ML20064J377

Application for Amend to License DPR-50,revising TS Re Allowable Outage Time for Emergency Feedwater Pumps During Surveillance Activities

ML20064J377
Person / Time
Site:	Three Mile Island
Issue date:	03/11/1994
From:	Broughton T GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20064J380	List: ML20064J377 ML20064J381
References
C311-94-2024, NUDOCS 9403210171
Download: ML20064J377 (7)

Text

._ ._ - - _ - _

- j

. i 1

i GPU Nuclear Corporation 5 Nuclear  ;;gnir" Middletown, Pennsylvania 17057-0480 (717)944 7621 Writer's Direct Dial Number:

(717) 948-8005 March 11, 1994 C311-94-2024 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Subject:

Three Mile Island Nuclear Station, Unit 1 (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No. 241 In accordance with 10 CFR 50.4(b)(1), enclosed is Technical Specification Change Request (TSCR) No. 241.

Also enclosed is a Certificate of Service for this request, certifying service to the chief executives of the township and county in which the facility is located, as well as the designated official of the Commonwealth of Pennsylvania, Bureau of Radiation Protection.

The purpose of this TSCR is to specify an allowable outage time for the Emergency Feedwater Pumps during surveillance activities. Also, this TSCR changes the requirement to test redundant components for operability to a requirement to ensure operability based on verification of completion of appropriate surveillance activities. Finally, administrative errors made during the processing of Amendments 133 and 174 are corrected.

l Sincerely, Q41'k.g A.

T. G. Brotidhton )

Vice President and Director, TMI l

1 AWM/ emf I l

Enclosure:

1) Technical Specifications Change Request No. 241  ;

2) Certificate of Service for Technical Specification Change Request No. 241 cc: Region I Administrator l THI-l Senior Project Manager l TMl Sr '~ Dacirient Inspector

$b(ICO._hEMNUEsois, -@' I PDR ,

GPU Nuclear Corporation is a subsidiary of General Public Utihties Corporation

! l

f1ETROPOLITAN 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. 241 COMMONWEALTH OF PENNSYLVANIA )

) SS:

COUNTY OF DAUPHIN )

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

GPU NUCLEAR CORPORATION BY: bb W bA Vice President und Director, IMI Sworn and Subscribed to before me this _jlb day of J e , 1994.

Notarf'Public Em M NAc w%"TJbEW%

Mentwt, Porsgivusa Amx2TKn of FKAW.es

. ..-- . . . ~ . . - _ . . - _ _ - - . . -

V .'

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1

d IN THE MATTER OF DOCKET NO. 50-289

^

GPU NUCLEAR CORPORATION LICENSE N0. DPR-50 CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No. 241 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, Bureau of Radiation Protection, by deposit in the United States mail, addressed as follows:

4 Mr. Darryl LeHew, Chairman Mr. Russell L. Sheaffer, Chairman Board of Supervisarr of Board of Ceraty Commissioners Londonderry Township of DaupF n County R. D. #1, Geyers Church Road Dauphin f .unty Courthouse Middletown, PA 17057 Harrisbu~g, PA 17120 ,

Director, Bureau of Radiation Protection PA. Department of Environmental Resources Fifth Floor, Fulton Building Third and Locust Streets P. O. Box 2063 Harrisburg, PA 17120 Attn: Mr. Robert Barkanic GPU NUCLEAR CORPORATION  :

i

1. ^

BY: "@

Vice President a6) Director, TMi-~

March 11, 1994 DATE:

4

---,,------n,. e -- - , p- - - -w.

~..-,-~w -- e ,-, --. --, - , - -

.  : l C311-94-2024 Page 1

1. 'TECHPICAL SPECIFICATION CHANGE RE0 VEST (TSCR) NO. 241 ~

GPU Nuclear requests that the following changed replacement pages be I inserted into existing Technical Specifications (T.S.): j Replace the existing pages 3-22, 3-25, 3-26b, 3-41, and 3-61 with the attached revised pages 3-22, 3-25, 3-26b, 3-41, and 3-61.

II. REASON FOR CHANGE This requested change to the T.S. will modify the existing requirements as follows:

a. T.S. 3.3.1.3.b is modified to correct an administrative error. TSCR No. 222 made no changes to this specification, however, this specification was retyped for this submittal. In the process of retyping, the "1" sign between 8 ft, and 6 inches was inadvertently omitted and not detected during review. Amendment 174 was issued with the i sign omitted.

b. T.S. 3.3.2 is modified to clarify that maintenance or testing shall be allowed during reactor operation on the components associated with emergency core cooling, reactor building (RB) emergency cooling, and the RB spray systems,

c. T.S. 3.4.1.1(2) is modified to provide a specified allowable outage time for the Emergency Feedwater (EFW) pumps during T.S. required surveillance testing,

d. Bases for T.S. 3.4, last paragraph on page 3-26b, is modified to correct an administrative error. A change was made to this paragraph with Amendment 124 which stated that either both motor driven EFW pumps or the single steam-driven EFW pump are required initially to remove .1 decay heat, with one EFW pump eventually sufficing. When Amendment 133 l was issued, this paragraph was inadvertently changed to pre-Amendment 124 wording. In addition, a clarifying sentence was added to explain that acceptably minor operator action may be required during -

surveillance testing to ensure both motor driven EFW pumps are .l available, j

e. T.S. 3.6.6 is modified to change the requirement to test a redundant RB isolation valve for OPERABILITY following a determination that the other valve in the line is inoperable. Instead of testing the redundant valve to verify OPERABILITY, the redundant valve is verified to be OPERABLE by ensuring the appropriate T.S. surveillance is current.

f. T.S. 3.15.1.3 is modified to change the requirement to test the redundant control room air treatment system when the other system is made or found to be inoperable for any reason. Instead of testing the redundant system to verify OPERABILITY, the redundant system is verified to be OPERABLE by ensuring the appropriate T.S. surveillance ,

is current. l l

o n C311-94-2024 1y Page'2 1

'l

.l 1hese changes, in conjunction with TSCRs 228.and 230, arc being made.to .l permit full implementation of the guidance provided to licensees regarding OPERABILITY determinations in Generic Letter 91-18. Guidance from NUREG-1366, " Improvements to Technical Specifications Surveillance Requirements," and NUREG-1430, " Standard Technical. Specifications for  ;

Babcock and Wilcox Plants," was used to dev lop these changes. j III. SAFETY EVALUATION JUSTIFYING CHANGE

1. Page 3-22 T.S. 3.3.2 currently specifies that maintenance is allowed during reactor operation on any component (s) in the makeup and purification, i decay heat, RB emergency cooling water, RB spray, Core Flood Tank (CFT) pressure instrumentation, CFT level instrumentation, BWST level instrumentation, or cooling water systems, which will not remove more than one train of each system from service. T.S. 3.3.2 also requires that only one train can be affected such that it is inoperable no more than 72 consecutive hours.

This proposed change would clarify the intent of this specification to also allow any component (s) to be removed from service for T.S.

surveillance testing. Thus, when any component (s) becomes inoperable in the course of T.S. surveillance ter. ting, the same restrictions as those for maintenance apply and thet a is no change in the safety function capability of the systems with redundant trains.

This proposed change also includes a modification to T.S. 3.3.1.3.b to il correct an administrative error. The " " sign between 8 ft. and 6 inches was inadvertently omitted when submitting TSCR No. 222 and was subsequently missing when the associated Amendment 174 was issued. 3

2. Page 3-25 T.S. 3.4.1.1 provides the requirements for EFW pumps and associatsd flow paths with the Reactor Coolant System (RCS) temperature greater than 250' F. The following test requirements have an impact on the EFW pumps and associated flow paths:

a. T.S. 4.9.1.2 requires that if one steam generator flow path is made inoperable a dedicated qualified individual who is in communication with the control room shall be continuously stationed at the affected EFW local manual valves. On instruction from the control room operator, the individual shall . realign the valves from the test mode to their operational alignment.

b. T.S. Table 4.1-1, Section 51.a requires quarterly EFW Auto Initiation testing.

. ~ -- . - - . _ . . . . ._ , - _. .

C311-94-2024 Page 4 inoperable. The periodic satisfactory completion of the existing surveillance tests assures that the associated valves are OPERABLE.

, 5. Page 3-61 T.S. 3.15.1.3 requires testing the redundant control room air treatment system within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and daily thereafter from the time one control i

room air treatment system is made or found to be inoaerable. This requirement reflects an earlier NRC staff position t1at has been revised and is not included in the revised B&W STS. By verifying the required periodic surveillance testing is current and there are no known reasons to suggest the redundant train is inoperable, adequate assurance exists that the redundant train is OPERABLE.

4 IV. NO SIGNIFICANT HAZARDS CONSIDERATIONS GPU Nuclear has determined that this TSCR involves no significant hazards j 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 proposed amendment specifies an allowable outage time for testing of the EFW pumps. Also, this preposed change reflects the current NRC staff position regarding the need for additional testing to assure OPERABILITY. The allowable outage time this change provides for EFW pump testing is acceptable because the operator action required to make the motor driven EFW pump OPERABLE is minimal and can be performed in a very short time by the Control Room Operato! who is continuously present during the time the motor-drivan EFV pump is in the  !

Pull-To-lock position.

The changes affecting OPERABILITY determ; nations of redundant train / components for reactor building isolation valves and the control room air treatment systems reflect the current NRC staff position.

Verifying that the required periodic surveillance testing is current .l and there are no known reasons to suggest the redundant train / component i is inoperable, provides adequate assurance of system OPERABILITY.

Therefore it can be concluded that the proposed changes do not involve a significant increase in the probability or consequences of an i accident previously evaluated, i

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 amendment specifies an allowable outage time and deletes unnecessary redundant equipment testing. These changes do not change system operational requirements or response to system transients.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident.

.-e- , ,- , r w,.-- ,, , - , . - , y

.  : i l

C311-94-2024 l Page 5

'3. Operation of the facility in accordance with the proposed amendment )

would not involve a_significant reduction in a margin of safety. l l

The proposed amendment specifies an allowable outage time and replaces I redundant equipment testing with verification that surveillance is  !

current as an adequate means to ensure OPERABILITY. These changes do l not involve any activities associated with the margin of safety j envelope. Thus, operation of the facility in accordance with the proposed amendment does not involve a significant reduction in a margin  ;

of safety.

V. IMPLEMENTATION It is requested that the amendment authorizing this TSCR be effective 30 days after issuance.

3 4

4 4

i!

- , - , , ... - -. - - - - -, .