ML20058F748

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TS Change Request 233 to License DPR-50 Re Removal of LCO & Surveillance Requirements for Chlorine Detection Sys from Current TS
ML20058F748
Person / Time
Site: Crane Constellation icon.png
Issue date: 12/02/1993
From: Broughton T
GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20058F734 List:
References
NUDOCS 9312080268
Download: ML20058F748 (4)


Text

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METROPOLITAN EDIS0N COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRICAL COMPANY GPU NUCLEAR CORPORATION Three Mile Island Nuclear Station, Unit I (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 Response to Technical Specification Change Request No. 233 COMMONWEALTH OF PENNSYLVANIA )

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COUNTY Of DAUPHIN

)

This Technical Specification Change Request is submitted in support of Licensee's request to change Appendix A to Operating License No. OPR-50 for Three Mile Island Nuclear Station, Unit 1.

As part of this request, proposed replacement pages for Appendix A are also included.

GPU NUCLEAR CORPORATION BY:

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Vice President and Director,lMI-l Sworn and sub cribed before me this R M day of e v, 1993.

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UNITED STATES OF AMERICA.

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.i NUCLEAR REGULATORY COMMISSION

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IN THE MATTER OF DOCKET NO. 50-289 GPU NUCLEAR CORPORATION LICENSE NO. DPR-50 i

CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No.

233 to Appendix A of the Operating License for Three Mile Island Nuclear Station Unit 1, has, on the date given below, been filed with executives of Londonderry Township, Dauphin County, Pennsylvania; Dauphin County, Pennsylvania; and the Pennsylvania Department of Environmental Resources, i

Bureau of Radiation Protection, by deposit in the United States mail, addressed as follows:

Mr. Daryl LeHew, Chairman Mr. Russell L. Sheaffer, Chairman i

Board of Superviscrs of Board of County Commissioners Londonderry-Township of Dauphin County R. D. #1, Geyers Church Road Dauphin County Courthouse Middletown, PA 17057 Harrisburg, PA 17120 t

Director, Bureau of Radiation Protection PA. Department of Environmental Resources

- i Fifth Floor, Fulton Building P.O. Box 2063 i

Harrisburg, PA 17120 l

Att: Mr. Richard R. Janati i

k GPU NUCLEAR CORPORATION l

BY:

Vice President gnd Director, THI-1 DATE:

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i C311-93-2081 I.

TECHNICAL SPECIFICATION CHANGE REQUEST (TSCR) NO. 233 GPUN requests that the following changed replacement pages be inserted l

into the existing Technical Specification:

l Revised pages:

ii, 3-40f, 4-7a These pages are attached to this change request.

II.

REASON FOR CHANGE THI-I removed the gaseous Chlorination System for the Circulating Water and River Water Systems. This modification eliminated the need for a Chlorine Dectection System (CDS) which was designed to automatically isolate the Control Room Building Ventilation System (CBVS) in the event l

of an accidental on-site release of chlorine from a one ton cylinder.

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The probability of an offsite chlorine release affecting the control room was calculated and presented (GPUN Letter 5211-84-2199) to the NRC l

staff on August 8, 1984. The probability of this event resulting in a radiation release in excess of 10CFR100 limits was 3.34 x 10-10 per year.

Since this probability was less than the 10-7 stated in Standard i

Review Plan Section 2.2.3, THI-l excluded this-event from the issue of Control Room Habitability.

III.

SAFETY EVALUATION JUSTIFYING CHANGE THI-l originally used a chlorine gas based system to prevent the growth of slime, bacteria and algae in the Circulating and River Water Systems.

for this purpose, THI-l stored liquid chlorine on-site at two locations, the River Water Chlorinator House and the Unit 1 Circulating Water Chlorinator House.

Since 2,000 pound containers were stored-at each location, TMI-1 installed a Chlorine Detection System (CDS) under the guidelines of Regulatory Guide 1.95 (Rev.1) to satisfy NUREG 0737, Item 111.D.3.4 requirements for control room habitability. The design basis of the CDS was to alarm and automatically isolate the control room in the event of an on-site chlorine gas release.

j i

The CDS consisted of two independent instrumentation channels with redundant detectors located at both the River Water Chlorinator House and the Air Intake Structure. The CDS was designed to provide interlocks with the CBVS for isolation and-signals for control room j

alarms.

The CDS was provided with redundant Class IE electrical power t

supplies. The interlocks and alarms were redundant and were designed so that the failure of one instrumentation channel would not prevent the CDS from performing its safety function.

i The CDS was designed so that the human toxicity limits of 15 PPM by l

volume (45mg/m3) were not exceeded in the control room within two (2).

minutes after the operators were made aware of'the presence of chlorine.

The control room operators were alerted of a chlorine release at any remote detector which allowed them two (2) minutes to don emergency l

breathing apparatus. A chlorine concentration of 5 PPM at any remote detector initiated isolation of the CBVS within. ten (10) seconds.

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THI-l has stopped using chlorine for the intermittent shock treatment of the Circulating and River Water Systems and removed the one ton cylinders. THI-1 has implemented administrative controls which prohibit the procurement and delivery of chlorine cylinders exceeding 150 pounds.

The sewage treatment system still uses 150 pound chlorine cylinders, but this facility is greater than 100 meters from the air intake structure.

GPUN reviewed information in the 1987 THI-l PRA to estimate the impact on the calculated Core Damage Frequency (CDF) due to chlorine releases from the sewage treatment plant. GPUN concluded the values assumed in the review were conservative and the contribution to CDF was negligible.

With the removal and the restriction on the delivery of one ton chlorine cylinders, the threat of an on-site chlorine release contributing to a radiological release is no longer credible.

Further, the TS limiting condition for operation and the surveillance requirements for the Chlorine Detection System are no longer required.

IV.

NO SIGNIFICANT HAZARDS CONSIDERATIONS GPU Nuclear has determined that this Technical Specification Change I

Request involves no significant hazards consideration as defined by NRC in 10 CFR 50.92.

1.

Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability of occurrence or the consequences of an accident previously evaluated.

The TS requirements assured the operability of the CDS in the event of an on-site chlorine release from a one ton cylinder. These TS requirements reduced the probability and the consequences of a radiological accident which may result from an incapacitation of control room operators after entry of chlorine into the control room. With the removal and the restriction on delivery of one ton chlorine cylinders, this postulated event is no longer credible, and there is a decrease in the probability of a radiological accident.

2.

Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated. The TS j

requirements associated with the CDS were for the on-site release of I

chlorine from a one ton cylinder.

These cylinders are removed and prohibited from the TMI-l site.

These actions preclude a significant on-site release of chlorine which could affect the control room operators.

3.

Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety.

The purpose of the TS requirements was to maintain operability of the CDS in the event of on-site release from a one ton chlorine cylinder. Since chlorine cylinders greater than 150 pounds are prohibited on-site, the TS requirements for chlorine detection are no longer required, and their removal will not reduce the margin of safety.

V.

IMPLEMENTATION It is requested that the amendment authorizing this change become effective upon issuance.

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