ML20073S394
| ML20073S394 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/23/1994 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20073S392 | List: |
| References | |
| GL-88-16, NUDOCS 9406030030 | |
| Download: ML20073S394 (5) | |
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WASHINGTON. D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.184 TO FACILITY OPERATING LICENSE NO. DPR-50 METROPOLITAN EDIS0N COMPANY JERSEY CENTRAL POWER & LIGHT COMPANY l
PENNSYLVANIA ELECTRIC COMPANY GPU NUCLEAR CORPORATION THREE MILE ISLAND NUCLEAR STATION. UNIT NO. 1 DOCKET NO. 50-289
1.0 INTRODUCTION
By letter dated November 30, 1993, the GPU Nuclear Corporation (the licensee) submitted a request for changes to the Three Mile Island Nuclear Station, Unit No. 1 (TMI-1) Technical Specifications (TS). The requested changes would relocate various cycle-specific values to the existing THI-l Core Operating Limits Report (COLR).
A number of TS address limits associated with reactor physics parameters that generally change with each reload core, requiring the processing of changes to TS to update these limits each fuel cycle.
The proposed changes are in accordance with Generic Letter (GL) 88-16 guidance with regard to placing cycle-specific parameter limits into the COLR and with the NRC-approved Babcock and Wilcox Fuel Company (BWFC) Topical Report BAW-10179P-A, " Safety Criteria and Methodology for Acceptable Cycle Reload Analyses." The THI-1 Cycle 10 COLR, submitted to the Commission on November 7, 1993, includes these limits to support the requested TS changes.
2.0 EVALUATION Section 50.36 of Title 10 of the Code of Federal Regulations (CFR) established the regulatory requirements related to the content of TS. The rule requires that TS include items in specific categories, including safety limits, limiting conditions for operation, and surveillance requirements; however, the i
rule does not specify the particular requirements to be included in a plant's TS. The NRC developed criteria, as described in the " Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors,"
(58 FR 39132) to determine which of the design conditions and associated surveillances need to be located in the TS.
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i i The Final Policy Statement adopted the subjective statement of the Atomic Safety and Licensing Appeal Board, ALAB 531, 9 NRC 263 (1979), (Trojan Nuclear Plant) as the basis for the criteria.
The Appeal Board stated,
... there is neither a statutory nor a regulatory requirement that every operational detail set forth in an applicant's safety analysis report (or equivalent) be subject to a Technical Specification, to be included in the license as an absolute condition of operation which is legally binding upon the licensee unless and until changed with specific Commission approval.
Rather, as best we can discern it, the contemplation of both the Act and the regulations in the Technical Specifications are to be reserved for those matters as to which the imposition of rigid conditions or limitations upon reactor operation is deemed necessary to obviate the possibility of an event giving rise to an immediate threat to the public health and safety."
Briefly, the criteria provided by the Final Policy Statement are (1) detection of abnormal degradation of the reactor coolant pressure boundary, (2) boundary conditions for design basis accidents and transients, (3) primary success paths to prevent or mitigate design basis accidents and transients, and (4) functions determined to be important to risk or operating experience.
The Commission's final policy statement acknowledged that its implementation may result in the relocation of existing technical specification requirements to licensee controlled documents and programs.
Specifically, GPU Nuclear proposed the following changes to the THI-1 TS:
(1) Changes in List of Figures (Page vii)
TS Page vii, List of Figures, is revised to indicate deletion of Figures 2.1-2 and 2.3-2.
(2) Changes in TS Section 2.1 (Pages 2-1, 2-2, 2-3, and 2-4b)
(a) TS Section 2.2.1 wording TS Section 2.2.1 is revised to replace " safety limit" with " protective limit" consistent with Topical Report BAW-10179P-A and Babcock and Wilcox Owner's Group (BWOG) Standard Technical Specification (STS) wording in NUREG-1430.
(b) Axial Power Imbalance Protective Limits The Bases for TS Section 2.1 are revised to reference the axial power imbalance protective limits in the COLR in lieu of reference to Figure 2.1-2.
Figure 2.1-2 is removed and incorporated into the THI-l COLR.
4 J (c) Nuclear Power Peaking Factor i
The Bases for TS Section 2.1 are also revised to remove the design nuclear power peaking factors and provide a reference to the COLR.
(d) Maximum Allowable Local Linear Heat Rate 1
The Bases for TS Section 2.1 is also revised to remove the maximum allowable local linear heat rate limit to the COLR. This limit is the basis for the imbalance portions of the axial power imbalance protective limits and setpoints. The limit is established for each core design.
The methodology for determining the maximum allowable local linear heat j
l rate is described in BAW-10179P-A, which was approved by the NRC in a safety evaluation report (SER) dated March 16, 1993.
i (3) Changes in TS Section 2.3 (Pages 2-4c, 2-5, 2-6, 2-7, 2-10, and 2-12)
- Protection System Maximum Allowable Setpoints for Axial Power Imbalance TS Section 2.3.1 and Basis are revised to reference the protection system maximum allowable setpoints for axial power imbalance in the COLR, in lieu of reference to Figure 2.3-2.
Figure 2.3-2 is removed form the TS and is incorporated into the THI-1 COLR. Table 2.3-1 and TS Section 2.3 1
Basis are revised to reference the reactor protection system trip setting l
limits for nuclear power based on flow and imbalance in the COLR for all reactor coolant pump operating conditions.
These setpoint curves, known i
as the power / imbalance / flow trip, provide steady-state protection for the 1
axial power imbalance protective limits and therefore may provide additional protection for the centerline fuel melt and criteria.
TS Figure 2.1-3 is administratively changed to be consistent with the removal to the COLR of the power-to-flow limit and setpoint.
By approving BAW-10179P-A, the NRC allowed licensees to remove the j
power / imbalance / flow trip setpoint envelope from the TS to the COLR.
I The licensee states that the specific values of the limits in the TMI-1 COLR 1
will be modified through the 10 CFR 50.59 process when such values are developed using NRC-approved methodologies consistent with all applicable limits of the safety analyses addressed in the TMI-1 Final Safety Analysis Report. As currently required by TS Section 6.9.5.4, any revisions to the COLR will be provided to the Commission upon issuance for trending information. The THI-l Cycle 10 COLR, submitted to the NRC on November 7, 1993 (C311-93-2140), includes these protective and maximum allowable setpoint limits and nuclear overpower trip setpoints to support these TS changes.
Plant operation will continue to be limited in accordance with the values of cycle-specific limits that are established using NRC-approved methodologies and the calculational methodologies and acceptance criteria are specified in 4
the TS.
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. The staff's review of the proposed change determined that the relocation of the setpoints for the axial power imbalance and flux-to-flow instruments does not eliminate the requirements for the licensee to ensure that those instruments are capable of performing their safety functions.
Although these setpoints are relocated from the TS to the COLR, the licensee must continue to evaluate any changes to these setpoints in accordance with 10 CFR 50.59.
Should the licensee's determination conclude that an unreviewed safety question is involved, due to either (1) a significant increase in the probability or consequences of accidents or malfunctions of equipment important to safety, (2) the creation of a possibility for an accident or malfunction of a different type than any evaluated previously, or (3) a significant reduction in the margin of safety, NRC approval and a license amendment would be required prior to implementation of the change.
NRC inspection and enforcement programs also enable the staff to monitor facility changes and licensee adherence to NRC regulations and licensee commitments and to take any remedial action that may be appropriate.
The staff's review concluded that 10 CFR 50.36 does not require the setpoints for the axial power imbalance and flux-to-flow instruments to be retained in the TS.
Requirements related to the operability, applicability, and surveillance requirements, including performance of testing to ensure operability of these instruments, is retained due to their importance in mitigating the consequences of an accident.
However, the staff determined that the inclusion of the specific setpoints are an operational detail related to the licensee's safety analyses which are adequately controlled by the requirements of 10 CFR 50.59.
Therefore, the continued processing of license amendments related to revisions of the affected setpoints, where the revisions to those requirements do not involve an unreviewed safety question under 10 CFR 50.59, would afford no significant benefit with regard to protecting the public health and safety.
The staff has concluded, therefore, that relocation of the setpoints for the axial power imbalance and flux-to-flow instruments is acceptable because (1) their inclusion in technical specifications is not specifically required by i
10 CFR 50.36 or other regulations, (2) the setpoints have been relocated to the COLR, are adequately controlled by 10 CFR 50.59, and.their inclusion in the TS is not required to avert an immediate threat to the public health and safety, and (3) changes that are deemed to involve an unreviewed safety question, will require prior NRC approval in accordance with 10 CFR 50.59(c).
3.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendment. The State official had no comments.
4.0 ENVIRONMENTAL CONSIDERATION
The amendment changes requirements with respect to installation or use of a facility component located within the restricted area as defined in
, 10 CFR Part 20. The NRC staff has determir.ed that the amendment involves no l
significant increase in the amounts or types of effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (59 FR 2867). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
5.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor:
C. Chung, W. Reckley, and R. Hernan Date: May 23, 1994 l
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