ML110540347

Electronic Transmission, Draft Request for Additional Information, Proposed Technical Specification Changes Regarding Relocation of Equipment Load List from Technical Specifications to a Licensee Controlled Document

ML110540347
Person / Time
Site:	Three Mile Island
Issue date:	02/23/2011
From:	Peter Bamford Plant Licensing Branch 1
To:	Chernoff H Plant Licensing Branch 1
Bamford, Peter J., NRR/DORL 415-2833
References
TAC ME4732
Download: ML110540347 (4)

Text

February 23, 2011 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, PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING RELOCATION OF EQUIPMENT LOAD LIST FROM TECHNICAL SPECIFICATIONS TO A LICENSEE CONTROLLED DOCUMENT (TAC NO. ME4732)

The attached draft request for additional information (RAI) was transmitted by electronic transmission on February 22, 2011, to Mr. Frank Mascitelli, 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 (LAR). The LAR proposes to relocate the equipment load list for the Sequence and Power Transfer Test from the Technical Specifications to the Updated Final Safety Analysis Report.

The draft RAI is related to the licensees submittal dated September 22, 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 No. 50-289

Enclosure:

As stated

February 23, 2011 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, PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING RELOCATION OF EQUIPMENT LOAD LIST FROM TECHNICAL SPECIFICATIONS TO A LICENSEE CONTROLLED DOCUMENT (TAC NO. ME4732)

The attached draft request for additional information (RAI) was transmitted by electronic transmission on February 22, 2011, to Mr. Frank Mascitelli, 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 (LAR). The LAR proposes to relocate the equipment load list for the Sequence and Power Transfer Test from the Technical Specifications to the Updated Final Safety Analysis Report.

The draft RAI is related to the licensees submittal dated September 22, 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 No. 50-289

Enclosure:

As stated DISTRIBUTION:

Public RidsNrrPMThreeMileIsland Resource LPL1-2 R/F Accession No.: ML110540347

• via email OFFICE LPL1-2/PM ITSB/BC NAME PBamford RElliott*

DATE 02/23/2011 02/22/2011 OFFICIAL RECORD COPY

DRAFT REQUEST FOR ADDITIONAL INFORMATION THREE MILE ISLAND NUCLEAR STATION, UNIT 1 PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING RELOCATION OF EQUIPMENT LOAD LIST FROM TECHNICAL SPECIFICATIONS TO A LICENSEE CONTROLLED DOCUMENT DOCKET NO. 50-289 By letter dated September 22, 2010 (Agencywide Documents Access and Management System Accession No. ML102650392), 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 relocate the equipment load list from Technical Specification (TS) 4.5.1.1.b from the TS to the Updated Final Safety Analysis Report (UFSAR). In order for the NRC staff to complete its review of the LAR, a response to the following request for additional information is requested.

1.) Title 10 of the Code of Federal Regulations (10 CFR), Paragraph 50.36(b) states, in part: The technical specifications will be derived from the analysis and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to §50.34. The LAR presents a brief description of how the requested changes meet the requirements of 10 CFR 50.36(c)(2)(ii), however it does not explain how the revised TS will comply with the above 10 CFR 50.36(b) requirement(s). Please explain how the revised TS will comply with 10 CFR 50.36(b). The response should include, but not be limited to, an explanation of how the revised TS will ensure that all equipment described in TMI-1 UFSAR Chapter 14 that depends on the sequencer, will be properly tested.

2.) TSs are required to contain surveillance requirements in accordance with the requirements at 10 CFR 50.36(c)(3) which states: Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. Please explain the regulatory process that will ensure that the safety requirements of the safety related equipment proposed for relocation from the TS to the UFSAR will continue to be met.

3.) In the LAR, Attachment 1, Section 4.3, the LAR states that the proposed changes are consistent with Standard Technical Specifications (STS), NUREG-1430, Standard Technical Specifications Babcock and Wilcox Plants. Section 3.0 of Attachment 1 states that the proposed changes are consistent with STS Enclosure

DRAFT surveillance test requirements contained in Surveillance Requirement (SR) 3.8.1.19 and SR 3.8.1.11. The LAR further states that while the performance of the Sequence and Power Test meets the criteria of 10 CFR 50.36(c)(2)(ii) for inclusion in the TS, the listing of equipment being relocated provides little or no safety benefit. However, the proposed relocation of the equipment load list does not include a high level description, in the TS, of the loads that the test is designed to cover, leaving very little description to ensure compliance with 10 CFR 50.36(c)(3). Such a high level description is provided in NUREG-1430, which includes reference to energizing permanently connected Emergency Diesel Generator loads and energizing auto-connected emergency/shutdown loads through the automatic load sequencer. Such a description would be needed to be consistent with the referenced STS, as the application purports.

Please provide an updated version of the proposed TS with a high level description of the equipment load list in the surveillance or provide justification as to why it is not provided.