ML20245L617
| ML20245L617 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/28/1989 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20245L620 | List: |
| References | |
| C311-89-2039, GL-88-16, NUDOCS 8905080086 | |
| Download: ML20245L617 (9) | |
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i GPU Nuclear Corporation Nuclear
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Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2388 Writer's Direct Dial Number:
April 28, 1989 C311-89-2039 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C.
20555 Gentlemen:
Three Mile Island Nuclear Generating Station, Unit 1 (TMI-1)
Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No. 190 Removal of Cycle-Specific Parameter Limits In accordance with 10 CFR 50.4(b)(1), enclosed is one (1) original, and in addition ten (10) conformed copies of Technical Specification Change Request No. 190.
Also enclosed is one signed copy of the Certification 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.
The proposed amendment modifies the TMI-1 Technical Specifications to remove certain Cycle 7 :ycle-specific parameter limits, in accordance with the guidance containad in NRC Generic Letter 88-16, dated October 4, 1988.
Based on preliminary c/cle design results for the next TMI-1 cycle it is believed that removal of the cycle-specific parameters may preclude the need for a reload licensing amendment for Cycle 8.
The proposed amendment includes the following revisions to the TMI-1 Technical Specifications:
(1) the addition of the definition of a Core Operating Limits Report that includes the values of cycle-specific parameter limits that have been established using an NRC-approved methodology and consistent witb d 1 applicable limits of the safety analysis, (2) the addition of an administrative reporting requirement to submit the formal report on cycle-specific parameter limits to the Commission for information, and (3) the modification of individual Technical Specifications to note that cycle-specific parameters shall be maintained within the limits provided in the defined formal report.
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GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation t____________________________________
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. e n e, C311-89-2039 April 28, 1989 Pursuant to 10 CFR 50.91(a)(1), and using the standards in 10 CFR 50.92, we enclose our analyses 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,.the proposed change in. Technical Specifications, and our analyses of significant hazards considerations to Thomas Gerusky, the designated representative of the. Commonwealth of Pennsylvania.
Sincerely,-
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D. 1 kill Vice President & Director, TMI-1 HDH/DD/1m1 Attachments:
- 1) Technical Specification Change Request No. ICE
- 2) Certificate of Service for Technical Specification Change Request No.190
- 3) TMI-1 Cycle 7 Core Operating Limits Report cc:
R. Hernan W. Russell J. Stolz F. Young l
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UNITED STATES OF AMERICA j
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF DOCKET NO. 50-289 GPU NUCLEAR CORPORATION LICENSE NO. DPR-50 CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No. 190 to Appendix A of the Operating License for Three Mile Island Nuclear Station Unit 1, has, on the date given below, been filed with executives of Londonderry Township, Dauphin County, Pennsylvania; Dauphin County, Pennsylvania; and the Pennsylvania Department of Environmental Resources, Bureau of Radiation Protection, by deposit in the United States mail, addressed as follows:
Mr. Kenneth E. Witmer, Chairman Ms. Sally S. Klein, Chairman Board of Supervisors of Board of County Commissioners Londonderry Township of Dauphin County 25 Roslyn Road Dauphin County Courthouse Elizabethtown, PA 17022 Harrisburg, PA 17120 l
Mr. Thomas Gerusky, Director PA. Dept. of Environmental Resources Bureau of Radiation Protection P.O. Box 2063 Harrisburg, PA 17120 l
GPU NUCLEAR CORPORATION i
BY:
Q Vice Presitent & Director, TMI-1 l
DATE:
April 28, 1989 l
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METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER & LIGHT COMPANY AND-PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION, UNIT 1 Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No. 190 This Technical Specification Change Request is submitted in support of Licensee's request to change Appendix A to Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1.
As a.part of this request, proposed replacement pages for Appendix A are'also included.
GPU NUCLEAR CORPORATION BY:
b Vide President & Director, TMI-1 Sworn and Subscribed i
to before me this #8N day of d o n,/.
, 1989.
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Notary Putilic NOTAR!AL SEAL SHARON P. BROWN, NOTARY PuBUC MIDDLETOWN BORO, DAUPHIN COUNTY MY colo11SSION EXPIRES f)NE 12,1989 08e*. Penv,Ma Associaton of Notaries
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e I. - TECHNICAL SPECIFICATION CHANGE REQUEST (TSCR) NO. 190 GPUN requests that the following changed replacement pages be inserted into the existing Technical Specifications:
Revised pages: i, v, vi, vii, viii, 1-7, 2-3, 3-33, 3-34, 3-34a, 3-35, 3-35a, 3-36, 3-36a, 3-38, 5-4, 5-5, 6-19 and 6-19a.
GPUN also requests that the following Technical Specification figures and tables be deleted from the Technical Specification and relocated to the TMI-1 Core Operating Limits Report:
Remove Figures: 3.5-2A, 3.5-2B, 3.5-20, 3.5-20, 3.5-2E, 3.5-2F, 3.5-2G, 3.5-2H, 3.5-21, 3.5-2J, 3.5-2K, 3.5-2L, 3.5-2M.
l Remove Table: 3.5-1A (page 3-34a).
These pages are attached to this change request.
II.
REASON FOR CHANGE This change is requested to modify the TMI-1 Technical Specifications to remove cycle-specific parameter limits, in accordance with the guidance contained in NRC Generic Letter 88-16, dated October 4,1988.
The change also creates the Core Operating Limits Report which is the formal report that documents the TMI-1 cycle specific parameter limits that have been established using NPC-approved methodology, consistent with the applicable limits of the TMI-1 FSAR Safety Analysis. The Core Operating Limits Report for Cycle 7 operation is attached. This report, including mid-cycle revisions and supplements, will be submitted to NRC for each reload cycle for continued trending of this information, as specified in Technical Specification Section 6.9.5. Implementation of this change will conserve NRC and licensee rescurces by eliminating the need for reload license amendments for the sole purpose of updating cycle-specific parameter limits.
Certaia additional changes have been made consistent with removal of the cycle-specific parameters to clarify the axial pcwer imbalance specifications, the power distribution limits Bases, the incore instrumentation operational requirements, and the reactor core specification.
III.
SAFETY EVALUATION JUSTIFYING CHANGES Section 1.24 is added to provide the definition of the Core Operating Limits Report.
Section 2.1 Bases and References are changed to correct typographical errors. - _
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Section 3.5.2.2.c is changed to state that the reactor is brought to HOT SHUTDOWN rather than hot standby, as now statec' This is te make the a
specification consistent with Section 1.2, Reactor Operating Conditions, which defines HOT SHUTDOWN.as the subcritical state, whereas in HOT STANDBY the reactor is critical.
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Sections 3.5.2.4, 3.5.2.5 and 3.5.2.7 are revised to note that 1
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cycle-specific limits for quadrant tilt, control rod group position, and J
l axial nower imbalance shall be maintained within the limits provided in I
the Core Operating Limits Report. The NRC-approved methodology for
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determining these cycle-specific limits is documented in the following:
BAW-10122A, Rev.1, " Normal Operating Controls", May 1984; BAW-10152A, "N0ODLE - A Multi-Dimensional Two-Group Reactor Simulator", June 1985, as supplemented by Letter JHT/86-111: from a
L J. H. Taylor (B&W) to H. R. Denton (NRC), " Revised Incore Detector f
Error Allowances" July 23, 1986.
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Accordingly, Table 3.5-1A and Figures 3.5-2A - 3.5-2L which specify the cycle-specific limits for quadrant tilt, control rod group position, and axial power imbalance are removed and incorporated into the Cycle 7 Core Operating Limits Report.
For clarification, Section 3.5.2.5.d has been rewritten as a new Section 3.5.2.7, Axial Power Imbalance and includes the specification of the Full Incore System (FIS) operability requirements associated with axial power imbalance.
"Available" is changed to " operable" for technical specification consistency.
Section 3.5.2.4.a is revised to include the specification of the Full Incore System (FIS) operability requirements associated with quadrant tilt. Section 3.5.2.4.d is administratively revised to clarify wording for the licensed operators.
Sections 3.5.2.4.b and 3.5.2.7.b are revised to remove the words "displaye.. on the console." This char.ge is administrative in that this information is available from the display console or from the computer j
indication.
Section 3.5.2.7 is changed to 3.5.2.8 and is revised to note that cycle-specific limits for power distribution shall be maintained within the acceptable operating range provided in the Core Operating Limits
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Report. The NRC-approved methodology for determining the LOCA-limited maximum allowable linear heat rate (kw/ft) power distribution limits is documented in the following:
BAW-10103, Rev.3, "ECCS Analysis of B&W's 177-FA Lowered Loop NS3," July 1977.
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BAW-1775, Rev. O, " TACO-2 Loss-of-Coolant Accident Limit Analysis l
for 177-FA Lowered Loop Plants," February 1983.
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BAW-1915P, " Sounding Analytical Assessment of NUREG-0630 Models on LOCA kw/ft Limits With Use of FLECSET," May 1986.
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The LOCA-derived power distribution limits are not strictly cycle-specific parameters and are not expected to change with a new reload design.
However, for consistency and ease of operator use these limits are removed to the Core Operating Limits Report.
Any future changes to these limits would be based on changes to the ECCS evaluation model which necessarily would require NRC review and approval.
Accordingly, Figure 3.5-2M which specifies the cycle-specific power distribution limits is removed and incorporated into the Cycle 7 Core Operating Limits Report.
Section 3.5.2, Bases have been revised to reflect the removal of the axial power imbalance, quadrant power tilt and control rod position limits to the Core Operating Limits Report and to clarify the applicability of the limits to the Final Acceptance Criteria.
References regarding error adjustments to the limits curves and description of the control rod position curve regions have been removed and included in the Core Operating Limits Report with the curves.
The Bases have also been revised to include a statement emphasizing that the operability of the FIS depends on the validity of the signals of a minimum number of Self Powered Neutron Detectors as assumed in the uncertainty analysis; otherwise an alternative monitoring system must be used.
Section 3.5.4, Incore Instrumentation has been revised to clarify that the existing requirements apply to the Minimum Incore System (new 3.5.4.2).
The titles of sections 3.5.4.1 and 3.5.4.2 are revised for technical specification consistency.
Section 5.3.1, Reactor Core has been revised to remove cycle-specific information that is found in the Updated FSAR.
References for the section were changed accordingly.
Section 6.9.5 is added to provide the administrative reporting requirement to submit the Core Operating Limits Report to the NRC for information. This section also specifies that the Topical Reports which describe the analytical methods used to determine the cycle-specific parameter limits are contained in the Core Operating Limits Report.
These analytical methods have been previously reviewed and approved by NRC.
Future cycle-specific parameter limits will continue to be established using the methodology identified in Technical Specification 6.9.5, unless NRC review and approval for a change has been obtained.
Reference to the new methodology will then be included in the Core Operating Limits Report.
The specific values of the lim'n in the Core Operating Limits Report will be modified through the 10CrR50.59 process when such changes are determined using an NRC-approved methodology and are consistent with all applicable limits of the safety analyses addressed in the TMI-1 FSAR.
The core operating limits will be established and documented in the TMI-1 Ccre Operating Limits Report before each reload cycle or any remaining part of 0 taload cycle before implementation.
The TMI-1 Core Operating Limits Repor9., including any mid-cycle revisions or supplements thereto, will be proviied upon issuance to the NRC for trending information.
s The proposed amendment provides continued control of the values of TMI-1 cycle-specific parameters and assures continued conformance to 10CFR50.36, by specifying the calculation methodology and acceptance criteria used to establish the lowest functional performance levels acceptable for continued safe operation.
Technical Specification Table of Contents pages i, v, vi, vii, and viii are editorially revised to reflect the above revisions. Table of Contents page i is also revised to correct an administrative oversight by adding Definitions Item 1.23 - Substantive Change, which was added in Technical Specification Amendment No. 141.
IV.
NO SIGNIFICANT HAZARDS CONSIDERATIONS GPUN has determined that this Technical Specification Change Request poses no significant hazards as defined by NRC in 10CFR50.92.
1.
Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability of occurrence or consequences of an accident previously evaluated. The proposed amendment relocates the cyclen.necific parameter limits to the TMI-1 Core Operating Limits Report in accordance with the guidance c ontained in NRC Generic Letter 88-16. The proposed amendment provides continued centrol of the values of the TMI-1 cycle-specific parameters and assures these values remain consistent with all applicable limits of the safety analyses addressed.in the TMI-1 FSAR. The Technical Specifications retain the requirement to maintain the plant within the appropriate bounds of the cycle-specific parameter limits.
Therefore, the proposed amendment has no effect on the probability of occurrence or consequences of an accident previously evaluated.
2.
Operation of the facility in accordance with the proposed amendment would not create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed amendment relocates the cycle-specific parameter limits to the TMI-1 Core Operating Limits Report. The Technical Specifications retain the requirement to maintain the plant within th9 appropriate bounds of the cycle-specific parameter limits. Therefore, the proposed amendment has no effect on the possibility of creating a new or different kind of accident from any accident previously evaluated.
3.
Operation of the facility in accordance with the proposed amendment would not involve a significant reduction in a margin of safety. The proposed amendment provides continued control of the values of the TMI-1 cycle-specific parameters and assures these values remain consistent with all applicable limits of the safety analyses addressed in the TMI-1 FSAR.
Therefore, it is concluded that operation of the facility in accordance with the proposed amendment does not involve a significant reduction in a margin of safety.
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The Commission has provided guidelines pertaining to the application of the three standards by listing specific examples in 45 FR 14870. The proposed amendment is considered to be in the same category as example (i) of amendments that are considered not likely to involve significant hazards consideration in that the proposed change constitutes a purely administrative change to Technical Specifications. This change is similar in that it implements the guidance contained in NRC Generic Letter 88-16 for relocating the cycle-specific parameter limits to the TMI-1 Core Operating Limits Report.
Implementation of this revision in accordance with the generic letter guidance provides control of the values of cycle-specific parameters and assures continued conformance to 10 CFR 50.36 by specifying the calculation methodology and acceptance criteria used to establish the lowest functional performance levels acceptable for continued safe operation. Thus, operation of the facility in accordance with the proposed amendment involves no significant hazards considerations.
V.
IMPLEMENTATION It is requested that the amendment authorizing this change become effective upon issuance.
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