ML20062E326

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Responds to NRC & Contends That Tech Spec Change Request 77 Clearly Simplifies Facility Tech Specs.No Further Review by NRC of Ring Girder Insp Program Required
ML20062E326
Person / Time
Site: Crane Constellation icon.png
Issue date: 12/01/1978
From: Herbein J
METROPOLITAN EDISON CO.
To: Miller W
NRC OFFICE OF ADMINISTRATION (ADM)
References
NUDOCS 7812060161
Download: ML20062E326 (2)


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METROPOLITAN EDISON COMPANY cm.e emm %: m m:m.y,

POST OFFICE box 542 READING. PENNSYLVANI A 19603 TELEPHONE 215 - 929-3601 g

GQL 1779 RECEIVED pY LFMB Mr. William O. Miller, Chief

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License Fee Management Branch 2

Office of Administration

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U. S. Nuclear Regulatory Co==ission j

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Washingten, D. C.

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Dear Sir:

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Three Mile Island Nuclear tation, Unit 1 (DE-1)

Cperating Lice se No. D.-50 Docket N 50-289 Technical Specification ge Request #77 Your letter of October 11, 1978 stated that Technical Specification Change $

Request No. 77 is not being considered for the convenience of the Co==ission, nor is it to simplify or clarify the TE-1 Technical Specifications, and therefore, you are requesting Class II amendment fees.

TMI-1 Technical Specification h.h.2.2 Ring Girder Inspection Program entails O ten pages of text, tables and figures. The inspection progra= as described, was ce=pleted during the 1977 Refueling Outage with sub=ission of the report '

following on August 26, 1977 The specification provides a provision for~

the re=aining schedule of inspections, if deemed necessary, to be determined based upon previous results of the ring girder inspection. NRC letter of Dece=ber 29, 1977 stated that as a result of NRC's review, NRC concluded that the surveillance tests were performed in accordance with applicable require-

=ents and that the safety =argins in the structure, at that time, were adequate.

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The NRC further concluded that there was reasonable assurance'that the con-tain=ent structure vould continue to perform its intended function. URC also evaluated the need for further inspections, and based on their evaluation, NRC concluded that the inspectior, program could consist of a visual inspec-tion of the ring girder performed at the same frequency and in conjunction with the Inservice Tendon Surveillance Program as described in TIE-1 Technical Specification h.h.2.1 and Regulatory Position C.3 of Regulatory Guide 1.35.

Revision 2.

Technical Specification Change Request No. 77 modifies the current specification k.h.2.2 to require only a visual inspection perfor=ed in conjunction with the Inservice Tendon Surveillance Program in accordance with NRC guidance for the

=cdified program, as requested by the Cc==ission. The modified specification deleted nine of the ten pages of the current specification. In addition, the Ring Girder Inspection Program reporting requirement in Specification 6.9.3 has also been deleted. It is Met-Fa's contention that the =odified specifica-s,M.

I tion clearly s1=plifies the TMI-1 Technical Specifications.

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William O. Miller December 1, 1978 GQL 1779 With regard to being issued for the convenience of the Commission, it is believed that considerable effort on the Commission's behalf is expended reviewing the results of the various inspection programs. Met-Ed has sub-mitted the results of four (k) Ring Girder Inspections in accordance with the Technical Specification requirement. The NRC has reviewed each of these submittals and as mentioned above, the NRC has concluded that the inspee-tion program,as currently described, can be modified. Therefore, upon NRC approval of Technical Specification Change Request No. 77, no further NRC review of the Ring Girder Inspection Progra=,as currently described, vill be necessary.

Based on the above discussion, Metropolitan Edison Company requests a rereview of your determination, and therefore, no remittance is forwarded at this time.

Sincerely,

/

J. G. Herbein Vice President-Generation JGH:RJS:cjg ec: Director of Nuclear Reactor Regulation Attn:

R. W. Reid, Chief Operating Reactors Branch No. k U. S. Nuclear Regulatory Commission Washington, D. C.

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