ML20012A297

Exemption from Reactor Coolant Pump Lube Oil Collection Requirements of Section Iii.O of App R to 10CFR50

ML20012A297
Person / Time
Site:	Three Mile Island
Issue date:	02/26/1990
From:	Boger B Office of Nuclear Reactor Regulation
To:	GENERAL PUBLIC UTILITIES CORP.
Shared Package
ML20012A298	List: ML20012A297
References
NUDOCS 9003090186
Download: ML20012A297 (5)

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UNITED STATES NUCLEAR REGULATORY COMMISSION 1

I In the Matter of

'l GPU NUCLEAR CORPORATION, ET AL.

Docket No. 50-289

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(Three Mile Island Nuclear Station,UnitNo.1)

EXEMPTION l

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GPU Nuclear Corporation (GPUN/ licensee) and three co-owners hold Facility Operating License No. DRP-50, which authorizes operation of the Three Mile IslandNuclearStation,UnitNo.1(TMI-1)(thefacility)atpowerlevelsnot in excess of 2568 megawatts thermal. This license provides, among other things, that the facility is subject to all rules, regulations, and Orders of the Nuclear' Regulatory Comission (the Comission or the staff) now or hereafter in effect.

The' facility is a pressurized water reactor located at the licensee's site in Dauphin County, Pennsylvania.

1 II.

On November 18, 1980, the Commission published a revised Section 10 CFR 50.48 and a new Appendix R to 10 CFR Part 50 regarding fire protection features of nuclear power plants (45 FR 76602). The revised Section 50.48 and Appendix R became effective on February 17, 1981.Section III of Appendix R contains 15 I

subsections, lettered A through 0, each of which specifies requirements for a particular aspect of the fire protection features at a nuclear power plant.

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One of these 15 subsections,111.0, is the subject of this exemption request.

This subsection specifically states that "the reactor coolant pump shall be equipped with an oil collection system if the containment is not inerted during normal operation... Such collection systems shall be capable of collecting lube oil from all pressurized and unpressurized leakage sites in the reactor coolant pump lube oil systems....

Leakage points to be protected shall include lift pump and piping, overflow lines, lube oil cooler, oil fill and drain lines and plugs, flanged connections on oil lir.es, and lube oil reservoirs where such features exist on the reactor coolant pumps."

TMI-1 has, in the past, been considered to be in full compliance with Section 111.0 of Appendix R.

However, a plant modification to reduce radiation exposure to workers during normal operation and to improve the occupational safety aspects of adding oil to the RCP lube oil system has been undertaken by the licensee. The modification relocates the lube oil fill station to a remote location outside of the secondary radiation shield with a corresponding addition of significant lengths of fill piping and tubing. Existing drip pans are retained as part of the oil collection system and new drip pans are added beneath reservoirs, drains and overflows. However, collection trays / pipes are not provided for the entire length of each pipe and beneath each fitting. By letter dated October 20, 1989, the licensee requested an exemption from the Appendix requirement to provide collection systems from all potential leakage sites and listed a number of compensatory considerations regarding design and operation of the modified system which would reduce the likelihood of fire.

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3 IV.

The purpose of Appendix R is to accomplish safe shutdown in the event of a single fire and maintain the plant in a safe condition.Section III.0 requires j

collection of oil leakage from RCP lube oil system fill lines. At THI-1, the intent of this section will be satisfied by both the design of the modification and procedurally controlled activities involved in adding oil to the RCPs.

Concerns related to fire caused by carelessness or material failure and resultant lube oil leakage during a seismic event are mitigated although highly unlikely. The additional considerations listed below will reduce the likelihood of fire even further during oil additions without concurrent seismic events.

In the absence of drip pans located below the entire portion of added fill piping / tubing, the licensee proposed minimizing the potential for and controlling leakage and spillage by:

1.

using welded joints at fill piping / tubing connections as much as C

possible; 2.

preventing oil from standing in piping outside the drip collection system by sloping the piping / tubing to drain completely into the RCP t

lube oil reservoirs; 3.

locating fill line connections to oil reservoirs above the reservoir's high level alarm set point and overflow line; j

4 extending existing or installing additional drip pans to collect j

possible leakage from the sight glasses; 5.

confirming after installation that added oil reaches the sump and is not trapped in the piping;

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based on startup and test' data, identifying sight glass level change 4

.versus volume of oil added and incorporate that information in oil-addition procedures; and e

7; revising operating procedures to require wipe-up of any spillage at the remote fill station local drip pans.

V.

Based upon its evaluation, the staff concludes that the licensee's proposed design achieves a level of safety equivalent to that which would be achieved by literal conformance with the requirements of Section III.0 of Appendix R to 10 CFR Part 50.

Accordingly, the Commission has determined pursuant to 10 CFR 50.12(a)

(2)(11) that (1) this exemption as described in Section IV is authorized by law, will not present an undue risk to the public health ano safety, and is consistent with the common defense and security, and (2) special circumstances are present for this exemption in that application of the regulation in this particular circumstance is not necessary to achieve the underlying purposes of Appendix R to 10 CFR Part 50. Therefore, the Commission hereby grants the exemption request identified in Section IV above.

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• I Pursuant to 10 CFR 51.32, the Counission has o'etermined that the granting of this exemption will have no significant impact on the environment I

( 55 FR 6717).

This exemption is effective upon issuance.

FOR THE NUCLEAR REGULATORY COM ISSION i

i Bruce A. Boger Acting Director Division of Rea,ctor Projects - I/II

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r Office of Nuclear Reactor Regulation Dated at Rockville, Maryland this February 26, 1990 t

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