ML021420021

Request for Additional Information Emergency Feedwater Technical Specification Change Request (Tac No. MB3660)

ML021420021
Person / Time
Site:	Three Mile Island
Issue date:	05/23/2002
From:	Colburn T NRC/NRR/DLPM/LPD1
To:	Skolds J Exelon Generation Co
Colburn T, NRR/DLPM, 415-1402
References
TAC MB3660
Download: ML021420021 (5)

Text

May 23, 2002 Mr. John L. Skolds, President and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

THREE MILE ISLAND NUCLEAR STATION, UNIT 1 (TMI-1), REQUEST FOR ADDITIONAL INFORMATION RE: EMERGENCY FEEDWATER (EFW)

TECHNICAL SPECIFICATION (TS) CHANGE REQUEST (TAC NO. MB3660)

Dear Mr. Skolds:

The Nuclear Regulatory Commission (NRC) staff has determined that it will need the enclosed additional information in order to complete its review of your December 19, 2001, application for changes to the TMI-1 EFW TSs. As discussed with your staff during a telephone call on May 16, 2002, we request that you provide the requested information within 30 days receipt of this letter.

If you have any questions, please contact me at 301-415-1402.

Sincerely,

/RA/

Timothy G. Colburn, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

Request for Additional Information cc w/encl: See next page

May 23, 2002 Mr. John L. Skolds, President and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

THREE MILE ISLAND NUCLEAR STATION, UNIT 1 (TMI-1), REQUEST FOR ADDITIONAL INFORMATION RE: EMERGENCY FEEDWATER (EFW)

TECHNICAL SPECIFICATION (TS) CHANGE REQUEST (TAC NO. MB3660)

Dear Mr. Skolds:

The Nuclear Regulatory Commission (NRC) staff has determined that it will need the enclosed additional information in order to complete its review of your December 19, 2001, application for changes to the TMI-1 EFW TSs. As discussed with your staff during a telephone call on May 16, 2002, we request that you provide the requested information within 30 days receipt of this letter.

If you have any questions, please contact me at 301-415-1402.

Sincerely,

/RA/

Timothy G. Colburn, Senior Project Manager, Section 1 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION PUBLIC RLaufer JBongarra PDI-1 Reading BPlatchek, RI SRichards MOBrien TColburn DTrimble ACCESSION NO.: ML021420021 *RAI input dated 05/01/02. No substantive changes made.

OFFICE PDI-1\PM PDI-2\LA IOLB\SC PDI-1\SC NAME TColburn SLittle for DTrimble* RLaufer MOBrien DATE 05/22/02 05/22/02 05/01/02 05/23/02 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION THREE MILE ISLAND NUCLEAR STATION, UNIT 1 (TMI-1)

EMERGENCY FEEDWATER (EFW) SYSTEM TECHNICAL SPECIFICATION (TS) CHANGE REQUEST DOCKET NO. 50-289

1. What is the minimum amount of time allowable for an individual to realign the valves to their operational positions in the event an EFW transient were to occur while performing this surveillance test? Also, please clarify: Using Figure 1 from the licensees December 19, 2001, submittal as a basis, identify which valves require manual actions and the relative distances between them. Also, identify the transit time between valves and, how much time and effort are required for an individual to manually realign each valve?

2. What is the basis for determining that an individual can successfully and reliably accomplish the required actions in the minimum allowable time under conditions that simulate the real event? For example, during an EFW transient event, are there harsh environmental factors such as radiation, excessive heat, noise, etc., that would hamper an individual from performing the required manual valve realignment and, if there are impediments, have they been considered in determining whether an individual can perform the required actions?

3. What are the consequences if the individual fails to perform the actions (i.e., valve realignment) in the allotted time?

4. The licensee (page 4 of 6 of Attachment 1 of the December 19, 2001, submittal) defines the individual performing the EFW surveillance as follows:

A dedicated qualified individual is defined in the revised Bases to be one who is involved exclusively with the EFW surveillance testing....."

However, the individual is not solely responsible for valve realignment but also has as his principal responsibility, EFW testing. The licensee, in its response, has changed the meaning of the term "dedicated" from its previous usage (see Attachment 3 of the licensees December 19, 2001 submittal, the licensees December 6, 2000, submittal, discussion on page 14 of 20). The individual, as described by the licensee in its December 19, 2001, submittal, is "designated," not dedicated because he has additional responsibilities relative to the function of valve realignment. Either term and set of responsibilities is appropriate, i.e., either the individual is "dedicated" exclusively to the valve manipulation, the action for which the licensee is seeking credit or, the individual is "designated" (i.e., can perform other tasks in addition to the principal task (which is valve realignment) such as EFW testing).

Enclosure

Three Mile Island Nuclear Station, Unit No. 1 cc:

Site Vice President - Three Mile Island Nuclear Senior Resident Inspector (TMI-1)

Station Unit 1 U.S. Nuclear Regulatory Commission AmerGen Energy Company, LLC P.O. Box 219 P. O. Box 480 Middletown, PA 17057 Middletown, PA 17057 Director - Licensing - MId-Atlantic Regional Senior Vice President Nuclear Services Operating Group Exelon Generation Company, LLC Exelon Generation Company, LLC 4300 Winfield Road Nuclear Group Headquarters Warrenville, IL 60555 Correspondence Control P.O. Box 160 Vice President - Mid-Atlantic Operations Support Kennett Square, PA 19348 Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N David J. Allard, Director Kennett Square, PA 19348 Bureau of Radiation Protection Pennsylvania Department of Senior Vice President - Environmental Protection Mid Atlantic Regional Operating Group P.O. Box 8469 Exelon Generation Company, LLC Harrisburg, PA 17105 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Three Mile Island Nuclear Station Unit 1 Plant Manager Vice President - AmerGen Energy Company, LLC Licensing and Regulatory Affairs P. O. Box 480 Exelon Generation Company, LLC Middletown, PA 17057 4300 Winfield Road Warrenville, IL 60555 Regulatory Assurance Manager - Three Mile Island Unit 1 Regional Administrator AmerGen Energy Company, LLC Region I P.O. Box 480 U.S. Nuclear Regulatory Commission Middletown, PA 17057 475 Allendale Road King of Prussia, PA 19406 John F. Rogge, Region I U.S. Nuclear Regulatory Commission Chairman 475 Allendale Road Board of County Commissioners King of Prussia, PA 19406 of Dauphin County Dauphin County Courthouse Michael A. Schoppman Harrisburg, PA 17120 Framatome ANP Suite 705 Chairman 1911 North Ft. Myer Drive Board of Supervisors Rosslyn, VA 22209 of Londonderry Township R.D. #1, Geyers Church Road Middletown, PA 17057

Three Mile Island Nuclear Station, Unit No. 1 cc: continued Vice President, General Counsel and Secretary Exelon Generation Company, LLC 300 Exelon Way Kennett Square, PA 19348 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Eric Epstein TMI Alert 4100 Hillsdale Road Harrisburg, PA 17112 Correspondence Control Desk Exelon Generation Company, LLC 200 Exelon Way, KSA 1-N-1 Kennett Square, PA 19348 Manager Licensing - Oyster Creek and Three Mile Island Exelon Generation Company, LLC Nuclear Group Headquarters Correspondence Control P.O. Box 160 Kennett Square, PA 19348