ML20009E171

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Safety Evaluation Supporting Exemption from Requirements to Periodically Update TMI-2 FSAR to Reflect Changes Made During Cleanup
ML20009E171
Person / Time
Site: Crane Constellation icon.png
Issue date: 07/20/1981
From:
Office of Nuclear Reactor Regulation
To:
Shared Package
ML20009E169 List:
References
NUDOCS 8107270184
Download: ML20009E171 (5)


Text

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION METROPOLITAN EDIS0N COMPANY JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY DOCKET N0. 50-320 THREE MILE ISLAND NUCLEAR STATION, UNIT N0, 2 Introduction By ' letter dated May 6,1981 (reference 1), the Metropolitan Edison Company (licensee) requested an exemption from the requirements of 10 CFR Part 50.71(e) to periodically update the TMI-2 final safety analysis report (FSAR). The exemption would be for the duration of the TMI-2 cleanup.

In lieu of periodically updating the FSAR, the licensee has committed to submit a System Description (SD) and a Technical Evaluation Report (TER) for each major step of the cleanup.

Evaluation The purpose of the requirements contained in 10 CFR Part 50.71(e) is to provide an updated reference document to be used in recurring safety analyses.

As a result of the March 28, 1979, accident at TMI-2, p1w e operation is no longer possible with TMI-2 in its present status but rather cleanup operations not anticipated in the design of the TMI facility nor described and analyzed in the TMI-2 FSAR must now be performed. The facility modifications and accom-panying safety analyses for.the cleanup operations are unique to the cleanup operations and such facility modifications would probably have to be removed orior to restoring TMI-2 to operation if such a decision is made at some future j

date. Therefore, the liceasee !.as proposed that rather than modifying and up-dating the FSAR to describe and analyze the facility modifications a'ssociated with thew cleanup operations, SDs and TERs be prepared and submitted to the NRC for each major step of the cleanup.

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i The SDs and TERs will include system descriptions and safety evaluations of the planned cleanup actions and will therefore provide the necessary information d

to describe and assess the cleanup operations as well as providing a record of the facility modifications necessary to perform the cleanup. Since the SDs and TERs will provide the same type of information that would be added to an updated FSAR and since the SDs and TERs will provide this information for the entire cleanup operation, we have concluded that the SDs and TERs will be an accentable alternative to the requirements of 10 CFR Section 50.71(e) provided they are kept updated. To ensure that these documents are kept updated, we will require as a condition of granting this exemption that the licensee review them at least once per six months and make any necessary updating revisions.

This will require updates more frequently than the annual updates required by Section 50.71 (e)(4) for FSARs. This augmented requirement is necessary because of the rapid pace at which snme of the cleanup activities may be conducted.

Furthermore, if a subsequent decision is made to restore TMI-2 to operation, the FSAR will then require updating in accordance with the requirements of 10 CFR Part 50.71(e).

Any changes in the facility described in the SDs and TERs, changes in the procedures described in the SDs and TERs, and conduct of tests or experiments not l

described in the SDs and TERs shall be subject to the requirements of 10 CFR Section 50.59.

Public Interest Considerations l

Under 10 CFR Section 50.12(a), the Commission may grant exemptions from the requirements set forth in Part 50 if it determines that the exemptions are l

" authorized by law and will not endanger life or property or the. common defense i

j and security and are otherwise in the public interest". As analyzed above, lu

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e' the SDs and TERs are a more appropriate vehicle than the FSAR for achieving the updating requirement of Section 50.71(e) during the cleanup period.

It is concistent, therefore, with the pJrpose of Section 50.71(e) to allcw this requested exemption. See Statement of Consideration, " Periodic Updating of Final Safety Analysis Reports", 45 F.R. 30614, May 9, 1980.

The exemption is authorized by law since it is consistent with the purpose of'Section 50.71(e) and will not endanger life or property o-the comr..on defense and se<;urity since it does not relax any Commission requirement.

Significant Hazards Considerations The granting of this exemption does not entail any significant hazards considerations since it merely permits an alternative form for the filing of 1-required documentation with the Commission.

Tha time interval for update of this information will be more frequent than required under the Come.ission's regulation. 'he granting of the exemption does not involve any increase in the probability or consequences of accidents previously evaluated nor the creation of the possibility of a different type of accident,..ar does it reduce the margin of safety defined in the basis of any license requirements.

Conclusions Based on the foregoing, we have determined that, pursuant to Section 50.12 of 10 CFR Part 50, a specific exemotion for the duration of the cleanup operations as discussed above is authorized by law and can be grantad without endangering life or property or the commor, defense and security and is otherwise in the J

l public interest.

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k Furthermore, we_ have determined that:the granting 'of this exemption does not authorize a. change in effluent types or. total amounts nor an increase in power level and will not result in any-significant environmental impact. We 4

have concluded that this exemption would be insignifi: ant from the standpoint of' l

environmental impact and pursuant to Paragraph (d)(4) of Section 51.5 of 10 CFR '

Part 51 that an environmental impact ?tatement, or negative declarr' ion and f

environmental impact appraisal, need not be prepared in connection with this action.

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References 1.

Letter to 8. J. Snyder, NRC, from G. K. Hovey, Met Ed/SPU, dated May6,1981,(LLi-81-0114).

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