ML20091M186

Suppl to Tech Spec Change Request 116,Rev 1 to License DPR-50 Re safety-related Reasons for Which Containment Purging Permitted

ML20091M186
Person / Time
Site:	Three Mile Island
Issue date:	06/05/1984
From:	Hukill H GENERAL PUBLIC UTILITIES CORP.
To:	Stolz J Office of Nuclear Reactor Regulation
Shared Package
ML20091M196	List: ML20091M186 ML20091M201
References
5211-84-2130, NUDOCS 8406110127
Download: ML20091M186 (2)

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p GPU Nuclear Corporation NggIgf Post Office Box 480 Route 441 South Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Number:

June 5, 1984 5211-84-2130 Office of Nuclear Reactor Regulations Attn: John F. Stolz, Chief Operating Reactors Branch No. 4 U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr. Stolz:

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

Operating License No. DPR-50 Dod<et No. 50-289 Stpplement to Technical Specification Change Request No.116, Rev.1 The attached Technical Specification should replace specifications 3.6.9 and 3.6.10 as submitted in Technical Specification Change request 116, Rev. 1, November 24, 1983, (TSCR 116).

The proposed change to Technical Specification 3.6.9 lists safety related reasons for which containment purging is permitted. A sample of past RWP's for containment entry shows that approximately 65% of entries _were for safety related non-routine corrective maintenance, the majority of which were I & C related (i.e.: level and flow transmitters). It is the goal of management to minimize repetitive safety related maintenance as acknowledged in the TMI-l Restart Hearings. Emergency surveillance entries will be necessary to

. identify the nature of, and to support, any safety related corrective maintenance.

Technical Specification required routine surveillances and engineering support entries shall be scheduled to coincide as practical, in order to reduce instances of containment purging. As a goal toward minimizing purge time it is expected that routine surveillance will require approximately 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br /> per

o. a- month of containment purging. This includes approximately 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of

$Q 40 pre-entry purge time per entry. Additionally, in response to IE Bulletin 80-24 GPU has established a procedure for weekly containment entry in order to 48 perform a. visual sump surveillance. This will add three entries per month as my well as prolonging Tech Spec. surveillance entries. Radiation surveys is necessary for RWP and ALARA considerations should add no more than an Ed additional four hours purge time for each containment entry. It is our goal

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. to minimize the numoer of planned outages _to no more than twice per year with pre-shutdown purging not to exceed 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> duration. 4g ma.L . GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation k t 9 P ,

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. 5211-84-2130 June 5 , 1984

, Mr. John F. Stolz

. The.need for purging is based on ALARA considerations which take into account overall . airborne isotope and noble gas concentration, job specific exposure rate, length of job and RWP restrictions. With the purge valves limited to approximately 300 open the accompanying reduction in flow necessitates longer

- purge time. Ou* ~ estimated goal of containment purge time to accomplish the activities.necessary for the safe operation and maintenance of the plant, as outlined in proposed Tech Spec 3.6.9, is approximately 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> per month.

This proposed specification outlines prudent safety related reasons for containment purging and is far more conservative than that proposed in TSCR 116 Rev. I which would have allowed unlimited, undefined purging. This change has no adverse impact on the previous safety evaluation for TSCR 116 Rev.1.

In addition, Technical Specification 4.4.1.2.5.d and 4.4.1.6.1 should be revised to telete.the phrases "when purging is permitted (TS 3.6)" and "once per retbeling or...if reactor building purging is permitted per TS 3.6" respectively,(see attached). This will make specification 4.4.1.6.1 consistent with 10 CFR 50 Appendix J and does not change the spec as currently stated in the TMI-l Technical Specifications. These phrases were added in TSCR 116 Rev. I with the assumption of continuous purging restricted only by purge valve inoperability. Containment purging will now be permitted for safety related reasons only, as outlined in the attached specification 3.6.9.

Removal of these phrases makes the specifications effective at all times which is a more conservative approach.

Sincerely,

. D.

Director, TMI FDH/ RAS /mle Enclosure cc: J. Van Vliet H.- Silver T. Gerusky

. J.-E. Minnich' J. H. Kopp s

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