ML20202H677

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Documents Basis for NRC Staff Generic Approval of Requests to Relocate TS Requirements from Tss.Staff Generic SER Finding Relative to Relocated TS Requirements Encl
ML20202H677
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 02/03/1999
From: Colburn T
NRC (Affiliation Not Assigned)
To: Langenbach J
GENERAL PUBLIC UTILITIES CORP.
References
TAC-M96532, NUDOCS 9902080179
Download: ML20202H677 (5)


Text

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.g j NUCLEAR REGULATORY COMMISSION h MS T t WASHINGTON, D.C. 20066 0001

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Mr. James W. Langenbach, Vice President and Director-TMl GPU Nuclear, Inc.

P.O. Box 480

. Middletown, PA 17057

SUBJECT:

TECHNICAL SPECIFICATION CHANGE REQUEST (TSCR) NO. 257 DATED AUGUST 29,1996 (M96532)

Dear Mr. Langenbach:

Per the request of Mr. Jack Wetmore of your staff, we are providing you this letter documenting the basis for the NRC staff's generic approval of requests to relocate Technical

' Specification (TS) requirements from the TSs. Such a request is the subject of TSCR 257. In order for the staff to be able to make the requisite findings related to approving such a request, the TS requirements must be relocated to a document that is required to be controlled under the provisions of 10 CFR 50.59. Examples would be to relocate the former TS requirements to the Final Safety Analysis Report (FSAR), procedures manual or other docyments (i.e., some licensees have developed a Technical Requirements Manual) that are incorporated by reference in the FSAR. In discussions with your staff regarding the above acceptance criteria, your staff has proposed te relocate the TS requirements that are the subject of TSCR 257 to the FSAR by the end of Februany 1999. This would be acceptable as an alternative to relocating them to procedures not described in the FSAR as currently proposed by the TSCR 257 application.

We request that you document your staff's commitment to relocate the TS requirements of TSCR 257 to the FSAR and provide the staff with a copy of the FSAR changes when approvedin order for the NRC staff to verify that the reixated requirements are being properly relocated to the FSAR. As an altemative, the staff would be willing, at your request, to include a license condition in the issuing amendment to make the effectiveness of the amendment contingent upon your completion of the FSAR changes described above. We would expect that you might pursue the latter approach if you anticipated significant slippage in the FSAR change schedule, but still wanted the staff to cornplete its review of your request in the near future.

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.d J.Langenbach ' Enclosed for your information is a copy of the staffs generic Safety Evaluation Report (SER) finding relative to relocated TS requirements. If you have any questions or comments, please contact me at (301) 415-1402.

Sincerely,

/s/

Timothy G. Colbum, Senior Project Manager I Project Directorate 1-2 Division of Reactor Projects - t/Il Office of Nuclear Reactor Regulation .

l Docket No. 50-289

Enclosure:

Generic SER finding cc w/ encl: See next page l

DISTRIBUTION

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4 9 J.Langenbach 2-Enclosed for your information is a copy of the staff's generic Safety Evaluation Report (SER) finding relative to relocated TS requirements. If you have any questions or comments, please contact me at (301) 4151402.

Sincerely, b-Timothy G. Colbum, Senior Project Manager Project Directorate I-2 Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

Generic SER finding cc w/enci: See next page

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l J.Langenbach Three Mile Island Nuclear Station, Unit No.1 I cci Michael Ross

~ Director, O&M, TMI Robert B. Borsum GPU Nuclear, Inc. B&W Nuclear Technologies P.O. Box 480 Suite 525 Middletown, PA 17057 1700 Rockville Pike ,

Rockville, MD 20852  !

John C. Fomicola '

Director, Planning and William Domsife, Acting Director  !

Regulatory Affairs Bureau of Radiation Protection GPU Nuclear, Inc. Pennsylvania Department of

100 Interpace Parkway Environmental Resources Parsippany, NJ 07054 P.O. Box 2063 Harrisburg, PA 17120 l Jack S. Wetmore -

Manager, TMI Regulatory Affairs Dr. Judith Johnsrud GPU Nuclear, Inc. National Energy Committee P.O. Box 480 Sierra Club Middletown, PA 17057 433 Oriendo Avenue .

State College, PA 16803 Emest L. Blake, Jr., Esquire Shaw, Pittman, Potts & Trowbridge Peter W. Eselgroth, Region 1 2300 N Street, NW. U.S. Nuclear Regulatory Commission Washington,'DC 20037 475 Allendale Road King of Prussia, PA 19406 Chairman Board of County Commissioners of Dauphin County Dauphin County Courthouse Harrisburg, PA 17120 Chairman Board of Supervisors of Londonderry Township R.D. #1, Geyers Church Road Middletown, PA 17057 Wayne L Schmidt Senior Resident inspector (TMI-1)

U.S. Nuclear Regulatory Commission P.O. Box 219 Middletown, PA 17057 Regional Administrator Region i U.S. Nuclear Regulatory Commitsion 475 Allendale Road King of Prussia, PA 19406

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EXCERPT FROM NRC STAFF GENERIC SAFETY EVALUATION REPORT RELATING TO RELOCATED TECHNICAL SPECIFICATION REQUIREMENTS i

The Final Policy Statement for Technical Specifications improvements states that LCOs and associat'ed requirements that do not satisfy or fall within any of the four specified criteria (now contained in 10 CFR 50.36) may be relocated from existing TS (an NRC-controlled document) to appropriate licensee-controlled documents. These requirements include the Limiting Conditions for Operation (LCOs), Required Action Statements, and associated surveillance requirements (SRs). In its application, the licensee can propose relocating such specifications to the Final Safety Analysis Report (FSAR), which would include the TRM (Technical Requirements Manual) or LCS (Licensee Controlled Specifications) by reference. The staff has reviewed the licensee's submittals, and finds that relocation of these requirements to the FSAR (TRM/LCS) is acceptable, in that changes to these documents will be adequately controlled by 10 CFR 50.59. These provisions will continue to be implemented by appropriate plant procedures; i.e., operating procedures, maintenance procedures, surveillance and testing procedures, work control procedures, and change control procedures.

ENCLOSURE

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