ML20062L678

Tech Spec Change Request 116 Supporting Amend to License DPR-50,App A.Change Implements Branch Technical Position Csb 6-4,providing for Leak Rate Testing of Purge/Vent Sys Isolation Valves.Certificate of Svc Encl

ML20062L678
Person / Time
Site:	Three Mile Island
Issue date:	08/13/1982
From:	Hukill H GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML19255C444	List: ML19255C443 ML20062L663 ML20062L678
References
NUDOCS 8208190204
Download: ML20062L678 (5)

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METROPOLITAN EDISON COMPAhi JERSEY CENTRAL POWER & LIGHT COMPAhT AND PENNSYLVANIA ELECTRIC COMPAh7 THREE MILE ISLAND NUCLEAR STATION, UNIT 1 Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No. 116 This Technical Specification Change Request is subtitted 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 Dire'c' tor , TMI-l Sworn and subscribed to before me this h day of _O* g mit. , 1982.

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Notary Yublic cs  %

DARLA JEAN BIRRY. NOTARY P98UC 10100ttTOWN BORO. DAUPMW C00Nff NY C050HS$10N EXPlR(5 JUNE 17.1905 Member. Pennsylvoma Association of hotenes 8208190204 820013 PDR ADOCK 05000289 P

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b UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF ,

DOCKET No. 50-289 LICENSE NO. DPR-50 GPU NUCLEAR CORPORATION This is to certify that a copy of Technical Specification Change Request No.116 to Appendix A of the Operating License for Three Mile Island Nuclear Station Unit 1, has, on the date given below, been filed with  !

the U. S. Nuclear Regulatory Commission and been served on the chief j executives of Londonderry Township, Dauphin County, Pennsylvania and Dauphin County, Pennsylvania by deposit in the United States mail, addressed as follows:

Mr. Jay H. Kopp, Chairman Mr. John E. Minnich, Chairman ,

Board of Supervisors 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 GPU NUCL'E CORPORATION t

By f i ' Director, TMI-l Dated: August 13, 1982 m

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1. TECHNICAL SPECIFICATION CHANGE REQUEST NO. 116 The Licensee requests the attached changed pages replace the following pages of the existing Technical Specifications:

Appendix A Replace pages 111, 3-41*, 3-41a, 3-62a, 3-62b, 4-32*, 4-34, 4-34a, 4-37, 4-38, 4-55b /

II. REASON.FOR THE CHANGE REQUEST In NRC letter dated April 30, 1982 CPU Nuclear Corporation was requested to provide Technical Specification Change Request for:

1. Proposed test program for Reactor Building Purge Exhaust Valves to determine seal deterioration.

2. TMI Action Plan, Item II.E.4.2 of NUREG 0737 " Containment Isolation Dependability".

In addition, since the installation of one (1) hydrogen recombiner and provision for a second have been completed the " Hydrogen Purge Exhaust Sub-System" is not needed.(See also Technical Specification Change Request No. 109).

SAFETY EVALUATION JUSTIFYING CHANGE III.

Present NRC policy as reflected in the long term resolution of Generic Issue B-24, " Containment Purging During Normal Plant Operation",-

includes, in part, the implementation of Item 3.4 of Branch Technical Position.(BTP) CSB 6-4, Item B.4 specifies that provisions should be made for leakage rate testing of the purge / vent system isolation valves, during reactor operation. Appendix J to 10 CFR Part 50 specifies a maximum test interval of 2 years.

As a result of the numerous reports on unsatisf actory performance of the resilient seats for the isolation valves in containment purge and vent lines (addressed in DIE Circular 77-11, dated September 6, 1977), Generic issue B-20, " Containment Leakage Due to Seal Deterioration," was estab-I lished to evaluate the matter and establish an appropriate cesting

[ frequency for the isolation valves. Excessive leakage past the resilient seats of isolation valves in purge / vent lines is typically caused by severe environmental conditions and/or wear due to frequent use.

Consequently, the leakage test frequency for these valvec should be keyed to the occurrence of severe environmental conditions and the use of the valves, rather thancthe current requirements of 10 CFR 50, Appendix J.

GPU Nuclear proposes that the following provision be added to t he Technical Specifications for the leak testing of purge vent line isolation valves:

• These pages also affected by TSCR 109 and/or 113

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1. An interspace pressurization test (per proposed TS 4.4.1.7) be performed

' for reactor building purge isolation valves at an interval not to exceed 6 months.

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If, while containment integrity is required (per proposed TS 3.6.1)

2.  ;

48" purge valve is found to be inoperable (per proposed TS 4.4.1.7) immediately close the associated valve and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> verify the associated valves operability. i

3. If inoperability was due to excessive combined leakage during  ;

interspace test (proposed TS 4.4.1.7.1) demonstrate that one of the valves has no detectable leakage.

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4. If neither purge valve in the penetration can be declared operable with 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, be in hot shutdown within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in '

cold shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Per TMI Action Plan, TMI II.E.4.2, NUREG 0737 (Attachment 1 Item (2)(a))

GPU Nuclear letters L1L 015 dated February 6, 1981, and L1L 199 dated July 2,1981 purge valves will be limited to 30 open whenever containment __

integrity is required. This commitment, which has been implemented. forces acknowledgement of the need for several operational modifications.

1. The hy'rogen d purge exhaust syst'em will not perform as originally designed.

2. Current Technical Specifications for determining fan and filter -

operability for the reactor building purge exhaust system become impossible during reactor operations.

The first item above, is not considered by GPU Nuclear to pose a safety hazard since a hydrogen recombiner is installed and provisions for a second ,

recombiner if needed are also insta13ed. Technical Specification Change Request 109 details the limiting conditions of operation and surveillance requirements for the_ hydrogen recombiners.

The second item above, has necessftated the revision of Pages 3-62a, 3-62b and 4-55b. These revisions require that design flow performance testing ,

be done only when the purge valves are permitted to be_ full open, prior  !

to containment integrity being required. ,

CONCLUSION In conclusion, with regard to the installed reactor building purge isolation valves and associated Technical Specifications:

1. The probability or consequences of accidents previously e'valuated have not increased. The use of hydrogen recombiners at TMI-1 would result in lower off-site doses, in the event of a LOCA, when com-pared with other post-accident hydrogen control techniques requiring containment venting.*

• The recombiner cooling air is vented directly to the environment. An evaluation involving failure of this cooling air system indicates that the resulting off-site doses are not significant (See Question 91, Supplement 1, Part 2, Restart Report).

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. .s 2. No accidents, other than those previously considered, will be introduced.

- 3., No safety margins have been reduced.

Based upon the above, wk conclude that the additional testing of purge valves, limiting of purge, valve opening and their associated Technical Specifications, do not involve any unreviewed safety questions with regard to the criteria of 100FR Part 50, Section J0.59(a)(2).

IV. AMENDMEMT _ CLASSIFICATION (10 CFR 170.221 l' .

This change request involves a single safety issue and is, therefore, con-sidered a class III license amendment. A check in the amount of'$4,000.00 is enclosed.

V. IMPLEMENTATION In order to finalize the necessary procedures and train personnel, an implementation period of 6 weeks from the date of receipt-of the applicable amendment or until cycle 5 criticality, whichever is sooner, is requested.

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V1. REFERENCES _

1. Technical Specifi' cation Change Request 109 transmitted January 26, 1982 (L1L 370).

2. NUREG 0578, Ju,1y 1979, Section 2.1.5.

3. NUREG 0103 I

4. NUREG 0737 Ittd II.E.4.2

5. NRC. Letters: November 29, 1978 January 28, 1980 '

April 30, 1982

6. GPU Nuclear Letters: February 6,1981 (L1L 015)

July 2,1981 (L1L 199)

March 22, 1982 (5211-82-072)

Attachment 1 of above

,- provides a tabulation of correspondence on this issue.

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