ML20249B239

TS Change Request 273 to License DPR-50,incorporating Alternate High Radiation Area Control Consistent W/Reg Guide 8.38

ML20249B239
Person / Time
Site:	Three Mile Island
Issue date:	06/11/1998
From:	Langenbach J GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20249B240	List: ML20249B239 ML20249B242
References
RTR-REGGD-08.038, RTR-REGGD-8.038 1920-98-20286, NUDOCS 9806220218
Download: ML20249B239 (6)

Text

.-

l GPU Nucleer, Inc.

\ Floute 441 South NUCLEAR Post Offsco Box 480 Middletown, PA 17057 0480 Tel717 944-7621 l June 11,1998 l

1920-98-20286 U.S. Nuclear Regulaterv Commission Att: Document Contrel Desk Washington, DC 20555

Subject:

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

Operating License No. DPR 50/ Docket No. 50-289 Technical Specification Change Request No. 273 Incorporate an Alternate High Radiation Area Control Pursuant to 10 CFR 50.4(b)(1), enclosed is TMI-l Technical Specification Change Request (TSCR)

No. 273. The purpose of this TSCR is to incorporate an altemate High Radiation Area Control consistent with Regulatory Guide 8.38.

Using the standards in 10 CFR 50.92, GPU Nuclear has concluded that these proposed changes do not constitute a significant hazards consideration, as described in the enclosed analysis performed in accordance with 10 CFR 50.9ig.)(1). Also enclosed is a Cenificate of Senice for this request, certifying senice to the chief executives of the township and county in which the facilities are located, as well as the designated official of the Commonwealth of Pennsylvania, Bureau of Radiation Protection.

Sincerely,

/

f Ideu James W. Langen ach Vice President and Director, TMI /

AWM - D/

Enclosures:

1) TMI-l TSCR 273 Evaluation and Significant Hazards Consideration

2) TMI-l Technical Specifications Resised Page

3) Cenificate of Senice for TMI-l TSCR 273 cc: RegionI Administrator TM1-1 Senior Project Manager TM1 Senior Resident Inspector File 98092

~,.,

~

9806220218 900611 PDR ADOCK 05000289 P PDR

I l . .

1 l

l Enclosure 1 TMI-l TSCR 273 Safety Evaluation and No Significant Hazards Consideration Analysis

1920-98-20286 Enclosure 1 '

Page'l  !

l

1. TECHNICAL SPECIFICATION CHANGE REOUEST (TSCR) NO. 273

)

GPU Nuclear requests that the following change be made to the existing TMI-l Technical l Specifications (TS): '

A. Replacement page: ,

6-22 l

i'

11. REASON FOR CHANGE The purpose of this TSCR is to incorporate an altemate High Radiation Area Control for TMI-1, which meets the requirements of 10 CFR 20.1601. The attemate control proposed would

{

provide greater operational efficiency by reducing the number of areas within the plant required to be maintained locked to prevent unauthorized or unintended access. In addition, a clarification was added to specification 6.12.1.b to plainly state that the personnel access requirements from specification 6.12.1.a are also required in specification 6.12.1.b. Also, an editorial change is made on specification 6.12.1.b to make the configuration of the term, "30 cm (11.8 in.)" consistent as used in specification 6.12.1.a.

An anticipated use of this alternate control would be to support future Once Through Steam Generator (OTSG) manway work. The current method of control (locking or guarding) results in a very cumbersome restriction on OTSG repair and testing operations and results in personnel receiving more dose than would be received using the requested attemate control.

III. SAFETY EVALUATION JUSTIFYING CHANGE As stated in 10 CFR 20.1601(a), licensees are required to institute strict controls for access to areas where an individual could receive greater than 100 mrem in one hour. A list of optional controls for high radiation areas is provided in 10 CFR 20.1601 paragraphs (a) and (b). For large complex facilities, such as a nuclear power plant, the most practical of these options is to maintain the entrances to high radiation areas locked except during periods of authorized personnel access. However, there are circumstances where the physical arrangement and access requirements of high radiation areas make this control method impractical. In cases where the controls provided in 10 CFR 20.1601(a) and (b) unnecessarily restrict plant operations,10 CFR 20.1601(c) provides for the licensee to propose altemative controls for access to high radiation areas.

I Regulatory Position 2.4 (Part C Section 2.4)in Regulatory Guide 838 describes an acceptable attemative to maintaining all high radiation areas locked. Under this alternative control scheme, areas where individuals could receive doses greater than 100 mrem, but less than or l

l l,

i l>

1920-98-20286 Enclosure 1 '

Page'2 equal to 1000 mrem, in I hour are barricaded and conspicuously posted in lieu of being maintained locked. Areas where doses in excess of 1000 mrem, but less than 500 rad, could be received in I hour are maintained locked (except for speciel cases where indisidual areas cannot reasonably be enclosed, a barricade with a flashing-light waming desice is provided.)

As a compensatory measure, access to a high radiation area may be controlled by the issuance of a radiation work permit to ensure that individuals are appraised of the known radiological conditions and protective actions required for accessing the area. Additional radiation monitoring is also required for individuals entering a high radiation area to provide for possible unanticipated exposure situations.

The requested flashing-light warning option is primarily intended for use with the OTSG primary manway doors / enclosures. Constructing lockable enclosures used solely for high radiation controls has proven in the past to be impractical due to the collective dose required and the interference they create for personnel and equipment. While the currently used shield doors are lockable, consistently using these locks has been difficult. For example, the !=ked shield doors interfere with OTSG tube testing and repair equipment, which use the small manways for access. The requested option provides a reasonable method to control access given the constraints of these areas.

The TMI-l Technical Specifications currently include all the above attemative methods of control, except for the flashing warning light altemative. GPU Nuclear's request meets the requirements of 10 CFR 20.1601(a) by incorporating all of the acceptable altemate high radiation area controls provided in Regulatory Guide 8.38. This regaested attemative control provides reasonable assurance that individuals will not exceed the regulatory dose limits by inadvenently accessing high dose rate areas at TMI-1.

The clarification added to specifica6on 6.12.1.b is editorial, and consistent with wording used in the corresponding section of the Standard Technical Specifications (STS) for B&W Plants (NUREG 1430).

IV. NO SIGNIFICANT HAZARDS CONSIDERATION GPU Nuclear has determined that this Technical Specification Change Request poses no significant hazards as defined by NRC in 10 CFR 50.92.

1. Operation of the facility in accordance with the proposed amendment would not involve a j significant increase in the probability of occurrence or the consequences of an accident previously evaluated. The proposed amendment involves changes to the TMI-l Technical Specifications, which are consistent with Regulatory Guide 8.38. This change does not involve any change to system or equipment configuration. The proposed amendment incorporates an attemate high radiation area control, which has been presiously found to l

i l

1920-98-20286 '

. Enclosure 1 - '

Page 3 -

l be acceptable by the NRC. The reliability of systems and components relied upon to prevent or mitigate the consequences of accidents previously evaluated is not degraded by the proposed changes. Therefore, this change does not increase the probability of-occurrence or the 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 change only involves controls for access to high radiation areas. Access to plant equipment during normal or accident conditions will not be affected by utilizing this ahernate method Therefore, the proposed amendment does not create the possibility of 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 is consistent with Regulatory Guide 838. The proposed amendment involves high radiation area access control and is not related to the margin of safety associated with any plant operation or transients, 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. .

V. IMPLEMENTATION d

It is requested that the amendment authorizing this change become effective upon issuance. -

l l_

METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY d/b/a

- GPU ENERGY GPU NUCLEAR, Inc.

Three Mile Island Nuclear Station, Unit 1 Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No. 273 COMMONWEALTH OF PENNSYLVANIA- .)

) SS:

COUNTY OF DAUPHIN )-

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 part of this request, a proposed replacement page for Appendix A is also included. All statements contained in this submittal have been reviewed, and all such statements made and matters set forth therein are true and correct to the best of my knowledge.

l BY: udt

%ce President andgrector, TMI Sw rn and subscribed before me this 2 day o @A,1998. 4 d

[ / NotanyPublic (.

n ,

k  ;

suunn.c"2%*Ly d u dngll:7.J7dstcd?&

I . hmba.Ponnsywant Assocaten of Notares l L

L