ML20207G805
| ML20207G805 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/15/1988 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20207G801 | List: |
| References | |
| NUDOCS 8808240241 | |
| Download: ML20207G805 (10) | |
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ETROPOLITAN EDISON - COMPANY -
. JERSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY GPU NUCLEAR THREE MILE ISLAND NUCLEAR STATION UNIT II Operating License No. DPR-73 Docket No. 50-320 Technical Specification Change Request No. 60 This Technical Specification Change Request is submitted in support of Licensee's request to change Operating License No.-DPR-73 for Three Mile
-l Island Nuclear Station Unit 2.
As a part of this request, proposed
-l replacement pages for Appendix 8 are also included.
j GPU NUCLEAR 1
By Director, TMI-2
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION IN THE MATTER OF DOCKET NO. 50-320 LICENSE NO. DPR-73 GPU NUCLEAR This.is to certify that a copy of ' Technical Specification Change Request No. 60 to Operating License DPR-73 for Three Mile Island Nuclear Statioq Unit 2 has been filed with the U.S. Nuclear Regulatory Commission and served to the chief executives of 1) Londonderry Township, Dauphin County, Pennsylvania; 2) Dauphin County, Pennsylvania; and 3) the designated official of the Cannonwealth of Pennsylvania by deposit in the United States mail, addressed as follows:
Mr. Jay H. Kopp, Chairman Ms. Sally Klein, Chairperson Board of Supervisors of Board of County Commissioners Londonderry Township of Dauphin County R. D. #1, Geyers Church Road Dauphin County Court House Middletown, PA 17057 Harrisburg, PA 17120 Mr. Thomas M. Gerusky, Director Bureau of Radiation Protection PA Dept. of Environmental Resources P.O. Box 2063 Harrisburg, PA 17120 GPU NUCLEAR f
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By.
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Director, TMI-2 jr
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l Th'ree Mile ~ Island Nuclear Station, Unit 2 (TMI-2)
Operating License DPR-73 Docket No. 50-320 I
l Technical Specification Change Request (TSCR) No. 60 The licensee reouests that the attached changed pages (i.e., ix, x,1-4, 6-3, 6-4, 6-5, 6-6, 6-7, 6-8, 6-9, 6-10, 6-11, 6-12, 6-13, and 6-14) replace tne existing pages in the TMI-2 Technical Specifications (Tech. Specs.).
Purpose for Change The primary purpose of this change is to revise the requirements for the TMI-2 Safety Review Group (SRG) to reflect the current and changing configuration of the plant.
o Following the completion of Mode 1, this change reouest proposes to reduce the minimum staffing requirement for the TMI-2 Safety Review Group (SRG) from one (1) manager and five (5) engineers to one (1) manager and three (3) engineers.
o Following the completion of Mode 2, this change reouest proposes to delete the reouirement for the SRG and proposes to implement a new reouirement for Independent Safety Reviewers (ISRs).
The following sections provide the description of each change, the reason for the change, and the safety evaluation justifying the change and are categorized as follows:
o Changes related to the reduction of the SRG minimum staffing reouirement following Mode 1.
o Changes related to the deletion of the SRG following Mode 2.
o Changes related to the implementation of ISRs during Mode 3.
o Miscellaneous changes.
I.
Cnanges Related to the Reduction of the SRG Minimum Staffing Recuirement Description of Change Section 6.5.4.2, "Safety Review Group - Organization," has been revised as follows:
"6.5.4.2 The TMI-2 SRG shall consists of:
6.5.4.2.1 Manager, SRG and a minimum staff of 5 engineers (Mode 1).
6.5.4.2.2 Manager, SRG and a minimum staff of 3 engineers (Mode 2).
In the event of an unanticipated vacancy in the SRG staff, the numoer of staff members can be two (2) for a period not to exceed one (1) month pending selection of a cualified canditate to fill the vacancy."
Reason'for Change Following the completion of Mode 1 (i.e., end of defueling), the scope of the TMI-2 cleanup effort will have been reduced to the extent that a reduction of the minimum SRG staffing reouirement to a manager and three (3) personnel can be implemented without significantly affecting the ability of the SRG to perform its required functions.
Justification for Change Following the completjon of Mode 1, the THI-2 Reactor Vessel (RV) and Reactor Coolant System will be defueled to the extent reasonably achievable, the possibility of criticality in the Reactor Building (RB) will be precluded, and there will be no canisters containing core material in the RB. Additionally, the number of Tech. Spec recuired systems / equipment will be reduced by approximately 50% and no further significant Tech. Spec, changes are anticipated to be submitted during the balance of the cleanup effort. The significant cleanup activities being performed during Mode 2 will be the completion of fuel shipping, which has been demonstrated to be a reliable and safe operation, and decontamination activities. As a result, GPU Nuclear expects there will be a significant reduction in the amount of changes to, or issuances of, docketed System Descriptions, Technical Evaluation Reports, Safety Evaluation Reports, and Review Significant Procedures, all of which require in-line SRG review. The potential for reportable events per 10 CFR 50.73, which requires in-line SRG review, will also have been significantly reduced. Tnus, GPU Nuclear believes that the proposed reduction in the SRG minimum staffing requirements is appropriate based on the reduced scope of the TMI-2 cleanup activities during Mode 2.
Additionally, GPU Nuclear has proposed a provision which will allow the SRG staf f to operate at a minimum staffing level of a manager and two (2) personnel for a period not to exceed one (1) month, in the event an unanticipated vacancy occurs. Tnis proposal assures sufficient time to select and assign a Qualified SRG member with minimal affect on the cleanup program.
II. Cnanges Related to the Deletion of the SRG Following Mode 2 Description of Cnange o
The phrase "During Modes 1 and 2" has been inserted in the following sections which refer to the SRG:
Section 1.14, "Review Significant."
Section 6.5.2.2, "Independent Safety Review."
Section 6.5.2.6, "Independent Safety Review."
Section 6.5.3.1.K, "Audits."
Section 6.5.3.2, "Records."
Section 6.6.1.b, "Reportable Events Action."
o Sectio'ns 6.5.1, "Technical Review and Control," 6.5.1.9, l
"Activities," and 6.5.2.1, "Independent Safety Review" The second paragraph of h'ction 6.5.1 has been deleted based on I
redundancy. The essence of this paragraph is reflected in the current wording in Section 6.5.1.9.
Additionally, Section 6.5.2.1 has been revised to state: "Divisions other than the TMI-2 Division will perform the Independent Safety Review of their own procedures effecting THI-2 in accordance with approved procedures except as specified in Section 6.5.1.9 "
The reference to SRG in Section 6.5.1.9 has been changed to "independent safety review."
o Section 6.5.4, "Safety Review Group (SRG)"
A subsection 6.5.4.1.1 titled, "Applicability," has been added which indicates that the requirement for the SRG applies during Modes 1 and 2 only.
Reason for Change Following the completion of Mode 2 (i.e., completion of fuel shipping),
the remaining scope of the THI-2 cleanup program will not warrant maintenance of a full-time independent SRG.
Justification for Change The TMI-2 SRG was established by t&C Amendment of Order dated September 19, 1983, which approved THI-2 TSCR No. 40 (reference GPU Nuclear letter 4410-83-L-0023 dated February 25, 1983). The SRG 3
replaced the functions previously performed by the Plant Operating Review Committee (PORC) and the Generation Review Comittee (GRC). Because of the unioue condition of TMI-2, the SRG performs many in-line functions which are normally performed after the fact by other licensee review groups (e.g., rev!ew of 10 CFR 50.73 reportable events). Additionally, the SRG performs t perational trend analyses which were previously performed by the lachnical Specification Compliance Group.
Following the completion of Modes 1 and 2, the Reactor Vessel and Reactor Coolant System will have been defueled and drained and the shipment of the TMI-2 defueling canisters (i.e., core debris) will have been completed. The potential for a release exceeding the guidelines of 10 CFR 50 Appendix I will be essentially eliminated as was recognized by NRC License Amendment 30 which approved TMI-2 TSCR 53. Tech. Spec.
systems / equipment recuired during Mode 3 are primarily those related to containment isolation, fire protection / detection, and ventilation for the Reactor Building, Auxiliary Building, and Fuel Handling Building.
Therefore, the potential for any imediate notifications per 10 CFR 50.72 or reportable events per 10 CFR 50.73, both of which currently require SRG review, will be unlikely. Most plant systems and components will be isolated and not operating. Thus, GPU Nuclear believes that the need for the SRG will no longer exist. Changes to procedures will continue to receive review and approval by Responsible Technical Reviewers (RTRs) per
Tech. Spec.'6.5.1.11.
Additionally, during Mode 3, GPU Nuclear is proposing to add a new requirement for ISRs which is discussed in the following section.
The changes to the second paragraph in Section 6.5.1 and 6.5.2.'l are administrative in nature to avoid redundancy and to avoid unnecessarily inserting "Modes 1 and 2" following each reference to the SRG. The second paragraph in Section 6.5.2.1 has been modified to reference Section 6.5.1.9 which identifies which Support Division procedures must receive TMI-2 Division review and concurrence. The reference to SRG in ~
Section 6.5.1.9 has been changed to " independent safety review" in order that the requirements of this section will continue to apply during Hoce 3.
III. Cnanges Related to the Implementation of ISRs During Mode 3 Description of Cnange o
Section 6.5.2.5, "Responsibilities," has been revised to state:
"The following subjects shall be independently reviewed by the SRG during Modes 1 and 2 and by the Independent Safety Reviewers during Mode 3."
The following subsections of 6.5.2.5 have been revised as follows:
o Subsection 6.5.2.5.b has been revised to replace the phrase "shall be reviewed by SRG" with "shall be independently reviewed."
o Subsection 6.5.2.5.c has been revised to delete the reference to SRG.
o Subsection 6.5.2.5.d has been revised to delete the last sentence which refers to the SRG.
o Subsection 6.5.2.5.e has been deleted. Tne requirements of this section have been incorporated into Section 6.6.1.b, "Reportable Events Action."
o Subsection 6.5.2.5.f has been revised to delete the reference to SRG.
o Subsection 6.5.2.5.1 has been revised to include references to the ISRs.
o New Section 6. 5.2.8 has been added which describes the qualifications of the ISRs and indicates that this section is applicable during Mode 3 only.
o The following sentence has been added to Section 6.6.1.b, "Reportable Events Action,": "During Mode 3, each REPORTABLE EVENT shall undergo an independent safety review. This review shall be performed after the fact."
Reason'for C'hange In lieu of a full-time dedicated SRG, the proposed change will establish ISRs which perform the independent review of the subjects listed in Tecn.
Spec. 6.5.2.5.
Justification for Change i
As discussed in the previous sections, the defueled, safe shutdown condition of THI-2 during Mode 3 does not warrant a full-time dedicated independent review group.
In lieu of the SRG, GPU Nuclear is proposing that ISRs, assigned on a departmental basis, shall perform the independent review of the subjects identified in Tech. Spec. 6.5.2.5.
The qualifications for the ISRs are identical to those for the current SRG members. The ISRs will be required to review documents and changes thereto that are currently reouired to be reviewed by the SRG as described in Tech. Spec. 6.5.2.5.
The proposed changes to incorporate the ISRs are similar to those in the TMI-1 Tech. Specs.; thus, the proposed changes have precedent. The independent review by ISRs will be documented by means of plant procedures and will include a review of technical aspects as well as a review of any associated safety evaluation attached to the document being reviewed. The ISR cannot be the Document Originator, RTR, Implementing Approver or an individual naving direct responsibility for perfnrmance of the activities under review. The ISR may be from the same functional oganization as the Preparer and RTR.
The ISRs shall perform in-line reviews of changes to documents which reouire a 10 CFR 50.59 evaluation as well as changes to Licensing Basis Documents. The ISRs will also review reportable events per 10 CFR 50.73; however, this review shall be performed after the fact. This is consistent with the TMI-l Tech. Specs, and is especially warranted in the case of TMI-2 since the criteria of 10 CFR 50.73 are primarily intended for operating plants.
The last sentence in Section 6.5.2.5.d requires that "SRG shall review all one or four hour immediate notifications and make recommendations as appropriate." This sentence nas been deleted due to redundancy. Section 6.5.2.5 has been revised to state that the subsections shall be independently reviewed by SRG, during Modes 1 and 2, and by the ISRs during Mode 3.
Additionally, Section 6.5.2.5.d states that "Review of events covered under this subsection shall include results of any investigation made and the recommendations resulting from such investigations...
The deletion of Section 6.5.2.5.e is administrative in nature. This section requires that the SRG investigate, prepare, and forward all reportable events. These reauirements are unique to the SRG; thus, they will not apply during Mode 3.
The current reovirements of this section have been transferred to Section 6.6.1.b, for purposes of consistency, which also specifies the actions required by SRG for reportable events.
IV. Miscellaneous Changes A.
Specification 1.14, "Review Significant" Description of Change This specification, in part, currently defines review significant items as "...those system operating procedures and associated emergency, abnormal, alarm response procedures which require tac approval." This phrase has been revised to state, "...those procedures which require NRC approval pursuant to Specification 3.9.13."
Reason for Change NRC License Amendment No. 30 dated May 27, 1988, which approved TSCR No. 53 deleted Tech. Spec. 6.8.2.2 which required in-line PRC approval of certain procedures. Currently, only those procedures which pertain to the disposal of Accident Generated Water reouire NRC approval prior to implementation pursuant to Tech. Spec. 3.9.13.
Justification for Change The proposed change is administrative in nature, thus, no further safety evaluation is reouiIed.
B.
Specificaticos 6.9.1, "Routine Reports and Reportable Occurrences,"
and 6.9.2, "Special Reports" Descript!on of Change The phrase "submitted to the NRC Region I Administrator" has been changed to "submitted in accordance with 10 CFR 50.4."
Reason for Change The proposed changes dele *,e conflicts with the distribution reovirements of paragraph (D) to 10 CFR 50.4, "Written communications." 10 CFR 50.4(f) states that the requirements of this section "...stpercede and replace all existing recuirements in any license conditions or technical specifications in effect on January 5, 1987."
Justification for Change This change is administrative in nature to delete a conflict with an existing regulatory requirements; thus, no further safety evaluation is reauired.
Significant Hazards Consideration 10 CFR Paragraph 50.92 provides the criteria which the Commission uses to evaluate a No Significant Hazards Consideration.
10 CFR 50.92 states that an amendment to a facility license involves No Significant Hazards if operation of the facility, in accordance with the proposed amendment, would not:
l.
Involve a significant increase in the probability or consequences of an accident previously evaluated; or 2.
Create the possibility of a new or different kind of accident'from any accident previously evaluated; or 3.
Involve a significant redtetion in a margin of safety.
The above criteria are addressed below:
Does the change involve a significant increase in the probability or consequences of an accident previously evaluai'ed?
Following the completion of Mode 1 (i.e., end of defueling), GPU Nuclear is proposing that the minimum staffing requirement for the SRG be reduced from a manager and five (5) personnel to a manager and three (3) personnel.
Following the completion of Mode 2 (i.e., completion of fuel shipping), GPU Nuclear believes that the need for a full-time dedicated on-site independent review group no longer exists. Thus, following the completion of Mode 2, GPU Nuclear is proposing that the SRG be deleted and proposes that the activities which currently receive independent review by the SRG will instead be reviewed by Independent Safety Reviewers (ISRs). GPU Nuclear believes the proposed changes are administrative based on the following:
o The activities which require ISR, as specified in Sections 6.5.2.5 and 6.6.1, will remain in effeet during Modes 1, 2, and 3.
o The proposed changes primarily modify the organizational structure for performing an independent safety review. During Moce 3, the amount of documentation currently requiring an independent safety review w!,ll be significantly reduced; thus, the need for a full-time Gedicated independent safety group will no longer be warranted.
o The qualifications of the ISRs are identical to those of the SRG members.
Based o* the above, GPU Nuclear concludes that the proposed changes are administrative in nature and do not involve a significant increase in the probability or consequences of an accident previously evaluated.
Does the change create the possibility of a new or different kind of accident from any accident previously evaluated?
As described above, the proposed changes are primarily administrative in i
nature and do not affect any plant systems or components. Thus, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.
Does the change _ involve a significant reduction in a margin of safety?
During Mode 3, the activities which currently receive independent review by the SRG will instead be reviewed by the ISRs.
The 1SRs will be required to have tne same Qualifications as the SRG members. Thus, the proposed changes ensure continued, cualified independent review of the activities required by Tech. Specs, as performed during Modes 2 and 3.
Therefore, the proposed changes do not involve a significant reduction in a margin of safety.
1
Based on the above analysis, it_is concluded that the proposed changes involve no significant hazards consideration as defined by 10 CFR 50.92.
Amendment Class Per the requirements of 10 CFR 170, "Licensing Fees," an' app 11 cation fee of
$150.00 is enclosed.
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