ML20082P411

Tech Spec Change Request 211 to License DPR-50,requesting Deletion of Note in Tech Spec Section 3.24 Which Provides Operability Requirements for Reactor Coolant Inventory Trending Sys Only to End of Cycle 8

ML20082P411
Person / Time
Site:	Three Mile Island
Issue date:	09/05/1991
From:	Broughton T GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20082P409	List: ML20082P407 ML20082P411 ML20082P415
References
NUDOCS 9109100319
Download: ML20082P411 (4)

Text

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METROPOLITAN EDIS0N 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. 211 This Technical Specification Change Request is submitted in support of Licensee's request to change Appendix A to Operating License No. DPR-53 for Three Mile Island Nuclear Station, Unit 1. As a part of this request, proposed replacement page(s) are included.

GPU NUCLEAR CORPORATION BY:

Vice Presidentv& Director, TMl-1 Sworn and Subscribed to before me this 5th day of September , 1591.

yng(lcn k y$ - Y'CY:L.)

Notary Public e "T"R,m cm

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ICI maernerenwommmesmmw*mmes 9109100319 910905 9 DR ADOCK 0500 l

l UNITED STATES OF AMERICA l, NUCIEAR REGULATORY COMMISSION  ;

t IN THE MATTER OF DOCKET N0 50-289 GPU NUCLEAR CORPORATION LICENSE NO. DPR-50 r

CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No.

211 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: '

Mr. Jay H, Kopp, Chairman Ms. Sally S. Klein, Chairman ,

Board of Supervisors of Board of County Commissioners Londonderry Township of Dauphin County  ;

R. D. #1, Geyers Church Road Dauphin Coui.ty Courthouse -

Middletown, PA 17057 Harrisburg, PA 17120 ,

Mr. Thorras Gerusky, Director .

PA. Dept. of Environmental Resources Bureau of Radiation Protection  :

P.O. Box 2063 Harrisburg, PA 17120 l GPU NUCLEAR CORPORATION

"~

BY: ^P ~

Vice Preside ()t & 0irector, THI-l ,

r DATE: 1/T/11 i t

1. lethnird.Jgetification Chance Reouest No _211 GPU Nuclear requests that the follnwing revision be made to the facility technical specification:

) Replace page 3-128

11. Reason for_(hanga Currently, Technical Specification (TS) Section 3.;4, Reactor Coolant Inventory Trending System (RCITS), is approved only to the erJ of Cycle 8 27, 1991. At that time the operation, which will occur on Septembercurrent technical specifications r is consistent with the Standard Technical Specification (STS) resulting from the NRC - initiated Technical Specification Improvement Program.

The specific change to Technical Specification 3.24 is as follows:

Page 3-128 has been revised to delete the " note" requiringTSCR GPUN to propose No. 211 an amendment consistent with the STS for Section 3.24.

responds to that requirement, as clarified below.

111. Safety Evaluation RCITS is an information system which provides an indication of the trend in water inventory in the hot legs and reactor vessel during the approach to inadequate core cooling (ICC). In this manner, RCITS provides additional information to the operator to aid in diagnosing the app,oach to ICC and to assess the adequacy of responses taken to restore core cooling.

This TSCR does not modify the existing denign of the RCITS system nor existing procedural practices. This is strictly an administrative change deleting the aforementioned note in Section 3.24.

Draft NUREG 1430. Vol.1, Standard Technical Specifications - Babcock and Wilcox plants, presents the results of the NRC's staff review of the Babcock and Wilcox Owners Group (B&WOG) proposed new STS and is currently under a review and coment process.

Draft NUREG 1430 covers RCl!S in Section 3.3, Instrumentation, under Table 3.3.16-1 as Item 5, Reactor Vessel Water Level. The Limiting Condition of Operation (LCO) for RCllS requires two (2) operable channels; otherwise, conformance with Condition E, therein, is required. Condition E requires actions in accordance with NUREG 1430 Specification 5.9.2.0.

When a pre-planned alternate method of monitoring post-accident instrumentation functions is required by Condition E of LCO 3.3 [16],

Specification 5.9.2.C requires that a report be submitted to the NRC within 14 days from the time the action resulting from inoperability is required. This rcport must contain the actions taken, the cause of the inoperability, and the plans and schedule for restoring the B&WOG instrumentation channels of the function to operable status.

comments on Draft NUREG 1430, contained in B&WOG letter to NRC OG-919, dated July 31, 1991, maintain this requirement.

A basic differ::nce between the draft HUREG 1430 requirements and the current TMI-l Tec.hnical Specifications is in the reporting period following inoperability of a channel (s) associated with RCITS. With one required channel or two required channels inoperable, the Draft NUREG 1430, Section 3.3.16 requires restoring the inoperable channel or one of the two inoperable channels to service in 30 days or 7 days, respectively.

If this condition is not met, the Draft NUREG requires reportsbility as indicated above. The current THI-1 Technical Specification Seuion 3.24 requires at least one channel be returned to operable status as soon as i possible. If at least one channel is not restored within 30 days, details similar to that required by the Draft NUREG shall be provided in the Monthly Operating Report. ,

The difference in the time of reporting is justified since THI-1 has additional instrumentrtion available which can be used to detect Inadequate Core Cooling such as the saturation margin monitor, core exit thermocouples, backup incore therhoocouples and other instrumentation discussed in the UFSAR, Section 7.3.2.2.C.10. The current TMI-1 Technical Specifications also provide separate operability requirements for the  !

saturation margin monitor and backup incore thermocouple display channels. l In summary, inoperability of the RCITS should not prevent detection of an  !

inadequate core cooling condition at TMI-1. As such, there is no exigent basis for a 14 day reporting period. Since no other changes to the RCITS Technical Specification requirements are proposed by the Draft NUREG, it is appropriate to delete the " note" in Section 3.24 of the current TM1-1 Technical Specifications. l IV, No Sianificant Hazards Consideration GPU Nuclear has determined that this TSCR poses no significant hazards as defined in 10 CFR 50.92 in that operation of TMI-1 in accordance with the proposed amendment will not:

1. Involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated.

Deleting- the " note" in Technical Specification Section 3.24, which provides operability requirements only to the end of Cycle 8, does not involve any changes to the design of the RCITS System or applicable procedures. Since this is an administrative change permitting continued implementation of TS 3.24 during future operating cycles, it has no effect on the probability of occurrence or consequences of any accidents previously evaluated.

2. Create the possibility of a new or different kind of accident from any accident previously evaluated.

The administrative change requested herein does not modify the existing plant configuration, or existing procedures, ner create new ones. As such, this TSCR does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Involve a significant reduction in a margin of safety.

The administrative change requested herein does not affect the plant configuration, procedures or operation. RCITS is an information system which is intended to enhance the accident monitoring capability and does not reduce safety. As such, margin of safety is unaffected by this TSCR.