ML20203L627
| ML20203L627 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/25/1986 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20203L619 | List: |
| References | |
| NUDOCS 8608290021 | |
| Download: ML20203L627 (5) | |
Text
e METROPOLITAN EDISON C(NPANY JERSEY CENTRAL POWER & LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION, UNIT 1 Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No.156 This Technical Specification Change Request is submitted in support of Licensee's l
request to change Appendix A to Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1.
As a part of this request, proposed replacement pages for Appendix A are also included.
GPU NUCLEAR CORPORATION BY:
Vic0 Presidbnt & Director, TMI-l Sworn and Subscribed l Jk to befor me thi day of 4/lo r, 1986.
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'llotary Pu ic
$r3K01 P. ERO N, NOTARY FUCllC MIDCLtIO AN BORD. DAUPHIM COUNTY M1 COMMIS$10N LIPIRis JUNE 12,1989 blember, Pennsylvants Association of Notaries 0600290021 860025 PDR ADOCK 05000209 P
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF
' DOCKET NO. 50-289 LICENSE NO. DPR-50 GPU NUCLEAR CORPORATION This is to certify that a copy of Technical Specification Change Request No.156 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. Frederick S. Rice, 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. Thomas Gerusky, Director PA. Dept. of Environmental Resources Bureau of Radiation Protection P.O. Box 2063 Harrisburg, PA 17120 j
GPU NUCLEAR CORPORAT N BY:
Vice Presicent & Director, TMI-l DATE: August 25, 1986
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I.
TECHNICAL SPECIFICATION CHANGE REQUEST (TSCR) No. 156 The Licensee requests that the following pages be inserted into the existing Technical Specifications:
3-62e, 3-62f, 4-55f, 4-55g and replace: 11, iv, 3-62c, 3-62d, Pages 3-104, 3-105, 3-105a, 4-55d, 4-55e, 4-94, 4-95, 4-106, 4-107, 4-109, 5-10, Fig. 5-3 II.
REASON FOR CHANGE This TSCR incorporates changes which are needed in order to comply with a condition of operation imposed by the Licensing Board as described in NRC's letter dated October 2,1985 (Item 1.C).
III. SAFETY EVALUATION JUSTIFYING CHANGE The Fuel Hanaling Duilding (FHB) ESF Air Treatment System contains, controls, mitigates, monitors and records radiation release resulting from a TMI-l postulated spent fuel accident in the FHB as described in FSAR, Section 14.2.2.1, Update 4, 7/85. The design of this system is describ,ed in GPUN's submittil to NRC dated March 27, 1986 (5211-86-2047).
This TSCR incorporates specifications for the new FHB ESF Air Treatment System, modifies the specifications for the Auxiliary and Fuel Handling Building Air Treatment System, includes editorial changes to improve clarity, and administrative changes in order to adopt the test requirements of later standards. These changes are justified as described in greater detail as follows:
- 1) Sections 3.15.4 and 4.12.4 have been added to provide additional technical specifications for the FHB ESF Air Treatment System. The existing Sections 3.15.3 and 4.12.3 for the Auxiliary and Fuel Handling Building Air Treatment System and the Bases have been modified to reflect the addition of the new system.
The FHB ESF Air Treatment System is required to be operable and operating whenever irradiated fuel is being moved within the FHB to protect against an accident involving the handling of irradiated fuel in the FHB. Design, construction, operation, and testing of the new system will be in accordance with Regulatory Guide 1.52, Revision 2,1978, as discussed in GPUN's submittal to the NRC dated March 27, 1986.
Revisions to commitments contained in that submittal are as follows:
a.
A requirement for performing surveillance tests at least once per 18 months is not included in this proposed specification.
This exception to Regulatory Guide 1.52, Revision 2,1978 is justified as discussed in ERDA 76-21, Section 3.4.2.
The FHB i
ESF Air Treatment System is not a continuously on-line system.
The expected service of this system approaches that of a stand by system.
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b.
Since Specification 4.12.4 includes requirements to operate each train for at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> each month, requirements to operate the FHB ESF Air Treatment System for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> prior to movement of irradiated fuel have not been included in this proposed specification as was discussed in the March 27, 1986 submittal to the NRC.
Regulatory Guide 1.52, Revision 2,1978 does not require the system to operate for two hours before declaring the 4
system operable. Therefore, this change in commitments does not represent an exception to Regulatory Guide 1.52.
The Auxiliary and FHB Air Treatment System is required to be operable at all times during power operation in order to ensure that doses to radiation workers and releases to offsite during power operation are filtered and maintained As Low As Reasonably Achievable (ALARA). With the addition of the new ESF System, the Auxiliary and FHB Air Treatment System will not be required to mitigate the off-site dose consequences of a fuel handling accident in the FHB. Therefore, the Auxiliary and FHB Air Treatment System will not be required to be operable in order to move irradiated TMI-l fuel in the FHB. Although not required by Technical Specifications, the Auxiliary and FHB Air Treatment System will be operated as necessary during movement of TMI-1 irradiated fuel in the FHB in order to minimize worker doses and ensure habitability of the Auxiliary Building and the Fuel Handling Buildirig.
Operation in accordance with this proposed amendmeric is adequate to ILeet the conditions assumed in the plant's safety analysis and comply with the condition of operation imposed by the Licensing Board as described in the NRC's letter dated October 2,1985 (Item 1.c).
- 2) Specification 3.15.3.2.b has been revised to specify a 30*C test temperature for laboratory carbon sample analysis radioactive methyl f odide decontamination efficiency tests of the Auxiliary and Fuel Handling Building Air Treatment System charcoal filters.
This is consistent with the more conservative test temperature for the same test specified in 3.15.4.2.b for the Fuel Handling Building ESF Air Treatment System.
- 3) Specification 4.12.3 has been revised to delete the 18 month maximum frequency for performing surveillance tests.
Under normal circumstances at present, this change would not result in less frequent testing. However, if this change were to result in testing less frequently, the justification to exceed 18 months is backed up by GPUN operational experience with this system.
Actual results has demonstrated that very little degradation of the system's methyl fodide removal efficiency has resulted even after approximately 5 years of continuous use.
Therefore, tests and analyses once per refueling interval are adequate to detect degradation of the filters...
- 4) Figure 5.3 has been revised to add the new release point associated with the FHB ESF Vent Stack. The FHB ESF Air Treatment System effluent will be released at a new location in close proximity to the main stack. The effluent will be released at an elevation of 348' which is adequate since no credit has been taken in the analysis for elevated releases. The use of a separate release point for the FHB ESF Air Treatment System, where effluent monitoring is optimized =for the flow conditions of the new system, enhances the ability to monitor effluents and assess dose rates.
The FHB ESF Air Treatment System with its separate release point will not degrade the capabilities of the Auxiliary and FHB Air Treatment System and the environmental effects will be less.
- 5) Tables 3.21-2, " Radioactive Gaseous Process and Effluent Monitoring Instrumentation" and 4.21-2, " Radioactive Gaseous Effluent Monitoring Instrumentation Surveillance Requirements" have been 4
revised to specify Operability and Surveillance Requirements for the FHB ESF Air Treatment System instrumentation provided.
Table 4.22-2, " Radioactive Gaseous Waste Sampling and Analysis Program" has been revised to specify sampling and analysis requirements for the new FHB ESF Air Treatment System. Since the FHB ESF Air Treatment System will only be operated during movement of irradiated TMI-1 fuel in the FHB, Quarterly Composite Particulate Sampling is not applicable.
- 6) Statements have been provided in the Bases for Sections 4.12.3 and 4.12.4 to reflect use of ANSI-N510-1980 guidelines for in-plant test criteria and laboratory test criteria of activated charcoal and ANSI-N509-1980 for qualification of replacement HEPA and charcoal filters. This is to allow use of the newer standards in lieu of the earlier 1975 and 1976 standards which are referenced in Regulatory Guide 1.52, Revision 2, March 1978.
- 7) Footnotes on page 3-62c and 4-55d were only applicable prior to Cycle 5 criticality and have been deleted.
The order of entries in Table 4.22-2 has been rearranged to improve clarity. Appropriate FSAR references have been added to the bases sections. And other editorial changes and corrections have been made to improve the clarity of the specifications affected by this proposed amendment.
IV.
NO SIGNIFICANT HAZARDS CONSIDERATIONS GPU Nuclear Corporation has determined that this TSCR poses no significant hazards as defined by NRC regulations in 10 CFR 50.92.
This ensures that operation of the facility in accordance with the proposed amendment would not:
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1) involve a significant increase in the probability or consequences of an accident previously evaluated (10 CFR 50.92(c)(1)). The design basis accident for the FHB ESF Air Treatment System is a fuel drop accident.
Operation of this system and that of the Auxiliary and Fuel Handling Building Air Treatment System in accordance with this proposed amendment does not interfere with the fuel handling operations and does not increase the probability of the acc.ident. The new system adds filtration redundancy, does not reduce filtration capacity, and therefore does not increase the consequences of an accident.
2) create the possibility of a new or different kind of accident from any accident previously evaluated (10 CFR 50.92(c)(2)). The FHB ESF Air Treatment System is similar in design features and l
configuration to other such systems. Therefore, operation in accordance with this proposed amendment does not create new or different risks from those evaluated.
l 3) involve a significant reduction in a margin of safety (10 CFR 50.92(c)(3)). To the contrary, the proposed changes provide an increased margin of safety by providing a separate ESF Air Treatment System.
The Commission has provided guidelines pertaining to the application of the Three Standards by listing specific examples in 48 FR 14870.
The proposed amendment is considered to be in the same category as the following examples of amendments that are considered not likely to involve significant hazards consideration:
(i)
A purely administrative change to achieve consistency, correction of an error, or a change in nomenclature.
(ii) A change that constitutes an additional limitation, restriction, or control not presently included in the technical specifications.
(v)
Upon satisfactory completion of construction in connection with an operating facility, a relief granted from an operating _ restriction that was imposed because the construction was not yet completed satisf actorily.
This proposed amendment: provides additional requirements for operation and test of the new FHB ESF Air Treatment System which is adequate to protact against accidents involving the handling of irradiated fuel in the FHB; reduces some of the requirements for the ' Auxiliary and FHB Air Treatment System which is no longer required to protect against this type of accident while retaining those requirements of the Auxiliary and FHB Air Treatment System necessary to ensure that doses to radiation workers on site and releases during normal power operation are maintained As Low As Reasonably Achievable (ALARA); and includes administrative or editorial changes for clarity. As described above, the Three Standards of 10 CFR 50.92(c) are satisfied.
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In summary, fiPU Nuclear Corporation has determined and submits that these proposed changes do not represent any significant hazards. _ _ - _ _
V.
IMPLEMENTATION It is requested that the amendment authorizing' this change become effective immediately with full implementation 90 days af ter receipt in order to allow for the necessary procedural revisions to be put in place. This system needs to be in operation to support the next refueling outage, scheduled for November,1986.
VI.
AMENDMENT FEE (10 CFR 170.21)
Pursuant to the provisions of 10 CFR 170.21, attached is a check for
$150.00.
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