ML20135C520
| ML20135C520 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/02/1996 |
| From: | James Knubel GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20135C523 | List: |
| References | |
| 6710-96-2354, NUDOCS 9612060332 | |
| Download: ML20135C520 (6) | |
Text
l l
GPU Nuclear,Inc.
(
Route 441 South NUCLEAR Post Office Box 480 Middletown, PA 17057-0480 i
Tel 717-944 7621 6710-96-2354 December 02, 1996 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555
Dear Sir:
Sub,iect:
Three Mile Island Nuclear Station, Unit 2, (TMI-1)
Operating License No. DPR-73 Docket No. 50-320 Technical Specification Change Request (TSCR) No. 75 In accordance with 10 CFR 50.4(b)(1), enclosed is Technical Specification Change Request No. 75.
Also enclosed is the Certificate of Service for this request cenitying service to the chief executives of the township and county in which the facility is located, as well as the designated official of the Commonwealth of Pennsylvania, Bureau of Radiation Protection.
The purpose of this TSCR is to request the relocation of audit frequency requirements from the j
TMI-2 Technical Specifications to the PDMS QA Plan. In addition, the maximum interval between certain types of audits _will be extended. The schedule can then be coordinated with that of TMl-1 which has had a similar request approved by the NRC. The activities to be audited and the scope ofindividual audits will not change. The revision to the PDMS QA Plan is being pursued concurrently.
Sincerely, 9612060332 961202 J. Knubel PDR ADOCK 05000320 Vice President and Director, TMI i
P PR I
Enclosures
(
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DPK/ pip
c:
Administrator Region I TMI Senior Resident Inspecter TMI-l Senior Project Manager
l METROPOLITAN EDISON COMPANY j
JERSEY CENTRAL POWER & LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY
)
THREE MILE ISLAND NUCLEAR STATION, UNIT 1 l
Operating License No. DPP.-73 4
l Docket No. 50-320 Technical Specification Change Request No. 75 l
l This Technical Specification Change Request is submitted in support of Licensee's request to i
l change Appendix A to Operating License No. DPR-73 for Three Mile Island Nuclear Station, Unit l
- 2. As a part of this request, proposed replacement pages for Appendix A are also included.
t GPU NUCLEAR INC.
i BY:
l e President and Director, TMI i
F Sworn d Subscribed to before me thi
_ day ofImde,1996.
[
Notary Pu I
NotarialSeal Londonderry Te,.. Dauphin CountySuzanne C. Miktocik. Notary i
i Member, Pennsylvansa Associa00n of Notanes
0 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 1
IN THE MATTER OF DOCKET NO. 50-320 GPU NUCLEAR INC.
LICENSE NO. DPR-73 CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No. 75 to Appendix A of the Operating License for Three Mile Island Nuclear Station Unit 2, has, on the date given below, been filed with executives of Londonderry Township, Dauphin County, Pennsylvania; Dauphin County, Pennsylvania; and the Pennsylvania Department of Environmental Resources, Bureau of Radiation Protection, by deposit in the United States mail, addressed as follows:
Mr. Darryl LeHew, Chairman Mr. Russell L. Sheaffer, Chairman Board of Supervisors of Board of County Commissioners Londonderry Township of Dauphin County R. D. #1, Geyers Church Road Dauphin County Courthouse Middletown, PA 17057 Harrisburg, PA 17120 Director, Bureau of Radiation Protection PA Dept. of Environmental Resources Rachael Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Att: Mr.- Stan Maingi GPU NUCLEAR INC.
BY:
Vic resident and Director, TMI DATE:
h
/$
I.
TECHNICAL SPECIFICATION CHANGE REQUEST (TSCR) NO. 75 GPU Nuclear requests the following changed replacement pages be inserted into the existing Technical Specifications (TS):
Replace existing pages 6-5 and 6-6 with the attached revised pages 6-5 and 6-6.
]
II.
REASON FOR CHANGE l
Section 6.5.3. of the Technical Specifications contains the audit program requirements.
1 Areas to be audited and audit frequencies are specified. Because these requirements are in the TS, there is little flexibility to adjust the audit program to make the audits more
]
meaningful. During PDMS only portions of the ventilation, electrical and fire detection systems are operational which results in few or zero day-to-day activities within QA Plan scope. Since the plant is in a non-operating and defueled status, there are no structures, systems or components that perform a safety function. Furthermore, the current audit program requirements can consume resources for auditing areas without problems which would be better used in monitoring and assessing weak areas or areas of declining performance before they become weak areas.
The proposed change deletes the audit program frequency requirements from the TS and relocates them to the PDMS QA Plan. In addition, the maximum interval for some audit frequencies are being increased. The change to the PDMS QA Plan is being pursued concurrently.
III.
SAFETY EVALUATION JUSTIFYING CHANGE The proposed change concerns audit frequency requirements. A fixed, inflexible schedule of audit requirements is being replaced with a more flexible scheduling mechanism. The areas to be audited and the scope of the audits performed are unaffected by this change.
In lieu of a prescriptive, unchangeable schedule, audits will be conducted within relatively flexible parameters based on the performance of the subject area. In this way, resources can be focused on weak areas and areas of declining performance. Areas with consistently high performance can be audited less frequently while still within the parameters. The schedule can be coordinated with that of TMI-1 which has had a similar request approved by the NRC. In this manner, the overall quality of the program will be enhanced.
The maximum interval between audits for two of the subject areas have been extended to twenty-four (24) months. Audit schedules shall be reviewed and revised, as necessary, to ensure appropriate audit coverage is maintained in accordance with section 18.2 of the PDMS QA Plan. There are several activities for which audit frequencies are mandated by regulation. For those activities, GPU Nuclear will continue to meet the specified schedule unless a specific exemption is sought and granted.
1 1
The PDMS QA Plan is part of GPU Nuclear's Safety Analysis Report (SAR) and subject to the provisions of 10 CFR 50.54 (a). A formal review of the proposed changes was made considering the requirements of 10 CFR 50.54 (a), the status of TMI-2 and the requirements of 10 CFR 50 Appendix B. That review concluded that the changes are consistent with the guidance of Appendix B, and do not result in a reduction in commitment contained in the PDMS QA Plan or the SAR. The revisions to the PDMS QA Plan will be submitted to the NRC in accordance with the provisions of 10 CFR 50.54 (a).
IV.
NO SIGNIFICANT HAZARDS CONSIDERATION GPU Nuclear has determined that this TSCR poses no significant hazard as defined by the NRC in 10 CFR 50.92.
1.
These changes do not affect the function of any system or component. Therefore, they do not increase the probability of occurrence or consequences of an accident previously evaluated in the SAR.
2.
These changes do not involve a physical change to plant configuration and they do not affect the performance of any equipment. Therefore, they do not create the possibility of an accident or malfunction of a different type than previously identified.
3.
The shifting of audit frequency requirements from the Technical Specifications to the PDMS QA Plan and the extension of the maximum interval between audits of certain areas do not change the activities to be audited nor the scope ofindividual audits. Furthermore, audit frequencies are not associated with the margin of safety in the bases of any Technical Specification. Therefore, the margin of safety is not affected by this change.
V.
IMPLEMENTATION It is requested that the amendment authorizing this change be effective 30 days after issuance to allow changes in procedure to be made.