ML050130389

RAI - Missed Surveillance Criteria Based on Technical Specification Task Force (TSTF)-358, Revision 6, and Inclusion of a Bases Control Program

ML050130389
Person / Time
Site:	Three Mile Island
Issue date:	01/19/2005
From:	Colburn T NRC/NRR/DLPM/LPD1
To:	Crane C AmerGen Energy Co
Colburn T, NRR/DLPM, 415-1402
References
TAC MC3653
Download: ML050130389 (5)

Text

January 19, 2005 Mr. Christopher M. Crane President and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) - MISSED SURVEILLANCE CRITERIA BASED ON TECHNICAL SPECIFICATION TASK FORCE (TSTF)-358, REVISION 6, AND INCLUSION OF A BASES CONTROL PROGRAM FOR THREE MILE ISLAND NUCLEAR STATION, UNIT 1 (TMI-1)

(TAC NO. MC3653)

Dear Mr. Crane:

By letter dated June 24, 2004, you submitted a license amendment application to the TMI-1 TSs to revise the required actions and time restraints regarding missed surveillances as stated in TMI-1 TS 4.0.2. Your application also proposed adding a new Section 6.18 to the TSs to provide a Bases Control Program. As discussed with your staff during a January 6, 2005, conference call, the enclosed information relates to the adoption of TSTF-358, Revision 6, by licensees for plants with non-standard (custom) TSs such as TMI-1. We request that you either follow option 1 or option 2 with respect to your proposed amendment request. Your staff indicated during the conference call that option 2 would most likely be your planned course of action. As discussed with your staff, please provide this information within 30 days of 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:

RAI cc w/encl: See next page

Mr. Christopher M. Crane January 19, 2005 President and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) - MISSED SURVEILLANCE CRITERIA BASED ON TECHNICAL SPECIFICATION TASK FORCE (TSTF)-358, REVISION 6, AND INCLUSION OF A BASES CONTROL PROGRAM FOR THREE MILE ISLAND NUCLEAR STATION, UNIT 1 (TMI-1)

(TAC NO. MC3653)

Dear Mr. Crane:

By letter dated June 24, 2004, you submitted a license amendment application to the TMI-1 TSs to revise the required actions and time restraints regarding missed surveillances as stated in TMI-1 TS 4.0.2. Your application also proposed adding a new Section 6.18 to the TSs to provide a Bases Control Program. As discussed with your staff during a January 6, 2005, conference call, the enclosed information relates to the adoption of TSTF-358, Revision 6, by licensees for plants with non-standard (custom) TSs such as TMI-1. We request that you either follow option 1 or option 2 with respect to your proposed amendment request. Your staff indicated during the conference call that option 2 would most likely be your planned course of action. As discussed with your staff, please provide this information within 30 days of 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:

RAI cc w/encl: See next page DISTRIBUTION:

PUBLIC TBoyce OGC DLPM DPR PDI-1 Reading TColburn ACRS DJaffe RLaufer TTjader GMatakas, Rgn-I MOBrien Accession Number: ML050130389 OFFICE PDI-1/PM PDI-1/LA IROB/SC PDI-1/SC NAME TColburn MOBrien TBoyce RLaufer DATE 1/19/05 1/18/05 1/19/05 1/19/05 OFFICIAL RECORD COPY

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

ADOPTION OF TECHNICAL SPECIFICATION TASK FORCE (TSTF)-358, REVISION 6, AND INCLUSION OF A BASES CONTROL PROGRAM The Nuclear Regulatory Commission (NRC) staff has reviewed the TMI-1 licensees June 24, 2004, license amendment request and proposed technical specification (TS) changes. During a conference call on January 6, 2005, the NRC staff provided guidance to the licensees staff for non-standard TS plants to adopt TSTF-358, Revision 6. This guidance is repeated below:

The change to the Standard Technical Specification (STS) surveillance requirement (SR) 3.0.3 that provides flexibility to entering a TS-Required Action based upon a risk evaluation, was approved in the Consolidated Line Item Improvement Process (CLIIP) change known as TSTF-358, Revision 6. CLIIP and TSTF changes are based upon the STS, and units that adopt those changes must either have the STSs or their custom TSs must be equivalent to the STSs in the area of the change.

SR 3.0.3 addresses the situation of a missed surveillance, a surveillance that was not performed within its required frequency, and the resulting implications for considering the surveillance and associated limiting condition for operation not met. To accurately adopt and implement TSTF-358, Rev 6, the custom plant must have or must establish identical requirements for what it means to meet an SR. STS SR 3.0.1 establishes those requirements. So, for a custom-TS plant to adopt TSTF-358, Rev 6, it must do either of the following options:

1. Adopt STS SR 3.0.1 and associated bases, or

2. Show that their custom TS have equivalent requirements to SR 3.0.1, and adopt the STS SR 3.0.1 Bases.

There are four sentences to STS SR 3.0.1, and each sentence is a requirement.

Custom-TS plants not adopting STS SR 3.0.1 must describe how their TSs contain these four elements.

The licensee is requested to either revise its submittal to adopt option 1, or provide the information necessary to show equivalency as required in option 2. Also, the licensee must commit to revise the TMI-1 TS Bases to adopt the STS SR 3.0.1 Bases.

ENCLOSURE

Three Mile Island Nuclear Station, Unit 1 cc:

Site Vice President - Three Mile Island Nuclear Director - Licensing and Regulatory Affairs Station, Unit 1 AmerGen Energy Company, LLC AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-E P. O. Box 480 Kennett Square, PA 19348 Middletown, PA 17057 Rich Janati, Chief Senior Vice President - Nuclear Services Division of Nuclear Safety AmerGen Energy Company, LLC Bureau of Radiation Protection 4300 Winfield Road Department of Environmental Protection Warrenville, IL 60555 Rachel Carson State Office Building P.O. Box 8469 Vice President - Operations, Mid-Atlantic Harrisburg, PA 17105-8469 AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-N Plant Manager - Three Mile Island Nuclear Kennett Square, PA 19348 Station, Unit 1 AmerGen Energy Company, LLC Vice President - Licensing and Regulatory Affairs P. O. Box 480 AmerGen Energy Company, LLC Middletown, PA 17057 4300 Winfield Road Warrenville, IL 60555 Regulatory Assurance Manager - Three Mile Island Nuclear Station, 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 Peter Eselgroth, 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 Senior Resident Inspector (TMI-1)

U.S. Nuclear Regulatory Commission P.O. Box 219 Middletown, PA 17057

Three Mile Island Nuclear Station, Unit 1 cc:

Vice President, General Counsel and Secretary AmerGen Energy Company, LLC 2301 Market Street, S23-1 Philadelphia, PA 19101 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 AmerGen Energy Company, LLC P.O. Box 160 Kennett Square, PA 19348 Manager Licensing - Three Mile Island Nuclear Station, Unit 1 Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Associate General Counsel AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555