ML20006C731
| ML20006C731 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 01/26/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20006C729 | List: |
| References | |
| NUDOCS 9002090069 | |
| Download: ML20006C731 (4) | |
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I SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PELATED TO AMENDMENT NO. 36 TO FACILITY OPERATING LICENSE N0. DPR-73 GPU NUCLEAR CORPORATION t
THREE MILE ISLAND NUCLEAR STATION, UNIT NO. 2 DOCKET NO. 50-320 INTRODUCTION By letter dated August 15, 1988, GPU Nuclear Corporation (GPUN or the licensee) requested the approval of a change to the Appendix A Technical Specifications of Facility Operating License No. DPR-73 for Three Mile Island Nuclear Station, Unit No. 2.
The proposed amendment would revise the specifications related to staffing requirements for the THI-2 Safety Review Group (SRG). The changes also revise the current definition of review significant items and resolve a conflict with the existing regulatory requirements related to the submission of reports to the NRC.
DISCUSSION AND EVALUATION In Section 1 of the Appendix A Technical Specifications the licensee proposes a change in the definition of " Review Significant." The definition defines ine part, review of significant items as those system operating procedures and essoci-ated emergency, abnormal, alarm response procedures which require NRC approval.
License Amendment No. 30, dated May 27, 1988 deleted the requirement for NRC prior approval of procedures except those specified by Section 3.1.13. The licensee proposes to change a portion of the definition to state specifically the procedures which still require NRC approval Therefore the definition would specify that the only procedures that would require NRC approval would be those associated with Section 3.1.13.
The staf f finds the propsed change acceptable.
Section 6.5 defines the licensee's review and audit requirements for THI-2.
The licensee proposes to reduce the minimum staffing requirement of the TMI-2 Safety Review Group (SRG), after completion of defueling and elimination of the possibility of a criticality accident and transition to Mode 2. The current Technical Specification, Section 6.5.4.2, requires a Manager, SRG and a minimum staff of five engineers. Af ter transition to Mode 2 the licensee proposes to reduce the SRG staff to a Manager, SRG and a minimum staff of three engineers.
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- l The licensee further proposed in their August 15, 1988 submittal that after all canisters containirg fuel have been shipped offsite the SRC would be eliminated.
In its place the licensee for Independent Safety Reviewers (ISPs) proposes to substitute a new requirement Subsequent to the literste's submittal the staff discussed the requirement to mair.tain an independent safety review organization that is truly independent of the functional organization responsible for the document or change. The licensee has agreed to retain the SRG until such time that the Unit 1 Independent Onsite Safety Review Group (10$RG) will assume oversight of TMI-2.
Therefore at some time af ter the licensee enters idoce 2 the independent safety review function at TMI-2 will be assumed by the THI-1 10SRG. Transition from i
the SRG to the 10SRG will be deGeminea by the licensee, with written notification to the NPC staff. The 10SRG staff will be specified in the TMI 1 Technical Specificatiers (Licenst No. OPR-50). An additional position will be specified in support of THI-2 activities. The 10SRG will report to the director respensible for nuclear safety essessa nt and will function for both TMI-1 and TM1-2.
The periodic review function of the 10SPG will result in independent safety reviews similar to that required of the SRG. The principal difference is that under the 10SPC the review function can te performed after the fact, i
Oualific6tions for 10SRC members are similar to those of the SRG although less experience is required.
The responsibilities and qualification requirements for the 10SRG will be the same for TMI-1 and 1M1-2.
Once the licersee transitions to the 10SPG the licensee will have an additional r5quirement for ISPs. The ISRs would perform the independent review of the subiects listed in Specification 6.5.2.5, for those actions which could effect the safety of the facility. This review would be performed prior to implementation of the activity. The qualifications for the ISRs are identical to those for the current SRG members. The ISRs will be required to review cocuments and changes thereto that are currently required to be reviewed by the SRG. The review by ISRs will be documented by medns cf plant procedures and will include a review of the technical aspects of the proposed as well as a review of any associated safety eyeluation attached to the document under review.
TheISRcannotbetheDocumentOriginator,ResponsibleTechnicalPeviewer(RTR)
Implementing Approver or an individual having direct responsitsility for performance ISR may be from the same functional organization as the preparer and RTR. The ISRs will be assigned on a departmental basis.
Ultimately when THI-? ccmes under the direction cf TMI-1 ISRs will be shared between both units.
Initially there will be approximately 12 ISPs appointed when TMI-2 eliminates the SRG and implements the 10SRC.
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following the completion of defueling and the elimination of the possibility of an inadvertent criticality, ficantly affecting the ability of the SRG to perform the reduction in the minimum SRG staffing would be implemented without signi its-required functions. The reduction is appropriate based en the reduced scope of the cleanup activities and the overall increase in the margin of safety after the end of defueling.
The licensee's planned transition from the SRG to the 10SRG and the use of ISRs subsequent to the mode change would not result in a decrease in the margin of safety at THI-2. The potential for a radiological release exceeding the guidelines of 10 CFR 50 Appendix I would be essentially eliminated once the licensee completes defueling. The potential for any event requiring immediate notification as required by 10 CFR 50.72 or an event which is reportable pursuant to 10 CFR 50.33, both of which currently require SRG review, would be unli kely. Furthermore, most plant systems and components will be isolated and not operating. Activities planned after the completion of defueling would be limited to readying the facility for long term storages. The use of the 10SRG and ISRs is consistent with current practices at THI-1. Furthennore transition from the SRG to the 10SRG and ISRs is consistent with the licensee's )lans to consolidate trany of the activities at THI into site organizations. C3anges to procedures will continue to receive review and approval by RTRs.
e The staff finds that the proposed reduction in the staffing of the SRG after transition to Mode 2 and the subsequent transition to a ISORG with the concurrent establishnent of the ISRs acceptable.
The licensee, in their August 15,1988 letter, requested that in Section 1.14, the definition of " Review Significant", be further revised to be applicable only during Modes 1 and P.
The staff has discussed this request with the licensee and the licensee, in a telephone conference on October 19, 1989, agreed to withdraw this requestec change.
The licensee also proposed changes to a nuinber of other sections in Section 6.5, Review and Audit, to reflect the reduction in SRG staffing during Mode 2 and the subsequent transition to 10SRG and initiation of ISRs. The staff finds these proposed changes acceptable.
The licensee also proposes to change Section 6.9.1, Routine Reports and Reportable Occurrences, and 6.9.2 Special Reports. Both specifications require that reports be submitted to the NRC Region I Administrator unless otherwise noted. The licensee proposes to change both sections and specify that reports be submitted in accordance with 10 CFR 50.4 Specific requirements for the submission of reports are contained in 10 CFR 50.4 The proposed change is administrative in nature and removes any conflict with existing regulatory requirements and the technical specifications. The staff finds the proposed change acceptable.
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ENVIRONMENTAL CONSIDERATION The amer.dment changes the reperting and administrative requirements of the I
licensee's review and audit procedures. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10).
Pursuantto10CFR51.22(b),noenvironmentalimpactstatementorenvironmental assessment need be prepared in conncction with the issuance of this amendment.
CONCLUSION, Wehaveconcluded,basedontheconsiderationsdiscussedabove,that(1)there is reasonable assurance that the health and safety of the public will not be endangered by operatien in the proposed renner, and (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of this amendment will not be inimical to the corrnon defense and security or to the health and safety of the public.
j Principal Contributor: Michael T. Masnik Dated: January 26, 1990 i