ML20085A233

Comments on 830531 Fr Notice Re Amend Request to Change Tech Spec & Approval of Steam Generator Repair.Release of SERs on Amend Prior to Final Decision on Safety Hazards Consideration Requested

ML20085A233
Person / Time
Site:	Three Mile Island
Issue date:	06/30/1983
From:	Gerusky T PENNSYLVANIA, COMMONWEALTH OF
To:	NRC OFFICE OF THE SECRETARY (SECY)
References
AA61-2-076, AA61-2-76, NUDOCS 8307050185
Download: ML20085A233 (2)

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- , i w ,' - k E a COMMONNEALT11 OF PENNSVLVANzA E i.T.

"~ bkPARTMENT OF ENVfRDNMENTAL RESOURCES --

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- thrfisburg, Pennsylvania 17120 June 30, ,tg 1 1.

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' kcreta5f 6 Oo Comisslon d gD tha. NucismiiRegulatory Comission ga n. It t Washington,it 20555 -

g g;*;g,,a'9/p --i Attentishi- bocketing and oarvice nranch og" gj9 4 b6ht.lenciN 3

t b Cormenwealth of Pennsylvania appreciates the opportunity to $

6tminant bh the NRC Staff's preliminary finding of no significant safety  ;

Mtard on 11 fdquest for an amendnent to the license for Dil-1 submitted -

Yr GPU NdeleAi and as noticed in the Federal Register dated htiy 31, 1983.

ihe Federal Register notice identifies two separate items that =

heed to be decided by the NRC -- the pending technical specification change -

i itquest, and the appmval of the steam Renerator ("GTSG") repair. 'Ihe OTSG -g tepair and teuse appmval is a separate issue from the technical specification a change request and is obviously much nore complex. Because of the difference  ;

i ih inportanto and conplexity between the two issues, it is necessary to separate 3 the decision making process into two distinct steps, both of which would be --

i ,. subject to the State consultation process.

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As you aro aware, the NRC Staff is mquired to nnke a good faith j-i I. hafety effort to const11t with the Coninonwealth on its finding of no significant haitard. It is our opinion that the consultation process should 4 always include the opportunity to review the Staff's safety evaluation itport ("SER") and discuss the report or reports for the Licensee's

) broposed amendments. We therefom request that the safety evaluation T

' reports for these amendments be provided for our review prior to a final 4 decision on safety hazards consideration, to ensure that all of our concerns l have been fully identified and satisfied.' In addition, the results of any 9

-- prelindnary leakage tests which have been conducted should be presented and j byaltrded to provide additional assurances that the repairs have been satisfactory. Only if this opportunity for full review of the safety 1

6 valuations is offered can we be assured that the repaired OTSGs can be 3

e reused without posing a significant safety hazard and that a hearing on ig tepair and reuse of the UrSGs is not necessary.

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fy Cf t}W Comnission Jtrie 30,1983 l

• Bafety hatards Although without wecopies cannotof make a determination the SERs, the Comonwenith on the h absenc l' to thethe variotis NRC safetyfor theevaluations 013G repairthat andhave been submitted subsequent reuse. by GPU Nuc1a car Corporation We have also mquested ndditional irtformation frun GPU Nuclear to us, such ns additional details on all possible release paths on issues that am of m and j detecting increased OrSG tube leakago and operator srespon t

for l, Wehevaluation Pennsylvania mports should as ainclude necessary the opportunity step in a to r good await recelpt of these mports Emm the NRC before m ki a .

ng any conclusion on

, the existence of a safety har.ard in connection with the two i

l Sincerely, 1%Q LLQ.$<f Thomas M. Gerusky, Dimetor Bureau of Radiation Pmtoction l

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