ML090990726

Request for Additional Information Regarding License Amendment Request to Adopt Technical Specification Task Force Traveler TSTF-490-A

ML090990726
Person / Time
Site:	Three Mile Island
Issue date:	06/24/2009
From:	Peter Bamford Plant Licensing Branch 1
To:	Pardee C Exelon Generation Co, Exelon Nuclear
Bamford, Peter J., NRR/DORL 415-2833
References
TAC ME0100
Download: ML090990726 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 24, 2009 Mr. Charles Pardee President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville,IL 60555 SUB~IECT: THREE MILE ISLAND NUCLEAR STATION, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT TECHNICAL SPECIFICATION TASK FORCE TRAVELER TSTF-490-A (TAC NO. ME0100)

Dear Mr. Pardee:

By letter dated November 6, 2008 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML083120122), supplemented by letter dated December 11, 2008, (ADAMS Accession No. ML083470249), AmerGen Energy Company, LLC (the licensee, now Exelon Generation Company, LLC) submitted a license amendment request regarding proposed changes to the technical specifications (TSs) for Three Mile Island Nuclear Station, Unit 1 (TMI-1). The proposed amendment would replace the current TMI-1 TS limit on Reactor Coolant System (RCS) gross specific activity with a new limit on RCS noble gas specific activity. The noble gas specific activity limit would be based on a new dose equivalent Xenon-133 definition that would replace the current E Bar average disintegration energy definition. In addition, the current dose equivalent lodine-131 definition would be revised.

The Nuclear Regulatory Commission staff has been reviewing the submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information. The questions were sent via electronic transmission on May 1, 2009, to Ms. Wendi Croft of your staff. The draft questions were sent to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. The questions were discussed in a teleconference with your staff on June 4,2009. It was agreed that a response would be submitted by July 10, 2009. If a response is not received by that date, the license amendment request will be subject to denial, pursuant to Title 10 of the Code of Federal Regulations, Section 2.108, "Denial of application for failure to supply information."

-2 Please contact me at 301-415-2833, if you have any questions.

Sincerely, rJd~~f~1.fT""'I7 Peter Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

As stated cc: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 REQUEST FOR ADDITIONAL INFORMATION THREE MILE ISLAND, UNIT 1 LICENSE AMENDMENT REQUEST TO ADOPT TSTF-490-A, DELETION OF E BAR DEFINITION AND REVISION TO REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY TECHNICAL SPECIFICATON DOCKET 1\10. 50-289 By letter dated November 6,2008, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML083120122), supplemented by letter dated December 11,2008, (ADAMS Accession No. ML083470249), AmerGen Energy Company, LLC (the licensee, now Exelon Generation Company, LLC) submitted a license amendment request regarding proposed changes to the technical specifications (TSs) for Three Mile Island, Unit 1 (TMI-1). The proposed amendment would replace the current TIVII-1 TS limit on Reactor Coolant System (RCS) gross specific activity with a new limit on RCS noble gas specific activity. The noble gas specific activity limit would be based on a new dose equivalent Xenon-133 (DEX) definition that would replace the current E Bar average disintegration energy definition. In addition, the current dose equivalent lodine-131 (DEI) definition would be revised. The Nuclear Regulatory Commission (NRC) staff has been reviewing the submittal and has determined that additional information is needed to complete its review.

1.) The proposed Inserts 1 and 2 contained in the letter dated November 6, 2008, provide definitions for DEI and DEX, respectively. These definitions indicate that DEI and DEX may be determined using several references for dose conversion factors (DCFs). However, the purpose of the limiting condition for operation (LCO) for DEI and DEX is to satisfy Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, criterion 2, which establishes an operating restriction that is an initial condition of a design-basis accident (DBA). When surveillance of the RCS radionuclides is performed, each acceptable set of DCFs will yield a different DEI and DEX. As approved by the NRC staff, the intent of Technical Specification Task Force Traveler (TSTF)-490 was to allow the licensee to select, from the acceptable list, one DCF reference for the calculation of DEI, and one DCF reference for the calculation of DEX. Therefore, consistent with 10 CFR 50.36 and TSTF-490, the licensee should specify one DCF reference for each definition, which will be consistent with the specified LCO and DBA analysis, or justify why a list of several DCFs is consistent with the specified LCO and DBA analysis. Therefore, please justify how the use of multiple DCFs maintains consistency with the specified LCO values and DBA analyses or provide revised definitions for DEI and DEX that specify one DCF reference for each definition.

Enclosure

-2 2.) Consistent with the safety evaluation for TSTF-490, please confirm that the site specific limits for both DEI and DEX, and the DCFs used for the determination of DEI and DEX surveillances, are consistent with the current design bases radiological dose consequence analyses (for example, steam generator tube rupture and main steam line break). For DEX, please provide the information necessary (dose conversion factors and RCS radioisotopic concentrations) for the NRC staff to verify the proposed value in the LCO.

3.) The proposed TS Table 4.1-3, item 1(a) requires a verification that DEX is less than or equal to 797 microcuries/gram. The TS bases submitted with the application letter dated November 6, 2008 (Insert 6), state that "Due to the inherent difficulty in detecting [Krypton] Kr-85 in a reactor coolant sample due to masking from radioisotopes with similar decay energies, such as [Fluorine] F-18 and 1-134, that it is acceptable to include the minimum detectable activity of Kr-85 in the [surveillance requirement] SR Table 4.1-3 calculation."

If no or little "masking" occurs, the use of the minimum detectible activity of Kr-85 would underestimate the amount of Kr-85 present in the reactor coolant sample.

Therefore, please justify why use of the minimum detectable Kr-85 is an acceptable and conservative approach for performing this surveillance.

4.) Inserts 4 and 5, contained in the letter dated November 6, 2008, refer to REFUELING as a mode in capital letters, indicating that REFUELING is defined in the TS Definition section. However, the current TMI-1 TS Definition section contains references to REFUELING SHUTDOWN, REFUELING OPERATION, and REFUELING INTERVAL, but not REFUELING. Please clarify the intended mode of applicability relating to inserts 4 and 5.

-2 Please contact me at 301-415-2833, if you have any questions.

Sincerely,

/raJ Peter Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

As stated cc: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsOgcRp Resource LPLI-2 R/F RidsAcrsAcnw_MailCTR Resource RidsNrrPMPBamford Resource RidsNrrDraAadb Resource RidsRgn1MailCenter Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl1-2 Resouce JWiliiams, NRR RGrover, NRR RidsNrrLAABaxter Resource MBlumberg, NRR ADAMS Accession Number" ML090990726 OFFICE LPL1-2/PM LPL1-2/LA MDB/BC LPLI-2/BC NAME PBamford ABaxter RTaylor HChernoff DATE 6/4/09 6/10/09 6/16/09 6/24/09 OFFICIAL RECORD COPY