ML20073C734

Requests Regional Temporary Waiver of Compliance from Requirement to Conduct Control Rod Movement Surveillance Test Per TS as Stated

ML20073C734
Person / Time
Site:	Three Mile Island
Issue date:	01/21/1994
From:	Broughton T GENERAL PUBLIC UTILITIES CORP.
To:	Martin T GENERAL PUBLIC UTILITIES CORP.
References
NUDOCS 9409260130
Download: ML20073C734 (3)

Text

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GPU Nuclear Corporation Nuclear  ;;;,o=*

Midoletown, Pennsylvania 17057 0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Numoer:

(717) 948-8005 January 21, 1994 C311-94-2010 Mr. T. T. Martin Regional Administrator, Region 1 US Nuclear Regulatory Comission '

475 Allendale Road King of Prussia, PA 19406-1415

Dear Sir:

Three Mile Island Station Unit 1 (TMI-1)

Operating License No. OPR-50 Docket No. 50-289 Request for a Regional Temporary Waiver of Compliance On January 20,1994, at 11:00 a.m., GPU Nuclear orally requested a regional ,

temporary waiver of compliance from the requirement to conduct the Control Rod Movement surveillance test. At 12:55 p.m. on January 20, 1994, Ms. Michele Evans, TMI Senior Resident Inspector, informed Mr. Jack Wetmore, Manager, TMI Licensing,'that the request had been granted. This letter is a. followup to GPU Nuclear's oral request for a regional temporary waiver of' compliance.

The Control Rod Movement surveillance test is a requirement of TMI-1 Technical SHicification 4.1.2 (Table 4.1-2). The current due date for the surveillance is T sursday, January 20,1994 and the late date for the surveillance (the allowable surveillance frequency of 14 days plus 25%) will be Sunday, January 23, 1994.

GPU Nuclear requested a waiver of compliance be effective iemediately until January 28, 1994. GPU Nuclear intends to perform the surveillance on or before January 28, 1994.

The temporary waiver of compliance was requested to minimize the possibility of a reactor power reduction or trip as a consequence of surveillance testing that is required to be performed during the extremely cold weather which the PJM grid is currently experiencing. TMI-1 has previously experienced a reactor power ,

reduction due to an inadvertent rod drop that occurred during the performance of the htweekly control rod movement surveillance that was the result of a faulty cable / stator electrical connection (December 12,1991). Note: The inadvertent rod drop did not affect the ability of .the Control Rod Drive Mechanisms to perform their safety function.

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The requested duration for the waiver of compliance will allow GPU Nuclear to postpone the performance of the Control Rod Movement surveillance testing until the extremely cold weather has abated and the PJM grid is restored to normal conditions (no voltage reductions or blackouts). .

The Commonwealth of Pennsylvania has declared a state of emergency in response  ;

to the current unprecedented extremely cold weather. The PJN grid is currently undergoing mandatory voltage reductions and rolling blackouts. It is in the public interest to minimize all activities that could jeopardize current electrical production.

The safety significance of postponing the performance of the surveillance until January 28, 1994 is minimal. The biweekly surveillance interval stated in current TMI-1 Technical Specifications is very conservative when compared to the 92 day surveillance interval specified in NUREG 1430, Revised Standard Technical ,

Specifications (RSTS) for BW Plants. The intent of the surveillance is to ,

ensure control rod movement, trippability and the reliability of the control rod mechanisms. The control rod mechanism movement surveillance has been -

i successfully performed in accordance with the surveillance interval since the i

plant returned to power after the 10 R outage. The reliability of the control rod mechanism can be assured during the period for which the temporary waiver of '

compliance has been requested by monitoring other available indicators of control I rod performance that are obtained from other Technical Specification recuired '

surveillance activities and from plant instrumentation such as the asyneetr' c rod '

position indicator alare.

We note that RSTS for BW Plants specifies a 92 day surveillance frequency for  !

i the performance of verifying control rod freedom of movement (SR 3.1.4.2, page 3.1-9) ver. sus the 14 day surveillance interval in the TMI-1 Technical ,

specifications. The Bases for the RSTS 3.1.4.2 (page 3.1-26) states the bases  ;

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for the g2 day surveillance interval takes into consideration other information available to the operator in the control room and the RSTS requirement for ,

verification that individual control rod positions are within 6.5% of their group  :

average be performed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> with the reactor at power. Along this same  !

line, TMI-1 Technical Specification 4.1-1.23,24 requires verification of control j rod absolute / relative position comparison be performed on a shiftly (once every  ;

12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />) surveillance interval with the plant critical. This requirement is  :

implemented by GPU Nuclear via TMI-1 Surveillance Procedure 1301-1.

The requested temporary waiver of compliance does not involve a significant  ;

hazards consideration because:  ;

1. There is no significant increase in the probability or consequences of an accident previously evaluated because control rod mechanism l i

operability is verifiable via other available information' and Technical Specification required surveillance and because the  !

sacified duration of the temporary waiver of compliance is much less t tinn the 92 day surveillance i.nterval that would be allowed under  ;

NUREG 1430. .

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C311-94-2010 Page 3

2. It will not create the possibility of a r:ew or different kind of i accident from any accident previously evaluated. A one-time change in the frequency in the performance of the control rod movement surveillance does not change plant operations or have any impact en .

l plant systems, structures or components, and I

3. It does not involve a significant reduction in a margin of safety.

The frequency of Technical Specification surveillance is not a specified margin of safety in TMI-1 Technical Specifications. ,

i The temporary waiver of compliance will not involve irreversible environmental consequences because the extension of the surveillance interval has no impact on plant operations or plant effluents. l The TMI-1 Plant Review Group reviewed and approved the action to request a temporary waiver of compliance from the specifded 14 day frequency requirement for the control rod movement survalliance on Wednesday, January 19, 1994, t

GPU Nuclear appreciates the prompt NRC review and approval of the temporary l

waiver of compliance. If you have any questions regarding this matter, please contact Mr. John Schork, TMI Licensing Engineer at (717) M S-8432. l Sincerely, T. G. Broughton Vice President & Director, TMI

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JSS/enf cc: M. G. Evans - TM1 Senior Resident Inspector R. W. Hernan . Senior Project Manager Document Control Desk i

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. I TOTAL P.04