ML20209G461
| ML20209G461 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/27/1987 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20209G389 | List: |
| References | |
| NUDOCS 8702050371 | |
| Download: ML20209G461 (8) | |
Text
.........
METROPOLITAN EDISON COMPANY
~
JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY GPU NUCLEAR THREE MILE ISLAND NUCLEAR STATION UNIT II Operating License No. DPR-73 Docket No. 50-320 Technical Specification Change Request No. 55 and Recovery Operations Plan Change Request No. 40 This Technical Specification Change Request and Recovery Operations Plan Change Request is submitted in support of Licensee's request to change Operating License No. DPR-73 for Three Mlle Island Nuclear Station Unit 2.
As a part of this request, proposed replacement pages for Appendix A are also included.
GPU NUCLEAR By VVice President /Di/ector SwornandsubscribedtomethisI day of d/Ju/#4'
, 19 Ah>
f$)
Notary Public 6f COR$fANct M. BERGEL NOTARY PtfBUC WOOLETOWE BORC, DAUPHIN 000NTT W CW518tl8N EIPlRES NAACM N,199 FMwr,hemghesis Aseeciabeief Reemhe
\\
8702050371 870127 PDR ADOCK 05000320 P
PDR l
v
-Three Mile Island Nuclear Station Unit 2 (TMI-2) o Operating License No. DPR-73 Docket No. 50-320 Technical Specifications Change Request (TSCR) No 55 and Recovery Operations Plan Chance Reauest No. (ROPCR) 40 The Licensee requests that the attached changed pages, i.e., pages 3.1-2, 3.4-1, 3.8-4, 3.9-1, 3.9-2, 3/4.4-1, 6-2, 6-11, 4.3-12, 4.4-1, and 4.9-1, replace the corresponding pages in the TMI-2 Technical Specifications and Recovery Operations Plan.
I Description of Change This attached change request proposes a revision to the criteria of Specification 6.8.2.2 which requires NRC approval of certain procedures prior to implementation. Additionally, revisions to various specifications which i
reference Specification 6.8.2.2 are proposed. GPU Nuclear believes that, based on the current nature and scope of Recovery Mode activities, the criteria of Specification 6.8.2.2, which were implemented shortly after the TMI-2 accident, should be revised. The proposed change to Specification 6.8.2.2 is intended to provide criteria for determining which Recovery Mode procedures should require NRC approval prior to implementation based on current TMI-2 conditions. The specific proposed changes are listed below, o
Technical Specification 6.8.2.2 has been modified as follows:
" Procedures of 6.8.1.a and changes thereto which alter the distribution or processing of a quantity of radioactive material the release of which could cause the magnitude of radiological release to exceed 10 CFR 50 Appendix I limits shall be subject to approval by the NRC prior to I
implementation.
I The action statement of Technical Statement 3.1.1.2, " Boron o
Concentration" which states:
...take action in accordance with procedures approved pursuant to Specification 6.8.2..." has been changed to, "...take action in t
accordance with Specification 3.0.3."
o Specification 3.4.1, 3/4.4.1 and 4.4.1, " Reactor Coolant System - Reactor Coolant Loops," have been deleted.
j Specification 3.4.9.2, " Pressure / Temperature Limits - Reactor Coolant o
System" which states "The Reactor Coolant System shall remain open to the reactor building atmosphere unless repressurization is approved in a safety evaluation submitted to the NRC.
This safety evaluation and associated procedures approved pursuant to Specification 6.8.2 shall specify the maximum pressure limits and over-pressure protection that is required." has been revised to delete "...and associated procedures approved pursuant to Specification 6.8.2...".
Specification 3.8.2.1, " Reactor Power Distribution Systems - A. C.
o Distribution," which states:
l 1 of 7 i
-__ - - _. _. _ _ _ _... _ _ _. _ _ _ _ _ _ _ _. -. -. _ _ _ _ _. - - ~ _ _ _ _ _ _ _ _,. _ _. _ _ -
...(unless cicsed in accordance uith procedures approved pursuant to Specification 6.8.2)..." has been changed to, "...(unless closed in accordance with site-approved procedures)..."
o Specification 3.9.2, " Spent Fuel Storage Pool 'A' Hater Level," which states:
"The water level in Spent Fuel Storage Pool 'A' shall be maintained as specified per NRC-approved procedures." has been changed to, "The water level in Spent Fuel Storage Pool 'A' shall be monitored as specified in Section 4.9.2 of the Recovery Operations Plan."
o Specification 3.9.4, " Fuel Transfer Canal (Deep End) Water Level," which states:
"The water level in the Fuel Transfer Canal (deep end) shall be maintained at the level specified per NRC approved procedures.", has been changed to, "The water level in the Fuel Transfer Canal (deep end) shall be maintained as specified in Section 4.9.4 of the Recovery Operations Plan."
o Specification 4.3.3.8.4, " Fire Detection - Southeast Storage Facility,"
which states:
...shall have circuitry per procedures approved pursuant to Specification 6.8.2," has been changed to "...shall have circuitry per site-approved procedures."
o Table 6.2-1, " Minimum Shift Crew Composition," which states "During Core Alterations an additional SOL or an SOL limited to fuel handling will be stationed on the operating floor, in the command center or in the control room, as specified in procedures approved pursuant to Specification 6.8.2..." has been changed to delete "...as specified in procedures approved pursuant to Specification 6.8.2...".
o That portion of Specification 4.9.2, " Spent Fuel Storage Pool 'A' Hater Level Monitoring," and 4.9.4, " Fuel Transfer Canal Water Level Monitoring," which states:
" Verify that surveillance of...is being performed in accordance with NRC approved procedures," has been changed to " Verify by surveillance that the water level of...is between elevations 326'10" and 328'01"."
Reason for Change The purpose of this proposed change is to reduce the scope of activities which require NRC approval based on the present and foreseen THI-2 Recovery Program activities. This proposal would also significantly reduce the quantity of procedures requiring NRC approval pursuant to Specification 6.8.2.2.
GPU Nuclear reviewed 47 procedural documents that were submitted for NRC review and approval, pursuant to Specification 6.8.2.2, during December 1986. This review has determined that less than half of the 47 documents submitted would most likely have required NRC-approval pursuant to the proposed revision of Specification 6.8.2.2.
2 of 7
r Additionally, GPU Nuclear believes that the proposed change will not noticeably affect the quality of procedures based on the following statistical information:
o Between August - December 1986, 280 procedural documents were submitted for NRC review and approval pursuant to Specification 6.8.2.2.
Of these 280 documents, only 24 (or 9%) were returned with comments.
o Of the 24 documents returned with comments, only seven (7),
i.e., 3% of the 280 documents, addressed technical inadequacies.
Further, even with approval of this change request any procedure that could have the potential to exceed 10 CFR 50 Appendix I guidelines would still require prior NRC approval.
Justification for Change Specification 6.8.2.2 The criteria of 6.8.2.2 was added to the Technical Specifications via the NRC Amendment of Order dated February 13, 1980. The present criteria of 6.8.2.2 was originally incorporated into Technical Specification 6.8.1 as follows:
"g.
RECOVERY MODE implementation.
(Specifically RECOVERY MODE procedures wh!ch involve a reduction in the margin of safety, including those which:)
1.
Directly relate to core cooling.
2.
Could cause the magnitude of radiological releases to exceed limits established by the NRC.
3.
Could increase the likelihood of failures in systems important to nuclear safety and radiation waste processing or storage.
4.
Alter the distribution or processing of significant quantitles of stored radioactivity or radioactivity being released through known flow paths."
Subsequently, NRC Amendment of Order dated September 19, 1983, relocated the above criteria to Technical Specification 6.8.2.2.
The safety evaluation attached to this Amendment of Order states, "Section 6.8.2 has been revised to eliminate the requirement for prior NRC approval of Recovery Operations Plan implementing procedures but preserves NRC prior approval for specific Recovery Mode implementing procedures."
Thus, GPU Nuclear believes that the intent of Technical Specification 6.8.2.2 was to define specific criteria related to Recovery Mode activities that, due to their significance, required hRC approval prior to implementation in order to ensure that public health and safety was not jeopardized.
Based on present plant conditions, GPU Nuclear believes that a modification of the specific criteria of Technical Specification 6.8.2.2 is warranted.
GPU Nuclear believes that, consistent with the original rationaie for NRC approval of GPU Nuclear procedures, only those procedures which control activities that have the potential to exceed 10 CFR 50 Appendix I guidelines 3 of 7
should warrant NRC approval prior to implementation. Additionally, this is consistent with the objectives of the THI-2 Appendix B Environmental Technical Specifications (reference: Section 2.1.2), i.e., to control effluents from TMI-2.
Consistent with this proposed criteria, GPU Nuclear has reviewed various NRC approved Safety Evaluation Reports, Technical Evaluation Reports, and System Descriptions. As a result of this review, listed below are examples of activities whose procedures potentially would or would not require NRC approval, prior to implementation, based on the proposed revision to Specification 6.8.2.2:
Activ'itles Which Hould Activities Which Would Not Potentially Reautre NRC Approval Potentially Reautre NRC Approval o Reactor Building Decontamination o Pressurizer Spray Line Defueling o Defueling o Submerged Demineralizer System o Canister Handling in Preparation o Waste Handling and Packaging for Shipment Facility o Defueling Water Cleanup System Thus, GPU Nuclear believes that the proposed revision to Specification 6.8.2.2 provides consistent criteria for determining which Recovery Mode procedures should require NRC approval prior to implementation, while still ensuring public health and safety is not jeopardized.
Specification 3.1.1.2 The statement "and take action in accordance with procedures approved pursuant to Specification 6.8.2..." was added to the THI-2 Technical Specifications via NRC Amendment of Order dated July 17, 1984.
However, the attached NRC safety evaluation does not provide any specific justification for the addition of this statement. GPU Nuclear has proposed, based on the proposed revision to 6.8.2.2, that the above referenced statement be replaced with "take action in accordance with Specification 3.0.3."
Specification 3.0.3 requires licensees to "... initiate appropriate actions to rectify the problem to the extent possible under the circumstances, and take all other actions necessary to maintain the unit in a stable condition; and submit a report to the Commission pursuant to the requirements of Section 50.73 of 10 CFR Part 50."
Thus, the proposed change is more conservative by requiring formal NRC notification whenever the requirements specified in the Limiting Condition for Operation of Specification 3.1.1.2 cannot be satisfied, whereas formal NRC notification, presently, is only required whenever the actions stated in the i
i
" procedures approved pursuant to Specification 6.8.2" cannot be satisfied.
i Specifications 3.4.1. 3/4.4.1 and 4.4.1 Technical Specification 3.4.1 states "The Reactor Coolant System shall be l
operated in accordance with procedures approved pursuant to Specification 6.8.2.'
The associated Recovery Operations Plan Surveillance, i.e., Section 4.4.1, states " Verify that surveillance of the Reactor Coolant System is being performed in accordance with procedures approved pursuant to Technical Specification 6.8.2."
4 of 7
7 The above requirements originated from the NRC Amendment of Order dated February 11, 1980. The basis of this section is to ensure appropriate core cooling; therefore, any activity that could affect the operations of the Reactor Coolant System (RCS) would require NRC approval.
Presently, with the very low decay heat generation from the THI-2 core, no active cooling systems are employed. Therefore, the original basis for this specification is no longer present at THI-2.
Additionally, it is noteworthy that those procedures which involve operation of the RCS and which meet the proposed revised criteria of Specification 6.8.2.2 will still require NRC approval prior to implementation.
Specification 3.4.9.2 This specification requires the Reactor Coolant System (RCS) to remain open to the Reactor Building atmosphere unless repressurization is approved in safety evaluation submitted to the NRC and " associated procedures approved pursuant to Specification 6.8.2."
This section was added to the Technical Specifications by NRC Amendment of Order dated December 19, 1984, in order to acknowledge that the RCS was open to the atmosphere following Reactor Vessel head removal. The basis for this requirement was to allow the NRC to approve reclosure of the Reactor Vessel, following head removal, without requiring a change to the Technical Specifications.
With the Reactor Vessel presently being defueled, repressurization of the Reactor Vessel is highly unlikely. The proposed change to Specification 3.4.9.2 solely deletes the requirement for NRC approval of procedures pursuant to Specification 6.8.2.
It still retains, however, the requirement to submit a safety evaluation to the NRC should repressurization of the Reactor Vessel be required. Additionally, any procedures involving repressurization of the Reactor Coolant System which could potentially generate an off-site release in excess of 10 CFR 50 Appendix I guidelines would still require approval in accordance with Specification 6.8.2.2.
Specification 3.8.2.1 The requirement for NRC approval of procedures to close the tie breakers was Instituted by February 11, 1980, NRC Amendment of Order.
The basis of this specification is to ensure "...that sufficient power will be available to supply the safety related equipment required to maintain the unit in stable conditions during recovery from the March 28, 1979, accident." The safety evaluation enclosed with THI-2 Technical Specification Change Request No. 51 (reference GPU Nuclear letter 4410-85-L-0135 dated July 31, 1985) demonstrates that the equipment serviced by the busses listed in 4.8.2.2.a are not required to maintain the unit in a safe shutdown condition and do not require back-up power. Thus, the criteria of 6.8.2.2 is no longer applicable to this specification. Additionally, closure of the bus-tie breakers is required only for preventive maintenance or in the event that one of the two independent A.C. power supplies is inoperable.
In this event, closure of the bus-tie breakers would be performed in accordance with site approved procedures.
Specifications 3.9.2, 3.9.4, 4.9.2, and 4.9.4 These sections require that the water level in Spent Fuel Pool 'A' and the deep end of the Fuel Transfer Canal be maintained and surveilled in accordance 5 of 7
with NRC approved procedures.
This requirement applies when canisters containing fuel or the plenum, in the case of the deep end of Fuel Transfer Canal, are stored therein. This requirement was incorporated into the Technical Specifications by NRC Amendment of Order dated April 23, 1985, which approved Technical Specification Change Request (TSCR) No. 47.
Normal Plant Technical Specifications specify a specific water level to be maintained in these pools.
In the case of TMI-2, the required amount of water shielding needed in these areas was not precisely known at the time TSCR 47 was submitted.
GPU Nuclear proposes to replace the requirement to maintain and survell the water levels in Spent Fuel Pool
'A' and the Fuel Transfer Canal (deep end) in accordance with procedures approved to Specification 6.8.2.2, with their current allowable levels, i.e., 326'10" to 328'01".
These levels are presently established in NRC-approved procedures; therefore, this change is administrative in nature and no further technical justification is necessary.
Specification 4.3.3.8d This section states that fire detection instruments for the Southeast Storage Facility "shall ha w circuitry per procedures approved pursuant to Specification 6.8.2."
This requirement was imposed in NRC Amendment of Order dated December 19, 1984, since this facility does not have NFPA Code 71 circulty.
Subsequently, the circuitry for this facility has been established in accordance with NRC-approved procedures. Additionally, there are no current or future plans for any modification to this facility's fire detection instrumentation.
Thus, the requirement for Specification 6.8.2 approval should no longer apply to Specification 4.3.3.8.4.
Table 6.2-1 The requirements of this table state that during core alterations an additional Senior Operator Licensed (SOL) or an 50L Limited to Fuel Handling will be stationed on the operating floor, in the Command Center, or in the Control Room as specified in procedures approved pursuant to Specification 6.8.2.2.
This requirement was imposed by NRC Amendment of Order dated July 17, 1984, to allow the flexibility in stationing the SOL during core alterations.
The basis for requiring 6.8.2.2 approval was to obtain NRC concurrence with GPU Nuclear's position that the SOL could directly control core alteration activities from locations other than the operating floor.
Based on the numerous and extensive core alterations performed to date, GPU Nuclear believes that assurance hn been demonstrated that core alterations can be supervised safely and effectively from locations other than the operating floor, e.g., Control Room, Ccmmand Center, etc.
Therefore, GPU Nuclear proposes that the criteria of Specification 6.8.2.2 should no longer apply to this level of activity.
Stanificant Hazards Determination 10 CFR Paragraph 50.92 provides the criteria which the Commission uses to evaluate a No Significant Hazards consideration.
10 CFR 50.92 states than an amendment to a facility license involves No Significant Hazards if operation of the facility in accordance with the proposed amendment would not:
6 of 7 i
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.
These proposed changes to the Technical Specifications are primarily administrative in nature.
The proposed changes revise the criteria of Specification 6.8.2.2 to be more consistent with current plant conditions.
Additionally, several Technical Specifications which reference Specification 6.8.2.2 have been revised to indicate that NRC approval of their implementing procedures is no longer required.
The criteria of Specification 6.8.2.2 have been revised to require NRC approval of procedures which alter the distribution or processing of a quantity of radioactive material the release of which could cause the magnitude of radiological releases to exceed 10 CFR 50 Appendix I limits.
This appendix provides numerical guidelines for design objectives and Limiting Conditions for Operation to meet the criterion of "As Low As Reasonably Achievable." Thus, this proposal is consistent with current regulatory requirements as provided in the TMI-2 Appendix B Technical Specifications and the original basis for requiring NRC approval of certain THI-2 procedures.
From the above review, it is concluded that the changes proposed in this Technical Specification Change Request involves no Significant Hazards as defined by 10 CFR 50.92.
Amendment Class Pursuant to the requirements of 10 CFR 170, Licensing Fees, an application fee of $150.00 is enclosed.
i l
l I
7 of 7
. _ -