ML20006A860
| ML20006A860 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/22/1990 |
| From: | Roche M GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20006A859 | List: |
| References | |
| NUDOCS 9001300367 | |
| Download: ML20006A860 (7) | |
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UNITED STATES CF AMERICA 4.
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NUQ. EAR REGil.ATORY COMMISSION l
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DOCKET NO. 50-320 LICENSE NO DPR-73
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GPU NUQ. EAR 1
This is to certify that a copy of Technical Specification Change Reouest No. 65, Revision 1, to Operating License DPR-73 for Three Mile Island Nucletar Station Unit 2 has been filed with the U.S. Nuclear Regulatory Commission and served to the chief executives of 1) Londonderry Township, Dauphin County, Pennsylvania; 2) Dauphin County, Pennsylvania; and 3) the designated official i
of the Commonwealth of Pennsylvania by deposit in the United States mail, addressed as follows :
Mr. Jay H. Kopp, Chairman Ms. Sally Klein, Chairperson Board of Supervisors of Board of County Commissioners Londonderry Township of Dauphin County R. O. #1, Geyers Church Road Dauphin County Court House Middletown, PA 17057 Harrisburg, PA 17320 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection PA Dept. of Environmental Resources P.O. Box 2063 Harrisburg, PA' 17120 l
GPU NUQ. EAR By _
b Director, TMI-2 01-22-90 Date 9001300367 900122 PDR ADOCK 05000320 P
PDC x
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Three Mile Isl nd Nuclear Stati:n, Unit 2 (TMI-2)
Operating License DPR-73 J
Docket No. 50-320 i
E Technical Specification Change Reouest (TSCR) No. 65 - Revision 1 The licensee mouests that the attached changed pages (i.e., pages 6-7 and l
6-8) replace the existing pages in the TMI-2 Technical Specifications (Tech.
Specs.). Revisions to the justifications provided in TSCR No. 65 are indicated by change bars.
f Purpose of Change t
I The purpose of this change is to revise tre administrative reouirements associated with audits as defined under Section 6.5.3, " Audits." The change is reouired to reflect the current and changing configuration of the plant.
L This change mouest proposes to:
1.
Establish a correlation between applicable unit mode and audit l
performance f m ouency for the.various audits.
2.
Deletes the mouirenent to perform a security audit as it is no longer under the cognizance and control of TMI-2. Reauirtnents to audit this J
function are contained in the TMI-l Tech. Specs.
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3.
Following the completion of Mode 1 and contingent up a submission of a l
revisiun to the-"GPU Nuclear Corporation Emergency Plan for Three Mile Island and Oyster Creek Nuclear Stations" (i.e., Energency Plan), celete the reouimment to audit the Emergency Plan and implementing procedures.
Emergency msponse activities will be uncer the cognizance and control of
.TMI-1 personnel. The mouirenent to audit the activity is contained in the TMI-l Tech. Specs.
4 Modify the audit fmouency such that the Training and Corrective Action Audits need only be performed on a once per 24-month basis, similar to the audit NQuired to demonstrate compliance to 10 CFR Part 50, Appendix B.
The following sections pIovide the description of each change, the reason for the change, and the safety evaluation justifying the change.
Description of Change Item 1 The phrase "During Modes 1, 2, and 3" has been added to the beginning of the following sections:
Section 6.5.3.1.a - Unit Operations Section 6.5.3.1.d - Appenoix B, 10 T R 50 t
Section 6.5.3.1.g - Radiation Protection Plan
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l Section 6.5.3.1.h - Fire Protection
'Ser: tion 6.5.3.1.1 - Fire Protection Section 6.5.3.1 j - Fire Pre'ection l-Section 6.5.3.1.k - Managemen.*, Reouested*
Item 2 g
The following section has been celeted:
Section 6.5.3.1.f - Security Plan Item 3 The phrase "During Mode 1" has been added to the beginning of the following section:
Section 6.5.3.1.e - Emergency Plan Item 4 The audit frecuency for the following sections has been extended to at least once per 24-months during Modes 1, 2, and 3:
Section 6.5.3.1.b - Training and Qualification Section 6.5.3.1.c - Cornetive Action Reason for Change l
Item 1
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The change makes the fomat of this section consistent with the fomat of the i
other sections affected by the TSCR.- It affims that audits of the specified l
activities will continue to be perfomed at the existing frecuencies.
Item 2 The deletion of audit reouirements for Security Plan activities is an l
l administrative change to reflect the transfer of implementing responsibilities in those areas from TMI-2 to TMI-1. Audits of the activities ~are reouired by' the TMI-1 Tech. Specs., and the audits will include a review.of TMI-2 facilities and personnel to the extent necessary to assure those responsibilities are being met.
Item 3 The completion of Mode 1 will result in a significant reduction of activities related to unit eculpment, structures, systems, and methods of operation that affect nuclear safety.
A revision to the Emergency Plan will be submitted to g
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- Section 6.5.3.1.k also contains changes proposeo in TSCR No. 60, which is j
pending NRC approval, i
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-c the NRC te fermalze the transition Gf.the responsibility f6r emergency 5
fesponse to TMI-1. This Emergency Plan revision, as well as the overall i
Mduction in personnel, activities, and credible accident scenarios, warrants deletion of a separate TMI-2 Emergency Plan Audit following Mode 1.
The e
Emergency Plan will continue to be audited pursuant to the TMI-l Tech. Specs.
Item 4-y Based on the' completion of defueling and the consecuent red?. tion in activity t
L at TMI-2, extending the audit frecuency to at least once per M nonths for the
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Corrective Action and the Training and Qualification audits is apptopriate.
Justification for Change p
Item 1
.This is an administrative change to make the format of these sections 3
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- consistent with the rest of the TSCR. These audits will continue to be L
. perfomed at the indicated frecuency during Modes 1, 2, and 3.
l Item 2 Security Plan Revision 26 to the Security Plan, approved by TMI-l License Amendment No. 45 and TMI-2 License Amendment No. 31, provides for a common site security force covering both TMI-l and TMI-2. Audits of the Security Plan and implementing i
procedures are reouired by Section 6.5.3.1.f of the TMI-1 Tech. ' Specs and will provide continued audit coverage of security and safeguards related L
activities occurring in TMI-2. Therefore, the deletion of this audit from the i
n TMI-2 Tech. Specs, will have no adverse effect on the adeouacy of audit coverage.
Item 3 Emergency Plan j
Currently, GPU Nuclear is processing a revision to the Emergency Plan which will shift most responsibilities for handling TMI-2 emergencies..to TMI-l personnel.. Specifically, the safety evaluation for this planned revision is predicated on an analysis which cemonstrates that following the completion of Mode 1 there is no TMI-2 emergency which can result in either a Site Area or Ceneral Emergency. Thus, the need for a full-time THI-2 Emergency organization will no longer exist. TMI-l Tech. Specs. Section 6.5.3.1.e reouires audits of the Emergency Plan and implementing procedures, which will continue to orovide audit coverage of any remaining proposed role for TMI-2 in Emergency Planning.
Item 4
~A.
Training and Qualification The scope of this audit covers the training and Qualification program associated with Operations and Maintenance personnel and also reviews changes to the TMI-2 organization. With the defueling program
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i cssentially compl te, the remaining signific nt activiti':s involve the
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' completion of fuel shipping and decont:mination and the Ovaporction of y
accident-generated water, which have been cetemined not to pose any public health and safety concerns.
The limited scope of these activities 00 not warrant an annual audit of the training and oualification of the personnel involved. Therefore, extending the audit frecuency to at least once per 24-months is appropriate.
B.
Corrective Action e
With the defueling effort essentially complete, both the safety
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significance and the probability of occ'Jrrerce for potential deficiencies and non-conformances is substantially reduced. Therefore, extending the audit fIwouency to at least once per 24-months is consistent with plant conditions.
No Sjgnificant Hazards Consideration 10 CFR 50.92 provides the criteria which the Commission uses to evaluate a No Significant Hazartis Consioeration. 10 CFR 50.92 states that an amendment to a facility license involves No Significant Hazards if operation of the facility in accordance with the proposed amenoment would not:
i 1.
Involve a significant increase in the probability or consecuences of an accident previously evaluated, or 2.
Create the possibility of a new or different kind of accident from any accident previously evaluated, or 3.
Involve e significant reduction in a margin of safety.
The above criteria are addressed below:
Does the above change involve a significant increase in the probability or consecuences of an accident previously evaluated?
The proposed changes are primarily administrative in nature to be consistent I
with the transition of TMI-2 as the cleanup program progresses (i.e., Modes 1, 2, and 3). The proposal celetes the reouirements for audit of the Security Plan.
This activity is now performed on a site basis and is reovired to be audited by the TMI-l Tech. Specs. With the defueling program essentially complete, the TIeQuency for perfoming the Training and Qualification, end the Corrective Action audits can be extended because of the reduced scope 01' activities at TMI-2. Following the completion of Mode 1, THI-2 will be in a defueled, safe shutdown and subcritical condition. Licensed operators vill no longer be reouired to ensure the safe shutdown condition of TMI-2. The remainirg significant activities involve the completion of fuel shippi y and the evaporation of the accioent-generated water. The NRC has reviewed these activities and has detemined that they do not pose any public health and safety concerns. Additionally, following Mode 1, there will no longer exist a i
need for a full-time TMI-2 Emergency Organization.
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Thus, GPU Nuclear conclu0es that the proposed changes are coministrative in
- nature and do not involve a signific:nt incre:se in the probability or j
consecuences of an accioent previously evaluated.
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Does the enange create the possibility of a new or different kind of accident from any accident previously evaluated?
As described above, the proposed changes are primarily administrative in nature and do not affect any plant systems or components.
Thus, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
Does the change involve a significant reduction in a margin of safety?
The proposed change does not celete any audits. Rather, it either recognizes that these functions are being assumed by TMI-l and will be audited in compliance with TMI-l Tech. Specs, or it recognizes the reduced scope of activities at TMI-2 and extends the audit frecuency accordingly.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
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