ML20128H405

Forwards Errata to TS Change Request 257 to Add Revised Table of Contents & to Make Minor Editorial Corrections

ML20128H405
Person / Time
Site:	Three Mile Island
Issue date:	10/03/1996
From:	James Knubel GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20128H409	List: ML20128H405 ML20128H412
References
6710-96-2317, NUDOCS 9610090332
Download: ML20128H405 (9)

Text

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l GPU Nuclear, Inc.

A Route 441 South NUCLEAR Post Office Box 480 Middletown, PA 17057-0480 Tel 717 944-7621 i

October 03, 1996 l 6710-96-2317 ,

i U.S. Nuclear Regulatory Commission  ;

Attn: Document Control Desk Washington, DC 20555 l

Dear Sir:

l 1

Subject:

Three Mile Island Nuclear Station, Unit 1 (TMI-1) j Operating License No. DPR 50 Docket No. 50-289 Errata to Technical Specification Change Request No. 257 in accordance with 10 CFR 50.4(b)(1), enclosed are errata to TMI-l Technical Specification Change Request (TSCR) No. 257. The purpose of these errata are to add a revised table of contents and to make minor editorial corrections. The addition of a revised table of contents and

errata are solely editorial in nature. They do not change or impact upon the original"No Significant Hazards Considerations" evaluation. Therefore, only the added and corrected pages i of the revised TSCR 257 are being submitted.

1 Also e iclosed is a Certificate 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  ;

i the CMamor. wealth of Pennsylvania, Bureau of Radiation Protection. '

i I

Sincerely, fe J. Knubel

! Vice President and Director, TMI i

JSS

Enclosures:

1) Revised TMI-1 Technical Specifications Change Request 257, revised pages for Enclosure 1

2) Revised TMI-l Technical Specifications Change Request 257, revised pages for Enclosure 2, Technical Specifications Revised Pages

! 3) Certificate of Service for Revised TMI-l TSCR 257 cc: Region 1 Administrator TMI l Senior Project Manager f I i TMI Senior Resident Inspector 9610090332 961003 PDR ADOCK 05000289 p PDR

. . c.

METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY GPU NUCLEAR, Inc.

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Three Mile Island Nuclear Station, Unit 1 Operating License No. DPR-50

)

Docket No. 50-289 Technical Specification Change Request No. 257 - Errata i

i COMMONWEALTH OF PENNSYLVANIA )

) SS:

COUNTY OF DAUPHIN )

Errata to Technical Specification Change Request 257 are 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. All statements contained in this submittal have been reviewed, and all such statements made and matters set forth therein are true and correct to the best of my knowledge.

B- /

Vice President and Director, TMI Swom and subscribed before me this ay o h/m .1996.

['Notly Public Notarial Seal Suzanne C. Miklosik, Netary Pub!!c Londonderry Twp., Dauphin County My Corntn ssion Enpires Nov. 22,19'39 Member, Pennsylvania Associa'ivn of Nounes

6710-9ft-2317*

Page 3 of 3 INSTRUCTIONS FOR INCORPOR ATING CII ANGES INTO TSCR 257 fagg Directions Channe Description Enclosure 1, page 1 of 14 Remove old page 1 of 14, Pt gs ii, iii, iv, v, vii,5-9 replace with new page 1 of 14 :Med to list of revised pages; page 5-10 added to list of deleted pages; Figure 5-3 identified as to be deleted.

Enclosure 1, page 3 of 14 Remove old page 3 of 14; added description of deletion replace with new page 3 of 14 of term " restricted area."

Enclosure 1, page 7 of 14 Remove old page 7 of 14; typographical error in 1st replace with new page 7 of 14 sentence of last paragraph corrected (3.11.1 changed to 3.1.13)

Enclosure 1, page 12 of 14 Remove old page 12 of 14; Added justification for replace with new page 12 of deletion of term" restricted  !

14 area."

Enclosure 1, page 13 of 14 Remove old page 13 of 14; Pagination change replace with new page 13 of '

14 Enclosure 2 Insert revised table of Incorporates revised table of contents, pages ii, iii, iv, v, vii contents ahead of page 3-10 Enclosure 2, page 3-45 Remove old page 3-45; Change bar added to identify replace with new page 3-45 changes Enclosure 2, page 5-1 Remove old page 5-1; replace Reference to Figure 5-3 with new page 5-1 deleted (Figure 5-3 is proposed to be deleted by TSCR 257). Description of

" restricted area" deleted.

Enclosure 2, page 5-9 Insert tevised page 5-9 after Page revised to refle.ct page 5-4 deletion of page 5-10 which described contents of Figure 5-3

O e O 6710-96-2317 '

ENCLOSURE 1 1

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1 l

l C311-95-2479 i

Enclosure 1 l

Page 1 (corrected) of 14 .

l TECHNICAL SPECIFICATION CH ANGE REOUEST (TSCR) NO. 257 GPU Nuclear requests that the following change be made to the existing TMI-l Technical Specifications (TS):

A. Replacement pages:

ii, iii, iv, v, vii, 3- 10, 3- 18c, 3- 18g, 3-44, 3-45, 3-46, 3-63, 4-5a, 4-9, 4-54, 4-56, 4-59, 5-1,5-2,5-4,5-9 B. Deleted pages:

3- 1 1, 3- 18h, 4-57, 4-60, 4-61, 4-62, 4-63, 4-64, 4-65, 4-66, 4-67, 5-3, 5- 10 C. Deleted Figure 5-3 II. REASON FOR CHANGE The purpose of this TSCR is to incorporate certain improvements from the Revised Standard Technical Specifications (RSTS) for B&W Plants (NUREG-1430) that would allow deletion or i relaxation of selected limiting conditions for operation (LCOs) that do not meet the criteria for technical specifications as set forth in 10 CFR 50.36(c)(2)(ii) and are not reflected in the Revised Standard Technical Specifications (RSTS) for B&W plants delineated in NUREG 1430. The requirements of the deleted LCOs are contained in licensee controlled documents.

This TSCR also proposes to delete the Surveillance Requirements that are related to the LCOs proposed for removal from Technical Specifications. As with the LCOs, the activities required by the Surveillance Requirements are contained in licensee controlled documents in addition, this TSCR proposes to delete from the TMl-1 Technical Specifications design features specifications that are contained in other licensing-basis documents, such as the FS AR and the ODCM, and are not contained in the RSTS for B&W plants delineated in NUREG 1430.

l C311-95-2470-Enclosure 1 Page 3'(corrected) of 14 E. Limiting condition for operation 3.8.5.

Communication during Changes in Core Geometry Deletion in its entirety requirements for direct communication between the control room and the refueling personnel in the Reactor Building whenever changes in core geometry are taking place.

F. Limiting condition for operation 3.10 and Surveillance Requirement 4.13 Sealed Source Leak Testing and Inventory of Miscellaneous Radioactive Sources I

Deletion of limiting condition for operation 3.10 and smveillance requirement 4.13 in i their entirety. Limiting condition for operation and surveillance requirement 4.13 require periodic leak testing and the maintenance of an inventory of miscellanecus radioactive materials sources.

G. Limiting condition for operation 3.16 and Surveillance Requirement 4.17: 1 Shock Suppressors (Snubbers)

Deletion oflimiting condition for operation 3.16 and the related surveillance requirement 4.17 in their entirety. Limiting condition for operation 3.16 specifies l operability requirements for snubbers. i i

H. Design Feature 5.1:

Effluent Release Locations Deletion of the a portion of Section 5.1.1 that describes the locations of gaseous effluent release points and liquid effluent outfalls (as tabularized on page 5-10), and the meteorological tower location (designated as " weather tower" on the figure).

Deletion of reference to figure 5-3 and the description of the "TMI restricted area".

I. Design Feature 5.2 Containment Deletion of Section 5.2 in its entirety. Section 5.2 describes the design features of the containment system relating to operational and public safety.

J. Design Features 5.3.1.2 through 5.3.2.3 Reactor Core and Reactor Coolant System Deletion of subsections 5.3.1.2 through 5.3.2.3 which describe the reactor core and the reactor coolant system.

C311-95-2479' Enclosure 1

' Page 7' (corrected) of 14 The deletion of Surveillance Requirement 4.16 is justified because its related LCO, LCO 3.1.11 is notjustified to be a Technical Specification and is to be deleted.

I.imitine Condition for Operation 3.1.13 and Surveillance Heauirement 4.11 The current TMI-l Technical Specifications limiting condition for operation 3.1.13 requires that sufficient reactor coolar. system (RCS) vent flow paths are operable to vent non-condensable gases to mitigate accidents beyond the design basis for the plant.

The RCS vents are not instrumentation and therefore do not meet Criterion 1 of 10 CFR 50.36(c)(2)(ii). The RCS vents are not a design feature that is an initial condition of a design basis accident and therefore do not meet Criterion 2 of 10 CFR 50.36(c)(2)(ii). The RCS vents can be used to help restore natural circulation conditions following an event in which natural circulation was lost due to non-condensable gas collection. However, design basis events do not generate sufficient non-condensable gasses to block natural circulation. RCS vents are, therefore, not a system or comnonent that is part of the primary success path and do not function to mitigate a design basis accident. Thus, the RCS vents do not meet Criterion 3 of 10 CFR 50.36(c)(2)(ii). The RCS vents have not been shown in operating experience or the TMI-l PRA to be significant to the public health and safety and therefore LCO 3.1.13 does not meet criterion 4 of 10 CFR 50.16(c)(2)(ii)

There is no technical specification that addresses the RCS vent valves in the RSTS contained in NUREG 1430. o The surveillance and opeiation of RCS vent valves do not meet the criteria for a Technical Specification limiting condinon for operation. They are addressed in coritrolled plant procedures. The positioning of the RCS Vent Valves is addressed in TMI-l Operations Prccedure 1103-2, Fill and Vent of the RCS. The in-service testing of the valves that comprise the RCS vent system is addressed in TMI-l Surveillance Procedure 1300-3R, IST of Valves During Shutdown and Remote Indication Check.

The deletion of limiting condition for operation 3.1.13 from the TMI-l Technical Specifications is justified because the LCO does not meet criteria 1 through 4 of 10 CFR 50.36(c)(2)(ii), is not contained in the RSTS of NUREG 1430 and is addressed in controlled plant procedures. The deletion of Sun eillance Requirement 4.11 is justified because its related LCO,3.1.13 is not justified to be a Technical Specification and is to be deleted.

C311-95-2479 Enclosure 1

' Page 12 (corrected) of 14 Desien Feature 5.1.1 The current TMI-l Tecnnical Specifications contain a description of the TMI-1 Site in Specification 5.1.1. The proposed amendment deletes a portion of Specification 5.1.1 that describes the gaseous and liquid effluent release points and the location of the meteorological tower. In addition, the proposed amendment deletes the associated Figure 5-3 and the tables on page 5-10.

There is no design feature regarding the gaseous and liquid effluent release points or the location of the meteorological tower in the RSTS contained in NUREG 1430 The location of the gaseous and liquid effluent release points and the location of the meteorological tower are addressed in the Off-Site Dose Calculation Manual (ODCM) for Three Mile Island Units I and 2, a licensing basis document.

The deletion of the description of the locations of the gaseous and liquid effluent release points and the location of the meteorological tower from Specification 5.1 is justified because there is no corresponding design feature in the RSTS of NUREG 1430 and they are described in another licensing basis document, the ODCM.

The current TMI-l Technical Specifications describe the " restricted area" at TMI in Specification 5.1.1. This description is deleted in its entirety because the fence depicted on Figure 5-3 is now known as the owner-controlled area fence. Also, the i l

term " restricted area"is not used elsewhere in the TMI-l Technical Specifications or in the UFSAR for the purposes of describing a general site area.. There is no term

" restricted area"in the RSTS contained in NUREG 1430.

Desien Feature 5.2 The current TMI-l Technical Specifications contain Specification 5.2, Containment, that describes on a summary level the TMI-l Containment Building. Specification 5.2 mentians the structural properties, systems and components that comprise the Containment Building and how they function together to provide a barrier between the Reactor Building atmosphere and the environment. However, the Specification does not address the performance standards or surveillance tests for the structure, system or co.nponents.

The design features addressed in Technical Specification 5.2 are discussed in equal and greater detail in other licensing basis documents. Technical Specifications 3.6, 3.19,4.4.1,4.4.2, and 4.4.4 specifically discuss the performance standards and surveillance tests for those structures, systems and components that function together to provide a barrier between the Reactor Building atmosphere and the environment .

Specification 5.2 is also redundant to the description of the Containment in Chapter 5 of the TMI-l UFSAR.

There is no design feature in the RSTS of NUREG 1430 that address the Containment Building.

C311-95-2479' Enclosure 1 l

' Page 13 (corrected) of 14 The deletion of Specifier. tion 5.2 is justified because it is redundant to other licensing basis documents and there is no corresponding design feature in the RSTS of NUREG 1430.

Desien Feature 5.3.1.2 throuch 5.3.1.6 The current TMI-l Technical Specifications Design Features 5.3.1.2 through 5.3.1.6 describe the TMI-l reactor core, fuel and control rod assemblies. The proposed amendment deletes all of the information except one sentence in Specification 5.3.1.6 which limits the maximum enrichment to a nominal 5.0 weight percent of U*.

The deletion of Specifications 5.3.1.2 through 5.3.1.5 and the revision of Specification 5.3.1.6 is justified because the sections proposed for deletion are repetitive of information presented in the TMI-l UFSAR and the Specifications 5.3.1.2 through 5.3.1.6 reference Chapter 3 of the UFSAR for detailed information. The Specifications to be deleted do not impose requirements or restrictions on TMI-l that are not contained in other licensing basis documents such as the COLR and the UFSAR.

The Specifications to be deleted are not contained in the RSTS of NUREG 1430. l The deletion of Technical Specifications Design Features 5.3.1.2 through 5.3.1.5 and the modification of Design Feature 5.3.1.6 is justified because they are redundant to information and requirements contained in other licensing basis documents and they are not contained in the RSTS of NUREG 1430.