ML071520229

Additional Information - Technical Specification Change Request No. 333, Relocation of Technical Specification Requirements for Refuel and Spent Fuel Pool Area Radiation Monitors.

ML071520229
Person / Time
Site:	Three Mile Island
Issue date:	05/31/2007
From:	Cowan P AmerGen Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
5928-07-20107
Download: ML071520229 (7)

Text

10 CFR 50.90 10 CFR 50.68 May 31, 2007 5928-07-20107 U S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Facility Operating License No. DPR-50 NRC Docket No. 50-289

Subject:

Additional Information - Technical Specification Change Request No. 333, Relocation of Technical Specification Requirements for Refuel and Spent Fuel Pool Area Radiation Monitors

Reference:

AmerGen letter to USNRC, Technical Specification Change Request No. 333, Relocation of Technical Specification Requirements for Refuel and Spent Fuel Pool Area Radiation Monitors, dated December 12, 2006 The referenced letter requested a change to the TMI Unit 1 Technical Specifications (TS) to relocate the reactor building refueling area and spent fuel storage area radiation monitor operability requirements to the Updated Final Safety Analysis Report (UFSAR) and plant procedures, since these radiation monitors do not meet the criteria for inclusion in the TS as presented in 10 CFR 50.36(c)(2)(ii). During subsequent discussions with the NRC staff the issue of compliance with 10 CFR 50.68(b) was discussed. Accordingly, Enclosure 1 provides a description of the TMI Unit 1 evaluation of current compliance with the Fuel Storage Area Radiation Monitoring requirements of 10 CFR 50.68(b).

Regulatory commitments established by this submittal are identified in Enclosure 2. If any additional information is needed, please contact David J. Distel at (610) 765-5517.

U.S. Nuclear Regulatory Commission May 31,2007 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 31st day of May, 2007.

Respectfully, Pamela B. cowan Director - Licensing & Regulatory Affairs AmerGen Energy Company, LLC

Enclosures:

1) TMI Unit 1 Evaluation of Current Compliance with 10 CFR 50.68(b)

2) List of Commitments cc: S. J. Collins, USNRC Administrator, Region I P. J. Bamford, USNRC Project Manager, TMI Unit 1 D. M. Kern, USNRC Senior Resident Inspector, TMl Unit 1 File No. 06041

ENCLOSURE 1 TMI Unit 1 Evaluation of Current Compliance with 10 CFR 50.68(b)

Enclosure 1 Page 1 of 2 ENCLOSURE 1 TMI Unit 1 Evaluation of Current Compliance with 10 CFR 50.68(b) 10 CFR 50.68(b) Each licensee shall comply with the following requirements in lieu of maintaining a monitoring system capable of detecting a criticality as described in 10 CFR 70.24:

(I) Plant procedures shall prohibit the handling and storage at any one time of more fuel assemblies than have been determined to be safely subcritical under the most adverse moderation conditions feasible by unborated water.

TMI Unit 1 complies with this criterion. Fuel handling procedures are based on the design basis numbers of fuel assemblies assumed in analyses for the new fuel and spent fuel storage racks.

(2) The estimated ratio of neutron production to neutron absorption and leakage (k-effective) of the fresh fuel in the fresh fuel storage racks shall be calculated assuming the racks are loaded with fuel of the maximum fuel assembly reactivity and flooded with unborated water and must not exceed 0.95, at a 95 percent probability, 95 percent confidence level. This evaluation need not be performed if administrative controls and/or design features prevent such flooding or if fresh fuel storage racks are not used.

TMI Unit 1 complies with this criterion for fresh fuel stored in the new fuel storage racks. (This criterion is not applicable for fresh fuel subsequently stored in the spent fuel storage racks.)

(3) If optimum moderation of fresh fuel in the fresh fuel storage racks occurs when the racks are assumed to be loaded with fuel of the maximum fuel assembly reactivity and filled with low-density hydrogenous fluid, the k-effective corresponding to this optimum moderation must not exceed 0.98, at a 95 percent probability, 95 percent confidence level. This evaluation need not be performed if administrative controls and/or design features prevent such moderation or if fresh fuel storage racks are not used.

TMI Unit 1 complies with this criterion for fresh fuel stored in the new fuel storage racks. (This criterion is not applicable for fresh fuel subsequently stored in the spent fuel storage racks.)

(4) If no credit for soluble boron is taken, the k-effective of the spent fuel storage racks loaded with fuel of the maximum fuel assembly reactivity must not exceed 0.95, at a 95 percent probability, 95 percent confidence level, if flooded with unborated water. If credit is taken for soluble boron, the k-effective of the spent fuel storage racks loaded with fuel of the maximum fuel assembly reactivity must not exceed 0.95, at a 95 percent probability, 95 percent confidence level, if flooded with borated water, and the k-effective must remain below 1.0 (subcriticai), at a 95 percent probability, 95 percent confidence level, if flooded with unborated water.

TMI Unit 1 complies with the applicable criterion for the Spent Fuel Pool A Region 1 racks. The Spent Fuel Pool A Region 2 and the Spent Fuel Pool 6 racks have a Technical Specification limit placed on them based on the fuel assembly initial enrichment and burnup. In addition a boron requirement of 600 ppm must be maintained when moving fuel assemblies in either pool to meet the NRC maximum allowable reactivity value under the postulated accident conditions.

Enclosure 1 Page 2 of 2 (5) The quantity of SNM, other than nuclear fuel stored onsite, is less than the quantity necessary for a critical mass.

TMI Unit 1 complies with this criterion based on the SNM, other than nuclear fuel, currently stored at TMI Unit 1.

(6) Radiation monitors are provided in storage and associated handling areas when fuel is present to detect excessive radiation levels and to initiate appropriate safety actions.

Radiation monitors that meet General Design Criteria 63 are located in the fuel handling areas.

These monitors are able to detect radiation levels caused by a fuel handling accident or spent fuel that is too close to the water surface. These monitors have alarms that allow personnel to take appropriate safety actions. Plant procedures require that either these radiation monitors or an equivalent portable monitor must be inservice in order to move fuel.

(7) The maximum nominal U-235 enrichment of the fresh fuel assemblies is limited to five (5.0) percent by weight.

TMI Unit 1 complies with this criterion. The TMI Unit 1 Technical Specifications contain this limit for fresh fuel in the new fuel storage vault and the spent fuel pool A storage racks, and contain a limit of 4.37 percent by weight for fuel stored in the spent fuel pool 8 storage racks.

(8) The FSAR is amended no later than the next update which 9 50.71(e) of this part requires, indicating that the licensee has chosen to comply with 5 50.68(b).

The TMI Unit 1 Updated Final Safety Analysis Report will be amended no later than the next update which 10 CFR 50.71 (e) requires, to indicate that TMI Unit 1 has chosen to comply with 10 CFR 50.68(b).

ENCLOSURE 2 List of Commitments

SUMMARY

OF AMERGEN COMMITMENTS The following table identifies regulatory commitments made in this document by AmerGen. (Any other actions discussed in the submittal represent intended or planned actions by AmerGen. They are described to the NRC for the NRCs information and are not regulatory commitments.)

COMMITMENT TYPE COMMITMENT COMMIlTED DATE OR OUTAGE PROGRAMMATIC The TMI Unit 1 Updated Final Safety Analysis Report will be Update 19 amended no later than the next (Spring 2008) update which 10 CFR 50.71 (e) requires, to indicate that TMI Unit 1 has chosen to comply with