ML20084P072
| ML20084P072 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 05/16/1984 |
| From: | Baxter T METROPOLITAN EDISON CO., SHAW, PITTMAN, POTTS & TROWBRIDGE |
| To: | Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8405170396 | |
| Download: ML20084P072 (46) | |
Text
-
Nk May 16, 1984 OfETED UNITED STATES OF AMERICA f 7 AIO 63 NUCLEAR REGULATORY COMMISSION __
BEFORE THE DIRECTOR OR NUCLEAR REACTOR REGULATION . l l
l In the Matter of )
)
GPU NUCLEAR CORPORATION ) Docket lio. 50-289 ,-
(Three Mile Island Nuclear )
Station, Unit No. 1) ) 1 LICENSEE'S AMENDED RESPONSE TO UNION OF CONCERNED SCIENTISTS' PETITION FOR SHOW CAUSE CONCERNING TMI-l EMERGENCY FEEDWATER SYSTEM ,
On January 20, 1984, the Union of Concerned Scientists filed a Petition for Show Cause Concerning TMI-l Emergency Feedwater System. Licensee filed its response to the UCS peti-tion on February 24, 1984, and subsequently filed amended re-sponses on March 26 and April 26, 1984. This third amendment is necessary to reflect additional factual developments which have occurred since the last amendment.
In its discussion of the seismic capability of the EFW system, UCS claimed that, due to the release of steam into the Intermediate Building resulting from the failure of the non-seismic vent stacks for the main steam and atmospheric dump valves, the operator would be unable to perform certain func-tions in the event of an EFW system malfunction. Licensee has determined that it will be able to install, prior to restart, seismic I supports for these vent stacks, in order to assure their structural integrity during a seismic event. Licensee 8@5170396 840516 PM ADOCK 05000299 0 PDR .
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will also, prior to restart, upgrade the supports for the EFW recirculation line to Seismic I. These modifications had pre-viously been scheduled to be completed during the Cycle 6 refueling outage, as discussed in Licensee's letter of August 23, 1983 (Reference 2 to the Technical Response).
A revised version of the "GPU Nuclear Technical Response to Union of Concerned Scientists' Petition for Show Cause Con-cerning TMI-l Emergency Feedwater System" incorporating a dis-cussion of the above-described modifications is enclosed.
These and other revisions are indicated by revision bars in the right-hand margin.
Finally, attached hereto is a copy of a letter dated May 10, 1984 from R. F. Wilson to D. G. Eisenhut, which responds to the Staff's May 3, 1984 request for additional information re-garding the environmental qualification of the EFW system and which also responds to three questions posed by UCS in its let-ter of February 13, 1984.
Respectfully submitted, Thomas A. Baxter, P.'C.
SHAW, PITTMAN, POTTS & TROWBRIDGE 1800 M Street, NW Washington, DC 20036 Counsel for Licensee Dated: May 16, 1984 I
i 1
. e NUOIMf GPU Nuclear Corporation loo lnterpace Parkway Parsippany.New Jersey 07054-114S (201)263-6500 TELEX 136-482 Writer's Direct Dial Number:
May 10, 1984 5211-84-2114 RFW-0120 Office of Nuclear Reactor Regulation Attn: D. G. Eisenhut, Director Division of Licensing U.S. Nuclear Regulatory Commission Washington, D. C. 20555
Dear Sir:
Three Mile Island Nuclear Station Unit 1 (TMI-1)
Operating License No. DPR 50 Docket No. 50-289 EFW System Environmental Qualification Your letter of May 3,1984 requested that GPUN provide (a) information to assist the NRC staff to respond to a February 13, 1984 letter forwarded to the Commission by the Union of Concerned Scientists (UCS) and (b) responses to the NRC Staff's questions relative to the UCS 2.206 petition. Enclosure 1 entitled "EFW System -
Safety Grade" discusses our response to the three questions posed in UCS letter dated February 13, 1984. Enclosure 2 entitled "EFW System - Environmental Qualification" discusses EFW system and related equipment in a harsh environment which is qualified or exempted and responds to questions concerning specific EFW System components.
cerely,
\E lt. F. Wi son
.=
Vice President-Technical Functions RFW/mt:04899 Sworn and subscribed to before me this /n N day of /h, / , 1984
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R. Conte l J. F. Stolz i
Enclosure:
- 1) EFW System - Safety Grade
- 2) EFW System - Environmental Qualification i
GPU Nuclear Corporation is a subsidiary of General Public Utilities Corporation
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Enclosure 1
{
! EFW System - Safety Grade l Response to UCS Letter of February 13, 1984
{ l. Identify each specific aspect of the TMI-l EFW system which does not !
l comply or is not known to comply with the regulations applicable to sys-tems important to safety (including safety-grade, safety-related, and 4
engineered safety feature systems).
i ,
Response: The EFW System complies with federal regulations as they apply to
! TMI-1. At the time of Licensing of TMI-l the Emergency Feedwater {-}
System complied with all applicable regulations and standards which
! existed at the time for the EFW System. Since the accident at TMI-2, increased focus has been placed on the Emergency Feedwater System as described in IE Bulletin 79-05 (Series) and NUREG-0737.
The EFW System at TMI-1 has also been the subject of extensive <
! review as part of the ASLB hearing and review before the ALAB. The
- ASLB found in its PID that the short-term actions recomended in l the Commission's Order and Notice of Hearing to improve the time-
! liness and reliability of the TMI-l emergency feedwater system are
! necessary and sufficient to provide reasonable assurance that the facility can be operated safely in the interim until the system is i made safety grade. Attached is a list of modifications which are i planned for the Cycle 6 refueling which will make the EFW System
- safety grade. This list was presented to the Staff in our meeting 3
in Bethesda on April 28, 1984.
] 2. For each deficiency or potential deficiency identified in response to 1 item 1 above, explain whether and why GPUN believes that TMI-1 can be ;
l operated without undue risk to public health and safety before correction
- of the deficiency or potential deficiency.
Response: There are no deficiencies in the EFW System in complying with regulations as they apply to TMI-1. Nevertheless, GPUN has com-
- mitted to upgrade the EFW System to safety grade. Below is a list of modifications planned for Cycle 6 and compensating measures to be i taken until these modifications are complete. Therefore, GPUN i believes that TMI-1 can be operated without undue risk to public
! health and safety as presently configured.
I I Long Term Items Measures i
l 1) Redundant Safety Grade The arrangement at restart of the EFV-30A/B control EFW Control & Block valves is not single failure proof but has the
. Valves valve fail open on loss of instrument air and loss '
! of control signal. Additionally, the EFW control i
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i l valves are equipped with a handwheel which pernits l manual operator action to establish flow to the
- . intact steam generator. When there is an initia-i tionstationed be of the EFW system, at the control anvalve.
auxiliarySee (operator TMI-l will
! Abnormal Transient Procedure 1210-10.) The auxi-11ary operator will establish communications with 4
- thecontrolroomandwillcontrolthevalvesifEFW*j' i flow cannot be established from the control room. b.
! The Appeal Board found itself "... satisfied with i the plant procedures for manual control of the EFW t i flow control valves." ALAB-729, 17 NRC 814, 833 -
j (1983). TheEFV-30swillbeenvironmentallyquali-dg
- fied under 10CFR50.49 by restart. i 1
- 2) Safety Grade Initiation This pending modification provides further j on 4 PSIG Containment enhancement of the system in the event of a steam ,
! Isolation line/feedwater line break. Currently, action is '
i manually initiated by the operator. Dependence on l the operator will not result in core uncovery. (
1 '
! 3) Safety Grade Hi OTSG Procedural guidance (ATP 1210-1) currently directs i 4
Level (MFWIsolation) the operator to isolate main feedwater based on and Low Level (EFW high OTSG 1evel. Also procedural guidance (ATP j Initiation) 1210-4) directs the operator to manually initiate i EFW on low OTSG 1evel. OTSG 1evel is safety grade.
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- 4) Safety Grade MSLRDS The Main Steam Line Rupture Detection System (MSLRDS) signals to the EFW control valves, j EF-V30A/8, have been deleted to preclude the pos-sibility of unnecessary isolation of emergency feedwater under single failure conditions. In !
addition, a cavitating venturi installed for each -
EFW line will limit flow to a ruptured steam 1
generator to minimize the potential of containment [
i overpressurization (or steam generator overfill :
condition), and will also ensure sufficient EFW flow to the intact steam generator. The MSLRDS is i
! considered to be adequate from a single failure t i standpoint--that is, a single active failure ;
i as a pressure switch, solenoid, control relay, 125V (such ,
i DC power source) will not prevent isolation of ,
I feedwater. Additionally, a single active failure ,
i i
will not result in inadvertent isolation of feed-water. The MSLROS is seismic Class I inside i containment. Following a main steam line break in ;
i the reactor building, the system will function to
! isolate feedwater from the affected steam generator i l since qualified pressure switches (for MSLRD) are >
l to be installed in June, 1984 and will be suitable ,
! -t i
for the accident environment. While electrical separation between the redundant circuits is not maintained outside containment (sinco a few of them runinthesametrays/ conduits),electricalsepara-tion outside containment is not required for a main steam line break inside containment, The MSLRDS, therefore, is adequate for operation until the i safety grade modification is installed.
- 5) Safety Grade Lo Lo Level By letter dated February 4,1983(83-Os0)GPUN Alarm in Control Room provided a failure modes analysis for thu for each CST existing control grade instrument. Only in the 3 4
event of a sensing lino crimp (due to thn trans- j mitter falling) would the transmitter continue te read a static level. However tho operator would note that no drawdown is indicated and investigate the problem. It is not credf ele to assume that each transmitter for each CST would fall in this manner. Therefore at least one transmittt;r is expectedtobeavaIlable.
- 6) Safety Grade Power to Although THI-I does not have a second it.olation C0-Villa /B and upgrade valve between S!/S!!! piping to the conNnser hot Cable routing for well for each line, the condensata storace system CO-V14Ai,8 is single failure proof. Tnere.are uo tendonsato storage tanks (CST) and Technical !pecifle.ations water inventory in either tank is sufficient iwr safe shutdown. The connon cross connect between the two condensate pipes (containtny C0~VI.tA/0) has two isolation valves (C0-V111A/8) and c,losure of eithervalve(C0-V111A/8)willrmsureintegrityof one CST inventory if one of the Co-V14A/8 cannot be closed.
All of the valves involor. (C0 '<14A/8 8 CO-V111A/8) are Seismic ! and by the end of Cycle 6 refueling outage their cable routing (C0-V14A/B and CO-V11A/8)andpowersuppl1es(C0V111A/8)will also be Seismic !. In the interim, manual operator action will ensure proper operatinn following a l seismic event.
The TMI-1 Emerge cy Precedu,Je for Earthquake
- (1202-30) and re ennt Alara Hesponse Procedures , . (
have been revised to instruct the operetne to. C ' .
Isolate the damaged f,ondensate Storage tank.from ;
I' the EFW system by cler.ing valves CO-V14A/it ac l C0-V111A/8whentanklevelhasreachedtheTo$ ff.
Spec. Ilmit fo)10 wing E/' A actuation, sedhe fol- , ,
lowing any recognigable seismic event (3 sefenit instrumentation alarm is available in the control room). ,
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- 7) OverSpehdTripAlarm This indication wilt provido additional diagnostic in the CR For Turbino information in the control room as to why this EFW EFW Pump pump was unavailable. No specific regulatory requirement addresses this feature.
- 8) Safety Grode' Auto Currently the operator uses safety grado OTSG Contro) Independent of level independent of ICS to manually control '
ICS for OTSG Level EFW and hence level in the OTSG. This modification !
' ' will enhance the operation of tho EFW system.
()
The relationship between the EFW system and the ICS was considered extrmively in the TMI-1 Restart ,
proceeding. Pur.uant to Short-term actiiin 1(b) of /
the Commission's August 9, 1979 Ordsr and Notice of V Hearing in that oroceeding, Licensee has imple-mented automath initiation of the EFW oumps independent of the ICS and, further, has provided separa'e manual EFW flow control capability in the control roem, which will allow the operators to mytually contro) EFW flow to the steam generators t
in the event af on ICS malfunction. The Licensing Board examined '6fils issueAnd required no further modifications, finding that the actions taken
/ provided a significant improvement in safety.
, LBP 81-59,14 MC 1211, W85-86 (Paragraph 002),
1J62(Paragraph 1031)(1981). The Appeal Board
. also eval'jated the matter and cor.sidered "...the concerns regarding dependence on the-ICS for con-
/ trol of emergency feedwater to te resolved."
e
,ALA8-729,17 MC 814, 83J 34(1983).
- 3. For pach deficiency >or potential deficiency which GPUN believes need not i be conected before the first refueling outay af ter restart, explain why that deficienry ever needs to be corrected. In oth6e words, if GPUN bcIleves ttut, t.he plant can be operated without undue risk to public
,e health and safety until the first refueling, why would modifications ho t
needed to assure public health and safety after the first refueling? .
Response s
- The heart of the UCS complaint is nnt with the improvements yet to be made 1.0 i ,! the TMl 1 EFW system, but with the schedule for implementing those modifica-
, , tions. It ap) oars to be the UCS position here, as it was in the TMI 1' Restart
/ , wreceeding, t1st whenever a safety improvement is endorsed as worthwkW,Tiii"
' g plent by definition is not safe to operate until the improvement is imple mented. In short, UCS rejects the concept, endorsed by the MC and nivfrntog '
courts, that backfitting safety improvements to operating plants invoW'.,(he exercise of judgment and may be accomplished in a phased manner over tfrw. , ,
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+ The Commission's backfit regulation, 10 CFR Subchapter 50,109(a), provides that "(t)he Commission may ... require the backfitting of a facility if it finds that such action will provide substantial, additional protection which is required for the public health and safety or the common defense and secu-rity." In promulgating that regulation, the Commission stated that: "the rapid changes in technology in the field of atomic energy result in the con-tinua.1 development of new or improved features designed to improve the safety 't of production and utilization facilities." 35 Fed. Reg. 5317 (1970).
Taking 1 steps to improve safety does not mean, however, that a facility is unsafe (,/
without the improvements. In applying the backfit rule, the Director pre- l viously had held that a decision to retrofit an existing facility does not I necessarily imply that it is unsafe, but rather that substantial benefits to i the public health and safety can be attained. In the Matter of Petition (j, i
Requesting Seismic Reanalysis, 00-00-1, 11 NRC 153, 166 (1980). j l
The UCS concept of the appropriate standard for deciding whether and when to !
require modifications at operating plants was rejected by both the Licensing and Appeal Boards in the TMI-l Restart proceeding. ALAB-729, 17 NRC 814, ;
827-28(1983)
' For the modificatio's n listed in Attachment 1 of this enclosure (attached) compensating measures exist as discussed above. This will increase the reli-ability of the system which has already been determined to be sufficient for restart. That time period of one cycle is the shortest reasonable time. period for modification of this complexity. Areas where compensating activities apply for the EFW system include principally seismic events, main steam line break and main feedwater line break. The probability of these events occurring in the given cycle is low for the magnitudes in the design basis accidents based on review of historical data and piping stress as indicated in our response of February 24, March 26 and April 26, 1984. In conclusion GPUN strongly believes.(coincident with findines by NRC staff ASLB and ALAB) that
- the Emergency.Feedwater System as configured at restart can be operated i without undue t-isk to public health and safety and can be operated safely until the'first refueling after restart.
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Enclosure 1 Attachment 1 EFW LONG TERM UPGRADE MODIFICATIONS MECHANICAL / STRUCTURAL
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4 e ADO REDUNDANT SAFETY GRADE EFW CONTROL AND BLOCK VALVES vi )
EFW IIEAT SINK PROTECTION SYSTEM .
e PROVIDE SAFETY GRADE EFW INITIATION ON 4 PSIG CONTAINMENT ISOLATION SIGNAL .
e PROVIDE SAFETY GRADE OTSG LEVEL INSTRUMENTATION AND SIGNALS .
FOR MFW OTSG HIGH WATER LEVEL ISOLATION AND OTSG LOW WATER LEVEL INITIATION OF THE EFW SYSTEM e PROVIDE A SAFETY GRADE AUTOMATIC CONTROL SYSTEM INDEPENDENT OF
.THE ICS THAT PERMITS THE EFW SYSTEM TO CONTROL OTSG LEVEL WITHOUT INTERACTION WITH-THE MFW SYSTEM i
e PROVIDE SAFETY GRADE MAIN STEAM RUPTURE DETECTION AND MFW ISOLATION SYSTEMS e ADD SAFETY GRADE LEVEL INDICATION AND LOW-LOW LEVEL ALARM IN THE CONTROL ROOM FOR EACH CONDENSATE STORAGE TANK EFW LONG TERM EPSI MODIFICATIONS
.ve e PROVIDE A SAFETY GRADE POWER SUPPLY TO VALVES C0-V111A/B AND UPGRADE THE CABLE ROUTING FOR POWER SUPPLY TO VALVES ' '
j CO-V14A/B TO SEISMIC CLASS I CRITERIA e PROVIDEANOVERSPEEDTRIPALARMINTHEMAINCONTROLROOMFOR!
THE TURBINE DRIVEN EFW PUMP (EF-P-1) 1 _
Enclosure 2 EFW System - Environmental Qualification In Attachment 2 to your letter of May 13, 19,84 you requested additional information related to the Environmental Qualification of the EFW system to assist you in responding to the UCS 2.206 petition of January 20, 1984.
Attachment 1 to enclosure 2 provides in tabular form a list of EFW and related 'y equipment located in a harsh environment. A number of these components have been previously identified as not requiring qualification and are summarily ,
explained. The additional items identified were audited during your visit on May 7 and 8 to GPUN corporate offices. Documentation concerning these addi-tional items were reviewed and comments were discussed.
1 Attachment 2 to enclosure 2 provide the basis for exempting the EFW and related system components in a harsh environment noted in Attachment 1.
Attachment 3 to this enclosure provides responses to questions asked about certain indications related to the EFW System in a harsh environment.
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e 4
Enclosure 2 -
Attachment 1 EFW ELECTRICAL EQUIPMENT LOCATED IN A HARSH ENVIRONMENT . .
INCLUDING ALL QUALIFIED EQUIPMENT TER Equipment Manufacturer Model Tag No(s). Item No. Qualification Status Motorized Valve Limitorque SMB-0 EF-V2A&B 11 Qualified based upon Limitorque Reports 80058 "
Actuators and B0027. [r Motorized Valve Limitorque SMB-000 EF-VlA&B 15 Qualified based upon Limitorque Reports B0058 [
and B0027. [!.
Pump Motors Westinghouse HP 450 EF-P2A&B 51 Qualified based upon Westinghouse Report WCAP
7829 (Written vendor confirmation in process),
GPUN calculation 1101x-5350-020 for the motor 1 bearings, and TMI-l Procedure 1420-Y-15 for i splices.
Cable Instru- Continental Silicon 107 Qualified based upon GPUN calculation 110lX- .
ment Wire & Cable Rubber 5350-70 and Anaconda letter of 2/15/84.
Co. Insulation '
i=
Cable, Power Kerite 106 Qualified based upon FRC reports. Submergence ^
& Control qualification verification ongoing based upon {
Kerite generic tests described in Kerite letter F of 5/4/84. L Diodes Square D JTXIN6071A Replaced No longer required. Diodes are used as suppres-sion devices across ASCO solenoid valve coils.
No ASCOs are used. ;
Terminal Block States NT 110 Qualified based upon various tests and data shown on SCEW sheet.
Flow Trans- Foxboro NE 130M FT-731, 799, None Qualified based upon Wyle Report 45592-4. ,:
mitters 782, 788 !.
E/P Converters Bailey RP-1211C SP-V5A&B 60 Replaced by I/P converters Conoflow model GT25CA1826. Qualification will be based upon Conoflow reports 3021 and 3419. '
C CM
TER -
Equipment Manufacturer Model Tag No(s). Item No. Qualification Status Limit Switches NAMC0 02400X2 LSA/MSV06 66 Associated with the turbi'ne drive EFP which does LSB/MSV-6 not require qualification. No electrical inter-connection to a functional system.
Limit Switches NAMC0 01200G2 LSA/MSV-13A&B 67 Associated with the turbine drive EFP which does LSB/MSV-13A&B not require qualification. No electrical inter-connection to a functional system.
Limit Switches Fisher LS/EFV-30A&B None These switches are electrically disconnected.
Solenoid Valves ASCO LB8201C94 SV3/EF-V-30 26 These solenoid valves are no longer installed A&B in the plant. No ASCOs are used in equipment SV4/EF-V-30A&B requiring qualification.
Solenoid Valves ASCO 8300068G SV1/EF-V-30 28 These solenoid valves are no longer installed A&B in the plant. No ASCOs are used in equipment SV2/EF-V-30A&B requiring qualification.
Solenoid Valves ASCO LB83146 SV/EF-V-8A, 31 These solenoid valves are electrically discon-
, B&C nected and locked open with a collar.
D/P Switches Barton '
277A FI-S-77, 78 77 These switches associated with EF-V-8 have been
& 79 electrically disconnected.
Cable Anaconda . FREP/CPE None Qualified based upon Anaconda Report 80282 FRC insulation Report F-C 4836-2 and Anaconda letter of 5/4/84.
Cable Boston Insu- None Qualified based upon BIW Report B 915 (written lation Wire vendor confirmation in process).
Motorized Valve ' Limitorque SMB-1 MSV-2A/B None Qualified based upon Limitorque Reports 80058 Actuator and B0027.
C C-
_._.__________________m.____________ _ --m. -- _ w _
Equipment Manufacturer Model Tag No.(s) TER Item No. Qualification Status COV-14A/B Exempted per attachment 2 COV-lllA/B Exempted per attachment,2 ASV-4 Exempted per attachment 2 EFP-1 Exempted per attachment 2 EFV-4&5 Exempted per attachment 2 MSV-4A/B Exempted per attachment 2 MSV-6 Exempted per attachment 2 MSV-1A,B,C,0 Exempted per attachment 2 MSV-10A/B Exempted per attachment 2 MSV-13A/B Exempted per attachment 2 PT 65, 71 & 75 Exempted per attachment 2
'. TE-230 Exempted per attachment 2 EFV-15A/B Exempted per attachment 2 ST-8 Exempted per attachment 2 MSV-8A/B Exempted per attachment 2 u
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+ . . - . _ - . . . . - _
i Enclosure 2 Attachment 2 i 1
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Emergency Feedwater and Related Equipment in a Hars". Environment l To Be Exempted from Qualification Under 10CFR50.49 .
.\
- l. COV-14A/B (Condenser Hotwell/ CST cross connect) have been exempted from U the master list of equipment within the scope of the EQ program based on the following [C0V-14A/B are motor operated valves which are normally open and which have indication in the Control Room.]: gi o Should COV-14A/B fail closed, there would be no effect on EFW delivery.
o Should COV-14A&B remain open following a High Energy Line Break 4
(HELB) in the Intermediate Building, delivery of condensate to the EFW pumps is ensured based on the fact that COV-12 (for COV-14A);
COV-7; COV-8; and COV-13 (for C0V-48) can be closed to maintain condensate storage tank inventory (ATP 1210-10).
- a. COV-12 (this a normally closed, motor operated valve with a 1E power supply) is located in the non-harsh environment of the Turbine Bldg. (If the valve fails open it can be manually closed locally.)
- b. COV-13 or COV-8 (C0V-13 is motor operated valve powered from a non-lE power source; C0V-8 is an electro-pneumatic level control valve with a IE DC power supply. Flow from the CST to the con-denser would cause these valves to go closed on high hotwell
- level) have handwheels for local manual closure and are located in the non-harsh environment of the Turbine Bldg.
! o No electrical failure to C0V-14A or B due to harsh environmental conditions woulo cause degradation of the lE power supply system.
o There is no electrical interconnection between C0V-14A or B and any other required system function.
o Operator action is based on CST level and is not relied upon by operators.
- 2. COV-lllA/B (CST Cross Connect) have been exen.pted from the master list of equipment within the scope of the EQ program based on the following.
[C0V-lllA&B are motor operated valves which are normally open and powered from a non-lE power source and which have indication in the Control Room.]:
o These valves are not required to change position following a HELB in ;
the Intennediate Bldg. (Closed for a seismic event.)
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i o Should either or both COV-111A or B close due to a failure, EFW delivery is not affected.
o Also, no electrical failure due to the environmental conditions would result in the valve failure in the closed position.
o No electrical failure to COV-Illa and B due to harsh environmental (j
conditions would cause degradation to the lE power supply system.
o There is no electrical interconnection between COV-lllA and B and any other required system function. ,
i o Valve position is not necessary to mitigate the event. V
- 3. ASV-4 (Aux Steam Supply Isolation) has been exempted from the master list of equipment within the scope of the EQ program based on the following.
[The ASV-4 valve is a normally closed, motor operated valve supplied with a non-1E power supply and with indication in the Control Room.]:
o Under LOCA and MSLB sufficient flow is provided to the OTSGs by a single motor driven EFW pump. (See GPUN letter dated 3/22/83). The l steam driven EFW pump is not required for accidents which produce a harsh environment in the Intermediate Building. Failure of ASV-4 in
! the open position would have no deleterious effect upon the required EFW system function.
o No electrical failure to ASV-4 due to a harsh environmental con-ditions would cause degradation to the IE power supply system.
o There is no electrical interconnection between ASV-4, and any other required system function. >
o The operator takes no action on position indication.
- 4. EFP-1 (Turbine Driven Pump) has been exempted from the master list of equipment within the scope of the EQ Program based on the following:
o EFP-1 does not contain any necessary electrical components.
- 5. EFV-4 & EFV-5 (River Water Supply) have been exempted from the master list of equipment within the scope of the EQ program based on the fol-lowing. [EF-V4 and 5 are locked closed, motor-operated valves with 1E power supplies. The breakers for these valves are locked open (operating procedure 1106-6).]:
o An emergency river water source is not required to mitigate the consequences of an HELB in the Intermediate Building.
l o With the breakers locked open, there is no position indication. ;
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- 6. MSV-4A/B (Atmospheric Dump) have been exempted from the master list of 4 equipment within the scope of the EQ Program based on the following.
[MSV-4A and B are normally closed, pneumatically operated valves, sup-plied with non-lE power to an I/P converter and with indication in the Control Room.]:
o The valves are not required to mitigate the consequences of an HELB ,.
or LOCA for hot (licensed) shutdown. I o Exposure to hart.h environmental conditions can not cause either MSV-4A and B valves to fail into the open position, o MSV-4A and B contain electric limit switches. These licit switches b provide indication in the main control room only. They have no interconnection to other system functions. Heat removal during HELB is assured using primary to secondary heat transfer which relies on instrumentation unaffected by the HELB. (See NAMC0 Limit Switch discussion in Enclosure 2, Attachment 3. of this letter.)
- 7. MSV-6 (Steam Supply to EFP-1) has been exempted from the master list of equipment within the scope of the EQ program based on the following:
o MSV-6 is a non-electric, pneumatic valve. The only electrical components associated with this valve are limit switches. (See dis-cussion of NAMC0 Limit Switches, Enclosure 2, Attachment 3 of this letter.)
- 8. MSV-lA/B/C/D (Main Steam Isolation) have been exempted from the master list of equipment within the scope of the EQ Program based on the fol-lowing. [The MSV-1A, B, C avi D valves provide main steam line isolation in the event of a steam line break and have indication in the Control Room:
o Should the MSV-1A thru D valves fail, the isolation function is achieved with the CV-1 thru 4 (turbine control valves) valves and/or SV-1 thru 4 (turbine stop valves) valves (located in a non-harsh environment).
o The MSV-1A thru D valves are stop-check valves providing an addi- -
tional assurance of main steam isolation.
o Between the MSV-1A thru D valves and the turbine control valves the following major lines may need to be isolated in the event of a steam line break to prevent blowdown of both OTSGs.
- steam supply to the main feed pumps steam supply to the turbine gland seal system.
Both of the above lines are isolatable via either local manual action (non harsh environment) or.via remote control from the control room.
l i
3 _; . . , -. : .=:....-... . .. .
.. . : - .- i o No electrical failure to the MSV-1A thru D valves due to harsh environmental conditions would cause degradation to the lE power l supply system. i o There is no electrical interconnection between the MSV-1A thru D valve and any other required system function. .
O Closure of the MSIV is based on overcooling, not valve position indication.
(j
- 9. MSV-10 A/B (Low pressure Steam Supply to EFP-1) have been exempted from the master list of equipment within the scope of the EQ Program based on ~;
the following. [MSV-10A & B are normally closed, motor operated valves, supplied with DC power and with indication in the Control Room.]:
o These valves are not required to mitigate the consequences of a LOCA or HELB in the Intermediate Building.
o No electrical failure to MSV-10A and B due to harsh environmental conditions would cause degradation to the lE power supply system.
o There is no electrical interconnection between MSV-10A and B and any othe. required system function.
o Operator action is based on overcooling considerations, not valve position indiciation.
l 10. MSV-13A/B (Steam Supply to EFP-1) have been exempted from the master list
, of equipment within the scope of the EQ Program based on the following.
! [MSV-13A and B are normally closed, solenoid operated pneumatic valves, supplied with DC power.]:
o These valves are not required to mitigate the consequences of an HELB or LOCA.
o Should the valves fail into the open position, the OTSGs could be isolated via closure of MSV-2A and B in conjunction with check valves MSV-9A and B.
o No electrical failure to MSV-13A and B due to harsh environmental conditions would cause degradation to the 1E power supply system.
o There is no electrical interconnection between MSV-13A and B and any other required system function.
o MSV-13A and B contain electric limit switches. These limit switches provide indication in the main control room only. They have no interconnection to other system functions. Heat removal during HELB is assured using primary to secondary heat transfer indication which is unaffected by the HELB. (See NAMC0 limit switch discussion in Enclosurc 2, Attachment 3 of this letter.)
f
. _ _ _ ____ _ _ _ _ _ - _ - - - i= , .-
- 11. PT-65, 71 & 75 (EFW Pumps Discharge Pressure) have been exempted from the master list of equipment within the scope of the EQ program based on the following. [PT-65, 71 & 75 monitor EFW discharge pressure. The output of these pressure transmitters is displayed in the control room, and pro-vide the operator an input relative to pump operation.]:
o These pressur2 transmitters are referenced in procedures used to mitigate the consequences of an HELB or LOCA. However, other quali- Q; fied instrumentation provided to the operator with data concerning the ope; ation of the EFW pumps are used to verify EFW flow. These other instrumentation indications are steam generator pressure and level, emergency feedwater flow, primary coolant system temperature ,
U and pressure, and incore thermocouple temperature.
- 12. TE-230 (Bearing Cooling Water Temperature for the Turbine Driven EFP) has
< been exempted from the master list of equipment within the scope of the EQ Program based on the following:
o Since EFP-1 is not required to mitigate the consequences of an HELB in the Intermediate Building and LOCA, TE-230 need not be included
- into the EQ Program. Additionally, there is not direct indication of TE-230 in the control room, rather, TE-230 is input to the plant computer data logger.
o A failure of TE-230 has no effect on DC power.
- 13. EFV-15A/B (Bearing Cooling Water Regulating valves in Supply to Turbine .
Driven EFP) have been exempted from the master list of equipment within
- the scope of the EQ Program based on the following [no indication in the Control Room]
l o EFV-15A and 8 contain no electrical components, and are therefore, not included within the scope of the EQ program.
- 14. ST-8 (EFP-1 Pump Speed) has been exempted from the master list of equipment within the scope of the EQ Program based on the following.
[ST-8 provides EFP-1 speed indication in the control room.]:
i o ST-8 indication is not called for in plant procedures and hence, the '
operators do not rely upon this instrumentation to indicate pump operation. Other qualified instrumentation are utilized to verify pump operation including EFW flow, steam generator level, reactor
- coolant system pressure and temperature and core temperature.
I o Failure of ST-8 has no effect on DC power.
- 15. MSV-8 A/B (Turbine Bypass Isolation) have been exempted from the master list of equipment within the scope of the EQ Program based on the fol-l lowing (MSV-8A/B are normally open motor operated valves supplied with IE l power with indication in the Control Room):
< - _ - _ - - _ . - - _ - ~ - . _ . _ . -
..: _ a .: = . - - ---- :g-l l
o MSV-8A/B are not required to mitigate the consequences of an HELB in the Intermediate Building.
o Should MSV-8A/B be needed to close to prevent blowdown of both OTSG's the MSV-3A thru F (located in a non harsh environment) provide the isolation function. ,
o No electrical failure to MSV-8A/B due to harsh environmental condi-tions would cause degradation to the lE power supply system.
o There is no electrical interconnection between MSV 8A/B and any other
("!
required system function.
o The operator does not rely on valve position for action.
For the above items, GPUN has detennined that the function is not needed for HELB (with Loss of Offsite Power) with a single active failure.
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,_ ~_ _ . _ . _ _.. __ . . - . _ . _ . _ . . _ . _.. _ _ _ . .
Enclosure 2 Attachment 3 Justification For Exempting Certain EFW System Electrical Equipment A. NAMC0 Limit Switches i V
- 1. An analysis of the effects that failure of the limit switches could have on other electrical equipment important to safety, e.g., if the switches are used in an interlock circuit for other equipment. :
L, Response: These limit switches for MS-V6 and MS-V13A&B provide indication only in the Main Control Room. They have no interconnection to other system functions.
- 2. A discussion of the emergency procedures used by the Operator, whether the operator is directed to rely on information from these limit switches for valve positions, how and when the operator will manually and "immediately" reduce overfeeding of the OTSGs in the event the limit switches on MSV-6 fail, and why qualified EFW flow and 0TSG level preclude the operator from being misled if the limit switches on MS-V13 A&B fail.
Response: The principal procedures used by the Operator in a MSLB accident are:
ATP 1210-3 Excessive Cooling ATP 1210-10 Abnormal Transient Rules Guides and Graph 0? 1106-6 Emergency Feedwater System.
These procedures require verification that 3 EFW pumps start; EFW pump discharge pressure is 1010 psig, EFW flow (if below OTSG '
level setpoint); and EFV-30's control 0TSC level at setpoint.
i The operator would follow EFW throttling criteria (of ATP 1210-10 Section 1.5) to prevent overfilling.
i 3. A discussion on the desirability of the operator needing to "immediately (manually)" reduce overfeeding the OTSGs because of failure of MS-V6 limit switches, and the desirability of relief valves lifting because of MS-V13A&B limit switches failing.
j Response: As discussed above the operator is observing the EFW system
- throttling criteria (not MS-V6/MS-V13 indication). As discussed in TMI-1 restart report overfeeding does not become a probTem.
(RR Supplement Part 2 Question 2) i
y.. +. s.--~-- .. a=..=-.=== -:._ = = = .
The pressure control valve (MS-V6) upstream of valves MS-V22A/B was modified to limit its travel at 65% of stroke to protect the EFW pump '
turbine from overpressurization due to the failure of any steam supply valves. This reduces the potential for opening of valves MS-V22A/B. In addition, these valves will not lift simply because the EFW turbine driven pump is started.
In our letter of 2/10/84 (5211-84-2038, Attachment II, Item I.G.1) we !, .
noted that under LOCA and MSLB sufficient flow is provided to the OTSGs by a single motor driven EFW pump. The referenced analysis (in GPUN letter dated 3/22/83) was for LOCA and LOFW (Loss of Feed-water). This analysis has been supplemented by analysis reported in (,
our letter of 12/9/83 (also for LOCA and LOFW). EFW flow require-ments for LOFW bound the flow requirements for MSLB.
B. Fisher Limit Switches
- 1. Same as 1 above for limit switches.
Response: These limit switches are not connected electrically and therefore have no electrical interconnection to system functions.
- 2. A discussion of the emergency procedures used by the operator and whether these procedures direct the operator to rely on infonnation from these limit switches. '
Response: As discussed in A 2 above the procedures listed apply. No reliance is placed on position indication of the EFV-30 valves.
These limit switches are not electrically connected. ,
C. ASCO Solenoid Valves
- 1. An analysis of the effects that failure uf the solenoid valves could have on other electrical equipment important to safety, e.g., disrup-2 tion of Class lE power on the circuit to which the solenoid valves are connected.
Response: The ASCO solenoid were once connected but now have had electrical
, leads lifted and instrument, air has been disconnected. These l modifications were performed as part of the deletion of the MSLRDS signal to the EF-V30's (no longer installed) and the removal of the EF-V8's control function. .
- 2. For TER item No. 31, formally submit on the docket the justification for qualification exemption. ,
Response: As discussed in our response to C.1, these ASCO solenoid valves should be placed in NRC category III.8 " Equipment not in the l Scope of the Review."
1
, , - . . . . - - - . . , - a ,, v,. , ~vw , , , ----------.e - -, - , . ,
l D. Barton D/P Switches ;
- 1. Address failure of these 0/P switches similar to 1. above for the l limit switches.
Response: The EF-V8 valves have had their electrical leads lifted, instrument air tagged out and a collar installed on the valve to physically prevent change in position. There is no electrical interconnection of these switches with other system functions. \J
- 2. A discussion of the emergency procedures used by the operator and whether these procedures direct the operator to rely on information :
from these D/P switches. 'd Response: Since these switches are not in operation there is no reliance in procedures on the operation of these valves (EF-V8A/8/C).
- 3. Formally submit on the docket the justification for qualification exemption.
.; Response: These flow switches are for the EFW pump recirculation lines. The EF-V8 valves is now locked open therefore these switches are not in the scope of 50.49 and should be placed in Category III.B. As dis-cussed above there is no adverse interaction with safety systems 4 and no way to mislead the operator.
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Attachment
! REVISION #3 (May 16,1984)
- GPU NUCLEAR TECHNICAL RESPONSE TO UNION OF CONCERNED SCIENTISTS' PETITION FOR
, SHOW CAUSE CONCERNING TMI-1 EMERGENCY FEEDWATER SYSTEM J
I. Introduction i.
i The UCS Petition describes what UCS alleges to be defi-l ciencies in the Emergency Feedwater (EFW) System at TMI-1 as it will be configured at the time of plant restart and throughout Cycle 5 operation. Each of the alleged deficiencies is addressed below. While the UCS Petition concentrates on per-ceived shortcomings in the EFW system, these allegations should not be weighed in a vacuum, but rather should be assessed with an understanding of the capabilities of the EFW system and the substantial improvements made to the qualification and reliability of that system since the accident at TMI-2. In brief, Licensee has already implemented the following modifica-i tions to the EFW system:
. safety-grade automatic starting of the EFW pumps;
, control of EFW independent of the ICS;
. condensate storage tank low-level alarm;
. safety-grade steam generator level indica-tions, independent of the ICS;
! . redundant two-hour air supply in the event of ,
a loss of all AC power;
. EFW flow control valves' failure mode modified to fail open on loss of instrument 4 air;
. addition of flow-limiting cavitating venturis in each EFW line; and
- , safety-grade EFW flow indication. R. 3 The additional modifications which will be undertaken dur-ing the Cycle 6 refueling outage will result in a fully safety-grade EFW system. Contrary to UCS's assertion that l
I
\
a . . - ,, - - ...a - - ,.
=
Licensee admitted, in our August 23, 1983 submittal, that the "EFW system needs to be upgraded" in order to provide increased reliability to mitigate design basis accidents (UCS Petition at 4, emphasis added), Licensee's submittal was merely noting the
" purpose" of the additional, long-term modifications. (Ref.
2.) Licensee stands by its original position that the TMI-1 EFW system is sufficiently reliable to allow operation during Cycle 5, pending completion of the long-term modifications.
II. Environmental Qualification t
UCS alleges that the TMI-1 EFW system is not environ-mentally qualified, and begins the discussion in its petition on this point with a reference to General Design Criterion 4 of Appendix A to 10 C.F.R. Part 50. As relevant background for this and other references in the UCS Petition to the General Design Criteria, the Staff's finding associated with the issu-ance of the TMI-1 operating license is quoted:
The Three Mile Island Unit 1 plant was de-signed and constructed to meet the intent of the AEC's General Design Criteria, as originally pro-posed in July 1967. Construction of the plant was i about 60% complete and the Final Safety Analysis Report (FSAR) had been filed as Amendment 12 with the Commission before publication of the revised General Design Criteria in February 1971 and the present version of the criteria in July 1971. As a result, we did not require the applicant to ,
reanalyze the plant on the basis of the revised criteria. However, our technical review did as-sess the plant against the General Design Design Criteria now in effect and we conclude that the plant design conforms to the intent of these newer criteria. (Ref. 1 at 3-1.)
With respect to safety-related electrical equipment, the 4 NRC has been pursuing environmental qualification (i.e., com-i pliance with GDC-4) on a generic basis first through IE Bulle-tin 79-01B, and now through its regulation on environmental qualification of electric equipment important to safety for nu-clear power plants, 10 C.F.R. 9 50.49, which first became effective June 30, 1982. Pursuant to section 50.49, TMI-l is to achieve final environmental qualification of the electric equipment within the scope of that section by March 31, 1985.
The EFW system has been included in the overall evaluation of TMI-1 under these generic programs.
Focusing upon a steam line break outside of containment, UCS states ". . . GPU recognizes that the TMI-1 EFW system is I
t I
not qualified for the hostile environmental conditions result-ing from a main steam line break." UCS Petition at 6. What GPU in fact stated in the reference cited by UCS, which de-scribes long-term modifications to the system, is that:
Equipment which is part of the EFW system or which is required to act in support of this system and which is located in the Intermediate. Building, shall either be upgraded to be qualified for the hostile environmental conditions resulting from a Main Steam Line Break (MSLB) in this building or be replaced with qualified equipment or be relocated to an environmentally acceptable loca-tion which is otherwise suitable for their safety function. (Ref. 2, Enclosure at 11.)
While UCS asserts that ". . . several pipes carrying steam or high temperature water are located in the Intermediate Building . . .", UCS Petition at 6, the qualification program has utilized two specific main steam line breaks (24 inch and 12 inch), which produce the most severe environment for elec-trical equipment. Other breaks in the feedwater lines produce a much less severe environment and are not the basis for quali-i fication, j The implications for the EFW system of a high energy line break in the Intermediate Building were recognized in the orig-i inal licensing of TMI-1. As a result of an analysis of the consequences of all the postulated breaks in the Intermediate i Building, utilizing criteria and guidelines provided by the Staff, corrective actions were identified. These included shielding of the EFW suction line and installation of addition- ,
4 al piping restraints to prevent pipe whip damage and the fail-
! ure of a line connected to one steam generator from causing the -
i failure of a line connected to the other steam generator. In
- addition, a significantly augmented inservice inspection of i
critical welds was instituted for the postulated break loca-tions. The Staff'c conclusion was stated as follows:
l The staff has evaluated the assessment per-l formed by the applicant and has concluded that the 1 applicant has analyzed the facilities in.a manner consistent with the criteria and guidelines pro-vided by the staff. The staff agrees with the applicant's selection of pipe failure locations
- and concludes that all required accident situa-tions have been addressed appropriately by the
- applicant. Furthermore, the staff has evaluated the locations where increased inservice inspection l
is proposed in lieu of plant modification and we find this justified and acceptable. (Ref. 1 at 4
10-7.)
l The augmented inservice inspection program for the Main Steam
! system is incorporated in the TMI-1 operating license (No. '
DPR-50, Technical Specification 4.15).
The harsh environment in the Intermediate Building follow-ing a main steam line break is being addressed in the review for TMI-1 under IE Bulletin 79-01B and_section 50.49. UCS ar-gues that the current status is not known of EFW system compo-nents for which the Technical Evaluation Report (TER) concluded that environmental qualification had not been established, and i that "it is known that many vital components in the TMI-1 EFW
- remain incapable of functioning properly during a steam line i break." UCS Petition at 7, 8.
t' As UCS and the Staff are aware, the deficiencies identi-c fied in the Franklin Research Center TER on TMI-1, dated
! November 5, 1982, were predominantly based on the uncertainty by Franklin.Research Center as to_whether Licensee had adequate documentation to demonstrate the qualification of the identi-fled equipment (although Franklin had not requested the docu-mentation). The purpose of the October 5, 1983 meeting with the Staff was not to achieve final. resolution of the TER deficiencies, as UCS implies, but to discuss Franklin's con-
- cerns. (UCS also inaccurately represents the December 16, 1983
- meeting. Licensee discussed 120 equipment deficiencies, not 120 types of equipment having deficiencies. The 120 deficiencies address the entire plant and not just the EFW sys-tem -- the focus of the UCS Petition.) There is no equipment i
at TMI-1 classified by the NRC in the category II.b, " EQUIPMENT i NOT QUALIFIED." (Ref. 3, TER at 4-3.) As discussed below, J
some equipment is classified category II.a, " EQUIPMENT QUALIFI-i CATION NOT ESTABLISHED."
While UCS may not be aware of the current statue of the.
specific components identified in its petition, Licensee docu- R.1 i
mented the resolution of cutstanding qualification items in letters to the Staff of February 10 and 22, 1984 and May 7 and II R. 3 10, 1984 (Refs. 4, 24, 27, 29) and by the Pevised Technical Re-sponse. The envircnmental qualifiestion cf the TMI-l EFW sys- '
tem under 10 C.F.R. 650.49 will .1xe completed by June, 1984,-
including replacement of the Bailey E/P Converters for the EFW
- control valves with qualified I/P Converters. (Licensee has continued to work on improving the' schedule for this modifica- R.1 tion, which had been set for the Cycle 6 refueling outage, and i; has now determined that it will be completed by-June, 1984.)
Thus, the environmental-qualification of-the'TMI-1 EFW system poses no undue risk to the public health and safety and does not provide an appropriate basis for the UCS Petition.
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III. Seismic Qualification The seismicity analysis for the licensing of TMI-1 indi-cated that the Pennsylvania area is relatively inactive seismically, based upon 200 years of historical data and 40 years of instrumental data. The TMI site is characterized by i i infrequent earthquakes of low intensity. This low intensity corresponds to_a ground acceleration of 0.04g. (Ref. 5, sec-tion 2.8.) The Seismic I_ portion of TMI-1 was designed to
- withstand a ground acceleration of 0.12g acting horizontally for the Safe Shutdown Earthquake (SSE) condition (Ref. 5, sec-f tion 5.1.2), which exceeds the 0.lg specified. ground accelera-tion of Appendix A to 10 C.F.R. Part 100. Consequently, Ole portions of the TMI-1 EFW system that are Seismic Category I .
are designed to more severe criteria than NRC regulations re- '
quire. Mechanical portions of the EFW system that are not now Seismic Category I are designed to the requirements of ANSI i B31.1, " Power Piping." Fossil power plants and conventional portions of nuclear power plants designed to this standard have exhibited significant seismic resistance. (Refs. 6, 7; Ref. 8 j at 2.)
e I
It is clear that while Staff guidance for seismic qualifi-cation of PWR auxiliary feedwater systems has been evolving over a long period of time, the evaluation to determine how to backfit seismic requirements to earlier plants has not resulted in the imposition of specific seismic requirements. (Ref. 9.)
In its information request .of February 10, 1981 (Ref. 8), the Staff stated:
Although we are not at this time requesting
- that the'AFW System be modified to be in con-
! formance vith the facility design seismic
. requirements, we have stated that our plan la j
, to increase the seismic resistance, where l necessary, to ultimately provide reasonable assurance that the system vill function after the cccurrence of earthquakes up to and
, including the SSE.
Licensee has made numerous submittals of information to the Staff, in response to Generic Letter 81-14, on_the seismic qualification of the TMI-1 EFW oystem.- The Staff's contractor, Lawrence Livermore National Laboratory (LLNL), has reviewed these responses and issued Technical Evaluation Reports dated October 29, 1982 and July 7, 1983. While-the first TER identi-
)
fled deficiencies in Licensee's responses, LLNL concluded in
-its second TER that, with the actions taken and planned by Licensee (i.e.,-the long-term-EFW modifications detailed in-
. Reference 2), the TMI-1 EFW system will be_ fully qualified to-
. Seismic Category I at the'next-refueling outage:(prior'to start
up for Cycle 6 operation). Based upon this TER and its own evaluation of Cycle 5 operation, the Staff has concluded that there is reasonable assurance that-the TMI-1 EFW system will be l able to withstand a SSE and perform its safety function. (Ref.
- 10.)
UCS challenges this conclusion, apparently, in its asser-tions that the TMI-1 EFW system is not seismically qualified and that operation of TMI-1 therefore would pose an undue risk to the health and safety of the public. As the assessment below will demonstrate, the UCS Petition is without technical merit and does not undermine the validity of the Staff's previ-ous safety evaluation.
! A major fault in the UCS Petition is the extensive refer-ence, in the present tense, to findings in the first TER issued by LLNL, while virtually ignoring the second TER. UCS Petition at 9-15 (especially the list of "many vital components in the TMI-1 EFW system which are not environmentally qualified," UCS Petition at 10-11).
In its final TER, LLNL concluded that the TMI-1 EFW system*
piping, valves, structures and power supplies possess a SSE
- level of seismic capability, and that the initiation / control system will possess such capability after the Cycle 6 refueling
- outage.
The available information, which provides reasonable as-i surance that the EFW system will perform its safety function after a SSE, and that has been ignored by the UCS Petition (at 10-11), includes:
- a. Recirculation lines of the EFW pumps. The TMI-1
, Emergency Procedure for Earthquakes (1202-30) calls for closing
, of the Condensate Storage Tank E isolation valve (CO-V-176) and the EFW pump recirculation isolation. valves (EF-V20A/B and '
EF-V22) if the EFW pump recirculation ljnes are ruptured.
- (Ref. 11, Item 1.) Licensee had criginally planned to upgrade l the supports for the EFW pump recirculation line to Seismic I R.3 during the Cycle 6 refueling outage, but has continued to work on this modification during the current shutdown. Licensee will now complete this modification prior to Restart.
- b. Portions of the EFW suction piping to the condenser hotwell, for which there are no double isolation valves between the seismic Class I piping and the non-seismic Class I piping.
l Although TMI-l does not have a second isolation-valve between l SI/SIII piping to the condenser hot well for each line, the condensate storage system is single failure proof. There are two condensate storage tanks (CST) and Technical Specifications water inventory in either tank is sufficient for safe shutdown.
The common cross connect between the two condensate pipes
J F (containing CO-V14A/B) has two isolation valves (CO-Villa /B) and closure of either valve (CO-V111A/B) will ensure integrity i- of one CST. inventory if one of the CO-V14A/B cannot be closed.
All of the valves involved (CO-V14A/B & CO-Villa /B) are Seismic I and by the end of Cycle 6 refueling outage their routing (CO-V14A/B and CO-Villa /B) and power supplies
-(CO-Villa /B) will also be Seismic I. In the interim, manual operator action will ensure proper operation following a seismic event.
The TMI-1 Emergency Procedure for Earthquake (1202-30) and relevant Alarm Response Procedures have been revised to in-struct the operator to isolate the damaged Condensate Storage i
Tank from the EFW system by closing valves CO-V14A/B and CO-Villa /B when tank level reaches the Tech Spec limit follow-ing EFW actuation, and following any recognizable seismic event t
(a seismic instrumentation alarm is available in the control
, room). (Ref. 12, TER Item 2.)
- c. EFW pumps' minimum flow valves (recirculation valves) and their controlling flow switches and associated circuitry.
i The EFW pumps' minimum flow valves (EF-V8A/B/C) are seismically qualified. (Ref. 25.) The fact that-their controlling flow ,
j switches and circuitry are not seismically qualified has been !
, resolved by locking open EF-V8A/B/C. This will prevent the possibility of dead heading the EFW pumps, and sufficient flow
- will still be available to the steam generators. (Refs. 18, j 19.)
i
- d. Electro-pneumatic converters for the EFW flow control i valves, EF-V-30A and EF-V-30B. The E/P Converters will be re-j placed by Junr, 1984 with seismically qualified I/P Converters. R.1 A seismic event vill not result in a failure of the converters l for the EFW ficw control valves and thus sufficient flow will ;
3 be established for the EFW sy= tem to perform its safety func-tion.
l 4
- e. Condensate storage tank 1cw level alarms. The ac-tions described above in "a, b and c" will ensure sufficient
, inventory in the Condensate Storage Tanks and a sufficient flow l path to the steam generators for the EFW system to perform its i safety function. (Ref. 11, Item 1.) Licensee has reviewed the i failure modes in a seismic event for the condensate tank level instrumentation,.(Ref. 11, Item 3.), and concluded that only in
- the event of a transmitter sensing line crimp (due to the j transmitter falling) would the transmitter continue to read a l static level. However the operator would note that no drawdown i
is indicated and investigate the problem. It is incredible to assume that both transmitters would fail in this manner.
- Therefore, at least one transmitter is expected to be avail-i able.
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5 f
In the Restart proceeding, the Licensing Board recognized and explicitly endorsed for Cycle 5 operation the non-safety-grade CST low-low level alarms as adequate pending the instal-lation of safety-grade alarms during the Cycle 6 refueling out-age. LBP-81-59, 14 N.R.C. 1211, 1363-64, 1373 (11 1033, 1037, 1059). These low-low alarms use the same transmitter as the low level alarms.
- f. Circuitry for main steam dump isolation valves i MS-V2A, MS-V2B, MS-V8A and MS-V8B. Since the EEW system safety J
function can be achieved with the motor driven EEW pumps with-out relying on the turbine driven pump, the circuitry for these valves is not essential and need not be seismically qualified.
- (Ref. 10, TER at 5; Ref. 12, Item 7.)
i 1
- g. Circuitry for condensate storage tank isolation valves CO-V10A, CO-V10B, CO-V14A and CO-V14B. The only non-
- seismic parts of the circuitry for valves CO-V10A/B are the cable routing through the turbine building and the electric power supplies. CO-V10A/B are normally open and are not re-
. quired to change position for the system to become operational.
t Valves CO-V10A/B are locked open now and there is no need to seismically qualify the circuitry for these valves. The only non-seismic part of the controls for valves CO-V14A/B is the cable routing through the turbine building. CO-V14A/B are nor-mally open and are required to change position for the system j to become operational if a pipe break occurs in the hotwell makeup piping. (Ref. 19.) Manual closing of CO-V14A/B is pro-vided as discussed above in "b".
i h. Circuitry for condensate storage tank cross connect valves CO-Villa and CO-V111B. The non-seismic parts of the circuitry for valves CO-V111B are the cable routing through the i
turbine building and the electric power supplies. CO-Villa /B
- are not required to change position for the system to become operational. (Ref. 19.) (See "b" above.)
! i. Contral systems for the atmospheric relief valves MS-V4A and MS-V4B.
These valves are within the seismic bound-ary and will maintain their structural integrity during a seismic event. However, the control of these valves is not es-sential for safe hot shutdown and, therefore, the control sys-tem need not be seismically qualified. These valves will re-main closed on loss of instrument air or loss of electrical i
signal. The MSV-4A/B can be manually operated.
- j. Vent stacks for both the main steam relief and i atmospheric dump valves. UCS argues that "it is very likely that the operator will not be able to enter the Intermediate Building to isolate the leak following an earthquake because of
! steam released to the building by failure of equipment which.is I
not seismically qualified" -- the vent stacks for MS-V-22A/B
! and MS-V-4A/B valves. UCS Petition at 13.
-. -. .- _ , ~ ,
l
)
The pressure control valve (MS-V6) upstream of valves MS-V22A/B was-modified to limit its travel at 65% of stroke to
! protect the EFW pump turbine from overpressurization due to the failure of any steam supply valve. This reduces the potential 4
for opening-of valves MS-V22A/B. In addition, these valves will not lift simply because a vent stack fails or the EFW tur- '
, bine driven pump is started.
Licensee previously had. evaluated the design of the vent j stacks for these valves and found that these vent stacks were l classified non-seismic and were designed for dead weight and 1 discharge loads only. However, the supporting scheme for the j MS-V22's stacks was judged by inspection to be seismically acceptable. (Ref. 14, Question 1 of Cnclosure 1; Ref. 15.)
Also, as noted in item "i" above, operation of MSV-4A/B is not required for safe hot shutdown and the failure mode of these i valves is closed. Nevertheless, Licensee had originally planned'to upgrade the supports for the MS-V4A/B and MS-V22A/B l to Seismic I during the Cycle 6 refueling outage, but has con- R.3 j tinued to work on these modifications during the current shut--
4 down. Licensee will now complete this work prior to Restart.
Therefore, the EFW System components will be protected ~from a steam environment crea ed by a postulated vent stack break and
- the operator will be able to function in the Intermediate Building.
- k. Main steam isolation valve circuitry. Circuitry for
- these valves (MSV-1A, B, C, D) is not essential for plant shut-j down (since the EFW turbine driven pump is not needed) and need
! not be seismically qualified. (Ref. 10, TER at 5; Ref. 12,
! Item 9; Ref. 11, Item 9.)
t
! FollcWing the dated list which is evaluated above, the UCS l Petition proceeds to criticize use of a " static analysis" to i i establish the seismic qualification of valves. UCS Petition at
- 11. The very Standard Review Plan passage quoted by UCS belies
! its claim that static analysis has bsen rejected by the NRC: ,
" Analysis without testing is acceptable if structural integrity alone can assure the intended function." UCS Petition at 12.
Further, the seismic analyses for the 47 EFW valves utilized as .
i inputs accelerations which were determined.frem a dynamic anal- *
, ysis of the EFW piping system -- using the response spectrum j approach specified in the Standard Review Plan. The valves and 3 their characteristics (i.e., center of gravity, weights and ge-ometry) were realistically included in the dynamic model of the piping system. 'The piping was analyzed considering the Op-erating Basis Earthquake, and the acceleration results were
! This approach is conservative since the increase in. damping of-the piping system during the SSE was not considered.
l
The accelerations used to analyze the valves were gener-ated using a fully qualified, realistic, " state of the art" dy-namic analysis of the EFW piping system. The dynamic model has been checked during t.he TMI-1 review in response to IE Bulle-tins 79-02 and 79-14, which showed that the pipe routing sup-port locations and pipe support construction are consistent with the analysis.
The analyses applied the dynamic acceleration from the piping analysis to the valve internals, pressure boundaries and actuators in a static manner, along with other consequential
} loads. This approach is justified because the valve internals are sufficiently stiff to preclude dynamic amplification within the valve itself.
l Here, stress analysis of the valves, considering accelera-tions derived from a dynamic analysis of the EFW piping system, reveals that the highest stress in the valves -- considering 4
consequent loads due to the SSE, internal pressure and dead-weight -- ranges from 3 to 91 percent of the ASME Code allow-able stress values. (These ASME allowable stresses are based on a safety factor of at least four, considering the ultimate strength of the materials.) This means that both the structur-al integrity and operability of the valves are assured because the materials experience stresses and strains within their elastic limits. Consequently, deformations are small and tem-porary, such that the moving parts inside the valves and.
actuators are not affected. For all of these reasons, the valve analyses are valid.
i As shown above, the TMI-1 EFW system has the capability to perform its scfety function following a seismic event, coin ~
cident with loas of offsite power with a single failure of any active ccmponent. Even if the inventory from either one or both Condensate Storage Tanks is depleted due to the single failure of isolation valve Co-V14A or B, a secondary backup supply of river water is available from the reactor building
+_mergency cooling pumps -- an entirely seisnic Class I wipply, although establishment of this supply may require operator sc-tion in the Intermediate Building. (Ref. 14, Question 1 of En-closure 1, Enclosure 2 at 5.)
i 4
UCS states that GPU apparently performed no evaluation of the potential effects of flooding the Intermediate Building from failure of the EFW system, and concludes that this is a "significant omission." UCS Petition at 14. It might be if it were true, but it is not. Licensee has evaluated the conden-sate piping from valves CO-V14A/B to the turbine building wall
- to determine if this piping will stay intact during an earth-quake. Seismic stress analysis of the condensate piping has included the restraining capability of the supports in the
! non-seismic piping from the valves CO-V14A/B to the Turbine
- l l
i . I i Building wall and into a portion of the piping that extends I i into. the Turbine Building. These supports, which have a com-bined restraining capability in three directions, will result in low seismic stresses in the non-seismic part of the system.
If a pipe rupture is postulated beyond these. supports, the break would be isolated and will not.cause flooding in the In-
! termediate Building. Furthermore, there are no components i vital to the EFW system which can be adversely affected by spray from a broken EFW pump recirculation line. (Ref. 11,
- Item 1.) Finally,-the procedural action (discussed above) to isolate the recirculation line will limit the leakage rate through this small line and avoid a flooding problem.
With respect to a main feedwater line break,' the time re-quired to. jeopardize EFW equipment is presently 5.5 minutes, not 86 seconds -- UCS Petition at 15, n. 40. (Ref. 16.) How-ever, prior to restart, Licensee will have completed additional i modifications which will extend to 25 minutes the time avail- R.2 able to the operator to terminate flooding in the Intermediate Building before EFW components not qualified for submergence would be adversely affected. As described in Licensee's letter 5211 , dated May , 1984, from H.D. Hukill to
- J.F. Stolz, structural modifications to the Intermediate Build-
- ing which will provide more volume for the accumulation of flood water will be completed in June.1984. (Ref. 26.) This modification had previously been scheduled for completion prior to startup from the Cycle 6 refueling outage. (Ref. 2, Attach-ment at 5.) In addition, evaluation of the stress analysis for the main feedwater lines from containment penetration to the turbine building indicates that the maximum stress levels from.
^
combined operating and seismic conditions are at most 46.5 per- l R.3 cent of the limits designated as the potential pipe rupture stress level. (Ref. 5, Section 4.0 of Appendix 14A.) The're- l R.3 L sults of these stress analyses show that the non-seismic por-tion of the main feedwater lines inside the Intermediate Build-inq has seismic resistance. Consequently, there is a low '
probability that a nain feedwater line break would cause :
flooding in the Intermediate Building following a. seismic '
j event.
4 Finally, Licensee notes that UCS repeatedly cites to tha '
plans for further hardware modifications to the EFW system (Ref. 2) as support for the proposition that the system is not t
seismically qualified, and. asserts that GPU has concluded that.
at restart the TMI-l EFW system cannot withstand a Safe Shut-down Earthquake. UCS Petition at 16. In contrast, it is l Licensee's position that the TMI-1.EFW system at restart, con- <
sidering accomplished modifications and with the implementation of the. plan of procedural actions. described above, will be = able
~
to perform its system function, in the'unlikely event it.should.
be called upon to do so following a design basis seismic event during Cycle 5. operation.
i -
l IV. Single Component Failure , ,
.J I s
& I jf '
- UCS states that "[t]he TMI-1 EFW system does not. meet,the's - '
i
+
single failure criterion because there is only a singla flow //"",. I control generator." valve UCS in the pipe used Petition at 19, to 20.
deliver UCS EFWdoestonet e,ach 5taam {)f address,
- however, the design modifications already accomplished which i
)
j improve the reliability of the system. >
,/'
i TheMainSteamLineRuptureDetectionSyitem(MSLRDd)sig-r; i nals to the EFW control valves, EF-V30A/B, have been dolhted to '
prevent unnecessary isolation of emergency feedwster under sin-
! gle failure conditions. In addition, a cavitating venturi in- , .
stalled for each EFW line will limit flow to a ruptured steam l l generator to prevent containment overpressurization (or steam !
generator overfill condition), and will also ensure opffi font EFW flow to the intact steam generator. (Ref. 17.) y t
3 At restart, the arrangement of the EF-V30A/B. controls will l
, result in the valves failing open on either loss cf instrumeht R.1 l l air or loss of control signal. Additionally, the EFW control ,
i valves are equipped with a handwheel which permits manual oper j '
- ator action to establish flow to the intact steam generator. e i When there is an initiation'of the EFW system or failure of an ,
! EFW control valve, an auxiliary operator will be stationed at' ' g ( !
i the control valves. (See TMI-1 Abnormil Transient Procedure ;
1210-10.) The auxiliary operator will establish. communications- (. ;
- with the control room and will concrol the valves if EFW flow U
- cannot be established from the~ control room. i t / i J
Isolation of EFW flow, if required, to a ruptured stskm
[
- generator can be achieved either~by closing the affected EFW '
- control valve or by closing the discharge header sectiodiliziny !
a valves (EF-V2A/B), and then tripping the respective EFW pump.. !
t UCS next states that "[a]nother way in which the E(W dys- }
tem does not meet the single failure criterion is that the EFW i flow control valves are presently controlled by the Integrated !
- Control System (ICS) which is not cafety grade."? UCS Petition l l at 20. The relationship between the EFW system und the ICS was
! considered extensively in the TMI-l Restart ~ proceeding. Pursu- ;
l ant to Short-term action 1(b)'of the Commission's,.Aupust 9, -
1979 Order and Notice of Hearing'in that proceeding, Licensee has-implemented automatic initiation of the EFW pumps indephn-dent of the ICS and,'further, has provided separate manual EFW flow control capability in the control room, which will.isllow.
i the operators to manually control EFW flow to the steam genera-l tors in the event of an ICS malfunction. The Liccasing Board' i examined.this issue and required no further modifications, finding that the actions taken provided a significant improve-ment in safety. LBP-81-59, 14 N.R.C.11211, 1285-86 (1 802),
^L-f' ;/'
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p q ,, /
g\ a: . <
- , ./ ~,e/ j
- l- g 136 .( ,1031)-(1981). The Appeal Board also evaluated the mat- ,' ;
'"\' tiettsidered ". . . the concerry regarding dependerice on / ;
( ' the terMn NCS/for control of emergency feedwater to be resolved." r
- l
'/' .A?AB-729, 17 N.R.C, 814, 833-34 (1983). i
,y
'n 4 ;In a'ddition, Licensee notes t/ hat the ICS has a reliable,
/ . uri.4 tntarruptible, on-site power'buppih It is'normally fed from. ?
I an inverter which is powered from the'"A" diesel backed 480 [
Volt AC bus. When the 480 Volt bus is unavailable, the in .
f d verter takes its power directly from one of the DC station bat-
- teries. In the unlikely event of an independent inverter fail ' f, -
ure; the /:CS poder supply will be switched to a regulating
\ 'y '
t*:ansforner which is fed direct:.y from the same 480 Volt AC ^
, bus. The independent manual cohtrol stations described in the l previousiparagraph> ire powered'from a different inverter which el
^
is backe'd up by a ,sepayate set cf- DC station batteries. In the ,
event of an indepand'snt failure of' tt.Ls inverter, the power supply for the mangil control stations automatically switches. .,i to an alternative yource backed by the "B" diesel generator.', , M '
i ,
In summary, means are available during cycle 5 operation s i
+],. 't/.
s,
- to prevent the EFW system from being disabled by a single com- .
ponent failure.>,
((
st
( < ,-,
. V. Emetiency Feedwater Flow Instr
- g y. tion ,
,. \ .
> V ' '
i' UCS attacks the adequacy of the new EFW flow indicators, l ./
e
,, alleging that the replacement of the unqualified sonic flow i s#, ' , ,'. % devices by differential pressure (D/P) transmitters " amounts to a request for exemption from the short-term lessons learned -
[
requirement for safety grade EFW flow instruments." UCS Peti-tion at 24. (UCS's complaints regarding the EFW flow indihe <>, !
tors are currently pending before de Commission in the Restart proceeding by virtue of UCS filings dated December 9, 1983 and- '
i January 6, 1984.) UCS here is patently wrong; as detailed in {
our submittal to the Staff of August 25, 1983, the EFW flow in- 1 strumentation meets all applicible enviremmental, seismic and.
ether safety-grade criteria. (Ref. 20, Attachment at.N.,'2).
- UCS's complaints regarding'the qualification of the EFW flow indicators rest upon its claim that this instrumentation ,
does not " meet the +'10% accuracy re irement in effect during i the restart hearing [d<?UCS Petition,a. 24. As Licensee re-ported, at lov 1.FW flow conditions (i.e., below appral:timately 120 gym)o cavitation of the EFW flow control valves (EFV-30's) ,
due to .lew fl'ow against negligible gackpressure resu'ited fin in-dicatientiofEFWflowoscillationsogtside+10%ofatheflow rate. '(kef. 21; Ref.'I2,2, Attachment at 1). Howeverk - recently '
reported test data,Irequested by the NRC (Ref. 23)/; confirm that at flows of 120 gym and above, the flow oscillations 1 i i
13 W ,
-- ,,.._. , ),_ ~, e--- - , --- -. . - _ - - -v..---,, ._ .
Oi
.. .. . ~ . .
hp recorde/ .ce within i 10% (e.g., at 200 gpm flow rate the os-cillatits:- 4ere ' 7.5% (15 gpm); at 600 gpm, the oscillations were'1 4.4% (25 gpm).) (Ref. 22, Attachment at 1.) (The os- ,
, cillations reported were measured on recorder traces. The EFW l i flow meter face contains 25 gpm graduations and thus these !
small oscillations combined with meter damping are not readable l on the meter itself. (Ref. 22, Attachment at 1.)) Further, as discussed in Licensee's most recent submittal, operators are directed to refer to the EFW flow indicators only in limited circumstances (i.e., upon EFW actuation with steam generator
,(SG) level below the SG level setpoint) and, additionally, are instruct.ed not to rely on EFW' flow indication for flow control at rates below 225 gpm. (Ref. 22, Attachment at 2.) Thus, it
, is clear that the EEW flow indicators are sufficiently accurate to perform their intended function.
L-With respect to UCS's reliance on the 1 10% accuracy I requirement, Licensee would merely note that (while this crite-i rion was part of an interim clarification of lessons learned requirements dated October 30, 1979) Item II.E.1.2 of
- NUREG-0737, which~ sets forth the latest position and clarifica- ,
I tion for EFW flow indication, contains no such set accuracy requirement. (Moreover, the Licensing Board decision itself i .makes no reference to this 1 10% accuracy requirement.
LBP-81-59, 14 N.R.C. 1211, 1362 (1 1029) (1981).) Rather, as recognized by UCS, NUREG-0737 merely referenced IEEE Standard 279-1971 which states, in pertinent part, that the system de-sign basis sh'all document the " minimum performance requirements including . . . system accuracies." See "UCS Rebuttal to Licensee's Reply Regarding EFW Flow-Instrumentation,"~(January
- 6, 1984) at 5, quoting IEEE 279-1971, 6 3(9). Licensee con-tends that -its documentation of EFW flow indication accuracy i meets this requirement and, moreover, that the earlier i 10%
i accuracy criterion is met at EFW flows of 120 gpm and above.
VI. Main Steam Line Rupture Detection System i UCS asserts that the Main Steam Line Rupture Detection System.(MSLRDS) ". . . is not safety grade and requires-modifi-cations so that a. single failure will not prevent isolation of main feedwater to the steam generator affected by a main steam line break." UCS Petition'at 29. As UCS notes,-the potential for inadvertent isolation of feedwater was considered in the TMI-l Restart proceeding as a part of the emergency feedwater reliability issues. LBP-81-59,~14 N.R.C..1211, 1373-74' (11 1060-64) (1981). .The Appeal Board found that the opera-(. tors' capability to bypass the MSLRDS and manually open the EFW l flow control valves if the MSLRDS isolates feedwater inadver-tently is an' adequate solution for restart. ALAB-729, 17 N.R.C. 814, 834', 887-88 (1983). In an Order'(January 27, 1984)
~ -
z
, S
-.;.Tha A; -
w
,^
. . . . - - . . . . ~ -- . - . - ,.
i issued in'the TMI-l Restart proceeding after the UCS Petition was filed, the Commission called for' comments on the adequacy ,
of Licensee's proposed solution to the MSLRDS " problem." I In its submission of August 2, 1982 to the Staff, Licensee described the design changes to the MSLRDS to prevent unneces-sary isolation of emergency feedwater under single failure con-ditions. -(Ref. 17.) In addition to those changes, existing pressure switches inside containment for MSLRD (Static-O-Ring devices) will be replaced by June, 1984, with fully qualified pressure switches. (Ref. 4.). Therefore, in the event of a main steam line rupture in containment, the pressure switches will be capable of performing their intended function. All
, components of the MSLRDS located inside containment will then be environmentally qualified. The following describes the MSLRD system configuration:
- 1. Each steam generator (S.G.) has two outgoing steam lines, each line has two pressure-switches for MSLRD.
- 2. Each S.G. has a parallel combination of startup and main FW control valves, and each control valve ~has a motor operated block valve upstream.
. 3. Upon MSLRD, the Df is isolated from the af-i facted S.G. by closing its control valves and l the block valves. Valve isolation logic is i as follows:
- A. Startup and Main Control Valves
~
(FW-V16A/B & FW-V17A/B):
(1) For isolation purposes, each valve is.provided with.two paths in the i pneumatic control circuit; however,
. only one path is required to
', achieve isolation.
(2) Each isolation path in the pneumat-ic control circuit'has two sole-noids. Each solenoid is energized by a separate pressure switch upon i
MSLRD. Both solenoids in either-of the control paths must be energized ,
- for isolation. '
l (3) The solenoids ~in the same. control path are powered from the same source but the two paths receive !
power from separate sources.
l L
l B. Block Valves:
(1)
For Main FW Controls Valves (FW-VSA/B):
Two pressure switches associated with either of the pneumatic con-
- j. trol paths (discussed in paragraph 3.A.2) must detect MSLR to cause a closure signal for the block
- valves. In this case, the
- isolation signals from RED & GREEN sources are tied together. Also the power for both the block valves is from the same source.
(2) For startup FW Control Valves (FW-V92A/B):
4 Separate power sources are avail-able to the motor operators. A single. failure will prevent block
, valve isolation, but the same fail--
ure will not prevent control valve 4 isolation.
t
, 4. On loss of instrument air, the control valves i
(FW-V16A/B and 17A/B) will fail closed which will result.in FW isolation.
- 5. Electrical Separation. Outside containment
- i. the MSLRDS circuits.are not all routed in
! safety-related trays and therefore separation l 'is not maintained throughout.
i-In conclusion, the MSLRDS is considered to be adequate from a single failure standpoint -- that is, a single active failure (such as a pressure switch, solenoid, control relay, 125V DC power source) will not prevent isolation of feedwater l and will not~ result in inadvertent isolation of-feedwater. The MSLRDS is seismic Class I inside containment. Following a main steam line break in the reactor building the system will func-tion to isolate feedwater from the affected steam generator since qualified pressure switches (for MSLRD) to be installed i by June,-1984 will,be suitable.for the accident environment.
While electrical' separation between the-redundant circuits'is not-maintained outside. containment, since a few of them.run.in the same trays / conduits, electrical separation outside contain-ment is not' required for a main steam line break inside con-tainment. The MSLRDS, therefore, is adequate:for operation untilithe fully safety grade modification is installed..
I I' ,
t
- . ~ + > - .- 4e.- ...,-2w , .-,s -#g . - , - -
VII. Conclusion There is reasonable assurance that the emergency feedwater system at TMI-1, as modified for restart and as augmented with plant do so. procedures, will perform its function if called upon to d sT- _
Richard F. Wils6n Vice President-Technical Functions GPU Nuclear Corporation Sworn 1964. to and subscribed before me this __/6// day of May,
~
/
>tb ./ ('n Notary Public ?
p.s m rid.cN33 .
,:mn , . - >: .: J av ~
'"~'2""I* 06#
My commission expires h*/ C - -
i S
l l
REFERENCES
- 1. Safety Evaluation by the Directorate of Licensing, U.S.
Atomic Energy Commission, in the Matter of Metropolitan Edison Company, Jersey Central Power & Light Company, Pennsylvania Electric Company, Three Mile Island Nuclear Station Unit 1, Dauphin County, Pennsylvania, Docket No.
50-289, July 11, 1973.
. 2. GPU Nuclear letter 5211-83-232 to NRC, Long Term EFW Mods (NUREG 0737 II.E.1.1), August 23, 1983.
- 3. Safety Evaluation Report by the Office of Nuclear Reactor Regulation for GPU Nuclear Corporation, TMI-1, Docket No.
50-289, Environmental Qualification of Safety-Related Electric Equipment, December 10, 1982.
- 4. GPU Nuclear letter 5211-84-2038 to NRC, Environmental Qualification of Electrical Equipment, February 10, 1984.
- 5. GPU Nuclear, Final Safety Analysis Report (Updated Ver-sion), Three Mile Island Nuclear Station Unit 1.
- 6. USNRC NUREG-0766, Reconnaissance Report: Effects of November 8, 1980 Earthquake on Humboldt Bay Power Plant and Eureka, California Area.
- 7. USNRC NUREG/CR-1665, Equipment Response at the El Centro Steam Plant During the October 15, 1979 Imperial Valley Earthquake (October 1980).
- 8. USNRC Generic Letter No. 81-14 to All Operating Pressur-ized Water Reactor Licensees, Seismic Qualification of f Auxiliary Feedwater Systems (February 10, 1981).
, 9. USNRC letter to All Operating Pressurized Water Reactor Licensees, Seismic Qualification of Auxiliary Feedwater Systems (October 21, 1980).
, 10. USNRC Safety Evaluation Report, Three Mile Island Unit 1, Seismic Qualification of the Auxiliary Feedwater System, 4
August 12, 1983.
- 11. Attachment 1 to GPU Nuclear letter 5211-83-040 to NRC, EFW Seismic Qualification, February 4, 1983.
- 12. GPU Nuclear letter 5211-82-301 to NRC, Emergency Feedwater System-Seismic, December 20, 1982.
- 13. GPU Nuclear letter 5211-83-133 to NRC, EFW Seismic Quali-fication, May 2, 1983.
l
, o
- 14. GPU Nuclear letter 5211-82-150 to NRC, Emergency Feedwater System-Seismic, July 7, 1982.
- 15. GPU Nuclear letter 5211-82-238 to NRC, Seismic Qualifica-tion of Emergency Feedwater System (EFW), September 29, 1982.
- 16. GPU Nuclear TDR-250, Rev. 1 (January 16, 1984), Review of Intermediate Building Flooding Following a Feedwater Line Break in the Intermediate Building of TMI Unit 1.
- 17. GPU Nuclear letter 5211-82-153 to NRC, Main Steam Line Rupture Detection System Changes, August 2, 1982.
- 18. GPU Nuclear letter 5211-83-055 to NRC, EFW Seismic Quali-fication Supplement, March 22, 1983.
- 19. GPU Nuclear letter 5211-82-018 to NRC, EFW Seismic Qualification-Electrical, February 16, 1982.
- 20. GPU Nucleat letter 5211-83-231 to NRC, EFW Flow Devices --
D/P Transmitters, August 25, 1983.
- 21. GPU Nuclear letter 5211-83-346 to NRC, EFW Flow Devices (D/P) Testing, November 23, 1983.
i
- 22. GPU Nuclear letter 5211-84-2032 to NRC, EFW Flow Instru-mentation, February 22, 1984.
- 23. USNRC letter to GPU Nuclear, January 18, 1984.
- 24. GPU Nuclear letter 5211-84-2044 to NRC, Environmental Qualification of Electrical Equipment, Supp. 1, February 22, 1984.
- 25. GPU Nuclear letter 5211-82-216 to NRC, Seismic Qualifica-tion of Emergency Feedwater System, September 14, 1982.
- 26. GPU Nuclear letter 5211 to NRC, Intermediate R.2 Building Flooding Modification, May , 1984.
- 27. GPU Nuclear letter 5211-84-2110 to NRC, Environmental Qualification of Electrical Equipment, Supp. 3, May 7, 1984. R.3
- 28. GPU Nuclear letter 5211-84-2114 to NRC, EFW System Envi- I ronmental Qualification, May 10, 1984.
l l
May 16, 1984 l
l UNITED STATES OF AMERICA NUCLEAR REGl?LATORY COMMISSION BEFORE THE DIRECTOR OF NUCLEAR REACTOR REGULATION In the Matter of ) Docket No. 50-289
GPU NUCLEAR CORPORATION )
)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Amended Re-sponse to Union of Concerned Scientists' Petition for Show Cause Concerning TMI-l Emergency Feedwater System" and Revision 3 of "GPU Nuclear Technical Response to Union of Concerned Sci-entists' Petition for Show Cause Concerning TMI-l Emergency Feedwater System" were served this 16th day of May, 1984 by de-posit in the U.S. Mail, first class, postage prepaid, to all those on the attached Service List, wvm ,
Thomas A. Baxter, P.'C.
Dated: May 16, 1984
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of )
)
METROPOLITAN EDISON COMPANY ) Docket No. 50-289
)
(Three Mile Island Nuclear )
Station, Unit No. 1) )
SERVICE LIST Lillian N. Cuoco, Esquire Gary J. Edles, Esquire Office of Executive Legal Director Chairman, Atomic Safety and Licensing U.S. Nuclear Regulatory Commission Appeal Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Mr. James A. Van Vliet Office of Nuclear Reactor Dr. John H. Buck
. Regulation Atomic Safety and Licensing Appeal Washington, D.C. 20555 Board U.S. Nuclear Regulatory Commission Mr. Harold R. Denton Washington, D.C. 20555 Director Office of Nuclear Reactor Dr. Reginald L. Gotchy Regulation Atomic Safety and Licensing Appeal U.S. Nuclear Regulatory Commission Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Chairman Nunzio J. Palladino U.S. Nuclear Regulatory Commission Ivan W. Smith, Esquire Washington, D.C. 20555 Chairman, Atomic Safety and Licensing Appeal Board Commissioner Victor Gilinsky U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Sheldon J. Wolfe, Alternate Chairman Commissioner Thomas M. Roberts Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Washington, D.C. 20555 Commissioner James K. Asslestine Mr. Gustave A. Linenberger, Jr.
U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board Washington, D.C. 20555 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Commissioner Frederick M. Bernthal U.S. Nuclear Regulatory Commission Richard J. Rawson, Esquire Wnshington, D.C. 20555 Office of Executive Legal Director U.S. Nuclear Regulatory Commission Docketing and Service Section Washington, D.C. 20555 Office of the Secretary U.S. Nuclear Regulatory Commission Washington, D.C. 20555
l l
Maxine Woelfling, Esquire Marjorie M. Aamodt :
Assistant Counsel R. D. 5 l Department of Environmental Coatesville, PA 19320 Resources 514 Executive House Steven C. Sholly Post Office Box 2357 Union of Concerned Scientists Hnrrisburg, PA 17120 Suite 1101 1346 Connecticut Avenue, N.W.
M2. Louise Bradford TMI ALERT ANGRY /TMI PIRC 1011 Green Street 1037 Maclay Street Harrisburg, PA 17102 Harrisburg, PA 17103 Ellyn R. Weiss, Esquire Chauncey Kepford Harmon, Weiss & Jordan Judith Johnsrud 2001 S Street, N.W., Suite 430 ECNP Washington, D.C. 20009 433 Orlando Avenue State College, PA 16801 John A. Levin , Esquire A sistant Counsel Pennsylvania Public Utility Commission Post Office Box 3265 Harrisburg, PA 17120
.