ML19316C659

License Amendment Request - Deletion of Pots 3/4.1.4, Handling of Irradiated Fuel with the Fuel Handling Building Crane; and Two Minor Administrative Changes

ML19316C659
Person / Time
Site:	Three Mile Island
Issue date:	11/12/2019
From:	David Helker Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TMI 19-094
Download: ML19316C659 (20)

Text

200 Exelon Way Kennett Square, PA 19348 Exelon Generation www.exeloncorp.com 10 CFR 50.90 TMl-19-094 November 12, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility License No. DPR-50 NRC Docket No. 50-289

Subject:

License Amendment Request - Deletion of POTS 3/4.1.4, "Handling of Irradiated Fuel with the Fuel Handling Building Crane;" and Two Minor Administrative Changes In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes changes to the Permanently Defueled Technical Specifications (POTS), Appendix A of Renewed Facility License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1 (TMl-1 ).

To support decommissioning activities and transfer of spent fuel to the TMl-1 Independent Spent Fuel Storage Installation (ISFSI), the manner in which fuel storage casks are handled inside the Fuel Handling Building (FHB) is being modified with a replacement FHB crane. The original FHB crane, which is non-single-failure-proof, will be replaced with a single-failure-proof FHB crane that will be designed, fabricated, and tested per the guidelines of NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants" and will satisfy the guidance in NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants: Resolution of Generic Technical Activity A-36." This will obviate the need for a Fuel Cask Drop Accident Analysis and the requirements in POTS 3/4.1.4, "Handling of Irradiated Fuel with the Fuel Handling Building Crane." This LAR is specifically seeking approval to delete POTS 3/4.1.4 once the replacement FHB crane is made operable.

In addition, two minor omissions that are administrative in nature, that were identified during implementation of TMl-1 POTS Amendment No. 297, have been included with this license amendment request. The proposed changes are: 1) to revise TS Appendix A List of Figures to include Figure 5-1, "Extended Plot Plan," and 2) to add the proper page number, 5-1a, to POTS Figure 5-1.

Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92, "Issuance of amendment."

License Amendment Request Deletion of POTS 3/4.1.4, Handling of Irradiated Fuel with the FHB Crane; and Two Minor Administrative Changes Docket No. 50-289 November 12, 2019 Page 2 The proposed changes have been reviewed by the TMI Safety Review Committee (SRC) in accordance with the requirements of the Exelon Decommissioning Quality Assurance Program (DQAP).

This amendment request contains no regulatory commitments. provides the evaluation of the proposed changes. Attachment 2 provides a copy of the marked-up POTS/Bases pages that reflect the proposed changes. The marked-up Bases pages that reflect the proposed changes are for information only.

Exelon requests approval of the proposed amendment by November 12, 2020 to support the schedule to move spent fuel to dry cask storage. Upon NRC approval, the amendment shall be implemented within 90 days following the date the replacement FHB crane is made operable.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the Commonwealth of Pennsylvania of this application for license amendment by transmitting a copy of this letter and its attachments to the designated State Official.

Should you have any questions concerning this submittal, please contact Frank Mascitelli at 610-765-5512.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 121h day of November 2019.

Respectfully, David P. Helker Sr. Manager, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes

2. Markup of Proposed Permanently Defueled Technical Specifications I Bases Pages cc: Regional Administrator - NRC Region I w/ attachments II NRC Senior Resident Inspector - TMl-1 It Region I Decommissioning Lead Inspector It NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 It Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection

ATTACHMENT 1 License Amendment Request Three Mile Island Nuclear Station, Unit 1 Docket No. 50-289 EVALUATION OF PROPOSED CHANGES

Subject:

License Amendment Request - Deletion of POTS 3/4.1.4, "Handling of Irradiated Fuel with the Fuel Handling Building Crane;" and Two Minor Administrative Changes 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

3.0 TECHNICAL EVALUATION

3.1 NUREGs-0554 and -0612 Compliance 3.2 Minor Administrative Changes

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 No Significant Hazards Consideration 4.4 Conclusion

6.0 REFERENCES

License Amendment Request Attachment 1 Deletion of POTS 3/4.1.4, Handling of Irradiated Fuel with the FHB Crane and Page 1 of 9 Two Minor Administrative Changes Docket No. 50-289 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes changes to the Permanently Defueled Technical Specifications (POTS), Appendix A of Renewed Facility License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1 (TMl-1 ).

To support decommissioning activities and transfer of spent fuel to the TMl-1 Independent Spent Fuel Storage Installation (ISFSI}, the manner in which fuel storage casks are handled inside the Fuel Handling Building (FHB) is being modified with a replacement FHB crane (Reference 1).

The original FHB crane, which is non-single-failure-proof, will be replaced with a single-failure-proof FHB crane that will be designed, fabricated, and tested per the guidelines of NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants" (Reference 2) and will satisfy NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants: Resolution of Generic Technical Activity A-36" (Reference 3), which combine to satisfy the Heavy Loads Control Program at TMl-1 .

The installation of a single-failure-proof FHB crane and operating the FHB crane in accordance with the Exelon Control of Heavy Loads Program (Reference 4) improves the assurance that handling of spent fuel casks in the FHB are performed safely and precludes the need to postulate a Fuel Cask Drop Accident in the FHB. As such, the existing POTS 3/4.1.4 "Handling of Irradiated Fuel with the Fuel Handling Building Crane" Specifications will no longer be required.

This LAR is specifically seeking approval to delete POTS 3/4.1.4 once the replacement FHB crane is made operable. The FHB crane modification activity is being evaluated under the 10 CFR 50.59 process (Reference 1).

In addition, two minor omissions that are administrative in nature, that were identified during implementation of TMl-1 POTS Amendment No. 297 (Reference 5), have been included with this license amendment request. The proposed changes are: 1) to revise TS Appendix A List of Figures to include Figure 5-1, "Extended Plot Plan," and 2) to add the proper page number, 5-1a, to POTS Figure 5-1 .

The proposed changes conform to the requirements of 10 CFR 50.36, "Technical specifications,"

for the contents of the POTS.

2.0 DETAILED DESCRIPTION In order to support decommissioning activities, and safely store spent nuclear fuel in dry cask storage, TMl-1 is modifying the manner in which fuel storage casks are handled in the FHB through the installation of a replacement FHB crane to support the use of a 10 CFR 72.214 approved dry cask storage system.

The original 110-ton FHB crane is underrated for the dry cask storage system and is non-single-failure-proof. The existing POTS 3/4.1.4 "Handling of Irradiated Fuel with the Fuel Handling Building Crane" Specifications were required for the original non-single-failure-proof FHB crane design based upon the TMl-1 Fuel Cask Drop Accident as described in the TMl-1 Defueled Safety Analysis Report (DSAR) (Reference 6) .

License Amendment Request Attachment 1 Deletion of POTS 3/4.1.4, Handling of Irradiated Fuel with the FHB Crane and Page 2 of 9 Two Minor Administrative Changes Docket No. 50-289 Evaluation of Proposed Changes The existing seven POTS 3/4.1.4.1 through 3/4.1.4. 7 provide limiting conditions for operation of the FHB crane to ensure assumptions in the fuel cask drop accident are maintained. POTS 3/4.1.4.1 through 3/4.1.4.5 were original specifications dating back to April 19, 1974 to ensure the original fuel cask drop accident analysis radiological consequences for the site boundary remained within the limits specified in 10 CFR 100. POTS 3/4.1.4.6 and 3/4.1.4. 7 were originally introduced in TS Amendment No. 34, dated December 19, 1977 (Reference 7) to support modifications that increased the capacity of the Spent Fuel Pool "B." Subsequently, in TS Amendment No. 109, dated July 30, 1985 (Reference 8), these specifications evolved to their current state to incorporate commitments regarding the control of heavy loads and specifically the potential drop of fuel casks. The commitments were made in support of the resolution of Multi Plant Action (MPA) C-10, Control of Heavy Loads.

The replacement FHB crane is single-failure-proof and compliant with the guidelines of NUREG-0554 to satisfy the defense-in-depth guidelines of NUREG-0612. The replacement FHB crane is designed with an upgraded main hoist capacity rated for 125 tons to handle the dry cask storage system. The installed location of the replacement FHB crane is not changed.

The FHB crane modification activity is being evaluated under the 10 CFR 50.59 process (Reference 1). Additionally, the original FHB crane will be relocated to TMI Unit 2 and no longer used for TMl-1 spent fuel cask handling.

The manner of compliance with NUREG-0612 Section 5.1.2 "Spent Fuel Pool Area-PWR" is changed to an approved approach considering installation and operation of a NUREG-0554 compliant single-failure-proof crane. Full compliance with NUREG-0612 is maintained through the Exelon Heavy Loads Control Program.

Upgrading the FHB load handling system to a NUREG-0554 compliant single-failure-proof crane and operating the FHB crane in accordance with the Exelon Control of Heavy Loads Program improves the load handling system reliability to an acceptably low probability of a fuel cask drop such that the Fuel Cask Drop Accident will no longer be credible. As such, the existing POTS 3/4.1.4 Specifications will no longer be required .

The marked-up POTS/Bases pages that reflect the proposed changes are provided in Attachment 2 of this submittal. The POTS Bases changes are submitted for information only. The POTS Table of Contents (page i) is being revised to show POTS 3/4.1.4 as deleted.

Additionally, two minor administrative changes as described in Section 3.2 below are being proposed.

3.0 TECHNICAL EVALUATION

3.1 NUREGs-0554 and -0612 Compliance NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants: Resolution of Generic Technical Activity A-36" provides guidance for upgrading handling system reliability and states

License Amendment Request Attachment 1 Deletion of POTS 3/4.1.4, Handling of Irradiated Fuel with the FHB Crane and Page 3 of 9 Two Minor Administrative Changes Docket No. 50-289 Evaluation of Proposed Changes that new cranes meet the guidelines of NUREG-0554 "Single-Failure-Proof Cranes for Nuclear Power Plants" to be qualified as single-failure-proof cranes.

The TMl-1 replacement FHB crane design, fabrication, and testing is compliant with guidelines of NUREG-0554, which is an acceptable approach for single-failure-proof cranes in accordance with NUREG-0612.

The Exelon Heavy Loads Program (Reference 4) satisfies the NUREG-0612 Section 5.1, "Recommended Guidelines," for the following defense-in-depth approaches:

(1) Provide sufficient operator training, handling system design, load handling instructions, and equipment inspection to assure reliable operation of the handling system.

(2) Define safe load travel paths through procedures and operator training so that to the extent practical heavy loads avoid being carried over or near irradiated fuel or safe shutdown equipment.

The manner of compliance with NUREG-0612 Section 5.1.2 "Spent Fuel Pool Area-PWR" is changed to an approved approach considering installation and operation of a NUREG-0554 compliant single-failure-proof crane. The implementation and use of a single-failure-proof crane in the SFP area negates the need for the additional controls provided in Section 5.1.2 to compensate for use of non-certified single-failure-proof crane. Although updating the method of compliance with Section 5.1.2 of NUREG-0612, full compliance with NUREG-0612 is maintained through the Exelon Heavy Loads Program.

Upgrading the FHB load handling system to a NUREG-0554 compliant single-failure-proof crane and having incorporated the additional defense-in-depth guidance for special lifting devices, lifting devices, and interfacing lift points into the Exelon Control of Heavy Loads Program satisfies NUREG-0612. The FHB crane upgrade will improve the load handling system reliability such that there is an acceptably low probability of occurrence of an uncontrolled lowering, or fuel cask drop so as to effectively preclude consideration of a fuel cask drop accident as a credible event.

3.2 Minor Administrative Changes During implementation of TMl-1 TS Amendment No. 297 (Reference 5), two administrative omissions were identified. The first one involved not including Figure 5-1, "Extended Plot Plan,"

in the TS Appendix A List of Figures, and the second one involved not paginating the TS Figure 5-1 with the proper page number of 5-1a. These two items have been corrected and included in the Attachment 2 Markup of the proposed POTS.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria TS Requirements (10 CFR 36)

License Amendment Request Attachment 1 Deletion of PDTS 3/4.1.4, Handling of Irradiated Fuel with the FHB Crane and Page 4 of 9 Two Minor Administrative Changes Docket No. 50-289 Evaluation of Proposed Changes The NRC provided guidance for the contents of Technical Specifications (TS) in its "Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58 FR 39132, July 22, 1993 (Reference 9). The Final Policy Statement identified future criteria to be used in determining whether particular safety functions are required to be included in the Specifications. In particular, the NRC indicated that certain items could be relocated from the TS to licensee-controlled documents and identified criteria to be used to determine the functions to be included in the TS. The NRC subsequently adopted an amendment to 10 CFR 50.36, "Technical specifications," (60 FR 36953, July 19, 1995; to codify and incorporate these criteria .

10 CFR 50.36c(2)(ii) contains the requirements for items that must be in TS. This regulation provides the four criteria that can be used to determine the requirements that must be included in the TS. A TS limiting condition for operation (LCO) of a nuclear reactor must be established for each item meeting one or more of the criteria. These criteria are restated and their applicability to the proposed license amendment are discussed below.

Criterion 1: Installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary.

This criterion addresses instrumentation installed to detect excessive reactor coolant system (RCS) leakage. TMl-1 has provided certifications in accordance with 10 CFR 50.82(a)(1 )(i) and (ii) that it has permanently shutdown and defueled (References 10 and 11, respectively) . In accordance with 10 CFR 50.82(a)(2) the 10 CFR Part 50 license for TMl-1 no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel. Since no fuel will be present in the reactor, or the reactor coolant system pressurized when the new crane is in operation, this criterion is not applicable.

Criterion 2: A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

The purpose of this criterion is to capture those process variables that have initial values assumed in the design basis accident and transient analyses, and that are monitored and controlled during power operation. This criterion also includes active design features (e.g., high-pressure/low-pressure system valves and interlocks) and operating restrictions (pressure/temperature limits) needed to preclude unanalyzed accidents and transients.

With the installation and operation of a replacement single-failure-proof FHB crane that complies with NUREG-0554 and NUREG-0612, the existing Fuel Cask Drop Accident will no longer be credible and the existing FHB crane's Specifications will no longer be required .

Criterion 3: A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.

The purpose of this criterion is to capture only those structures, systems, and components (SSCs) that are part of the primary success path of the safety analysis (an examination of the actions required to mitigate the consequences of the design basis accident and transients) . The primary success path of a safety analysis consists of the

License Amendment Request Attachment 1 Deletion of PDTS 3/4.1.4, Handling of Irradiated Fuel with the FHB Crane and Page 5 of 9 Two Minor Administrative Changes Docket No. 50-289 Evaluation of Proposed Changes combinations and sequences of equipment needed to operate so that the plant response to the design basis accident and the transients limits the consequences of these events to within the appropriate acceptance criteria. Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function, but the criterion does not include backup and diverse equipment.

With the installation and operation of a replacement single-failure-proof FHB crane that complies with NUREG-0554 and NUREG-0612, the existing Fuel Cask Drop Accident will no longer be credible. In addition, the replacement crane will not be considered a mitigating SSC that is part of the primary success path and which functions or actuates to mitigate an accident or transient.

Criterion 4: A structure, system , or component which operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

The purpose of this criterion is to capture only those SSCs that operating experience or probabilistic risk assessment has shown to be significant to public health and safety.

With the installation and operation of a replacement single-failure-proof FHB crane that complies with NUREG-0554 and NUREG-0612, the existing Fuel Cask Drop Accident will no longer be credible and the existing FHB crane Specifications will no longer be credited to ensure public health and safety.

With the installation of the replacement single-failure-proof FHB crane, this replacement crane and its functions do not satisfy any of these four specified criteria and therefore will not require TS Limiting Conditions for Operation (LCOs).

NUREG-0554. "Single-Failure-Proof Cranes" The replacement FHB crane design, fabrication, and testing is compliant with NUREG-0554 which is an acceptable approach for single-failure-proof cranes in accordance with NUREG-0612.

NUREG-0612. "Control of Heavy Loads at Nuclear Power Plants: Resolution of Generic Technical Activity A-36" NUREG-0612 provides NUREG-0554 as the guidance document for single failure proof cranes.

Compliance with NUREG-0554 meets the requirements of NUREG-0612, although the manner of compliance with Section 5.1.2 "Spent Fuel Pool Area-PWR" is changed to an approved approach considering the single-failure-proof FHB crane. The Exelon Program for Control of Heavy Loads and the FHB crane's operation under this Program, combined with the single-failure-proof replacement FHB crane provide the defense-in-depth requirements and full compliance with NUREG-0612.

4.2 Precedent NRC has approved the use of a single-failure-proof crane compliant with NUREG-0554 and NUREG-0612 as one methodology to establish an acceptably low probability of a fuel cask drop

License Amendment Request Attachment 1 Deletion of PDTS 3/4.1.4, Handling of Irradiated Fuel with the FHB Crane and Page 6 of 9 Two Minor Administrative Changes Docket No. 50-289 Evaluation of Proposed Changes so as to effectively preclude consideration of a fuel cask drop accident. Upgrading the FHB load handling system to a NUREG-0554 compliant single-failure-proof crane and having incorporated the additional defense-in-depth guidance for special lifting devices, lifting devices, and interfacing lift points into the Exelon Control of Heavy Loads Program combine to satisfy NUREG-0612. As such, the existing PDTS 3/4.1.4 Specifications for the replacement FHB crane will no longer be required and can be deleted.

4.3 No Significant Hazards Consideration In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes changes to the Permanently Defueled Technical Specifications (PDTS), Appendix A of Renewed Facility License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1 (TMl-1 ).

The proposed changes delete PDTS 3/4.1.4, "Handling of Irradiated Fuel with the Fuel Handling Building Crane," once the single-failure-proof replacement Fuel Handling Building (FHB) crane is made operable. The Defueled Safety Analysis Report (DSAR) Fuel Cask Drop Accident analysis is addressed as part of the 10 CFR 50.59 Review for the installation of the replacement single-failure-proof FHB crane.

In addition, two minor omissions that are administrative in nature, that were identified during implementation of TMl-1 PDTS Amendment No. 297 have been included with this license amendment request. The proposed changes are: 1) to revise PDTS Appendix A List of Figures to include Figure 5-1, "Extended Plot Plan," and 2) to add the proper page number, 5-1 a, to PDTS Figure 5-1.

The proposed changes conform to the requirements of 10 CFR 50.36, "Technical specifications,"

for the contents of TS.

Exelon has evaluated the proposed changes, using the criteria in 10 CFR 50.92, "Issuance of amendment," and has determined that the proposed changes do not involve a significant hazards consideration. The following information is provided to support a finding of no significant hazards consideration .

1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed License Amendment Request (LAR) to operate a single-failure-proof FHB crane demonstrates that no analysis is required for the fuel cask drop event based on the replacement crane's design, fabrication, testing, and installation and the associated programmatic controls for control of heavy loads.

A single-failure-proof crane that is compliant with NUREG-0554 and NUREG-0612 has an acceptably low probability of a fuel cask drop so as to effectively preclude consideration of a fuel cask drop accident.

License Amendment Request Attachment 1 Deletion of POTS 3/4.1.4, Handling of Irradiated Fuel with the FHB Crane and Page 7 of 9 Two Minor Administrative Changes Docket No. 50-289 Evaluation of Proposed Changes In addition, two minor changes that correct the POTS Figure List and paginate a POTS figure are administrative in nature, and do not involve any accident probabilities or consequences.

Therefore, the proposed changes do not significantly increase the probability or consequences of an accident previously evaluated, as the previously evaluated accident will no longer be credible.

2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The location of the replacement FHB crane is not changed from that currently described in the DSAR. The design features of the replacement crane have changed to single-failure-proof design and thus uncontrolled lowering, or drop, of a fuel storage cask will not be considered credible per NUREG-0612. Based on the design pedigree and programmatic controls on the replacement crane, no load will lower uncontrollably or drop in or around the spent fuel pool or near an open cask containing spent fuel, nor will a cask containing spent fuel drop or be lowered uncontrollably during operation of the crane. Hence, no new or different kind of accidents will be initiated.

In addition, two minor changes that correct the POTS Figure List and paginate a POTS figure are administrative in nature, and do not create the possibility of a new or different kind of accident.

Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Do the proposed changes involve a significant reduction in a margin of safety?

Response: No The proposed changes involve deleting the POTS 3/4.1.4 Specifications as a result of the replacement of the existing non-single-failure-proof FHB crane with a replacement single-failure-proof FHB crane. The replacement FHB crane has been designed to meet the guidelines of NUREG-0554 to provide adequate protection and safety margin against the uncontrolled lowering of the lifted load.

The occurrence of a fuel cask load drop accident is considered not credible when the load is lifted with a single failure proof lifting system meeting the guidance in NUREG-0612. As a result, the proposed change to delete POTS 3/4.1.4 once the replacement FHB crane is made operable, has no adverse impact on stored spent fuel , or structural integrity of the spent fuel pool or any existing SSC.

License Amendment Request Attachment 1 Deletion of PDTS 3/4.1.4, Handling of Irradiated Fuel with the FHB Crane and Page 8 of 9 Two Minor Administrative Changes Docket No. 50-289 Evaluation of Proposed Changes The maximum critical lift capacity of the replacement crane has been increased.

The supporting analyses for the crane and support structure satisfy the acceptance criteria of the design basis codes and regulatory guidelines to demonstrate adequate margin considering the increased maximum critical load.

In addition, two minor changes that correct the PDTS Figure List and paginate a PDTS figure are administrative in nature and do affect any margin of safety.

Therefore, the proposed changes do not involve a significant reduction in the margin of safety.

Based on the above evaluation, Exelon concludes that the proposed license amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (c), and accordingly, a finding of "no significant hazards consideration" is justified.

4.4 Conclusion In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

Exelon has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation ." However, the proposed amendment does not involve: (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review,"

paragraph (c)(9). Therefore, pursuant to 10 CFR 51.22, paragraph (b), no environmental impact statement or environmental assessment needs to be prepared in connection with the proposed amendment.

License Amendment Request Attachment 1 Deletion of POTS 3/4.1.4, Handling of Irradiated Fuel with the FHB Crane and Page 9 of 9 Two Minor Administrative Changes Docket No. 50-289 Evaluation of Proposed Changes

6.0 REFERENCES

1. Exelon Engineering Change (EC) 625307, "ISFSI - EC #07 - Fuel Handling Building Crane Upgrade"

2. NUREG-0554, "Single-Failure-Proof Cranes for Nuclear Power Plants"

3. NUREG-0612, "Control of Heavy Loads at Nuclear Power Plants: Resolution of Generic Technical Activity A-36"

4. Exelon Procedure MA-AA-716-022, "Control of Heavy Loads Program"

5. Three Mile Island Nuclear Station, Unit 1 - Issuance of Amendment No. 297 Re:

Defueled Technical Specifications and Revised License Conditions (EPD L-2018-LLA-0204), dated August 29, 2019(Ml192110317)

6. TMl-1 Defueled Safety Analysis Report, Section 6.3, "Fuel Cask Drop Accident"

7. TMl-1 TS Amendment No. 34, dated December 19, 1977 (ML003763097)

8. TMl-1 TS Amendment No.109, dated July 30, 1985 (ML003764822)

9. Final Policy Statement on Technical Specifications Improvements for Nuclear Power Reactors" (58 FR 39132, July 22, 1993)

10. Letter from J. Bradley Fewell (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Certification of Permanent Cessation of Power Operations for Three Mile Island Nuclear Station, Unit 1," dated June 20, 2017 (Ml 17171A151)

11. Letter from Michael P. Gallagher (Exelon Generation Company, LLC), "Certification of Permanent Removal of Fuel from the Reactor Vessel for Three Mile Island Nuclear Station, Unit 1," dated September 26, 2019 (ML19269E480)

ATTACHMENT 2 License Amendment Request Three Mile Island Nuclear Station, Unit 1 Docket No. 50-289 Deletion of POTS 3/4.1.4, "Handling of Irradiated Fuel with the Fuel Handling Building Crane;" and Two Minor Administrative Changes Markup of Proposed Permanently Defueled Technical Specifications/Bases Pages Unit 1 POTS/Bases Pages ii 3/4 - 10 3/4 - 11 3/4 - 12 314 - 13 5-1a

TABLE OF CONTENTS Section TECHNICAL SPECIFICATIONS 1 DEFINITIONS 1-1 1.1 ACTIONS 1-1 1.2 CERTIFIED FUEL HANDLER 1-1 1.3 NON-CERTIFIED OPERATOR 1-1 1.4 OPERABLE 1-1 1.5 STATION. UNIT. PLANT. FACILITY 1-1 3/4 LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS 3/4-1 3/4.0 GENERAL ACTION REQUIREMENTS AND SURVEILLANCE REQUIREMENT APPLICABILITY 3/4-1 3/4.1 HANDLING AND STORAGE OF IRRADIATED FUEL IN THE SPENT FUEL POOL 3/4-4 3/4.1 .1 SPENT FUEL POOL WATER LEVEL 3/4-4 3/4.1 .2 SPENT FUEL POOL BORON CONCENTRATION 3/4-6 3/4.1.3 SPENT FUEL ASS EMBLY STORAGE 3/4-7 3/4.1.4 I 11';PdBl::lt~6 9F IRR1';81,a.;TEB F~EI: WFFI I =Fl IE FUEL HAME?LIMS BUILBlt~6 CRANE Deleted 3/4-10 5 DESIGN FEATURES 5-1 5.1 SITE 5-1 5.2 SPENT FUEL STORAGE FACILITIES 5-2 5.2.1 Spent Fuel Storage 5-2 6 ADMINISTRATIVE CONTROLS 6-1 6.1 RESPONSIBILITY 6-1 6.2 ORGANIZATION 6-1 6.2.1 Onsite and Offsite Organization 6-1 6.2.2 Facility Staff 6-1 6.3 FACILITY STAFF QUALIFICATIONS 6-2 6.4 Deleted 6-2 6.5 Deleted 6-2 6.6 Deleted 6-2 6.7 Deleted 6-2 6.8 PROCEDURES AND PROGRAMS 6-11 6.9 REPORTING REQUIREMENTS 6-12 6.9.1 Routine Reports 6-12 6.9.2 Annual Radiological Environmental Operating Report 6-12 6.9.3 Annual Radioactive Effluent Release Report 6-13 6.10 RECORD RETENTION 6-13 6.11 Deleted 6-13 6.12 HIGH RADIATION AREA 6-13 6.13 Deleted 6-14 6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM) 6-14 6.15 Deleted 6-15 6.16 Deleted 6-15 6.17 Deleted 6-15 6.18 TECHNICAL SPECIFICATION (TS) BASES CONTROL PROGRAM 6-15 Amendment No. 11, 72 , 129, 1 J7, 142, 150, 155, 17J, 27B;-29T-

LIST OF FIGURES FIGURE TITLE 3.1.3-1 Minimum Burnup Requirements for Fuel in Region II of the Pool A 3/4-8 Storage Racks 3.1.3-2 Minimum Burnup Requirements for Fuel in the Pool "B" Storage Racks 3/4-9 3.1.4-1 Transfer Path to and from Cask Loading Pit 3/4-13 5-1 Extended Plot Plan 5-1a ii Amendment No. 59,72,78, 97,98, 119, 122, 136, 149, 167, 182, 196,211,216,234,242,245,248,264, 269,278,297

3/4.1.4 t-4A~JDLING O~ IRRADIATED FUEL \fiJITl-4 Tt-4E J=UEL MANDLING BUILDl~'G CRANE Deleted Aeelicabilitv Ap13lies te the eperation of tl:ie f1:Jel l:ianelling b1:JildinJ crane wl=len witl=lin tl=le confines ef Unit 1 and there is any spent f1:Jel in storage in tl:ie Unit 1 f1:Jel hanelling b1::1ileling.

Objective To aeflne the lift conelitions anel allowable areas of travel when loaeis to be lifted ans trans13orteei with the fuel t:ianalinJ b1:1ilelinJ crane are in e)(eoss of 16 tons or betv.1eon 1.5 tons anel 16 tons or consist of irraeliatoel f1:1el eleR=1ents.

Saeeiflcation 3.1.4.1 Spent f1:1el oleR=1ents having less than 120 elays for aecay of tt:ieir irradiates fuel shall not be loaded into a spent fuel transfer eask in tho shipping eask area.

3.1.4 .2 The key operated travel interlock system for automatieally limiting the tra*1el area of tt:ie f1:Jel handling b1:Jilding erane shall be iR'l13osed whenever loaeJs in eMoess of 16 tons are to be lifteel and transported with the exception of f1:Jel handlinJ bridge R'laintenanse.

a.1.4.a The lowest surface of all loads in e>Ecess of 16 tons shall ee administratively liFRited to an elevation one feet oF less above the concrete swface at the nominal 348 ft O in. elevatien in tt:ie fuel hanelling b1:1ilding.

3.1.4 .4 Loaels in excess of heok capacity shall not be lifted, e)(cept for loaei testing.

3.1.4.6 F=ollowing modifioations OF repairs to any of tt:ie lead bearing members, tt:ie crane shall be s1:J19:ieeted to a test lift of 126 percent of its rated load.

a.1 .4.e Administrative oontrols shall req1:Jire the 1:Jse of an approved prosed1:Jre with an identified safe load path fer loads in e)(sess ef 3,000 lbs. l=landled above the Spent F1:Jel Pool Operating Floor (348' elevation).

3.1.4.7 During transfer of tl=ie oask to anel from tt:ie oask leasing pit, tt:ie oask will be Festricted to the transfer path st:iown in J=ig1:tre 3.1.4 1.

AdFRinisti:ativo eontrols will be usoel to ensure tt:iat ell lateral R=10*1eR=1ents of the eask are i:ierforR=leel at slow brielge and trolley speeels. D1:1ring this transfer the eask lifting yoke shall be oriented in tho east Wost direction.

3/4-10 Amendment No. ~

This s,:>esifisation will lifflit activity releases to 1:1nrestristee areas res1:1ltiA!iiJ from dafflage to spent f1:1el storeei in tl':ie spent f1:1el storage pools in the post1:1lated e*.ient of the dropping of a heavy lead freffl the f1:10I handling l31:1ilding srane. /\ F1:10I l=landling assident analysis was perforff!ed ass1:1FRing that the sask anei its entire sontents of ten f1:1ol asseffll:llies are sl:lfflsiently eafflagod as a res1:1lt of drapf:!ing the sask, to allow the essaf:le of all noels gases and iodine in the gaf:l (Referense 1) . This release was ass1:1 FR ed to so eliroctly to the atffloSf:!hore anel to osc1:1r instantaneet:Jsly. The site l301:1naary eases res1::1lting froffl tt:iis assiaent are e.29 R wf:lole beey and 1.02 R to tf:lyreia, and are 'Nitt:iin tt:ie lifflits Sf:lecified in 10 GFR 100.

Sf:leeifieation 3.1. 4.1 reei1:1ires tt:iat s,:ient fuel , having less than 120 days deeay f:IOSt irradiation, not be loaded in a spent fuel transfer cask in oreer to ensure that the elosos resulting froFR a t:lighly irnf:lrobable Sf:lent fuel transfer sask drof:l wo1::1ld ee witt:iin tt'lose sals1:1latee aeeve.

Spesifisation 3.1 .4.2 reeiuires the key operates interlosk systeffl ,

wt'lish autofflatioally lifflits the travel area of tho fuel handling orane wl=lile it is lifting and transporting the spent fuel shipf:ling sask, to be ifflposed wt'lenever leaels in e>Esess of 15 tons are to be lifted and transperted *.1.'hile there is any Sf:!Ont f1:1el in storage in the spent f1:1ol storage f:IOOls in Unit 1. This at:Jtofflatically ens1:1ros that those heavy loaas travel in areas whore , in tho 1:1nlikely event of a loael elrop ascielent, there wo1:1lel ea no possieility of this event res1:1lting in any dafflage to tt'le spent f1:1el stored in the pools, any 1:1nacGeJ:1table strnct1:1ral dafflage to the spent fuel f:IOGI strnsturo, or daFRago to redundant trains of safoty related sompenents. The shipping oask aFOa is designed ta 'Nitl=lstand the dFOp of the spent fuel shif:lping cask froffl tt=te a49 ft 0 in. elevation without unasoeptable aarnage to the Sf:lent fuel f:IOOI structure (Referense 2) .

Specification a.1.4.a ensures tt'lat the lowest surface of any hem,'y loaa never gets higFier tl=lan one foot above the sonorete surface of the 348 ft 0 in. elevation in tt'le fuel l=lanaling building (nominal elevation 349 ft 0 in.) thereby l(eeping any iFRpact force froFR an unlikely load drop aosident within asoeptable limits.

Sposifisation 3.1.4 .4 ens1:1res tl=lat the f:!roper capacity crane hook is 1:1sed for lifting anel transperting loads thus roeluoing the prebability of a load elrop assident.

F=ollowing ffloeifisation or repairs, Sf:IOGifisation 3.1.4.9 eonfirffls the loael Fatin!iiJ of the srane.

Spooification 3.1.4 .G ifflf:IOSes aarninistralive Ii FR its on hanaling leaels weighing in o>Ecess of 3000 las. to fflinifflize tho f:!Otential for heavy loads, if elropf:leel, to ifflpact irraeliated f1:1el in the Sf:lent fuel f:IOOI ,

er to ifflpaot redundant safe sh1:1tdown equipment. The safe load path shall follow, to the e>Etent praotioal, struetural floor rnernbors, beaffls, etc., sueh that if tl=le load is elFOf:lf:IOel, tt'le strusture is 3!4 11

/\rnenelfflent No. 297

ff!Ore likely to withstaRd tho impast. PlaRdliAg loads of less than JQQQ llas. witho1:i1t those rostriotioAs is assoptaele eeoa1:i1so tho 00Aseet1:10Roes of droppiRg loaels in tl=lis weight range are 00R=1paraele to tl=loso proel1:1soel ey the fuel hanelliR!i;I aooident oonsieloreel in tho FSAR anel fo1:i1nd aoooptaelo.

Spooifisation 3.1.4.7 in GOR=!Bination with 3.1.4 .J eRSblFOS tl:io spent f1:i1el oask is hanelleel in a fflanner oonsistont with the loael elrop analysis (Referenoe ~) .

RefereRses f41 UFSAR, Seotion 14.2.2.1 "F1:i1el l-lanellin§ Aeeident"

~ UFSAR, Sestion 14.2.2.8 "Fuel Cask Drof:l Aoeident"

~ GPU e1Jal1:i1ation of l-4oavy Load Marn'11ing Operations at TMI 1 Folar1:i1ary 21 , 1984 , as traRsfflitteel to tho NRG in GPUN Lotter

~Jo . 5211 84 2Q13.

314 12 AmenelmoRt ~Jo . 297

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FIGURE 3.1.4 1 3/4 13 AFF1endFF1ent No. 297

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~Gl-ft:tllOQ:O Amendment No. 140, 216, 246, 2 11 Exelon Three Mile Island Nuclear Station EXTENDED PLOT PLAN I CAD FILE: 6717R1.DWG FIG 5-1 5-1a