ML20113D190
| ML20113D190 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 06/28/1996 |
| From: | James Knubel GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20113D192 | List: |
| References | |
| 6710-96-2221, NUDOCS 9607030058 | |
| Download: ML20113D190 (9) | |
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.A GPU Nuclear Corporation N UCIe M Route 441 South P.O. Box 480 Middletown, Pennsylvania 17057-0480 (717)944-7621 Writer's Direct Dial Number:
(717) 948-8005 June 28,1996 6710-96-2221 U. S. Nuclear Regulatory Commission Att: Document Control Desk Washington, DC 20555
Dear Sir:
Subject:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR 50 Docket No. 50-289 Technical Specification Change Request No. 259 Implementation of 10 CFR 50 Appendix J, Option B In accordance with 10 CFR 50A(b)(1), enclosed is TMI-l Rhnical Specification Change Request (TSCR) No. 259. The purpose of this TSCR is to allow implementation of the recently appmved Option B to 10 CFR 50, Appendix J. This rule allows for a performance i
based option for determining the frequency for containment (Reactor Building) leakage rate testing.
Using the standards in 10 CFR 50.92, GPU Nuclear has concluded that these proposed changes do not constitute a significant hazards consideration, as described in the enclosed analysis performed in accordance with 10 CFR 50.91(a)(1). Also enclosed is a Cenificate of Service for this request, certifying service to the chief executives of the township and county in which the facilities are located, as well as the designated official of the Commonwealth of Pennsylvania, Bureau of Radiation Protection.
It is requested that an amendment authorizing this change be approved by February 1,1997 and effective ninety (90) days after issuance. The requested date is our scheduled date for completion of plans for the TMI-l Cycle 12 Refueling Outage which is scheduled to begin in early September 1997. The performance based Reactor Building leakage Rate Testing Progmm, as requimd by Option B of 10 CFR 50 Appendix J, and as identified by a new Section 6.8.5 of the TMI-1 TS. will be contained in the surveillance Building inspection, Integrated leak Rate Testing, and local Leak Rate Testing.
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.6710-96-2221 Page 2 of 2 This program will be developed through revision of these procedures to contain the necessary 2
requirements to ensure testing is consistent with Regulatory Guide 1.163, " Performance-Based Containment Ixak-Testing Program," dated September 1995.
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j These changes are being submitted to the NRC as a Cost Beneficial Licensing Action. The j
proposed changes will provide a cost savings in excess of $100,000 over the remaining life of the plant without adversely impacting safety, as demonstated in NUREG-1493, and the j
enclosed license amendment application.
Sincerely, i
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J. Knubel Vice President and Director, TMI MRK i
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Enclosures:
- 1) Certificate of Service for TMI-l TSCR No. 259
- 2) TMI-l TSCR 259 Evaluation and Significant Hazards Consideration j
- 3) TMI-l Technical Specifications Revised Pages 1
i cc:
Region I Administrator TMI Senior Resident Inspector TMI-I Senior Project Manager j
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION l
IN THE MATTER OF DOCKET NO. 50-289 GPU NUCLEAR CORPORATION LICENSE NO. DPR-50 CERTIFICATE OF SERVICE This is to cenify that a copy of Technical Specification Change Request (TSCR) No. 259 to Appendix A 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 Depanment of Environmental Resources, Bureau of Radiation Protection, by deposit in the United States mail, addressed as follows:
Mr. Darryl LeHew, Chairman Mr. Russell L. Sheaffer, Chairman Board of Supervisors of Board of County Commissioners Londonderry Township of Dauphin County R. D. #1, Geyers Church Road Dauphin County Courthouse Middletown, PA 17057 Harrisburg, PA 17120 Director, Bureau of Radiation Protection PA Depanment of Environmental Protection Rachel Carson State Office Building PO Box 8469 Harrisburg, PA 17105-8469 Attn: Mr. Stan P. Maingi GPU NUCLEAR CORPORATION BY:
i President and Director, TMI DATE: ( A 2V,/ffi
METROPOLITAN EDISON 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. 259 COMMONWEALTH OF PENNSYLVANIA )
) SS:
s COUNTY OF DAUPHIN
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This Technical Specification Change Request is submitted in support of Licensee's requert to change Appendix A to Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1. As pait of this request, proposed replacement pages are also included.
GPU NUCLEAR CORPORATION
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BY: o*
Vi President and Director, TMI i
1 Sworn and Subscritxxl to before me this j/,$ day of V##L,1996.
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Notary Public Notarial Seal Dobra S. Khck, Notary Pub 0c Londonderry Twp, Dauphin County My Commission Expires July 4,1998 Mmter, Pennsylvansa A"m*on of Nc'%4
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.' 6710-96-2221 Page 1 of 5
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TMI-l TECHNICAL SPECIFICATION CHANGE REOUEST (TSCR) NO. 259 GPU Nuclear requests that the following change be made to the existing TMI-1 Technical Specifications (TS):
A.
Replacement pages:
The following revised pages, provided in Attachment 2, replace existing TS pages:
3-41a, 3-41b, 3-41c, 3-41d, 4-29, and 4-30 B.
The following pages are to be removed from the existing TMI-l TS:
4-31, 4-32, and 4-33 C.
A new page 6-lle is to be added.
II. DESCRIPTION OF THE CHANGE A.
Revised Specification 3.6 and its Bases as necessary to reflect the changes in Section 4.4.1.
B.
Revised Technical Specification sections 4.4.1.1, 4.4.1.1.4, 4.4.1.2, and 4.4.1.2.5 to require leakage rate tests to be conducted in accordance with the Reactor j
Building Leakage Rate Testing Program.
C.
Relocated the applicable information from Technical Specification sections 4.4.1.1.1, 4.4.1.1.2, 4.4.1.1.3, 4.4.1.1.5, 4.4.1.1.6, 4.4.1.1.7, 4.4.1.2.1, 4.4.1.2.2, 4.4.1.2.3, 4.4.1.2.4, 4.4.1.3, 4.4.1.4, 4.4.1.5 and 4.4.1.7 to the Reactor Building Leakage Rate Testing Program.
D.
Revised bases information in TS 4.4.1 to be consistent with the Reactor Building Leakage Rate Testing Program.
E.
Deleted Specification 4.4.1.3 which is redundant to 10 CFR 50.55a(f) and Specification 4.2.2 F.
Reformatted Specification 4.4.1 and moved Specification 4.4.1 and its Bases to Pages 4-29 and 4-30 for human factors considerations.
G.
Added section 6.8.5 which requires the Reactor Building Inkage Rate Testing Program.
'.6710-96-2221 Page 2 of 5 III. SAFETY EVALUATION JUSTIFYING CHANGE A. BACKGROUND The Nuclear Regulatory Commission has amended its regulations to provide a
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performance based alternative for leakage rate testing of containments. The new testing alternative is Option B of 10 CFR 50, Appendix J, and is available in lieu of compliance with the present prescriptive requirements contained in Option A of Appendix J.Section V.B of Option B requires licensees who wish to voluntarily adopt Option B, or parts thereof, to submit to the NRC an implementation plan and a request for a revision to the Technical Specifications. Therefore, GPU Nuclear is proposing appropriate Technical Specification changes to adopt Option B of 10 CFR 50 Appendix J for Type A, B, and C testing, along with our Implementation Plan presented in Section V below.
B. DISCUSSION OF THE CHANGES The proposed changes involve relocating the prescriptive infonnation concerning leakage rate testing out of the Technical Specifications and establishing a leakage rate testing program referenced in the Administrative Controls Section, Chapter 6.
In accordance with the performance based program, test frequencies may be relaxed if test history shows good results; othenvise the program could require an increased test frequency.
NEI 94-01 also includes a minor change in scope in that Section 6.0 states that "an LLRT is not required for primary containment boundaries that do not constitute potential primary containment atmospheric pathways during and following a Design Basis Accident (DBA)." This change will permit the elimination of approximately six valves from LLRT requirements since these valves were included in the existing i
LLRT scope only because they receive automatic close signals for containment isolation events.
The reponing requirements of sections of 4.4.1.1.3.a and 4.4.1.1.7 are also being j
moved to the Reactor Building Leakage Rate Testing Program. Submittal of a report is no longer required by NRC regulations. The requirement for submittal of repons was revised in 10 CFR 50 Appendix J Section V.B, "Recordkeeping of Test Results," (60 FR 13615) to require that a summary repon be available for inspection.
Specifications 4.4.1.1,4.4.1.1.4,4.4.1.2, and 4.4.1.2.5 have been changed to require Irakage Rate Tests to be conducted in accordance with the Reactor Building Leakage Rate Testing Program consistent with the Improved Standard Technical Specifications (ISTS) and NRC's policy of not duplicating regulations in the Technical Specifications.
Sections 3.6.8.2 and 3.6.12 and the bases for Section 3.6, which had references to the sections affected by this TSCR, have been n: vised to refer to the Reactor Building leakage Rate Testing Program. Other statements in the bases for Section 3.6 are being deleted which referred to the prescriptive test requirements that are being moved to the Reactor Building leakage Rate Testing Program.
.'.6710-96-2221 Page 3 of 5 The applicable information from Technical Specification Sections 4.4.1.1.1, 4.4.1.1.2, 4.4.1.1.3, 4.4.1.1.5, 4.4.1.1.6, 4.4.1.1.7, 4.4.1.2.1, 4.4.1.2.2, 4.4.1.2.3, 4.4.1.2.4, 4.4.1.2.5, 4.4.1.4, 4.4.1.5, and 4.4.1.7 has been relocated to the Reactor Building leakage Rate Testing Program.
To achieve human factors benefits, the whole Specification 4.4.1 has been i
reformatted to eliminate the sections which were deleted or relocated and to I
combine or renumber the sections which remain. The applicable requirements from Sections 4.4.1.2.1 and 4.4.1.2.5 have been combined into the new Section 4.4.1.2.
The requirements of Section 4.4.1.6, " Operability of Personnel and Emergency Air Lock Door Interlocks," was renumbered as 4.4.1.3.
Purge valve test requirements will continue to satisfy Safety Issue B-24 because the Reactor Building Leak Rate Testing Program will not permit a degradation of purge valve operability. The prescriptive purge valve test requirements of Section 4.4.1.7 i
were implemented because of a poor test history up to the early 1980s. Following development of the improved purge valve maintenance and testing procedures, GPU I
Nuclear has had excellent test results. These procedures will be preserved as appropriate by the performance based Reactor Building Ixak Rate Testing Program.
The requirements of Specification 4.4.1.2.2, " Conduct of Tests," are preserved in the revised Specification 4.4.1.2 as allowed by NEI 94-01, Revision 0, Section 10.2.2.1 which states that " Door seals shall be tested at P, or at a pressure stated in the plant Technical Specifications."
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Section 4.4.1.3, " Isolation Valve Functional Tests," is being deleted because the tests required by this section are also required to be performed in accordance with
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10 CFR 50.55a(f) and Technical Specification 4.2.2. Any changes to these j.
requirements through changes to the ASME Code will need specific NRC approval.
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The bases information under Technical Specification 4.4.1 has been modified to be consistent with the Reactor Building Leakage Rate Testing Program which is l
defined to be contained in the surveillance procedures for Reactor Building i
inspection, Integrated Leak Rate Testing, and local I.eak Rate Testing. Also added to the bases for this specification is information that specifies the Reactor Building l
leakage rate acceptance criteria in accordance with the ISTS.
A new Section 6.8.5, " Reactor Building Leakage Rate Testing Program," is being i
added to require the Reactor Building Leakage Rate Testing Program. This section j
is in accordance with the latest draft of the ISTS criteria with the exception of the j
air lock acceptance criteria. The air locks are penetrations that require Type B j
tests. Section 6.8.5 of the proposed change maintains the requirement for the air locks to be Type B tested with the same acceptance criterion of s; 0.60 L, for the l
total leakage from all Type B and Type C tests. Testing experience with the air locks does not demonstrate a need for a specific criterion.
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Page 4 of 5 I
IV. NO SIGNIFICANT HAZARDS CONSIDERATION The proposed change has been evaluated against the standards in 10 CFR 50.92 and determined not to involve a significant hazards consideration, in that the editorial a
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changes do not change the meaning or intent of the technical specifications, and operation of the facility in accordance with the proposed amendment:
- 1. Would not involve a significant increase in the probability of occurrence or the i
consequences of an accident previously evaluated, because the proposed changes are j
either purely administrative changes (involving format, wording, or reporting i
requirements) or changes in containment leakage test requirements (minor scope changes or increased intervals between containment leakage tests). None of these 4
changes are related to conditions which cause accidents. The proposed changes do not involve a change to the plant design or operation.
e NUREG-1493, " Performance-Based Containment Leak-Test Program," contributed to the technical bases for Option B of 10 CFR 50 Appendix J. NUREG-1493 contains a detailed evaluation of the expected leakage from containment and the j
associated consequences. The increased risk due to lengthening of the intervals between leakage tests was also evaluated and found to be acceptable. Using a l
1 statistical approach, NUREG-1493 determined the increase in the expected dose to j
the public from extending the testing frequency to be extremely small.
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- 2. Would not create the possibility of a new or different kind of accident from any accident previously evaluated, because the testing or reporting requirements associated with this change do not involve a physical alteration of the plant design i
or changes in the methods governing normal plant operation. No safety related equipment or safety related functions are altered as a result of this change. As a result, the proposed change does not affect any of the parameters or conditions that could contribute to initiation of any accidents.
- 3. Would not involve a significant reduction in a margin of safety because the proposed changes are either purely administrative (involving format, wording, or l
reporting requirements) or changes in containment leakage test requirements (minor j
scope changes or increased intervals between containment leakage tests) such that i
the allowable containment leakage rates presently specified in the Technical Specifications remain unchanged. The Technical Specifications and the Reactor I
Building Leakage Rate Testing Program will ensure that containment system testing j
is performed in full compliance with 10 CFR 50 Appendix J.
V.
IMPLEMENTATION PLAN l
It is requested that an amendment authorizing this change be approved by February 1, j
1997 and effective ninety (90) days after issuance. The requested approval date is our scheduled date for completion of plans for the TMI-I Cycle 12 Refueling Outage which j
is scheduled to begin in early September 1997. The performance based Reactor Building Leakage Rate Testing Program, as required by Option B of 10 CFR 50 l
Appendix J, and as identified by a new Section 6.8.5 of the TMI-l TS, will be I
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.' 6710-96-2221 l
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contained in the surveillance procedures for Reactor Building inspection, Integrated l
1eak Rate Testing, and Local Leak Rate Testing. This program will be developed through revision of these procedures to contain all of the necessary requirements to ensure testing consistent with Regulatory Guide 1.163, " Performance-Based Containment Leak-Testing Program," dated September 1995.
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