ML20012B587
| ML20012B587 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/07/1990 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 4410-90-L-0014, 4410-90-L-14, NUDOCS 9003150368 | |
| Download: ML20012B587 (6) | |
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s GPU Nuclear Corporation Q
f Post Office Box 480 l
Route 441 South -
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- Middletown, Pennsylvania 17057-0191.
717 944 7621 TELEX 84 2386 Writer's Direct Dial Numtier:
wi (717) 948-8400
.s c March 7, 1990 4410-90-L-0014/0523P 1
A US Nuclear Regulatory Commission Washington, DC.
20555
' Attention: '. Document Control Desk
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Three Mile Island Nuclear Station,. Unit 2 (TMI-2)
Operating License No. OPR-73 j
Docket No. 50-320 r
Recovery Operations Plan Change Reauest No. 45 j
Dear Sirs:
Attached for NRC review and approval is Recovery Operations Plan Change
-l Reouest'(ROPCR).No. 45. This proposal. modifies the surveillance requirements for certain criticality monitors as specified in Table 4.3-3 of the TMI-2
- Recovery Operations Plan; l
. Sincerely,
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M. B. Roche-Director, TMI-2 JJB/ emf:
Attachment'
' cc:. W.. T.: Russell'- Regional Administrator, Region I J.' F. Stolz - Director, Plant Directorate 1-4 L. H. Thonus - Project Manager,. TMI Site l4:
' F. I. Young - Senior Resident Inspector, TMI-l' i
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.GPU Nuclear Corporaign'is a subsidiary of the General Public Utilities Corporation 9003150368-900307 9
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Threa Mils Island Nucitar Station, Unit 2.(TMI-2) i
- Operating Lic;nse No. DPR-73 Docket No. 50-320 Recovery Operations Plan Change' Recuest (ROPCR) No. 45
.The Licensee reouests that attached pages 4.3-5 and 4.3-7 of the Recovery Operations Plan (ROP) replace existjrvj pages 4.3-5 and 4.3-7.. This change
'Ieouest deletes the reouirement to maintain the EndPitting Storage Area criticality monitor following entry into Facility Mode 2, the Fuel Transfer Canal criticality monitor following entry into Facility Mode 2 and completion of the transfer of Defueling Water Cleanup System (DWCS) filter canisters to the Fuel Handling Building (FHB), and the Fuel Pool "A" and FHB Truck Bay j
criticality monitors following entry into Facility Mode 3.
1 Description of Change j
The proposed revision to the surveillance reouirements for the Fuel Transfer Cnnal, Fuel Pool "A", FHB Truck Bay, and Endfitting Storage area criticality
. monitors adds a Facility Mode designation to the Applicability Statement for each of these monitors.
Reason for Change The changes proposed in the R0PCR reflect the f act that the reouirement to maintain tnese criticality monitors can be related to specific TMI-2 Facility Modes. For example, transition from Facility Mode 1 to Facility Mode 2 -
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- establishes, by definition, that a criticality event in the TMI-2 Reactor Building has been precluded. Therefore, the Endfitting Storage Area criticality monitors are no longer needed.
Likewise, the transition from Facility Mode 2 to Facility Mode 3 occurs following completion of the Fuel Shipping Program; no canisters containing core material are stored'on the TMI-2 site. The' storage location for these canisters is the Fuel Pool "A" in the FHB..Thus, after the last canister is transferred from Fuel Pool "A" to a shipping cask and' shipped off-site, there will: be no need.for the Fuel Pool "A" and FHB Truck Bay criticality monitors.
LThe Fuel Transfer Canal. criticality monitors present a slighMy different case. Although a criticality event in the Reactor Building is precluded'in Facility' Mode 2, some DWCS filter canisters may remain in the Reactor Building.1 -Transfer of these canisters to the FHB reouires monitoring in accordance with 10 CFR 70.24. Therefore, the applicability statement for this monitor recuires its. surveillance until transition to Facility Mode 2 and all
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'DWCS filter canisters must have been transferred to the FHB.
~ Safety Evaluation Justifying Change Criticality monitors are reouired by 10 CFR 70.24 in order to detect a criticality in an area where Special Nuclear Material (SNM) in excess of a
. minimum ouantity (450 grams of contaired SNM) is handled, used, or stored.
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Ho' wever, monitors are not Itouired when' SNM is handlsd or stored beneath catar
.shiilding Cr etn it is 'transportGd when pickaged in accortEnce tith the reouirements of 10 TR Part 71. GPU Nuclear's Defueling Completion Report
. (GPU' Nuclear. letter 4410-904.-0012 dated February 22, 1990) contains an evaluation of the cuantity of fuel remaining in the Endritting Storage Area.
containers, the Fuel Transfer Canal, and Fuel Pool "A" (external to defueling canisters). Conservatively assuming 3% enrichment, these areas contain less than 250,- 400, and 150 grams, respectively, of SNM extemal to the oefueling.
canisters.. (NOTE: There is no measurable residual fuel in the FHB Truck l
Bay.) Thus, each of these areas contain less than 450 grams of SNM extemal L
to.the defueling canisters. :In addition, the safety evaluation performed by i
the NRC and provided in the May 27, 1988, exemption from 10 CFR 70.24, It
" Criticality Accident Recuirements" for TMI-2,. supports this reouest for deletion of criticality monitoring in the Reactor Building upon transition to Facility Mode 2.
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Prior to the transition to Facility Mode 2, all defueling canisters will be 1
transferred from the Reactor Vessel to Fuel Pool "A"; DWCS filter canisters that.may remain.for water cleanup activities will be stored underwater in the Fuel Transfer Canal. Therefore, upon transition to Facility Mode 2, deletion of the requirement to maintain the Endfitting Storage Area criticality mortitor is appropriate. Futher, upon transition to Facility Mode 2 and transfer of all DWCS filter canisters to the FHB, deletion of tne reouirement to maintain the Fuel Transfer Canal criticality monitors is appropriate.
Finally, prior to transition to Facility Mode 3, all defueling canisters,
. including those which may have been used for water cleanup activities, will have been transferred to a licensed fuel shipping cask and shipped off-site.
Therefore, upon transition to Facility Mode 3, celetion of the reouirement to
. maintain the Fuel Pool "A" and FHB Truck Bay criticality monitors is appropriate.
10 CFR 50.59 Evaluation 10 CFR 50.59 allows a licensee to make changes.in the facility without prior Commission approval provided the proposed change does not involve a change in the Tech. Specs, incorporated in the license or an unreviewed safety
.ouestion. The proposed revision to the ROP does not involve a change to the TMI-2. Tech. Specs, currently incorporated in the license. The pIuposed change l:
shall be deemed to involve an unreviewed safety cuestion:
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-If the probability of occurrence or the consecuences of an accident or malfunction of eouipment important to safety previously evaluated in the i
safety analysis report may be increased; or i
2.
If the possibility of an accident or malfunction of a different type than l'
any evaluated previously in the safety analysis report may be created; or l '3.
If the margin of-safety,.as defined in the basis for any Technical
-Specification, is reduced.
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-Ha's the probability rf occurrenc7 or the consecuences of an accioent or malfunction of Louipment important to safwty previously evaluatud in the F
safety analysis report been increased?
The proposed revision does not ircItase the probability of occurIence or the consecuences of an accident or malfunctiun of eouipment-important to safety.
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The underlying purpose of these monitors'is to provide personnel radiation
. protection by detecting inadvertent criticality events. GPU Nuclear's'
- Defueling Completion Report demonstrates that the possibility of an inadvertent criticality has been precluded at TMI-2. Further, by modifying the-applicability ~ statements for these monitors to be contingent on defined
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facility conditions, an exemption from the reouirements of 10 TR 70.24 is not reouired.
Has the possibility of an accident or malfunction of a different type than any evaluated previously in the safety analysis report been created?
The' proposed revision does not cIsate the possibility of. an accident or malfunction of a different type than any previously evaluated. These monitors are reouired for personnel protection in the event of an inadvertent criticality. As preclusion of an inadvertent. criticality is an underlying reouirement for transition to Facility Mode 2 (for the Reactor Building) and Facility Mode 3 (for tho.TMI-2 facility), a different type of accident or' malfunction is not created.
Has the margin of safety, as defined in the basis for any Technical Specification, been reouced?
The Technical Specification basis for reCFJiring these monitors is to be able to detect-radiation levels that may be present as the result of an inadvertent criticality. As Nmoval of these monitors is contingent on demonstrating that an inadvertent criticality has been precluded, the margin of safety has not been reduced.
Therefore, pursuant to 10 CFR 50.59, this proposed change does not zusult in an unreviewed safety ouestion.
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. TABLE'4.3 (Cont'd)
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. RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS 3
m NOTES:
(Cont'd) l h
- 11. Mode 1 and 2 (until all DHCS' filter canisters have been transferred to the Fuel Handling Building) j during either of the following' operations.
a.
Handling of canisters containing core material.*
E b.
Handling of any heavy load over canisters containing core materials.
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- 12. With'less than one channel operable, terminate the following operations:
a.
Handling of. canisters containing core material.*
b.
Handling of any heavy load over canisters containing core materials.
- 13. With less than one channel operable, effluents releases via the affected pathway may continue for up'to-thirty (30) days provided that samples are continutously collected with auxillary sampling equipment within the HHPF. These auxiliary filter samples will be changed daily and a gamma scan performed within 24-hours. After completion of the gamma scan, an analysis for gross alpha, gross beta, and y
Sr/Y-90 activities will be completed within 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br />.
- 14. Mode 1 during periods when personnel are in the containment and er.d fittings are being transferred to or stored in their designated location outside the Reactor Vessel.
- 15. With less than one-channel operable, terminate the following operations:
a.
Handling of end fitting storage containers outside the Reactor Vessel.**
b.
Handling of any heavy load over the end fitting storage container area.
- 16. Modes 1 and 2 during either of the following operations.
a.
Handling of canisters containing core material.*
b.
Handling of any heavy load over canisters containing core materials.
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- This shall not prohibit placing a canister in transit in a safe storage location.
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- This shall not prohibit placing an end fitting' storage. container in transit in a. safe storage location.
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. TABLE-4.3-3 (Cont'd) w RADIATION MONITORING INSTRUMENTATION SURVEILLANCE REQUIREMENTS.
'3E CHANNEL MINIMUM N
CHANNEL CHANNEL.
FUNCTIONAL:
CHANNELS E
FUNCTIONAL UNIT CHECK CALIBRATION TEST OPERABLE APPLICABILITY-ACTION 5.
FUEL TRANSFER' CANAL e:5 Note.12 a.
Criticality Monitor D-R H
I Note 11
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6.
FUEL POOL "A" a.
Criticality Monitor D
R M
1 Note 16 Note 12 7.
FUEL HANDLING BUILDING TRUCK BAY a.
Criticality Monitor D
R H
1 Note 16 Note 12'~
a 8.
HASTE HANDLING AND PACKAGING FACILITY a.
Exhaust Monitor D
R M
- 1 ~
Note 1 Note 13' 9.
REACTOR BUILDING a.
End Fitting Storage Area' D
R M
1 Note 14 Note 15 Criticality Monitor 8
(See following pages for Notes)
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