ML20236Y592
| ML20236Y592 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/04/1987 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20236Y474 | List: |
| References | |
| NUDOCS 8712140147 | |
| Download: ML20236Y592 (6) | |
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METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY GPU NUCLFAR THREE MILE ISLAND NUCLEAR STATION UNIT II l
Operating License No. OPR-73 Docket No. 50-320 Technical Specification Change Request No. 57 and Recovery Operations Plan Change Request No. 42 This Technical Specli'ication Change Request and Recovery Operations Plan J
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 part of this request, proposed replacement pages for Appendix A are also included.
GPU NUCLEAR
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By ' /
Director, TMI-2 F Sworn and subscribed to me this /
day of g d.yn d 4 1987, i
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>!Ge Notary Public
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Three Mile Island Nuclear Station, Unit 2 (THI-2)
Operating License No. DPR-73 Docket No. 50-320 Technical Specification Change Request (TSCR) No. 57 and Recovery Operations Plan Change Request (ROPCR) No. 42 The Licensee requests that the attached changed pages, listed below, replace l
the corresponding pages of the TMI-2 Technical Specifications and Recovery Operations Plan:
1-3 3.7-11 4.3-12 l
3.3-7 3/4 3-3 4.3-13 3.7-6 3/4 7-2 4.7-7 3.7-7 3/4 7-3 4.7-8 3.7-8 4.7-9 3.7-9 4.7-10 3.7-10 4.7-11 It is noteworthy, that there are no changes to pages 3. L7, 3.7-7, 3.7-10, 4.7-7, and 4.7-8; they are included solely for purposes of consistency.
The purpose of the proposed modifications is to modify those specifications related to fire protection systems to be consistent with the current unique safe shutdown condition of TMI-2.
This proposal is based on Revision 2 to the TMI-2 Fire Protection Program Evaluation (FPPE) (reference GPU Nuclear Letter 4410-87-L-0146 dated November 17, 1987). The FPPE revision demonstrates that only one (1) fire area need be maintained (i.e., the Reactor Building) based on an analysis that a fire in this facility and other areas (e.g., Auxiliary and Fuel Handling Buildings) would not affect the safe shutdown condition of the plant nor would it result in an off-site release greater than 10 CFR 100 limits.
Each of the proposed c.'anges is described below.
Description of Change I
1.
Specification 1.13, " Fire Suppression Water System," has been revised to delete terms " sprinkler" and "...or spray system riser" based on the proposed deletion of Tech. Spec. 3.7.10.2.
2.
Specification 3.7.10.1, " Fire Suppression Water System," has been revised as follows:
o Specification 3.7.10.1.a.3, " Unit 2 River Water Intake Diesel Fire Purrp," has been deleted.
o Specification 3.7.10.1.b.4, " Unit 2 River Water Intake Diesel Structure," has been deleted, o
Specification 3.7.10.1.c has been revised to delete the references to " sprinkler," " spray system riser," and Specification 3.7.10.2.
The required number of high pressure pumps and water supplies has been revised accordingly.
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3.
. Specifications 3.7.10.2 and 4.7.10.2, " Deluge / Sprinkler Systems," have been deleted.
4.
Specifications 3.7.10.3 and 4.7.10.3, "Halon System," have been deleted.
5.
Specifications 3.7.11, 4.7.11, and Basis 3/4.7.11, " Penetration Fire Barriers," have been deleted.
6.
Recovery Operations Plan Section 4.3.3.8.4, " Fire Detection - Southeast Storage Facility," has been deleted.
7.
Table 4.3-11, " Fire Detection Instruments," has been revised to retain only the fire detection instruments in the Reactor Building (i.e.,
RC-P-1A/2A and RC-P-1B/28).
8.
Table 4.7-1, " Fire Hose Stations," has been revised to retain only those fire hose stations on the 305' and 367' elevations of the Reactor Building.
9.
Bases 3/4.3.3.0, " Fire Detection Instrumentation," and 3/4.7.10, " Fire Suppression System," have been revised based on the proposed changd, to their respective specifications. Additionally, Basis 3/4.3.3.3.8 has been revised to reflect current practice to utilize remote mechanisms (e.g., CCTV coverage) for purposes of ALARA considerations, in lieu of a patrol, for performance of the required roving firewatch.
Reason for Change The proposed changes modify the TMI-2 Technical Specification Fire Protection requirements to reflect the current safe shutdown condition of TMI-2 as defined by Revision 2 to the TMI-2 FPPE.
Safety Evaluatirn Justifying Change 1.
Specification 1.13, " Fire Suppression Water System" - The proposed change to this specification is administrative in nature to ensure internal consistency of the Technical Specifications due to the proposed deletion of Specification 3.7.10.2.
2.
S3ecifications 3.7.10.1, " Fire Suppression Water System" - The basis for t7e above specification (i.e., Basis 3/4.7.10) currently states, in part: "The OPERABILITY of the Fire Suppression Systems ensures that adequate fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility where Safety Related equipment is located. The Fire Suppression System consists of the water system, spray and/or sprinklers, Halon and fire hose stations.
The collective capability of the Fire Suppression Systems is adequate to minimize potential damage to Safety Related equipment and is a major element in the Facility Fire Protection Program."
Revision 2 of the TMI-2 FPPE notes in Sections E.2(b) and (c), " Fire Protection Water Supply System," of the NRC Branch Technical Position (BTP) APCSB 9.5-1 comparison that only two (2) of the currently required four (4) fire pumps are necessary to provide the required flowrate of 3575 gpm for the TMI site. Additionally, Section E.2(d) requires only i
too (2) of the current four (4) cater supplies for the TMI site. Thus, the deletion of the TMI-2 Fire Pump FS-P1 and one (1) associated eater source will have no adverse affect on the ability to achieve the minimum design flowrate.
3.
Specification 3.7.10.2 and Recovery Operations Plan Section 4.7.10.2,
" Deluge / Sprinkler Systems - The basis for the above specification (i.e.,
Basis 3/4.7.10) is paraphrased in the Safety Evaluation Justifying Change for Specification 3.7.10.1.
The FPPE revision Section D.4(d),
" Ventilation," of the NRC BTP APCSB 9.5-1 comparison notes that the current Technical Specification required deluge systems for suppression of charcoal filter in TMI-2 ventilation systems are no longer necessary to maintain the safe shutdown condition of the plant or to maintain off-site doses less than 10 CFR 100 limits.
Therefore, it can be reasonably concluded that Technical Specifications no longer need to be retained for these systems.
4.
53 edification 3.7.10.3 and Recovery Operations Plan Section 4.7.10.3, "dalon System" - The basis for the above specification (i.e., Basis 3/4.7.10) is paraphrased in the Safety Evaluation Justifying Change for Specification 3.7.10.1.
The FPPE revision Sec' ion E.4, "Halon Suppression Systems," of the NRC BTP APCSB 9.5-1 comparison notes that the current Technical Specification required cable room and air intake tunnel halon systems are not necessary to maintain the safe shutdown or to maintain off-site doses less than 10 CFR 100 limits. Therefore, it can be reasonably concluded that Technical Specifications no longer need to be retained for these systems.
5.
Table 4.7-1, " Fire Hose Stations" - The basis for the above section (i.e., Basis 3/4.7.10) is paraphrased in the Safety Evaluation Justifying Change for Specification 3.7.10.1.
The FPPE revision, Section E.3(d),
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" Water Sprinklers and Hose Standpipe Systems," of the NRC BTP APCSB 9.5-1 comparison notes that the current Technical specification required fire hose station are not necessary to maintain the safe shutdown condition of the plant or to maintain off-site doses less than the 10 CFR 100 limits.
Therefore, it can be reasonably concluded that Technical Specifications no longer need to be retained for these systems. However, in the special case of the Reactor Building, the fire hose stations at the 305' and 367' elevations of the Reactor Building will still be maintained operable per the Technical Specifications to ensure adequate fire suppression capability exists.
6.
Recovery Operations Plan Section 4.3.3.8.4, " Fire Detection - Southeast Storage Facility," and Table 4.3-11, " Fire Detection InstI'uments" - The I
basis for the above specification (i.e., Basis 3/4.3.3.8) currently states:
"0PERABILITY of the Fire Detection Instrumentation ensures that adequate warning capability is available for the prompt detection of fires. This capability is required in order to detect and locate fires in their early stages. Prompt detection of fires will reduce the potential for damage to Safety Related equipments and is an integral element in the overall facility fire protection program."
Based on the analyses in Section 3.2 of the FPPE revision, a dasign basis fire will not affect either the capability to maintain the safe shutdown condition of the plant or to maintain off-site doses less than 10 CFR 100
limits. Therefore, it can be reasonably concluded that Technical Specifications no longer need to be retained for these systems. Hocever, fire detection capability will still be required to be maintained operable in the Reactor Building in order to ensure adequate warning exists in the event of a fire in this area.
4.
Specifications 3.7.11 and 4.7.11 - The revised FPPE maintains the Reactor Building as the sole fire area. The FPPE revision, Section D.l.j of the NRC BTP APCSB 9.5-1 Appendix A comparison states, "The Reactor Building exterior walls, penetration seals, and access hatches are not fire rated due to overriding nuclear considerations. However, they are of substantial construction and are considered to provide an adequate level of protection." Therefore, it can be reasonably concluded that Technical Specifications no longer need to be retained for these systems.
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 facility license involves No Significant Hazards if operation of the facility, in accordance with the proposed amendment, would not:
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.
Each of the above criteria is addressed below.
Does the change involve a significant increase in the probability or consequences of an accident previously evaluated?
The proposed change request modifies the Technical Specification requirements for fire protection to reflect the current monitored safe shutdown condition of TMI-2. This proposal is based on a safety analysis in Section 3.2 of Revision 2 to the TMI-2 FPPE which justifies that maintaining only one (1) fire area (i.e., the TMI-2 Reactor Building) will not affect either the capability to maintain the monitored safe shutdown condition of the plant nor result in off-site doses greater than 10 CFR 100 limits. Thus, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
Various Licensing Basis Documents presently address fire related accident scenarios (e.g., Technical Evaluation Report for the Waste Handling and Packaging Facility and the Containment Air Control Envelope; the Safety Evaluation Report for GPU Nuclear Corporation Seismic Design Criteria).
These documents do not take credit for the fire suppression / detection systems in the respective facilities for preventing or mitigating the
fire accident scenarios. Similarly, the accident scenarios in Chapter 15 of the THI-2 FSAR do not take credit for the fire suppression / detection systems to prevent or mitigate the consequences of an accident.
Therefore, the proposed change does not create possibility of a new or j
different kind of accident from any accident previously evaluated.
Does the change involve a significant reduction or a margin of safety?
The proposed change is consistent with the current bases for fire suppression / detection in the THI-2 Technical Specifications and FPPE in that the proposal will not affect the capability to maintain the safe shutdown condition nor result in off-cite doses greater than 10 CFR 100 limits.
The proposed change will still require fire detection and firefighting equipment in the Reactor Buildirg which will ensure adequate warning and l
fire suppression capability exists in the event of a fire in this area.
l Thus, the proposal does not involve a significant reduction in a margin of safety.
Based on the above analysis, it is concludea that the proposed changes involve no significant hazards 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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