ML102290394

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Electronic Transmission, Draft Request for Additional Information Regarding License Amendment Request to Adopt TSTF-425, Relocation of Surveillance Frequencies to a Licensee Controlled Program
ML102290394
Person / Time
Site: Crane Constellation icon.png
Issue date: 08/17/2010
From: Peter Bamford
Plant Licensing Branch 1
To: Chernoff H
Plant Licensing Branch 1
Bamford, Peter J., NRR/DORL 415-2833
References
TAC ME3587
Download: ML102290394 (4)


Text

August 17, 2010 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-425, RELOCATION OF SURVEILLANCE FREQUENCIES TO A LICENSEE CONTROLLED PROGRAM (TAC NO. ME3587)

The attached draft request for additional information (RAI) was transmitted by electronic transmission on August 17, 2010, to Mr. Glenn Stewart, 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 relocation of certain technical specification surveillance frequencies to a licensee-controlled program. The draft RAI is related to the licensees submittal dated March 24, 2010. 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

August 17, 2010 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-425, RELOCATION OF SURVEILLANCE FREQUENCIES TO A LICENSEE CONTROLLED PROGRAM (TAC NO. ME3587)

The attached draft request for additional information (RAI) was transmitted by electronic transmission on August 17, 2010, to Mr. Glenn Stewart, 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 relocation of certain technical specification surveillance frequencies to a licensee-controlled program. The draft RAI is related to the licensees submittal dated March 24, 2010. 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 RidsNrrPMThreeMileIsland Resource LPL1-2 R/F Accession No.: ML102290394 OFFICE LPL1-2/PM NAME PBamford DATE 8/17/10 OFFICIAL RECORD COPY

DRAFT Enclosure REQUEST FOR ADDITIONAL INFORMATION THREE MILE ISLAND NUCLEAR STATION, UNIT 1 PROPOSED RELOCATION OF SURVEILLANCE FREQUENCIES TO A LICENSEE CONTROLLED PROGRAM DOCKET NO. 50-289 By letter dated March 24, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100840205), Exelon Generation Company, LLC (the licensee), submitted a license amendment request (LAR) for Three Mile Island Nuclear Station, Unit 1 (TMI-1). The licensee proposes to modify the TMI-1 Technical Specifications (TSs) by relocating certain surveillance frequencies to a licensee-controlled program through the implementation of Nuclear Energy Institute (NEI) 04-10, Risk-Informed Technical Specifications Initiative 5b, Risk-Informed Method for Control of Surveillance Frequencies. According to the licensee, the changes are consistent with U.S. Nuclear Regulatory Commission (NRC)-approved Technical Specifications Task Force (TSTF) Standard Technical Specifications change TSTF-425, Relocate Surveillance Frequencies to Licensee Control - Risk Informed Technical Specifications Task Force Initiative 5b, Revision 3. In order for the NRC staff to complete its review of the LAR, a response to the following request for additional information (RAI) is requested.

RAI-1

Certain of the proposed specifications do not clearly delineate that only the required frequency of surveillance is controlled by the surveillance frequency control program (SFCP). For example proposed TS 3.5.2.4.g states that Quadrant tilt shall be monitored in accordance with the surveillance frequency control program In order to clearly delineate what the SFCP is authorized to control, this wording should be Quadrant tilt shall be monitored at a frequency in accordance with the surveillance frequency control program or similar wording (italics added). This applies to proposed TSs located on pages 3-34a, 3-35a, 3-59, 4-3, 4-29, 4-39, 4-41, 4-42, 4-43, 4-44, 4-45, 4-46, 4-47, 4-52, 4-52a, 4-54, 4-55, and 4-86 of the LAR. Please provide revised specification pages that incorporate this clarification.

RAI-2

Proposed revised TS 3.14.1.1, relating to periodic inspection of the dikes around TMI, is a site specific specification not contained in NUREG-1430 Standard Technical Specifications Babcock and Wilcox Plants, and therefore not included as a line item in TSTF-425. As described in the LAR, Attachment 3, page 3-59, this surveillance relates directly to protection against external flooding. Attachment 2 of the LAR, page 21 of 23, states that external flooding was evaluated in the IPEEE [Individual Plant Examination for External Events] and a CDF [core damage frequency] estimated, and that this evaluation has not been maintained. Please describe, for a relocated dike surveillance

DRAFT frequency, how an analysis for a surveillance frequency change of the dike inspections would incorporate recent site-specific information and use up-to-date databases, if the external flooding analysis is not maintained. Alternatively, please submit a revised application removing the dike surveillance from the scope of this LAR.