TMI-09-037, Supplement: Technical Specification Change Request No. 86 Deletion of Sections 6.5, Review and Audit

Supplement: Technical Specification Change Request No. 86 Deletion of Sections 6.5, Review and Audit

ML090960226
Person / Time
Site:	Three Mile Island
Issue date:	03/16/2009
From:	Hagan J GPU Nuclear
To:	Document Control Desk, NRC/FSME
References
TMI-09-037
Download: ML090960226 (5)

Text

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GPU Nuclear, Inc.

ONPU Route 441 South Post Office Box 480 NUCLEAR. Middletown, PA 17057-0480 Tel 717-944-7621 10 CFR 50.90 March 16, 2009 TMI-09-037 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 2 (TMI-2)

Possession Only License No. DPR 73' NRC Docke No. 5Q2 1;

Subject:

,,- i_ ..Supplement: Techn1caI Specification Criange Request for TM Un 2:

Technical Specification Chan*ge, Re 8est (TSCR) No. 86 -

Deletion of Technical SpecifiCation SeCti0ns 6.5, Review-and-Audit:.. -

References:

1) Letter from U.SNRCoto Joseph J. Hagan, "Request for Additional Information

-* (RAI) on Technical Specification"'Cange Req.ustNo `86 for theThree.Mile

'Island Nuclear.Station, Unit 2," dated November'12, 2008-.,

2) Letter from Joseph J. Hagan to U. S. NRC, "Response to Request for Additional Information (RAI) on Technical Specification Change Request No. 86, "Deletion of Technical Specification 6.5, Review and Audit," dated December 10, 2008.

Our letter dated June 11,2008, as supplemented by letter dated September 15, 2008, forwarded the Technical Change Request No. 86 (TSCR 86) for Three Mile Island Nuclear Station (TMI), Unit 2. TSCR 86 requests deletion of Technical Specification 6.5, Review and Audit. In Reference!,,' NRC stated that TSCR 86was accepted for-review on July 11, 2008 and has.determined that additional information is-required to0coImplete the review., ,In;Reference 2, we provided a response'to the RAI'-:-

Subsequently, per teleconference on February' 23 2009, 9the'N RC0inIdicated'that the response

.provided in Reference did ;not fully6address several tems 'withrespect to their impact on the PDMS Quality Assurance'(QA) Plan. In order to -addre*ssýthis issue,w vwilirelocate verbatim the TMI-2 TS 6.5,-"Review and Audit,"'. requirements to the PDMS QA Plan within 60 days from the issuance of the approved amendmr-ent an.d prior.to implementation of the deletion of the TS 6.5 requirements from theTMI-2 T6echnidai sp-e1dific-tions.

TMI-09-037 Page 2 of 2 We have concluded that the supplemental proposed changes do require a change to the original no significant hazards consideration (NSHC) evaluation submitted in the June 11, 2008 TSCR. A revised NSHC evaluation is provided in the Attachment to this letter.

Pursuant to 10 CFR 50.91 (b)(1), a copy of this supplement is being provided to the designated official of the Commonwealth of Pennsylvania, Bureau of Radiation Protection, as well as the chief executives of the township and county in which the facility is located.

No new regulatory commitments are established by this submittal.

Please contact Adam Miller of TMI-1 Regulatory Assurance at (717) 948-8128 if you have any questions.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 16 day of March, 2009.

Respectfully, Pres' anUh uc'ear Oficer

Attachment:

evised No Significant Hazards Consideration Evaluation for Technical Specification Change Request No. 86 cc: USNRC Region I Administrator USNRC TMI-2 Senior Project Manager USNRC TMI-2 Inspector USNRC TMI-1 Senior Resident Inspector Director, Bureau of Radiation Protection-PA Department of Environmental Resources Chairman, Board of County Commissioners of Dauphin County Chairman, Board of Supervisors of Londonderry Township File No. 08020

Attachment Revised No Significant Hazards Consideration for Technical Specification Change Request No. 86

Attachment Revised No Significant Hazards Consideration for TSCR No. 86 Page 1 of 2 5.0 Regulatory Analysis 5.1 No Significant Hazard Consideration GPU Nuclear has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

No physical changes to the TMI-2 Facility, will occur as a result of this proposed amendment. The proposed changes will not alter the physical design or operational procedures associated with any plant structure, system, or component. As such, the change is administrative in nature and does not affect initiators of analyzed events or assumed mitigation of accidents.

The proposed changes include the relocation of several administrative requirements from the Technical Specifications (TS) to the Post Defueling Monitored Storage Quality Assurance Plan (PDMS QAP). The TS requirements involve Technical Review and Control and Audits. In accordance with the guidance provided in NRC Administrative Letter 95-06, "Relocation of Technical Specification Administrative Controls related to Quality Assurance," the proposed changes are an acceptable method for removing technical specification quality assurance requirements.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident. from any accident previously evaluated?

,Response: No.

The proposed changes are administrative in nature. The proposed changes do not alter the physical design, safety limits, or safety analysis assumptions associated with the operation of the plant. Accordingly, the changes do not introduce any new accident initiators, nor do they reduce or adversely affect the capabilities of any plant structure, system, or component to perform their safety function.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

Attachment Revised No Significant Hazards Consideration for TSCR No. 86 Page 2 of 2

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed changes to relocate TS 6.5 requirements to the PDMS QAP conform to NRC regulatory guidance regarding the content of plant Technical Specifications. The guidance is presented in Administrative Letter 95-06 and NUREG-1430. The relocation of these administrative requirements to the PDMS QAP will not reduce the quality assurance commitments as accepted by the NRC, nor reduce administrative controls essential to the safe operation of the plant. Future changes to these administrative requirements will be performed in accordance with NRC regulation 10 CFR 50.54(a), consistent with the guidance identified above. Accordingly, the replacement of TS requirements by existing proposed TMI-2 PDMS QAP requirements results in an equivalent level of regulatory control.

Therefore, the proposed changes do not involve a significant reduction in a margin of safety.

Based on the above, GPU Nuclear concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.