ML20150D267
| ML20150D267 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 03/17/1988 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20150D265 | List: |
| References | |
| NUDOCS 8803230272 | |
| Download: ML20150D267 (6) | |
Text
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METROPOLITAN EDIS0N COMPANY JERSEY CENTRAL POWER & LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION, UNIT 1 Operating License No. DPR-S0 Docket No. 50-289 l
Technical Specification Change Request No.178
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This Technical Specification Change Request is submitted in support of Licensee's request to change Appendix A to Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1.
As a part of this request, proposed replacement pages for Appendix A are also included.
GPU NUCLEAR CORPORATION BY:
@ /. N o % u.
Vice Presidpt & Director, TMI-l Sworn and Subscribed to before me this
- E day of VJ/,n
,1988.
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'n Notary Public UNDA L tlTTER,20fAff PU8 tlc INDOLETOWN 80400GH. DAUPNiN COUM NY COMMIS$f0N EXPlRfS FEB. 26.1996 Beniber. Pennsylvania AssociaWor, M kn <9:
8303230272 880317 PDR ADOCK 05000289 P
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4, UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF DOCKET NO. 50-289 GPU NUCLEAR CORPORATION LICENSE NO. DPR-50 CERTIFICATE OF SERVICE This is to certify that a copy of Technical Specification Change Request No.178 to Appendix A of the Operating License for Three Mile Island Nuclear Station Unit 1, 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. Kenneth E. Witmer, Chairman Ms. Sally S. Klein, Chairman Board of Supervisors of Board of County Commissioners Londonderry Township of Dauphin County 25 Roslyn Road Dauphin County Courthouse Elizabethtown, PA 17022 Harrisburg, PA 17120 Mr. Thomas Gerusky, Director PA. Dept, of Environmental Resources Bureau of Radiation Protection P.O. Box 2063 Harrisburg, PA 17120 GPU NUCLEAR CORPORATION BY:
/n. #e /M u Vice Presignt & Director, TMI-l DATE:
3 - t 7. FJ
t THREE MILE ISLAND UNIT 1 OPERATING LICENSE NO. DPR-50 DOCKET NO. 50-289 TECHNICAL SPECIFICATION CHANGE REQUEST NO. 178 1.
Sections to be changed a.
Section 3.20 b.
Section 6 - 6. 2.1, 6. 2.2, 6.3. 2, 6.4, 6. 5.1, 6. 5. 2.1, 6. 5. 3.2, 6.5.4, Figure 6-1 and Figure 6-2.
2.
Extent of Changes a.
Section 3.20 - this section is deleted, b.
Section 6.2.1 - deleted reference to Figure 6-1 and added 6.2.1.1 to 6.2.1.3.
c.
Section 6.2.2 - deleted reference to Figure 6-2 and reformatted adding 6.2.2.1 and 6.2.2.3.
d.
Section 6.3.2 - deleted title for Radiological Controls Director, Section 6.4.1 - deleted reference as to who will direct training of e.
unit staff and Radiological Controls.
Also revised reference for training of licensed operators to 10 CFR Part 55.
f.
Section 6.4.2 - deleted reference as to who directs Fire Brigade
- Training, g.
Section 6.5.1 - deleted reference to Figure 6-1.
h.
Page 6-4 retyped due to spacing of sections.
No changes made.
1.
Section 6.5.2.1 - deleted reference to Figure 6-1.
j.
Section 6.5.3.2 - deleted title of Vice President - Technical Functions.
k.
Section 6.5.4 - deleted titles and added a clarifying statement of size of 10SRG staff.
1.
Figure 6 deleted, m.
Figure 6 deleted.
3.
Changes Requested Replace pages 111, viii, 3-95a, 6-1, 6-3, 6-4 and 6-5 with pages attached.
Add page 6-la; and delete pages 3-95b, 3-95c, Figure 6-1, and Figure 6-2..
X;j.:
H 4.
Reason for Change a.
Section 3.20 is being: deleted as it is no longer a'pplicable. The i
Applicability section states:
"This Technical Specification is cancelled following the completion of this test."
This test was for Cycle 5 Restart which was completed in 1985.
Therefore there-is no longer a need.to keep this section in the Technical Specifications.
b.
The proposed change deletes the organization charts and most position titles from the Technical Specifications (TS).
10 CFR 50.36 (c)(5) requires Administrative Controls necessary to assure operation of the facil.ity in a aafe manner to.be included in the Technical Specifications. However this-does not specifically i
require the inclusion of organization charts in the Technical.
Specifications.
Chapter 12 of the TMI-1 Updated FSAR contains detailed organization structure and a description of the conduct of operations. This information is required by 10 CFR 50.34.
In addition 10 CFR 50.71 requires this Updated FSAR to be maintained and updated annually.
Over the past years, there have been several TMI-l Technical Specification Change Requests (TSCR) that have addressed organization changes. These TSCRs did not delete any organization structure but rather rearranged various positions / groups / divisions.
Deletion of the organization charts and position titles from the Technical Specifications will eliminate the need of GPUN and the NRC to expend time processing these changes.
It has been the experience that organization charts by themselves have little use in assessing safety significance of changes to the plant and license. The NRC Senior Resident Inspector will be advised of significant organization changes as they occur.
This submittal is similar in content to the Shearon Harris Nuclear Power Plant, Docket 50-400/ License No. NPF-63, Technical Specification Change Request submitted June 12,1987..This request was approved by the NRC as Amendment No. 3 to the Shearon Harris i
Technical Soecification on January 27, 1988.
Along with deleting the organization charts, other changes in this TSCR include the references to the deleted figures, references to what departments are responsible for training of the unit staff and the fire brigade and revised reference to 10 CFR Part 55 for operator training. The requirements for the training programs will remain in the Technical Specifications while the responsibility for conducting the training is and will be contained in the Updated FSAR.
c.
A clarifying statement was added for the number of 10SRG staff.
At times there will be unanticipated vacancies within the 10SRG staff.
This clarifying statement will permit management to adequately recruit for the vacancy without having the burden of obtaining a temporary replacement.
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5.
Safety Evaluation Justifying Change The deletion of the organization charts and position titles from the Technical Specifications and removing reference to what department is responsible for training of the unit staff and the fire brigade does not have an adverse effect on safety. Although these items no longer will be detailed in the Technical Specifications, the details are included in the Updated FSAR.
The requirements as to what the unit staff training and fire brigade training programs must meet will still be in the Technical Specifications. Therefore these changes will not adversely effect safe operation of TMI-1.
The reference to 10 CFR Part 55 was revised to agree with the revised rule effective May 1987.
The temporary vacancy in the 10SRG will not significantly affect the review function for IOSRG.
In the event that specific issue is identified, additional temporary support is available within the company to address the issue.
6.
Significant Hazards Consideration This proposed change is similar to example (i) of the "Amendments Not Likely to Involve Significant Hazards Consideration" from the Federal Register Vol. 48, No. 67 at 14870 on April 6,1983.
This change is considered an administrative change.
This Technical Specification Change Request does not involve significant hazards consideration as stated below.
(1) Involve a significant increase in the probability or consequences of an accident previously evaluated.
The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated because deletion of the organization charts and position titles from the Technical Specifications does not affect plant operation. As in the past, the NRC will continue to be informed of organizational changes through other required controls.
In accordance with 10 CFR 50.34 (b)(6)(1) the applicant's organizational structure is 1
required to be included in the Updated Final Safety Analysis i
Report. Chapter 12 of the Updated Final Safety Analysis Report provides a description of the organization and detailed organization charts. As required by 10 CFR 50.71 (e) GPUN submits annual updates to the Updated FSAR. Appendix B to 10 CFR Part 50 and 10 CFR 50.54 (a)(3) govern changes to organization described in the Quality Assurance Program. Some of these organizational changes require prior NRC approval. Also, it is GPUN's practice to inform the NRC of organizational changes affecting the nuclear facilities prior to implementation.
The requirements for training are also contained in the Updated FSAR and the same controls apply, i
i (2) Create the possibility of a new or different kind of accident from any accident previously evaluated.
The proposed amendment does not create the possibility of a new or different kind of accident than previously evaluated because the proposed change is administrative in nature, and no physical alterations of plant configuration or changes to setpoints or operating parameters are proposed.
(3) Involve a significant reduction in a margin of safety.
The proposed amendment does not involve a significant reduction in a l
margin of safety because GPUN, through its Quality Assurance programs, its commitment to maintain only qualified personnel in positions of responsibility, and other required controls, assures that safety functions will be performed at a high level of competence.
Therefore, removal of the organization chart from the Technical Specifications will not affect the margin of safety.
7.
Implementation i
It is requested that the amendment authorizing this change become effective upon issuance.
1 8.
Amendment Fee (10CFR170.21)
Pursuant to the provisions of CFR170.21, a check for $150.00 is included with this request.
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