ML20134L936

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Exemption from GDC 34 Re Removal of Residual Heat & GDC 37 Re Testing of Eccs,Per Util 850326 Request.Environ Assessment & Notice of Finding of No Significant Environ Impact Encl
ML20134L936
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 08/28/1985
From: Harold Denton
Office of Nuclear Reactor Regulation
To:
GENERAL PUBLIC UTILITIES CORP.
Shared Package
ML20134L916 List:
References
OLA, NUDOCS 8509030475
Download: ML20134L936 (9)


Text

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UNITED STATES NUCLEAR REGULATORY COMMISSI,0N In the Matter of )

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GENERAL PUBLIC UTILITIES NUCLEAR ) Docket No. 50-320 CORPORATION )

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(Three Mile Island Nuclear Station )

Unit 2) )

EXEMPTIONS I.

GPU Nuclear Corporation, Metropolitan Edison Company, Jersey Central Power and Light Company and Pennsylvania Electric Company (collectively, the licensee) are the holders of Facility Operating License No. DPR-73, which has authorized operation of the Three Mile Island Nuclear Station, Unit 2 (TMI-2) at power levels up to 2772 megawatts thermal. The facility, which l

is located in Londonderry Township, Dauphin County, Pennsylvania, is a pressurized water reactor previously used for the commercial generation of electricity.

By Order for Modification of License, dated July 20, 1979, the licensee's t

authority to operate the facility was suspended and the licensee's i

authority was limited to maintenance of the facility in the present shutdown cooling mode (44 Fed. Reg. 45271). By further Order of the

! Director, Office of Nuclear Reactor Regulation, dated February 11, 1980, a new set of formal license requirements was imposed to reflect the post-accident condition of the facility and to assure the continued maintenance of the current safe, stable, long-term cooling condition of the facility (45 Fed. Reg.11292). This license provides, among other things, that it is subject to all rules, regulations and Orders of the Commission now or hereaf ter in effect. -

8509030475 850828 -

1 ADOCK 05000320 PDR C PDR -

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II.

On November 6,1984, General Public Utilities Nuclear Corporation (GPUNC) submitted Technical Specification Change Request No. 46. This corres-pondence contained a request to delete the Decay Heat Removal System from the Ti11-2 Proposed Technical Specifications. The staff responded to this and other change requests with a list of questions forwarded on February 6, 1985. The licensee was asked to consider whether exemptions from 10 CFR 50, Appendix A, General Design Criteria (GDC) 34, 35, 36 and 37 were

appropriate. GPUNC respcnded in correspondence dated March 27, 1985 which stated that exemptions from GDC 35 and 36 were not required. However, an exemption request from GDC 34 and 37 was requested by GPUNC in a letter dated March 26, 1985. The staff is issuing the requested exemptions as discussed herein. .

III.

10 CFR 50, Appendix A, GDC 34 requires that a system to recove residual heat shall be provided. The purpose shall be to transfer fission product decay heat and other residual heat from the core at such a rate that acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded.

Since January 1981, the TMI-2 core has been cooled passively via the loss-to-ambient mode. At present the decay heat level is less than 12 Kw thermal with an associated maximum core temperature of less than 100*F.

The maximum temperature that is credible while in this mode (no forced circulation) is less than 170*F assuming water level is lowered to the e ,r.-- -.,--., ,- .,----_,,,._-,,....-n.- ---.,--,,y.,

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botton of the hot leg nozzles. At this temperature sufficient buffer is still maintained between the maximum anticipated core temperature and the temperature at which the water in the vessel would boil (212*F). There-fore, the staff concludes that since the current loss-to-ambient mode is effective for all anticipated core temperatures, the requirement to have a residual heat removal system (GDC 34) is no longer necessary at TMI-2. On the other hand, portions of the residual heat removal system at TMI-2 still contain radioactive contamination resulting from the accident. Operation of the system could result in the spread of radioactive contamination. In addition, the requirement to maintain an operable residual heat removal system would result in an unnecessary burden for maintenance, surveillance and testing and could result in unnecessary radiation exposures to the workers. Accordingly, an exemption f.or GDC 34 is warranted.

The licensee has proposed in Technical Specification Change Request No. 46 that a Reactor Building Sump Recirculation System (RBSRS) be used for l

emergency core cooling at TMI-2. The system would only be installed in the event of an unisolable leak in the RCS. Licensee calculations, which are I supported by the staff in an Amendment of Order concurrently issued with l

this exemption, conclude that at least 10 days are available between the i detection of the worst-case credible leak and when the RBSRS would be i required. This gives ample time for the system to be put in service. As stated in the referenced Amendment of Order, the staff has accepted the RBSRS and its proposed method of use. This acceptance included Recovery Operations Plan requirements for testing the operability of major system

a components on a regular basis (see the staff's Safety Evaluation Report dpproving the modifications to the Proposed Technical Specifications related to Borated Cooling Water Injection). GDC 37 requires the testing of the emergency core cooling syst m including the operability of the system as a whole and the performance of the full operational sequence.

Since the staff has accepted the installation of the RBSRS in the reactor building only in the event of an unisolable leak in the RCS, the testing of the system according to GDC 37 is not necessary. In addition, since the reactor building basement still contains accident generated contaminated water, testing of a basement sump recirculation system in a' full operational sequence could result in the spread of contamination and radiation exposures to the workers. Accordingly, an exemption from GDC 37 is warranted.

IV.

Accordingly, the Commission has determined that, pursuant to 10 CFR 50.12, an exemption is authorized by law and will not endanger life or property or ,

the common defense and security and is otherwise in the public interest.

The Commission hereby grants exemptions frem the requirements of 10 CFR 50, App'endix A General Design Criteria 34 and 37 in accordance with the licensee's request dated March 26, 1985.

It is further determined that the exemptions do not authorize a change in effluent types or total amounts nor an increase in power level and will not result in any significant environmental inpact. In light of this deter-mination and as reflected in the Environmental Assessment and Notice of

Finding of No Significant Environmental Impact prepared pursuant tb 10 CFR 51.2 and 51.30 through 51.32, issued concurrently herewith, it was con-cluded that the instant action is insignificant from the standpoint of environmental impact and an environmental impact statement need not be prepared.

FOR THE NUCLEAR REGULATORY COMl11SSION l k Harold R. Denton, Director Office of Nuclear Reactor Regulation

.- Effective Date: September 23, 1985

' Dated at Bethesda, Maryland Issuance Date: August 8, 1985 ,

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UNITED STATES NUCLEAR REGULATORY COMMISSION GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION DOCKET NO. 50-320 ENVIRONMENTAL ASSESS!!ENT AND NOTICE OF FINDING OF NO SIGNIFICANT ENVIRONMENTAL IliPACT The U. S. Nuclear Regulatory Commission (the Commission) is planning to issue concurrently with an Amendment of the Director of the Office of Nuclear Reactor Regulation's Order an Exemption relative to Facility Operating License No. DPR-73, issued to General Public Utilities Nuclear Corporation (the licensee), for operation of the Three Mile Islano Nuclear Station, Unit 2 (TMI-2), located in Londonderry Township, Dauphin County,

, Pennsylvania.

ENVIRONMENTAL ASSESSMENT Identification of Proposed Action: The action being considered by the Commission is the issuance of exemptions from the requirements of 10 CFR 50, Appendix A, General Design Criteria (GDC) 34 and 37. These criteria state requirements for residual heat removal system capabilities and for testing emergency core cooling systems, respectively. On November 6,1984, the licensee submitted Technical Specification Change Request No. 46. This correspondence contains a request to delete the Decay Heat Removal System from the Tl11-2 Proposed Technical Specifications (PTS). Review of the PTS by staff resulted in a list of questions forwarded to the licensee on February 6,1985. In response to those questions, the licensee considered that exemptions to GDC 34 and 37 were appropriate. These exemptions were requested in the licensee's letter dated !! arch 26, 1985. .

D

e The Need for the Action: The exemptions are warranted because of the successful use of the loss-to-ambient cooling mode at Tt11-2 for residual heat removal. This is a passive method for removing decay heat and there-fore it is very stable. The licensee also proposed in Technical Specification Change Request 46 to have available a Reactor Building Sump Recirculation System (RBSRS) to be used in the case of an unisolable leak.

When considering the current status of the TMI-2 core and the amount of time that would be available to install the RBSRS, an in-place, routinely tested emergency core cooling is not necessary. The licensee has proposed to test the major system components separately tc ensure that if they are needed, they will function properly. In-place testing is not desirable because of the risk of spread of radioactive contamination and because of radiation exposures to the workers.

Environmental Impacts of the Proposed Actions: The staff has evaluated the subject exemptions and concluded that they will not result in significant increases in airborne or liquid radioactivity inside the reactor building or in corresponding releases to the environment. There are also no non-radiological impacts to the environment as a result of this action.

Alternative to this Action: Since we have concluded that there is no sig-nificant environmental impact associated with the subject exemptions, any alternatives to this change will have either no significant environmental impact or greater environmental impact. This would not reduce significant O

e environmental impacts of plant operations and would result in the appli-cation of overly restrictive regulatory requirements when considering the unique conditions of TMI-2.

Agencies and Persons Consulted: The NRC staff reviewed the licensee's request and did not consult other agencies or persons.

Alternate Use of Resources: This action does not involve the use of

. resources not previously considered in connection with the Final Program-matic Impact Statement for Till-2 dated March 1981.

I Finding of No Significant Impact:

The Comission has detemined not to prepare an environmental impact statement for the subject exemptions.

Based upon the foregoing environmental assessment, we conclude that this action will not have a significant effect on the quality of the human environment.

For further details with respect to this action see; (1) Letter to B. J.

Snyder, USNRC, from F. R. Standerfer, GPUNC, Technical Specifications Change Request No. 46, dated November 6,1984,(2) Letter to F. R. Standerfer, GPUNC, from B. J. Snyder, USNRC, NRC Questions on Technical Specifications Change Request No. 46, dated February 6,1985, (3) Letter to B. J. Snyder, USNRC, from F. R. Standerfer, GPUNC, Technical SpecificationsChangeRequestNo.46(responsetoNRCquestions), dated March 27,1985,and(4)LettertoB.J.Snyder,UStiRC,from ,

F. R. Standerfer, GPUNC, General Design Criteria 34 and 37, dated March 26, 1985.

r' The above documents are available for inspection at the Comission's Public local Document Room, 1717 H Street, N.W., Washington, DC, and at the Commission's Local Public Document Room at the State Library of Pennsylvania, Government Publicati'ons Section, Education Building, Comon-wealth and Walnut Streets, Harrisburg, Pennsylvania 17126.

FOR THE NUCLEAR REGULATORY COMMISSION

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Bernard J. Snyde , ogram irector Three Mile Isla d Program Office Office of Nuclear Reactor Regulation f

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