ML20137L569

Response Supporting NRC Motion to Conform Proposed Tech Specs,Modifying & Adding Limiting Conditions for Operation to More Correctly State Sys & Equipment Needed Per Amend of Order.Certificate of Svc Encl

ML20137L569
Person / Time
Site:	Three Mile Island
Issue date:	09/11/1985
From:	Ridgway D GENERAL PUBLIC UTILITIES CORP., SHAW, PITTMAN, POTTS & TROWBRIDGE
To:	Atomic Safety and Licensing Board Panel
References
CON-#385-478 OLA, NUDOCS 8509120432
Download: ML20137L569 (5)

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'l 00CKETED USNRC September 11, 1985

'85 SEP 12 mo:25 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION k-fgf7 g}C S BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY, ) Docket No. 50-320 OLA et al. )

)

(Three Mile Island Nuclear )

Station, Unit No. 2) )

LICENSEE'S RESPONSE TO STAFF'S MOTION TO CONFORM PROPOSED TECHNICAL SPECIFICATIONS IN ACCORDANCE WITH AUGUST 8, 1985 AMENDMENT OF ORDER By Order of the Director, Office of Nuclear Reactor Regu-lation, dated February 11, 1980, the Commission established a set of formal license requirements reflecting the post-accident condition of the TMI-2 facility and assuring the continued maintenance of the current safe, stable, long-term cooling con-4 dition of the facility. The February 11 Order further provided that the requirements of the proposed Technical Specifications (attached to the Order) were immediately effective, with an op-portunity for hearing prior to the effectiveness of the pro-posed formal license amendment. At the time the February 11-Order was issued, both the Staff and Licensee anticipated that, during the pendency of this matter, changes in the proposed Technical Specifications might be necessary as the facility i status evolves as a result of ongoing recovery efforts.

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On August 8, 1985, the Director of the NRC Office of Nu-clear Reactor Regulation issued'an " Amendment of Order,"1!

revising.the Proposed Technical Specifications (1) to modify existing limiting conditions for operation to more correctly reflect the systems and equipment necessary based on the pres-ent status of TMI-2, (2) to add nev limiting conditions for op-eration to more correctly state the systems and equipment nec-essary based on the present status of TMI-2, and (3) to modify the bases to appropriately reflect corresponding changes in limiting conditions for operation.

By the August 28, 1985 "NRC Staff Notice of Issuance of Amendment of Order and Motion to Conform Proposed Technical Specifications In Accordance Therewith," the Staff has moved that the proposed Technical Specifications attached to the February 11, 1980 Order be formally modified in accordance with the August 8, 1985 " Amendment of Order," subject to the author-ity which 10 C.F.R. 52.717(b) reserves to the presiding officer in this proceeding.

As Licensee understands the Staff's motion, it is simply a request by the Staff that the Board issue an order notifying 1/ Concurrently issued on August 8, 1985 were (1) an exemp-tion from the requirements of 10 C.F.R. 50, Appendix A, General Design Criteria 34 with respect to the residual heat removel system, and (2) an exemption from the re-quirements of 10 C.F.R. 50, Appendix A, General Design Criteria 37 with respect to the testing of the emergency core cooling system.

d all parties that the proposed Technical Specifications under consideration in the prospective hearing requested in this pro-ceeding are revised in accordance with the August 8, 1985

" Amendment of Order." The formal license amendment incorporating the proposed Technical Specifications, as I

amended, would await the outcome of the prospective hearing.

With this understanding, Licensee does not oppose the motion.

Respectfully submitted, SHAW, PITTMAN, FOTTS & TROWBRIDGE By: am_ dpMy Georg6 F. Tro#bridhe9 Pqf.

Delissa A. Ridgway Counsel for Licensee 1800 M Street, N.W.

Washington, D.C. 20036 (202) 822-1000 Dated: September 11, 1985 4

.. h September 11, 1985 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY, ) Docket No. 50-320 OLA et al. )

)

(Three Mile Island Nuclear )

Station, Unit No. 2) )

CERTIFICATE OF SERVICE I hereby certify that copies of " Licensee's Response To Staff's Motion To conform Proposed Technical Specifications In Accordance With August 8, 1985 Amendment of Order" were served this lith day of September, 1985, by deposit in the U.S. mail, j first class, postage prepaid, upon the parties listed on the attached Service List.

NE DeVid pa A. 'NidgwAy U (/

Dated: September 11, 1985

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, . UNITED STATES OF AMERICA  ;

NUCLEAR REGULATORY COMMISSION ,

1 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

METROPOLITAN EDISON COMPANY et al. ) Docket No. 50-320 OLA

)

(Three Mile Island Nuclear )

Station, Unit No. 2) )

SERVICE LIST Administrative Judge Sheldon Docketing and Service Section (3)

J. Wolfe, Chairman Office of the Secretary Atomic Safety and Licensing Board U.S. Nuclear Regulatory *'

U.S. Nuclear Regulatory Commission *-

Commission Washington, D.C. 20555 Washington, D.C. 20555 A*.omic Safety and Licensing Dr. Oscar H. Paris Board Panel U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Atomic Safety and Licensing Washington, D.C. 20555 Board Panel -

Washington, D.C. 20555 Atomic Safety and Licensing Appeal Board Panel Mr. Frederick J. Shon U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C. 20555 Atomic Safety and Licensing Board Panel William D. Paton Washington, D.C. 20555 Office of the Executive Legal Director Stephen H. Lewis, Esquire U.S. Nuclear Regulatory Office of the Executive Commission Legal Director Washington, D.C. 20555 U.S. Nuclear Regulatory

, Comgission Lawrence J. Chandler Washington, D.C. 20555 l Special Litigation Counsel I

Office of the Executive J. H. Johnsrud Legal Director Environmental Coalition on U.S. Nuclear Regulatory Nuclear Power Commission 433 Orlando Avenue Washington, D.C. 20555 State College, PA 16801 Karin W. Carter, Esquire Assistant Attorney General 505 Executive House P.O. Box 2357 Harrisburg, PA 17120

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