TMI-18-100, Supplement 2 to License Amendment Request - Proposed Changes to Technical Specifications Sections 1.0, Definitions, and 6.0, Administrative Controls for Permanently Defueled Condition

Supplement 2 to License Amendment Request - Proposed Changes to Technical Specifications Sections 1.0, Definitions, and 6.0, Administrative Controls for Permanently Defueled Condition

ML18302A071
Person / Time
Site:	Three Mile Island
Issue date:	10/29/2018
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2018-LLA-0053, TMI-18-100
Download: ML18302A071 (3)

Text

Michael P. Gallagher Exelon Nuclear Exelon Generation © Vice President License Renewal and 200 Exelon Way Kennett Square, PA 19348 610 765 5958 Office 610 765 5658 Fax www.exeloncorp.com m1chaelp.gallagher@exeloncorp.com 10 CFR 50.90 TMl-18-100 October 29, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket Nos. 50-289

Subject:

Supplement 2 to License Amendment Request - Proposed Changes to Technical Specifications Sections 1.0, "Definitions," and 6.0, "Administrative Controls" for Permanently Defueled Condition

References:

1. Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request -

Proposed Changes to Technical Specifications Sections 1.0, "Definitions," and 6.0, "Administrative Controls" for Permanently Defueled Condition," dated November 10, 2017 (NRC Accession No. ML17314A024)

2. Letter from U.S. Nuclear Regulatory Commission to Bryan C. Hanson, (Exelon Generation Company, LLC) "Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; James A. Fitzpatrick Nuclear Power Plant; Lasalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; R. E. Ginna Nuclear Power Plant; and Three Mile Island Nuclear Station, Unit 1 - Issuance of Amendments to Relocate the Staff Qualification Requirements (EPID L-2018-LLA-0053) " dated August 2, 2018 (NRC Accession No. ML18206A282)

3. Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Supplement to License Amendment Request - Proposed Changes to Technical Specifications Sections 1.0, "Definitions," and 6.0, "Administrative Controls" for Permanently Defueled Condition," dated October 10, 2018 (NRC Accession No. ML18283A138)

U.S. Nuclear Regulatory Commission Supplement 2 to TMI License Amendment Request Docket No. 50-289 October 29, 2018 Page 2 By letter dated November 1O, 2017 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a license amendment request (LAA) to the U.S. Nuclear Regulatory Commission (NRC) for the Three Mile Island Nuclear Station, Unit 1 (TMl-1 ). The LAA proposed to revise or remove certain Technical Specifications (TS) Administrative Controls to reflect the permanently defueled condition.

On August 2, 2018, the NRC issued Amendment Number 294 (AMO 294) to TMl-1 (Reference 2). The approved amendment revised TS 6.3 to relocate the licensee's staff qualification requirements to the Exelon Quality Assurance Topical Report (QATR). The implementation of AMO 294 altered TS 6.3 from what was originally submitted in Reference 1.

On October 10, 2018, Exelon supplemented the LAA (Reference 3) to align TS 6.3 submitted in the LAA (Reference 1) with the now current TS amended through AMO 294. However, the proposed definitions for Certified Fuel Handler and TS 6.2.2.e contained references to TS 6.3, which were not addressed in the supplement.

This letter is to request that the proposed definitions for Certified Fuel Handler and TS 6.2.2.e be revised to align with AMO 294. Proposed revisions are shown in Bold-Italics and deletions are shown using strikethrough.

The following definition in Reference 1 is proposed to read as follows:

1.28 CERTIFIED FUEL HANDLER A CERTIFIED FUEL HANDLER is an individual who complies with provisions of the CERTIFIED FUEL HANDLER training program required by Specification 6.3.a2.

Additionally, TS 6.2.2.e as revised in Reference 1 is proposed to read as follows:

e. An individual qualified pursuant to 6.3.2 in radiation protection procedures shall be on site during movement of fuel and during the movement of loads over the fuel. The position may be vacant for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence provided immediate action is taken to fill the required positions.

In accordance with AMO 294 (Reference 2) and the Supplemented LAA (Reference 3) all staff qualification requirements were relocated to the Decommissioning Quality Assurance Program (DQAP). Therefore, this change is editorial in nature.

Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference 1. The additional information provided in this submittal does not affect the previously stated bases in Reference 1 for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

U.S. Nuclear Regulatory Commission Supplement 2 to TMI License Amendment Request Docket No. 50-289 October 29, 2018 Page 3 There are no new regulatory commitments contained in this letter.

If you have any questions concerning this submittal, please contact Paul Bonnett at (610}

765-5264.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 29th day of October 2018.

Respectfully, M~~fffe/4ri--

Vice President, License Renewal & Decommissioning Exelon Generation Company, LLC cc: Regional Administrator - NRC Region I NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRA - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRA - Three Mile Island Nuclear Station Director, Bureau of Radiation Protection - PA Department of Environmental Resources