ML082730520

Supplement to License Amendment, Technical Specification Change Request No. 330 Deletion of Technical Specification Requirements for Review & Audit, & Additional Administrative Changes

ML082730520
Person / Time
Site:	Three Mile Island
Issue date:	09/29/2008
From:	Cowan P AmerGen Energy Co, Exelon Corp
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
5928-08-20178
Download: ML082730520 (5)

Text

10 CFR 50.90 5928-08-20178 September 29, 2008 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:

Supplement to License Amendment Request for TMI Unit 1 Technical Specification Change Request No. 330 Deletion of Technical Specification Requirements for Review and Audit, and Additional Administrative Changes

Reference:

Letter from Pamela B. Cowan to U.S. NRC, "Oyster Creek Technical Specification Change Request No. 336, TMI Unit 1 Technical Specification Change Request No. 330, Deletion of Technical Specification Requirements for Review and Audit, and Additional Administrative Changes," dated November 13, 2007 In Reference 1, AmerGen Energy Company, LLC (AmerGen) requested NRC approval for the deletion of Oyster Creek Nuclear Generating Station (OCNGS) and Three Mile Island Unit 1 (TMI) Technical Specification (TS) 6.5, Review and Audit requirements.

SUbsequently, through an internal TMI audit, two additional changes were identified that should have been included in the TMI portion of the submittal. Two references to the proposed deleted TS 6.5 sections, which should have been included in the referenced submittal, had not been identified during the review process. Specifically, TS 6.6.1.b references the proposed deleted TS 6.5.2.5.d and TS 6.17.1.2 references the proposed deleted TS 6.5.1. These additional changes are administrative in nature and the attached TS markups are requested to be included in the review and approval of the reference license amendment request. This issue has been entered into our corrective action program.

The technical justification for deletion of TS 6.6.1.b (independent safety reviews for reportable events) is bounded by the technical analysis section for TS 6.5.2.5.d of the referenced license amendment request. The technical justification for deletion of TS 6.17.1.2 (independent technical reviews for major changes to radioactive waste treatment systems) is bounded by the technical analysis section for TS 6.5.1.11 of the referenced license amendment request. In addition, TS 6.6.1.a (NRC notification per 10 CFR 50.73) will be grammatically changed to remove the word "and" due to the deletion of TS 6.6.1.b.

U.S. Nuclear Regulatory Commission September 29, 2008 Page 2 of 2 OCNGS corresponding TS sections were reviewed and found not to require similar changes. provides the additional proposed TMI Technical Specification Marked-Up Pages.

AmerGen has concluded that the supplemental proposed changes do not require a change to the original no significant hazards consideration of the referenced license amendment request.

Pursuant to 10 CFR 50.91 (b)(1), a copy of this supplemental license amendment request is being provided to the designated officials of the Commonwealth of Pennsylvania, as well as the chief executives of the township and county in which the facility is located.

We request approval of the proposed supplemental amendment by November 13, 2008. Upon approval, the supplemental TS changes will be implemented concurrent with the referenced license amendment request (Le., 60 days of issuance).

No new regulatory commitments are established by this submittal.

If any additional information is needed, please contact Frank Mascitelli at (610) 765-5512.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 29th day of September 2008.

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

Attachment:

1) Supplement to TMI Unit 1 Technical Specification Change Request No. 330 Proposed Technical Specification Marked-Up Pages cc: S. J. Collins, Administrator, USNRC Region I D. M. Kern, USNRC Senior Resident Inspector, TMI Unit 1 P. J. Bamford, USNRC 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

Attachment 1 Supplement to TMI Unit 1 Technical Specification Change Request No. 330 Proposed Technical Specification Marked-Up Pages The pages included in this attachment are:

6-10 6-25

6.6 REPORTABLE EVENT ACTION 6.6.1 The following actions shall be taken for REPORTABLE EVENTS:

a. The Nuclear Regulatory Commission shall be notlfied and : ~ubmitted pursuant to the requirements of Section 50.73 to 10 CFR 5~~

'-.b. Each REPORTABL VENT shall pursuant to SpecIfi ion 6.5.2.5.d.

unde~o

/'

an independent ety review )

6.7 SAFETY L ; ;VlOLATION '\ DE""Ll:fJ 6.7.1 The following actions shaH be taken in the event a safety limit is violated:

a. The reactor shall be shutdown and operation shall not be resumed until authorized by the Nuclear Regulatory Commission.

b. An immediate report shall be made to the Plant Manager, and Vice President-TMI Unit I, and the event shall be reported to NRC in accordance with 10 CFR 50.72.

c. A complete analysis of the circumstances leading up to and resulting from the occurrence shall be prepared by the unit staff. This report shaH include analysis of the effects of the occurrence and recommendations concerning operation of the unit and prevention of recurrence. This report shall be submitted to the Plant Manager and the Vice President-TMI Unit I. The safety limit violation report shall be submitted to NRC in accordance with 10 CFR 50.73.

6-10 Amendment No. 1I,77, 129, 157, 179,m, 219

6.17 MAJOR CHANGES TO RADIOACTIVE WASTE TREATMENT SYSTEMS 6.17.1 Licensee initiated safety related changes to the radioactive waste system (liquid, gaseous and solid):

1. Shall be reported to the Commission in the Annual Report (Specification 6.9.1 B) for the period in which the evaluation was reviewed. The discussion of each change shall contain:

a. A summary of the evaluation that led to the determination that the change could be made in accordance with 10 CFR 50.59;

b. Sufficient detailed information to totally support the reason for the change without benefit of additional or supplemental information;

c. A detailed description of the equipment. components and processes involved and the interfaces with other plant systems;

d. An evaluation of the change which shows the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid waste that differ from those previously predicted in the license application and amendments thereto;

e. An evaluation of the change which shows the expected maximum exposures to individuals in the unrestricted area and to the general population that differ from those previously estimated in the license application and amendments thereto;

1. A comparison of the predicted releases of radioactive materials. in liquid and gaseous effluents and in solid waste, to the actual releases for the period prior to when the changes are to be made;

g. An estimate of the exposure to plant operating personnel as a result of the change; and

h. Documentation of the fact that the change was reviewed and approved.

Shall become eff~tive upon review nd approval in accfdance with Section 6.5.1. I OeiLt!Tt::"'

6.18 TECHNICAL SPECIFICATIONS (TS) BASES CONTROL PROGRAM This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

6-25 Amendment No. 72, 77, 102, 173, 207, 218, 256