ML20063H793

TS Change Request 230 to License DPR-50,replacing Word Tested W/Words Verified to Be Operable in TS Section 3.7.2.c,including New Page 3-43a

ML20063H793
Person / Time
Site:	Three Mile Island
Issue date:	02/10/1994
From:	Broughton T GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20063H790	List: ML20063H787 ML20063H793 ML20063H798
References
NUDOCS 9402220198
Download: ML20063H793 (5)

Text

.- - .- -_. . .-- . .. -.

1. .

.l l

METROPOLITAN EDISON COMPANY j JERSEY CENTRAL POWER & LIGHT COMPANY l l

AND i PENNSYLVANIA ELECTRIC COMPANY l

THREE MILE ISLAND NUCLEAR STATION, UNIT l'

]

l l

Operating License No. DPR-50  ;

Docket No. 50-289 Technical Specification Change Request No. 230 .l

.l l

COMMONWEALTH OF PENNSYLVANIA )

) SS-COUNTY OF DAUPHIN )

This Technical Specification Change Request is submitted. in sup' port 'of - ,

Licensee's request to change Appendix A to'0perating 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: 4dW4b'~

Vice President & Director, TMI ,

l Sworn and subscribed l to beforg.me this IOk l day of ha b u. m , 1994.

l 6

! . Notary Fublic M

NotarialSeal ErinM.Flowen,No Public 7

.W es l Membwfw@ia Meadaton d Natanes 9402220198 DR 940210 'i-ADOCK 05000289 [!

enR a .- . - . = -

i . .

UNITED STATES OF' AMERICA

. NUCLEAR REGULATORY COMMISSION 1 IN THE MATTER OF DOCKET NO. 50-289 j GPU NUCLEAR CORPORATION LICENSE N0..DPR !

J j CERTIFICATE OF SERVICE

! This is to certify that a copy of Technical Specification ' Change Reques't i No. 230 to Appendix A of the Operating License- for Three Mile' Island Nuclear i 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, l

Bureau of Radiation Protection, by deposit in the United. States mail,  ;

j addressed as follows l l i . .

i Mr. Darryl LeHew, Chairman Mr. Russell L. Sheaffer, Chairman 1 i

Board of Supervisors of Board'of County Commissioners  !

Londonderry Township of-Dauphin County. I

{ R. D. #1, Geyers Church. Road Dauphin County Courthouse Middletown, PA 17057 Harrisburg, PA 17120

{

1

! Director, Bureau of Radiation Protection

!- PA. Department of Environmental Resources i Fifth Floor, Fulton Building i

Third and Locust Streets P. O. Box 2063 j Harrisburg, PA 17120

Attn

Mr. Richard R. Janati i i

! GPU NUCLEAR CORPORATION 1

i i BY: bh*'m Vice, President _ add Director,'TMI.

f DATE: b ~ bb i

a i ,

r m e~ ,, m ,ew u: m , .--- - ..ee,we. , - .w w n- ,ew-wt,.r,.m -~ s~e- .v.-

i I

1

1. TECHNICAL SPECIFICATION CHANGE RE0 VEST (TSCR) N0. 230 GPUN requests that the revised replacement page 3-43 and new page l 3-43a be inserted into the existing Technical Specifications (TS): j 1

II. REASON FOR CHANGE l l

The change proposed enhances emergency diesel generator (EDG) reliability by elimination of the TS requirements to demonstrate operability of the redundant EDG by testing, when an EDG wili be made )

or has been determined to be inoperable. l The proposed change replaces the word " tested" with the words

" verified to be operable" in TS section 3.7.2.c. Additional wording j was included to require that, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the inoperability.

declaration, station personnel will determine the redundant diesel is l not inoperable due to a common mode failure or test the redundant  !

diesel generator in accordance with surveillance requirement 4.6.1.a., l if it cannot be determined that a common mode failure does not exist. j i

Elimination of the requirement to test the redundant EDG is beneficial I for the following reasons: j

1) minimization of the number of entries into an equipment configuration where a loss of safety function exists duririg' the period of the test, ]

l

2) overall engine degradation (wear and stress) and the probability of failure due to degradation are reduced and i

3) the susceptibility to damage from an electrical grid fault, while the engine undar test is running paralleled to the grid, is reduced.

I III. SAFETY EVALUATION JUSTIFYING CHANGE l TS section 3.7.2.c presently requires that "... from the date that one l of the diesel generators is made or found to be inoperable for any'  !

reason, reactor operation is permissible for the succeeding seven days  ;

provided that during such seven days the operable diesel generator is '

tested immediately and daily."

The TS requirement for testing of the operable diesel generator was based on an earlier NRC staff position. The intent of the prior position was to provide positive demonstration that'a loss of safety-function had not occurred. To satisfy the current TS requirement, the operable EDG must be taken out of service to demonstrate operability -

through supplemental testing. The detrimental effects of the testing exceed the benefit derived from any added assurance of operability the test provided. Supplemental testing results in both an increased probability of equipment failure due to unnecessary wear and a loss of safety function exists during the period of performance of the test.

1 4

w n

The requirement for supplemental testing would increase the risk of losing the remaining operable diesel generator.

Industry operating experience has since demonstrated that. testing EDGs, when one train is operable, is not. necessary to provide assurance of system operability. A failure of a different diesel generator does not reduce the reliability of an otherwise operable diesel generator. Deleting the requirement to demonstrate the operability of an otherwise operable diesel generator, once a determination has been made that no common mode failure exists, has no affect on the design or performance characteristics of the engine.

Barring common mode failure, TS surveillance. testing schedules established in accordance with Generic Letter 84-15 assure that operable EDGs are capable of performing their intended functions.

Therefore, the ability of the diesel generator to perform its design function is maintained.

i l

The proposed change to section 3.7.2.c allows an EDG to be out of service without requiring supplementary immediate and daily testing of-the redundant EDG. Station personnel will determine if the redundant diesel has been made inoperable by a common mode failure 'within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The redundant EDG will remain in service during the entire l period of inoperability of the out of ' service EDG. There will be'no concurrent loss of safety function previously experienced during the.

required supplemental testing if the inoperability is determined not to be the result of a common mode failure. If a common mode failure cannot be ruled out, the redundant diesel will be tested in accordance with the surveillance requirements of TS section 4.6.1.a. to show operability.

It is recognized that while testing the redundant diesel in accordance with surveillance requirement 4.6 1.a, the diesel will not respond to an automatic initiation signal. In this situation, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> time clock will not be entered per the provisions of section 3.7.2.f. due to the low probability of an event occurring while the diesel is being tested.

The proposed revision reflects the revised NRC staff position on testing redundant safety equipment and is consistent with conclusions in recent NRC safety _ evaluations and the change is compatible with plant operating experience and is consistent with a staff approved.

change in NUREC-1430, Standard Technical Specifications for B&W Plants dated September 28, 1992.

IV. N0 SIGNIFICANT HAZARDS CONSIDERATIONS i

I GPUN has determined that this Technical Specification Change Request-involves no significant hazards consideration as defined by NRC in 10CFR50.92.

1. The proposed amendment serves to assure that an EDG is always available to perform on demand and the lower number of demands for performance reduce the probability of equipment failure. The 2

required action no longer requires a " test" be performed.

Therefore, the word " test" has been deleted from TS 3.7.2.c. The change is administrative. Since the proposed amendment does not affect the design or performance of the diesel generators or their ability to perform their design function,.the change will not result in an increase in the consequences or probability of an accident previously analyzed. The proposed change will increase diesel generator reliability, thereby increasing overall plant safety.

2. Operation of the facility in accordance with.the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Accidents involving loss of off-site power and single failure have been previously evaluated. The change does not introduce any new mode of plant operation or new accident precursors, involve any physical alterations to plant configurations, or make any changes to system setpoints which could initiate a new or different kind of accident.

3. Operation of the facility in accordance with the proposed amendment does not involve a significant reduction in a margin of safety. This change does not result in a reduction in the margin of safety since there is no margin of safety associated with the supplemental immediate and daily testing of the operable EDG. If I a margin of safety were presumed to exist, no reduction would result because of the proposed amendment: no physical modification to the plant or change to procedurally prescribed operator actions resulted from the proposed amendment,

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

l l

! l I

l i

3 l

I