ML20085N155

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TS Change Request 227 to License DPR-50,replacing Pages for App A.Certificate of Svc Encl
ML20085N155
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 06/22/1995
From: Broughton T
GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20085N146 List:
References
NUDOCS 9506300071
Download: ML20085N155 (6)
v • d • e


Text

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m METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER & LIGHT COMPANY  !

AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION, UNITS 1

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Operating License No. DPR-50 1 Docket No. 50-289 Technical Specification Change Request No. 227, Supplement 1 COMMONWEALTH OF PENNSYLVANIA )

) SS: j COUNTY OF DAUPHIN )

This Technical Specification Change Request supplement 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. l 1

GPU NUCLEAR CORPORATION f E UN h BY: I C 8m1 Me4.

Vice President and Director, TMI Sworn and Subscribed to before me this D day of One ,1995.  !

O 950630oo71 950622 PDR ADOCK 0500o289 AAo bd Notary Public mw emumans. suse Hy

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' UNITED STATES OF AMERICA'  :

NUCLEAR REGl'_ATORY COMMISSION i

i IN THE MATTER OF DOCKET NO. 50-289 GPU NUCLEAR CORPORATION LICENSE NO. DPR-50 ,

t CERTIFICATE OF SERVICE 1 This is to cenify that a copy of Technical Specification Change Request (TSCR) No. 227,.

Supplement I to Appendix A of the Operating License for Thme Mile Island Nuclear Station -

Unit 1, has, on the date given below, been filed with executives of Iondonderry Township, ,

Dauphin County, Pennsylvania; Dauphin County, Pennsylvania; and the Pennsylvania -

Depanment of Environmental Resources, Bureau of Radiation Pmtection, by deposit in the .  ;

United States mail, addressed as follows: '

i Mr. Jay Kopp, Chairman Mr. Russell L. Sheaffer, Chairman '  :

Board of Supervisors of Board of County Commissioners  !

I.ondonderry Township of Dauphin County ~

R. D. #1, Geyers Church Road Dauphin County Counhouse ,

Middletown, PA 17057 Harrisburg, PA 17120 .

Dimetor, Bureau of Radiation Protection 3 PA. Depanment of Envimnmental Resources  ;

Fifth Floor, Fulton Building  ;

Third and Iocust Streets  !

P. O. Box 2063 i Harrisburg, PA 17120 .l Attn: Mr. Roben J. Barkanic j i'

GPU NUCLEAR CORPORATION

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BY:

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% C. 6 % ,(h4 h l Vice President and Director, TMI DATE: #2/fI

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?. ' ' C311-95-2245 : .

<v ,; Enclosure 1L ,

j Page'l' I

- GPU NUCLEAR RESPONSE TO'NRC REQUEST FOR' ADDITIONAL INFORMATION _;

p FOR TMI TECHNICAL SPECIFICATION CHANGE REQUEST NO. 227 .:

l FOR INCORPORATING CERTAIN STANDARD TECHNICAL SPECIFICATIONS h1

1. Containment Airlocks  !

STS 3.6.2.C.I requires immediate initiation of action to evaluate overall containment f L leakage ate per LCO 3.6.1 (which in turn references 10 CFR 50, Appendix J) when one ,

or more containment air locks are inoperable for reasons other than those stated in STS 3.6.2.A and 3.6.2.B. The proposed TS 3.6.12.d pmvides no specific guidance or  :

criteria regarding this leakage rate evaluation and does not include reference to or the.

requirements of 10 CFR 50, Appendix J. Please provide clarification in the form a i revised TS page 3-41.b. .!

GPU Nuclear Response f i

Attached are revised TS pages which include additional verbiage taken from the Standard Technical Specifications (STS) for B&W Plants (NUREG-1430). TMI-l TS 3.6.12.d and -

the corresponding bases have been revised to provide the specific guidance and criteria i associated with this leakage rate evaluation. A reference to the requirements of 10 CFR 50, Appendix J has been added as follows:

a. ' Page 3-41b has been revised' to clarify that the overall containment leakage rate is to [

be evaluated with respect to the requirements of 10 CFR 50, Appendix J, as 'i modified by appmved exemptions. .;

b. Page 3-41c has been revised to include the following STS bases statement: _

" Maintaining the containment OPERABLE requires compliance with the visual  ;

examinations and leakage rate test requirements of 10 CFR 50, Appendix J (Ref.1),

as modified by approved exemptions." *

c. Page 3-41d has been revised to include a reference to 10 CFR 50, Appendix J. j
2. Hydroeen Recombiner System- l l

The proposed changes to TS 4.4.4.1 do not include the performance criteria for the recombiner system functional test and heater electrical circuit integrity as given in the current TMI-l TS and the STS. Please explain why the performance criteria described j above do not need to be retained in the TS.  ;

1 I

i

"__ _ .- _ ., _. _____i

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. C311-95-2245 _

2 ~ ,, Enclosure 1 -

Page'2  ;

i GPU Nuclear Response -l The revised TS page incorporates the performance criteria from TS's 4.4.4.1.b.3 and- 3 4.4.4.1.b.4 as follows:

I

a. For the hydmgen recombiner system functional test, verify that the reaction  !

chamber gas temperature is maintained 21200*F for at least four hours.' j

b. For the resistance to gmund test of each heater phase, verification that the- i resistance to ground for any heater phase is 210,000 ohms.  !

c As discussed with'the NRC in a meetin'g on March 20,1995, GPU Nuclear feels that if the performance criteria are required to be specified,- they should be part of the specification rather than the bases.

3. Reactor Building '

A proposed change has been made to TS page 3-41 (TS 3.6.7) that would delete the requirement to bring the reactor to hot shutdown within seven days when the hydrogen  ;

recombiner is inoperable. Please pmvide justification for the change to TS 3.6.7.

GPU Nuclear Response Deletion of the requirement to bring the reactor to hot shutdown within seven days when the hydmgen recombiner is inoperable was not intended. The intent had been to revise ,

TS 3.6.7 to match the STS requirement. The attached revised TS page 3-41 _

incorporates the STS and changes TS 3.6.7 which currently reads "... restore the recombiner to operable status or bring the reactor to HOT SHUTDOWN within seven (7) days" to read "... restore the inoperable hydmgen recombiner to operable status  ;

within 7 days or be in HOT SHUTDOWN within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />."

4. Emereency Contml Room Air Treatment System I

This submittal proposed a change in TS 4.12.1.2.d to incorporate a variation of  !

STS 3.7.10.1 (i.e., operate each [ Control Room Emergency Ventilation System (CREVS)] train for 2 15 minutes every 31 days) which is intended only for control mom emergency ventilation systems without heaters upstream of the charcoal beds. l However, the TMI-1 Emergency Control Room Air Treatment System does contain .

heaters upstream of the charcoal beds. In that case, the STS specifies opemting each ;l train of the system for 210 hours0.00243 days <br />0.0583 hours <br />3.472222e-4 weeks <br />7.9905e-5 months <br /> every 31 days. This surveillance is specified in Regulatory Guide 1.52, Revision 2 (which is referenced in the TS bases). As stated in the STS bases, and RG 1.52, operation of the heaters on a monthly basis is intended to

C311-95-2245

.. Page 3 dry out (or reduce) moisture that has built up in the charcoal adsorbers because of humidity in the ambient air. The amendment request stated that the heaters are not needed for humidity control because the inlet air flow to the system is a combination of about 75% return air and 25% outside air, with maximum relative humidities of 50%

and 100%, respectively. It was therefom stated that the resultant inlet flow should never exceed 70% relative humidity without operation of heaters, which is the reference humidity specified in Table 2 of RG 1.52, "Labomtory Tests for Activated Carbon."

Although the argument has some merit and the proposed change would result in a .

burden reduction, the GPUN submittal does not provide adequate information for the staff to allow deviation from the STS requirements nor does it provide any compensatory measures, which might include laboratory test verification data, that would justify or substantiate the GPUN statement that mnning the monthly operational test for only 15 minutes and without energizing the electric heating coils will not degrade the performance of the system. Please provide additionaljustification for your request.

GPU Nuclear Resnonse  ;

Reference:

TMI-l P&ID 302-842, Sheet 1 of 2 Thermostatically controlled preheat heating coils (AH-C-5A/B), are located in the ponion of the TMI-l Control Building Ventilation System (CBVS) upstream of the Control Room Emergency Ventilation System (CREVS) loop. These heaters are provided for habitability and are not required or relied upon for operability of the CREVS. They are not designed for nor are they needed for humidity control and their ,

operation is not required by the current TMI-l Technical Specifications during testing.

A single temperature controller in each train (TC-737 or TC-738) controls the operation of both the preheaters upstream and the coolers (AH-C-6A/B) downstream of the i emergency supply fans (AH-E-18A/B) to provide either heating or cooling as necessary l to maintain the desired temperature. Therefore, during surveillance tests of the CREVS i performed to date, the heaters would have only been energized during cold weather I

conditions. During warm weather conditions (and often high humidity conditions) the heaters are not energized. I Listed below are the results from laboratory analysis of the CREVS charcoal for the last five years. TMI-l TS mquires laboratory carbon sample analysis results 2:90 %,

radioactive methyl iodide decontamination efficiency when tested at 125 F and 95%

relative humidity. Additional tests at 30 C and 95% relative humidity are performed for additional information. These results demonstrate that performance of the surveillance tests without energizing the heaters for a large percentage of the year has not resulted in degradation of the charcoal bed performance.

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C311-95-2245 Page,4 .

CONTROL ROOM EMERGENCY VENTILATION SYSTEM LABORATORY CHARCOAL ANALYSIS Train Test Charcoal Efficiency (%) Charcoal Efficiency (%)

Date (TMI-1 Tech spec Test - (TMI-1 Information only Test -

@ 125'F & 95% Relative Humidity) @ 30*C & 95% Relative Humidity)

A 6/94 99.19 97.23 B 6/94 98.99 97.04 A 7/93 98.54 94.61 B 7/93 98.36 96.54 A 7/92 99.29 95.31 B 7/92 99.22 96.77 A 8/91 99.84 92.75 B 8/91 99.98 96.64 A 8/90 99.97 98.84 B 8/90 99.84 99.79 Opemting the two CBVS fan / filter circuits in the emergency mode for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each month creates unnecessary hardship during warm weather conditions in that the emergency mode shuts off the majority of the cool air supply to the first floor of the Control Building. This first floor contains plant chemistry sample rooms and labs, health physics offices, and check in/ check out points. After a period of time, elevated temperatures cause personnel discomfort and unnecessary heating of the equipment in these areas.

GPU Nuclear has concluded that operation of the CREVS fan / filter circuits for 15 minutes each month is adequate to demonstrate operability and will not result in a buildup of moisture in the charcoal beds sufficient to adversely affect system performance.

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