept 50-289/99-04 on 990606-0717.Two Severity Level 4 Violations Occurred & Being Treated as Noncited Violations ML20211H3571999-08-19019 August 1999 Forwards Itemized Response to NRC 990712 RAI Re TS Change Request 248 Re Remote Shutdown Sys,Submitted on 981019 ML20211A3931999-08-12012 August 1999 Requests NRC Concurrence with Ongoing Analytical Approach as Described in Attachment,Which Is Being Utilized by Gpu Nuclear to Support Detailed License Amend Request to Revise Design Basis for TMI-1 Pressurizer Supports ML20210R4691999-08-11011 August 1999 Forwards Update 3 to Post-Defueling Monitored Storage SAR, for TMI-2.Update 3 Revises SAR to Reflect Current Plant Configuration & Includes Minor Editorial Changes & Corrections.Revised Pages on List of Effective Pages ML20210N7601999-08-10010 August 1999 Informs That NRC Staff Reviewed Applications Dtd 990629, Which Requested Review & Approval to Allow Authority to Possess Radioactive Matl Without Unit Distinction Between Units 1 & 2.Forwards RAI Re License Amend Request 285 ML20210N7191999-08-0606 August 1999 Forwards Notice of Partial Denial of Amend to FOL & Opportunity for Hearing Re Proposed Change to TS 3.1.12.3 to Add LCO That Would Allow Continued HPI Operation ML20210L3831999-07-30030 July 1999 Responds to NRC 990617 RAI Re OTSG Kinetic Expansion Region Insp Acceptance Criteria That Was Used for Dispositioning Indications During Cycle 12 Refueling (12R) Outage ML20210K7371999-07-30030 July 1999 Forwards Rev 2 to 86-5002073-02, Summary Rept for Bwog 20% Tp LOCA, Which Corrects Evaluation Model for Mk-B9 non- Mixing Vane Grid Previously Reported in Util to Nrc,Per 10CFR50.46 ML20210L1151999-07-28028 July 1999 Confirms Two Senior Management Changes Made within Amergen Energy Co,Per Proposed License Transfer & Conforming Administrative License Amends for TMI-1 05000289/LER-1999-009, Forwards LER 99-009-00 Re 990626 Event Involving Partial Loss of Offsite Power & Subsequent Automatic Start of EDG 1A.Commitments Made by Util Are Contained in long-term Corrective Actions Section1999-07-22022 July 1999 Forwards LER 99-009-00 Re 990626 Event Involving Partial Loss of Offsite Power & Subsequent Automatic Start of EDG 1A.Commitments Made by Util Are Contained in long-term Corrective Actions Section ML20216D4001999-07-22022 July 1999 Provides Summary of Activities at TMI-2 During 2nd Quarter of 1999 ML20210B8231999-07-21021 July 1999 Forwards Exemption from Certain Requirements of 10CFR50.54(w) for Three Mile Island Nuclear Station,Unit 2 in Response to Licensee Application Dtd 990309,requesting Reduction in Amount of Insurance for Unit to Amount Listed ML20210G9471999-07-15015 July 1999 Forwards Pmpr 99-10, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting period,990605- 0702.Diskette Containing Pmpr in Wordperfect 8 Format Is Also Encl ML20209H9401999-07-15015 July 1999 Forwards Copy of Environ Assessment & Findings of No Significant Impact Re Application for Exemption Dtd 990309. Proposed Exemption Would Reduce Amount of Insurance for Onsite Property Damage Coverage as Listed ML20209G2451999-07-15015 July 1999 Advises That Suppl Info in Support of Proposed License Transfer & Conforming Adminstrative License Amends,Submitted in & Affidavit,Marked Proprietary,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) ML20212K1701999-07-13013 July 1999 Submits Concerns Re Millstone & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Should Provide Adequate Emergency Planning in Case of Radiological Accident ML20216D9861999-07-12012 July 1999 Forwards RAI Re 981019 Application Request for Review & Approval of Operability & SRs for Remote Shutdown Sys. Response Requested within 30 Days of Receipt of Ltr ML20209G5861999-07-0909 July 1999 Forwards Insp Rept 50-289/99-05 on 990510-28.No Violations Noted ML20209F2571999-07-0909 July 1999 Forwards Staff Evaluation Rept of Individual Plant Exam of External Events Submittal on Three Mile Nuclear Station, Unit 1 ML20209D8451999-07-0808 July 1999 Forwards Insp Rept 50-289/99-06 on 990608-11.No Violations Noted.Overall Performance of ERO Very Good & Demonstrated, with Reasonable Assurance,That Onsite Emergency Plans Adequate & That Util Capable of Implementing Plan ML20209D6291999-07-0808 July 1999 Forwards Notice of Withdrawal & Corrected TS Pages 3-21 & 4-9 for Amend 211 & 4-5a,4-38 & 6-3 for Amend 212,which Was Issued in Error.Amends Failed to Reflect Previously Changes Granted by Amends 203 & 204 ML20209D5141999-07-0808 July 1999 Forwards RAI Re 981019 Application & Suppl ,which Requested Review & Approval of Revised Rc Allowable Dose Equivalent I-131 Activity Limit with Max Dose Equivalent Limit of 1.0 Uci/Gram.Response Requested within 30 Days 05000289/LER-1999-008, Forwards LER 99-008-00 Re Discovery of Degraded But Operable Condition of RB Emergency Cooling Sys.Condition Did Not Adversely Affect Health & Safety of Public1999-07-0202 July 1999 Forwards LER 99-008-00 Re Discovery of Degraded But Operable Condition of RB Emergency Cooling Sys.Condition Did Not Adversely Affect Health & Safety of Public ML20196J3981999-07-0101 July 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Y2K Readiness Disclosure for TMI-1 Encl ML20209C1131999-07-0101 July 1999 Forwards Signed Agreement as Proposed in NRC Requesting Gpu Nuclear Consent in Incorporate TMI-1 Thermo Lag Fire Barrier Final Corrective Action Completion Schedule Commitment of 000630 Into Co Modifying License 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217D8361999-10-11011 October 1999 Provides NRC with Summary of Activities at TMI-2 During 3rd Quarter of 1999 ML20217F8271999-10-0707 October 1999 Forwards Pmpr 99-13, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting Period 990828- 0924.Diskette Containing Pmpr in Wordperfect 8 Is Encl. All Variances Are Expressed with Regard to Current Plans ML20216J6581999-09-28028 September 1999 Provides Info as Requested of Licensees by NRC in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams ML20212E1971999-09-16016 September 1999 Forwards Rev 11 of Gpu Nuclear Operational QAP, Reflecting Organizational Change in Which Functions & Responsibilities of Nuclear Safety & Technical Support Div Were Assigned to Other Divisions ML20212A2101999-09-13013 September 1999 Forwards Rev 3 of Gpu Nuclear Post-Defueling Monitored Storage QAP for Three Mile Island Unit 2, Including Changes Made During 1998.Description of Changes Provided on Page 2 ML20216G4151999-09-0909 September 1999 Forwards Pmpr 99-12, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting Period 990731- 0827.All Variances Expressed with Regard to Current Operations Plans ML20211M5861999-09-0202 September 1999 Forwards non-proprietary & Proprietary Response to NRC 990708 RAI Re TS Change Request 272,reactor Coolant Sys Coolant Activity.Proprietary Encl Withheld ML20211M6591999-09-0101 September 1999 Forwards Errata Page to 990729 Suppl to TS Change Request 274,to Reflect Proposed Changes Requested by . Page Transmitted by Submitted in Error ML20211L2401999-09-0101 September 1999 Submits Response to NRC AL 99-02, Operator Reactor Licensing Action Estimates ML20211H3731999-08-27027 August 1999 Responds to NRC 990810 RAI Re TMI LAR 285 & TMI-2 LAR 77 Re Changes Reflecting Storage of TMI-1 Radioactive Matls in TMI-2 Facility.Revised License Page mark-up,incorporating Response,Encl ML20211H4001999-08-27027 August 1999 Responds to NRC 990810 RAI Re TMI-1 LAR 285 & TMI-2 LAR 77 Re Changes to Clarify Authority to Possess Radioactive Matls Without Unit Distinction.Revised License Page mark-up, Incorporating Response Encl ML20211K2391999-08-23023 August 1999 Forwards fitness-for-duty Performance Data Repts for TMI, Oyster Creek & Corporate Headquarters Located in Parsippany, Nj 05000289/LER-1999-007, Forwards LER 99-007-01 Re Increasing Failure Rate of ESAS Relays.Rept Supplements Preliminary Info Re Determination of Root Cause & Long Term Corrective Actions.Changes Made for Supplement Are Indicated in Bold Typeface1999-08-20020 August 1999 Forwards LER 99-007-01 Re Increasing Failure Rate of ESAS Relays.Rept Supplements Preliminary Info Re Determination of Root Cause & Long Term Corrective Actions.Changes Made for Supplement Are Indicated in Bold Typeface ML20211H5041999-08-20020 August 1999 Forwards Proprietary & non-proprietary Rept MPR-1820,rev 1, TMI Nuclear Generating Station OTSG Kinetic Expansion Insp Criteria Analysis. Affidavit Encl.Proprietary Rept Wihheld ML20211H3571999-08-19019 August 1999 Forwards Itemized Response to NRC 990712 RAI Re TS Change Request 248 Re Remote Shutdown Sys,Submitted on 981019 ML20211A3931999-08-12012 August 1999 Requests NRC Concurrence with Ongoing Analytical Approach as Described in Attachment,Which Is Being Utilized by Gpu Nuclear to Support Detailed License Amend Request to Revise Design Basis for TMI-1 Pressurizer Supports ML20210R4691999-08-11011 August 1999 Forwards Update 3 to Post-Defueling Monitored Storage SAR, for TMI-2.Update 3 Revises SAR to Reflect Current Plant Configuration & Includes Minor Editorial Changes & Corrections.Revised Pages on List of Effective Pages ML20210L3831999-07-30030 July 1999 Responds to NRC 990617 RAI Re OTSG Kinetic Expansion Region Insp Acceptance Criteria That Was Used for Dispositioning Indications During Cycle 12 Refueling (12R) Outage ML20210K7371999-07-30030 July 1999 Forwards Rev 2 to 86-5002073-02, Summary Rept for Bwog 20% Tp LOCA, Which Corrects Evaluation Model for Mk-B9 non- Mixing Vane Grid Previously Reported in Util to Nrc,Per 10CFR50.46 ML20210L1151999-07-28028 July 1999 Confirms Two Senior Management Changes Made within Amergen Energy Co,Per Proposed License Transfer & Conforming Administrative License Amends for TMI-1 05000289/LER-1999-009, Forwards LER 99-009-00 Re 990626 Event Involving Partial Loss of Offsite Power & Subsequent Automatic Start of EDG 1A.Commitments Made by Util Are Contained in long-term Corrective Actions Section1999-07-22022 July 1999 Forwards LER 99-009-00 Re 990626 Event Involving Partial Loss of Offsite Power & Subsequent Automatic Start of EDG 1A.Commitments Made by Util Are Contained in long-term Corrective Actions Section ML20216D4001999-07-22022 July 1999 Provides Summary of Activities at TMI-2 During 2nd Quarter of 1999 ML20210G9471999-07-15015 July 1999 Forwards Pmpr 99-10, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting period,990605- 0702.Diskette Containing Pmpr in Wordperfect 8 Format Is Also Encl ML20212K1701999-07-13013 July 1999 Submits Concerns Re Millstone & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Should Provide Adequate Emergency Planning in Case of Radiological Accident 05000289/LER-1999-008, Forwards LER 99-008-00 Re Discovery of Degraded But Operable Condition of RB Emergency Cooling Sys.Condition Did Not Adversely Affect Health & Safety of Public1999-07-0202 July 1999 Forwards LER 99-008-00 Re Discovery of Degraded But Operable Condition of RB Emergency Cooling Sys.Condition Did Not Adversely Affect Health & Safety of Public ML20196J3981999-07-0101 July 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Y2K Readiness Disclosure for TMI-1 Encl ML20209C1131999-07-0101 July 1999 Forwards Signed Agreement as Proposed in NRC Requesting Gpu Nuclear Consent in Incorporate TMI-1 Thermo Lag Fire Barrier Final Corrective Action Completion Schedule Commitment of 000630 Into Co Modifying License ML20196J7651999-06-29029 June 1999 Provides Updated Info Re Loss of Feedwater & Loss of Electric Power Accident Analyses to Support TS Change Request 279 Re Core Protection Safety Limit,As Discussed at 990616 Meeting ML20196J7701999-06-29029 June 1999 Forwards LAR 285 for License DPR-50,clarifying Authority to Possess Radioactive Matls Without Unit Distinction,So That After Transfer of TMI-1 License to Amergen,Radioactive Matls May Continue to Be Moved Between TMI-1 & TMI-2 Units ML20209C0391999-06-29029 June 1999 Forwards LAR 77 to License DPR-73,clarifying Authority to Possess Radioactive Matls Without Unit Distinction,So That After Transfer of TMI-2 License to Amergen,Radioactive Matl May Continue to Be Moved Between TMI-1 & TMI-2 Units ML20196G2061999-06-23023 June 1999 Requests That NRC Update Current Service Lists to Reflect Listed Personnel Changes That Occurred at TMI 05000289/LER-1999-006, Forwards LER 99-006-00,providing Complete Description,Extent of Condition & Actions Taken in Association with Determination of Inability of Pressurizer Support Bolts to Meet FSAR Requirements1999-06-23023 June 1999 Forwards LER 99-006-00,providing Complete Description,Extent of Condition & Actions Taken in Association with Determination of Inability of Pressurizer Support Bolts to Meet FSAR Requirements ML20196D2171999-06-17017 June 1999 Forwards Pmpr 99-9, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting period,990508- 0604.New Summary Personnel Table Was Added to Rept Period.Matl Scientist Joined Staff Period ML20196A0431999-06-15015 June 1999 Providess Notification That Design Verification Activities Related to Calculations Supporting Analytical Values Identified in Gpu Nuclear Ltr to NRC Has Been Completed 05000289/LER-1999-004, Forwards LER 99-004-00,re Discovery of Emergency FW Pump Bearing Failure During Performance of Oil Change on 990510. Event Was Determined Reportable IAW 10CFR50.73,since Pump Was Determined to Be Inoperable Longer than TS AOT1999-06-0909 June 1999 Forwards LER 99-004-00,re Discovery of Emergency FW Pump Bearing Failure During Performance of Oil Change on 990510. Event Was Determined Reportable IAW 10CFR50.73,since Pump Was Determined to Be Inoperable Longer than TS AOT ML20212K2541999-06-0808 June 1999 Submits Concerns Re Millstone NPP & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Requests That NRC Provide Adequate Emergency Planning in Case of Radiological Accident ML20212K2671999-06-0808 June 1999 Submits Concerns Re Millstone NPP & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Requests That NRC Provide Adequate Emergency Planning in Case of Radiological Accident ML20195E2751999-06-0404 June 1999 Informs That PCTs & LOCA Lhr Limits Submitted in Util Ltr for LOCA Reanalysis Performed in Support of TMI-1 20% Tube Plugging Amend Request Have Been Revised.Revised PCT & LOCA Lhr Limit Values Are Provided on Encl Table 1 ML20195E3281999-06-0404 June 1999 Forwards Application for Amend to License DPR-50,modifying Conditions Which Allow Reduction in Number of Means for Maintaining Decay Heat Removal Capability During Shutdown Conditions ML20195C5721999-06-0202 June 1999 Forwards Description of Gpu Nuclear Plans for Corrective Actions for 1 H Fire Barriers in Fire Zones AB-FZ-3,AB-FZ-5, AB-FZ-7,FH-FZ-2 & Previous Commitments for Fire Zones CB-FA-1 & FH-FZ-6 ML20207E2561999-05-25025 May 1999 Submits 30-day Written Rept on Significant PCT Change in ECCS Analyses at TMI-1 ML20195B2461999-05-21021 May 1999 Forwards Itemized Response to NRC 990506 RAI for TS Change Request 279 Re Core Protection Safety Limit ML20206R6461999-05-13013 May 1999 Forwards Rev 39 of Modified Amended Physical Security Plan for TMI 05000289/LER-1999-003, Forwards LER 99-003-00, Discovery of Condition Outside UFSAR Design Basis for CR Habitability, Which Was Determined Reportable on 990310.Rept Is Being Submitted Four Weeks Later than Required,Per Discussion with NRC1999-05-0707 May 1999 Forwards LER 99-003-00, Discovery of Condition Outside UFSAR Design Basis for CR Habitability, Which Was Determined Reportable on 990310.Rept Is Being Submitted Four Weeks Later than Required,Per Discussion with NRC ML20206K6301999-05-0707 May 1999 Provides Addl Info Re TMI-1 LOFW Accident re-analysis Assumptions for 20% Average SG Tube Plugging as Discussed on 990421 ML20206H0781999-04-30030 April 1999 Forwards Rev 0 to 1092, TMI Emergency Plan. Summary of Changes Encl ML20206J4811999-04-30030 April 1999 Provides Summary of Activities at TMI-2 During First Quarter of 1999.TMI-2 RB Was Not Inspected During Quarter.Routine Radiological Surveys of Auxiliary & Fuel Handling Bldgs Did Not Identify Any Significant Adverse Trends ML20206E4121999-04-27027 April 1999 Requests That TS Change Request 257 Be Withdrawn ML20206C5211999-04-23023 April 1999 Requests Mod to Encl Indemnity Agreement Number B-64,on Behalf of Gpu & Affiliates,Meed,Jcpl,Penelec & Amergen Energy Co,Llc.Ltr Supersedes & Withdraws 990405 Request Submitted to NRC ML20206C8261999-04-22022 April 1999 Submits Financial Info IAW Requirements of 10CFR50.71(b) & 10CFR140.21 1999-09-09
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GPU Nuclear Co:poration (uclear i, U =',,wsgreo Middletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Nurnber:
(717) 948-8005 June 24, 1992 C311-92-2092 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Dear S;r:
Subject:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Inservice Testing (IST) of Pumps and Valves - Operability On December 3, 1990, GPU Nuclear responded to NRC Generic Letter (GL) 89-04 concerning the Inservice Testing (IST) and o)erability of pumps and valves at THI-1. GPU Nuclear intends to fulfill our o)li license, Technical Specifications (Tech Specs)and gations relative other NRC re to the However our response took exception to Position 8 of GL 89-04'quirements. which calls for declaring a component inoperable, without proper evaluation, when the test data for a component test falls within the ASME Section XI " required action range." GPU Nuclear has concluded that to do so could ultimately result in entering a 72-hour Tech Spec allowable outage time (A0T) and lead to an unnecessary plant shutdown.
Discussions with the NRC during a April 28-29, 1992 workshop on Generic letter 91-18 in King of Prussia, PA, as well as operating experience subsequent to our December 3, 1990 letter, have reinforced our desire to contic.ue our ongoing discussion of operability considerations regarding the pump and valve IST program. The purpose of this letter is to clarify our position regarding operability determinations resulting from IST, to demonstrate that our g, approach is consistent with the general view espoused by NRC management, and ono to attempt to achieve consensus with the NRC staff regarding this approach, gga. It is noteworthy that the history of component test operability detsrminations oc as a result of IST are a rare occurrence at TMI-1. Typically we have g8 experienced this condition one or two times each year and, in almost every instance, the final evaluation proved the component to be operable.
SU OQ f.o 1
This exception applies also to section 6.11, " Technical Specification Operability vs. ASME Code Section X7 Operative Criteria," of the NRC ,
om Inspection Manual Part 990o, which was transmitted to licensees as an 7
/ j k enclosure to NRC Generic Letter 91-18.
l Q Q O 'j 3 GPU Nuclear Corporanon is a subsidiary ct General Pubhc Ubbt<es Corporation
e C311-92-2092 Page 2 GPU Nuclear believes there are greater risks associated with unnecessarily shutting down the plant during an operating cycle than those associated with operating while a component's continued o>erability is being evaluated. We endorse the general guidance promulgated ay Dr. T. Murley in his memorandum of July 19, 1989. In his memorandum Dr. Murley stated that after careful consideration, NRR had concluded that guidance was not necessary concerning the length of time a licensee should be allowed to decide the question of operability when an equipment deficiency is discovered. He stated "There is no generally ap)ropriate timeframe in which operability determinations should be made." Furtier, Dr. Murley went on to note that equipment which is in fact inoperable should be immediately declared as such and the appropriate Tech Spec timeclock entered. However, when a question is raised regarding the operability of a component, operability determinations should be made using the best information available (e.g., analyses, a test or partial test, experience with operating events, engineering judgement, or a combination of these factors). We have and will continue to adhere to these guidelines.
Actions taken at TMI-; over the years support our position that compliance with this philosophy is prudent.
The central issue related to an nperability determination is the component's ability to perform its intended function. A determination of operability based solely on generic limits, narrowly defined by ASME Section XI tables or formulae, may force a judgement to declare a-component inoperable when, in fact, the component will perform its intended function acceptably and predictably. Attachment 1 provides examples where TMI-l components have been determined to be in the " required action range" and remained fully functional.
Consequently, GPU Nuclear consiaers it imprudent to start the Tech Spec timeclock when a component has not been evaluated and may be fully able to perform its intended function.
GPU Nuclear intends to assure ccmpliance with NRC requirements, including the TMI-l Tecn Specs. However, GPU Nuclear believes it is appropriate to adequately evaluate test data before making a determination of liioperability which could potentially force a shutdown of the plant based on acceptance criteria which ray prove to be excessively conservative. We remain committed to the premise that obviously inoperable components (i.e., broken shaft, pump / valve will not move, etc.),- will be declared inoperable immeciately per Administrative Procedure (AP) 1041, and the appropriate action will be taken as' directed by Tech Specs. In regard to pump tests, AP 1041 states: " If confirmed test data falls within the ' Required Action Range' and the pun.p is clearly inoperable in the N gement of the Shift Foreman, the pump shall be declared inoperable and the acclicable Tech Spec requirements observed." In regard to valve tests, AP 1041 states: " If confirmed-test data exceeds the-
' maximum allowable stroke time for a MOV (or if a check valve fails to move to its safety position
- the SF/SS, the Tech) Spec time clock shall be started per the applicable Techand the valv Spec."
t Therefore, based on the above rationale, GPU Nuclear has concluded thai. it is not appropriate to declare a component inoperable basu solely on IST results which fall within the " Required Action Range" as proposed in Position 8 of
, GL 89-04. When a component's IST results fall within that range, the preliminary determination will be made that s component is operable unless its inoperability is apparent. Operabili+y determinations are based upon everything we know about that comporent. GPU Nuclear will apply the resources t
r e *-,,..rv3-y,,s,., -
,a.- ,4- vv ----+m-,..e -,+-~m ~m.- ..--,.--,,vv . = ,----w-- .- c 4 e .r =~ " - - - - -
C311-92-2092 Page 3 .
1 necessary to complete a timely evaluation to support the initial determination '
of operability when the results from IST fall in the " required action range."
We agree with the statement made by the NRC during the GL 91-18 workshop that the time for evaluation will depend on safety significance. When a judgement based upon evaluation determines that a component is in fact inoperable, adherence to the Tech Spec A0T, retroactive to discovery of the discrepant data, will be effected.
Sincerely, l
T.G.Broub[tondNbww t/<%
Vice Presi ent and Director, TMI-l i
i MRK Attachment cc: Region I Administrator TMI-l Senior Project Manager TMI Senior Resident inspector l
i-l l
l
~
l l
ATTACHMENT l MS-V13B HS-V138 is an air operated valve which supplies steam to the turbine driven Emergency Feedwater (EFW) Pump, EF-P1, one of three safety related EFW pumps.
Since 1988, the stroke time for MS-V13B had been 19 to 20 seconds with a maximum allowable stroke time of 23 seconds. On 12/29/91 at ~0200 hours, its stroke time was 24.7 seconds which would have rendered MS-V138 immediately inoperable under strict GL 89-04 guidance. Tech Spec 3.4.1.1 requires the operability of all three EFW pumps. If one pump is inoperable, it must be restored in 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or the plant is required to be in cold shutdown within the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
In an initial telephone call on 12/29/91 at -0800 hours, MS-V138 was evaluated to be operable based upon the satisfactory EF-P1 startup time data. Extensive analysis by the GPU Nuclear's technical support organization was completed on 2/11/92 whi .h showed that the maximum stroke time of MS-V13B could be increased to a conservative value of 27 seconds. It is noteworthy that the solenoid valve for MS-V138 was replaced on 1/25/92 leaving the "as lef t" stroke time for MS-V13B of 17.5 seconds.
MU-V51 MU-V51 is a 1", 150 lb Grinnell air operated diaphragm valve which fails closed. The valve opens with air pressure on one side of a diaphragm and closes by spring force when a solenoid valve bleads the air off. On 7/10/91 the measured stroke time of MU-V51 was 3.8 seconds. This exceeded its 2 second maximum allowable stroke time. Restroking MU-V51 gave acceptable stroke times of 1.6 and 1.5 seconds. The valve's stroke time was -1 second in 1988, ~1.2 sec in 1989, and -l.8 sec in 1990 and 1991.
The safety _ function of MU-V51 is to open and supply concentrated boric acid from the Boric Acid Mix Tank (BAMT) or Reclaimed Boric Acid Tanks (RBATs) to the Makeup Tank (MUT) if the Borated Water Storage Tank (BWST) is lost. -The MUT-is pumped to the Reactor Coolant System (RCS) by the High Pressure Injection (HPI) Pumps. As provided in the Basis of Tech Spec 3.2.2, the RCS can be borated-to one percent (1% Ak/k) subcritical at the worst time in core life with a stuck control rod assembly in less than-13 hours using one of the-10 gpm BAMT Pumps. In_ addition to the MU-V51 line, there is an alternative flow path through WDL-V61 from the BAMT or RBATs to the MUT. Operator action is required to start the pump to begin addition of concentrated boric acid to the MUT. The above shows that it takes significant time to add a sufficient amount of boric acid such that a stroke time of 3.8 second for MU-V51 has no significant impact on pumping time.
On 11/1/91 maintenance was performed on MU-V51 when tests demonstrated an increasing stroke time. The solenoid valve operator was found rusty with interior scale deposits. MU-V51 stroke time following maintenance was
-1.0 second.
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'[ SF-Pl A/B THI-l FSAR, Table 9.4-1 states that the capacity of SF-PIA /B is 1,000 gpm at 100 ft. A flow rate of 1,000 gpm per pump ensures that under the highest heat load (574 spent fuel assemblies in storage accumulated from 11 successive
. yearly refuelings and the addition of the entire core,177 assemblies during the twelfth refueling, completed in 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br />) the pool temperature will not exceed 147'F. Therefore, 1,000 gpm from SF-PIA /B delivered to the pool (s) satisfies the safety function of SF-PIA /B. SF-PIA /B is operable if 21,000 gpm can be delivered to the pool (s) and vibration is satisfactory.
In 1985 SF-PIA /B were in the AP required action range. At 1000 gpm SF-PIA had 85.6 ft of head and SF-P13 had 83.3 ft of head. For SF-PIA this was 14.4%
less than the design point (100 ft and 1000 gam) and for SF-PIB this was 16.7%
below the design point. Pump vibration was extremely low (0.21H for SF-PIA and 0.15H for SF-PIB). ASME Section XI, Table IWP 3100-2 states that the required action range is <.9 times the reference value. For SF-PIA:
85.6 ft X (<.9) - <77 ft. For SF-PIB: 83.3 ft X (<.9) - <75 ft. For SF-PIA and SF-PIB trains the head loss (both piping frictional loss and elevation head) has been estimated to be <50 ft by standard head loss calculations in accordance with the Crane Handbock and other text book references. This indicates that the head of SF-PIA /B could drop to 50 ft and 1000 gpm still could be delivered to the pool (s). Therefore, <75 ft as a required action range is clearly acceptable and conservetive. IST Testing in 1991 shows that SF-PIA has remained at -85.6 ft at 1000 gpm while SF-PIB has dropped to -80 ft ,
at 1000 gpm. 30 ft is greater than the <75 ft chosen as the required action range.
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