ML20112K125

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Safety Evaluation Supporting Amend 106 to License DPR-50
ML20112K125
Person / Time
Site: Crane 
Issue date: 03/21/1985
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20112K122 List:
References
NUDOCS 8504090348
Download: ML20112K125 (4)


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UNITED STATES y

g NUCLEAR REGULATORY COMMISSION

j WASHINGTON, D. C. 20555

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SAFETY EVALUATION BY THE OFFICE 0F NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO.106 TO FACILITY OPERATING LICENSE NO. DPR-50 METROPOLITAN EDISON COMPANY s1ERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY GPU NUCLEAR CORPORATION THREE MILE ISLAND NUCLEAR STATION, UNIT NO. 1 DOCKET NO. 50-289 1.

INTRODUCTION Operating experiences, advances in the state-of-the-art, voids in some specific requirements, and nonuniform interpretations indicated the need for changes, clarifications, and improvements in the Standard Technical Sp.ecifications (STS) for inservice operability and surveillance requirements for snubbers. To reflect accumulated experience obtained in the past several years, the NRC staff issued Revision 1 of the snubber STS. By letters dated November 20, 1980, to power reactor licensees (except SEP licensees) and March 23, 1981, to SEP licensees, the NRC requested all licensees to incorporate the requirements of this STS revision into their plant specific Technical Specifications (TS).

The revised STS included:

- Addition of mechanical snubhers to the surveillance prnaran;

- Deletion of the blanket' exemption for testing of greater than 50,000 lb. rated: capacity snubbers (Snubbers of areater than 50,000 lb.

capacity are now included in the testing program.);

- Deletion of the requirement that seal material receive NRC approval;

- Clarification of test requirements;

- Provision for in-place testing; and

- Addition of a service life monitoring program.

Recently, by letter dated May 3,1984, the NRC advised licensees that an amendment request reay be submitted to delete the snubber Table listing from their TS if the licensee so chooses.

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DISCUSSION In response to the NRC reouest, by letter dated June 8,1981, the licensee subnitted an application for license amendment and proposed TS changes for operability and surveillance requirements for snubbers. By letter dated February 17, 1984, the licensee resubmitted a revised proposed snubber TS change which superseded the previous request in its entirety.

The NRC staff has reviewed the licensee's February 17, 1984, resubmittal of proposed snubber TS changes. In addition, an inspection relating to snubbers was performed at the licensee's plant and discussions were held with coanizant licensee personnel regarding the proposed TS changes.

The staff review compared the proposed snubber TS with the model STS and TS recently approved for Near Term Operating Licenses (NT0Ls). The g

facility inspection and discussions with cognizant personnel provided a means to observe snubber installation and testing practices and to review the supplementary procedural documentation needed for implementation of the TS, and to obtain clarification of several of the proposed changes.

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EVALUATION The staff has evaluated the licensee's snubber TS submittal a'nd has found it to be in substantial agreement with the intent of the STS and the recently approved TS for NT0Ls. The licensee's proposed snubber TS clarify and increase snubber surveillance, define testing and acceptance criteria, include a snubber seal service life program (this plant only has hydraulic snubbers), and commits the licensee to develop a functional test program for the four 550,000 lb. reactor coolant pump snubbers.

The specific aspects of the licensee's proposed snubber TS which are different than the STS or the recently approved TS for MTOLs and reouire further explanation are addressed below.

3.1 VISUAL INSPECTION ACCESS The licensee's proposed TS 4.17.1.b contains tre provision to visually inspect snubbers in accordance with the STS tabular schedule. The licensee's proposed TS 4.17.1.b also contains the provision that snubbers inaccessible during normal operation shall be inspected during each reactor shutdown greater than 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> where access is restored, unless previously inspected in accordance with the tabular schedule'. The access restoration provision is related to radiation in the reactor building. Restoring access is recognized to be dependent on the licensee's capability to establish appropriate habitability in the areas to be inspected.

Pased on the licensee's stated intent to make every reasonable effort to restore access, the staff finds the licensee's provision for access restoration to perform visual inspection to be acceptable.

I e-3.2 FUNCTIONAL TESTING OF LARGE SNUBBERS The licensee's submittal implicitly excludes the reactor coolant pump snubbers from proposed TS 4.17.1.e because the bases section contains the commitment to develop a functional test program for the 550,000 lb.

reactor coolant pump snubbers and to submit this program to the NRC for approval by Cycle 6 refueling. The staff realizes that functional testing of these exceptionally large size snubbers in accordance with the STS cannot be done until a testing program has been developed. Based on the licensee's comitment to develop the test program and to submit it to NRC for review, the staff finds this limited time delay in testing of these large snubbers to be acceptable.

3.3 SNUBBER SEAL SERVICE LIFE PRGGRAM The licensee's proposed TS 4.17.1.i contains the' provision that a snubber seal replacement program shall be developed to monitor and replace seals so their service life will not be exceeded. The proposed TS includes the provision to fully implement this program by startup following Cycle 7 refueling. The staff recognized that the STS inclusion of a service life program would require time to develop and implement the necessary procedures. A recent inspection of the facility verified that the licensee has already partially implemented the program and is proceeding with revisions for full implementation of the program. Based nn the licensee's commitment and the staff's verification of progress made, the staff finds the licensee's schedule for implementation to be acceptable.

3.4 TS SNUBBER TABLES The licensee's proposed snubber TS does not contain a table lis+ina o' snubbers. The licensee has provided acceptable.iustification for the proposed table deletion; that a complete safety related snubber list with appropriate detailad information is maintained in plant procedures and any change to the list of safety related snubbers would be subject to 10 CFR 50.59 review. The most recent NRC letter to licensees dated May 3,1984, permits removal of snubber TS Tables on the same premise as the licensee's oroposal; therefore the staff finds the proposed TS snubber table deletion acceptable.

3.5 PLANT SPECIFIC INSTALLATION DIFFERENCES The lice.nsee's oroposed snubber TS does not contain the STS provisions related to mechanical snubbers or to common hydraulic i

fluid reservoirs. The licensee has stated that these items are not I

installed at the facility; therefere the staff finds the omission of these provisions to be acceptable.

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ENVIRONMENTAL CONSIDERATION This amendment involves a chance in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 70' and surveillance reouirements. We have determined that the amendment involves no significant increase in the amounts, and no significant chance in the types, of any 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 this amendment involves no sienificant hazards consideration and there has been no public comment on such #indino.

Accordingly, this amendment meets the eligibility criteria for catecerical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.27(bl, ne environmental impact statement or environmental assessment need be prepared in connection with the issuance o# this amendment.

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CONCLUSION

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We have concluded, based on the considerations discussed above, that: (11 there is reasonable assurance that the health and safety of the public will not be endancered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's renulations and the issuance of this amendment will not be inimical to the conmon defense and security or to the health and safety o# the oublic.

Dated: March 21,1985 The following NRC personnel have contributed to this Safety Evaluation:

Parold Gregg, and Donald Haverkamp.

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