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Category:CORRESPONDENCE-LETTERS
MONTHYEARML20217M0721999-10-19019 October 1999 Forwards NRC Rept Number 17, Requal Tracking Rept from Operator Licensing Tracking Sys.Rept Was Used by NRC to Schedule Requalification Exam for Operators & Record Pass Dates ML20217D8361999-10-11011 October 1999 Provides NRC with Summary of Activities at TMI-2 During 3rd Quarter of 1999 ML20217F8271999-10-0707 October 1999 Forwards Pmpr 99-13, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting Period 990828- 0924.Diskette Containing Pmpr in Wordperfect 8 Is Encl. All Variances Are Expressed with Regard to Current Plans ML20212L1831999-10-0101 October 1999 Responds to Recent Ltr to Wd Travers Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Performance of Millstone to Ensure Adequate Protection to Public Health ML20212L2081999-10-0101 October 1999 Responds to Recent Ltrs to President Wj Clinton,Chairman Jackson & Commissioners & Wd Travers,Expressing Concerns Re Millstone NPPs & Continued Lack of Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance ML20212K1241999-10-0101 October 1999 Responds to Recent Ltrs to Chairman Jackson,Commissioners & Wd Travers,Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performace of Millstone to Ensure That Public Health & Safety,Adequately Protected ML20212L1971999-10-0101 October 1999 Responds to Recent Ltr to Chairman Jackson & Commissioners Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Continues to Monitor Plant Performance to Ensure Public Health & Safety ML20212J9991999-10-0101 October 1999 Responds to Recent Ltr to President Clinton,H Clinton, Chairman Jackson &/Or Wd Travers Expressing Concern Re Millstone Npps.Nrc Continues to Monitor Performance of Plant to Ensure That Public Health & Safety Adequately Protected ML20212L0061999-10-0101 October 1999 Discusses GL 97-06 Issued by NRC on 971231 & Gpu Response for Three Mile Island .Staff Reviewed Response & Found No New Concerns with Condition of SG Internals or with Insp Practices Used to Detect Degradation of SG Internals ML20212L2171999-10-0101 October 1999 Responds to Recent Ltr to President Wj Clinton,Chairman Jackson & Commissioners,Wd Travers & Ferc,Expressing Concerns Re Millstone NPPs & Continued Lack of Emergency Mgt Plan for Eastern Long Island ML20212K8771999-09-30030 September 1999 Informs of Completion of mid-cycle PPR of Three Mile Island on 990913.No Areas Identified in Which Licensee Performance Warranted Addl Insp Beyond Core Insp Program.Provides Historical Listing of Plant Issues & Insp Schedule ML20212K8551999-09-30030 September 1999 Informs That During 990921 Telcon Between P Bissett & F Kacinko,Arrangements Were Made for Administration of Licensing Exams at Facility During Wk of 000214.Outlines Should Be Provided to NRC by 991122 ML20216J6581999-09-28028 September 1999 Provides Info as Requested of Licensees by NRC in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams ML20212J0011999-09-27027 September 1999 Forwards Insp Rept 50-289/99-07 on 990828.No Violations Noted ML20212E1971999-09-16016 September 1999 Forwards Rev 11 of Gpu Nuclear Operational QAP, Reflecting Organizational Change in Which Functions & Responsibilities of Nuclear Safety & Technical Support Div Were Assigned to Other Divisions ML20212A2101999-09-13013 September 1999 Forwards Rev 3 of Gpu Nuclear Post-Defueling Monitored Storage QAP for Three Mile Island Unit 2, Including Changes Made During 1998.Description of Changes Provided on Page 2 ML20216G4151999-09-0909 September 1999 Forwards Pmpr 99-12, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting Period 990731- 0827.All Variances Expressed with Regard to Current Operations Plans ML20211M5861999-09-0202 September 1999 Forwards non-proprietary & Proprietary Response to NRC 990708 RAI Re TS Change Request 272,reactor Coolant Sys Coolant Activity.Proprietary Encl Withheld ML20211M6591999-09-0101 September 1999 Forwards Errata Page to 990729 Suppl to TS Change Request 274,to Reflect Proposed Changes Requested by . Page Transmitted by Submitted in Error ML20211L2401999-09-0101 September 1999 Submits Response to NRC AL 99-02, Operator Reactor Licensing Action Estimates ML20211H3731999-08-27027 August 1999 Responds to NRC 990810 RAI Re TMI LAR 285 & TMI-2 LAR 77 Re Changes Reflecting Storage of TMI-1 Radioactive Matls in TMI-2 Facility.Revised License Page mark-up,incorporating Response,Encl ML20211H4001999-08-27027 August 1999 Responds to NRC 990810 RAI Re TMI-1 LAR 285 & TMI-2 LAR 77 Re Changes to Clarify Authority to Possess Radioactive Matls Without Unit Distinction.Revised License Page mark-up, Incorporating Response Encl ML20211K2391999-08-23023 August 1999 Forwards fitness-for-duty Performance Data Repts for TMI, Oyster Creek & Corporate Headquarters Located in Parsippany, Nj ML20211H5041999-08-20020 August 1999 Forwards Proprietary & non-proprietary Rept MPR-1820,rev 1, TMI Nuclear Generating Station OTSG Kinetic Expansion Insp Criteria Analysis. Affidavit Encl.Proprietary Rept Wihheld 05000289/LER-1999-007, Forwards LER 99-007-01 Re Increasing Failure Rate of ESAS Relays.Rept Supplements Preliminary Info Re Determination of Root Cause & Long Term Corrective Actions.Changes Made for Supplement Are Indicated in Bold Typeface1999-08-20020 August 1999 Forwards LER 99-007-01 Re Increasing Failure Rate of ESAS Relays.Rept Supplements Preliminary Info Re Determination of Root Cause & Long Term Corrective Actions.Changes Made for Supplement Are Indicated in Bold Typeface ML20211A4261999-08-19019 August 1999 Forwards Insp Rept 50-289/99-04 on 990606-0717.Two Severity Level 4 Violations Occurred & Being Treated as Noncited Violations ML20211H3571999-08-19019 August 1999 Forwards Itemized Response to NRC 990712 RAI Re TS Change Request 248 Re Remote Shutdown Sys,Submitted on 981019 ML20211A3931999-08-12012 August 1999 Requests NRC Concurrence with Ongoing Analytical Approach as Described in Attachment,Which Is Being Utilized by Gpu Nuclear to Support Detailed License Amend Request to Revise Design Basis for TMI-1 Pressurizer Supports ML20210R4691999-08-11011 August 1999 Forwards Update 3 to Post-Defueling Monitored Storage SAR, for TMI-2.Update 3 Revises SAR to Reflect Current Plant Configuration & Includes Minor Editorial Changes & Corrections.Revised Pages on List of Effective Pages ML20210N7601999-08-10010 August 1999 Informs That NRC Staff Reviewed Applications Dtd 990629, Which Requested Review & Approval to Allow Authority to Possess Radioactive Matl Without Unit Distinction Between Units 1 & 2.Forwards RAI Re License Amend Request 285 ML20210N7191999-08-0606 August 1999 Forwards Notice of Partial Denial of Amend to FOL & Opportunity for Hearing Re Proposed Change to TS 3.1.12.3 to Add LCO That Would Allow Continued HPI Operation ML20210L3831999-07-30030 July 1999 Responds to NRC 990617 RAI Re OTSG Kinetic Expansion Region Insp Acceptance Criteria That Was Used for Dispositioning Indications During Cycle 12 Refueling (12R) Outage ML20210K7371999-07-30030 July 1999 Forwards Rev 2 to 86-5002073-02, Summary Rept for Bwog 20% Tp LOCA, Which Corrects Evaluation Model for Mk-B9 non- Mixing Vane Grid Previously Reported in Util to Nrc,Per 10CFR50.46 ML20210L1151999-07-28028 July 1999 Confirms Two Senior Management Changes Made within Amergen Energy Co,Per Proposed License Transfer & Conforming Administrative License Amends for TMI-1 05000289/LER-1999-009, Forwards LER 99-009-00 Re 990626 Event Involving Partial Loss of Offsite Power & Subsequent Automatic Start of EDG 1A.Commitments Made by Util Are Contained in long-term Corrective Actions Section1999-07-22022 July 1999 Forwards LER 99-009-00 Re 990626 Event Involving Partial Loss of Offsite Power & Subsequent Automatic Start of EDG 1A.Commitments Made by Util Are Contained in long-term Corrective Actions Section ML20216D4001999-07-22022 July 1999 Provides Summary of Activities at TMI-2 During 2nd Quarter of 1999 ML20210B8231999-07-21021 July 1999 Forwards Exemption from Certain Requirements of 10CFR50.54(w) for Three Mile Island Nuclear Station,Unit 2 in Response to Licensee Application Dtd 990309,requesting Reduction in Amount of Insurance for Unit to Amount Listed ML20210G9471999-07-15015 July 1999 Forwards Pmpr 99-10, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting period,990605- 0702.Diskette Containing Pmpr in Wordperfect 8 Format Is Also Encl ML20209H9401999-07-15015 July 1999 Forwards Copy of Environ Assessment & Findings of No Significant Impact Re Application for Exemption Dtd 990309. Proposed Exemption Would Reduce Amount of Insurance for Onsite Property Damage Coverage as Listed ML20209G2451999-07-15015 July 1999 Advises That Suppl Info in Support of Proposed License Transfer & Conforming Adminstrative License Amends,Submitted in & Affidavit,Marked Proprietary,Will Be Withheld from Public Disclosure,Per 10CFR2.790(b)(5) ML20212K1701999-07-13013 July 1999 Submits Concerns Re Millstone & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Should Provide Adequate Emergency Planning in Case of Radiological Accident ML20216D9861999-07-12012 July 1999 Forwards RAI Re 981019 Application Request for Review & Approval of Operability & SRs for Remote Shutdown Sys. Response Requested within 30 Days of Receipt of Ltr ML20209G5861999-07-0909 July 1999 Forwards Insp Rept 50-289/99-05 on 990510-28.No Violations Noted ML20209F2571999-07-0909 July 1999 Forwards Staff Evaluation Rept of Individual Plant Exam of External Events Submittal on Three Mile Nuclear Station, Unit 1 ML20209D8451999-07-0808 July 1999 Forwards Insp Rept 50-289/99-06 on 990608-11.No Violations Noted.Overall Performance of ERO Very Good & Demonstrated, with Reasonable Assurance,That Onsite Emergency Plans Adequate & That Util Capable of Implementing Plan ML20209D6291999-07-0808 July 1999 Forwards Notice of Withdrawal & Corrected TS Pages 3-21 & 4-9 for Amend 211 & 4-5a,4-38 & 6-3 for Amend 212,which Was Issued in Error.Amends Failed to Reflect Previously Changes Granted by Amends 203 & 204 ML20209D5141999-07-0808 July 1999 Forwards RAI Re 981019 Application & Suppl ,which Requested Review & Approval of Revised Rc Allowable Dose Equivalent I-131 Activity Limit with Max Dose Equivalent Limit of 1.0 Uci/Gram.Response Requested within 30 Days 05000289/LER-1999-008, Forwards LER 99-008-00 Re Discovery of Degraded But Operable Condition of RB Emergency Cooling Sys.Condition Did Not Adversely Affect Health & Safety of Public1999-07-0202 July 1999 Forwards LER 99-008-00 Re Discovery of Degraded But Operable Condition of RB Emergency Cooling Sys.Condition Did Not Adversely Affect Health & Safety of Public ML20196J3981999-07-0101 July 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Y2K Readiness Disclosure for TMI-1 Encl ML20209C1131999-07-0101 July 1999 Forwards Signed Agreement as Proposed in NRC Requesting Gpu Nuclear Consent in Incorporate TMI-1 Thermo Lag Fire Barrier Final Corrective Action Completion Schedule Commitment of 000630 Into Co Modifying License 1999-09-09
[Table view] Category:INCOMING CORRESPONDENCE
MONTHYEARML20217D8361999-10-11011 October 1999 Provides NRC with Summary of Activities at TMI-2 During 3rd Quarter of 1999 ML20217F8271999-10-0707 October 1999 Forwards Pmpr 99-13, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting Period 990828- 0924.Diskette Containing Pmpr in Wordperfect 8 Is Encl. All Variances Are Expressed with Regard to Current Plans ML20216J6581999-09-28028 September 1999 Provides Info as Requested of Licensees by NRC in Administrative Ltr 99-03, Preparation & Scheduling of Operator Licensing Exams ML20212E1971999-09-16016 September 1999 Forwards Rev 11 of Gpu Nuclear Operational QAP, Reflecting Organizational Change in Which Functions & Responsibilities of Nuclear Safety & Technical Support Div Were Assigned to Other Divisions ML20212A2101999-09-13013 September 1999 Forwards Rev 3 of Gpu Nuclear Post-Defueling Monitored Storage QAP for Three Mile Island Unit 2, Including Changes Made During 1998.Description of Changes Provided on Page 2 ML20216G4151999-09-0909 September 1999 Forwards Pmpr 99-12, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting Period 990731- 0827.All Variances Expressed with Regard to Current Operations Plans ML20211M5861999-09-0202 September 1999 Forwards non-proprietary & Proprietary Response to NRC 990708 RAI Re TS Change Request 272,reactor Coolant Sys Coolant Activity.Proprietary Encl Withheld ML20211M6591999-09-0101 September 1999 Forwards Errata Page to 990729 Suppl to TS Change Request 274,to Reflect Proposed Changes Requested by . Page Transmitted by Submitted in Error ML20211L2401999-09-0101 September 1999 Submits Response to NRC AL 99-02, Operator Reactor Licensing Action Estimates ML20211H3731999-08-27027 August 1999 Responds to NRC 990810 RAI Re TMI LAR 285 & TMI-2 LAR 77 Re Changes Reflecting Storage of TMI-1 Radioactive Matls in TMI-2 Facility.Revised License Page mark-up,incorporating Response,Encl ML20211H4001999-08-27027 August 1999 Responds to NRC 990810 RAI Re TMI-1 LAR 285 & TMI-2 LAR 77 Re Changes to Clarify Authority to Possess Radioactive Matls Without Unit Distinction.Revised License Page mark-up, Incorporating Response Encl ML20211K2391999-08-23023 August 1999 Forwards fitness-for-duty Performance Data Repts for TMI, Oyster Creek & Corporate Headquarters Located in Parsippany, Nj 05000289/LER-1999-007, Forwards LER 99-007-01 Re Increasing Failure Rate of ESAS Relays.Rept Supplements Preliminary Info Re Determination of Root Cause & Long Term Corrective Actions.Changes Made for Supplement Are Indicated in Bold Typeface1999-08-20020 August 1999 Forwards LER 99-007-01 Re Increasing Failure Rate of ESAS Relays.Rept Supplements Preliminary Info Re Determination of Root Cause & Long Term Corrective Actions.Changes Made for Supplement Are Indicated in Bold Typeface ML20211H5041999-08-20020 August 1999 Forwards Proprietary & non-proprietary Rept MPR-1820,rev 1, TMI Nuclear Generating Station OTSG Kinetic Expansion Insp Criteria Analysis. Affidavit Encl.Proprietary Rept Wihheld ML20211H3571999-08-19019 August 1999 Forwards Itemized Response to NRC 990712 RAI Re TS Change Request 248 Re Remote Shutdown Sys,Submitted on 981019 ML20211A3931999-08-12012 August 1999 Requests NRC Concurrence with Ongoing Analytical Approach as Described in Attachment,Which Is Being Utilized by Gpu Nuclear to Support Detailed License Amend Request to Revise Design Basis for TMI-1 Pressurizer Supports ML20210R4691999-08-11011 August 1999 Forwards Update 3 to Post-Defueling Monitored Storage SAR, for TMI-2.Update 3 Revises SAR to Reflect Current Plant Configuration & Includes Minor Editorial Changes & Corrections.Revised Pages on List of Effective Pages ML20210L3831999-07-30030 July 1999 Responds to NRC 990617 RAI Re OTSG Kinetic Expansion Region Insp Acceptance Criteria That Was Used for Dispositioning Indications During Cycle 12 Refueling (12R) Outage ML20210K7371999-07-30030 July 1999 Forwards Rev 2 to 86-5002073-02, Summary Rept for Bwog 20% Tp LOCA, Which Corrects Evaluation Model for Mk-B9 non- Mixing Vane Grid Previously Reported in Util to Nrc,Per 10CFR50.46 ML20210L1151999-07-28028 July 1999 Confirms Two Senior Management Changes Made within Amergen Energy Co,Per Proposed License Transfer & Conforming Administrative License Amends for TMI-1 05000289/LER-1999-009, Forwards LER 99-009-00 Re 990626 Event Involving Partial Loss of Offsite Power & Subsequent Automatic Start of EDG 1A.Commitments Made by Util Are Contained in long-term Corrective Actions Section1999-07-22022 July 1999 Forwards LER 99-009-00 Re 990626 Event Involving Partial Loss of Offsite Power & Subsequent Automatic Start of EDG 1A.Commitments Made by Util Are Contained in long-term Corrective Actions Section ML20216D4001999-07-22022 July 1999 Provides Summary of Activities at TMI-2 During 2nd Quarter of 1999 ML20210G9471999-07-15015 July 1999 Forwards Pmpr 99-10, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting period,990605- 0702.Diskette Containing Pmpr in Wordperfect 8 Format Is Also Encl ML20212K1701999-07-13013 July 1999 Submits Concerns Re Millstone & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Nrc Should Provide Adequate Emergency Planning in Case of Radiological Accident 05000289/LER-1999-008, Forwards LER 99-008-00 Re Discovery of Degraded But Operable Condition of RB Emergency Cooling Sys.Condition Did Not Adversely Affect Health & Safety of Public1999-07-0202 July 1999 Forwards LER 99-008-00 Re Discovery of Degraded But Operable Condition of RB Emergency Cooling Sys.Condition Did Not Adversely Affect Health & Safety of Public ML20196J3981999-07-0101 July 1999 Responds to GL 98-01,Suppl 1, Y2K Readiness of Computer Sys at Npps. Y2K Readiness Disclosure for TMI-1 Encl ML20209C1131999-07-0101 July 1999 Forwards Signed Agreement as Proposed in NRC Requesting Gpu Nuclear Consent in Incorporate TMI-1 Thermo Lag Fire Barrier Final Corrective Action Completion Schedule Commitment of 000630 Into Co Modifying License ML20196J7651999-06-29029 June 1999 Provides Updated Info Re Loss of Feedwater & Loss of Electric Power Accident Analyses to Support TS Change Request 279 Re Core Protection Safety Limit,As Discussed at 990616 Meeting ML20196J7701999-06-29029 June 1999 Forwards LAR 285 for License DPR-50,clarifying Authority to Possess Radioactive Matls Without Unit Distinction,So That After Transfer of TMI-1 License to Amergen,Radioactive Matls May Continue to Be Moved Between TMI-1 & TMI-2 Units ML20209C0391999-06-29029 June 1999 Forwards LAR 77 to License DPR-73,clarifying Authority to Possess Radioactive Matls Without Unit Distinction,So That After Transfer of TMI-2 License to Amergen,Radioactive Matl May Continue to Be Moved Between TMI-1 & TMI-2 Units ML20196G2061999-06-23023 June 1999 Requests That NRC Update Current Service Lists to Reflect Listed Personnel Changes That Occurred at TMI 05000289/LER-1999-006, Forwards LER 99-006-00,providing Complete Description,Extent of Condition & Actions Taken in Association with Determination of Inability of Pressurizer Support Bolts to Meet FSAR Requirements1999-06-23023 June 1999 Forwards LER 99-006-00,providing Complete Description,Extent of Condition & Actions Taken in Association with Determination of Inability of Pressurizer Support Bolts to Meet FSAR Requirements ML20196D2171999-06-17017 June 1999 Forwards Pmpr 99-9, CNWRA Program Manager Periodic Rept on Activities of CNWRA, for Fiscal Reporting period,990508- 0604.New Summary Personnel Table Was Added to Rept Period.Matl Scientist Joined Staff Period ML20196A0431999-06-15015 June 1999 Providess Notification That Design Verification Activities Related to Calculations Supporting Analytical Values Identified in Gpu Nuclear Ltr to NRC Has Been Completed 05000289/LER-1999-004, Forwards LER 99-004-00,re Discovery of Emergency FW Pump Bearing Failure During Performance of Oil Change on 990510. Event Was Determined Reportable IAW 10CFR50.73,since Pump Was Determined to Be Inoperable Longer than TS AOT1999-06-0909 June 1999 Forwards LER 99-004-00,re Discovery of Emergency FW Pump Bearing Failure During Performance of Oil Change on 990510. Event Was Determined Reportable IAW 10CFR50.73,since Pump Was Determined to Be Inoperable Longer than TS AOT ML20212K2541999-06-0808 June 1999 Submits Concerns Re Millstone NPP & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Requests That NRC Provide Adequate Emergency Planning in Case of Radiological Accident ML20212K2671999-06-0808 June 1999 Submits Concerns Re Millstone NPP & Continued Lack of Emergency Mgt Plan for Eastern Long Island.Requests That NRC Provide Adequate Emergency Planning in Case of Radiological Accident ML20195E2751999-06-0404 June 1999 Informs That PCTs & LOCA Lhr Limits Submitted in Util Ltr for LOCA Reanalysis Performed in Support of TMI-1 20% Tube Plugging Amend Request Have Been Revised.Revised PCT & LOCA Lhr Limit Values Are Provided on Encl Table 1 ML20195E3281999-06-0404 June 1999 Forwards Application for Amend to License DPR-50,modifying Conditions Which Allow Reduction in Number of Means for Maintaining Decay Heat Removal Capability During Shutdown Conditions ML20195C5721999-06-0202 June 1999 Forwards Description of Gpu Nuclear Plans for Corrective Actions for 1 H Fire Barriers in Fire Zones AB-FZ-3,AB-FZ-5, AB-FZ-7,FH-FZ-2 & Previous Commitments for Fire Zones CB-FA-1 & FH-FZ-6 ML20207E2561999-05-25025 May 1999 Submits 30-day Written Rept on Significant PCT Change in ECCS Analyses at TMI-1 ML20195B2461999-05-21021 May 1999 Forwards Itemized Response to NRC 990506 RAI for TS Change Request 279 Re Core Protection Safety Limit ML20206R6461999-05-13013 May 1999 Forwards Rev 39 of Modified Amended Physical Security Plan for TMI 05000289/LER-1999-003, Forwards LER 99-003-00, Discovery of Condition Outside UFSAR Design Basis for CR Habitability, Which Was Determined Reportable on 990310.Rept Is Being Submitted Four Weeks Later than Required,Per Discussion with NRC1999-05-0707 May 1999 Forwards LER 99-003-00, Discovery of Condition Outside UFSAR Design Basis for CR Habitability, Which Was Determined Reportable on 990310.Rept Is Being Submitted Four Weeks Later than Required,Per Discussion with NRC ML20206K6301999-05-0707 May 1999 Provides Addl Info Re TMI-1 LOFW Accident re-analysis Assumptions for 20% Average SG Tube Plugging as Discussed on 990421 ML20206H0781999-04-30030 April 1999 Forwards Rev 0 to 1092, TMI Emergency Plan. Summary of Changes Encl ML20206J4811999-04-30030 April 1999 Provides Summary of Activities at TMI-2 During First Quarter of 1999.TMI-2 RB Was Not Inspected During Quarter.Routine Radiological Surveys of Auxiliary & Fuel Handling Bldgs Did Not Identify Any Significant Adverse Trends ML20206E4121999-04-27027 April 1999 Requests That TS Change Request 257 Be Withdrawn ML20206C5211999-04-23023 April 1999 Requests Mod to Encl Indemnity Agreement Number B-64,on Behalf of Gpu & Affiliates,Meed,Jcpl,Penelec & Amergen Energy Co,Llc.Ltr Supersedes & Withdraws 990405 Request Submitted to NRC ML20206C8261999-04-22022 April 1999 Submits Financial Info IAW Requirements of 10CFR50.71(b) & 10CFR140.21 1999-09-09
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e l GPU Nuclear, Inc.
( Route 441 south NUCLEAR Post Office Box 480 March 09,1999 Middletown. PA 17057-0480 Tel 717 944 7621 1920-99-20104 U.S. ' Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555
Dear Sir:
Subject:
Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Possession Only License No. DPR-73 Docket No. 50-320 Request For Exemption From The Insurance Coverage Limit Of 10CFR50.54(w)
GPU Nuclear, Inc. (G1 UN), on behalf ofitself and its afliliates, Metropolitan Edison Company, Jersey Central Power & Light Company, and Pennsylvania Electric Company, as the NRC licensee of Three Mile Island Unit 2 (TMI-2) hereby requests an exemption for TMI-2 from the insurance coverage amount set forth in 10CFR50.54(w). This exemption is requested in accordance with 10CFR50.12, " Specific Exemptions." The exemption would become etTective after the transfer of the Three Mile Island Unit 1 (TMI-1) facility operating license to AmerGen Energy Company, LLC (AmerGen).
TMI-2 is permanently shutdown and licensed as a possession only facility. TMI-2 Post Defueling Monitored Storage (PDMS) Safety Analysis Report (SAR) describes TMI-2's status as follows:
"TMI-2 has been defueled and decontaminated to the extent that the plant is in a safe, inherently stable condition suitable for long-term management and any threat to the public health and safety has been eliminated. All fuel and core debris which have been removed from the Reactor Vessel 1 and associated systems have been shipped off-site." This same conclusion is reflected in the i f
NRC's Safety Evaluation Report related to PDMS. O EXEMPTION REOUESTS GPUN hereby requests an exemption from the requirement of 10CFR50.54(w), which requires licensees to maintain $1.06 billion in on-site property damage insurance coverage for each reactor station site. GPUN requests that after transfer of the TMI-1 license to AmerGen, GPUN be .
permitted to maintain $50 million in on-site property damage insurance coverage for TMI-2. This request would not affect the insurance coverage that AmerGen would be required to maintain for TMI-l as the licensee of an operating reactor, pursuant to 10 CFR 50.54(w), except that the k
property damage insurance coverage for TMI-l would be limited to the TMI-l site. Upon NRC approval of this exemption request, GPUN intends to obtain a separate on-site property damage insurance policy for TMI-2 to become effective upon the date of the referenced transfer of the TMl-1 operating license. The separate policies for TMI-l and TMI-2 will include appropriate 9903180197 990'309 1 PDR ADOCK 05000320 <
J PDR
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1920-99-20104 Page 2 of 4 cross contamination clauses designed to hold the other party harmless from any contamination which that party's Unit may cause to the other.
DISCUSSION l The financial protection limit of 10CFR 50.54(w) was established to require a licensee to maintain sufficient insurance to cover the costs of on-site property damage resulting from a nuclear accident at an operating reactor. Those costs were derived from the expected consequences of a release of radioactive material from the reactor. In an operating plant, the high temperature and pressure of the reactor coolant system, as well as the inventory of relatively short lived radionuclides, contribute to both the risk and consequences of an accident. In a permanently shutdown and defueled reactor, the reactor coolant system will never be operated and contains no short-lived radionuclides, which eliminates the possibility of reactor accidents. A further reduction in risk occurs when the fuel is shipped offsite. Thus, the potential for a significant release of radioactive material has been eliminated at TMI-2, for which the 10 CFR 50.54(w)
$1.06 billion on-site insurance coverage is otherwise required.
In SECY 96-256, " Changes to the Financial Protection Requirements for Permanently Shutdown Nuclear Power Reactors,10 CFR 50.54(w) and 10 CFR 140.11," dated December 17,1996, the NRC staff estimated the on-site cleanup costs of accidents considered to be the most costly at a permanently defueled site with spent fuel removed from the site, and with the on-site radioactive liquid inventory greater than 1000 gallons. Although a small amount of fuel debris remains at TMl-2, the NRC Safety Evaluation for TMI-2 Technical Specifications Amendment #48, dated December 28,1993, states in part that "no credible accident could result in the release of radioactive materials to the environment in quantities that would require protective actions for the public, and there is reasonable assurance that the health and safety of the public will not be endangered." Thus it is reasonable to assume that the staff would so describe the situation at TMI-2.
The stat. in SECY 96-256, found that the estimated on-site cleanup costs to recover from the rupture of a large liquid radwaste storage tank could range up to $50 million. The proposed level of $50 million for on-site property insurance is sufficient to cover these estimated cleanup costs.
A recent study submitted to the NRC by the Nuclear Energy Institute (NEI) indicates that this I level ofinsurance would be very conseivative.-
The on-site property damage insurance that GPUN will obtain for TMI-2 will provide coverage for property damage at TMI-2 irrespective of whether the loss is caused by TMI-2 or TMI-l activities.
i
1920-99-20104 L Page 3 of 4 BASIS FOR EXEMPTION REOUEST
' The specific requirements for granting exemptions from Part 50 regulations are set forth in 10CFR50.12. The commission is authorized to grant an exemption upon a determination that the exemption: (A) is authorized by law; (B) will not present an undue risk to the public health and
- safety; and (C)is consistent with the common defense and security. Special circumstances must exist for the NRC to consider an exemption request. Special circumstances include: (1) particular circumstances where the application of the regulation would not serve the underlying purpose of l the rule or is not necessary to achieve the underlying purpose of the rule and (2) undue hardship o ccosts that are significantly in excess of those incurred by others similarly situated.
A. The requested exemption is authorized by law and has been routinely granted by the
. Commission. Those plants granted insurance exemptions include Rancho Seco, Haddam Neck, Maine Yankee, Trojan, among others. In addition, the requested exemptions are consistent with SECY 96-256 and the NRC proposed rule for 10CFR Parts 50 and 140, noticed in the Federal Register on October 30,1997.
B. The requested exemption produces no undue risk to the public health and safety. As stated above, the risks associated with TMI-2 in its current condition and the possible resulting l damage to property are greatly reduced from those of power operations. The reduction in coverage is commensurate with the reduction in the risk and consequences of an accident.
C. The requested exemption is consistent with the common defense and security. The exemption would reduce the required on-site property damage coverage. There would be no physical change to the plant or the fuc! debris as a rest.it of this exemption and no impact on the common defense or security of the public or the TMI-2 facility.
- 1. - The continued application of the requirements of 10CFR50.54(w) is not necessary to achieve the underlying purpose of the rule which is to provide assurance that the licensee will have the financial capability to restore the facility to a safe configuration after a design basis accident.
The $1.06 billion coverage specified in the rule was clearly applicable to the potential for damage at an operating plant. In the present PDMS condition, $50 million in property coverage is more than sufficient to provide safe restoration assurance. The NRC analysis l discussed in SECY 96-256 estimates the cleanup costs associated with the rupture of a large l tank of slightly contaminated water to be about $50 million. The requested exemption is consistent with these estimates and meets the purpose of the rule.
i l The requirements of 10CFR50.54(w) did not contemplate a shutdown reactor owned by one )
l licensee on the site of an operating reactor owned by another licensee. In this respect, the j provision in section 50.54(w) imposing the $1.06 billion property damage coverage on the j entire " reactor station site" was never mtended to require the licensee of the shutdown unit to also carry property damage insurance in the amount required for the operating unit.
I I
1920-99-20104 Page 4 of 4 Any property damage to TMI-2, due to a TMI-l accident, is expected to be within the $50 million limit requested. This expectation is consistent with and supported by the limited property damage that TMI-l experienced from the TMI-2 accident in 1979.
- 2. The requirement to maintain $1.06 billion in property coverage represents a financial burden to the licensee of TMI-2 and the electric customers ofits owners, which has no benefit to the licensee, the public, or the Faderal Government. As such, the financial burden of the specified insurance level represents a hardship not appropriate nor ever intended for a facility in the PDMS condition. '
CONCLUSION 1
The risks for which 10CFR50.54(w) requires a licensee to obtain specific financial protection l amounts for an operating plant are no longer applicable to TMI-2. The guidelines discussed in l SECY 96-256 provide for a reduced level ofinsurance coverage appropriate for a permanently defueled plant. Therefore, GPUN respectfully requests the NRC Staff to exempt TMI-2 from the financial protection requirements for an operating plant and approve reduced financial protection ;
coverage for a permanently defueled plant of $50 million in on-site insurance coverage consistent with Reactor Configuration 3, as described in SECY 96-256.
If the NRC should have any questions, please contact Adam Miller of the TMI Nuclear Safety &
Licensing Department at (717) 948-8128.
Sincerely, yt mes W. Lang bach Vice President and Director, TM1 AWM cc: TMI Senior Resident Inspector Administrator, Region I TMI-2 Senior Project Manager File 99057
.