ML20236Y327
| ML20236Y327 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/04/1987 |
| From: | Standerfer F GENERAL PUBLIC UTILITIES CORP. |
| To: | |
| Shared Package | |
| ML20236Y321 | List: |
| References | |
| NUDOCS 8712110243 | |
| Download: ML20236Y327 (3) | |
Text
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METROPOLITAN EDISON COMPANY IRSEY CENTRAL POWER AND LIGHT COMPANY PENNSYLVANIA ELECTRIC COMPANY GPU NUCLEAR THREE MILE ISLAND NUCLEAR STATION UNIT II Operating License No. OPR-73 Docket No. 50-320 Technical Specification Change Request No. 53 - Revision 3 This Technical Specification Change Request is submitted in support of Licensee's request to change Operating License No. DPR-73 for Three Mile i
Island Nuclear Station Unit 2.
As a part of this request, proposed replacement pages for Appendix A are also included.
GPU NUCLEAR' By d irector, TMI-2 //
Sworn and subscribed to me this day of exem[gA2,,1987.
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Three Mile Island Nuclear Station, Unit 2 (TMI-2)
Operating License No. DPR-73 Docket No. 50-320 Technical Specification Change Request (TSCR) No. 53 - Revision 3 The licensee requests that the attached changed page replace the corresponding i
page previously submitted for NRC review and approval via GPU Nuclear letters l
4410-87-L-0042 dated April 23, 1987, 4410-87-L-0152 dated October 26, 1987, and 4410-87-L-0167 dated November 9, 1987.
Purpose of Change The above referenced GPU Nuclear letters submitted Revision 0, 1, and 2, I
respectively, of TSCR 53.
The purpose of this revision is to futher implement the intent of NRC Comment No. 3 of their letter dated September 25, 1987, by deleting the requirement for an NRC-approved Radiation Protection Plan from i
Technical Specification (Tech. Spec.) Section 6.11.
In doing this, Tech.
Spec. 6.11 will also be revised to be consistent with Standard Technical Specifications.
Safety Evaluation inrnediately following the March 1979 accident, the NRC raised concerns regarding radiation safety at TMI-2 during cleanup operations. As a result of these concerns, a special panel was established by the NRC to assess the TMI-2 Radiation Protection Program. This panel concluded that although the TMI-2 Radiation Protection Program had deficiencies and required corrective actions, the company management demonstrated a strong commitment to upgrade the program to assure radiation exposure to all employees would be as low as reasonably achievable.
As part of the commitment to a strong radiation safety program, GPU Nuclear developed the TMI-2 Radiation Protection Plan.* The plan was submitted to the NRC for review and approval in January 1980. TPa plan set forth the radiation protection policies and philosophies of GPU Nuclear in regards to cleanup operations.
To ensure that GPU Nuclear maintained an effective Radiation Protection i
Program throughout the cleanup of THI-2, the NRC imposed the requirement for an NRC-approved Radiation Protection Plan as part of the February 13, 1980, Amendment of Order. Thus, since February 13, 1980, all changes to the GPU Nuclear Corporate Radiation Protection Plan had to receive NRC review and approval prior to implementation.
However, at this point of the cleanup program, it is the belief of GPU Nuclear that it is no longer necessary for the NRC to approve changes to the Radiation Protection Plan. GPU Nuclear believes that throughout the cleanup program the
- NOTE: The TMI-2 Radiation Protection Plan was incorporated into the GPU Nuclear Corporate Radiation Protection Plan effective March 15, 1982.
cdmpany has demonstrated a strong commitment to a high quality radiation safety program. This commitment is evidenced by the exemplary performance of all Radiological Controls sections in their support of many challenging program objectives. In addition, the most recent Systematic Assessment of Licensee Performance (SALP) report for TMI-2 noted that the quality of the program can be evidenced by the major reductions in airborne, surface, and general area radioactivity and radiation levels throughout TMI-2 while at the same time minimizing personnel exposure. GPU Nuclear sees no reason why this commitment to a strong radiation protection program would be reduced and, therefore, GPU Nuclear believes that it is unnecessary for the NHC to review and approve changes to the Radiation Protection Plan.
In addition, the deletion of the requirement for an NRC-approved Radiation Protection Plan will be consistent with the NRC intent to be removed from the procedural review and approval cycle at TMI-2.
This intent was expressed in the NRC Letter dated September 25, 1987, which contained comments on TSCR 53 Revision O.
However, it should be noted that revisions to the GPU Nuclear Corporate Radiation Protection Plan will still be submitted to the NRC for their information.
No Significant Hazards Determination The proposed change is within the scope of the No Significant Hazards Determination analysis originally submitted in TSCR 53.
The proposed change to delete the requirement for an NRC-approved Radiation Protection Plan pursuant to Tech. Spec. 6.11 is primarily administrative in nature. The deletion of this requirement is based on the strength of the GPU Nuclear Corporate Radiation Protection Plan and the desire to revise Tech.
Spec. 6.11 to be consistent with the intent of previous NRC comments regarding TSCR 53. Thus, per the criteria of 10 CFR 50.92, the proposed revision does not:
1.
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 reduction in a margin of safety.
Based on the No Significant Hazards Determination of the original TSCR 53 submittal and from the above review, GPU Nuclear concludes that the change proposed in this revision does not involve Significant Hazards.
Amendment Class An application fee, per the requirements for 10 CFR 170, was previously submitted for TSCR 53 and Recovery Operations Plan Change Request 38.
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