ML20246P302

Safety Evaluation Supporting Amend 151 to License DPR-50

ML20246P302
Person / Time
Site:	Three Mile Island
Issue date:	08/31/1989
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20246P289	List: ML20246P285 ML20246P302
References
NUDOCS 8909110083
Download: ML20246P302 (4)

Text

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%.a....f SAFETv EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.151 TO FACILITY OPERATING i.ICENSE NO. DPR-50 METROPOLITAN EDISON COMPANY JERSEY CENTPAL POWER & LIGHT COMPANY PENN5YLVANIA ELECTRIC COMPANY GPU NUCLEAR CORPORATION THREE MILE ISLAND NUCLEAR STATION. UNIT NO. 1 DOCKET NO. 50-289, INTRODUCTION

.GPU Nuclear Corporation (GPU' submitted Technical Specification Change Request (TSCR) No. 191 by letter dated June 13, 1989. The amendment requested by this TSCR would remove Section a.4.1.2.1, Scope of Testing, from the Technical Specifications (TS) anc relocate the listing of containment penetration components and valves requiring type "B" and "C" leak rate testing to the Updated Final Safety Analysis Report (USAR). The request also included changes to these lists resulting from modifications to the facility and reevaluation of 10 CFR 50, Appendix J requirements as well as various other editorial changes.

Finally, the TSCR requested removal, from the TS, of a periodic surveillance regarding the Penetration Pressurization System.

EVALUATION The operability of containment isolation valves and leak integrity of containment penetration components ensure that the containment atmosphere will be isolated from the outside environment in the event of a release of radioactive material to the containment atmosphere or pressurization of the containment.

To ensure operability and integrity of this hardware, Appendix J requires periodic leak testing of three different types: type A for overall containment integrated leakage, type 8 for various types of containment penetrations and type C for containment isolation valve leakage. Presently the specific components requiring type B and C leak tests are specifically listed in TS Section 4.4.1.2.5.

Each time the content of this list changes due to facility modifications or regulation interpretation a formal amendment to the facility operating license is required. GPU has proposed removal of the list from the TS and incorporating it in the USAR as Table 5.7-2 (type B testing) and Table 5.7-3 (type C testing).

Final draft copies of these tables were included with the TSCR.

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i 3 s The Commission's Interim policy Statement on Technical Specification Improvements recognized the advantages of improved TS and endorsed the recommendations of the nuclear industry and the NRC staff for a program to develop improvements in TS. An important part of that program is the implementation of line-item improvements in TS. This change has been implemented in the TS for new licenses and is consistent with previous guidance provided by Generic Letter 84-13 on removing the list of snubbers from TS. Guidance to licensees regarding removal of this list from TS will be provided to all power reactor licensees in a future generic letter based on issuance of a similar amendment for Crystal River Unit 3 in May 1989. Relocation of the listing of components requiring Appendix J type B cnd C leak testing would allow future changes to be made without a license amendment. This would relieve both the NRC and the licensee of an administrative burden but would not change any requirements to perform Appendix J leak testing. Maintaining the table in the USAR would also ensure that the information is still available to the operators. Changes to the table would be controlled under 10 CFR 50.59 as a change to the facility. Therefore, adequate measures exist to control changes to the facility without having these components listed in the TS. Due to the proposed relocation of Section 4.4.1.2.5 from the TS to the USAR, references to the section would be deleted from TS 4.4.1.2.3.

The TSCR also discusses three changes to the local leak rate test listing itself. The first is moving containment purge valves AH-VIA/B/C/D from the type B list to the type C list. Type B test requirements apply to containment penetrations whose design incorporates resilient seals, airlock doors, and doors with resilient seals or gaskets.

In accordance with 10 CFR 50 Appendix J, the type C test is clearly specified to apply to valves such as AH-VIA/B/C/D that " provide a direct connection between the inside and outside atmospheres of the primary reactor containment under normal operations, such as purge and ventilation,... valves." Apparently, because the 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 type B components.

Special tests and inspections of the purge valves would continue to exceed the Appendix J test requirements for containment 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 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 less than 92 days since the last test. The existing special tests of the purge valves each kS!E [ deSNcki$ k N e'0akve* h! b $g ab!O $n En N op$fa0$ N Iy* lbe"skaN agrees with this change. A resultant editorial change to TS 4.4.1.2.5.c is required to reflect the appropriate Appendix J section (III.D.3).

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e e The second change to the local leak rate test listing is deletion of valve LR-V10 from the type C list. LR-V10 has been included in the list of valves requiring a type C test 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 10 CFR 50 Appendix J.

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

1. 417. LR-V10 has a blind flange installed at its outlet resulting in double manual isolation of the test connection. Therefore LR-V10 should be deleted from the list of vlaves requiring a type C test. The staff agrees with this change m The third change to the listing is addition of valves PP-V210, 211, 212 and 213 to the list of type C valves to be tested. During a recent modification, these globe valves were added to the facility to replace four check valves in the Penetration Pressurization System. The staff agrees with this change.

The TSCR also requested deletion of TS 4.4.1.2.5.e which provides for quarterly monitoring of the Penetration Pressurization System. The TSCR stated that this system is not required by Appendix J or any codes and that the TMI-1 safety analysis takes no credit for the active function of this system. The system, in fact, is disabled during the Appendix J type A containment integrated leak rate test. The staff notes, however, that this system interconnects with the instrument air system. The original purpose for the Penetration Pressurization System and related surveillance tests would have been to permit a reduced leak rate test program or justify exemptions from the 10 CFR 50 Appendix J.

However, all containment penetrations with resilient seals, process system flanges, valves, and gaskets requiring periodic leak test per Appendix J are now tested using Type B or C tests with no credit or exemptions for the use of a fluid blocking system.

The apparent purpose of TS 4.4.1.2.5.e is to detect abnormal leakage in the Penetration Pressurization System. Since credit is not taken for this system the staff agrees that this surveillance serves no useful purpose. The staff reviewed the possible detrimental effects this system may have on the instrument air system should a major rupture occur in the system, thereby potentially causing depletion of instrument air. We concluded that the possibility of this occurrence is very remote in light of existing low pressure alarms, the ability to isolate the system and recent instrument air system enhancements under the Safety Performance Improvement Program. We therefore conclude that deletion of this TS is appropriate and has no detrimental effect on plant operation.

SUMMARY

The staff finds that the requested changes will maintain conservative limiting conditions for plant operation and adequate surveillance requirements. Thus, the staff finds the proposed changes to be acceptable.

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. ENVIRONMENTAL CONSIDERATION

'The amendment changes a requirement with respect to installation or use of l

a facility component located within the restricted area as defined in 10 CFR Part 2, and also relates to changes in recordkeeping, reporting or administrative l'

procedures or 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 off site, and that there is no significant increase in individual or cumulative occupational exposure. The staff has previously issued a proposed finding that this the amendment involves no significant hazards consideration, and there has been no public comment on such finding. Accordingly, the amendment meets the eli exclusion set forth in 10 CFR 51.22(c)(9) and (10)gibility criteria for categorical 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.

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 not be endangered by operation in the proposed manner, and (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance

-of this emendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: Ronald L Hernan Dated:

August 31, 1989 i

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