ML20118A301

TS Change Request 216 to License DPR-50,changing TS to Eliminate Requirement to Test for Operability,Each Component in ECCS Sys,Immediately Prior to Removing Redundant Component from Svc for Maint

ML20118A301
Person / Time
Site:	Three Mile Island
Issue date:	08/24/1992
From:	Broughton T GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20118A299	List: ML20118A298 ML20118A301 ML20118A302
References
NUDOCS 9208280225
Download: ML20118A301 (4)

Text

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NETROF0LITAN EDIS0N COMPANY JERSEY CENTRAL POWER & LIGHT COMPANY AND-PENNSYLVANIA ELECTRIC COMPANY i

THREE MILE ISLAND NUCLEAR STATION, UNIT 1 i

4 Operating License No. b.

-50 Docket No. 50-289 j

Technical Specification Change Request No. 216 4

This Technical Specification Change Request is submitted in support of Licensee's request to change Appendix A to Operrting License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1.

As a part of this request, proposed replacemeat pages for Appendix A are also included.

GPU NUCLEAR CORPORATION t

bt6^Y b' A BY:

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_Vice President athd Director, TMI-l Signed and sworn before me this 24th day of August

, 1992.

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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF DOCKET N0. 50-289 GPU NUCLEAR CORPORATION LICENSE NO DPR-50 CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Chang.. Request No. 216 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 Department of Environmental Resources, Bureau of Radiation Protection, by deposit in the United States mail, addressed as follows:

Mr. Jay H. Kopp, Chairman Mr. Russell 1., 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 Mr. William P. Dornsife, Acting Director PA. Dept. of Environmental Resources Bureau of Radiation Protection P,0. Box 2063 Harrisburg, PA 17120 GPU NUCLEAR CORPORATION BY:

b A dW b^

Vice Presidenti and Director, TMI-l DATE:

August-24, 1992

m I

I.

TECHNICAL _ SPECIFICATION CHANGE RE0 VEST (TSCR) N0. 216 GPUN requests that the attached revised pages replace 3-23 and 3-24 of the THI-l Technical Specifications.

II. Egason for the Chanae This request involves a change to the Technical Specifications, which will eliminate the requirement to test for operability, each component in Emergency Core Cooling (ECC) systems, immediately prior to removing the redundant component from service for maintenance. Operability will now be based upon the satisfactory completion of surveillance and inservice testing and inspection required by Technical Specification Section 4.2 and 4.5.

TMI-l Technical Specification 3.3.4 presently requires that prior to initiating maintenance on any of the components addressed in Technical Specification 3.3.1, the redundant component shall be tested to assure operability.

This is an unnecessary requirement, in that all ECC systems

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and components are tested periodically to assure their operability.

In order to assure that redundant components are operable, without testing, the completion of normally scheduled surveillance testing and inservice inspection and testing activities shall be verified prior to removing an Emergency Core Cooling System component from service for maintenance. The testing requirements to be accomplished for ECC Systems are as specified in Technical Specifications 4.2 and 4.5.

III. Safety Evaluation Justifyina the Chanae in order te verify that Emergency Core Cooling System components are operable prior to removing one of two redundant components from service for maintenance, TMI-l Technical Specifications require that the redua, dant component be tested to verify its operability. This requirement is unnecessary in that all ECC systems and components are tested periodically to assure their operability in accordance with Section 4 of the Technical Specifications.

In addition, in some instant es, testing of these components could be considered to render the redundant component inoperable. The operability of ECC Systems, particularly the injection systems, core flood systems, reactor building spray, reactor building emergency cooling and cooling watcr systems which are cescribed in Section 3.3.1 are ';erified by thc associated surveillance testing requirements specified in Technical Specification Secticas 4.2 and 4.5. _ The periodic satisfactory completion of these surveillance tests assures tlat the associated systems and components are operable.

Further additional testing does not add increased assurance that the redundant component will operate satisfactorily when a component is temporarily removed from service for maintenance * " vities.

The change to Technical Specification Section 3.3.4 to verify operability of redundant components based on satisfactory completion of surveillance test activities specified in Sections 4.2 and 4.5 will not result in a reduction in the level of assurance that redundant components are operable when like systems and components are undergoing maintenance activities.

Deletion of the " test for operability" requirement will also assure that unnecessary test %g which causes additional cycling of mechanical and electrical equipment is not accomplished. Additionally, the current Standard Technical Specifications for B&W raactor plants (NUREG-0103, l

1

Revision 4) and the Revised Standard Technical Specifications (Draft NUREG-1430), which are in final review, de not contain a requirement to

" test for operability" immediately prior to removing ECC System components from service for maintenance activities.

IV. No Sionificant Hazards Consideration Operation of the facility in accordance with the proposed amendment will I

have no adverse effect on nuclear safety or safe plant operations The e' tmination of the requirement to test components for operability-innediately prior to remo,g the redundant component from service for maintenance will be replace by the requirement to verify that the appropriate surveillance has been completed in accordance with Technical Specification 4.2 and 4.5.

This requirement is consistent with Standard Technical Specifications.

GPUN has determined that this Technical Specification Change Request poses no significant hazards as defined by 10 CFR 50.92. Operation of the facility in accordance with the proposed amendment will have no adverse effect on nuclear safety or safe plant operations as evaluated below:

1.

Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated. ECC Systems and equipment will be verified to be operable prior to removing redundant equipment from service for maintenance. A review and verification of completed surveillance and inservice test and inspection activities shall be accomplished which will ensure the same or greater level of verification of operability as previous testing.

2.

Operation of the facility in accordance with the proposed amendment I

would not create the possibility of a new or different kind of accident from any previously evaluated. The propcsed amendment does not modify plant operation or methods of conducting maintenance activities.

ECC systems and equipment will continue to be required to be operable when redundant equipment is removed from service for maintenance activities.

The facility will continue to be operated within the limits of the existing accident analysis and margins of safety.

3.

Operation of the facility in accordance with the proposed amendment would not involve a sigr.ificant reduction _ in the margin of safety since the change contained in the proposed amendment-does not change and existing safety margins.

V.

Imolemantation It is requested that the amendment authorizing this change become effective on issuance..

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