ML20137G833

Safety Evaluation Accepting Containment Penetration Valve Configurations

ML20137G833
Person / Time
Site:	Three Mile Island
Issue date:	07/08/1985
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20137G826	List: ML20137G821 ML20137G828 ML20137G833
References
NUDOCS 8508270394
Download: ML20137G833 (13)

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Enclosure 2 l

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION GPU NUCLEAR CORPORATION METROPOLITAN EDIS0N COMPANY PENNSYLVANIA ELECTRIC COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY DOCKET NO. 50-320 THREE MILE ISLAND NUCLEAR STATION UNIT NO. 2 INTRODUCTION Py letter dated October 31, 1984, GPU Nuclear Corporation (GPUNC) informed the NRC that certain penetration valve configurations did not comply with the definition for containment integrity stated in a July 17, 1984

.- Amendment of Order issued by the Director, Nuclear Reactor Regulation. The staff also compared the referenced penetration configurations to a July 17,

, 1984 Approval of Alternate Design for 10 CFR 50, Appendix A, for Criteria 55 and 56 type penetrations and concluded that the subject configurations were also not in compliance with these requirements.

DISCUSSION On February 11, 1980, the Director of Nuclear Reactor Regulation issued an Order, modifying the pre-accident technical specifications to more appro-l priately reflect what was required at that stage of the TMI-2 recovery. As l

l a part of that Order, the definition of containment integrity was made more restrictive by deleting the reference to any exceptions that could be taken j by the licensee relative to isolation valve requirements.

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As a result of the February 11, 1980 Order, the THI-2 Proposed Technical Specifications (PTS), Section 1.7.a stated the following:

" CONTAINMENT INTEGRITY shall exist when:

a. All penetrations are closed by automatic valves, manual valves, blind flanges, or deactivated automatic valves i secured in their closed positions, except those pene-trations required open per approved procedures."

On July 17, 1984, an Amendment of.0rder modified the above wording to state as follows:

" CONTAINMENT INTEGRITY shall exist when:

a. All penetrations are maintained by two closed automatic or manual containment isolation valves or a double barrier

, in each penetration per procedures approved pursuant to

- specification 6.8.2.

On December 19, 1984, this section was revised to be even more specific by a subsequent Amendment of Order to:

" CONTAINMENT INTEGRITY shall exist when:

a. All penetrations required to be closed during accident 4

conditions are either:

1. Capable of being closed by valves on each side of the penetration or by double valve isolation outside of the reactor building per procedures approved pursuant to Specification 6.8.2. Isolation valves inside the reactor building shall be capable of remote operation

. from a control station outside of the reactor building, or;

2. Closed by manual valves, blind flanges, or deactivated automatic valves secured in their closed positions to provide double isolation of each penetration."

The July 17 and December 19, 1984 definitions clearly state that double isolation of containment penetrations is required. GPUNC informed the staff in their October 31, 1984 letter that two of the containment isolation valve configurations used at THI-2 do not satisfy the July 17, 1984

. criteria. Also, they do not satisfy the December 19, 1984 modification of containment integrity criteria. Since guidelines for containment integrity had to be' maintained in the PTS and the fact that the staff was still

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considering what actions would be taken as a result of the October 31, 1984 submittal, the NRC chose not to delay the December 19, 1984 Amendment of Order and therefore did not address the subject penetrations in that issuance. Subsequently, it has been recognized by the staff that as the pre-accident technical specifications originally stated, a number of the containment penetrations do not need double valve isolation. Therefore, we

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are again indicating in the PTS that the valve configurations on these penetrations are acceptable. One configuration consists of a check valve located inside containment in combination with either one locked closed

? isolation valve or one automatic isolation valve outside of containment.

The other configuration consists of a single valve outside of containment (seeattachedTables1and2). All of the affected systems and their con-figurations were in place prior to the flarch 28, 1979 accident. The staff has previously reviewed these configurations and issued a September 1976 Safety Evaluation (NUREG-0107) which stated as follows:

"We have reviewed the containment isolation system and we conclude that it conforms with the requirements

[ intent] of General Design Criteria 54, 55, 56 and 57 and Regulatory Guide 1.11, " Instrument Lines Penetrating Primary Reactor Containments," and therefore is accept-able."

The above conclusion was based on an operating reactor which has reactor coolant temperatures of approximately 600 F and an operating pressure of approximately 2150 psig. This temperature and pressure can provide a greater driving force for airborne and liquid radionuclides when com-pared to THI-2's current maximum indicated RCS temperature of 96 F and atmospheric pressure of 0 psig.

_4 Therefore, since the staff has previously accepted these configurations for operating conditions more severe than those now existing, the same config-urations are acceptable for all plant conditions bounded by the staff's previous analysis.

Accordingly, based on TMI's current and anticipated RCS condition, the -

staff has decided to add a table to the Proposed Technical Specifications, listing the subject penetrations as exceptions to the "two isolation valve" criteria. The presently existing Limiting Conditions for Operation and Surveillance Requirements adequately address actions to be taken if the single isolation valve should fail. Similar wording was contained in the TMI-2 pre-accident technical specifications. This change will acknowledge the NRC's continued concurrence in these exceptions.

ENVIRON!1 ENTAL CONSIDERATIONS This action involves changes in the installation or use of facility compo-nents located within the restricted area. The staff has determined that this action involves no significant increase in the amounts of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupation radiation exposure.

Therefore, this action meets the eligibility criteria for categorical exclusion set forth in 10 CFR Sec. 51.21(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of this action.

CONCLUSION The staff therefore concludes that; (1) The subject penetration valve configurations were previously concurred with by the NRC in NUREG-0107,

• (2) Many of the systems affected are not in use during the recovery period and are therefore depressurized, and (3) Those systems still in use are primarily used under emergency conditions and will not experience transients as extreme as those previously analyzed in NUREG-0107 for emergency or non-emergency use. Therefore, the addition of exceptions to the two valve isolation requirements of the PTS is warranted and will not adversely impact the health and safety of the public. -

We have also 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 the implementation of this change will not be inimical to the common defense and security or to the health and safety of the public.

, _ TABLE 1 - PENETRATIONS WHICH UTILIZE A CECK VALYE INSIDE CONTAIN4ENT As A CONTAINMENT ISOLATION VALVE Penetration Service System Descriotion R-537 Nitrogen and Fill to Core CF Plant Design uses a check valve inside Flooding Tank as a Containment Isolation Yalve. All annual isolation valves are located outside the Reactor Buf1 ding.

R-539 Leakage Cooling DC Plant design uses a check valve inside as a Containment Isolation Valve. An automatic isolation valve is located outside containment.

R-542 Pressurizer Auxiliary Spray DH Plant design uses a check valve inside as a Containment Isolation Yalve. A manual Isolation Valve is located outside containment.

R-544 Nitrogen and Fill to Core Flooding CF Plant design uses a check valve inside Tank as a Containment Isolation Valve.

There is also a check valve located outside contaimeent; however, a manual isolation valve outside the check valve is being verified closed.

R-557 Nuclear Services Closed Cooling NS Plant design uses a check valve inside Water to Reactor Coolant Pump 011 as a Containment Isolation Valve. An and Motor Coolers automatic isolation valve is located' outside containeent.

R-559 Intermediate Closed Cooling Water IC Plant design uses a check valve inside to Roller Nut Drive Cooling Coils contalmeent as a Containment Isolation Valve. An automatic isolation valve is located outside contaimeent.

R-563 Intennediate Closed Cooling System IC Plant design uses a check valve inside containment as a Containment Isolation Valve. An automatic isolation valve is located outside contairment.

R-566 Service Air SA Plant design uses a check valve inside containment as a Containment Isolation Valve. An automatic isolation valve is located outside contatement.

R-570/R-572 High Pressure Injection MU Plant design uses a check valve inside j containment as a Containment Isolation l valve. An automatic isolation valve l 1s located outside contaimeent.

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R-573/R-574 R: actor Coolant Paup Seal Water E Supply Each cf these pInetrations, by plant R-575/R-576 design, utiliz:s a stop check valve inside containment as a Containment Isolation Valve. Each penetration has either an automatic or manual isolation valve located outside contafrument.

A-577/A-579/R-584 Reactor Building Air Cooling RR Each of these penetrations, by plant R-587/R-580 Unit Cooling Water design, utilizes a check valve inside containment as a Contairement Isolation Valve. Penetrations R-577, R-579, R-584, and R-587 have a Containment Isolatton Check Valve, by plant design, outside the penetration followed by an automatic isolation valve. Penetration R-580 has two (2) check valves, in parallel, located outside containment each of which is bounded by an automatic isolation valve.

R-583/R-586 Reactor Building spry Inlet Line B5 Plant design uses a check valve inside containment as a Contairunent Isolation Valve. Either an automatic isolation valve or a manual isolation valve is

.- located outside containment.

R-589/R-590 Decay Heat Coolant Supply DH Plant design uses a check valve inside containment as a Containment Isolation Valve. An automatic isolation valve

.. is located outside contairunent.

Additionally, a test connection valve located between the check valve and the penetration is being verified.

• R-591/R-592 Higa Pressure Injection IRI Plant design uses a chefck valve inside

. contafrument as a containment Isolation Valve. An automatic isolation valve is located outside contairunent.

Codes: BS-- Reactor Building Spray CF-- Core Flooding DC-- Decay Heat Closed Cooling Water DH-- Decay Heat Removal EF-- Emergency Feedwater FW-- Feedwater IC-- Intermedtate Closed Cooling Water IRJ-- Makeup and Purification RR-- Reactor Building Emergency Cooling - River Water SA-- station service Air

• Verification of valve position is performed on a routine basis.

TA8LE 2 - PENETRATIONS WHICH HAVE SINGLE VALVE ISOLATION Penetrati on Service Systee Description R-545A/R-554C/ Building Pressure 85 Plant design uses a single manual R-571C isolation valve outside containment.

R-562C Sullding Spray Systes Pressure BS Plant design uses a single manual Systee isolation valve outside containment.

R-593/R-594 Sump Penetraton Sleeve and DH By plant design, a Centainment Drain Line Isolation Valve is not located inside i containment. A single automatic l isolation valve is located outside each penetration. l R-616/R-623/ Auxiliary Feedwater Lines EF By plant design, a Containment '

R-617/R-618 Feedwater Lines 'W Isolation Valve is not located inside I containment. A check valve is located outside each penetration followed by  ;

an automatic isolation valve. Test connection isolation valves located inside containment are being verf fled.*

. R-619/R-620/ Steam Lines MS By plant design, a Containment R-621/R-622 Isolation Valve is not located inside containment for each of these penetratiens. An automatic f solation valve is located outside containment.

Various test connection isolation valves, located on both sides of the penetrations are being verified.

• Additionally, there are relief valves located between the pedetration and

• the outboard isolation valve.

Codes: BS-- Reactor Building Spray CF-- Core Flooding DC-- Decay Heat Closed Cooling Water DH-- Decay Heat Removal EF-- Emergency Feedwater FW-- Feedwater l IC-- Intermediate Closed Cooling Water i IRI-- Nakeup and Purffication AR-- Reactor Building Emergency Cooling - River Water SA-- Station Service Air l

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• Verification of valve position is performed on a routine basis.

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Enclosure 3 1

FACILITY OPERATING LICENSE NO. DPR-73 DOCKET NO. 50-320 The following list of pages of the Appendix "A", Proposed Technical Specifications have been modified as a result of this Amendment of Order.

Therefore, you should replace your present pages with those enclosed.

1-2 3.6-4

.= 3.6-5

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i 1.0 DEFINITIONS CONTAINMENT INTEGRITY 1.7 CONTAINMENT INTEGRITY shall exist when:

a. All penetrations required to be closed during accident conditions, except those listed in Table 3.6.2, are either: '

1. Capable of being closed by valves on each side of the penetration or by double valve isolation outside of the reactor building per proce-dures approved pursuant to Specification 6.8.2. Isolation valves inside the reactor building shall be capable of remote operation from a control station outside of the reactor building, or; l 2. Closed by manual valves, blind flanges, or deactivated automatic -

l valves secured in their closed positions to provide double isolation of each penetration,

b. The Equipment Hatch is closed and sealed.

c. Each airlock is OPERABLE pursuant to Specification 3.6.1.3.

.- d. The sealing mechanism associated with each penetration (e.g., welds, bellows or 0-rings) is OPERABLE.

CHANNEL CALIBRATION 1.8 A CHANNEL CALIBRATION shall be the adjustment, as necessary, of the channel output such that it responds with necessary range and accuracy to

, known values of the parameter which the channel monitors. The CHANNEL

• CALIBRATION shall Oncompass the entire channel including the sensor and alarm and/or trip functions, and shall include the CHANNEL FUNCTIONAL TEST.

CHANNEL CALIBRATION may be performed by any series of sequential . overlapping or to'tal channel steps such that the entire channel is calibrated.

CHANNEL CHECK i

1.9 A CHANNEL CHECK shall be the qualitative assessment of channel behavior during operation by observation. This determination shall include, where '

l possible, comparison of the channel indication and/or status with other indica-

tions and/or status derived from independent instrument channels measuring the j same parameter.

THREE MILE ISLAND - UNIT 2 1-2 August 12, 1985

TABLE 3.6-2 PENETRATIONS WITHOUT DOUBLE ISOLATION Penetration Function System R-537* Reactor Coolant Pump MU R-574* Seal Water Supply

- R-575*

R-576*

R-577* Reactor Building Air RR R-579* Unit Cooling Water R-584*

R-587*

R-580*

R-583* Reactor Building Spray BS R-586* Inlet Line

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R-589* Decay Heat Coolant Supply -

DH R-590*

R-591* + High Pressure Injection MU R-592*

R-537* Nitrogen and Fill to Core CF

. Flooding Tank R-539* Leakage Cooling DC R-542* Pressurizer Auxiliary Spray DH R-544* Nitrogen and Fill to Core CF Flooding Tank l R-577* Nuclear Services Closed Cooling NS l

Water to Reactor Coolant Pump 011 and Motor Coolers l

R-559* Intermediate Closed Cooling IC Water to Roller Nut Drive Cooling Coils I

R-563* Intermediate Closed Cooling IC System R-566* Service Air SA R-570* High Pressure Injection MU R-572*

I THREE MILE ISLAND - UNIT 2 3.6-4 August 12, 1985

m Penetration Function System R-545A! Building Pressure BS R-554C#

R-571C#

R-562C# Building Spray System BS Pressure System R-593# Sump Penetration Sleeve DH R-594# and Drain Line R-616# Auxiliary Feedwater Lines EF R-623#

R-617# Feedwater Lines FW R-618#

R-619# Steam Lines MS

.- - R-620#

R-621#

R-622#

Codes: BS-- Reactor Building Spray CF-- Core Flooding DC-- Decay Heat Closed Cooling Water DH-- Decay Heat Removal EF-- Emergency Feedwater FW-- Feedwater IC-- Intermediate Closed Cooling Water

. MU-- Makeup and Purification l - RR-- Reactor Building Emergency Cooling - River Water L

SA-- Station Service Air MS-- Main Steam NS-- Nuclear Services Closed Cooling Water L

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• Penetrations which utilize a check valve inside containment as a

( containment isolation valve i

j # Penetrations which have single valve isolation l

i THREE MILE ISLAND - UNIT 2 3.6-5 August 12, 1985

@ m.s. esvaanneses easev ens str oc a : 1976-633412 d

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Enclosure 4 1 l' i, 3 UNITED STATES o,, NUCLEAR REGULATORY COMMISSION

'4, g WASHINGTON. D C. 20555

• • • • • July 8,1985 Docket No. 50-320 Docketing and Service Section Office of the Secretary of the Commission

SUBJECT:

Three Mile Island Huclear Station, Unit 2 Operating License No. DPR-73 Amendment of Order for Containment Isolation Valves y Two signed originals of the Federal Register Notice identified below are enclosed for your transmittal to the Office of the Federal Register for publication. Additional conformed copies ( /.f., ) of the Notice are enclosed for your use.

J. O Notice of Receipt of Application for Construction Permit (s) and Operating Ucense(s).

C O Notice of Receipt of Partial Application for Construction Permit (s) and Facility Ucense(s): Time for g Submission of Views on Antitrust Matters.

! O Notice of Availability of Applicant's Environmental Report.

O Notice of Proposed issuance of Amendment to Facility Operating Ucense.

E'- 0 Notice of Receipt of Application for Facility License (s); Notice of Availability of Applicant's Environmental Report; and Notice of Considerrtion of issuance of Facility Ucense(s) and Notice of Opportunity for Hearing.

7 1 O Notice of Availability of NRC Draft / Final Environmental Statement.

A O Notice of Umited Work Authorization.

I'- , O Notice of Availability of Safety Evaluation Report.

Br l O Notius of issuance of Construction Permit (s).

4 O Notice of issuance of Facility Operating Ucense(s) or Amendment (s).

Q Other: AmpAmagt gf gpfgp Office of Nuclear Reactor Regulation i

Enclosure:

l As Stated i

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Bernard J. Snyder, regram Dir.

Three Mile Island Program Ofc.

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