ML20197H163

Application for Amend to License DPR-50,consisting of Change Request 138,revising Tech Specs Re Reporting Requirements Reflecting Rule Changes to 10CFR50.72 & 50.73. Fee Paid

ML20197H163
Person / Time
Site:	Three Mile Island
Issue date:	05/12/1986
From:	Hukill H GENERAL PUBLIC UTILITIES CORP.
To:	Stolz J Office of Nuclear Reactor Regulation
Shared Package
ML20197H168	List: ML20197H163 ML20197H171
References
5211-86-2079, GL-83-43, GL-86-43, NUDOCS 8605190077
Download: ML20197H163 (8)

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i GPU Nuclear Corporation Nuclear  ;;;omegr8os Middletown, Pennsylvania 17057-0191  ;

717 944 7621 TELEX 84 2386 j Me s Dkect Dial Nu@en l May 12, 1986 5211-86-2079 Office of Nuclear Reactor Regulation Attn: John F. Stolz, Director PWR Projects Directorate No. 6 U. S. Nuclear Regulatory Commission Washington, DC 20555

Dear Mr. Stolz:

Three Mile Island Nuclear Station, Unit I, (TMI-1)

Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No.138 Enclosed are three originals and forty conformed copies of Technical Specification Change Request No.138.

Also enclosed is one signed copy of the Certificate of Service for this request to the chief executives of the township and county in which the facility is located, as well as the Bureau of Radiation Protection.

Pursuant to 10 CFR 50.91(a)(1), we enclose our analyses, using the standards in 10 CFR 50.92 of significant hazards considerations. As stated above, pursuant to 10 CFR 50.91(a) of the regulations, we have provided a copy of this letter, the proposed change in Technical Specifications, and our analyses of significant hazards considerations to Thomas Gerusky, the designated representative of the Commonwealth of Pennsylvania.

Pursuant to the provisions of 10 CFR 170.21, enclosed is a check for $150.00 as payment of the fee associated with Technical Specification Change Request No. 138.

Sincerely, 8605190077 860512 PDR ADOCK 05000289 P PDR . D. H fil Director, TMI-l HDH/MRK/spb p,

Enclosures:

1) Technical Specification Change Request No.138 i

2) Certificate of Service for Technical Specification Change Request No.138 f

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3) Check No. 221951 LO g cc: J. Thoma I

$PD uclear Corporation is a subsidiary of the General Public Utilities Corporation m - -

t METROPOLITAN EDISON COMPANY JERSEY CENTRAL POWER & LIGHT COMPANY AND PENNSYLVANIA ELECTRIC COMPANY THREE MILE ISLAND NUCLEAR STATION, UNIT 1 1

Operating License No. DPR-50 Docket No. 50-289 Technical Specification Change Request No.138 l

l 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 i

BY

'Diredtor, TMI-l Sworn and Subscribed to before me this /# L day of 7)/a,/ , 1986.

Al6Y b kotish

/ Notary Public SEAIG!i P. EIG1. l0!A77 i' ;UO UlDDLETOWN BORD. DAUFillid COUNTY MY COMMI5510N EXPIRCS JUNE 12,1939 Member, Pennsylvania Association of Notaries

i UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF DOCKET NO. 50-289 LICENSE NO. DPR-50 GPU NUCLEAR CORPORATION This is to certify that a copy of Technical Specification Change Request No.138 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. Jay H. Kopp, Chairman Mr. Frederick S. Rice, 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 Mr. Thomas Gerusky, Director PA. Dept. of Environmental Resources Bureau of Radiation Protection P.O. Box 2063 Harrisburg, PA 17120 GPU NUCLEAR CORPORATION BY

['irecfot, TMI-l DATE: May 12, 1986

g. s' I. TECHNICAL SPECIFICATION CHANGE REQUEST (TSCR) NO. 138 l The licensee requests that the following page changes be made to the existing Technical Specifications using the attached revised pages:

a. Replace the following pages:

i 3-107 4-35 6-10 111 3-108 4-35a 6-11 iv 3-109 4-36 6-13 v 3-112 4-37 6-17 3-12 3-113 4-81 6-18 1 3-46 3-114 4-83 6-19 3-88 3-118 4-85 6-20 3-95 3-119 6-4 6-21

b. Remove the following pages which have been deleted:

4-38 6-14 6-15 6-16

c. Add the following pages which are new:

1-7a 3-112a 3-119a Hote: This TSCR requests changes to some of the same pages that are affected by other proposed amendments which have been submitted or will be submitted in the near future. Since each TSCR is submitted as a proposed change to the approved TS and TSCRs do not overlap, extra effort may be necessary to ensure that amendments do not inadvertently cancel previously approved changes.

II. REASON FOR CHANGE This TSCR is intended to revise reporting requirements to be consistent with rule changes to 10 CFR 50.72 and 50.73 as requested by Generic Letter (G.L.) 83-43 and also to incorporate other administrative changes affecting those same pages. Due to the volume of the changes involved, this task has been divided into more than one submittal.

NRC Generic Letter (G.L.) 63-43 dated December 19, 1983 requested licensees to amend their technical specifications to reflect changes in reporting requirements of 10 CFR Part 50, Section 50.72 and 50.73. A model technical specification was enclosed showing revisions to be made in the " Administrative Control" and " Definitions" sections of the technical specifications. The letter further requested that other conforming changes to technical specifications be made in order to reflect the revised reporting requirements. This TSCR provides the majority of the changes to THI-1 Technical Specifications requested by Generic Letter 83-43. To complete GPUN's response to G.L. 83-43, an additional TSCR will follow separately, i

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In addition to changes required in order to reflect the reporting I requirements of 10 CFR Part 50, Sections 72 and 73, the following administrative changes are being requested as follows:

a. Deletion of reports that are no longer needed by NRC.

b. Clarification of T.S. Section 6.10.2 by inserting the words

".. . unless otherwise specified in 6.10.1 above."

c. Deletion of Specification 6.10.2.n concerning equipment qualification record retention.

d. Designation of the appropriate individual responsible for maintaining administrative control of keys to locked barricades specified in 6.12.1.b by changing " Radiological Controls Foreman on duty" to "the respective Radiological Controls Supervisor."

e. Deletion of the reference to Regulatory Guide (R.G.) 10.1 in Specification 6.9.1.C.

f. Clarification of Specification 6.8.3 to specify more clearly the approval process for temporary changes to the procedures of 6.8.1.

g. Deletion of the redundant listing of special reports in Specification 6.9.3.

h. Correction of format, grammar, misspellings, and other clerical errors; and additions or changes to improve clarity of the technical specifications or to incorporate revisions to the Standard Technical Spectfications.

III. SAFETY EVALUATION JUSTIFYING CHANGE This change is administrative in nature and serves to clarify the existing technical specifications in order to reflect the new reporting requirements of 10 CFR 50.72 and 10 CFR 50.73. These regulatory requirements supercede the existing technical specifications.

Therefore, these changes constitute neither a change in reportability nor content of the reports.

Administrative changes in addition to those in response to G.L. 83-43 are evaluated as follows:

a. Deletion of the requirements for submittal of certain reports or information no longer required by NRC.

Submittal of these reports is no longer needed by NRC as evidenced by the fact that the requirements for such reports has been deleted from Standard Technical Specifications (NUREG 0472, Revision 3, Draft 7). Such information will continue to be available at the

. site for review by NRC on request.

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b. Clarification of T.S. Section 6.10.2 by inserting the words

... unless otherwise specified in 6.10.1 above."

This is to distinguish between the records which are to be retained for the duration of the operating license and those which are required to be retained for at least five years. This change is not intended to modify the requirements for record retention, but to eliminate any confusion which might result from any apparent overlap between 6.10.1 and 6.10.2.

c. Deletion of Specification 6.10.2.n concerning the retention of equipment qualification records, as these requirements are adequately addressed by regulation in 10 CFR 50.49.

The section to be deleted references T.S. 6.15 which was deleted by Amendment No. 102. It was an oversight that T.S. 6.10.2.n was not requested to be deleted at that time.

d. Designation of the appropriate individual responsible for maintaining administrative control of keys to locked barricades specified in 6.12.1.b.

As a result of a recent shif t of responsibilities, the Radiological Controls Foreman on duty no longer maintains key control for the outside facilities. Currently he maintains administrative control over keys to such barricades within the radiological instrument shop and other outside facilities through the respective Radiological Controls Supervisor only because it is required by the old T.S. wording. His administrative controi over keys to outside facilities serves no safety related function under the current

, division of responsibilities. This change places the responsibility for maintaining administrative control of keys to locked barricades under the respective Radiological Controls l

Supervisor who is able to maintain more effective key control over these areas, and more clearly reflects organizational responsibili ties,

e. Deletion of the reference to R.G.10.1 from Specification G.9.1.C.

This reference is being deleted since the NRC has requested a different distribution of the Monthly Operating Reports from that specified in R.G.10.1. Reference to R.G.10.1 should be deleted from Section 6.9.1.C if it is no longer appropriate,

f. Clarification of Specification 6.8.3 to specify more clearly the approval process for temporary changes to the procedures of 6.8.1.

This is to remove the ambiguity of the current wording. References given in 6.8.3.b and c to other sections are being changed to reference the appropriate section numbers. The section numbers referenced on 6.8.3.b and c may be the result of errors

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incorporated in Amendment 77. The intent of the reference in 6.8.3.b is to specify that members of GPUNC management staff authorized to approve temporary changes to the procedures of 6.8.1 be Responsible Technical Reviewers qualified in accordance with 6.5.1.14. The intent of the reference given in 6.8.3.c is to specify that the balance of the 6.5.1 approval process for temporary changes be completed within 14 days of implementation.

g. Deletion of the redundant listing of special reports in Specification 6.9.3.

This change is editorial in that none of the required reports which are currently listed in 6.9.3 are being deleted. With the exception of one report, each of the reports listed is required either by Regulation or other T.S. sections, or has been deleted by a previous amendment. The one exception is the report on the results of Radioactive Sealed Source Leakage in excess of the LCO specified by Section 3.10.1. In order to presene this requirement, which was committed to in GPUN's request that resulted in T.S. Amendment No. 64, it is requested that this be moved to Section 3.10.1.

A Special Report on the Inservice Inspection Program (currently listed as 6.9.3.A.4) was to have been a report giving the conclusions of a review at the end of 5 years of operation to consider incorporation of new inspection techniques and equipment and possible extension of the program to additional examination areas. The requirenent for this report was deleted as part of T.S.

Amendment 54 The listing in 6.9.3 should have been deleted at that time.

1 The list of Special Peports in T.S. Chapter 6 is not a complete  :

list of Special Reports. The list is redundant to the Regulations or to other T.S. sections. Separation of the requirements for Special Reports from the corresponding LC0 or Surveillance Specification is a potential source of confusion. Any changes to the Regulations or the T.S. LC0 or Surveillance section without a corresponding change to the Special Report section of Chapter 6 would make such a listing outdated. Therefore, the Special Report ,

section of Chapter 6 is merely an unnecessary source of confusion '

and should be deleted as an improvement to T.S clarity,

h. Correction of format, grammar, misspellings, and other errors from previous amendments and addition of language to improve clarity of the Technical Specifications.

l NUREG 0472, Revision 3 (Draf t 7) was used as a guide for improvement.

,. I IV. NO SIGNIFICANT HAZARDS CONSIDERATION GPU Nuclear Corporation has determined that this Technical Specification Change Request poses no significant hazards as defined by NRC regulations in 10 CFR 50.92. This ensures that operation of the facility in accordance with the proposed amendment would not:

1. involve a significant increase in the probability or consequences of an accident ~ previously evaluated (10 CFR 50.92(c)(1)) since the proposed amendment does not involve plant design or operational changes; or -

2. create the possibility of a new or different kind of accident from any accident previously evaluated (10 CFR 50.92(c)(2)) since the proposed amendment does not involve modifications to existing plant equipment; or

3. involve a significant reduction in a margin of safety since the proposed amendment does not involve changes to the conditions assumed in the accident analyses (10 CFR 50.92(c)(3)).

The Commission has provided guidelines pertaining to the application of the three standards by listing specific examples in 48 FR 14870. The proposed amendment is considered to be in the same category as the following examples of amendments that are considered not likely to involve significant hazards consideration:

(i) A purely administrative change to achieve consistency, correct errors, change nomenclature and improve clarity, and (vii) A change to make a license conform to changes in the regulations, where the license change results in very minor changes to facility operations clearly in keeping with the regulations.

The proposed amendment does not affect plant design or operation, does r.ot involve modification of plant equipment, does not involve changes to any plant release limits, and does not affect the plant's safety analysis. Therefore, the three standards of 10 CFR 50.92(c) are sa ti sfied.

In summary, GPU Nuclear Corporation has determined and submits that the proposed administrative changes described herein do not represent any significant hazards.

V. IMPLEMENTATION We request that the amendment approving this TSCR be made effective upon issuance.

VI. AMENDMENT CLASSIFICATION (10 CFR 170.22)

Portions of this change to the technical specifications are made at the request of the Commission. NRC Generic Letter 83-43 states that remittance of a license fee for these changes is not required. To cover those portions of this change request which are not specifically related to Generic Letter 83-43, pursuant to the provisions of 10 CFR 170.21, a check for $150.00 is enclosed.

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