ML20070R435

Application for Amend to License DPR-50,consisting of Tech Spec Change Request 183,reformatting Tech Spec 3.4.1.1 by Specifying Allowable Outage Time for More than Two Turbine Bypass Valves

ML20070R435
Person / Time
Site:	Three Mile Island
Issue date:	03/25/1991
From:	Broughton T GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20070R431	List: ML20070R428 ML20070R435 ML20070R446
References
NUDOCS 9104010191
Download: ML20070R435 (6)

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!EIPDFOLITAN FDISON COMPNW l

JERSEY CDfIRAL IWER & LIGfr CCMPMW I MO l PDINSYLVANIA ELDCIRIC COMPNW

'HIREE MILE ISINO NUCLEAR STATION, UNIT 1 Operating Li nse No. DPR-50 Docke; No. 50-289 Technical Specification Owge Rcquest No.183

'Ihis Technical Specification Onnge Roquest .ts subnitted in support of Li nsee's request to change Apperdix A to operatire License No. DPR-50 for 'Ihree Mile Island

..uclear Station,. Unit 1. As a part of this request, proposed replacement pages T Appendix A are also ircluded.

GPU NUCLEAR CDRPORATION BY: A H b"'

Vice Preajdent & Director, 'IMI-1 Sworn and subscribed to before me this e W' day of Muwch , <991.

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0 UNITED STATES OF AMERICA NUCLEAR REGUIA70RY CCtMISSION IN THE PATTER OF DOCKET NO. 50-28')

GPU NUCLEAR 00REOPATION LICDISE NO. DPR-50 cu<nr1CATE OF SUNICE This is to certify that a copy of 7bchnical Specification Charge Rrquest No.183 l to A;perdix A of the Operatirq License for 9hree Mile Islard Nuclear Station Unit 1, has, on the date given below, been filed with executives of lordorderry l

Township, Dauphin County, Pennsylvania; Dauphin County, Pennsylvania; ard the Pennsylvania Department of Environmental Re. m., Bureau of Radiation Protection, by deposit in the United States unil, addressed as folloas:

l Mr. Jay J. Kopp, Chainnn Ms. Sally S. Kleir, Chaiman Board of Supervisors of Board of County c'annissioners Iordorderry 7bwnship of Dauphin CD ity l R.D. #1 Geyers Church Road Dauphin County Courthouse Middletown, PA 17057 Harrisburg, PA 17120 Mr. Thomas. Jerusky, Director PA. Dept. of Envirortmental Resources l

Bureau of Radiation Protection P.O. Box 2063 Harrisburg, PA 17120 GIU NUCLEAR CDRFORATION BY: bH ~

Vice President & Director, 7MI-1 DATE: M F/91 l

l C'.11-90-2321 Page 1 of 4 I. IEC}]hLQAL SPECIFICATION CHANGE _ REQUEST (TSSR) NO. 183 GPUN requests that the attached revised page 3-25 replace the existing page 3-25 of the TMI-1 Technical Specifications.

II. REASON FOR._Q1[h%E This submittal. requests changes to the TMI-1 Technical Specifications by specifying an allowable outage time (AOT), for more than two turbine bypass valves (TBVs).

Section 3.4.1.1 is being reformatted to group action statements with the appropriate operability statement.

III. SAFETY EVALUATION JUSTIFYIt'G THE CHANGE Currently, the TMI-1 Technical Specificatio m do not specify an AOT or a requirerent to shutdowr when less than the required number of T9'Jo are operable. Unlike the B&W Standard Technical Specificatione, the sbutdown requirements or TMI-1 Technical Specliication Section 3.0.1 are applicable only where so stated in the individual specifications. The current Technical Specification Section 3.4.1.1.c does not invoke the applicability of Section 3.0.1. Therefore, neither the AOT nor the shutdown requirements of 3.0.1 apply. The purpose of this change is to provide an appropriate AOT. Seventy two (72) hours was chosen tecause this is consistent with that specified in the standard technical specifications for many sr ;ty system components.

The TBV's function in a safety capacity only as a means of dose reduction for certain accident scenarica. Credit is given to the TBVs for dose reduction in TMI-l's accident analysis for the steam generator tube rupture event because of the ability of the condenser to scrub out and retain almost all particulates and iodine thet otherwise would be present in the release to atmosphere. Analysis has shown

t. hat even without the TFIs, accident releases to atmosphere would be well within the limits of 10 CFR 100, and that it would be possible to justify removing the operability requirements for the TBVs from technical specification.

GPUN has chosen the approach of revising the current specification to be consistent with other specifications, rather than revising the safety analysis as would be required if the TBVs were to be deleted from the TMI-1 Technical Specifications.

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C311-90-2121 Page 2 of 4 The TBVs are not required for achieving hot shutdown. The TBVs would not be available for events involving loss of offsite power (e.g., station blackout), because without condenser vacuum the TBVs can not function.

The TBVs have three purposes: (1) relieving steam line pressure through the condenser when the main turbine is not able to accept a load sufficient to remove all of the reactor heat being generated, (2) depressurization and cooling of the steam generators sturing plant cooldown, and

'3) reduction of direct releases to atmosphere resulting

. rom primary to secondary leakage.

The primary means of performing-the secondary plant pressure relief function is provided by the main steam safety valves (MSSVsl, Operability of the MSSVs are contained in Section 3.4.1.2. The MSSVs can accommodate 100% of full steam flow. Partial steam relief capability is provided by the atmospheric dump valves (ADVs) which are able to accommodate 6.4% of full steam flow and the six (6)

TBVs which can accommodate up to 22.5% of full steam flow.

Because the TBVs would normally be the preferred _ method of depressurizing the steam generators while shutting down, it would not be correct in most cases of TBV inoperability to require a forced plant shutdown. Without the"1BVs, the ADVs would normally be availahle as an alternate means of depressurizing the steam generators. Rather than shutting down with TBVs temporarily incapacitated in some way, we believe that it would be more appropriate to restore their operability while continuing et operate at power.

During a normal shutdcem, the TBVs minimize offsite releases by limiting the amount of slightly radioactive steam that is released to the atmosphere. Shutting down without the TBVs would not be in keeping with the ALARA principle as this would necessarily result in some increase in the doses cffsite while shutting down. Therefore, a forced shutdown requirement would not be in the best interest of public health and safety because use of the

-ADVs in this manner woutd force a release of radionuclidcs to the environment that perhaps could be avoided.

i In summary, this change defines the A0T for TBV inoperability. This change does not affect the capability for achieving hot shutdown. Alternate means are normally-available for achieving cold shutdown such that the offsite dose consequences would be minimal. This proposed change has no adverse effect on nuclear safety or safe plant operation.

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C311-90-2121 Page 3 of 4

n/. . NO SIGNIFICANT HAZARDS CONSIDERATIONS E

GPUN has_ determined that this Technical Specification Change Request poses no significant hazard consideration as defined by the NRC in.10CFR 50.92. - This change is considered to be administrative in nature and does not involve significant hazards consideration as evaluated below.

1. Operation of Three Mile Island Nuclear Station, Unical, in:accordance with this change would not involve a significant increase in-the probability or consequences of an accident previously evaluated. The proposed Technical Specification change does not modify or create any accident initiating _ condition. Any minor change in operation resulting from the amendment authorizing-this change could not affect the probability of an accident and would have an insignificant effect on the consequences of accidents that take credit for the turbine bypass valves.

(10CFR 50.92 (c) (1))

2. operation of.Three' Mile Island Nuclear Station,-Unit-1, inLaccordance with this change would not create the

. possibility:of a new or different kind of_ accident from any accident previously evaluated. The proposed change would not result in a change to-facility hardware or a significant change in operation. Therefore this change has no.effect on the possibility:of creating;a new or different kind of accident from any accident previously evaluated.

(10CFR 50.92 (c) (2))

- 3. operation;of Three Mile Island Nuclear Station, Unit-1,

in accordance with this change would not involve a

. significant reduction;in a margin of safety.- This-change includes' editorial. format changes and. defines an allowable-outage-time for the. turbine bypass valves.

This. change does_not involve Lny margins.-

- (10CFR -50. 92 (c) (3 ) )

The Commission has provided gridelines pertaining to the application of tus three' standards by listing specific examples in tho.Faderal Register: (48 FR;14870). This-proposed change is' considered to be in the sama category as example - (i)~ ar4d (vi)L of the '" Amendments Not Likely to '

Involve Significant-Hazards Consideration" from that .

- listing.

The Federal Register describes example (1) as a purely .

adiit m n s rative change to technical specifications: for example, a change to achieve consistency throughout_the c

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C311-90-2U-Page 4 of technical specifications, correction of an error, or a change in nomenclature. This change is administrative in nature in that it incorporates editorial changes in format and provides a clarification of the TBV AOT consistent with that given in the standard technical specifications for other safety system components.

The Federal Register describes example (vi) as a change which either may result in some increase to the probability or consequences of a previously analyzed accident or may reduce in some way a safety margin, but where the results of the change are clearly within all acceptable critoria with respect to the system or component specified in the Standard Revicw Plan. The amendment authorizing this change would not result in a significant change in operation of the unit.

The results of any change in operation from this proposed amendment would remain clearly within all acceptable

criteria with respect to the system or component specified gg' in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, July 1981, Section 10.4.4, " Turbine Bypass System."

Thus, operation of the facility in accordance with the proposed amendment involves no significant hazards considerations.

V. IMPLEMENTATION It is requested that the amendment authorizing this change become effective upon issuance and shall be implemented within thirty days of receipt.

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