ML20062C347

Application for Amend to License DPR-50,consisting of Suppl 1 to Tech Spec Change Request 179

ML20062C347
Person / Time
Site:	Three Mile Island
Issue date:	10/26/1990
From:	Hukill H GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20062C341	List: ML20062C340 ML20062C347
References
NUDOCS 9010310148
Download: ML20062C347 (5)

Text

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METROPOLITAN EDISON COMPANY l j

, JERSEY CENTRAL POWER & LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY ,

THREE MILE ISLAND NUCLEAR STATION, UNIT 1 l

Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No. 179 Supplement 1 i

This Technical Specification Change Rurquest 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.

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BY: .N J* .

Vic'e Preafident &

Director, TMI-1 Sworn and subscribed I

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l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l

i IN THE MATTER OF DOCKET NO. 50-289 l GPU NUCLEAR CORPORATION LICENSE No. DPR-50 CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No. 179, Supplement 1 to Appendix A of the Operating License l

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

l

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

l GPU NUCLEAR CORPORATION BY:

Vide Pre'si' dent &

Director, TMI-1 l

l DATE: October 26, 1990

Page 1 Technical Soecification Chance Reauest (TSCR) No. 179. Suoolement 1 GPU Nuclear letter C311-90-2030 dated June 18, 1990, initially submitted TSCA 179 for NRC review and approval. This TSCR revised the surveillances associated with the TMI-1 hydrogen recombiner system (i.e., Technical Specification 4.4.4.1). The t

following responds to verbal NRC comments concerning this submittal.

NRC Comment 1 The proposed change request did not provide, in the NRC's opinion, adequate justification for revising the current 18 month surveillance to a once per refueling interval.

GPU Nuclear Resoonse The Safety Evaluation justifying change for the original submittal of TSCR 179 provided the following justification for revising the current 18 month surveillance to a refueling interval frequency:

o The proposed revision would not decrease the effectiveness of the hydrogen recombiner system since operation of a hydrogen recombiner at TMI-1 would not be required until approximately 9.8 days following a LOCA (reference TMI-1 FSAR Section 6.5.3.1).

o Regulatory Guide 1.7 recommends that one (1) recombiner per site be available for installation with a redundant recombiner either onsite or offsite. TMI-1 has two (2) installed, 100% capacity hydrogen recombiners.

Additional justification for this proposed change is provided below:

o Revising the current 18 month surveillance to a once per refueling interval would eliminate testing of the hydrogen recombiner system with the plant in operation.

o The proposed change will retain the current requirement to conduct a functional test at a temperatore and time period twice that of the current quarterly functional test (i.e.,

1200 F for at least 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> vs. 600 F for at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />).

l It is noteworthy that the 18 month surveillance for the '

l hydrogen recombiner system in the B&W Standard Technical >

l Specifications (NUREG 0103, Revision 4) does not include the requirement to perform a functional test. Thus, the proposed '

change will provide greater assurance of the operability of the hydrogen recombiner system in comparison to the 18 month surveillance in the B&W Strandard Technical Specifications.

l Page 2 l

l l GPU Nuclear Resoonse (Cont'd) o B&W Standard Technical Specification Table 1.2 categorizes an 18 month surveillance as a refueling surveillance.

Additionally, TMI-1 Technical Specification 4.4.4.1.b

( includes a channel calibration which in the vast majority of TMI-1 Technical Specification surveillances is performed on a refueling interval frequency (e.g., TMI-1 Technical Specification Tables 4.1-1 and 4.21-1). Thus, the proposed i refueling interval surveillance is consistent with other surveillance frequencies in the B&W Standard Technical Specifications and the TMI-1 Technical Specifications.

liR0 Comment 2

! The proposed change request did not provide justification for the following changes:

a) Deletion of the requirement in Tech. Spec. 4.4.4.1.a to perform the hydrogen recombiner system functional test during, ' REACTOR CRITICAL, HOT STANDBY, or POWER OPERATION;"

and b) Deletion of the last sentence in Tech. Spec. 4.4.4.1.a, concerning the functional test, which currently states: "This test shall a5ao be performed prior to-STARTUP following a reactor oui...je greater than 90 days."

GPU Nuclear Resoonse TMI-1 Technical Specification 3.6.7 states, "The hydrogen l recombiner shall be operable during REACTOR CRITICAL, HOT STANDBY, and POWER OPERATION. " TMI-1 Technical Specification 4.4.4.1 is the associated surveillance for Technical Specification 3.6.7. Thus, the requirement in Technical Specification 4.4.4.1.a to perform the functional test during i

" REACTOR CRITICAL, HOT STANDBY, or POWER OPERATION" is redundant and can be deleted.

TMI-1 Technical Specification 4., " Surveillance Standards,"

states:

"During Reactor Operational Conditions for which a Limiting Condition for Operation does not require a system / component to be operable, the associated surveillance requirements do not have to be performed. Prior to declaring- a system / component operable, the associated surveillance requirements must be current."

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. l GPU Nuclear ResDonse (Conted) 1 In the case of the hydrogen recombiner system, if a plant outage ,

were to exceed any of the surveillance intervals specified in I Technical Specification 4.4.4.1, then the associated surveillance (s) would have to be performed prior to declaring the system operable. Therefore, the requirement in Technical l Specification 4.4.4.1.a to perform the hydrogen recombiner functional test "... prior to STARTUP following a reactor outage greater than 90 days" is not necessary.

No Sionificant Hazards Considerations This supplement to TSCR 179 does not affect the No Significant Hazards Consideration contained in the original submittal.

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