ML20206G276

Forwards Tech Specs Change Request 126 Rev 1 Deleting Section 4.5.E.5.a(1),re Reduced Pressure Test of Drywell Airlock,Per NRC 881107 Request

ML20206G276
Person / Time
Site:	Oyster Creek
Issue date:	11/16/1988
From:	Fitzpatrick E GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20206G279	List: ML20206G276 ML20206G280
References
NUDOCS 8811220201
Download: ML20206G276 (7)

Text

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MNuolear  ?:M:w~

Route 9 Soum Forked River, y Jersey 08731-o388 609 971-4000 Writer's Direct Dial Number:

November 16, 1988 Director of Nuclear Reactor Regulation U.S. Nuclear Regulatory Comission Mail Station PI-137 Washington, DC 20555 Dear Sir Subj ect. Oyster Creek Nuclear Generating Station Docket No. 50-219 Technical Specification Change Request (TSCR) No.126, Revision 1 General Public Utilities Nuclear Corporation (GPUN), by letter dated February 19, 1988, submitted TSCR No.126 Revision 1 which requested changes to Apper. dix A of Operating License No. DPR-16. The changes were requested in order to explictly include the requirements of 10CFR50, Appendix J. By letter dated October 13, 1988, GPUN, in response to NRC's concern, agreed to delete Section 4.5.C.2 and provided the revised request.

NRC Contacted GPUN on November 7, 1988 concerning Section 4.5.E.5.a.(1).

This section allows a reduced pressure test of the drywell airlock provided the airlock had not been opened within the preceding six months. The NRC safety evaluation eport dated March 4,1982 agrees that reduced pressure testing is acceptable during periods of frequent opening. However, the NRC does not agree that reduced pressure testing is allowable for the required six (6) month test. Therefore, GPUN agrees that Section 4.5.E.5.a.(1) will be deleted.

GPUN has reviewed the 10CFR50.91 determination of no significant hazards considert tions which was submitted with TSCR No.126, Revision 1. GPUN has determined the deletion of this section does not affect the determination as described in TSCR No.126 Rev.1, since deldton of this section is in accordance with the requirements of 10CFR50, Appendix J. For ease of administration, enclosed is a reprint of the TSCR reflecting the deletion of section 4.5.E.5.a.(1) and the incorporation of Technical Specification Amendment No.128 issued on October 12, 1988. No other changes have been made to the October 13, 1988 submi ttal .

As GPUN is currently shutdown for the sycle 12 refueling outage, the next PCILRT will be performed prior to startup. The PCILRT is scheduled to begiq on December 19, 1988. Therefore, GPUN requests that TSCR 126, Revision 1 be reviewed as expeditiously as possible so that the PCILRT may be accomplished in conformance with the requested changes.

• 8P2snN Mi!@ go/7 GPU Nuclear Corporation is a substd aty cf the GeneralPubhc Utmt.es CorporaSon l Il

If you should have any questions, please contact Mr. Geos ge W. Busch at (609) 971-4909.

Very truly yours,

(

E. E. Fitzp .:-ick L

Vice President and Director Oyster Creek EEF/GB/smz (0599A) -

Mr. William T. Russell, Administrator  !

Region I U.S. Nuclear Regulatory Comission 475 Allendale Road King of Prussia, PA 19406 Mr. Alexander W. Dromerick, Project Manager i 11.S. Nuclear Regulatory Commission Division of Reactor Projects I/II Washington, DC 20555 NRC Resident Inspector ,

Oyster Creek Nuclear Generating Station '

Forked River, NJ 08731 i

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0YSTER CREEK NUCLEAR GENERATING STATION PROVISIONAL OPERATING LICENSE NO. DPR-16 DOCKET NO. 50-219 TECHNICAL SPECIFICATION CHANGE REQUEST NO.126, Rev.1 Applicant hereby requests the Commission to change Aopendix A to the above-captioned license ar, below and, pursuant to 10CFR50.91, an analy;is concerning the determination of no significant hazards considerations is also presented:

1. Section to be changed:

Section 3.5.A.3 and Section 4.5 and the corresponding bases.

2. Extent of chinge:

The revision to section 3.5 A.3 is actually the addition of 3.5. A.3.b which is a Limiting Condition for Operation (LCO) concerning plant operations if the drywell airlock is not operable. The revisions made to Section 4.5 reflect the requirements of Appendix J of 10CFR50. This revision also incorporates a change to the paragraph numbers as necessary to correct inconsistencies caused by this and previous revisions. The specific changes requested are as follows:

(1) Specification 3.5.A.3 is modified as follows: Step 3.5.A.3.b is added to create an additional LCO concerning drywell airlock j operability.

(2) Specification 4.5, "Applicability", is modified as follows: This section now lists the major system surveillances and tests described in this section.

(3) Specification 4.5, "Objectives", is modified as follows: This section now refers to Appendix J of 10CFR50.

(4) Specification 4.5.A is modified as follows:

a) Step 1 concerning the pre.. operational testing is deleted. Step 1 is no longer relevant, as it applies only to initial (pre-startup) testing of the containment.

b) Steps 2 and 3 are modified to reflect 10CFR50 Appendix J requi rements. Part of step 2 has become the new step 1, and the rest of step 2 along with step 3 are moved to 4.5.C.

c) Step 4 has remained essentially intact and renumbered Step 2.

d) Steps 3 and 4 are added to reflect the requirements of Appendix J. Step 3 establishes a stabilization period prior to beginning the PCILRT and step 4 establishes a verification test to confirm calibration of instruments.

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. e) Step 5 retains the test deration reouirement.

f) Step 6 is added to reflect the requirements of 10CFR50, Appendix J Section V.A.

(5) Specification 4.5.B is modified as follows:

a) Step 1 remains essentially unchanged with minor subscript changes to parallel variables used in Appendix J.

b) Steps 2 and 3 are modified to reflect the applicable standards.

c) Step 4 is added to establish an acceptance criteria for the verification test in accordance with section !!!.A.3(b) of Appendix J.

(6) Specification 4.5.C is modified as follows:

a) This section is the largest change and adds more restrictions

, than previously existed. These additions reflect compliance i with Appendix J.

(7) Specification 4.5.0 is modified as follows

a) Thir, first section concerning the first refueling outage is deleted, b) The remainder of this section is modified to more alosely reflect the testing frequency limits as imposed by Appendix J.

(8) Specification 4.5.E is modified as follows:

a) Steps 1 through 4 are taken apart and rearranged, but technically are still steps 1 through 4 with the addition of a requirement to use normal valve closures.

b) Step 5 is added to define testing of the largest containment

penetration, the airlock.

(9) Specification 4.5.F is modified as follows:

l a) The heading is changed from "Corrective Action" to "Acceptance Criteria".

b) Step 4.5.F.1 establishes the acceptance limits as presented in l Appendix J.

c) Step 4.5.F.2 maintains the special case limits established for MSIVs at Oyster Creek.

, d) Specification 4.5.F.3 includes the approved method for reduced pressure testing of the drywell airlock (Letter dated March 4, 1982 Re: Safety Evaluation Report and Technical Evaluation Report by Franklin Research Center.)

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(10) Specification 4.5.G is modified as follocs: l a) The original specificatio. 4.5.G is moved to specification 4.5.H. This is the beginning of the paragraph numbering change. '

b) The new specification 4.5.G is added to establish a local leak rate testing interval limit in accordance with the referenced standards.

(11 ) Specifications 4.5.H. I, J K, and L in the proposed change correspond respectively to 4.5.G. H, I, J, and K in the present Technical Specifications. This change is merely a change to the caragraph numbering system.

(12) Specification L in the present technical specification is deleted.

The proposed change to the Technical Specifications will atilize paragraph '_. The rest of specification 4.5. is unchanged with the exception of the corresponding bases. l l t (13) Several typographical errors have been corrected as follows:

Section Correctioq 4.5.J.4.b 3.5.A.3.a changed to 3.5.A 4.a

4. 5.J . 5. b . (3 ) 3.5 A.4.a change 1 to 3.5.A.S.a 4.5.Q.1.a 124 months changed to 124 days  ;

(14) The section 4.5 basis has been revised to eliminate reference to the preoperational containment test pressures since this is no longer '

applicable.

3. Changes requested:

i Replace the old pages 3.5-3 with new pages 3.5-3 and 3.5-3a, and replace l the old section 4.5 with the new section 4.5 in its entirety.  :

i 4. Discussion:

Appendix J to 10 CFR Part 50 was published on February 14, 1913. On i August 7,1975, the NRC requested Jersey Central Power and Light (JCP&L)

Company *.o review its containment leakage testing program for Oyster Creek i and the associated technical specifications, for compliance with the

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i requirements of Appendix J.

JCP&L responded by letter dated December 24, 1975, which was supplemented by letters dated August 12, 1976, November 22, 1978 and June 27, 1980.

NRC letter dated March 4,1982 transmitted their Safety Evaluation of the Appendix J review for the Oyster Creek Nuclear Generating Station.

, Consistent with that safety evaluation, and by letter dated September 25, e 1984, General Public Utilities (GPU) Nuclear (now the licensee) submitted Technical Specification Change Request No.130 to change paragraph 4.5.F.1.b. After the NRC staff June / July Progress Review meeting with GPUN on July 31 and August 1,1985, the licensee agreed to withdraw >

l Technical Specification Change Request No.130. The withdrawal was  :

,' confirmed by NRC letter dated August 26, 1985.  ;

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! , GPUN is now submitting Technical Specifica% ion Change Request No.126.

, Change No.126 addresses the program which verifies that the leakage from the Primary Containment, both integrated and local, is maintained within t

specific values as outlined in Appendix J of 10CFR50. The major modifica+1ons incorporated in the Integrated Leak Rate Testo.g Program are the este alishment of a stabilization period for internr1 containment pressure and a verification test to check the n wocy rf leakage detectior, methods. The leakage limits are also more closely defined in this proposed revision. The new section on "Corrective Action" gives detailed options as to what may be done to limit leakage during the PCILRT. This specification allows for repairs and local testing of the i repairs. It also allcws for the re-comencement of the PCILRT without the required stabilizatioi period if containment was not depressurized. The testing frequency of three times in ten years, or approximately every 40 months is established and the reference to doing the pre-operatf oral test is eliminated.

The major modification to the LLRT program is the modification ',o the drywell airlock test. The 35 psig peak pressure airlock test required by Appendix J is established, but because of concerns described ii NUREG/CR-4398 the frequency of airlock tests at 35 psig will 'ee limited.

When permissible a 10 psig test will be utilized. The acceptance criteria for the LLRT program is established as well as a testing frequency. The change also adds an LCO in section 3.5. The LCO limits plant operation when the airlock is not operable.

There is no plant configuration change involved with this technical specification change request. The testing described here is merely a surveillance program designed to verify primary containment integrity.

The program outlined here is designed to bring the current program in line wi tt, the requirements of Appendix J to 10CFR50,

5. Determination The Comission has provided guidance concerning the application of the standards of 10CFR50.92 for determining whether a significant hazards consideration exists by providing certain examples as discussed in the Federal Register on Ap-il 6,1983 (48 FR 14870) under the heading 1 "Examples of Amendments That Are Considered Not Likely to Involve l Significant Hazards Considerations". Example (f) relates to a purely administrative change to Techr ical Specifications: 1.e., a change to

achieve consistency throughout the Technical Specifications, correction of

) an error, or a change in nomenclature. Example (11) relates to a change that constitutes an additional limitation, restriction, m control not presently included in the Technical Specifications; i.e., a more stringent surveillance requirement. Example (vii) relates to a change to make a Itcense conform to changes in the regulations, when the license change results in very minor changes to facility operations clearly in keeping with the regulacions.

! In this case, each component of the proposed change described above is

! similar to at least one of the three examples. The change in the numbering scheme is clearly an administrative change as described in i example (1). The addition of Specification 3.5. A.3.b is consistent with l both examples (ii) and (vii). The modifications and additions made to l Specifications 4.5.A through 4.5.G also relate easily to example (ii) in

, 290 a ore stringent and comprehentive surveillance requirement is estabisshed. Example (vii) also relab: in .that the surveillance program, in to.e form presented in this proposal, is o f ned by a regulation to whi,h the licensee is conforming.

Tt t proposed modification to the Technical Specifications will not involve a >tgnificant hazards consideration because operation of Oyster Creek Nuclear Generating Station in ace'.* dance with this change would not:

(1) involve a significant increase in the 7robsbility or consequences of an accident previously evaluated. This enange merely re-defines the leak rate testing program for Primary Containment. This program is designed to ensure that the Primary Containment is able to perform its design function. That function i3 to contain the energy and the radioactive release of the design basis 10ss of coolant accident.

Therefore, this change cannot increase the nrobability or consequences of an Mcident previously evaluated.

(2) create the possibility of a new or different kind of accident from any previously analyzed. It has been determined that, because this revision more clearly establishes the requirements and methods of testing the Primary Containment Integrity and does not involve a change to the containment configuration, this change will not create the possibility of a new or different kind of accident from any previously evaluated.

(3) involve a significant reduction in a margin of safety. This change has increased the requirements as established in Appendix J that the primary containment must meet to be considered operable. There fore, this change will not reduce the margin of safety.

This change reflects the requirements of Appendix J to 10CFR50.