ML092990645

Electronic Transmission, Draft RAI Regarding License Amendment Request to Adopt TSTF-490-A, Deletion of E Bar Definition & Revision to Reactor Coolant System Specific Activity TS

ML092990645
Person / Time
Site:	Three Mile Island
Issue date:	10/27/2009
From:	Peter Bamford Plant Licensing Branch 1
To:	Chernoff H Plant Licensing Branch 1
Bamford, Peter J., NRR/DORL 415-2833
References
Download: ML092990645 (4)

Text

October 27, 2009 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Peter Bamford, Project Manager /RA/

Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

THREE MILE ISLAND, UNIT NO. 1 - ELECTRONIC TRANSMISSION, DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT TSTF-490-A, DELETION OF E BAR DEFINITION AND REVISION TO REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY TECHNICAL SPECIFICATON The attached draft request for additional information (RAI) was transmitted by electronic transmission on October 26, 2009 to Ms. Wendi Croft, at Exelon Generation Company, LLC (Exelon, the licensee). This draft RAI was transmitted to facilitate the technical review being conducted by the Nuclear Regulatory Commission (NRC) staff and to support a conference call (if needed) with Exelon in order to clarify the licensees amendment request regarding the proposed deletion of the E Bar definition and a revision to Reactor Coolant System Activity technical specifications. The draft RAI is related to the licensees submittal dated November 6, 2008. The draft questions were sent to ensure that they were understandable, the regulatory basis was clear, and to determine if the information was previously docketed. Additionally, review of the draft RAI would allow Exelon to evaluate and agree upon a schedule to respond to the RAI. This memorandum and the attachment do not represent an NRC staff position.

Docket Nos. 50-289

Enclosure:

As stated

October 27, 2009 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Peter Bamford, Project Manager /RA/

Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

THREE MILE ISLAND, UNIT NO. 1 - ELECTRONIC TRANSMISSION, DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO ADOPT TSTF-490-A, DELETION OF E BAR DEFINITION AND REVISION TO REACTOR COOLANT SYSTEM SPECIFIC ACTIVITY TECHNICAL SPECIFICATON The attached draft request for additional information (RAI) was transmitted by electronic transmission on October 26, 2009 to Ms. Wendi Croft, at Exelon Generation Company, LLC (Exelon, the licensee). This draft RAI was transmitted to facilitate the technical review being conducted by the Nuclear Regulatory Commission (NRC) staff and to support a conference call (if needed) with Exelon in order to clarify the licensees amendment request regarding the proposed deletion of the E Bar definition and a revision to Reactor Coolant System Activity technical specifications. The draft RAI is related to the licensees submittal dated November 6, 2008. The draft questions were sent to ensure that they were understandable, the regulatory basis was clear, and to determine if the information was previously docketed. Additionally, review of the draft RAI would allow Exelon to evaluate and agree upon a schedule to respond to the RAI. This memorandum and the attachment do not represent an NRC staff position.

Docket Nos. 50-289

Enclosure:

As stated DISTRIBUTION:

Public RidsNrrPMPBamford LPL1-2 R/F Accession No.: ML092990645

• via email OFFICE LPL1-2/PM AADB/BC NAME PBamford RTaylor*

DATE 10/27/09 10/19/2009 OFFICIAL RECORD COPY

DRAFT 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 NO. 50-289 By letter dated November 6, 2008, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML083120122), supplemented by letters dated December 11, 2008, (ADAMS Accession No. ML083470249), and July 2, 2009 (ADAMS Accession No. ML091870996), AmerGen Energy Company, LLC (the licensee, now Exelon Generation Company, LLC) submitted a license amendment request (LAR) regarding proposed changes to the technical specifications (TSs) for Three Mile Island, 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 (DEX) definition that would replace the current E Bar average disintegration energy definition. In addition, the current dose equivalent Iodine-131 (DEI) definition would be revised. The licensee states in the application that the changes are consistent with Technical Specification Task Force (TSTF) change traveler TSTF-490-A, Revision 0, Deletion of E Bar Definition and Revision to Reactor Coolant System Specific Activity Technical Specification Using the Consolidated Line Item Improvement Process. The Nuclear Regulatory Commission staff has been reviewing the submittal and has determined that additional information is needed to complete its review.

In the subject LAR, the licensee proposed TS changes to revise Limiting Condition for Operation (LCO) 3.1.4, Reactor Coolant System (RCS) Activity, APPLICABILITY requirements and Table 4.1-3, Minimum Sampling Frequency. The APPLICABILITY requirements are changed to At all times except REFUELING SHUTDOWN and COLD SHUTDOWN. The proposed change also modifies Item 1.a in Table 4.1-3 to require this surveillance only during POWER OPERATION, even though the APPLICABILITY covers other lower modes. This eliminates the HOT STANDBY, START-UP and HOT SHUTDOWN modes for normal DEX sampling. Similarly, for DEI, Item 1.b.ii is modified to only require sampling during POWER OPERATION, eliminating the START-UP and HOT STANDBY modes. The DEI sampling change is not evaluated by TSTF-490-A, nor is it evaluated in the LAR, beyond a comparison with NUREG-1430 Standard Technical Specifications Babcock and Wilcox Plants.

The NRC staff has a concern about the proposed changes described above. The proposed changes revise conditions for sampling and may exclude sampling during the plant conditions where LCO 3.1.4 may be exceeded. After transient conditions (i.e. reactor trip, plant depressurization, shutdown or startup) that end in plant conditions other than POWER OPERATION, sampling is not required to be performed. Radioisotopic spiking and potentially fuel failures are more likely to occur because of the transient plant conditions (i.e. reactor trip, plant depressurization, shutdown or startup), than at steady state operations. Currently the TMI-1 TSs provide a method for DEI sampling after transients and power changes that change RATED THERMAL POWER more than 15%.

Because LCO 3.1.4 could potentially be exceeded after a plant transient or power change, please justify why sampling for DEX and DEI is no longer needed in the plant conditions or modes that are proposed to be eliminated and justify how the LCO remains consistent with the design bases analysis from which the LCO limits are derived (i.e. main steamline break, steam generator tube rupture etc.). Furthermore, please justify why there is an apparent disparity between the modes of applicability (At all times except REFUELING SHUTDOWN and COLD SHUTDOWN) and the limited mode (POWER OPERATION) under which the surveillances are required.