ML20056F017

Safety Evaluation Accepting Proposed Changes to Pdms Requirements & Commitments List of 930115

ML20056F017
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Site:	Crane
Issue date:	08/05/1993
From:	Office of Nuclear Reactor Regulation
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NUDOCS 9308250407
Download: ML20056F017 (13)

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NUCLEAR REGULATORY COMMISSION 7

' hs4 WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO FACILITY OPERATING LICENSE N0. DPR-73 l

GPU NUCLEAR CORPORATION THREE MILE ISLAND NUCLEAR STATION. UNIT NO. 2 DOCKET NO. 50-320 i

1.0 INTRODUCTIO_y By letter dated May 28, 1993, GPU Nuclear Corporation (GPUN or the licensee) requested changes to the NRC approved list of remaining Post Defueling Monitored Sterage (PDMS) requirements and commitments.

These requirements and commitments were originally forwarded to the NRC in a letter dated January 15, 1993. The January 15, 1993 list was developed by the NRC staff and the licensee during a series of meetings at the THI-2 site during the fall of 1992. The NRC staff reviewed the January 15, 1993 list and approved the list in a letter dated May 19, 1993. The approved list included a procedure to allow for changes to the list of requirements and commitments in recognition of the difficulties associated with readying the facility for long term storage and the changeable nature of the effort.

2.0 DISCUSSION AND EVALUATION The May 28, 1993 submittal by the licensee requested changes to the approved list. The licensee requested to correct a number of typographical errors in the list and to delete several items. The staff evaluation of each of the proposed changes by the licensee to the PDMS list of requirements and commitments are as follows:

(1)

Item A.6, change the disposition of the "B" spent fuel pool from " drain and shield" to " drain and cover."

Evaluation: The original list requires the licensee to drain and shield the "B" spent fuel pool. The licensee requested that this requirement be changed 4

to " drain and cover." The licensee has determined that no shielding is necessary since the general area radiation levels emanating from the pool are below the level that requires shielding. The staff finds the change acceptable.

(2)

Item A.7, change the citation of the requirement or commitment.

Evaluation: The January 15, 1993 list references the PDMS Safety Analysis Report (PDMS SAR) Supplement 4, Item 1.

The licensee proposes changing the _

citation to the PDMS SAR Section 6.2.3.2.

Amendment 17 to the PDMS SAR, dated May 28, 1993, deletes the commitment from Supplement 4, Item 1, and adds the i

commitment to the PDMS SAR Section 6.2.3.2.

The staff finds this administrative change acceptable.

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. (3)

Item C.5, change the reference to Supplement 3, Item B-3 to B.3.

Evaluation: This is an administrative change that corrects an incorrect reference to a response in Supplement 3 to the PDMS SAR. The staff finds this administrative change acceptable.

(4)

Item D.2, change the reference to PDMS SAR 5.3.2.

Evaluation: The January 15, 1993 reference to PDMS SAR Section 5.4.3 for this item was in error. The correct reference is the PDMS SAR Section 5.3.2.

The staff finds this administrative change acceptable.

(5)

Item H.7, change the reference to PDMS SAR 7.2.5.2.2.

Evaluation: The January 15, 1993 reference to PDMS SAR Section 7.2.5.2.5 for-this item should be changed to PDMS SAR Section 7.2.5.2.2.

The staff finds this administrative change acceptable.

(6)

Item H.9, delete this commitment.

Evaluation: The purpose of.this requirement is to provide a backup power source to support onsite radiation monitoring at TMI-2 during a temporary loss of power. The licensee has requested that this requirement for a backup power source be deleted.

During a temporary loss of power, all active ventilation at TMI-2 would cease.

Monitoring of plant release pathways that normally have active ventilation is unnecessary when there is no active ventilation.

The staff finds the change acceptable.

(7)

Item I.1, change the reference to SAR 7.2.2.2.2k to SAR 7.2.2.2k.

Evaluation:

This is an administrative change that corrects an incorrect reference to a section in the PDMS SAR. The staff finds this administrative change acceptable.

(8)

Item I.2, delete the parenthetical reference to the auxiliary transformers.

Evaluation:

The January 15, 1993 list of requirements and commitments states that areas and systems that contain significant amounts of combustibles and j

possible ignition sources should have a fire suppression system.

The licensee provides as an example, in parenthesis, the auxiliary ' transformers.

Since the submission of the January 15, 1993 list, the licensee has decided not to use l

the auxiliary transformers for powering TMI-2, therefore there is no need for a fire suppression system for the auxiliary transformers. The staff finds the change acceptable.

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-> (9)

Item I.6, change the reference to PDMS SAR 7.2.2.2d.

Evaluation: The January 15, 1993 reference to PDMS SAR Section 7.2.2.2d for this item was in error. The correct reference is the PDMS SAR Section 7.2.2.2d.

The period was inadvertently omitted from the end of the reference citation. The staff finds this administrative change acceptable.

(10)

Item I.10, delete this commitment.

Evaluation: The January 15, 1993 list requires that freeze _ protection be added to the applicable portions of the fire main. The assumption was made by the licensee that there would be no active heating or ventilation of the fire main. The licensee has determined that heating and ventilation systems that affect the fire main will remain operational during PDMS, therefore no supplemental freeze protection measures need to be taken provided that the licensee documents the commitment to maintain operation of the heating and ventilation in the next PDMS SAR amendment. The staff finds the change acceptable.

(11)

Item I.13, delete reference to PDMS SAR Supplement 1, Item 14.

Evaluation:

Item I.13 of the January 15, 1993 list references PDMS SAR Supplement 1, Item 14. The licensee's May 28, 1993 submittal included Amendment 17 to the PDMS SAR.

Amendment 17 revised Supplement 1, Item 14 and it no longer addresses the issue of the operability of the river water pump house.

The staff finds the change acceptable.

(12)

Item I.14, change this requirement from turning over the fire pump house and fire pump 2/FS-P-1 to Unit I to deactivate the fire pump house.

Evaluation:

Item I.14 of the January 15, 1993 list described the turnover of the fire pump house and fire pump 2/FS-P-1 to Unit 1.

The May 28, 1993 revision to the list states that the fire pump house will be deactivated.

TMI-1 has decided not to maintain the TMI-2 diesel fire pump 2/FS-P-1 as an additional emergency backup fire supply source. The site yard fire' main, which provides fire supply source water for both TMI-l and TMI-2, will continue to be supplied by the TMI-I pump house and fire pumps. During PDMS, l

the TMI-2 facilities and the systems within these facilities serve no active i

or pa -ive function and therefore no longer need to be maintained operational.

The staff finds this change acceptable, i

-(13)

Item I.16, delete the terms " steam generator feedwater pumps" and

• reservoirs" and add the terms "feedwater pump turbines", " emergency feedwater pump turbine", and " condensate pumps."

Evaluation:

Item I.16 of the January 15, 1993 submit.tal lists secondary components that shall be drained of oil to the extent reasonably achievable.

The component " steam generator feedwater pumps" is redundant with~the term

" main feedwater pump" and is being deleted. The term " reservoirs" is being r

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I deleted from the term " condensate booster pump reservoirs" since specifying only the reservoirs is more restrictive than specifying the entire component.

Additionally, the licensee proposes to add to the list of components or systems that require draining the feedwater pump turbines, emergency feedwater i

pump turbine and the condensate pumps. The staff finds the changes acceptable.

(14)

Item J.6, delete this requirement.

i Evaluation:

Item J.6 of the January 15, 1993 submittal requires that the j

licensee verify that freeze protection has been provided for portions of the i

Waste Disposal liquid (WDL) system that are determined to be subject to freezing due to deactivation of the building ventilation systems.

Originally, the Auxiliary and Fuel Handling Building ventilation systems were to be deactivated during PDMS. The licensee has decided to maintain operability of the building ventilation system. The staff finds the change acceptable, provided that the licensee documents the commitment to operate the heating and ventilation systems, as necessary, to provide freeze protection during PDMS.

(15)

Item J.7, delete this requirement.

Evaluation:

Item J.7 of the January 15, 1993 submittal requires that the licensee verify that alternate provisions have been provided for operating the j

air-operated valves required for the WDL system during PDMS.

Originally the licensee planned to deactivate the instrument-air supply system during PDMS.

However, the liccnsee has decided to maintain the instrument-air system.

Therefore, until the licensee deactivates the instrument-air system, no alternate means of operating the WDL valves need to be considered. The staff finds the change acceptable.

(16)

Item K.1, change the reference to Supplement 3, Item A-16 to A.16.

Evaluation: This is an administrative change that corrects an incorrect reference to a response in Supplement 3 to the PDMS SAR.

3.0 CONCLUSION

The proposed changes to the PDMS requirements and commitments list of January 15, 1993 that were submitted to the staff in Amendment 17 to the PDMS SAR will not adversely affect the health and safety of the public. These changes do not constitute an unreviewed safety question, nor do they involve a significant hazard or an environmental impact.

The changes described fall within the bounds of Final Supplement 4 to the Programmatic Environmental Impact Statement issued by the staff in August 1989.

Principal Contributor: Michael T. Masnik

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Date:

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ENCLOSURE i

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LIST OF PDMS i

i REQUIREMENTS AND COMMITMENTS i

REVISION 1 i

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o Additional Reauirements/ Licensee Commitments l

A.

Removal of Water from Reactor Coolant System and Fuel Transfer Can._al 1.

Remove water to the extent reasonably achievable.

l Reactor Vessel; drained to less than 10 gallons (38 liters) of water. (SAR 6.2.27.2; TER 5-9)

Reactor Building Fuel Transfer Canal. (TER 5-9) 2.

Isolate the fuel transfer tubes. (SAR 1.1.2.1).

3.

Drill holes in canal seal plate to prevent refueling canal fmm filling. (TER 5-9) 4.

Cover the Reactor Vessel to minimize water entry. (SAR 6.2.27.2) 5.

Drain the Submerged Deminemlizer System to the extent reasonably achievable.

l (SAR 6.2.36.2) 6.

Drain and cover the "B" spent fuel pool to the extent reasonably achievable.

(SAR 6.2.36.2) 7.

Dmin and cover the "A" spent fuel pool to the extent reasonably achievable.

(SAR 6.2.3.2)

B.

Badiation Safgty & Reduction of Potential for Releases 1.

Ship offsite or package and stage for shipment remaining radioactive waste from the major TMI-2 decontamination activities. (SAR 1.1.2.1; TER xiv) 2.

Reduce radiation levels within the facility, to the extent reasonably achievable and consistent with ALARA, to allow plant monitoring, maintenance, and inspection.

(SAR 1.1.2.1; TER xiv) 3.

Apply shielding in critical locations after reactor vessel dmindown to reduce dose rates. (TER 5-23) 4.

Define and establish an ovemll surveillance progmm plan for PDMS envimnmental protection systems to ensure public health and safety. (TER xiv) 1 Revision 1 l

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C.

Ventilation 1.

Verify that a surveillance pmgram exists to ensure AFHB ventilation and filtration operability, maintenance and testing. (SAR 7.1.2 and 7.1.3; TER 6-26) 2.

Verify that the licensee has procedures in place to continue to operate the AFHB ventilation system until the Accident Generated Water is no longer being processed or transferred in the AFHB. (TER 6-28) 3.

Ensure that penetration R-626 has been upgraded to 5 psi. (SAR Supp. 3, Item B.2; TER 6-17) 4.

Ensure that the reactor building breather system is the predominant pathway for effluent and influent to the building during those times that the reactor building ventilation system is not being operated; and that the effluent is filtered and monitored. (SAR 7.2.1.2; TER 6-25).

5.

DOP test the HEPA filter in breather prior to entry into PDMS. (SAR 7.2.1.2.2 and Supp. 3, item B.3; TER 6-25) l 6.

Ensure installation, actuation setting, and routine surveillance testing of the isolation valve between containment and HEPA filter in the reactor building breather (to automatically close upon receipt of a containment pressure increase of 0.25 psi). (SAR 7.2.1.2; TER 5-10,5-11, and 6-24) 7.

Develop and implement a reactor building entry pmcedure that requires an evaluation of the reactor building atmospheric conditions prior to personnel entry.

(SAR 7.2.1.3) 8.

Develop and implement procedures for maintaining HEPA filter banks for the Reactor Building Purge System.(SAR 7.2.1.3) 9.

Develop and implement procedures for monitoring the Reactor Building vent during reactor building purge. (SAR 7.2.1.3)

D.

Plant Contamination Survey 1.

Licensee will meet established contamination level goals for entrance into PDMS for each area of the AFHB. If the decontamination goals cannot be met because of the unique situation at TMI-2 or ALARA considerations, the licensee will provide an evaluation of the specific situation to the NRC. (SAR 5.3.1 and Supp.

3, Item A.ll; TER p. 4-2) 2 Revision I

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2.

Update information in the following tables from the SAR as fmal decontamination results become available. (SAR 5.3.2)

- Table 5.3-2 (SAR) "PDMS Radiological Conditions - AFHB"

- Table 5.3-4 " Surface Contamination - Reactor Building"

- Table 5.3-5 " Surface Contamination - AFHB"

- Table 5.3-6 " Surface Contamination - Other Buildings" 3.

Perform survey of the service building, elevation 305 ft.; the turbine building, elevation 281 ft. and the containment air control envelope building and provide infonnation in the PDMS SAR befom entry into PDMS in order to establish a radiological baseline for the facility. (SAR 5.3.2; TER 4-2) 4.

Ensure that a program exists for periodic measurement of radiation and contamination levels to verify radiological conditions. (SAR 7.2.4.1 and 7.2.4.2; TER 6-42 and 6-43).

E.

Physical Maintenance in Reactor Buildine and Vessel 1.

Have the capability of inserting a video camera into the reactor vessel to verify fuel location if it is determined at a later time that such an examination is required. (TER 6-3) 2.

Create a program plan to perform monthly entries into the reactor building for at least 6 months after placing it into its PDMS condition. (PDMS SAR 7.2.4; TER 5-23)

F.

Physical Maintenance in AFHB 1.

Create a program plan to perfonn monthly entries into the AFHB for at least 6 months after placing it into its PDMS condition. (SAR 7.2.4; TER 5-23) 2.

Ensure that both fuel pool structures remain intact (SAR 7.1.3.2)

G.

Physical Maintenance in other Buildings 1.

Ensure that the Control Room Ventilation Systems (i.e., Control Room HVAC and Cable Room HVAC) and the Service Building Ventilation System are maintained in an operational condition and will be operated as required. (SAR 7.2.6.8,9,10) 3 Revision 1

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Maintain the capability to process potentially contaminated liquids.

(SAR 7.2.3.1; TER 5-14)

H.

Electrical Related 1.

In reactor contamment, reactor building electric power circuits will be deenergized except those necessary for PDhiS monitoring, inspection, and surveillance equipment and other PDhiS suppon requirements. (SAR 7.1.1.4; Supp.1, Item 17; TER 6-34 and 6-38)

I 2.

In the auxiliary building, the power to lighting, fire detectors, and sump level indication circuits will be energized and will remain operational. The aux 1hary sump, auxiliary sump tank and associated level indication will also remain operational. (SAR 7.1.2.2; TER 6-37) 3.

In the fuel-handling building, low voltage circuits to lighting and fire detection will be energized. (SAR 7.1.3.2; TER 6-37) 4.

In the Control and Service Buildings, verify that the electrical distribution will remain configumi to power low voltage lighting loads and fire detectors. (SAR 7.1.7.2) 5.

Ponions of the Thil-2 electrical distribution system will be operational and energized to pmvide power for the PDhiS suppon systems and their associated controls and instmmentation.

Power will be available for area lighting, i

receptacles, heating, and ventilation to suppon PDMS activities. (SAR 7.2.5.1.1; TER 6-37) 6.

Emergency lighting (8-hr ponable emergency lights) is staged with emergency response crew equipment. (SAR 7.2.5.2.1; TER 6-37) 7.

Verify that exit signs are powered from the normal lighting system and from a locally mounted battery during emergency conditions. (SAR 7.2.5.2.2) 8.

DC power during PDhiS will be available. Loads have been consolidated where practicable to reduce the number of energized circuits. (SAR. 7.2.5.1.3; TER 6-38) 9.

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Fire Protection 1.

Have procedures in place to ensure that the file mains within the reactor building will be closed with valves drained to the extent reasonably achievable within 30 days following entry into PDMS to minimize the potential for introduction of water into the reactor vessel. (SAR 7.2.2.2k.; TER 6-2) 2.

Ensure that automatic fire suppression is provided and maintained to areas of the facility and systems which contain significant amounts of combustibles and l

possible ignition sources. (SAR 7.2.2.1) 3.

Ensure that either the DiI-2 control room or some other location is continuously manned with a fully qualified person or that remote monitoring capabilities are available in DII-1 control room to identify the specific zone in which a fire in the DiI-2 facility is located. Ensure that procedural control exists to delineate the location of the monitoring activity. (TER 6-29; SAR 7.2.2.2b.)

4.

Demonstrate that DiI-1 Operations has accepted responsibility for maintaining the fire service system in operable areas of the plant as required to support operations; in the waste-handling and packaging facility, the respirator cleaning facility and the administration building. (TER 6-29) 5.

Deactivate deluge systems in the auxiliary building and the control building. (SAR 7.2.2.3; TER 6-29) 6.

Ensure that all Halon systems have been deactivated by disconnecting the cylinders and either emptying or removing them. (SAR 7.2.2.2d.)

7.

Verify that portable fire extinguishers are located in the areas specified in Figures 7.2-6 and 7.2-7 of the SAR. (SAR 7.2.2.2e.)

8.

Verify that self-contained breathing apparatus are available for fire fighting 4

purposes in the areas shown on Figures 7.2-6 and 7.2-7 of the SAR. (SAR 7.2.2.2f.)

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9.

Ensure that the fire detection system remains operational in the Air Intake Tunnel and the relay room. (SAR 7.2.2.2d.)

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10.

Deleted.

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i 11.

To the extent that fire protection is not required in work or storage areas, ensure isolation of the 12-inch fire service loop, which runs through the AFHB, the control building area and the turbine building (east and west). (SAR 7.2.2.2k.;

i TER 6-32) 12.

Ensure that the fire system line is cut and 'olanked off at the fuel-handling building, where the fire system line runs from the diesel generator building. (SAR 7.2.2.2k.; TER 6-32) 13.

Deactivate the river water pump house. (SAR 6.1.10; TER 6-33) 14.

Deactivate the fire pump house. (SAR 6.1.10 and Supp.1, Item 14; TER 6-33) 15.

Ensure that transient combustibles have been removed from inside the containment and the.AFHB to the extent practicable. (SAR 7.2.2.2g.; TER 6-33)

This includes most plant items installed after the accident. Fire loading must be less than a 1-hour loading of 80,000 BTU / square foot. (SAR Supp.1, Item 17) 16.

Drain oil to the extent reasonably achievable from the main turbine, feedwater pump turbines, emergency feedwater pump turbine, main feedwater pumps, emergency feedwater pumps, condensate pumps, condensate booster pumps and hydrogen seal oil unit. (SAR 7.2.2.2h.; TER 6-34) 17.

Taken as an aggregate, demonstrate that no more than 57 percent of the original total volume of reactor coolant pump lubricating oil remains in the upper and lower reservoirs of the four reactor coolant pump reservoirs. (SAR Supp.1, Item 33; TER 6-34) i 18.

Charcoal filters have been removed from all HVAC systems in TMI-2. (SAR 7.2.2.21.; TER 6-34)

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19.

Train and familiarize station fire brigade with the TMI-2 system configurations, plant layout and procedures for TMI-2. (SAR 7.2.2.2m.; TER 6-35) 20.

Procedure in place for reactivation of the deactivated portions of the fire t

protection system if necessary. (SAR 7.2.2.21.; TER 6-29) 21.

Verify that the procedure for inspection of the fire loop drain valves during freezing weather is in place. (SAR 7.2.2.2k.; TER 6-32) i 22.

Verify that the procedures and system are in place for testing of the operable i

ponion of the fire detection and alann system. (SAR 7.2.2.2b.; TER 6-34) 1

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23.

Verify that procedures for manual suppression of fire by the fire brigade are provided as stated in the FPPE. (TER 6-35) i J.

Flood Protection 1.

Ensure that flood panels are provided for all entrances to the control building, and to the entrance of the auxiliary building. (TER 6-36) Doors and entrances to the Control Building Area that are not flood-protected are either watertight or are provided with flood panels. All openings that are potential leak paths (i.e., ducts, pipes, conduits, cable trays) are sealed. (SAR 7.1.4) 2.

Verify that the containment basement and auxiliary building sumps level indications will be maintained. (SAR 7.2.3.1.2) 3.

Verify that the auxiliary building sump pumps are maintained operational and placed in a manual control mode. (SAR 7.2.3.1.2) 4.

Verify that the Miscellaneous Waste Holdup Tank and the Auxiliary Building Sump Tank (ABST) have been isolated from the Radwaste Disposal Gas System and vented via HEPA filters to protect against airborne releases from these tanks.

(SAR 7.2.3.1.2) 5.

Ensure that a flow path exists to dmin down the reactor building basement floor.

(SAR 7.2.3.1.2) 6.

Deleted 7.

Deleted 8.

Ensure that the active sumps have a high level alarm that armunciates in the e

control room and the PDMS Alarm Monitoring System. (SAR 7.2.3.2.2)

K.

Procedures and Programs 1.

Include a surveillance program under which a limited number of rodent carcasses j

will be analyzed for gamma-emitting isotopes as part of the non-routine Radiological Environmental Monitoring Program. (SAR Supplement 3, A.16) i 7

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STANDARDS FOR SATISFYING REOUIREhiENTS AND COhihilThiENTS The staff recognizes that many of the above requirements and commitments have been i

acted upon by the licensee. Once this list is finalized, the licensee will submit a letter that documents which of the listed requirements and commitments have been satisfied.

The letter will reference primary documentation (UWIs, procedure numbers, drawings, etc.) that demonstrate ihat the work was completed or the requirement or commitment met. It will not be necessary to submit the primary reference documents but only have them accessible at the ThiI-2 site. The staff will verify by reviewing the primary documentation and/or inspection of the actual modification. Once the staff has conducted its review and determined that the requirement or commitment has been satisfied, the staff will close out the item. As other items are completed, the licensee will continue to notify the staff in writing of the completed status and identify the appropriate primary references. The staff and licensee plan to agree prior to notification of completion of an item what constitutes the standard for demonstrating completion of the item.

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PROCEDURES FOR CHANGING THE ABOVE REOUIREhiENTS AND COhihfIThfENTS During the remainder of the current cleanup effon, conditions may change resulting in a change in the licensee's ability to satisfy the above requirements and commitments.

Licensee's request for deviations to the above list of requirements and conditions must be made in writing, as an amendment to the SAR, providing a description of the old requirement or commitment and a description of the change. The deviation request must include a safety analysis evaluating the proposed change. Requests for deviations to the above list must be timely and allow for staff review (typically 60 days). The NRC staff t

will either approve or disapprove the licensee's request in writing based on the results of the staff review. The licensee understands that PDhiS was evaluated and received t

staff approval based on the requirements and commitments made by the licensee through SAR Amendment 15. Significant changes to the requirements and commitments may invalidate, or require a reevaluation of the staff's Safety Evaluation and Technical Evaluation Report.

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