ML20127D830
| ML20127D830 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 05/08/1985 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20127D814 | List: |
| References | |
| NUDOCS 8505170054 | |
| Download: ML20127D830 (8) | |
Text
-..
@ *toqk UNITED STATES '
. ~ j.-
p, NUCLEAR REGULATORY COMMISSION
-4
'j;
, WASHINGTON, D. C. 20555 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
-SUPPORTING AMENDMENT NO.108 TO FACILITY OPERATING LICENSE NO. DPR-50 METROPOLITAN EDIS0N COMPANY
. JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY j
GPU NUCLEAR CORPORATION THREE MILE-ISLAND NUCLEAR STATION, UNIT NO. 1 DOCKET NO. 50-289 Introduction / Evaluation C
-In order-to complete the resolution of mutliplant action (MPA) B-24 regarding purge and vent, the licenses was requested to provide certain Technical Specification-(TS) changes. Guidance was provided in Standard Technical Specifications (STSs) sent to the licensee in letters from J. Stolz (NRC) to
.H. Hukill (GPUN) dated April 30, 1982, and July 8, 1983. The licensee has responded with Technical Specification Change Request (TSCR) 116 dated August r,'
13, 1982, TSCR 116 Rev. 1,. dated November 24, 1983, and supplements to TSCR' 116, Rev. 1 dated June 5,.and December 3, 1984. We have reviewed the licensee's submittals 'for compatibility with the resolution of MPA B-24 items using the STSs as review guidance. The two subjects covered by the STSs are (1) primary coolant activity and (2) vent / purge valve operability and surveillance.
The licensee found that other changes were needed in the TMI-1 TSs for compatibility between the proposed TS requirements and operational needs.
These changes were not covered by STSs and therefore were reviewed on a plant-specific ' basis (Section 3, following).
1.
Primary coolant activity (proposed TS pages 3-8, 3-9, 3-9a, 3-9b, 4-9 and 6-17).
p
Background
[
The NRC staff's generic safety evaluation of the radiological consequences of purging and venting at power concluded that 10 CFR Part 100 dose guideUnes and the Standard Review Plan requirements would be -
n met if iodine equilibrium and spiking coolant activity levels are limited-to those of the STSs.
Evaluation
-The. licensee has proposed revisions to TS 3.1.4, Reactor Coolant Activity, and TS 4.1, Operational Safety Review (Table 4.1-3, Minimum Sampling Frequency for Reactor Coolant). The proposed TSs would limit the allowable specific activity of the primary coolant to not more than i
l 8505170054 850508 PDR ADDCM 05000289 P
100/E microcuries/gm-and generally to not more than 1.0 microcuries/gm DOSE ~ EQUIVALENT. _These proposed limits, and the proposed action to be followed if the limits are exceeded, including reporting requirements, are consistent with the STSs and therefore are acceptable. That is, the revisions _ proposed for TS pages 3-8, 3-9, 3-9a and 3-9b are acceptable.
The proposed sampling program for reactor coolant (TS Table 4.1-3) would require checking of specific activity for comparison with the 100/E microcurie /gm limit each 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (except during cold shutdown) and, in general, an isotopic' analysis for DOSE EQUIVALENT I-131 concentration
. every 14 days. These requirements along with the other limitations that
- would be imposed by the TSs are compatible with the STSs and therefore acceptable.. That is, proposed revisions to.TS page 4-9 are acceptable.
. In proposed TS 6.9.3, paragraph (6) has been added to require a special i
report to the NRC if the DOSE EQUIVALENT I-131 exceeds 1.0 microcuries/gm for more than 500 hours0.00579 days <br />0.139 hours <br />8.267196e-4 weeks <br />1.9025e-4 months <br /> in a 6-month period. This-requirement on TS page 6-17 is consistent with the STSs and therefore
-~
acceptable.
2.
Vent / purge valve operability and surveillance requirements (TS pages 3-41, 3-41a, 3-41b, 3-41c, 4-34, 4-34a and 4-34b).
Background
~
The satisfactory. resolution of MPA B-24 required operability and surveillance requirements for purge / vent valves that would assure reliability and the ability to close within the required time.
Evaluation Proposed TS 3.6.6 addresses reactor building isolation valves other than (large)purgevalvesandwouldrequireonevalvetobeclosedifthe companion valve in-line is inoperable, or proceed to cold shutdown.
Inoperability of the large purge valves because of resilient seal
. leakage is coveced by proposed TS 3.6.8.
The proposed actions would require the reactor to be shut down if excessive leakage cannot be corrected within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following quarterly testing. The proposed TS actions are consistent with the STSs and resolve the seal leakage concerns identified in MPA B-24.
The limits on purge valve opening that were found acceptable in the resolution of MPA B-24 have been included in proposed TS 3.6.9.
l Therefore this section is acceptable.
It is our' position that purging should be limited during reac' tor operation because a closed containment is inherently safer than an open containment during purging. Some licensees have a specific limit on purging but for TMI-1 a more flexible TS is proposed that identifies acceptable reasons for purging (proposed TS 3.6.10). We find that the c
listed reasons and the licensee's commitment to minimize entries (and thus purging) are acceptable. The licensee has estimated that about j
100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> of purging per month will be needed and has committed te z
+
n,
, - - -, + +
.n-.
,,.w.------..
--,.r--_
--n-
-,.,,--,n,-
-,.,v_--.,,..,. -,
,n-
-v,
--wc--
.. -n
i-provide a report after the next cycle of operation that discusses the actual amount of purging during operation. During cold shutdown, continuous purging is permitted and therefore proposed TS 3.6. 11 is
' acceptable and in accordance with the resolution of MPA B-24.
' The proposed TSs on purge valve testing frequency (TS 4.4.1.2.5) would require testing each 3 months, and the proposed TSs on operability criteria (TS 4.4.1.7) specify acceptance criteria and rubber seat e
(resilient seal) inspection requirements, as well as periodic seat replacement requirements. These requirements meet the guidelines of MPA B-24.
In particular, the acceptance criteria provide reasonable assurance that gross seal deterioration will be detected in a timely manner, and the seal replacement frequency (at least every 5 years) is in accordance with the menufacturer's recommendations. Accordingly, we j
find these proposed TSs acceptable.
The. licensee has not specified valve closure time as an operability requirement in the TSs because closure times are included in the
~
' inservice' testing program. We find this acceptable because the licensee has committed to include a discussion of purge valve closure time in the-Final Safety Analysis Report (FSAR) including the safety-related reasons for needing less than 3.5 sec. closure time, i.e., to mitigate damage to downstream structures / components following a Loss-of-Coolant Accident (LOCA).
3.
'Other Changes Initiated by Licensee 3.1 - Reactor building purge air treatment system (TS pages 3-62a, 3-62b, 4-55b and 4-55c)
Background
. The licensee has installed a hydrogen recombiner and has completed provisions for a second hydrogen recombiner. Therefore purging is no longer needed for hydrogen control and the reactor building purge air treatment system does not perform an' operating accident mitigation function; it is required only for purging associated with normal releases and for fuel handling accidents in containment. Therefore, the system fans are no longer required to be operable during normal plant operation but they must operate within design limits to properly test the' filters. The filters, however, are needed to mitigate accident releases whenever the purge valves are open during refueling operations.
Evaluation
-Proposed TSs 3.15.2.1 and 3.15.2.3 remove operability requirements for fans AH-E7A and B.
Additionally, surveillance requirements for fans (TS 3.14.2.2(e)) are moved to TS 4.12.2.2.e.
These changes are acceptable because the fans are no longer required during nomal operations since the hydrogen recombiner will be available as discussed under background, above. The proposed surveillance requirements for fans (TS 4.12.2.2.e) would require testing of fans each refueling (or 2 years) in lieu of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> of operations each month. This change is acceptable because the
_4 fans.will be required only.for filter testing specified in TS 4.12.2.2 which. is_ done primarily at refueling.
ProposedTS3.15.2.1alsoclarifiesthatfilteroperabilityfsnot required when.the purge valves are closed. This change is acceptable because when purge valves are closed, no filtering is needed.
In accordance with proposed TS 3.15.2.3, purging will not now be permitted with the filter inoperable and the purge valves open (previously permitted for 30 days). This change is acceptable because it' assures compliance with 10 CFR Part 100 release-guidelines during refueling operations.
The bases for proposed TS 3.15.2 would be revised to reflect the changed requirements for the reactor building purge air treatment system because of the availability of hydrogen recombiners. Also, the bases for filter testing would be_ revised to eliminate considerations of purge valve position because testing will-be done at cold shutdown when the purge
~ val d s ar'e fully open and the fans can operate at full flow.
In proposed TS 4.12.2 the surveillance interval for the reactor building purge air treatment system would be extended from a maximum of 18 months to a maximum of 2 years. This change would make the requirements for the reactor building compatible with those for auxiliary and fuel handling buildings whose air treatment systems serve no operating accident mitigation function. All these systems will-now serve similar functions because of the availability of the hydrogen recombiners for the reactor building ventilation system, and therefore the proposed change is acceptable.
In proposed TS 4.12.2.2.a the reactor building air treatment system surveillance _would be required within 30 days prior to movement of fuel in-lieu of surveillance each 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of operation. The 720-hour surveillance requirement is no longer needed for this air treatment system since hydrogen recombiners are available to control hydrogen in the containment.
The proposed TS 4.12.2.3 would require air distribution test.s on the HEPA filter bank to be perfomed at the full reactor building purge system flow rate of 50,000 cfm rather than 25,000 cfm as currently provided. This section also would clarify that testing would be performed with the purge valves fully open. The proposed change is appropriate and acceptable because the system should be tested at maximum air flow to assure operability under all anticipated conditions.
3.2 - Calibration of containment area monitors (TS page 4-Sa);
Background
An area radiation monitoring s,vstem is designed to (1) inform operations personnel of radiation levels in areas where these systems are located, (2) provide warning (by audible and visual alarms) both locally and in the control room, when abnomal levels occur, (3) warn of possible equipment malfunction, and (4) provide a continuous record of radiation
levels at key locations. The criteria for area monitor location are usually. based on occupancy factors and potential exposure to high radiation, among other factors. ANSI 6,8,1-1981 " Location and Design Criteria for Area Radiation Monitoring Systems for Light Water Nuclear.
Reactors specifies that area monitors should be used to assist in minimizing exposure to personnel and shall be located in areas most likely to be occupied.
Based on the criteria as stated above, containment area radiation monitors function essentially as event oriented monitors to provide functions (2), (3) and (4) rather than personnel monitors used to assist in minimizing exposure to personnel. This is because no personnel entry can be made into containment, as with all high radiation areas, without the administrative control TS requirement that specifies Radiation Work Permits (RWPs) for entry into a high radiation ~ area. Additionally, the TS requires that portable survey meters or other monitoring devices.
which continuously indicate or integrate the radiation dose rate in the area of concern, must be used. Thus, the area monitors, if they are in the appropriate location where work is to be performed, merely serve as
' general level indicators essentially as a secondary line of defense to the portable. survey meters.-
It should be noted that calibration of containment monitors, such as area gamma radiation monitor RM-GS..may be considered a special case when compared to the calibration needs of all other area monitors in the plant. Calibration of these monitors requires personnel entry to the containment. With the reactor at power, this person would be potentially exposed to high levels of neutron and gamma radiation, as well as airborne radioactivity levels.
In order to minimize radiation to personnel calibrating the containment area monitors, the licensee would have to shut down the reactor.and purge containment prior to personnel entry. However, shutting down the reactor every quarter to e
calibrate the containment area monitors is not cost effective with L
respect to the philosophy of ALARA, t
Some additional factors that would influence our evaluation are as follows: Area monitors in containment are not safety related and are l
not required to operate during accident or seismic events. Only those two high-range monitors installed in accordance with NUREG-0737 need be so qualified. Three Mile Island Unit 1 TSs require all area monitors to have a channel check and functional test at frequent intervals (i.e.,
weekly and monthly respectively) to verify operability of the channel, including alarm function.
Evaluation
[
From the above, we can draw the following conclusions concerning area l
monitor RM-G5, and area monitors in containment in general:
I i
i l
t (1) They 'are not used primarily for occupational exposure purposes.
(2) They are 1ccated in high radiation areas so that an RWP.and portable radiation survey equipment are required for entry into the area in accordance with TSs. Therefore, these area monitors are not needed for radiation protection when entry into containment is made.
(3) There is no need for calibrating them every quarter if this necessitates unnecessarily exposing personnel to high levels of radiation during each calibration. This is not consistent with-ALARA philosophy. Channel checks and functional tests are performed frequently to assure operability of the channel in accordance with TSs.
(4) They should, however, be calibrated quarterly whenever full containment purging is permitted and not less often than once every 18 months during refueling outages.
~ (5) Recalibration of these monitors should be performed after maintenance or replacement of any component that could affect calibration.
Based on the above criteria, we concur with the TS change that defers calibration frequency requirements for area monitor RM-G5' from quarterly to periods of shutdown when full purging is permitted.
3.3 - Removal of hydrogen purge system (TS pages (iii), 4-37 and 4-38)
Background
TS 4.4.3 describes the surveillance procedures and limiting conditions of operation that were associated with.the safety-related post-accident hydrogen purge system.
The licensee proposes to delete Section 4.4.3 from the TSs because the licensee has installed a hydrogen recombiner and has provisions for a second recombiner to remove the hydrogen that could be generated following a LOCA.
i Evaluation Because the licensee is replacing the hydrogen purge system with hydrogen recombiners, the hydrogen purge system is no longer needed to i
perform a safety-related function. Therefore, we agree that it is appropriate and acceptable to remove the testing and availability requirements of the hydrogen purge system from the TSs.
l l
3.4 - Surveillance of fire hose stations (TS page 4-76)
Background
The existing TSs require monthly visual inspections of fire hose stations and, each 18 months, removal and inspection of hoses and gaskets. The licensee proposes to permit exceptions to delay these surveillances if the reactor building is not purged and therefore the hose stations are not accessible.
Evaluation We. find the proposed exception acceptable because of the likelihood that the required surveillances would not be delayed and that any delay would be short, considering that the licensee anticipates about 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per month of purging. Therefore, the proposed changes to TS 4.18.6.1 are acceptable.
~
~ 3.6 - Adm'inistrative changes (TS page 4-55c)
An administrative change is proposed on TS page 4-55c where the title
" Unit Superintendent" is changed to reflect the revision of Amendment 77 to read " Operations and Maintenance Director - TMI-1." This change is acceptable because it merely updates the TSs.
Environmental Considerations This amendment involves changes in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20.and changes in surveillance requirements. The amendment also relates to a change in reporting requirements. We have detennined that the amendment involves no significant increase in the amounts, and no significant change 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 Comission has previously issued a proposed finding that this amendment involves no significant hazards consideration and there has been no public comment on such finding. Accordingly, this amendment meets the elig(ibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9) and 10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
Conclusion We have concluded, based on the considerations discussed above, that (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Dated: May 8,1985' Principal Contributor - 0. Thompson, M. Fields, F. Akstulewicz, C. Hinson, C. Nichols and D. Kubicki
-. -.