ML20005A493

Forwards ACRS 810609 Ltr Re Instrumentation for Detection of Inadequate Core Cooling.Certificate of Svc Encl.Related Correspondence

ML20005A493
Person / Time
Site:	Three Mile Island
Issue date:	06/19/1981
From:	Baxter T METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Jordan W, Little L, Smith I Atomic Safety and Licensing Board Panel
References
NUDOCS 8106300393
Download: ML20005A493 (4)

Text

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Ivan W. Smith, Esquire Chairman Dr. Walter H. Jord Q u f(N Atomic Safety and Licensing Atomic Safety and Licensing Board Board Panel U.S. Nuclear Regulatory Cominission 881 West Outer Drive Washington, D.C. 20555 Oak Ridge, Tennessee 37830 Dr. Linda W. Little Atomic Safety and Licensing Board Panel 5000 Hermitage Drive Raleigh, Ncrth Carolina 27612 In the Matter of Metropolitan Edison Company (Three Mile Island Nuclear Station, Unit No. 1)

Docket No. 50-289 (Restart)

Administrative Judges Smith, Jordan and.Little:

Please find enclosed, for your information, a copy of a letter, dated June 9, 1981, from the Advisory Committee on Reactor Safeguards to the NRC Staff (with an attached letter from the Franklin Research Center) on the subject "Instrumen-tation for Detection of Inadequate Core Cooling."

Respectfully submitted, l Thomas A. Baxte j Counsel for Licensee Enclosure fp j g cc: per Certificate of Service  ;

8106300393 g P00R ORIGINAL.

LIC 6/19/81 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION, BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-789

) (Restart (Three Mile Island Nuclear )

Station, Unit No. 1) )

CERTIFICATE OF SERVICE I hereby certify that copies of the foregoing letter to the Atomic Safety and Licensing Board with attachment were

' served this 19th day of June, 1981 by deposit in the U.S.

mail, fir:st class, postage prepaid, to the parties identified on the attached Service List.

Thomas A. Baxter

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

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METROPOLITAN EDISON COMPANY ) Docket No. 50-289

) (Restart)

(Three Mile Island Nuclear )

Station, Unit No. 1) )

SERVICE LIST Ivan W. Smith, Esquire John A. Ierin, Esquire  !

mairman Assistant Counsel Atmic Safety and Licensing Pennsylvania Public Utility Ccmnission Board P.O. Box 3265 U.S. Nuclear Regulatory Ccmnission Harriahurg, Pennsylvania 17120 Washington, D.C. 20555 Karin W. Carter, Esquire Dr. Walter H. Jordan Robert Adler, Esquire Atomic Safety and Licensing Assistant Attorney General Board Panel 505 h tive House 881 West Outer Drive P.O. Box 2357 Oak Ridge, Tennessee 37830 Farr4ahurg, Pennsylvania 17120 Dr. Linda W. Little John E. Minnich Atmic Safety and Licensing Chaiman, Dauphin Cbunty Board Board Panel of Ccmnissioners 5000 Hemitage Drive Datphin County Courthouse Raleigh, North camlina 27612 Front and Market Streets Harrichgg, Pennsylvania 17101 James R. Tourtellotte, Esquire Offim of the NRive Iagal Director Walter W. Cohen, Esquire U.S. Nuclear Regulatory reianinn Omsuner Advocate Washington, O.C. 20555 Office of Consumer Advocate 1425 Strawberry Square Docketing and Service Section Harriahurg, Pennsylvania 17127 i Office of the Secretary l U.S. Nuclear Regulatory Ccmnission Weshington, D.C. 20555 l

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~2-Jordan D. Cunningham, Es @ Ibbert Q. Pollard 2320 North Second Street 609 Mantpelier Street Harrisburg, Pennsylvania 17110 Baltinore, Maryland 21218 Ms. Iouise Bradford Chauncey Kepford mI AIERr Judith H. Johnsrud 315 Peffer Street Envirornental rnalition cn Nuclear Power Ha @ hurg, Pennsylvania 17102 433 Orlando Avenue State College, Pennsylvania 16801 Ellyn R. Weiss, Esquire Harmon & Weiss Marvin I. Iewis 1725 Eye Street, N.W., Suite 506 6504 Bradford Terrace Washington, D.C. 20006 ?biladal ttia, Pennsylvania 19149 Steven C. Sholly Marjorie M. Aamodt Uniat of Concerned Scientists R. D. 5 1725 Eye Street, N.W., Suite 601 Coatesville, Pennsylvania 19320 Washingtcm, D.C. 20006 2 ntas J. Ger. tine, Esquire Gail Bradford Deputy Attorney General ANGRY Division of Iaw - Pocm 316 245 West Pb41ada11 tda Street 1100 Raymond Boulevard York, Pennsylvania 17404 Newark, New Jersey 07102 William S. Jordan, III, Esquire Harnon & Weiss -

1725 Eye Street, N.W., Suite 506

• Washington, D.C. 20006 1

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NUCLEAR REGULATORY COMMISSION

• t, ADVISORY COMMITTEE ON REACTOR SAFEGUARDS gv f[ WASHINGTON D. C.20555 June 9,1981 Mr. William J. Oircks Executive Director for Operations U. S. Nuclear Regulatory Comission Washington, D. C. 20555

SUBJECT:

INSTRUMENTATION FOR DETECTION OF INADEQUATE CORE COOLING As the result of recent discussions with the NRC Staff regarding the posi-tion taken on Instrumentation for Detection of Inadequate Core Cooling 1.7

' Section II.F.2 of NUREG-0737, we have several issues which we would like to discuss further with the Staff.

First, we would like to know the extent to which the Staff has examined a spectrum of transient and accident scenarios to detennine what information an ope'rator needs in order to recover from an incident successfully. Illus-trative examples of the questions we believe should be addressed are the following:

(1) What are the conditions unuer which a level indication would be needed?

(2) What system conditisns are to be evaluated by its use? For example, are void fonnation, coolant depletion rate, and/or adequacy of core ccoling to be indicated?

i (3) Are there operational anomalies or transients under which a level indicator might give the operator information itkely to 3 produce an erroneous conclusion which could lead to operator I action that would increase risk?

Second, we have questions about the wisdont of installing e .'lipment on a schedule which provides for little or no testing under actual operating conditions. Illustrative of some of the questions which arise are those contained in a letter to the Committee from Dr. Zenons Zudans, an ACRS consul tant. A copy of his letter is attached.

In light of these questions we have some concern about a schedule which calls for installation of a level indication system before any significant demonstration of its capability or reliability has occurred.

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• Mr. William J. Of rcks June 9, 1981 We would like to discuss this subjct with appropriate members of the NRC Staff at an early meeting of the ACRS.

Sincerely, J. Carson Mark Chairman

Enclosure:

6/1/81 ltr to W. Kerr, ACRS, from Z. Zudans, re. Mtg. on Electric Systems Subcommittee on Core Water Level Measuring Devices, 5/28/81 O

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' 3 N Franklin Research Center A Division of The Franklin institute Juhe 1, 1981 Professor W. Kerr, Chairman ACRS Subcommittee on the Electrical Systems Departnent of Nuclear Engineeriitg

• Phoenix Lab-North Campus University of Michigan Ann Arbor, riichigan 48109 re: Meeting on the Electric Systems Subcom=ittee on Core Water Level Measuring Devices, 28 May,1981. Washington, D.C.

Dear Professor Kerr:

NRC's plan to review individual systems proposed for Reactor Versei Leve.1 Indicating Systa=s (RVLIS) and to generate SER's (by Decmeber 1,1981) for such systems is a good plan to start with. However, I do not think that it is possible to generate a meaningful SER on the basis of currently available licensee

( submitedis or even on the basis of the responses (due by Septe=be.r 1,1981) to be received on steff questions and positions. The problem is - there is no

, completely validated RVLIS systa= available as of now.

NRC, CE and y, indicate, that LP and HJTC syste=s are preven technologically, but clearly significant amount of additional perfor:ance testing and qualification is PWR in required before either of these two systems are proven to be able to operate environment, survive IDCA and provide meaningful signal after LOCA (LP type systems are used for pressurizer water level indication).

CE presentation on ICC (which CE calls IAOPICCI!) displayed a systematic approach to the entire problem addressing requirements, discussion of ICC param-eters, instrumentation training and projected display system including the operator and new guidelines. The CE proposed system is potentially able to identify to the trends, identification if notonset, of ICC the actual absolute values, of parameters pertinent progress and recovery. Proof of principle and design development testing of CE system is complete and prototype tests scheduled to be completed by the end of 1981. In spitsi of Dr. Bailey's (EPRI) negative comments (severe materials problems for C-E probes above 200 psia) . I believe C-E system represents a workable alternative. I do not believe, however, that it is the rad prudent to install any environmental hardware prior to the prototype test completion qualification.

P00R ORIGINAL

June 1, 1981

., Professor W. Kerr University of Michigan

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From the presentations (CE and others) it is not clear that the impact of the Commissioner's Memorandus and Order CLI-80-21 May 23, 1980, has been evaluated on the completion dates proposed. CLI-80-21 requires that safety related equipment installed *in cli NPP shall be qualified in accordance with the DOR Cuidelines or NURIG-0588 (in sum equivalent to IIII-323,1974) by Jur..a 30, 1962 (Mr. Vincent Thomas, I&E).,

Westinghouse has performed analysis of certain transients and evaluated the (calculated) indication of 6F system. It appears that W has a good understandies of the shortcomings of AP system. Advantage of AP system over HJTC is its ability to indicate reactor vessel water level over its entire range. This indication, houever, requires special calibration for each of the various oper-ating conditions because AP measures the differential pressure between two points in the primary system. This AP is made up of contributions due to the hydrostatie head, head losses due to friction (with flow) and transient decom-pression/ compression locally due to blowdown expansion. In the pressurizer there is normally no flow, hence indication of level can be better calibrated. In general, however, AP will give a reasonable gross indication of mass inventory in the vessel, no pumps running, and mass inventory in the vessel and in the primary coolant system if RCP are running.

With respect to the actual hardware to =ake up a AP system, sensors, hydraulie isolators and 400 feet long capillary tubing may contain modes of f ailure not as yet carefully evaluated. It is advisable to identify such redes of failure and assess the performance of degraded 6P system and its effect on the rest of the plant. Then it is necessary that LP prototypical hardware be environmentally qualified for PWR operating conditions prior to installing it in a NPP.

In conclusion I wish to point out that there is no need for any hysteria in this matter. NPP have instrumentation for most of the ICC (except for an unanbiguous indication of reactor vessel water level). This instrumentation has been improved lately (post TMI-2), operators have been restrained to cope with ICC better: hardly a need to coc= nit to the installation of unproven hardware at this time. ,

very truly yours, UY %Y f

Zenons Zudans ces enior Vice President cc: R. Savio. ACRS P00R ORIGINAL "e - - g - r