ML041210215
| ML041210215 | |
| Person / Time | |
|---|---|
| Site: | Crane  (DPR-050) |
| Issue date: | 04/23/2004 |
| From: | Gallagher M AmerGen Energy Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| 5928-04-20095 | |
| Download: ML041210215 (10) | |
Text
1, I..
I AmerGenSM AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com An Exelon Company 10 CFR 50.90 April 23, 2004 5928-04-20095 U.S. Nuclear Regulatory Commission An-N: Document Controi Desk Washington, D.C. 20555-0001 Three Miil Island Nuclear Station, Unit 1 Facility Operating License No. DPR-50 NRC Docket No. 50-289
Subject:
Technical Specification Change Request No. 321 - Application for Technical Specification Improvement to Eliminate Requirements for Post Accident Sampling System for Babcock and Wilcox Reactors Using the Consolidated Line Item Improvement Process in accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," AmerGen Energy Company, LLC (AmerGen) proposes changes to Appendix A, Technical Specifications (TS), ot the Three Mile Island Nuclear Station, Unit 1 (TMI Unit 1),
Facility Operating License. The proposed change deletes TS Section 6.16, "Post-Accident Sampling Programs NUREG 0737 (lI.B.3, ll.F.1.2)," and thereby eliminates the requirement to have and maintain the Post Accident Sampling System (PASS) at TMI Unit 1. The change is consistent with NRC approved Industry/TS Task Force (TSTF) Standard TS Change Traveler, TSTF-442, "Elimination of Requirements for a Post Accident Sampling System (PASS)." The availability of this TS improvement was announced in the Federal Register, Volume 68, Number 92., "Notice of Availability of Model Application Concerning Technical Specification Improvement To Eliminate Post Accident Sampling Requirements for Babcock and Wilcox Reactors Using the Consolidated Line Item Improvement Process," Pages 25664-25667, on May 13, 2003. This change is consistent in approach with other Exelon/AmerGen and industry applications for tne elimination of requirements for Post Accident Sampling Systems.
This proposed amendment request is subdivided as follows.
- 1. Enclosure 1 provides X description of the proposed change, the requested confirmation of applicability, and plant-specific verifications.
- 2. Enclosure 2 provides the existing TS pages marked-up to show the proposed change.
- 3. Enclosure 3 provides a summary of the regulatory commitments made in this submittal.
Using the standards in 10 CFR 50.92, AmerGen has concluded that these proposed changes do not constitute a significant hazards consideration, as described in the enclosed analysis performed in accordance with 10 CFR 50.91(a)(1). Pursuant to 10 CFR 50.91(b)(1), a copy of this Technical Specification Change Request is provided to the designated official of the Commonwealth of Pennsylvania, Bureau of Radiation Protection, as well as the chief executives of the township and county in which the tacility is located.
.4lI1
5928-04-20095 April 23, 2004 Page 2 We request approval of the proposed change by April 23, 2005, with the amendment being implemented within 180 days of issuance.
These proposed changes have been reviewed by the Plant Operations Review Committee and approved by the Nuclear Safety Review Board.
If you have any questions or require additional information, please contact David J. Distel at (610) 765-5517.
I declare under penalty of perjury that the foregoing is true and correct.
Respectfully, Of-z3 -o' I Executed on Michael P. Gallagher Director, Licensing and Regulatory Affairs AmerGen Energy Company, LLC
Enclosures:
- 1) TMI Unit 1 Technical Specification Change Request No. 321 Description and Assessment
- 2) TMI Unit 1 Technical Specification Change Request No. 321 Markup of Proposed Technical Specification Page Changes
- 3)
TMI Unit 1 Technical Specification Change Request No. 321 List of Regulatory Commitments cc:
H. J. Miller, Administrator, USNRC Region I D. M. Kern, USNRC Senior Resident Inspector, TMI Unit 1 D. M. Skay, USNRC Senior Project Manager, TMI Unit 1 D. Allard, Director, Bureau of Radiation Protection - PA Department of Environmental Resources Chairman, Board of County Commissioners of Dauphin County Chairman, Board of Supervisors of Londonderry Township File No. 03060
ENCLOSURE 1 TMI Unit 1 Technical Specification Change Request No. 321 Description and Assessment
/
Request for TS Change to Eliminate Requirements for PASS Using the Consolidated Line Item Improvement - Description and Assessment Page 1 of 3 ENCLOSURE 1 DESCRIPTION AND ASSESSMENT
1.0 DESCRIPTION
In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," AmerGen Energy Company, LLC (AmerGen) proposes changes to Appendix A, Technical Specifications (TS), for the Three Mile Island Nuclear Station, Unit 1 (TMI Unit 1).
The proposed change deletes TS Section 6.16, "Post-Accident Sampling Programs NUREG 0737 (ll.B.3, Il.F.1.2)," and thereby eliminates the requirement to have and maintain the Post Accident Sampling System (PASS) at TMI Unit 1. The change is consistent with NRC approved Industry/TS Task Force (TSTF) Standard TS Change Traveler, TSTF-442, "Elimination of Requirements for a Post Accident Sampling System (PASS)." The availability of this TS improvement was announced in the Federal Register on May 13, 2003, as part of the Consolidated Line Item Improvement Process (CLIIP).
2.0 ASSESSMENT
2.1 Applicability of Published Safety Evaluation AmerGen has reviewed the safety evaluation published on March 3, 2003 (68 FR 10052) as part of the CLIIP. This verification included a review of the NRC staff's evaluation as well as the supporting information provided to support TSTF-442 (i.e., BAW-2387, "Justification for the Elimination of the Post Accident Sampling System (PASS) from the Licensing Basis of Babcock and Wilcox-Designed Plants," which was submitted to the NRC on June 25, 2001, and the associated NRC safety evaluation dated November 14, 2002). AmerGen has concluded that the justifications presented in the TSTF proposal and the safety evaluation prepared by the NRC staff are applicable to TMI Unit 1 and justify this amendment for the incorporation of the changes to the TMI Unit 1 Technical Specifications.
2.2 Optional Changes and Variations AmerGen is not proposing any variations or deviations from the technical specification changes described in TSTF-442 or the NRC staff's model safety evaluation published on March 3, 2003.
Requirements for installing and maintaining PASS were included in NUREG-0680, Supplement No. 3, "TMI-1 Restart," dated April 1981, and NRC Generic Letter 83-37. This amendment request includes superseding the requirements imposed by NUREG-0680, Supplement No. 3 associated with the TMI Unit 1 PASS, and NRC Generic Letter 83-37.
Request for TS Change to Eliminate Requirements for PASS Using the Consolidated Line Item Improvement - Description and Assessment Page 2 of 3 3.0 REGULATORYANALYSIS 3.1 No Significant Hazards Determination AmerGen has reviewed the proposed no significant hazards consideration determination published on March 3, 2003 (68 FR 10052) as part of the CLIIP. AmerGen has concluded that the proposed determination presented in the notice is applicable to TMI Unit 1 and the determination is hereby incorporated by reference to satisfy the requirements of 10 CFR 50.91 (a).
3.2 Verification and Commitments As discussed in the model safety evaluation published in the Federal Register on March 3, 2003 for this technical specification improvement, plant-specific verifications were performed as follows:
- 1.
AmerGen will develop and maintain contingency plans for obtaining and analyzing highly radioactive samples from the RCS, containment sump, and containment atmosphere.
The contingency plans will be contained in the TMI Unit 1 chemistry procedures and implementation will be completed with the implementation of the License amendment.
Establishment and maintenance of contingency plans is considered a regulatory commitment.
- 2.
The capability for classifying fuel damage events at the Alert level threshold will be established for TMI Unit 1 at radioactivity levels of 300 micro Ci/cc dose equivalent iodine. This capability will be described in the TMI Unit 1 emergency plan and emergency plan implementing procedures and implementation will be completed with the implementation of the License amendment. The capability for classifying fuel damage events is considered a regulatory commitment.
- 3.
AmerGen has established the capability to assess radioactive iodines released to offsite environs. The capability for monitoring iodines will be maintained within the TMI Unit 1 emergency plan and emergency plan implementing procedures. Implementation of this commitment is complete. The capability to monitor radioactive iodines is considered a regulatory commitment.
4.0 ENVIRONMENTAL EVALUATION AmerGen has reviewed the environmental evaluation included in the model safety evaluation published on March 3, 2003 (68 FR 10052) as part of the CLIIP. AmerGen has concluded that the staff's findings presented in that evaluation are applicable to TMI Unit 1 and the evaluation is hereby incorporated by reference for this application.
Request for TS Change to Eliminate Requirements for PASS Using the Consolidated Line Item Improvement - Description and Safety Analysis Page 3 of 3
5.0 REFERENCES
- 1.
Industry/Technical Specifications Task Force Standard Technical Specification Change Traveler TSTF-442, "Elimination of Requirements for a Post Accident Sampling System (PASS)."
- 2.
Federal Register, Volume 68, Number 41, 'Notice of Opportunity To Comment on Model Safety Evaluation on Technical Specification Improvement To Eliminate Post Accident Sampling Requirements for Babcock & Wilcox Reactors Using the Consolidated Line Item Improvement Process," Pages 10052-10057, on March 3, 2003.
- 3.
Babcock & Wilcox Owners Group (BWOG) Topical Report BAW-2387, "Justification for the Elimination for the Post Accident Sampling Stations (PASS) from the Licensing Basis of Babcock & Wilcox Plants," submitted to the NRC on June 25, 2001.
- 4.
Volume 68, Number 92, "Notice of Model Application Concerning Technical Specification Improvement To Eliminate Post Accident Sampling Requirements for Babcock & Wilcox Reactors Using the Consolidated Line Item Improvement Process," Pages 25664-25667, on May 13, 2003.
- 5.
NUREG-0680, Supplement No. 3, "TMI-1 Restart," dated April 1981.
- 6.
NRC Generic Letter No. 83-37, "NUREG-0737 Technical Specifications," dated November 1, 1983.
ENCLOSURE 2 TMI Unit 1 Technical Specification Change Request No. 321 Markup of Proposed Technical Specification Page Changes Revised TS Pages Table of Contents Page v 6-24
CT;OLLE; COY TABLE OF CONs ENTS Section Prim 5
DESIGN FEATURES 5-I
- 5.
SITE I
5.2 CONTAINMENT 5-2 5.2.1 REACTOR BUILDING 5-2 5.2.2 REACTOR BUILDING ISOLATION SYSTEM 5-3 5.3 REACTOR 54 5.3.1 REACTOR CORE 5-4 5.3.2 REACTOR COOLANT SYSTEM 5-4 5.4 NEW AND SPENT FUEL STORAGE FACILITIES 5-6 5.4.1 NEW FUEL STORAGE 5-6 5.4.2 SPENT FUEL STORAGE 5-6 5.5 AIR INTAKE TUNNEL FIRE PROTECTION SYSTEMS 5-8 6
ADMINISTRATIVE CONTROLS 6-1 6.1 RESPONSIBILITY 6-1 6.2 ORGANIZATION 6-1 6.2.1 CORPORATE 6-1 6.2.2 UNIT STAFF 6-1 6.3 UNIT STAFF QUALIFICATIONS 6-3 6.4 TRAINING 6-3 6.5 REVIEW AND AUDIT 6-3 6.5.1 TECHNICAL REVIEW AND CONTROL 6-4 6.5.2 INDEPENDENT SAFETY REVIEW 6-5 6.5.3 AUDITS 6-7 6.5.4 INDEPENDENT ONSITE SAFETY REVIEW GROUP 6-8 6.6 REPORTABLE EVENT ACTION 6-10 6.7 SAFETY LIMIT VIOLATION 6-10 6.8 PROCEDURES AND PROGRAMS 6-11 6.9 REPORTING REQUIREMENTS 6-12
'6.9.1 ROUTINE REPORTS 6-12 6.9.2 DELETED 6-14 6.9.3 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT 6-17 6.9.4 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT 6-IS 6.9.5 CORE OPERATING LIMITS REPORT 6-19 6.10 RECORD RETENTION 6-20 6.11 RADIATION PROTECTION PROGRAM 6-22 6.12 HIGH RADIATION AREA 6-22 6.13 PROCESS CONTROL PROGRAM 6-23 6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM) 6-24 6.15 DELETED 6-24 6.16 C
DELET-6-24 6.17 MAJOR CHANGES TO RADIOACTIVE WASTE TREATMENT SYSTEMS 6-25 Amendment No.11,47-,72-,77-,129,150.47 4
(
CONPFRCWE1 OP 6.14 OFFSTTE DOSE CALCUrLATON MNTL (ODCM) 6.14.1 Licensee initiated changes to the ODCMI:
- 1.
Shall be submitted to the N-sRC in the Annual Radioactive Effluent Release Report for the period m which the changes were made.
This submittal shall contain:
- a.
sufficiently detailed information to justify the changes without benefit of additional or supplemental information;
- b. a determination that the changes did not reduce the accuracy or reliability of dose calculations or setpoint determinations; and
- c.
documentation that the changes have been reviewcd and approved pursuant to 6.8.2.
- 2.
Shall become cffective upon review and approval by licensee management.
6.15 DELETED I
I 6.16
)
6-24 Amendment No.='r, 102, 1 3, 19:, 07 4-I
ENCLOSURE 3 TMI Unit 1 Technical Specification Change Request No. 321 List of Regulatory Commitments The following table identifies those actions committed to by AmerGen Energy Company, LLC (AmerGen) in this document. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.
COMMITMENT Due Date/Event AmerGen will develop and maintain contingency plans for Implemented with the obtaining and analyzing highly radioactive samples from the RCS, implementation of the containment sump, and containment atmosphere. The license amendment contingency plans will be contained in the TMI Unit 1 chemistry procedures and implementation will be completed with the implementation of the License amendment. Establishment and maintenance of contingency plans is considered a regulatory commitment.
The capability for classifying fuel damage events at the Alert level Implemented with the threshold will be established for TMI Unit 1 at radioactivity levels implementation of the of 300 micro CVcc dose equivalent iodine. This capability will be license amendment described in the TMI Unit 1 emergency plan and emergency plan implementing procedures and implementation will be completed with the implementation of the License amendment. The capability for classifying fuel damage events is considered a regulatory commitment.
AmerGen has verified that it has established the ability to assess Complete, capability radioactive iodines released to offsite environs. The capability for currently exists monitoring iodines will be maintained within the TMI Unit 1 emergency plan and emergency plan implementing procedures.
Implementation of this commitment is complete. The capability to monitor radioactive iodines is considered a regulatory commitment.