ML19347C038
| ML19347C038 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 10/08/1980 |
| From: | Sweeney L JERSEY CENTRAL POWER & LIGHT CO. |
| To: | Vollmer R Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8010160490 | |
| Download: ML19347C038 (3) | |
Text
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,I Jersey Central Power & Light Company Macison Avenue at Punch Bowl Road Mornstown, New Jersey 07960 (201)455-8200 October 8, 1980 Mr. Richard H. Vollmer Director, Three Mile Island-2 Support Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission 7920 Norfolk Avenue Bethesda, MD 20014 Re: NRC Ebeket No. 50-289 - TMI-l Restart Proceedirsj;
Dear Mr. Vollmer:
By your letter dated September 21, 1979, to R. C. Arnold, and Mr. J. C.
Petersen's data requests sent to C. W. Smyth on November 9,1979, you requested us to keep the NRC informed of significant regulatory developments affecting the GPU cocpanies. Accordingly, the enclosed material (8 copies) has been sent for that purpose.
Enclosed is a copy of J. B. Kirsten's memo to Judge Marshall and the Co=pany's letter to the NRC dated September 26, 1980.
Very truly yours, f u m [. h aa-,o Lawrence E. Sweeney
/
Rate Department j
rc Enclosure cc:
M. Karlowicz (w/ enc)
J. Petersen D. Carroll (w/o eno)
L. Gentieu i
i l
Q/9) 8010160YfD
[
Jersey Central Power & Ught Company :s a Merrter cf tre Ger:eral Puchc Utst es System
K T itSTEN, FIZI)Cl)M AN & C II IC itI N A PROFESSIONAL CORPOn ATION COU N S C LLOR G AT LAW 17 ACAD CM Y ST R E CT RICH ARO E. C H E Rih.
N EW A R K, N. J. 0710 2 tiAROLD F R 6 E DM AN
" " ^
JACK B. pIRSTEN OF COUNSEL PHILLip LEwas FALEY STEVEN D. FL E15 5 aG OOLORES M.CELADAR
' MEMBER N J. & N V. G ARS e
October 6, 1980 Honorable Stephen l'arshall Administrative Law Judge Office of Administrative Law 185 Washington Street Newark, New Jersey 07102
- \\
Re:
Jersey Central Power & Light Company OAL Docket No. PUC 3518-80
Dear Judge Marshall:
Enclosed please find the Company's letter dated September 26, 1980 to the Nuclear Regulatory Commission.
The NRC's letter of September 5, 1980 referred to in the Company's letter is too voluminous and costly to reproduce, therefore we are making the information avail-able to the parties by contacting Mr. Richard Preiss at GPU in Parsippany, 263-6654.
Copies of the enclosure are being sent to all parties on the attached service list.
,/
Recpctfully yours, JACK B.
KIRSTEN JBK/cmg Enclosure cc:
Attached Service List
JCP&L Cc. SER7 ICE LIST SPU Docket No. 304-235 and CAL DCCKET NO. PUC 3513-30 Alfred L. Nardelli, Esq.
Willia = F. Hyland, Esq.
Oepart=ent of Public Advocate Riker, Dan =ig, Scherer & Hyland Divisien of Rate Counsel 744 3rcad Street l
10 Coc=erce Court-Roo= all Newark, NJ 07102 Newark, NJ 07102 Ja=es 3. Liber =an, Esq.
Menasta Tausner Berlack, Israels & Liber =an l
Depart =ent of Public Advecate 26 Brcadway l
Division of Rate Counsel New York, NY 10004 10 Cc==erce Court-Roc = 411 Newark, NJ 07102
!. Paul Slevin N.J. Board of Public Utilities I
Ray =end l'akul
- bpart=ent of Energy Depart =ent of the Public Advecate 1100 Ray =ond Boulevsed Division of Rate Counsel Newark, NJ 07102 10 Cc==erce Court-Roo= 411 Newa rk, NJ 07102 Dr. Fred S. Crygiel N.J. 2 card of Public Utilities David A. Waters, Esq.
1100 Ray =cnd Boulevard l
Waters, Mc?herson, Hud:in & McNeil Newark, NJ 07102 l
32 Joarnal Square i
Jersey City, NJ 07306 Louis McAfoes, Esq.
N.J. Board of Public Utilities i
t W1111a= Holzapfel, Esq.
1100 Ray =ced Boulevard Bol:apfel, Perkins & Kelly Newark, NJ 07102 108 N. Unicn Avenue Cranferd, NJ 07C16 Anthony J. Zarillo I
~
N.J. Scard of Public Utilities l
Sarthele=ew T. Zanelli, Es1 1100 Ray =end Boulevard S tryker, Ta=s & Dill Newark, NJ 07102 33 Washington Street Newark, NJ 07102 Eugene R. Ccyle 2731 Alcat s: Avenue Frsncis P. Piscal, Esq.
Berkeley, California 94705 Barry, Su==erill, Piscal, Kagan & Privetera 34 Washington Street Dr. W. R. Sel=cnt Tc=s River, NJ 02653 6153 Executive Boulevard Rockville, MD 2C852 Robert H. S toloff, Esq.
Ce; art =ent of Transportation Dennis Baldassari 1035 Parkway Avenue JCP&L Co.
Trenton, NJ 08S35 Madisen Ave. at Punchbowl Ed.
Morristown, NJ 07960 Carla Bello, Esq.
Ceputy Attorney Genert -
Syron Ricks 11C0 Ray =cnd Boulevard JCP&L Co.
Newark, NJ 07102 Madison Ave. at Punchbowl Rd.
Merristown, NJ 07960 Edward Payne Woodside Associates Fred C. Hafer 733 Su==tr S treet General Public Utilities Sta=ferd, CT 06901
~100 Interpace Parkway Parsi;;any, NJ 07054 Tho=as E. Knudsen Woodside Asscciates Richard T. Preiss 733 Su==er S treet General Public Utilities S ta=ferd, CT C6 col 100 Interpace Parkway Farsi;;any, NJ 07054 Captain Ernest C. Pearsen Regulatory Law Cffice Paul H. Preis 5611 Colu=bia Pike JC?&L Co.
Falls Church, VA 22041 Madisen Ave. at Punch Scwl Rd.
Morristcwn, NJ 07960 l
Mr. Divid Helsby R. W. Beck and Associates Jack 3. Kirsten, E q.
P. O. Box 63 Kirsten Fried =an'& Cherin i
Colu= Sus, NE 68601 17 Acade=y S treet 1
Newark, NJ 070C2 1
I John Hoff=an, Esq.
Wilents, Gold =an & Spit:er ch qN CN' og 0
i P. O. Box 10 ev _
.L 43 Woodbridge, NJ 07095 ggggeg c/17/30
t Jersey Central Power & Ught Compat J
bg 4. g%y, / {I h 4
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Madison A venue at Punch Bowl Road M+
Mornstown. New Jersey 07960 (201)455-8200 i
i September 26, 1980 1
Mr. Darrell G. Eisenhut Director, Division of Licensing j
U.S. Nuclear Regu l atory Comnission j
Washington, D. C.
20555 i
l
Dear Mr. Eisenhut:
1
Subject:
TMl2 Related Requirements for Operating l
Reactors (NUREG 0660) i Oyster Creek Nuclear Generating Station j
Occket No. 50-219 i'
i n response to your is Pter dated September -5,1980, JCP&L has reviewed all of Oyster Creek's TM I lessons learned activities against the clarified requirements of that letter. As a result of that review, we are requesting that the implementation date of sane items be extended.
4 i
j Attachment A and B to th i s letter provide alternative schedules and j
justification for two items:
il.K.3.14, Isolation of the isolation Condensers j
on High Radiation in Vent and ll.K.3.27, Common Ref erence Level for Vessel Level j
Instrumentation.
Our position on these two items was originally addressed in
]
our June 23, 1980 letter written in response to your May 7',
1980 letter.
Also, since a plant shutdown would be required to complete item would propose completing j
11.u.3.19, Interlock on Recirculation Pump Loop, we 2
that item during a Spring 1981 shutdown scheduled for the purpose of completing j
other action plan items.
We feel this is justified since JCP&L has already i mp i cm ented comprehensive adm i n istrati ve control s to assure at least two 4
recirculation loops are open at all times.
These administrative controls i
include:
establishing this as a Safety Limit in Oyster Creek's Technical Speci f ications, ' procedure changes, hi ng ed covers ov er all recirculation loop isolation valves and conspicuous warning signs on each cover.
j rurther, the Federal Environmental Protection Agency's National j
Poll ution Discharge Permit for Oyster Creek, prohibits in Section 9.b.5, planned j
shutdowns during December through March. Th i s leaves a very brict period for j
planning and preparation fcr the modification, including provisions for adequate j
nLARA review.
We al so feel that a shutdown before January 1981 would not f acilitate the completion of other items, but would in fact divert resources from the items that are required to be ccapleted by Janusry 1, 1981.
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Vr. Carrell G. Eisenhut September 26, 1980 JCD &'_ c annot yet conmit to comp leting the rev ised requirements of item li.E.4.2.3, Containment i solation Dependability, until e have had a chance to revjew the additional NRC guidance on requirements for three (3) diverse isolation signals and essential vs. nonessential systems.
If you should have any questions regarding the response, please contact
!P.. lanes Knube 1 (201-455-8753) of my statt.
Very truly yours, e
Ns/ W.l Ivan R. Finfro x, Jr Vice Presider I 6 s l i 1
s ATTACHMENT A ISDLATION OF THE ISOLATICN CONDENSERS ON HIGH RADI ATION IN VENT (NUREG 0660, 1I K.3.14) NRC REQUIREMENT Modify the isolation condenser logic so that the isolation condensers are isolated from the reactor upon the receipt of a high radiation signal in the atmospheric vent monitor instead of the steam line monitor. The goal of this modification is to increase the avaiIability of the isolation condensers dur i ng an accident by isolating them only if there is radiation being released fran the plant through the shell side vents to the atmosphere. Such a release could only occar i f there aere a tube leak. Mod i f ications shou ld be ccep lete by January 1, 1981. OYSTER CREEK s PRESENT DESIGN The i sol ation condenser isolation log ic is somewhat d i f f erent from that described for the typical SWR. A vent line radiation monitor does exist which alarms in the control room, however Oyster Creek does not have a steam line radiation monitor which is used to isolate the reactor from the condensers. OYSTER CREEK POSITION JCP&L agrees with the NRC's goals of increasing the availability of the isolation condensers, post accident. They are passive systems and are welI suited for long term core cooling. JCP&L's concern is that if this modification is not proper 1y designed, it wii have en adverse etfect on avaiiabiiity. To do this job properly we cannot simply rewire the existing vent line radiation monitor alarm into the isolation circuit. In our judgement, the existing [ monitor would alarm, even if there were no tube f ail ure simply because of the extremel y high radiation level s expected in the area of the monitors from the i solated condenser's steam & condensate piping. Furthermore, it is impractical to shield the present detectors suf f icientl y to ensure that their alarming impIies a tube rupture. JCP&L feels that a modification to this system which achieves the desired results cannot be ccmpleted by January 1, 1981. At this time the required radiation cenitoring scheme has not been specitied and obvTous!y the p roc urem ent lead times are unknown. We propose to submit a design for this modification by January 1, 1981 and at that time wilI also include an imp lementation schedule based upon vendor supplied delivery dates.
ATTACHMENT B COMMON RE:ERENCE LEVEL FCR VESSEL LEVEL INSTRUMENTATION (NUREG 0660, I!. K.3.27) l NRC REQUIREMENT Modify all reactor vessel water level instrumentation so that they have a common reference level. Complete by January 1, 1981. OYSTER CREEK's POSITION level in general we agree with the concept of having a common reference f or al l reactor vessel level 'nstrumentation. Most persons not involved with control room operations find the present system of level instrumentation cumberseme and difficult to comprehend. Control room operators and shift supervisors who have been working with the present system for a number of years, quite comfortable with it and adept at using it. JCP&L is however, are concerned that an abrupt change f rom the present system may have a confusing ef fect and consequently be the cause of operational problems. In addition, a substantial adm inistrative task is associated with this alteraticn. Relabeling { the faces of the indicators and recorders is relatively simple compared to the l task of identi f ying and revising all logs and operations, emergency and surveillance procedures which use' the present system of level instrumentation. 4 JCP&L proposes the following alternate schedule. By October, 1980, all level indicators and recerders wili have their f aces altered showing two scales. One will be the present markings and the other will be referenced,to the top of the active fuel. We will al so identi fy al l documents (e.g. logs and procedu-es) which will need to be revised as a result of changing the ref erence ro!nt. The period between October 1980 and the 1981 refueling outage wiIi be a y ansition period during which the operators will beccme accustcrned to the new scales and changes to all documentation will be draf ted. The el imination of the ol d sca l es and changes to all affected procedures, logs, etc will occur uuring the 1981 outage. it is felt that an cutage period is.the best time f or th is trans i tion because l ev el instrumentation in the normal operating ranges is not used and therefore the opportunities for cperator misjudgement are minimized. The spring outage will al so prov ide a block of time during whlch the required training sessions can be conducted. 4 .}}