ML20245A228

Forwards Application for Amend to License DPR-50, Consisting of Tech Spec Change Request 191,relocating Local Leak Rate Test Component & Valve Lists from Tech Specs to Updated FSAR to Permit Future Changes W/O License Amend

ML20245A228
Person / Time
Site:	Crane
Issue date:	06/13/1989
From:	Hukill H GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20245A230	List: ML20245A228 ML20245A286
References
C311-89-2040, NUDOCS 8906210161
Download: ML20245A228 (11)

Text

_ _ _ _ _ - _ _ _ _ - _ _ _ - -

GPU Nuclear Corporation GM Nuclear

=.orar8o Middletown, Pennsylvanly 17057 0191 717 944 7621 TELEX 84 2306 Writer's Direct Dial Number:

June 13, 1989 C311-89-2040 US Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

Dear Sir:

Three Mile Island Nuclear Station, Unit 1 (TMI-1)

Cperating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No. 191 In accordance with 10 CF4 50.4 (b)(1), enclosed is one (1) original, and in addition ten (10) conformed copies of Technical Specification Change Recuest No. Bl.

This TSCR includes changes related to 10CFR 50 Appendix J Local Leakage Rate testing (LLRT) including the relocation of LLRT component and valve lists from the Technical Specifications to the Updated FSAR.

Removal of tabular listings from the Technical Specifications is an area of Technical Specifications improvement that has been identifice by the Atcmic Industrial Forum (AIF) and the NRC. Relocation of these tabular listings to the Updated FSAR would allow future changes t' these lists, as permitted by the regulations, to be made without a license amendment, This would relieve both the NRC and GPUN of this adniinistrative burden.

This letter assumas that the license amendment authorizing this change will be approved by the NRC before the end of TMI-l's Operating Cycle 7 in early January, 1900. Therefore, this request does not include changes that will be neederi as a result of modifications currently planned for the Cycle 8 refueling outage (OR).

If the NRC does not intend to approve the amendment authorizing the relocation of valve and component lists from the Technical Specifications to the Updated FSAR prior to startup for TMI-1 Cycle 8 operation in February, 1990, GPUN requests to be notified by June 30, 1989 in order to allow sufficient time for preparation of a separate request for changes that will be needed to accommodate the BR modifications.

Enclosed 1s a copy of the revised FSAR pages that GPUN intends to submit in July, 1989 as part of FSAR Update 8.

The new FSAR Tr.bles 5.7-2 and 5.7-3 currently reflect chtnges regarding valves AH-VIA/B/C/D and LR-V10 as described in this request. Therefore, in order to ensure the accuracy of Tables 5.7-2 and 5.7-3 in our July, 1989 submittal, GpuN requests to be notified by June 30, 1989 of any changes to these tables that might be expected as a result of NRC approval of TSCR 191.

off GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation 8906210161 890613 I f (

FDR ADOCK 05000289 l

P poc

r l-l-

1 1

1, C311-89-2040 June 13, 1989 Also enclosed is one. signed copy of the' Certificate of Service for this request to the chief executives of the township and county in which the facility is:

located, as well as the Bureau of Radiation Protection.-

Pursuant to 10 CFR 5.0.91(a)(1), we enclose our analyses, using the standards in 10 CFR 50.92.of significant hazards considerations..As stated above, pursuant to 10 CFR'50.91(a) of the regulations, we have provided a copy of this letter,

.tha proposed change in Technical Specifications, zand our analyses of-significant hazards considerations to Thomas Gerusky, the designated representative of the Commonwealth of Pennsylvania.

Sincerely, i

'b H. D. Hul D1 Vice President & Director, TMI-1 HDH/MRK/spb

Enclosures:

1) Technical Spcelficot.f on Change Request No.191

2) Certificate of Service for Technical. Specification Change Request No. 191

3) Draft FSAR pages related t6 TSCR 191 that are i.ntended for GPUN submittal of FSAR Update 5 in July, 1989 cc:

J. Stolz R., dernan W. Russell F. Young l

I

4 e,

METROPOLITAN EDISON COMPANY-

JERSEY CENTRAL POWER A LIGHT COMPANY AhD PENNSYLVANIA ELECTRIC COMPANY l

1 THREE MILE ISLAND NUCLEAR STATION, UNIT 1 l

l Operating License N'o. DPR-50 Docket No. 50-289 Technical Specification _Changa Request No. 191 l

This Technical Specification Change Request is submitted in support of Licensee's 1

request to change Appendix A to Operating License Wo. DPR-50 for Three Mile Island Nuclear Shstion, Unit 1.

As a part of this request, proposed replacement pages for Appendix A are also included.

GPU NUCLEAR CORPORATION l

gy. %, W ;y v.cths,uu Vice Pret#ident & Director, TMI-1

{

l Sworn and Subscribad to beforpsme this

/dyt i

day of W me-1989.

l 0

l

> Lat 0

1 l

4 Nots'ry PubWe j

~

h01 ARRL SUL LIN0AL Rrf7ER,NOTARYPUBdC

]

M!DDLETCWN BORO, DAUPHtN COUNTY MYcOMMISS;0N EXFIRES FEB16,1993 MemW,Pannsylvand Ass:eie:cnof Notanos,

l.

l l

i

.l I

.j i

' UNITED STATES OF AMERICA-I 1

NUCLEAR REGLILATORY' COMMISSION -

1 i

IN THE MATTER OF DOCKET NO. 550-289 GPU~ NUCLEAR CORPORATION LICENSE NO. DPR-50' i

i i

i CERTIFICATE OF n WICE j

This is to certify that a. copy of Technical Specification Change Request No, G1 te Appendix A of the Operating License for Three Mile Island Nuclear Station Unit 1, has, en th1 date given below, been filed with executives of'Londonderry Township, pauphin County, Pennsylvania; Dauphin Ccunty, Pennsylvania; and the l

Pennsylvenla Department et Environmental. Rasources, Carwni of Radiation l

Protection, by deposit in the Unitad States mail, addressed as follows:

I Mr. Kenneth E. Witmer, cheirman Ms. Sally S. Klein, Chairman.

Board of Supervisors of Scard of County Commissioners Londonderry Township of Dauphin C6unty:

15 Ro.slyn Road Dauphin County Courthouse

)

Elizabethtowr., PA 17022 Harrisburg, PA 17120 l

l

]

l Mr. Thomas Gerusky, Director l

l

'PA Dept. of Ewironmental Rcisowces i

Bureau of Radiation Protection P.0, Box 2063 1

Harrisburg, PA 1h20 GPU NUCLEAR CORPORATION l

-1 YM k-b N 8 A4 "-

.l BY:

Vice Pndsident'& Directorv TMI-1 1

DATE:

b de 'M u

I l

'l

,i

l i

I.

TECHNICAL SpECIFTCAT!ON CHANGE REQUEST QSpR) NO. 191 i

1 GPUN requests that the attached revised pages 4-32, 4-33, 4-34, 4-34a, and 4-34b replace the respective pages and that page 4-34c be deleted from the TMI-1 Technical Specifications.

4 II. P.EASON FOR CHANGE J

This submittal requests changes to the listing of ' Reactor Building Containment Isolation penetrations and valves that are required to be tested in ectordance with 10CFR 50 Appendix J Local Leakage Rate type "B" and "C" tests (LLRT) as follows:

i A.

Changes or deletion from the lists to accurately reflect the j

requirements of 10CFR 50 Appendix J 4

1.

Helocation of the Reace r Building Containment Purge l

Supply /Edeust valves (AH-VIA/B/C/D) from the list of type "B" l

components to the list of valves requiring a type "C" test.

I l

2.

LR-V10 is a valve for which the 10CFR 50 Appendix J test 3

requirements were not intended and therefore this valve is to be deleted from the list of valves requiring a type "C"

test.

I B.

Addition of recently installed valves PP-V210,211,212,213 to the list j

of valves requiring LLRT type "C" testing in accordance with 10CFR 50 Appendix J to bring the lists up to date, i

l C.

Removal of the lists of Meactor Building Containment Isolation penetrations and valves from the Technical Specifications and relocation of these component lists to the FSAR.

D.

Deletion of requirements for maintenance of the Penetration Pressurization system ud for periodic surveillance of the Penetration Pressurization System rotameters.

(

l E.

Editorial changes and corrections to improve clarity and consistency to conform the above changes to the amendment approving this i

Technical Specificatioits Change Request (TSCR 191).

i l

This istter assumes that the amendment authorizing this ckrge will be l

l apprcved by the NRC prior to the end of TMI-1 Operating Cycle 7 in early

)

January, 1990. Therefore, this request dcas not include the changes that are expected to result from modifications planned for the cycle 8 refueling outage (SR).

If the amendment authorizing the relocation of l

valve anri component lists from the Technical Specifications to the ypdated FSAR lo not to be approved prior to startup for TMI-1 Cycle 8 operation, i

ther GPUN requests to be informed in order that we m&y submit a siparate request for changes that will be needed to accommodate the BR modifications.

( i L__._____._______

i Also, attached is a copy of the F3AR revised pages that GPUN will I

incorporate into FSAR Update 8 wMch is to be submitted in July,1989.

l These new FSAR Tables 5.7-2 and 5.7-3 currently reflect changes that are l

part of this request. Therefen, to casure that Tables 5.7-2 and 5.7-3 1

will be correct in our July,1989 submittal, GPUN reque' ts to ce notified s

no later than June 30, 1989 if the NRC does not intend to approve the 1

changes identified in A above regarding AH-VIA/B/C/D and LR-V10.

III. SAFETY EVALUATION JUSTIFYING THE CHANGE I

A.

Cctrcctions and deletions to the list which conform to 10CFR 50 Appendix J Local Leukage Rate test requirements:

~

I 1.

AH-VIA/B/C/D:

The Reactor Beilding Ccatainment Wrge Supply / Exhaust valves j

(AH-V1A/B/C/0) are to be moved from the list of type "B" components to the list of valves requiring a type "C" test. An editorial change to Technical Specification 4.4.1.2.5.c is therefore being made to provide the appropriate reference to the applicable 10CFR 50 Appendix J, section (III.D.3). This chmge I

is editorial because the purpose of this reference is to refer to the applicable test frequency and not to require that the parge valves be included in the litt of valves requiring a type "B" test. The test methodology and acceptance criteria for purge valve testing will remain the same, j

l Special tests and inspections of the purge valyes would continue j

to exceed the Appendix J test requirements For Containment i

Isolation Valve type "C" tests. Moving the purge valves from the list of valves requiring a type "B" test to the type "C" list could result in a change in purge valve test requirements i

in that it would no longer be required to test the valves prior to startup if opened following a Type "A" or "B" test if the

(

startup were to occur < 92 days since the last test. The 3

existing special tests of the purge valves each quarter and

~

examinations each refueling interval provide adequate assurance l

of timely detection of purge valve seat degradation and j

inoperability.

]

LLRT Type "B" Test requirements apply to containment penetrations whose design incorporates resilient seals, airlock 3

doors, and doors with resilient seals or gaskets.

In accordance with 10CFR 50 Appendix J, the type "C" test is clearly specified f

to apply to valves such as AH-V1A/B/C/D that " provide a direct connection between the inside and outside atmospheres of the l

primary re&ctor containment under normal operation, such as l

purge and ventilation,... valves." Apparertly, because tYe-design of the purge valves incorporates the use of resilient seals, these valves were inappropriately included in the original TMI-1 Technical Specifications as type "B" components.

The purge valves were the only valves included in the list of j

type "B" components.

l9 i

^

Because of the conr.ern for timely detection of seal degradation j

for valves with resilient seals, it was part of the resolution 1

of the NRC's'senaric issue, Multi-plant Action (MPA) B-24,' to I

increase the frequency of purge valve testing to quarterly j

(Technical Spr.cification section 4.4.1.2.5.d), add examir.ation requirements for the purge ;alve seats each refueling interval and require replacement of the seals each refueling outage after

]

a five (5) years service life (Technical Specification section I

4.4.1.4).

Tests of the purge valves on a quarterly frequency in conjunction with refueling interval inspections is adecuate to i

detect seal degradation ar.d provide for timely determination of i

purge valve inoperability. Thecefore, placing the purge valves j

on the list of valves requiring s 10CFR 50 Appendix J, type "C" test does not pose a safety concern.

I 2.

LR-V10:

i l

LR-V10 has been included in the list of valves requiring a type I

l "C" t?st ever since the original TMI-1 Technical Specifications was issued even though such a test is not needed in meeting the Local Leakage Rate test requirements of 10CFR 50 Appendix J.

LR-V10 is a manual handwheel operated test connection valve between containment isolation valve LR-V49 and a containment isolatica blind flange associated with containment penetration

1. 417. LR-V1D has a blind flange installed at its outlet i

resulting in double manual isolation of the test connection.

Therefore LR-V10 should be deleted from the list of valves requiring a type "C" test.

B.

Addition of valves to the list of valves requiring Local Leakage Rate tests in accordance with 10CFR 50 Appendix J to bring the list up to i

8 ate as a reselt of a recent modification:

l PP-V210,211,212,213 are normally closed, handwheel oparated Penetration Pressurization System globe valves which are being added to the list of valves for which the type "C" test requirements apply. These valves are being added to update the list as a result of recent plant modifications and reflect all of tha valves that are required to be tested in accordance with 10CFR 50 Appendix J Local Leakage Rate test requirements.

On November 7, 1986 TMI-1 feiled an as-found Reactor Building Integrated leakage hte Test (ILRT). This event was reported to tha NRC in a Licensee Event Report (LER) 86-13.

In a followup uctica related to this event, Penetration Pressurization System check valves PP-V100, 103, 132, and 135 were char.ged to globe valves and renumbered to PP-V210, 211, 212, and 213. These valves will be maintained closed to serve a containment isolation valve function.

1

-34

)

l i

~

C.

Relocation of the lists to the FSAR Removal of tabular listings from the Technica'i Specifications is an area of Technical Specifications improvement that has been identified by the Atomic Industrial Forum (AIF) and the NRC.

The tabular listing of penetration components and valves requiring i

LLRT are to be removed from Technical Specification section 4.4.1.2.1

)

and relocated tc the FSAR in Update 8, dated 7/89. The new Updated l

FSAR tabult-listing of penetrations and valves requiring Local Leak Rate tests in accordance witn 10CFR 50 Appendix J (TM14 Updated FSAR l

Tables 5.7-2 and is.7-3) are enclosed.

Requirements fer containment i

isolation, the action statements and the specific test requirements l

associated with the listed components and valves will remain in the Technical Specifications.

A Technit.a1 Sp2cification section 4.4.1.2.3 referen.e to the list is being deleted titd a statement is being added to the bases which l

refers to the list in the Updated FSAR.

Future changes to the list of Containment Isolation Valves requiring Local Leakage Rate Tests in Table 5.7-2 and 5.7-3 in the FSAR would l

only be implemented following completion of a safety evaluation in l

accordance eith 10CFR 50.59 and a review by the Plant Review Group l

(PRG). Relocation of tnese tabular listings to the Updated FSAR would allow future changes to these lists, as permitted by the regulations, to be made without a license amendment. This would relieve both the NRC and G9UN of this administrative burden.

D.

Deletion of the require;nents for ouarterly yendinos of the i

Penetration Pressurization System rotameters (Technical Specification J

surveillance 4.4.1.2.5.e.):

The Penetration Pressurization system is capable of being lined up to constantly pressurize all mechanical penetrations to greater than the 1

i building design pressure. Neither IOCFR 50 Appendix J nor any other I

code requires the constant pressurization of any TMI-1 containment j

isolation device.

Likewise, the Standard Technical Specifications do not require periodic monitoring of the Penetration Pressurization System. The originai purpose for the Penetration Pressurization System and related surveillance tests would have been to permit a i

reduced LLRT program or justify exemptions from the 10CFR 50 Appendix J which was not issued until after the issuance of the TMI-1 l

Technical Specifications. However, all containment penetrations with I

resilient seals, process system flanges, valves, and geskets l

requiring periodic leak test per Appendix J are now tested using Type l

"B" or "C" tests with no credit or exemptions for the use of a fluid l

blocking system. During ILRT (Type "A", integrated leakage rate tests), tha Penetration Pressurization Syttem is disabled and no J

l credit is taken for the system.

i

, l

v=W

_-w The Penetration Pressurization system is not qualified by design or fabrication to act as a fluid blocking system as defined by Appendix J.

TMI-1 therefore takes no credit in the safety analysis for the a:tIve function of the system.

Likewise, there is no code or Standard Technical Specification requiring the quarterly use of the Penetration Pressurization System for Leakage Rate testing. The sole safety related function of the Penetration Pressurization system pertains to the fact that '.nterconr.teticus to safety related systems act as qualified pressure boundaries. Deletion of the requirements for atarterly monitoring of Penetration Pressurization System rotameters is therefore justified.

E.

EDITORIAL CHANGES AND CORRELATIONS 1.

"AEC" has been changed to "NRC" on page 4-32, 2.

"FSAR Section 5" has been changed to "FSAR Chapter 5" on revised page 4-34b.

3.

"(0.06 percent)" in the Bases, on revised pages 4-34a and 4-34b, has been changed to "0.6 L." and moved to the end of the sentence in which it is located on revised page 4-34a. The purpose of this change is to improve clarity and to be consistent with specification 4.4.1.2.3. terminology. The meaning is unchanged.

4.

"27.5 psig' in the Bases on page 4-34a has been changed to "30 psig" to be consistent with the change to Specification 4.4.1.1.3 that was made in Amendment 63, dated March 30, 1981.

This change is editorial in that the Bases should have been changed in Amendment 63 to be consistent with the change to Specification 4.4.1,1.3.

Reduced pressure testing in accordance with Specification 4.4.1.1.3 is not currently approved for use, however GPUN considers this a viable test method that has been included in the TMI-1 design and this method may be approved by the NRC some time in the future.

For this reason we would like to clear up an inconsistency but we do not wish to delete Specification 4.4.3.1.3 at this time.

5.

An inccrrect reference in Section 4.4.1.5 on revised page 4-34 l

has been changed to crrectly reference the acceptance criteria of Specification 4.4.1.1.6.

6.

Other editorial changes and corrections that are not changes limited to punctuation only are discussed in A. through D.

above.

In summary, these changes are either purely administrative in nature or changes of minor technical significance and are intended to make corrections that are justifieri and appropriate in accordance with the requirements of 10CFR 50 Appendix J.

No question of safety is involved in the changes reflected in this Technical Specification Change Request. _

4 4

IV NO SIGNIFICANT HAZARDS CONSIDERATIONS GPUN has determined that this Technical-Specification Change Re4uest p0ses no significant hazards as defined by the NRC in 10CFR 50.92. This change is considered to be administrative in nature and does not involve significant hazards consideration as evaluated below.

1.

Operation of Three Mile Island Nuclear Station, Unit-1,in accordance with this change would not involve a significant increase in the l

probability or consequences of an accident previously evaluated 4

because the proposed Tachnical Specification change does not modify or create any accident initiatir.g condition. This change provides for update of tne list of components subject to 10CFR 50 Appendix J i

Type "C" tests to add additional componer,ts to the list, improvement in the Technical Specifications by relocating lists to the FSAR, and deletion of certain test requirements that are not needed to facet the requirements of 10CFR 50 Appendix J.

Deletior, of the rs@irementc for Penetration Pressurization System quar *.erly rotameter readinss does not result in changes contrary to the requirements of 10CFR 50 Appendix J or the NRC's Star.dard Technical Specifications for Babcock and Wilcox Pressurized Water Reactors (NUREG-0103). The changes included in this request are either purely administrative in nature or are of minor technical significance and have no significance J

related to safe plant operation.

1 (10CFR 50.92(c)(1))

2.

Operation of Three Mile Island Nuclear Station, Unit-1, in acccrdance j

with this change would not create the possibility of a new or different kind of accident from any accident previrusly evaluated 1

because the proposed Technical Specification change does not modify i

or create any accident initiating condition. The proposed changes to the LLRT test requirements in Technical Specifications will result in technical specification requirements that meet or exceed the requirements of 10CFR 50 Appendix J.

1 (10CFR 50.92(c)(2))

l 3.

Operation of Three Mile Island Nuclear Station, Unit-1, in accordance l

with this change would not involve a significant reduction in a margin of safety because all Updated Final Safety Analysis Report I

(USAR) assumptions remain unchanged. The proposed changer to the LLRT test requirements will result in technical specification requirements that meet or exceed the requirements of 10CFR 50 Appendix J.

A minor change in the test requirements for the purge valves would not change the test methodology or the acceptance criteria and would not significantly affect the assurance of the early detection of purge valve seat degradation cnd inoperability because the additional examinations and increased (quarterly) test frequency of the purge valves bey 9nd the Appendix J test requirements would be retained.

Deletiori of the requirements for penetration pressurization System quarterly rotameter readings is not discussed in the basis for any __

l TM1-1 Technical Specification'. Any. reduction-in test requirements-resulting from this change would not significantly affect the timely detection of. contain;aent isolation valve or penetration inoperability.

(10CFR 50.92(c)(3))

The Commission has provided guidelines pertaining to the application of the three standardt by listing @ecific examples in the Federal Register (48 FR 14870). This proposed change is considered to be in the same category as examples.(i), (ii),'or (iv) of the " Amendments Not Likely to-l Involve Significant Hazards C6nsideration" from that listing. Thus, operation of the facility in accordance with the proposed amendment involves no. significant hazards considerations.

l. -

V.

IMPLEMENTATION It is requested that the amendment authorizing this change become effective upon issuance and shall be implemented within thirty days of receipt.

t 1

l i i

.