ML19345F966

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Provides Estimates of Schedules for TMI-1 Restart Per 810128 Request.Schedule Is Reasonable for Scope of Work to Be Completed Prior to Restart.Forwards TMI-1 Restart Plan & Assumptions Used in Scheduling & Planning
ML19345F966
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 02/13/1981
From: Arnold R
METROPOLITAN EDISON CO.
To: Ahearne J, Hendrie J
NRC COMMISSION (OCM)
Shared Package
ML19345F964 List:
References
L1L-044, L1L-44, NUDOCS 8102190617
Download: ML19345F966 (11)
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{{#Wiki_filter:- Metropolitan Edison Company N ) Post Office Box 480 I I {-TU f4" P' n Middletown, Pennsyivania 17057 R)tMrbN400 

                                                                                      .wnter's Direct Dio %moer 9                                           o 717-948-8189 February 13, 1981 L1L 044 The Honorable John A. Ahearne -                        SMII'l        4 Chairman The Honorable Joseph M. Hendrie            '

DOC D Co==1ssioner 

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D, '- FEB 171964 > -4 U. S. Nuclear Regulatory Cocsission o g d the W ' Washington, D. C. 20555 gga:.r.g & SW"M Smnei + Gentlemen: 9) T fd3 i \ In response to your January 28, 1981 request, we are providing our best estimates of schedules for the restart of Unit 1 based upon various assumptions as to the scope of work to be accomplished. We are answering the questions set forth in part 2 of your memorandum in the context of the schedule we believe to be reasonable for the scope of work we plan on completing prior to restart. Our planned work scope is based upon our own reviews and evaluations in addition to the Co ission's Orders of August 9, 1979 and March 6, 1980, NUREO 0694, NUREG 0737 and several other NRC docusents which have addressed a variety of potential safety issues. A su= mary of our TMI-l Restart Plan, which shows a return to criticality and power operations at the end of October 1981 as a plan-ning date, is forwarded as Attachment 1. The notes in the Attachment explain the assu=ptions upon which our planning and scheduling are based. The planning dates and footnotes in Attachment 1 are consistent with cur January 23, 1981 letter which responded to NUREG 0737 and >b. D. Eisenhut's letter of November 25, 1930. Attachment 2 provides the answers to the three questiops in your memorandum which were addressed to us. Our current information has led us to conclude that the controlling work for restart may not be related to the TMI-2 accident but will be the completion of codifications to the Integrated Control System and the Non-Nuclear Instrumen-tation Systems resulting from evaluations prompted by the Crystal River 3 event. The TMI-2 related modification that may prove to be schedule controlling is the change to the containment isolation loyic. As can be seen from Attachment 1, the physical work at the plant and other requirements for startup appear to be close to a " dead ' neat" with the hearing and post-hearing review procedures, especially when one considers that the NRC staff has projected that the evi-dentiary hearing may not be completed until the end of May instead of the end of April as set forth in Attachment 1. While we recognize that there are 810219 0 tel l 

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The Honorable John A. Ahearne Page 2 The Honorable Joseph M. Hendrie February 13, 1981 uncertainties associated with our present planning, we believe the= to be on the order of one to two month:,, and we are striving to not only avoid slippage but to improve on :he current milestone planning da:es. In our judg=ent, the uncertainties associated with the hearing and post-hearing procedures are con-siderably greater than the uncertainties associated with ccmple:ing the work required to provide adequate assuranca that the plant will be operated safely. We continue to believe that ample justification exists f or decoupling the restar: of TMI-l frc: the completion of the hearing process. Seing able to meet the planning dates set forth in Attachmen: 1 is dependent upon a number of items. First and foremost, we need to have the requirements for restart stabill:ed. We need :o have our requests f or modifications to the July 2 and August 9,1979 Orders of the Cc= mission approved so tha; pre-startup activities can proceed as the werk per:1:s. Also, the necessary NRC Staff resources will have :o be applied in parallel with our own so that certification of completion of prerequisites for proceeding beyond critical milestones is not imp ed ed . Finally, we need to be per=itted the same flexibility in fulfilling NUREG 0737 i: ens as other operating reactors. Zhile attention : ends Oc be focused upon the plant modifications as the indica-tors of the extent of improvement in safety of operations, the various investi-gations into the TM1-2 accident, including those conducted by the NRC, clearly identified tha: the major changes necessary to improve saf ety are related : management, training and s:rengthening of procedural aspects of u:ility nuclear operations. This perception of which upgrading activities should receive priority was also reflected in the short term recc==endations of the NRC's 

   " Lessons Learned Task Force". We have dedicated a major pertion of our ef forts to these areas, since we are convinced that a balanced program of improvements will provide the maximum contribution to safety.

Sincerely, 

                                               }J , Wi -

R. C.' Arnold Senior Vice President 4-Jr cc: Cc==issioner Victor Gilinsky Cc=missioner Peter A. Bradford Herman Dieckamp

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TMI-I RESTART PLAN 19 81 1982 JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC JAN FEB ICIll ;g. PLANT ' k h,d[  ?., j'y' 

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i N}Ms , '}If s'4 p LOW PROCEDURES WRITING OPERATOR T R AINING PROGRAM EVALUATION th REVIEW g llEARING AND POST 11 EARING REVIEW FEERUARY 13, 19 88 g MILESTONE PL ANNING DATES' PRELIMINARY llEAT-UP - MID JUNE 1981 FINAL llEAT-UP FOR llOT TESTING - MID SEPIEMBER 1981 CRITICALITY - END OCTOHER 1981 COMPLE TE POWER RANGE TESTING - END JANUARY 1982 S I

4 l ATTACHMENT 1 Page 2 ASSLMPTIONS FOR GPU NUCLEAR RESTART PL.C

1. Modifications to the August 9,1979 Order granting the requests for (a) NRC decision in parallel with NRC certification, (b) flexibility
af forded other OR's, and (c) early non-nuclear heatup authorization.

1 i

2. Full NRC Staff support for prompt completion of certification so as 4

to not impede critical miles:ones.

3. No addition to hearing of psychological stress or post-accident hydrogen control issues.

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4. Comple:icn of ASL3 Hearing and Post Hearing procedures no later than I the following schedule:

il A. April 30, 1931 - Complete evidentiary sessions.

3. July 1,1981 - Co=pletion of all proposed findings and replies to proposed findings.

i 5 C. Septe=ber 1, 1981 - Initial ASL3 Decision i 5. Commission action on lif ting suspension of TMI-l opera:ing authority within 35 days of ASL3 decision. 1 1

6. No delays due to appeals or other post-hearing activities.

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7. . No additional pre-restart require =en:s as a result of ASLB Decision.

f S. No delay due to FEMA certification of s: ate / local emergency plans. 4 a 4 e w= , , *

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ATTACHMENT 1 Page 3

9. Acceptance by NRC of planned schedules for TMI-2.related items, including:

A. Completion of full EFW saf ety upgrades in 1982.

3. Allowance for licensed operator abnormal attrition in establishing required number of licensed operators.

C. Installation of reactor coolant system high point vents in 1982. D. Completion of saf ety grade post-accident monitoring instruments in 1982. E. Installation of certain control room design review modifications in 1982 (and later). F. No major analytical, procedural or training impacts from NRC pilot program to review selected emergency procedures. G. Acceptance of phased implementation dates for heat up, critical, and full power as proposed in response to N'JREG-0737.

10. No significant deviations from current planning for Equipment Environmental Qualification (IE3-79-013) Program. Program completion anticipated prior to 6/30/82.
11. Pre-start completion of IE3 79-14 activities only on limited access components. Post restart program completion.

? [ 12. No pre-restart reactor vessel internals inspection.

13. Approval of variance allowed by the regulations for long term fire protection modifications.
14. Resolutien of reactor -building spray performance issues based upon analyses.

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i 4 1 i ATTACEMENT 2 Response to Part 2 of the January 28 Me=orandum from - Chairman Ahearne and Cc==issioner Hendrie , i 2(a) When can Me:-Ed expect to be in compliance with the itc=s contained in the Augus: 9, 1979 and March 6, 1930 Cot:21ssion Orders. i 4 Met-Ed currently expec:s that the shor: term items of the August 9,1979 Order (CLI-79-3) and March 6,1980 Order (CLI-80-5) have been, or will be, ce=pleted within the schedule set forth in Attachment 1. Since we do not i intend to restar prior to co=ple:ing certain =cdifications to the ICS/NNI > systems which are outside the scope of the Orders, we have not tried :o develop a hypothetic schedule which s?uld apply absent the ICS/NNI modification require-cents. Such a schedule would not be significantly dif f erent because of the status of the contain=ent isolation modification discussed under sub-paragkaph 2. For those 1:e=s of the August 9,1979 Order which required " reasonable progress" :owards completion, Met-Ed believes that reasonable progress has been - i made, and will continue to be =ade, on all of the=. Many of the 1: ens which are i in the " reasonable progress" category as defined in the August 9. Order will be ce=plete prior to criticality. ' Our evaluation includes the following August 9,1979 Order Ite: S considerations of which the Staff has been =ade aware:

1. NUREG 0578 Items 2.1.3.b - Me:-Ed has taken the position that the l

saturation meter proposed by Met-Ed along with the availability of readou:s fro = the in-core thermoccuples provide suf ficient indica-l tion of inadequate core cooling. Further, a reactor vessel level i instrument that will reliably provide necessary information is not now available. Therefore, proposed design information on the latter ! could not be provided. We are continuing to participate in industry i efforts on this ite . 

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ATTACICIENT 2 Page 2

2. NUREG 0578 Item 2.1.4 - Met-Ed has proposed bnplementation of diverse isolation of reactor coolant pump services on high-high containment building pressure or on detection of rupture in the cooling service lines. The completion of the rupture detection isolation system with safety grade components is dependent ?t this time on qualified material delivery dates which are projected f or the latter part of 1981. Efforts to expedite delivery are under way.

2(b) When can Met-Ed expect to be in compliance with the items relating to near term operating licenses cont.ined in NUREG-0694, "TMI-Related Requirements for New Operating Licenses" (NTOL) as revised by NUREG-0737, 

        " Clarification of TMI Action Plan Requirements";

The schedule for criticality based on the requirements of NUREG-0694, "TMI Related Requirements for New operating Licenses" as revised by NUREG-0737, 

 " Clarification of TMI Action Plan Requirements" is very uncertain and highly dependent upon clarification of NRC interpretations of the applicability of the requirements.      Accepting literally the requirements of NUREG-0694, as modified by NUREG-0737 (Enclosure 2 schedule and scope), that all of the actions required of NTOL's prior to fuel load or full power would be required of TMI-l prior to restart, the schedule for criticality would stretch into late 1982. Among the pacing items, the fully safety grade upgrade of the emergency f eedwater system would likely not be completed until the second half of 1932 (Ite     II.E.1.1). Similarly, long lead time modifications to the control room ventilation system that =ay be required as a result of current evaluations performed for Item III.D.3.4 could probably not be            -

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Fage 3 ATTACH'd.ENT 2 co=pleted until well into 1982. There are a number of other items that would i be required by the literal interpretation of the NTOL items, and which are not required for operating reactors on the .-ame schedule, that would in all likeli-hood extend the schedule past the anticipated October 1931 cri:icali:y. However, as we understand the Staff's proposal on restart requirements as contained in the November 25, 1980 letter from D. Eisenhut to R. C. Arnold and as listed by D. Ross in testimony prefiled in response to a question by the TMI-l ASL3 (Scard Question 2), not all of the short-ter: NTOL requirements would have to be met prior to restar:. Specifically, implecenta: ion of a fully saf e:y grade emergency f eedwa:er system and modifications resulting ' from the human factors review of control roo design would be required on the sa e schedule as o:her operating reac: ors. On this basis :here would still remain, however, three potentially significant i= pacts from items of these lists.

1. Ice: I. A.l.3 - Shif t Manning - Met-Ed 's current progra: for training and testing will provide the desired number of licensed operators by the planned October criticality assuming our past experience with our operators success-fully passing NRC licensing examinations and no more than the normal expec:ed attrition rate from licensed personnel leaving the company. With a higher than nor=al f ailure or i

attrition . rate, full conf or=ance with this item before the 7/1/82 date required of other operating reactors may not be feasible. A portion of the uncertainty results from ! the 100% NRC recertification of all TMI-l licensed personnel which is well beyond the requirement? of 10 CFR 55. 9 

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ATTACHMENT 2 Page 4 1 2. Item I.C.8 - Pilot Monitoring of Selected Emergency Procedures for NTOL Applicants - Met-Ed has received a recent (2/6/81) expansion of Staff requirements to provide backup analysis and guidelines for the specific events in the program beyond those presently available fro: :he NSSS vendor. The full i= pact of f i this request is still under detailed review, but should substantive revised procedural or training requirements be imposed by :he Staff, implementation during the period i= mediately preceding heatup or cri:icality will likely cause day for day delays. The program previously contemplated by Met-Ed to upgrade pro-cedures was proposed in response to the August 9,1979, Order Item 8, NUREG 0737 Ite= 0.1. 9.c. which was a long-term require =en and as to which the --Staff found that Met-Ed has 

           =ade "satisf ac tory progreca" (NUREG-06SO, pg. CS-49) .

3. I:en I.D.1 - Control Room Human Factors Review - Met-Ed has cc pleted an extensive evaluation of the TMI-l Control Room. The Staff has also performed an evaluation. Me:-Ed has pro-posed to implement the majority of items reco== ended by both studies, a significant =ajori:y of which will be completed . prior to criticality. There are a limited number of issues, however , ' tha t the Staff has proposed as conditions for restart which, if . required, could delay criticali:y. The final deter =ination of the extent of delay is no: now possible. b'

ATTACHMENT 2 Page 5 i 2(c) When can Met-Ed expect to be in compliance with any other ites which the parties believe Me:ropolitan Edison should be required to i=plement. In addition to : hose ite=s which are associated with the original NRC Orders and the requirements for NTOL plants, there are several other sources of items which have a direct bearing on the ability to meet an anticipated October 1981 criticality. There are a significant number of items contained in NUREG-0737 which are dated requirements for all operating reactors and NT0L's. As noted in prior paragraphs, :here are some ite=s, namely reactor vessel water level and contain=ent isolation, where mee:ing NUREG-0737 L:ple=entation dates may 4 not be possible. At present there are no other significant restraints for the additional items due before the anticipated October cri:icali:y. Many items unrelated to the TM!-2 accident and outside the scope of the TMI-l res: art hearing have continued to be developed by the 5:af f through both NRR and ISE activities. Several of these items have :he potential to

delay restart if tsposed as prerequisites for startup. The potentially delaying items include resolution of the need for surveillance inspection i
                                                                ~

of reac:or in:ernal vent valves, resolution of containment spray syste= perfor=ance characteristics, satisfaction of the short-ters require =ents of IE Bulletin 79-013 (Environ = ental cualification of Equipment), completed evaluations of seismic hangers (IES 79-14), and fire protection modifications to meet Appendix R if schedule . variances allowed by Appendix R are not granted. We believe : hat adequate progress can be =ade on each of these items by October 1981 to support res: art of the plant. The many remaining items covered by other regulations, letters, bulletins, or inspections while 

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c ATTACIC4ENT 2 Page 6 i requiring dedication of resources, do no: appear to directly jeopardize an October restar:. The intervenors in the TMI-l restar proceeding have proposed a very wide i range of items that they feel are prerequisites f or restart. The impact of 1 these items varies frc= none for those i:ess already accomplished (such as 4 perfor=ance of an ICS FMEA, installation of hydrogen recombiner capable of I' handling R.G.1.7 hydrogen sources, and certain improvements to Met-Ed's on-i site e=ergency preparedness) to indefinite delay for items that may not be possible or practical. for existing opera:ing reactors (such as saf ety grade t reac:or coolant pumps, filtered-vented containnent, high pressure decay heat re= oval systems). Both Met-Ed and the 5:af f have opposed these requirements as unnecessary, and Met-Ed has not prepared an engineering estimate of the delays involved should the requirements be inposed on TMI-1. One additional ites that could poten:ially delay criticality beyond October that is also beyond Me:-Ed's control is the requirement that FEMA l certification be obtained for the Co=monwealth of Pennsylvania and local I county emergency planning capabilities. I t P 

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