ML061210039

Biennial 10 CFR 50.59 and Commitment Revision Report for 2004 and 2005

ML061210039
Person / Time
Site:	Three Mile Island
Issue date:	04/19/2006
From:	Chick G E AmerGen Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
5928-06-20442, NEI 99-04
Download: ML061210039 (11)

Text

AmerGen .AmerGen Energy Company, LLC Three Mile Island Unit 1 Route 441 South, P.O. Box 480 Middletown, PA 17057 Telephone:

717-948-8000 An Exelon Company April 19, 2006 5928-06-20442 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 THREE MILE ISLAND UNIT I (TMI UNIT 1)OPERATING LICENSE NO. DPR-50 DOCKET NO. 50-289

SUBJECT:

BIENNIAL 10 CFR 50.59 AND COMMITMENT REVISION REPORT FOR 2004 AND 2005 Enclosed are the 20042005 Biennial 10 CFR 50.59 and Commitment Revision Report as required by 10 CFR 50.59 (d)(2) and SECY-00-0045 (NEI 99-04).There are no regulatory commitments contained in this transmittal.

If you have any questions or require additional information, please contact Adam Miller, of Regulatory Assurance, at 717-948-8128.

Sincerely, Plant Manager GEC/awm Enclosure cc: Administrator, Region I TMI-1 Senior Resident Inspector File 06019 THREE MILE ISLAND UNIT I DOCKET NO. 50-298 BIENNIAL l0CFR 50.59 AND COMMITMENT REVISION REPORT TABLE OF CONTENTS 1OCFR 50.59 Report Modifications Procedure Changes Commitment Revision Report 3 4 5 9 2 AMERGEN ENERGY THREE MILE ISLAND UNIT I DOCKET NO. 50-289 BIENNIAL l0CFR 50.59 REPORT JANUARY 1, 2004 THROUGH DECEMBER 31, 2005 10CFR50.59 EVALUATION SUMMARIES 3 2004-2005 Biennial I OCFR 50.59 and Commitment Revision Report Modifications Title: AH-E-1's Condensate Flow Switch Removal (ECR 04-00601)Year Implemented:

2002 Evaluation Number SE-000823-022 Brief

Description:

Remove from service AH-FS-241 ANB/C, RB Coolers Excessive Condensate flow switches.

These flow switches are the input for Main Alarm Panel (MAP) alarm, B-2-8, URB Clrs Excessive Condensate." Summary of Evaluation:

The sensing lines for the flow switches have become clogged with boron and rust making the switches inoperable.

AH-FS-241 A/B/C are used to monitor reactor coolant leakage inside containment.

Other means are available to detect this leakage so plant operations and its design bases is not impacted.

Only two methods for leak detection are required and this commitment is still met by the remaining instrumentation.

The safety analysis in the UFSAR does not use AH-FS-241 A/B/C indications to mitigate the consequences of an accident.AH-FS-241 A/B/C can be removed from service without impacting the ability to detect a RCS leak. There are three other means available and compliance with Tech. Spec. 3.1.6 and its bases is not compromised.

An evaluation was performed because components with a design function described in the UFSAR is being removed from the plant. There is no impact on the frequency of occurrence or the consequences of any accident or malfunction.

The change removes the flow switches and plugs the drain piping in accordance with applicable codes and standards.

This change can be made without prior NRC approval.*Title: Thermal-Hydraulic Analysis for TMI-1 SFP (ECR TM-05-00617)Year Implemented:

2005 Evaluation Number TM-05-00617 Brief

Description:

This change documents the new analysis of the Spent Fuel Pool (SFP) temperatures associated with core offload scenarios based on 4 2004-2005 Biennial IOCFR 50.59 and Commitment Revision Report cooling water temperature and the design assumptions of the rerack project. This 50.59 review evaluates the new analysis.Summary of Evaluation:

The new analysis is intended to provide a more accurate determination of the SFP temperatures during core offload in order to allow the capability to offload earlier, conditional to system parameters, to support shorter refueling outage duration.The new analysis more accurately determines the bulk temperature of the SFP in relation to offload times and cooling water conditions based on updated methodology and more specific correlations (vs. worst case conditions).

The new analysis allows earlier offload start times based on cooling system conditions.

The analysis is implemented without adversely affecting SFP design requirements as specified in the UFSAR per the original rerack analysis.

This analysis provides bounding criteria to ensure that no systems, structures, or components relevant to spent fuel pool cooling or fuel handling during offload are impacted.Procedure Changes Title: Procedure change to address fire mitigation.

Year Implemented:

2005 Evaluation Number SE-000733-008 Brief

Description:

This change adds preemptive actions to prevent multiple high impedance fault (MHIF) from causing a loss of I B Engineered Safeguards (ES) Motor Control Center (MCC) in the event of a fire in Control Building on elevation 305 (CB-FA-1).

Summary of Evaluation:

The, loss of 1 B ES MCC in the event of a fire in CB-FA-1 could result in loss of all plant remote indication and control, as documented in Issue Report 327038. The recovery of 1 B or 1 D Vital buses, after a loss of I B ES MCC in a fire in CB-FA-1 cannot be accomplished as described in the current procedure revision.

The inverter cannot be started without DC power, as documented in Issue Report 328623.Safety related electrical loads on 1 B ES MCC, which are not essential to achieve safe shutdown for a fire in CB-FA-1 (i.e. not credited in Fire Hazards Analysis 5 2004-2005 Biennial )OCFR 50.59 and Commitmnent Revision Report Report (FHAR) Attachment 3-5), are disabled in order to prevent a fault due to the fire in CB-FA-1 from causing the loss of I B ES MCC. This procedure revision provides a method to prevent loss of 1 B ES MCC in the event of a fire in CB-FA-1. This approach is contingent upon completion of the new actions before a MHIF condition occurred.

The time between event recognition and potential MHIF is not known. This approach is an interim risk reduction measure and does not provide a permanent design solution.

The affected procedure section provides a method to achieve safe shutdown with a fire in CB-FA-1. The safe shutdown equipment relied upon for a fire in CB-FA-1 is not adversely affected by this procedure change. This change can be made without prior NRC approval.NOTE: This interim condition was resolved by a revised MHIF event analysis issued in the fall of 2005. The procedure revision addressed in this 50.59 evaluation was superceded at that time.Title: Procedure revision to uLoss of Control Building Cooling" Year Implemented:

2005 Evaluation Number: SE 000826-016 Brief

Description:

This change provides an allowable operating time, without Control Building ventilation or cooling.Summary of Evaluation:

Entry into this abnormal operating procedure, and plant shutdown, are required for conditions where cooling of safety related Control Building areas may be inadequate.

The procedure directs mitigation actions or plant shutdown within a timeframe supported by analysis to ensure the operability of safety related equipment with the plant operating.

Analysis was performed to demonstrate that safety related equipment operability would not be affected before five hours after a loss of all forced flow, and before eight hours after a loss of both chillers.

This period will be used to determine and correct the cause of a loss of Control Building ventilation or loss of both chillers.If ventilation (or a chiller) cannot be restored, a reactor shutdown shall be initiated and the reactor shall be in cold shutdown in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in accordance with the applicable Technical Specification.

6 2004-2005 Biennial IOCFR 50.59 and Commitment Revision Report The procedure change does not involve any change to the systems, structures, or components associated with the Control Building Ventilation Systems, or an UFSAR described design function.Title: 480-Volt Engineered Safeguards (ES) Bus Cross-Tie Year Implemented:

2005 Evaluation Number: PC 18967 Brief

Description:

Establishes procedure to cross tie 480-Volt ES Buses, during plant shutdown, if both trains of ES power cannot be restored after a Loss of Offsite Power (LOOP).Summary of Evaluation:

The abnormal event procedure for "Loss of Station Power," OP-TM-AOP-020 was revised, and two new Emergency Support Procedures to cross tie the ES power trains at the 480V level were created to provide direction for this activity.A 50.59 evaluation was required because the UFSAR stated that the buses would only be cross-tied for maintenance.

The use of a bus cross tie has the potential to impact the reliability of the Emergency Diesel Generator (EDG) or ES bus by exceeding the equipment load limits.The emergency diesel and ES power train load limits will not be exceeded.

The cross tie will only be closed if the diesel load is less than 2300 kW. The cross tie overload protection will open the cross tie breakers if the load is greater than 650 kW. The emergency diesels are rated for continuous operation at 3000 kW and short-term operation at 3300 kW. All large loads on the buses being energized through the cross tie will be positively controlled by procedure steps before the cross tie is closed to prevent automatic loading. If an ES actuation occurs while the primary ES 4160 V bus is supplied by either emergency diesel, then the cross tie breakers will open to ensure that the primary ES power train can support its ES loads without challenging the EDG load limit.The loads on the ES train being energized will be reduced to ensure the cross tie overload protection is not challenged.

The loads have been reduced to less than 400 kW. Additional loads of up to 250 kW are permitted but only when necessary for event mitigation.

The maximum load permitted by the procedure is less than 650 kW. The cross tie is rated for 650 kW..7 2004-2005 Biennial lOCFR 50.59 and Commitment Revision Report The cross tie overload protection coordinates with the primary ES bus feeder breaker so that a fault on the secondary ES power train will be isolated without affecting the primary ES power train.These procedures will only be performed when the reactor is shutdown and one of ES 4160 V AC buses cannot be energized from either the normal or emergency source.8 2004-2005 Biennial 1OCFR 50.59 and CommitmentRevision Report AMERGEN ENERGY THREE MILE ISLAND UNIT 1 DOCKET NO 50-289 BIENNIAL COMMITMENT REVISION REPORT JANUARY 1, 2004 THROUGH DECEMBER 31, 2005 9 2004-2005 Biennial )OCFR 50.59 and CommilynentRevision Report Letter Source: Exelon Tracking No.: Nature of Commitment:

IE Information Notice 81-05 1981 T0024 Modification of operations procedure to lock closed the station battery disconnect switches when the reactor is critical.Summary of Justification:

The purpose of the original commitment was to provide a second barrier to prevent inadvertent opening of a battery disconnect switch during periodic battery surveillance when the reactor is critical.

Applying tamper seals will-provide the equivalent second barrier and meets the intent of the original commitment.

Letter Source: Exelon Tracking No.: Nature of Commitment:

TMI-1 Inspection Report 1986-06 1988T0075 Ensure proper logging of thermal cycles on the High Pressure Injection (HPI) nozzles.Summary of Justification:

The commitment, 1988T0075, references procedure 1202-8, "CRD Equipment Failure." Procedure 1202-8 has been deleted and replaced by several other procedures.

None of these procedures address events, which require thermal cycle log entries or have any effect on HPI nozzle thermal cycles.Letter Source: Exelon Tracking No.: Nature of Commitment:

5211-84-2072, "Control of Heavy Loads" 1984T0055 The development of an annual crane operator retraining program.Summary of Justification:

ANSI 830.2 1976 and subsequent 2001 edition do not require annual training retraining.

Training needs analysis is used to address training requirements.

In addition, review of NUREG 0612, Control of Heavy Loads at Nuclear Power Plants, identified it does not impose qualification requirements beyond ANSI B30.2.10 2004-2005 Biennial JOCFR SO.S9 and Commitment Revision Report End of Commitment Revision Report 11