ML20237D601

Forwards Response to Request for Addl Info Re Rev 1 to Tech Spec Change Request 112.Statement in Tech Spec 1.22 Re Unrestricted Access by Persons Defined as Members of Public Omitted Since No Individuals Have Unrestricted Access

ML20237D601
Person / Time
Site:	Crane
Issue date:	12/21/1987
From:	Hukill H GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
5211-87-2225, TAC-62815, NUDOCS 8712240065
Download: ML20237D601 (4)

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December 21, 1987 b

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Three Mile Island Nuclea'r Station, Unit 1 (TMI-1)

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t Docket No. 50-289 Response to Request for /tdditional Information i[

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on Technical Specification Change Request No.112, Rev. "j-j 7 9, l /*

t Technical Specification Change Request No.112, Rev.1 date6 Nov,information on Attached isf91D's response to the NRC's request for addifonal ember 10, V', C j

1987.

No chmges to any of the Technical Specification pagesirevioasly

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RESPONSE TO U; GUEST FOR ADDITIONAL INFORMATION 1

l 1.

The definition for "mer6er{h) of the public" in' proposed TS 1.22 is different than the definition in the' Standard Tecnnical Specifications (STSL The definition in the STS includes persor.( who use portions of the site for recreational, occupational or other purposes not associated with the plant.

Egla7s why the preceding individuals should not be considered " member (s) "if the public," or adopt the definition in the STS.

Rssponse The definition of " member (s) of the public" as proposed in' TS 1.22 differs from the Standard Technical Specification definition in that the sentence "This category does. include persons wPo use portions of tb site for recreational, occupational or other perposes not associated with the plant." is not included. This sentence was omitted because there is no unrestHcted access of individuals to tue site, thus, the statemer.t does not ap,'ly.

All individuals who are on the site, which is considered the cwher controiT td area (Updated FSAR figure 2.1-3), are radiologically

onitored and therefore not considered " members of the pubMc" for the purposes of ca%ulating dose per the Tech. Spec. requirements.

2.

GPU propows to change the applicability for the surveillar.ce l

requirement.t for the instrumentation used to monitor the Containment

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Purge Vent System and the Condenser l'ent System (e.g., jsee pages 4-91 and 4-93). GPU proposes that the surveillance 9 re@irements will only apply when the containment is being purged, or when condenser vacutu is established. However, the STS state that the surveillance requirewits should be applicable at all times. Provide a basis for concluMng that the monitoring system should not be required to be tested prior to its use during containment purging or when condenser vacuum fr. estabin.hed.

Describe any circumstances in which it woulo be necessary, or desirable, to purge or vest ed there would not be suf ficient time to check, test, and/or calibraa INe instruments.

Describe Yae benefits frem relaxing this requirement.

For example, wtil the reiaxation of this requirement be compensated by a decrease in occupational exposure, or enhanced safety in the plant? Be quantitative to the extent feasible.

Response

The applicability for the t. surveillance requirements f ter the Contelament Purge Vent System and t.ie Condenser Vent System was rMsed to be only

. when the containment id being purged, or when condenser vacuum is established. The applicability was revised to be consistent with the 4

proposed applicability of thq corresponding Limiting Conditions for Operation.

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2.

Response (Cont'd.)

Tech. Spec. 4.0, Surveillance Standards states:

During Reactor Operational Conditions for which a Limiting Condition for Operation does not require a system / component to be operable, the associated surveillance requirements do not have to be performed. Prior to declaring a system / component operable, the associated surveillance requirements must be current. The above applicability require-ments assure the operability of systems / components for all Reactor Operating Conditions when required by the Limiting Conditions for Operation.

This Tech. Spec. assures that the surveillance will be performed prior to containment purging or condenser vacuum being established. Also, the instruments are maintained in a stand-by condition by performing the surveillance at the specified frequencies. The change does not represent a relaxation, thus, the benefits will not be discussed.

Purging may be performed per Tech. Spec. 3.6.10.b and c.

There is an administrative process to be performed prior to purging, thus, sufficient time would exist to perform any surveillance that were not current.

As clarification, the function of the Condenser Vent System identified in Table 4.21-2 is to continuously remove non-condensable gases via the vacuum pumps once vacuum has been established.

The instrument RM-A5 and its equivalent are parallel condenser off-gas monitors.

3.

GPU proposes to change the applicability for the minimum channels operable requirements and the " Action" statements for the instrumentation used to monitor:

the Containment Purge Monitoring System and the Condenser Vent System (e.g., see pages 3-102, 3-103, and 3-105). GPU proposes that the operability requirements and the " Action" statements will only apply when the containment is being purged, or when condenser vacuum is established. However, the STS states that the operability requirements and the " Action" statements should be applicable at all times. Provide a basis for concluding that the monitoring system should not be required to be operable prior to its use during containment purging or when condenser vacuum is established.

Although the current TS allows releases to continue even if the monitoring system is not operable (provided that grab samples are taken), describe any problems with collecting grab samples that might either delay the purge or vent, or allow a purge or vent without proper sampling and analysis.

Describe the benefits from relaxing this requirement.

For example, will the relaxation of this requirement be compensated by a decrease in occupational exposure, or enhanced safety in the plant? Be quantitative to the extent feasible. L

3.

Response

By requiring operability of instrumentation in the Containment Purge l

Monitoring System and the Condenser Vent Systen when containment is being purged, or when condenser vacuum is established, it is inherent that the instrumentation is operable prior to its use.

This is assured by Tech.

Spec. 4.0 as stated in our response to Item 2.

Current Tech. Specs, allow purging to continue provided that grab samples i

are taken and analyzed as part of an Action Statement. Thus, purging would not be allowed without proper sampling.and analysis.

Due to the nature'of the purposes for which we may purge, any delay that could possibly occur due to problems with grab sampling would not affect the safe operation of the plant. The Action Statement associated with the y

Condenser Vent System does not permit grab sampling as an' alternate means of sampling and analysis.

By decreasing the frequency of grab sampling to once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (STS) from once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, occupational exposure would be reduced.

The distribution 'of the radionuclides mix would be the same in the less frequent sample, thus, any trend would still be detected. Also, any trend would also be detected by the reactor coolant leak detection system sensitive to radioactivity required by Tech. Spec. 3.1.6.8.

4.

Explain why the quarterly channel test for the sample flow rate monitor for the Auxiliary and Fuel Handling Ventilation System is not necessary (i.e., page 4-92, item 5.e. ).

Response

The quarterly channel test for the sampler flow rate monitor for the Auxiliary and Fuel Handling Ventilation System is not necessary due to the type of monitor. The monitor is a rotometer, therefore, a channel test involving injection of a test signal, as defined by TS 1.5.2, does not apply. These mechanical devices are periodically removed and placed in a flow test stand.

Rotometers that fail to meet the performance standard are discarded since no adjustment exists. Performing this test every 18 months is adequate because precise sampler flow rate is not critical. This monitor is the same as the atmospheric monitor in Table 4.21-2 Item 3.E, which currently does not require a channel test to be performed.

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