ML20215E880
| ML20215E880 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/12/1986 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20215E867 | List: |
| References | |
| NUDOCS 8612230153 | |
| Download: ML20215E880 (11) | |
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION c
E WASHINGTON, D. C. 20555 s.,,,/
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING APENDMENT N0. 122 TO FACILITY OPERATING LICENSE NO. DPR-50 METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY GPU NUCLEAR CORPORATION THREE MILE ISLAND NUCLEAR STATION, UNIT N0. 1 DOCKET N0. 50-289
1.0 BACKGROUND
In a letter dated March 27, 1986, GPU Nuclear Corporation (GPUN or the licensee) submitted a description of their engineering design for a new Fuel Handling Building (FHB) Engineered-Safety-Feature (ESF) ventilation system in response to a commitment in the TMI Restart Hearing Partial Initial Decision (PID),Section III.B. paragraph 1265, Vol. I, dated December 14, 1981, and in the GPUN Letter 5211-83-103, R.C Arnold to J.F. Stolz " Engineered-Safety-Feature (ESF) Filter System' dated March 31, 1983.
Further descriptive information regarding the design and operation of the TMI-1 FHB ESF ventilation system and related aspects of the TMI-2 FH3 ventilation system was provided by the licensee in their letter dated October 1, 1986. By letter dated August 25, 1986, the licensee also submitted Technical Specification Change Request (TSCR)
No. 156 in order to comply with the condition of operation imposed by the Licensing Board as described in the NPC letter dated October 2, 1985 (Item 1.C). Subsequently TSCR No. 156, Revision 1, was submitted by another letter dated October 1,1986, to address NRC staff comments generated during review of the original TSCR 156. This letter also revised two previous consnitments contained in the March 27, 1986 submittal.
Item 1.C of the NRC's October 2, 1985 letter states that: "After the restart of Unit I and prior to any movement within the Unit 1 fuel handling building of any irradiated Unit 1 fuel, GPU Nuclear Corporation shall install, and have operable, an engineered safety feature (ESF) filtration system for the Unit I fuel handling building. The ESF filtra-tion system for Unit I shall be operable whenever irradiated Unit I fuel is moved within the Unit i fuel handling building." This item in the NP.C j
letter was based on the aforementioned PID which states:
" Prior to tha first refueling outage, licensee will upgrade the system to include a new ESF filter system meeting the guidelines of Regulatory Guide (RG) 1.52, " Design, Testing, and Maintenance Criteria for Post-Accident ESF Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants, (Revision 2, March 1978)";
and...the purpose of the ESF filter system is...to protect against Unit 1 fuel handling accidents."
8612230153 861212 PDR ADOCK 05000289 l'
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2.0 INTRODUCTION
The FHB ESF Air Treatment System (i.e., FHB ESF ventilation system) is being installed to contain, confine, control, mitigate, monitor and record the radiation release resulting from a TMI-1 postulated spent fuel accident in the FHB as described in Final Safety Analysis Report (FSAR),
Section 14.2.2.1, Update 4, 7/85.
In general terms, the licensee has stated, "The functions of the FHB ESF Ventilation System are as follows:
1.
Reduce the possibility of airborne radioactive releases to the environment by discharging the fuel handling flonr exhaust air through a filtered, monitored, and controlled path.
2.
Serve as a means of collecting the radioactive release and processing the radioactive iodine and particulates from the postulated fuel handing accident to levels acceptable for the release to the environment."
To comply with GPUN commitments, the TMI-1 FHB ESF Air Treatment System is required to be operable and operating whenever irradiated fuel is being moved within the FHB to protect against a fuel handling accident. Design, construction, operation, and testing of this new system in accordance with RG 1.52, Revision 2, 1978, were reviewed by the NRC staff.
Operability and surveillance requirements of TSCR 156 and Revision 1 were examined by the NRC staff. These requests provided specifications for the new FHB ESF Air Treatment System and modified the specifications for the existing Auxiliary and Fuel Handling Exhaust Air Treatment System.
In addition, editorial and administrative TS changes were made to improve clarity and adopt later testing standards.
Furthermore, appropriate TS bases and design features were also updated.
In both requests, the name Auxiliary and Fuel Mandling Exhaust Air Treatment System was replaced by the name Auxiliary and FHB Air Treatment System. For clarity, the latter name will be used in this evaluation.
The Auxiliary and FHB Air Treatment System is required to be operable at M1 times during power operation for accident mitigation as described in FSAL Chapter 14 and 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 ventilation system, the Auxiliary and FHB Air Treatment System will not be required to mitigate the offsite dose consequences of a fuel handling accident in the FHB.
3.0 EVALUATION A.
FHB ESF Air Treatment System Design In this review, the NRC staff focused primarily on design of the TMI-1 FHB ESF ventilation system in accordance with the guidelines of RG 1.52, as prescribed by the PID.
However, for review purposes, RG 1.52 does also reference RG 8.8, "Information Relevant to Ensu-ing that Occupational Radiation Exposures at Nuclear Power Stations will be As low As Is j
)
' Reasonably Achievable," and other standards for use in design and testing of ESF atmosphere cleanup systems (e.g., ANSI N509-1976 " Nuclear Power Plant Air Cleaning Units and Components" and ANSI N510-1975 " Testing of Nuclear Air Cleaning Systems").
7t should be noted, Standard Review Plan (SRP)
Section 6.5.1, "ESF Atmosphere Cleanup Systems", Rev. 2, July 1981, has referenced the more recent revisions of the air cleaning standards than PG 1.52.
Consequently, we have also accepted in our evaluation any appropriate references to ANSI-N509-1980 and ANSI-N510-1980, instead of ANSI-N509-1976 and ANSI-N510-1975.
RG 1.52 does not address the acceptability of ESF atmosphere cleanup systens with regard to the radiological consequences of postulated fuel handling accidents. Therefore, the NRC staff used the following acceptance criterion from SRP Section 15.7.4, " Radiological Consequences of Fuel Handling Accidents," Rev. 1, July, 1981, to evaluate the design of the FHB ESF ventilation system filter system:
"The plant site and dose mitigating ESF systems are acceptable with respect to the radiological consequences of a postulated fuel handling tecident if the calculated whole-body and thyroid doses at the exclusion area and low population zone boundaries are well within the exposure guideline values of 10 CFR Part 100, paragraph 11.
'Well within' means 25 percent or less of the 10 CFR Part 100 exposure guideline values, i.e., 75 rem for the thyroid and 6 rem for the whole-body doses."
The NRC staff did not review the FHB ESF ventilation system against the acceptance criteria of SPP Section 6.5.1 or SRP Section 9.4.2,
" Spent Fuel Pool Area Ventilation System" since the PID referred only to the guidelines of RG 1.52.
In their Parch 27, 1986 letter, GPUN stated that "the FHB ESF ventilation system shall be designed in accordance with RG 1.52 and applicable sections of RG 8.8 using the guidelines of SRP Sections 6.5.1, 9.4.2 and 15.7.4.
Specific design features shall be as identified in ANSI /ASME N509."
The NRC staff has reviewed all applicable information submitted by the licensee and concludes that the design of the TMI-1 FHB ESF Air Treatment 1
System meets the intent of the RG 1.52 guidelines. Specific aspects which warrant further detailed explanation are described telow.
Section C.2.a of RG 1.52 recommends ESF atmosphere cleanup systems should be provided with demisters.
In response, the licensee has stated that the ESF filter units are not provided with demisters because the presence of saturated steam or water droplets is not anticipated in the air stream during a fuel handling accident. The NRC staff agrees and concludes this design meets the intent of the RG 1.52 guidelines.
Section C.2.b of RG 1.52 recommends that the generation of missiles from high pressure equipment rupture and natural phenomena should be considered in the design of ESF atmosphere cleanup systems.
In response, the licensee has stated there is no high energy pipe near the FSF filter system.
- Furthermore, natural phenomena w,-re addressed by procedural requirements-which halt all fuel movement activity in the event of a hurricane or tornado warning. Therefore, ro additional protection for high energy rupture and natural phenomena is needed. The NRC staff finds that high pressure missiles and natural phenomena have been adeouately considered and concludes this design meets the intent of the RG 1.52 guidelines.
Section C.2.c of RG 1.52 recommends all components of an ESF atmosphere cleanup system should be designated Seismic Category I if failure of a 4
component would lead to the release of significant quantities of fission
-products to working or outdoor environments.
In response, the licensee stated that components of the ESF ventilation system and their enclosure are not required to be seismically. qualified since their
. failure during a design basis seismic event would result in onsite and offsite doses below those of the criteria of SRP Section 15.7.4.
This is based upon the TMI-1-FSAR design basis fuel handling accident of 56 damaged fuel rods. The NRC staff performed independent analyses of the dose consequences of this accident assuming failure of the FHB ESF Air Treatment System.
In these analyses, the staff used the guidelines of RG 1.25, " Assumptions Used for Evaluating the Potential Radiological Consequences of a Fuel Handling Accident in the Fuel Handing and Storage Facility for Boiling and Pressurized Water Peactors," as referenced in SRP Section 15.7.4.
In addition to the offsite dose consequences, the staff calculated doses to personnel in the TMI-1 and TMI-2 control rooms, assuming failure of the FHB ESF ventilation system during the design basis fuel handling accident. SRP Section 6.4, " Control Ro m Habitability System," provides doses to an individual in the control room that should not be exceeded for a postulated accident. The NRC staff concludes, based on these analyses, that the calculated doses to personnel in the TMI-1 and TMI-2 control rooms, and at the exclusion area boundary, for the design basis fuel handling accident without a functional ESF atmosphere cleanup system are below those of the acceptance criteria of SRP Sections 6.4 and 15.7.4 respectively. Thus, the corresponding releases of fission products to working and outdoor environments are not significant. Therefore, the NRC staff finds that a non-seismically qualified FHB ESF ventilation system design meets the intent of the 1
'RG 1.52 guidelines.
l Section C.2.d of RG 1.52 recommends ESF filter systems should be protected
,i from pressure surges resulting from postulated accidents.
In response, the licensee has stated there are no pressure surges associated with the design basis fuel handling accident, therefore, protection from pressure i.
surges is not provided. The NRC staff agrees and concludes this design meets the intent of RG 1.52.
i Section C.2.g of RG 1.52 recommends ESF atmosphere cleanup systems should be instrumented to signol, alarm, and record pertinent pressure dror.s and flow rates in the control room.
In response, the licensee stated thit the ESF Ventilation System shall be operated continuously during fuel handling operations. The system will be provided with minimum instrumentation for local readout and alarm, and for readout and alarm at a remote manned l
control panel, as indicated in ANSI-N509-1980. Critical operating parameters shall be alarmed, indicated, and recorded at remote locations i
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- (remote from the system filter components), which will only be manned (as required by plant procedure) if a fuel handling accident has occurred.
Fuel handling accident indication by the Effluent Radiation Monitor shall be alarmed, indicated, and recorded in the Control Room. The NRC staff concludes the instrumentation design and provisions meet the intent of RG 1.52 guidelines.
Section C.2.h of RG 1.52 recommends the following:
The power supply and electrical distribution system for ESF atmosphere cleanup systems should be designed in accordance with RG l
1.32.
All instrumentation and equipment controls should be designed to IEEE Standard 279. The systems should be qualified and tested under RG 1.89.
To the extent practicable, RGs 1.30, 1.100 and 1.118, and IEEE Standard 334should be considered in the design.
In response, the licensee has stated the electrical power and control system for the E3F ventilation system design complies with RG 1.52 provisions, including a reliable electrical power supply for effluent radiation monitoring capability. Redundant Class lE power circuits for each ESF fan and filter preheater, as well as instrumentation circuits, also meet RG 1.52 requirements where applicable. However, due to bus loading limitations, the FHB ESF Air Treatment System will not be operated whenever one of the station auxiliary transformers (or 4160 V ESF bus) is out of service while Unit 1 is operating. During such conditions there will be no irradiated fuel movement. This restriction does not apply when Unit 1 is shutdown.
In the event of a loss of offsite power, the capability to manually load the ESF ventilation system onto the diesel is provided. The NRC staff concludes the licensee's power and control system design meets the intent of RG 1.52 guidelines.
Section C.S.c of RG 1.52 recommends that HEPA filter sections-should be leak tested in place at least once per 18 months; Section C.S.d recommends the activated carbon adsorber section should be leak tested at least once per 18 months; and Section C.6.a(3) recommends representative samples of used activated carbon should pass the laboratory tests given in.
Table 2 (of RG 1.52) at least once per 18 months for systems maintained in a standby status or after 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation.
In response, the licensee has stated the expected service life of filters in the FHB ESF ventilation system is comparable to a standby system, and reouiring testing at least once per refueling interval, rather than at least once per 18 months is justified. The NRC staff concludes that performing the above tests for TMI-1 ESF ventilation system filters at least once per refueling outage meets the intent of PG 1.52 (see the TS discussion on this same subject for more detail).
Section C.6.b of RG 1.52 recommends that representative samples of used ESF filter system activated carbon should pass the laboratory tests given in Table 2 of the RG.
In response, the licensee has proposed a laboratory acceptance criterion of 90% minimum removal efficiency for methyl iodide by the ESF filter system carbon adsorbers. This is consistent with require-ments for laboratory testing of carbon adsorbers for other atmosphere cleanup systems at TMI-1. The NRC staff concludes this acceptance criterion meets the intent of RG 1.52.
. The NRC staff evaluated acceptability of the FHB ESF filter system with regard to the radiological consequences of postulated fuel handling accidents in accordance with the previously cited acceptance criterion of SRP Section 15.7.4.
The licensee has maintained that, in accordance with the FSAR, the design basis accident consists of only 56 damaged fuel rods.
However, the FHB ESF Air Treatment System has the capability to adeouately monitor and mitioate the consequences of effluent
- resulting from a 208 rod cccident, using RG 1.25 guidelines. We performed an independent analysis of the dose consequences of this accident usino D
RG 1.25 guidelines as referenced in SRP Section 15.7.4 Based on this analysis, dose consequences are within the acceptance criterion.
j Therefore, the NRC staff concludes FHB ESF Air Treatment System filter system design capacity for removal of fission products from exhaust air t
is acceptable, The licensee has stated the FHB ESF Air Treatment System shall include adequate air filtration and exhaust capacity to ensure that no uncon-trolled radioactive release to the atmosphere occurs. RG 1.52 contains no statement regarding testing to demonstrate that ESF atmosphere cleanup systems are capable of maintaining a negative. pressure in specified critical plant areas to ensure no uncontrolled radioactive releases to the atmosphere occur. Proposed TSs by the licensee (August.25 and October 1, 1986) for the FHB ESF ventilation system likewise contain no requirement for such testing.. However, another GPUN letter of October 1, 1986 did propose a one time post-installation start-up test to demonstrate system capability of drawing a negative pressure in the
. fuel handling area. Furthermore, the licensee has committed to put procedures in place (before fuel handling operations commence) that preclude any significant or unevaluated changes in the arrangement of physical barriers relied upon by the FHB ESF ventilation system design (which were in place during initial verification testing of. the system) to control releases of radioactive material during a fuel handling j
accident. The NRC staff concludes, based upon satisfactory implement-ation of startup testing and procedure commitments, that this aspect of the FHB ESF ventilation system meets the intent of RG 1.52.
The NRC staff determined from its review that prompt isolation of both the TMI-1 and the TMI-2 normal FHB ventilation systems and the prompt closure of the railway access door-common to the FHBs, following an accident signal in the TMI-1 FHB, are required in order for the TMI-1 FHB ESF ventilation system to perform its intended function. The licensee has committed to impose procedures prior to Cycle 6 refueling which will require:
- 1) maintaining the railway access door closed during irradiated fuel handling operations, and 2) implementing prompt isolation of both TMI-1 and TMI-2 normal FHB ventilation systems following fuel handling accident indication in the TMI-1 FHB. The NRC staff considers these procedural instructions will be acceptable to address FHB isolation.
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L The Commonwealth of Pennsylvania and the NRC staff had some questions 2 -
concerning the seismic capability of the roof supporting the new ESF ventilation system. These concerns are addressed herein. GPUN has evaluated the. adequacy of the Auxiliary Building structure for the additional loadings resulting from components of the FHB ESF ventil-ation system. The licensee has indicated that the total added weight on top of the auxiliary building roof due to the FHB ESF ventilation system, and supporting concrete pad, is 216,000 pounds. Original weight of the roof used in the mathematic medel for the auxiliary building seismic 1
analysis was 43,871,000 pounds. Therefore, the added weight represents.
only 0.49% of the original weight. The NRC staff concurs with the' licensee's evaluation that the effect of this additional weight is negligible with respect to seismic response. The NRC staff also concurs the effect of this additional weight is negligible with respect to the local supporting strength of the-roof because the roof was designed for a concentrated load of 17,000,000 pounds. Based on.the above, the NRC staff concludes the L
Auxilitry Building structure is adequate to support additional loadings resulting from the components of the FHB ESF Air Treatment System.
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In summary, the NRC staff concludes that the design of the TMI-1 FHB ESF Air Treatment System, described in the aforementioned GPUN submittals, meets the intent of RG 1.52 for ESF filter systems designed to control radioactive releases and protect against unacceptable offsite doses following a FHB accident. Therefore, this system is acceptable provided the previously detailed procedural commitments are properly implemented (see also the following TS evaluation summary).
1 i
B.
FHB ESF Air Treatment and Auxiliary and FHB Air Treatment Systems Technical Specifications (TSCR 156 & Revision 1)
The NRC staff reviewed the proposed addition of TS 3.15.4 and 4.12.4 (including bases) for operation and surveillance of the new FHB ESF Air Treatment System primarily for conformance with the guidelines of RG 1.52 as specified in the PID. Proposed changes to TS 3.15.3 and 4.12.3 (including bases) were reviewed for the existing Auxiliary and FHB Air Treatment System with respect to this system's reduced accident mitigation responsibility. Other TSCR 156 (Revision 1) changes to incorporate the new 4
FHB ESF Air Treatment System in Section five (" Design Features") Tables i-3.21-2 and 4.21-2 (" Radioactive Gaseous Process and Effluent Ponitoring Instrumentation" operability and surveillance requirements), and Table 4.22-2 (" Radioactive Gaseous Waste Sampling and Analysis Program") were i
also reviewed.
Furthermore, additional editorial and administrative changes or corrections affecting the TSs to improve clarity, reflect newer standards, or delete inapplicable notes have been examined by the NRC staff.
Mitigation of a fuel handling accident (in the FHB) is now to be provided by the new FHB ESF Air Treatment System and will no longer depend on the operation of the Auxiliary and FH3 Air Treatment System. However, in the proposed changes to the TS for the Auxiliary and FHB Air Treatment System, references to FSAP Sections 14.2.2.5 and 14.2.2.6 were added which describe 4
the role of this system in mitigating the consequences of, respectively, t'
engineered safeguards leakage external to the reactor building during the
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- . recirculation phase for long-term core cooling following the maximum hypothetical accident, and the rupture of a waste gas tank.. Therefore, the staff review considered the proposed TS changes for the Auxiliary and FHB Air Treatment System in accordance with its continuing role for mitigation of offsite dose consequences for the above postulated accidents.
The NRC staff has reviewed the proposed TS changes and safety analyses submitted by the licensee and finds the proposed changes and supporting rationale to be generally acceptable. Those specific aspects which warrant further detailed explanation are described below.
Section C.2.a of RG 1.52,' recommends ESF atmosphere cleanup systems designed and installed for the purpose of mitigating accident doses should be I
redundant. Proposed TS 3.15.4 (FHB ESF Air Treatment System) would require both trains of the system to be operable (prior to fuel movement) for each refueling outage, with one train operating continuously whenever irradiated fuel handling operations in the FHB are in progress. With only one train operable and operating, fuel handling operations could still continue; but, with both trains inoperable, fuel handling operations could not continue except to complete any fuel assembly movement in progress. However, no limit is specified on the period of time during which fuel handling operations are allowed to continue with only one train operable and operating.
In order to evaluate this proposal, the NRC staff performed an independent analysis of the dose consequences of the design basis fuel handling accident (56 damaged fuel rods), assuming the complete failure of th? new FHB ESF Air Treatment System.
In this analysis, the staff used the guidelines of RG 1.25, as referenced in SRP Section 15.7.4.
Based on this analysis, the staff determined that the calculated doses to personnel in the TMI-1 and TMI-2 control rooms and at the exclusion area boundary are below those of the acceptance criteria of SRP.
Sections 6.4 and 15.7.4, respectively. Therefore, the NRC staff concludes TS 3.15.4 is acceptable. Fuel handling operations, once started, can continue indefinitely with only one train of FHB ESF Air Treatment System operable and operating. That is until the next refueling outage, when both trains are again required to be operable (prior to fuel movement).
1 Section C.4.d of RG 1.52 recommends that each ESF atmosphere cleanup train should be operated at least 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month, with the heaters on (if so equipped), to reduce the buildup of moisture on the adsorbers and HEPA filters. Proposed TS 4.12.4.3 for the FHB ESF Air Treatment System contains this requirement and is, therefore, acceptable. However, in the licensee's proposal, TS 4.12.3.2.d for the Auxiliary and FHB Air Treatment System, which contained this requirement, was deleted on the basis that the Auxiliary and FHB Air Treatment System is not (now) required to meet PG 1.52.
Contrary to'this, as described previ6usly, the Auxiliary and FHB t
Air Treatment System continues to perform a post-accident function for mitigation of offsite dose consequences. Therefore, this change to 1
TS 4.12.3.2.d is not acceptable, and the 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> per month testing requirement has been retained.
Section C.S.c of RG 1.52 recommends that HEPA filter sections should be leak-tested inplace at laast once per 18 months. Section C.S.d recommends that the activated carbon adsorber section should be leak-tested at least once per 18 months, and section C.6.a(3) recommends that i~
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representative samples of used activated carbon should pass the laboratory tests given in Table 2 (of the RG), which indicates that tests should be performed at least once per 18 months for systems maintained in a standby status or af ter 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation.
ERDA 76-21,
" Nuclear Air Cleaning Handbook", referred to in ANSI N509-1980 end
~ ANSI N510 1980 states that regular in place testi g of sta dby systems n
n is necessary os.cause deterioration (and leaks) can take place even when systems are not being operated.
Further, because of the uncertain life of activated carbon under normal operating conditions, ERDA 76-21 indicates that the NRC recommends adsorbent samples from ESF systems be taken for laboratory testing every 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of fan operation, and for standby systems, at least once per 18 months. However, propcsed TS 4.12.3 for the Auxiliary and FHB Air Treatment System and TS 4.12.4 for the FHB ESF Air Treatment System require the above test at least once per refueling outage, rather than at least once per 18 months. These TSs represent a revision in the commitment contained within the GPUN submittal of March 27, 1986.
In response, the licensee has stated the expected service time of the FHB ESF Ventilation System filter system approaches that of a standby system. Therefore, requiring the HEPA filter and carbon adsorber-leak testing and carbon laboratory testing at least once per
~
refueling interval rather than at least once per 18 months is justified since, under current circumstances, this would not result in less frequent testing.
Furthermore, actual results of GPUN operational experience with the TMI-1 Auxiliary and FHB Air Treatment System have demonstrated that very little degradation of the system filter's methyl iodide removal efficiency has resulted even after approximately five years of continuous use. Based on the above, the NRC staff finds that performing the above tests for the Auxiliary and FHB Air Treatment System and the FFB ESF Air Treatment System at least once per refueling outage meets the intent of RG 1.52, and, therefore, this aspect of proposed TS 4.12.3 and 4.12.4 is acceptable, Section C.6.b of RG 1.52 recommends that representative samples of used ESF filter system activated carbon should pass the laboratory tests given in Table 2 of the RG. Proposed TS 3.15.3.2.b for the Auxiliary and FHB Air Treatment System and TS 3.15.4.2.b for the FHB ESF Air Treatment System require that the results of laboratory carbon sample analysis shew greater than 90% radioactive methyl iodide decontamination efficiency when tested at 30 C, 95% relative humidity. This is consistent with reouirements for laboratory testing of carbon adsorbers for other atmosphere cleanup systems at TMI-1. The NRC staff finds that this requirement meets the intent of RG 1.52 and is, therefore, acceptable.
l Proposed TS 4.12.4 for the FHB ESF Air Treatment System 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, but does not require the system to be operated for two hours prior to movement of irradiated fuel as was discussed in the licensee's March 27, 1986 submittal. This constitutes a revision of a previous written statement. However, RG 1.52 Revision 2 of 1978, does not require the system to operate for two hours before declaring the system operable.
Therefore, the NRC s'.aff concludes this change in commitments does not represent an exception to RG 1.52 and is acceptable for the TSs.
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' - TSCR 156 and Revision 1 did not propose any requirements in Table 4.22-2 for' quarterly composite sampling and analysis of gross alpha, Sr-89, and Sr-90 from the FHB ESF Air Treatment System exhaust. Attachment 2, of the GPUN letter-dated October 1, 1986 (" Responding to NRC questions i
on the TMI-1 FHB ESF Ventilation System") provided justification for-not routinely analyzing FHB ESF Air Treatment System effluents for gross i
alpha, SR-89, and SR-90. The reasons given were that this ventilation
~
system will not be operated continuously during TMI-I operation; and even for those specific periods when it is, the majority cf FHB ventilation flow will be through the Auxiliary and FHB Air Treatment System to the Unit 1 stack, which is sampled and analyzed quarterly for the radionuclides of concern.
Furthermore, the licensee had at detected any significant levels
~ of these radionuclides during Cycle 5 continuous composite sampling.
Thus, the NRC staff concludes the TS for continuous composite sampling and routine analysis of gross alpha, Sr-89, and Sr-90 at the FHB ESF Air
+
i Treatment System exhaust are not warranted. However, the licensee should be sensitive to any indicators from their sampling program that suggest the significance of these radionuclides has changed, at which time additional analysis may be necessary.
RG 1.52 contains no guidelines regarding testing tn demonstrate that ESF l'
atmosphere cleanup systems are capable of maintaining negative pressures in specified critical plant areas to ensure that uncontrolled radioactive releases to the atmosphere will not occur. The existing TMI-1 TSs for the Auxiliary and FHB Air Treatment System, which were relied on to mitigate the consequences of a fuel hant"hg accident in the FHB, contain no requirement for such testing. ISCR and Pevision 1 for the FHB ESF Air Treatment System and the Auxiliary and FHB Air Treatment System likewise contain no requirements for such testing. The proposed TSs for these systems just require periodic air distribution tests at specified
+
design air flow rates. The licensee, however, has committed to establish procedures, before commencing fuel handling operations, that will preclude significant or unevaluated changes from being made to the physical. barriers relied upon by the FHB ESF Air Treatment System design i
and initial start-up test. Therefore, the system's ability to maintain a i
negative pressure in the FHB will not be compromised due to relocation of barriers, which could result in uncontrolled release of radioactive materials during a fuel handling accident. Based on the abcve, the NRC i
staff concludes that this aspect of the proposed TSs for the FHB ESF Air Treatment System meets the intent of RG 1.52 and is, therefore, acceptable. Furthermore, the proposed TS amendments ensure a level of safety which is no less than that provided by the existing TSs and, therefore, are acceptable.
l In summary, the NRC staff concludes, based on the review and evaluation detailed above, that proposed changes to TS 3.15.3, 3.15.4, 4.12.3, and 4.12.4; Tables 3.21-2, 4.21-2, and 4.22-2; Figures 5-3; and pages ii, iv, and 5-10 meet the intent of RG 1.52 and are acceptable. However.
l deletion of TS 4.12.3.2.d is denied and the following additional considerations apply to the new ESF FHB ventilation system (per GPUN commitments identified in letter dated December 5, 1986):
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Pertinent procedures shall be implemented prior to fuel movement to preclude significant or unevaluated changes in physical barriers relied upon by system design and initial startup test, and 2.
Pertinent procedures shall be in place prior to fuel movement which maintain the rail way access door closed during fuel handling,and assure prompt isolation of TMI-1 and TMI-2 normal FHB ventilation during a FHB accident.
ENVIRONMENTAL CONSIDERATION l
This amendment involves a change in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and in surveillance requirements. We have determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure..The Commission has previously issued a proposed finding that this l
amendment involves no significant hazards consideration and there has been l
no public comment on such finding. Accordingly, this amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of this amendment.
i l
CONCLUSION We have concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will r.ot be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public.
Dated: December 12, 1986 Principal Contributor:
C. Nichols
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