ML20059M346

Application for Amend to License DPR-50,consisting of Tech Spec Change 202 Re Operability of Purge Valves

ML20059M346
Person / Time
Site:	Three Mile Island
Issue date:	09/25/1990
From:	Hukill H GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20059M322	List: ML20059M320 ML20059M346 ML20059M350
References
NUDOCS 9010040095
Download: ML20059M346 (8)

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METROPOLITAN EDISON COMPANY JERSEY CENTRAL-POWER & LIGHT COMPANY AND-PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION, UNIT 1 Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No. 202 i This Technical Specification Change Request is submitted in support of Licensee's request to change Appendix A to Operating License No. DPR-50 for Three Mile Island Nuclear _ Station, Unit 1. As a part of this request,- proposed replacement pages for Appendix A are also included.

GPU NUCLEAR CORPORATION BY:

Vice'Presid6nt &-Director, TMI-1 l-Sworn and subscribed to beforp m9_this c

/4 day of dzo h l w ,2f1990.

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u t e>< f.

Notary PubH c LLtw l-i Sharon P. M, Ri4 k N M d 1I T E

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l 9010040095 900925 i PDR ADOCK 05000289 L P PDC

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UNITED STATES OF AMERICA NUCLEAR REGULATORY CottilSSION ,

IN THE MATTER OF DOCKET NO. 50-289 l

GPU NUCLEAR CORPORATION LICENSE NO. DPR-50  ;

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CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No. 202 [

to Appendix A of the Operating License for Three Mile Island Nuclear Station i 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, Bureau of Radiation Protection, by deposit in the United States mail, addressed as follows:

Mr. Kenneth E. Witmer, Chairman Ms. Sally.S. Klein, Chairman Board of Supervisors of Board of County Commissioners Londonderry Township :of Dauphin County 25 Roslyn Road Dauphin County. Courthouse Elizabethtown, PA 17022 Harrisburg, PA 17120 I

l l Mr. Thomas Gerusky, Director PA. Dept. of Environmental Resources Bureau of Radiation Protection P.O. Box 2063 Harrisburg, PA 17120 l

GPU NUCLEAR CORPORATIO M

BY:

1 Vic'e PresiBent & Director, TM1-1 l

DATE: September 25 -1990 L

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j Page 1- j I. ' TECHNICAL SPECIFICATION CHANGE REOUEST (Ti,CR)- NO. 202 l 1 l GPU Nuclear requests that attached pages 4-34'and-4-34b.

l_- replace existing pages 4-34 and 4-34b' in the TMI-1 y

i. Technica1 Specifications, q II. Descriotion of Technical Soecification Chances Tech. SDec. 4.4.1.7.2. "Ocerability of Purae Valves"

1. The first sentence has been r e v i s e d ' t'o r e q u i r e.- a durometer test, in addition to~ the visual. examination, as part of the refueling surveillant 3 for the Reactor:

Building (RB) purge valve seats.-

2. The last sentence, which currently states, "As a '

minimum, seats shall be: replaced at - th6 first refueling' interval following _5 years of seat service,"

has been deleted.

3. The phrase "and durometer testing"-has been added to the first sentence of the last paragraph-of the bases for Tech. Spec. 4.4.1'.7 (i.c.., page 4-34b).

III. REASON FOR CHANGE The proposed change negates the requirement to replace the -

RB purge valve seats at _ the 'first refueling: interval following 5 years of service.- The criteria for seat replacement should be based on Tech. Spec. surveillances associated with visual examination, _ leak rate testing, and durometer testing which are consistent L with the recommendations of the vendor (i.e. , Henry lPratt Company)

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for extended service. ' Replacing.the purge valve seats on a calendar frequency is not necesary~if the seats are in good physical condition as evidenced by periodic inspections, leak-testing, .and durometer testing. -This:

change will result in savi;.gs in direct costs, person-hours, and radiological dose associated with- the-replacement of the purge valve. seats without decreasing the effectiveness of the - seats or adversely affecting public health and safety.

IV. SAFETY EVALUATION JUSTIFYING CHANGE The requirement for purge valve' seat replacement in Tech.

Spec. 4.4.1.7.2 was added via License Amendment =108 dated -

May 8, 1985, which approved TMI-1 TSCR 166, Revision 1 (reference GPU Nuclear letter _ 5211-83-240 dated' November 24, 1983). The NRC safety evaluation attached to the~ i i

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Page 2 IV. SAFETY EVALUATION JUSTIFYING CHANGE (CONT'D.)

t referenced License Amendment states the following basis l for the requirements of Tech. Spec. 4.4.1.7.2:

"...the acceptance criteria provides reasonable assurance that gross seal deterioration will be detected in a timely manner and the seal replac' ament frequency (at least every 5 years) is in accordance with the manufacturer's recommendations."

The seats for RB purge valves AH-V-1A&B were last replaced in March 1985, and the seats f or RB purge valvec AH-V-20&D were last replaced in February 1985. Thus, pursuant to .

current Tech. Spec. 4.4.1.7.2, the seats for these valves  !

are currently scheduled for replacement during the 9R refueling outage schsduled to commence the thirA quarter i of 1991. However, based on the following justaication, GPU Nuclear believes that a replacement frequency for the purge valve seats is not requ:. red.

A. Vendor Guidance and Plant Inspection concerning the purge valve seats The RB purge valve seats are made of molded ethylene propylene terpolymer (EPT). The vendor (i.e., Henry Pratt Company) notes that the 5 year replacement criteria for EPT material is based on a recommended shelf life (reference Henry Pratt Company memorandum dated January 16, 1990, B.R. Cummins to P.E. Boucher) . -

However, the referenced memorandum statest.

"It is our opinion that EPT seats may be suitable for service af ter the specified five years, provided the material is properly stored, durometer hardness checks?,, and visuallf inspected for osone cracking prior to use."

l Thus, the current Tech. Spec. replacement frequency I

for the RB purge valve seats is based on the vendor's recommended shelf life. However, GPU Nuclear believes-that the above quoted vendor criteria - for extended i service life slso applies to in-service use, especially the recommendation for durometer testing.

Currently, the RB purge valves are leak tested in accordance with the requirements of 10 CFR 50 Appendix J (i.e., Tech. Spec. 4.4.1.2.5.c} and an interspace .

pressurization test is performed on a quarterly basis (i.e., Tech. Specs. 4.4.1.2.5.d and 4.4.1.7.1).

Additionally, during each refueling interval the purge

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IV. SAFETY EVALUATION JUSTIFYING CHANGE (CONT'D.)  !

l valve seats are visually examined for evidence of  !

l degradation (e.g., cracking, brittleness). These  !

i surveillances verify the operability of the purge valve seats.

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It is noteworthy that a durometer test was performed  ;

to check.the hardness of the purge valve seats during the 8R refueling outage. The results of the test were i satisfactory based on the vendor's criteria. The  !

proposed change adds a requirement for a durometer l 2 test as part of the refueling interval surveillance for the purge valve seats (i.e., Tech. Spec.

4.4.1.7.2) >

B. Thermal Aging 1 ,

GPU Nuclear has calculated (reference GPU Nuclear '

memorandum 5542-90-012 dated February 5, 1990) that i the purge valve seat material (i.e., E?T) will have a service life of at least 40 years when exposed to a l temperature of 120 F which is the normal ambient i temperature of purge valve AH-V-1C. The remaining l purge valves have ambient temperatures less than or equal to AH-V-1C.

C. Integrated Dose  ;

The purge valve seat material has a threshold '

radiation of 1 x 106 Rads gamma and mild to moderate damage (i.e. , 25% degradation) is expected to occur up to 2 x 108 Rads gamma. As of January 1990, the TMI-1 RB purge valves were each estimated to have a total beta and gamma dose of 4000 Rads (reference GPU Nuclear memo 6610-90-0043 dated January 23, 1990). At '

the start of the 9R outage (scheduled to commence October 1991), this total is expectbd to increase to 6000 Rads, beta and gamma, for each purge valve. Thus, there is an extremely large margin of safety compared to the threshold radiation level.

Based on the i. cove analysis, GPU Nuclear believes that the ,

vendor recommendations for extended service life have been satisfied with respect to the TMI-1 RB purge valve seats.

Furthermore, it should be noted that a purge valve seat replacement frequency is not required by the B&W Standard Tech. Specs. (reference NUREG 0103, Revision 4) or the Tech. Specs. of other utilities which have similar type purge valves (e.g., Arkansas 1, Davis Besse, Oconee).

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i IV. SAFETY EVALUATION JUSTIFYING CHANGE fCONT'D.)

When the purge valve seats are replaced, the seal of the i new seat may not be as leaktight as the previous seat due to difficulties in valve seat alignment and the need for  !

a " break-in" period. GPU Nuclear researched Nuclear Plant l Reliability Data Survey (NPRDS) data of other utilities-  !

with the same type of purge valve and rubber seat i material. The data indicated that a total of 37 failures I

were reported. Of those reported, 19 were fixed by seat ,

adjustment, 6 were repaired by seat replacement, and 12 l were corrected by other repairs (e.g. , replacement of coil i on air supply valve, open terminal lock). It is ,

I noteworthy that seat replacement was required to repair cracking or other deficiencies which would be expected to

• be detsoted by current and proposed TMI-1 Tech. Spec. '

i surveillances. Thus, replacement of the purge valve seats 1 on a periodic frequency is likely to degrade the seat i performance until " break-in" period seat readjustments -

have been made.

il GPU Nuclear has concluded that the purge valve seats are in good condition, are able to continue to perform ,

satisfactorily beyond the conservative 5 year service life, and that continued Tech. Spec. surveillances will assure evidence of degradation will be detected and corrected in a timely manner. Thus, GPU Nuclear requests that the requirement to replace the purge valve seats 1 during the first refueling outage following 5 years of i service be deleted from Tech. Spec. 4.4.1.7.2.

Replacement of the purge valve seats will be based on their pysical condition as monitored by current and attached proposed Tech. Spec. surveillances associated with the purge valves.

V. NO SIGNIFICANT HAZARDS CONSIDERATIONS l

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GPU Nuclear has determined that this Technical Specification Change Request involves no _significant hazards consideration as defined by the 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 proposed change is not expected to decrease the effectiveness of the purge valve seats. Operability of the purge valve seats will continue to be verified by performance of Tech. Spec, surveillances including .

quarterly pressurization leak testing during power

I Page 5 V. NO SIGNIFICANT HAZARDS CONSIDERATIONS (CONT'D.)

operation. Therefori, this change does not increase  ;

the probability of occurrence or the consequences of an accident previously evaluated.

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 proposed change will allow replacement of the purge valve seats based on the  :

results of Tech. Spec. surveillances which are i consistent with vendor recommended criteria for  :

extended service of the seat material (e.g., visual examinations, durometer testing). Therefore, this L change has no effect on the poscibility of creating a new or different kind of accident from any accident previously evaluated. ,

3. Operation of the facility in accordance with - the proposed amendment would not involve a significant reduction in a margin of safety. The bases for Tech.

Spec. 4.4.1.7 state, in part, " purge valve interspace pressurization test operability requirements and

, inspections provide a high degree of assurance of 1 purge valve performance as a containment isolation ,

l barrier." The proposed change does not-affect the I current Tech. Spec. surveillances which verify the containment isolation ability of the . purge valves.

Rather, the proposed change adds a requirement to perform a durometer test to measure the hardness of the purge valve seats pursuant to vendor recommended criteria for extended service life.

The purge valve seat material is calculated to have a service life of at least 40 years at current TMI-1 RB ambient temperatures; thus, degradation due to thermal aging is not expected to occur. Additionally, there is an extremely large margin of safety between the expected cumulative dose for each purge valve at the start of the 9R outage (i.e., 6000 rads beta and l gamma) compared to the threshold radiation for the I

valve seat material (i.e., 1x 106 rads gamma).

Therefore, it is concluded that operation of the facility in accordance with the proposed amendment does not involve a significant reduction in a margin .

of safety.

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j V. NO SIGNIFICANT HAZARDS CONSIDERATIONS (CONT'D.) l The Commission has provided guidelines pertaining to the application of the three standards by listing specific i examples in 45 FR 14870. The proposed amendment is  !

considered to be in the same category as example (vi) of amendments that are considered not likely to involve significant hazards consideration. Thus, operation of the facility in accordance with the proposed amendment involves no significant hazards considerations.

VI. IMPLEMENTATION It is requested that the amendment authorizing this change ,

become effective immediately upon issuance and shall be '

implemented within 30 days.

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