ML20128M448

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Amend to 800211 Order,Modifying Proposed Tech Specs to Add Certain Exceptions to Two Valve Isolation Requirements. Certificate of Svc Encl
ML20128M448
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 07/08/1985
From: Eisenhut D
Office of Nuclear Reactor Regulation
To:
GENERAL PUBLIC UTILITIES CORP.
Shared Package
ML20128M435 List:
References
OLA, NUDOCS 8507250311
Download: ML20128M448 (18)


Text

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Enclosure 1 L'UITED STATES OF AMERICA NUCLEAR REGULATORY COM!ilSS10t!

In the l'atter of )

)

GENERAL FUBLIC UTILITIES NUCLEAR ) Docket No. 50-320 CORPORATION

)

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(Three Mile Island Nuclear Station, )

Unit 2) )

AMEND! TENT OF ORDER I.

GPU Nuclear Corporation, Metropolitan Edison Company, Jersey Central Power .

.end Light C.mpany and Pennsylvania Electric Company (collectively, the licensee) are the holders of Facility Operating License No. DPR-73, which had authorized operation of the Three Mile Island Nuclear Station, Unit 2 .

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(THI-2) at power levels up to 2772 megawatts themal. The facility, which is located in Londonderry Township, Dauphin County, Pennsylvania, is a pressurized water reactor previously used for the comercial generation of electricity.

II.

By Order for Modification of License, dated July 20, 1979, the licensee's aui.hority to operate the facility was suspended and the licensee's authority was limited to maintenance of the facility in the present shut-down cooling mode (44 Fed. Reg. 45271). By further Order of the Director, Office of Nuclear Reactor Regulation, dated February 11, 1980, a new set of formal license requirements was imposed to reflect the post-accident condition of the facility and to assure the continued maintenance of the current safe, stable, long-term cooling condition of the facility (45 Fed.

Reg. 11292).

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4 Although these requirements were imposed on the licensee by an Order of the Director of Nuclear Reactor Regulation, dated February 11, 1980, the TMI-2 license has not been formally amended. The requirements are reflected in the Recovery Mode Proposed Technical Specifications (PTS) presently pending before the Atomic Safety and Licensing Board. The revisions that are the subject of this order do not give the licensee authorizations that may be needed to undertake specific cleanup activities. Hereafter in this Amend-ment of Order, the requirements in question are identified by the applicable 1

Proposed Technical Specification.

III.

By letter dated October 31, 1984, GPU Nuclear Corporation (GPUNC) informed the NRC that certain containment penetration valve configurations presently in use at the Three Mile Island, Unit 2 (TMI-2) do not conform to the -

July' 17, 1984 Amendment of Order which modified the PTS definition of cor.-

tainment integrity. In addition, these configurations do not conform to the. staff's Approval of Alternate Design relative to 10 CFR 50. Appendix A, Criteria.55 and 56 also issued on July 17, 1984.

' After reviewing the licensee's discussion in the subject letter and performing a safety evaluation addressing the containment isolation configurations, the staff has modified Section 1.7 of the PTS and added Table 3.6-2 which lists exceptions to containment penetration valve configurations.

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  • The staff review concluded that; (1) The subject penetration valve configurations were previously concurred with by the liPC in liUREG-0107, (2) Many of the systems affected are not in use during the recovery period and are therefore depressurized, and (3) Those systems still in use are primarily used under emergency conditions and will not experience transients as extreme as those previously analyzed in NUREG-0107 for emergency or non-emergency use.

Based on the above, the addition of certain exceptions to the two valve j isolation requirements of the PTS are warranted and will not ihave an adverse impact on the health and safety of the public. The staff's safety assess-ment of this matter as discussed above is set forth in the concurrently issued Safety Evaluation.

Since, the February 11, 1980 Order imposing the Proposed Technical Specifications is currently pending before the Atomic Safety and Licensing Board, the staff will be advising the Licensing Board of this Amendment of Order through a Notice of Issuance of Amendment of Order and a Motion to Conform Proposed Technical Specifications in Accordance Herewith.

It is further determined that the modification does not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental impact. The staff has deter-mined that this action is insignificant from the stand;oint of environ-mental impact and neither an environmental impact statement nor an environmental assessment need be prepared.

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  • 4 IV.

Accordingly, pursuant to the Atomic Energy Act of 1954, as amended, the Director's Order of February 11, 1980, is hereby revised to incorporate the

. deletions, additions, and modifications set forth in Enclosure 3 hereto.

This Amendment of Order shall be effective on August 12, 1985.

For further details with respect to this action, see (1) Letter to B. J.

Snyder, USNRC, from F. R. Standerfer, GPUNC, Containment Isolation Valves, and (2) the Director's Order of February 11, 1980.

All the above documents are available for inspection at the Commission's Public Document Room,1717 H Street, N.W., Washington, DC 20555, and at the Commission's Local Public Document Room at the State Library of Pennsylvania, Government Publications Section, Education Building, Common-wealth and Walnut Streets, Harrisburg, Pennsylvania 17126.

FOR THE NUCLEAR RESULATORY COMMISSION s

arrell G. 1sen ut, eputy Director Office of Nuclear Reactor Regulation Effective Date: August 12, 1985

' Dated at Bethesda, Maryland Issuance Date: July B, 1985 i

O Enclosure 2 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION GPU NUCLEAR CORPORATION METROPOLITAN EDIS0N COMPANY PENNSYLVANIA ELECTRIC COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY DOCKET NO. 50-320 THREE MILE ISLASD NUCLEAR STATION UNIT NO. 2 INTRODUCTION By letter dated October 31, 1984, GPU Nuclear Corporation (GPUNC) informed the NRC that certain penetration valve configurations did not comply with the definition for containment integrity stated in a July 17, 1984 0-Amendment of Order issued by the Director, Nuclear Reactor Regulation. The staff also compared the referenced penetration configurations to a July 17,

, 1984 Approval of Alternate Design for 10 CFR 50, Appendix A, for Criteria 55 and 56 type penetrations and conclude ( that the subject configurations were also not in compliance with these requirements.

DISCUSSION On February 11, 1980, the Director of Nuclear Reactor Regulation issued an Order, modifying the pre-accident technical specifications to more appro-priately reflect what was required at that stage of the THI-2 recovery. As

' a part of that Order, the definition of containment integrity was made more restrictive by deleting the reference to any exceptions that could be taken by the licensee relative to isolation valve requirements.

As a result of the February 11, 1980 Order, the TMI-2 Proposed Technical Specifications (PTS), Section 1.7.a stated the following:

" CONTAINMENT INTEGRITY shall exist when:

a. All penetrations are closed by automatic valves, manual valves, blind flanges, or deactivated automatic valves secured in their closed positions, except those pene-

-_ . trations required open per approved procedures."

On July 17, 1984, an Amendment of .0rder modified the above wording to state as follows:

" CONTAINMENT INTEGRITY shall exist when:

a. All penetrations are maintained by two closed automatic or manual containment isolation valves or a double barrier in each penetration per procedures approved pursuant to

.- specification 6.8.2.

On December 19, 1984, this section was revised to be even more specific by a subsequent Amendment of Order to:

" CONTAINMENT INTEGRITY shall exist when:

a. All penetrations required to be closed during accider.t conditions are either:
1. Capable of being closed by valves on each side of

' the penetration or by double valve isolation outside of the reactor building per procedures approved pursuant to Specification 6.8.2. Isolation valves inside the reactor building shall be capable of remote operation from a control station outside of the reactor building, or;

2. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions to provide double isolation of each penetration."

'The July 17 and December 19, 1984 definitions clearly state that double isolation of containment penetrations is required. GPUNC informed the staff in their October 31, 1984 letter that two of the containment isolation valve configurations used at THI-2 do not satisfy the July 17, 1984 criteria. Also, they do not satisfy the December 19, 1984 modification of containment integrity criteria. Since guidelines for containment integrity had to be maintained in the PTS and the fact that the staff was still

considering what actions would be taken as a result of the October 31, 1984 submittal, the NRC chose not to delay the December 19, 1984 Junendment of Order and therefore did not address the subject penetrations in that issuance. Subsequently, it has been recognized by the staff that as the pre-accident technical specifications originally stated, a number of the containment penetrations do not need double valve isclation. Therefore, we are again indicating in the PTS that the valve configurations on these penetrations are acceptable. One configuration consists of a check valve located inside containment in combination with either one locked closed f isolation valve or one automatic isolation valve outside of containment.

The other configuration consists of a single valve outside of containment (see attached Tables 1 and 2). All of the affected systems and their con-figurations were in place prior to the March 28, 1979 accident. The staff has previously reviewed.these configurations and issued a September 1976

  • Safety Evaluation (NUREG-0107) which stated as follows:

"We have reviewed the containment isolation system and we conclude that it conforms with the requirements -

[ intent] of General Design Criteria 54, 55, 55 and 57 'd and Regulatory Guide 1.11, " Instrument Lines Penetratingf 3 Primary Reactor Containments," and therefore is accept-able."

l i The above conclusion was based on an operating reactor which has reactor coolant temperatures of approximately 600*F and an operating pressure of approximately 2150 psig. This temperature and pressure can provide a greater driving force for airborne and liquid radionuclides when com-pared to THI-2's current maximum indicated RCS temperature of 95'F -

and atmospheric pressure of 0 psig.

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s Therefore, since the staff has previously accepted these configurations for operating conditions more severe than those now existing, the same config-urations are acceptable for all plant conditions bounded by the staff's previous analysis.

q Accordingly, based on TMI's current and anticipated RCS condition, the staff has decided to add a table to the Proposed Technical Specifications, s, ' listing the subject penetrations as exceptions to the "two isolation valve" criteria. The presently existing Limiting Conditions for Operation and

Surveillance Requirements adequately address actions to be taken if the single isolation valve should fail. Similar wording was contained in the TMI-2 pre-accident technical specifications. This change will acknowledge the NRC's continued concurrence in these exceptions.

EN\'IRONMENTAL CONSIDERATI0MS This action involves changes in the installation or use of facility compo-nents located within the restricted area. The staff has deterndned that this action involves no significant increase in the amounts of any effluents that may be released offsite ar.d that there is no significant increase in individual or cumulative occupation radiation exposure.

Therefore, this action meets the eligibility criteria for categorical exclusion set forth in 10 CFR Sec. 51.21(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this action.

C0t:CLUS10N The staff therefore concludes that; (1) The subject penetration valve configurations were previously concurred with by the NRC in NUREG-0107,

' (2) tiany of the systems affected are not in use during the recovery period

-.. and are therefore depressurized, and (3) Those systems still in use are primarily used under emergency conditions and will not experience transients as extreme as those previously analyzed in NUREG-0107 for emergency or non-emergency use. Therefore, the addition of exceptions to the two valve isolation requirements of the PTS is warranted and will not adversely

... impact the health and safety of the public. '

We have also 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 implementation of this change will not be inimical to the connon defense and security or to the health and safety of the public.
  • TGLE 1 - PtWITRATIONS VHitH UTILIZE A CCCa: YAL YC INSICE COETA!wCET As A COETAlWCWT ISOL AT:04 VALVE Penetration Service Sy s ter. Description R-537 Witrogen and Fill to Core CT Flooding Tank Plant Design uses a check valve inside as a Contatn=ent Isolation Yalve. All manual isolation valves t re located outside the Eeactor Building.

R-539 Leakage Cooling DC Plant design uses a check valve inside as a Containment Isolation Yalve. An autos 4 tic isclation valve is located outside contairment.

R-542 Pressurizer Auxilf ary Spray DH Plant design uses a check valve inside

-- - as a Containment Isolation Yalve. A o manual Isolation Yalve is located outside contaf rnent.

R-54 4 Witrogen and Fill to Core Flooding CF Plant design uses a check valve inside Tank as a Contatrwrent Isolation Yalve.

There is also a check valve located outside containment; however, a manual f sclation valve outside the check

valve is bein; verified closed.

R-557 Nuclear services Closed Cooling NS Plant design uses a check valve inside WateF to Raactor Coolant Puc Df1 and Motor Coolers as a Contafteent Isolation Yalve. An automatic isclation valve is located, outside contairment.

R-559 In*armediate Closed Cooling Water IC Plant design uses a check valve inside to Roller Wut Drive Cooling Ccils

- containment as a Containment Isolation Yalve. An autosatic isolation valve is located outside containment.

R-563 Intermediate Closed Cooling systes IC Plant design uses a check valve inside contairment as a Contairment Isolation

- Yalve. An automatic isolation valve is located actside containment.

R-566 Service Air SA Plant design uses a check valve inside containment as a Contairment Isolation Yalve. An automatic isolation valve is located outside contairment.

! R-570/R-572 High Pressure Injection

! KJ Plant design uses a check valv. ir.:ide containment as a Containment Isolation valve. An automatic isolation valve is located outside containment.

a.573/R-574

  • Reactor Coolant Pump Seal Water KJ R-575/R-576 Supply Ecch of these prnetrations, by plant design, uttitzes a stop chte vain inside containment as a Contaiment Isolation Yalve. Each penetratter. has either an automatic or manual isolation valve located outside contairment.

R-57 7/R-579/R-584 Reactor Building Air Cooling RR R-587,R-583 Unit Cooling Vater Each of these penetrations, by plant 6esign, utilizes a check valve inside containeent as a Containment Isolation Yal ve. Penetrations R-577. R-579 R-584, and R-587 have a Contairment Isolation Check Yalve, by plant design, outside the penetration followed by an automatic isolation

"' valve. Penetration R-580 has two (2) check valves, in parallel, located octside contairment each of which is bcunded by an autosatic isolation valve.

R-SS3/R-586 Reactor Building Spray Inlet Line 85 Flant design uses a check valve inside co.tainment as a Contairment Isolation Yalve. Either an autosatic isolation valve or a manual isolation valve is-

.- located outside contairment.

R-589/R-590 Decay Heat Coolant Supply DH Flant design uses a check valve inside containment as a Containment Isolation Yalve. An automatic isolation valve is located cutside containment.

Additionally, a test connection valve located bet =een the check valve and the penetration is being verified.

  • R-591/R-592 High Prtssure IrJecticn MJ Plant design uses a che'ct valve inside contairment as s Contatnuent Isolation Ytive. An automatic isolation valve is 1ccated cutside contatraent.

Codes: Es-- Reactor Building Spray CF- Core Flooding D C-- Decay Heat Closed Cooling Water DH-- Decay Heat Removal EF-- Emergency Feedwater FW-- Feedwate r IC-- Intermediate Closed Coolin2 Water KJ-- Mateup and Purification RR-- Reactor Building Emergency Cooling - River Water SA-- Station service Air

  • Verification of valve position is performed on a routine' basis.

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TABLE 2 - PEWITRATIONS VHICH KHT 5!NI4.E VALVE ISoLATIDW Fenetration _ Service Systee Descriotton R-54 M/R-5540/ Building Pressure BS R-571C Plant design uses a single manual isolation valve outside containment.

R-SC2C Building spray System Pressure BS Sy stee Plant design uses a single manual isolation valve outside containment.

R-593/R-594 Suwp Penetra*on Sleeve and DH Drain Line By plant design, a Contaitseent Isolation Yalve is not located inside containment. A single automatic isolation valve is located outside

~. .. each penetration.

R-616/R-623/ Auxilia y Feedvater Lines EF By plant design, a contatrueent R-617/R-618 Feedwater Lines FW Isolation Yalve is not located inside containment. A check valve is located outside each penetration followed by an automatic isolation valve. Test connection isolation valves located inside coetafraeent are being verified.*

. R-619/R-620/ Steam Lines MS R-621/R-622 By plant design, a Containment 1 solation Yalve is not located inside containment for each of these penetrations. An automatic isolation valve is located outside containment.

Various test connection isolation valves, located on both sides of the penetratites are being verified.

  • Additionally, there are reitef valves located bet =eer. the perfetration and
  • the outboard Tsalation valve.

Codes: 85-- Reactor Building Spray

, CF-- Core Flooding DC-- Decay Heat Closed Cooling Water DH-- Decay Heat Removal LF-- Energency Feedvater FW-- Feedvater IC-- Intermediate Closed Cooling Water KJ-- Makeup and Purification RR-- Reactor Building Energency Cooling - River Water sA-- station service Air Verification of valve position is perforrned on a routine basis.

Enclosure 3

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FACILITY OPERATING LICENSE NO. DPR-73 DOCKET NO. 50-320

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i The following list of pages of the Appendix "A", Proposed Technical Specifications have been modified as a result of this Amendment of Order.

Therefore, you should replace your present pages with those enclosed.

1-2 3.6-4 2

3.6-5 4

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, 1. 0 DEFINITIONS CONTAINMENT INTEGRITY

.1.7 CONTAINMENT INTEGRITY shall exist when:

a.

_All penetrations required to be closed during accident conditions, except those listed in Table 3.6.2, are either: .

1. Capable of being closed by valves on each side of the penetration or by double valve isolation outside of the reactor building per proce-dures approved pursuant to Specification 6.8.2. Isolation valves inside the reactor building shall be capable of remote operation from

_,, ,, a control station outside of the reactor building, or; ,

2. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions to provide double isolation of each penetration.
b. The Equipment Hatch is closed and sealed.

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c. Each airlock is OPERABLE pursuant to Specification 3.6.1.3.

. d. The sealing mechanism associated with each penetration (e.g., welds, bellows or 0 rings) is OPERABLE.

CHANNEL CALIBRATION 1.8 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with necessary range and accuracy to

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known values of the parameter which the channel m'onitors. The CHANNEL CALIBRATION shall encompass the entire channel including the sensor and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST.

CHANNEL CALIBRATION may be performed by any series of sequential, overlapping or to'tal channel steps such that the entire channel is calibrated.

CHANNEL CHECK 1.9 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where possible, comparison of the channel indication and/or status with other indica-tions and/or status derived from independent instrument channels measuring the same parameter.

It THREE MILE ISLAND - UNIT 2 1-2 August 12, 1985  ;

e TABLE 3.6-2 PENETRATIONS WITHOUT DOUBLE ISOLATION Penetration Function System R-537* Reactor Coolant Pump MU R-574* Seal Water Supply R-575*

R-576*

--,. . R-577* Reactor Building Air RR -

R-579* Unit Cooling Water R-584*

R-587*

R-580*

R-583* Reactor Building Spray BS R-586* Inlet Line R-589* Decay Heat Coolant Supply -

DH

  1. R-590*

R-591* High Pressure Injection MU R-592*

R-537* Nitrogen and Fill to Core CF Flooding Tank R-539* Leakage Cooling DC R-542* Pressurizer Auxiliary Spray DH R-544* Nitrogen and Fill to Core CF Flooding Tank R-577* Nuclear Services Closed Cooling NS Water to Reactor Coolant Pump Oil and Motor Coolers R-559* Intermediate Closed Cooling IC Water to Roller Nut Drive Cooling Coils R-563* Intermediate Closed Cooling IC System R-566* Service Air SA R-570* High Pressure Injection MU

( R-572*

THREE MILE ISLAND - UNIT 2 3.6-4 August 12, 1985 m

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Penetration Function System R-545A# Building Pressure BS R-554C#

R-571C#

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R-562C# Building Spray System BS Pressure System

--- - R-593# Sump Penetration Sleeve DH .

R-594# and Drain Line a

R-616# Auxiliary Feedwater Lines EF R-623#

R-617# Feedwater Lines FW R-618#

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. R-619# Steam Lines MS

',- R-620#

R-621#

R-622#

Codes: BS-- Reactor Building Spray CF-- Core Flooding DC-- Decay Heat Closed Cooling Water DH-- Decay Heat Removal EF-- Emergency Feedwater FW-- Feedwater IC-- Intermediate Closed Cooling Water

. MU-- Makeup and Purification RR-- Reactor Building Emergency Cooling - River Water SA-- Station Service Air MS-- Main Steam NS-- Nuclear Services Closed Cooling Water

  • Penetrations which utilize a check valve inside containment as a containment isolation valve
  1. Penetrations which have single valve isolation THREE MILE ISLAND - UUTT 2 3.6-5 August 12, 1985

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(

0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BFFORE THE ATOMIC SAFETY AND LICENSING BOARD 80CdETED UShiiC In the Matter of )

METROPOLITAN EDIS0N COMPANY, ET AL. Docket No. 50-320 OLA E JUL 24 A10 32

)

(Three Mile Island Nuclear St'ation, ) CFFICE OF SECdt. LAD Unit 2) ) 00CHETING & SERVici

-. ., BRANCH CERTIFICATE OF SERVICE I hereby certify that copies of "NRC STAFF NOTICE OF ISSUANCE OF AMENDMENT OF CRDER AND MOTION TO CONFORM PROPOSED TECHNICAL SPECIFICATIONS IN ACCORDANCE THEREWITH" in the above-captioned proceeding have been served on the following by deposit in the United. States mail, first class, or as indicated by an .

asterisk through deposit in the Nuclear Regulatory Commission's internal mail system, this 23rd day of July, 1985:

Sheldon J. Wolfe, Chairnan George F. Trowbridge, Esq.

Administrative Judge Shaw, Pittman, Potts & Trowbridge Atomic Safety and Licensing Board 1800 M Street, N.W.

U.S. Nuclear Regulatory Commission Washington, D.C. 20036 Washington, D.C. 20555*

Dr. Oscar H. Paris Dr. Judith H. Johnsrud Administrative Judge Environmental Coalition on Atomic S=# 'v and Licensing Board Nuclear Power U.S. Nu:.iu r 'egulatory Commission 433 Orlando Avenue Washington, 0 '. 20555* State College, PA 16801 Mr. Frederf-F J. Shon Atomic Safety and Licensing -

Atomic Safety and Licensing Board Panel Board Panel U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555* Washington, D.C. 20555*

. Atomic Safety and Licensing Appeal Docketing and Service Section Board Panel (5) Office of the Secretary U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555* Washington, D.C. 20555*

Karin W. Carter Mr. William A. Lochstet Assistant Attorney. General 119 E. Aaron Drive 505 Executive House State College, PA 16801 P.O. Box 2357 Harrisburg, PA 17120

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' Jay Gutierrez Regional Counsel USNRC, Region I

~631 Park Avenue King of Prussia, PA- 19406*

8 William D. Paton Counsel for NRC Staff

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