ML20151B145

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Application for Amend to License DPR-73,consisting of Tech Spec Change Request 59,revising Tech Specs Re Surveillance Terms & Definitions
ML20151B145
Person / Time
Site: Crane Constellation icon.png
Issue date: 04/04/1988
From: Standerfer F
GENERAL PUBLIC UTILITIES CORP.
To:
Shared Package
ML20151B133 List:
References
NUDOCS 8804080077
Download: ML20151B145 (6)


Text

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.ETROPOLITAN EDISON COWANY JERSEY CENTRAL POWER AFO LIGHT COWANY PENNSYLVANIA ELECTRIC COWANY GPU NUCLEAR THREE MILE ISLAND NUCLEAR STATION UNIT II Operating License No. DPR-73 Docket No. 50-320 Technical Specification Change Request No. 59 This Technical Specification Change Request is submitted in support of Licensee's request to change Operating License No. DPR-73 for Three Mile Island Nuclear Station Unit 2.

As a pr et of this request, proposed replacement pages for Appendix B are also included.

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UNITED STATES OF AERICA NUCLEAR REGtLATORY COMMISSION IN THE MATTER OF DOCKET NO. 50-320 LICENSE NO. OPR-73 GPU NUCLEAR This is t.o certify th3i; a copy of Technical Specification Change Request No. 59 to Operating License DPR-73 for Three Mile Island Nuclear Station Unit 2 has been filed with the U.S. Nuclear Regulatory Commission and served to the chief executives of 1) Londonderry Townchip, Dauphin County, Pemsylvania; 2) Dauphin County, Pemsylvanie, and 3) the designated official of the Commonwealth of Pennsylvania by deposit in the United States mail, addressed as follows:

Mr. Jay H. Kopp, Chairman Ms. Sally Klein, Chairperson Board of Supervisors of Board of County Commissioners Londonderry Township of Dauphin County R. D. #1, Geyers Church Road Dauphin County Court House Middletown, Pemsylvania 17057 Harrisburg, Pemsylvania 17120 1r. Thomas M. Gerusky, Director Sureau of Radiation Protection PA Dept. of Environmental Resources P.O. Box 2063 Harrisburg, PA 17120 GPU NUCLEAR D

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Three Mile Island Nuclear Station, Unit 2 (TMI-2)

Operating License No. DPR-73 Docket No. 50-320 Technical Specification Change Request (TSCR) No. 59 The Licensee requests that the attached changed pages of the Appendix B Technical Specifications (Tech. Specs.) (i.e., pages 1-1,1-2, 2-3, 2-10, 2-15a, and 2-15c) replace the corresponding pages in the Appendix B Tech.

Specs.

Reason for Change The proposed modifications revise certain surveillance tems and definitions in the Appendix B Tech. Specs, in order to ensure consistent terminology throughout the Tech. Specs.

The purpose of the prcposed change is to correct a discrepancy concerning the surveillance tems and definitions in the Appendix B Tech. Specs. and curmnt plant practice for implementing these surveillances. A review of the surveillances currently required by the Appendix B Tech. Specs, has been completed. This review determined that the current procedural methodology for performing the affected Appendix B Tech. Spec. surveillances meets the intent of the current Tech. Specs, and adequately demonstrates the operability of Tech. Specs, required equipment. However, this review determined that the current Appendix B Tech. Specs, surveillance terms and definitions are ambiguous and have resulted in some confusion as to their application in the implementation of surveillance requirements. Based on this review, it was determined that revising the surveillance terms and definitions in the Appendix B Tech. Specs. to be consistent with those in the Appendix A Tech.

Specs. will correct this discrepancy. Additionally, in the specific case of Appendix B Tech. Spec. Table 2.1-3b, the proposed change deletes a surveillance no longer needed based on the current design features of the affected monitor.

Description of Change l

Section 1.0, "Definitions" The current Appendix B Tech. Spec. definitions for "Functional Check" and Functional Test" have been deleted and replaced with the following definitions, respectively, which are consistent with the Appendix A Tech.

Specs.:

o "CHANNEL FUNCTIONAL TEST a.

Analog enannels - the injection of a simulated signal into the channel as close to the primary sensor as practicable to wrify OPERABILITY includity alarm and/or trip functions.

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Bistable channels - the in,)ection of a simulated signal into the channel sensor to verify OPERABILIT( including alarm and/or trip functions."

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o "CHANNEL CHECKa A~ qualitative assessment of channel behavior during operation by observation. This deteImination shall include, where possible, comparison of the channel indication and/or status with other indication ard/or status derived from independent instrument channels measuring the same parameter."

In the Appendix B Tech. Spec. definition for "Calibration," the term "functional test" has been changed to "channel functional test."

Section 2.1.1, "Liquid Effluents," Monitoring Requhement F The terms "instrument channel test" and "source check" have been changed to "channel functional test" and "channel check," respectively.

Section 2.1.2, "Gaseous Effluents," Monitoring Requirement I The terms "instrument functional test" and "sensor check" have been changed to "channel functional test" and "channel check," respectively.

Section 2.1.3, "Radioactive Gaseous Effluent Monitoring Instrumentation" and Table 2.1-3b, "Radioactive Gaseous Monitoring Instrumentation Surveillance Requirements" The source check surveillance for the Noble Gas Activity channel of the EPICOR II Ventilation System Monitor has been deleted.

Safety Evaluation Justifyir.g Change Section 1.0 The proposed change i.s administrative in nature and is intended to ensure consistent usage of terms throLghout the Tech. Specs. The current l

Appendix B Tech. Spec. definiticns for "Functional Check" and "Functional Test" are somewhat ambiguous and have resulted in some confusion as to their application in the implementation of tne surveillance requirements. For example, the term "functional check" is not specifically referenced in any of tne Appendix B Tech Spec.

l surveillances though its definition is synonymous with the definition of l

"channel functional test" in the Appendix A Tech. Specs. A review h;.s been performed of the surveillances currently required by the Apperdix B i

Tech Specs. This review has determined that the current procedural methodology for performing the affected Appendix B Tech Spec.

surveillances meets the intent of their current Tech. Specs. definitions and adequately demonstrates the operability of the Tech. Specs. required equipment.

The proposed definitions for "channel functional test" and "channel check," which are ideni,1 cal to the definition in the Appendix A Tech.

Specs., reflect actual plant practices in conducting the affected Appendix B Tech. Spec. surveillances. Thus, the proposed change involves only the nomenclature used and does not entail any change in the methodology of the testing.

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Sections 2.1.1 and 2.1.2 The proposed changes are administrative in nature to comply with the proposed change to Section 1.0..It is noteworthy that monitoring requirement 2.1.1.F refers to "instrument channel test" and "source check" and that monitoring requirement 2.1.2.I refers to "sensor check;"

however, these tems are not specifically defined in the Appendix B Tech.

Specs. A review of plant procedures indicates that the proposed "channel furctional test" and "channel check" definitions are consistent with the.

actual surveillance performed on these monitors.

Sections 2.1.3 and Table 2.1-3b Table 2.1-3b of Section 2.1.3 requires a monthly source check of the Noble Gas Activity Channel of the EPICOR II Ventilation System Monitor.

As previously noted, "source check" is not defined in the Appendix B Tech. Specs. The EPICOR II Ventilation System Honitor has been modified from a Nuclear Measurement Corporation (NMC) type monitor to an Eberline PING 2A type monitor. The monthly source check had been performed in accordance with Surveillance Procedure 4221-SUR-3661.10, "NMC Atmospheric Radiation Monitors Source Check." This procedure was cancelled on July 17, 1987, due to the installation of the Eberline PING 2A monitor. The monthly source check is currently performed via Surveillance Procedure 4221-SUR-3661.17, "Eberline Radiation Monitoring Operational Check."

However, due to the design features of the Eberline PING 2A monitor, the methodology for performing the daily channel check verifies the same degree of operability as the monthly source check. The proposed revised surveillances for this monitor (i.e., channel check, channel functional test, and channel calibration) are consistent with the surveillances of other Tech. Spec, required Eberline PING 2A monitors (e.g., HP-R-219, HP-R-219A, HP-R-225, HP-R-226). Thus, there is no longer a basis for performing a monthly source check for this type monitor. The proposed change is conservative in nature since the operability of this monitor will continue to be verified on a daily basis.

Significant Hazards Consideration 10 CFR Paragraph 50.92 provides the criteria which the Commission uses to evaluate a No Significant Hazards Consideration.

10 CFR 50.92 states that an amendment to a f acility license involves No Significant Hazards if operation of the facility, in accordance with the proposed amendment, would not:

1.

Involve a significant increase in the probability or consequences of an accident previously evaluated; or 2.

Create the possibility of a new or different kind of accident from any accident previously evaluated; or 3.

Involve a significant reduction in a margin of safety.

The proposed change is solely administrative in nature and ensures consistent usage of terms throughout the Tech. Specs. The proposed changes eliminate potential confusion regarding intent. The prnposed changes neither revise the

current methodology for performing the surveillances in the Appendix B Tech.

Specs., which adequately verifies the operability of the Tech. Spec. required equipment, nor relax the surveillances. The proposed change to Table 2.1-3b -

deletes a surveillance requirement (i.e., the source check requirement) which is.no longer necessary based on the design features of the EPICOR II Ventilation System Monitor.

Therefore, the proposed changes do not:

1.

Involve a significant increase in the probability or consequences of an accident previously evaluated; or 2.

Create the possibility of a new or dif ferent kind of accident from any accident previously evaluated; or 3.

Involve a significant reduction in a margin of safety.

Based on the above analysis, it is concluded that the proposed changes involve no significant hazards considerations as defined by 10 CFR 50.92.

Amendment Class Per the requirements of 10 CFR 170, "Licensing Fees," an application fee of

$150.00 is enclosed.

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