TMI-10-054, Technical Specifications Change Request (Tscr) No. 348 Relocation of Equipment Load List from TS 4.5.1.1 B, Sequence and Power Transfer Test, to the Updated Final Safety Analysis Report

Technical Specifications Change Request (Tscr) No. 348 Relocation of Equipment Load List from TS 4.5.1.1 B, Sequence and Power Transfer Test, to the Updated Final Safety Analysis Report

ML102650392
Person / Time
Site:	Three Mile Island
Issue date:	09/22/2010
From:	Cowan P Exelon Generation Co, Exelon Nuclear
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
TMI-10-054
Download: ML102650392 (20)

Text

Exelon Nuclear www.exeloncorp.com Exelon.

200 Exelon Way Nuclear Kennett Square, PA 19348 10 CFR 50.90 TMI-10-054 September 22, 2010 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 No. 50-289

Subject:

TMI-1 Technical Specifications Change Request (TSCR) No. 348 Relocation of Equipment Load List from TS 4.5.1.1 b, Sequence and Power Transfer Test, to the Updated Final Safety Analysis Report (UFSAR)

In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (Exelon) requests the following amendment to the Technical Specifications, Appendix A, of Renewed Facility Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1 (TMI-1).

The proposed amendment would relocate the list of pumps, fans, and valves in Technical Specification (TS) TS 4.5.1.1 b, Sequence and Power Transfer Test to the TMI-1 UFSAR Section 8.3. TS 4.5.1.2b, TS 4.5.2.2a, and TS 4.5.2.2b are also being revised to reflect the proposed change to TS 4.5.1.1 b. TS Bases 4.5 are being changed (for information only) to be consistent with NUREG-1430, "Standard Technical Specifications Babcock and Wilcox Plants."

Attachment 1 provides the Evaluation of Proposed Technical Specifications Changes.

Attachment 2 provides the proposed Technical Specifications marked-up pages. Attachment 3 provides the proposed TS Bases marked-up page for information only. Attachment 4 provides the proposed TMI-1 UFSAR Section 8.3 marked-up pages for information only.

The proposed changes have been reviewed by the TMI-1 Plant Operations Review Committee and approved in accordance with Nuclear Safety Review Board procedures.

Exelon requests approval of the proposed amendment by September 22, 2011. Once approved, the amendment shall be implemented within 30 days.

u.s. Nuclear Regulatory Commission Relocation of Equipment Load List from TS 4.5.1.1 b, Sequence and Power Transfer Test, to the Updated Final Safety Analysis Report (UFSAR)

September 22, 2010 Page 2 There are no regulatory commitments contained in this letter.

Using the standards in 10 CFR 50.92, Exelon has concluded that these proposed changes do not constitute a significant hazards consideration, as described in the enclosed analysis performed in accordance with 10 CFR 50.91 (a)( 1).

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 changes to the TS and Operating License by transmitting a copy of this letter and its attachments to the designated state official.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 22 nd day of September 2010.

Respectfully,

'iJ/,l( r6naf@ZJa<1 Pamela B. Cowan Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Evaluation of Proposed Technical Specifications Changes

2) Proposed Technical Specifications Marked-up Pages

3) Proposed Technical Specifications Bases Marked-up Page for information only

4) Proposed TMI-1 UFSAR Section 8.3, Tests and Inspections, Marked-up Pages for information only cc: USNRC Regional Administrator, Region I USNRC Project Manager, TMI USNRC Senior Resident Inspector, TMI Director, Bureau of Radiation Protection, PA Department of Environmental Resources Chairman, Board of County Commissioners, Dauphin County, PA Chairman, Board of Supervisors, Londonderry Township, PA R. R. Janati, Commonwealth of Pennsylvania

ATTACHMENT 1 EVALUATION OF PROPOSED TECHNICAL SPECIFICATIONS CHANGES TMI-1 Technical Specifications Change Request (TSCR) No. 348 Relocation of Equipment Load List from TS 4.5.1.1b, Sequence and Power Transfer Test, to the Updated Final Safety Analysis Report (UFSAR)

CONTENTS 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA 4.2 PRECEDENT 4.3 NO SIGNIFICANT HAZARDS CONSIDERATION

4.4 CONCLUSION

S

6.0 REFERENCES

Page 1 of 10 Evaluation of Proposed Technical Specifications Changes 1.0

SUMMARY

DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (Exelon) is requesting changes to the Renewed Facility Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1 (TMI-1). The proposed amendment would relocate the list of pumps, fans and valves in Technical Specification (TS) 4.5.1.1b, Sequence and Power Transfer Test, to the TMI-1 Updated Final Safety Analysis Report (UFSAR) Section 8.3, Tests and Inspections.

Consistent with this relocation, the subject equipment list referenced in TS 4.5.1.2b, TS 4.5.2.2a and TS 4.5.2.2b is also being revised to reflect relocation to UFSAR Section 8.3.

Additionally, a proposed change to the TS 4.5 Bases has been included for information only to be consistent with NUREG-1430, Standard Technical Specifications Babcock and Wilcox Plants, (STS) Surveillance Requirement (SR) Bases for SR 3.8.1.11 and SR 3.8.1.19.

2.0 DETAILED DESCRIPTION TMI-1 Renewed Facility Operating License No. DPR-50, Appendix A, Technical Specifications:

Page 4 Modify TS 4.5.1.1b from:

The test will be considered satisfactory if the following pumps and fans have been successfully started and the following valves have completed their travel on preferred power and transferred to the emergency power.

-M. U. Pump

-D. H. Pump and D. H. Injection Valves and D. H. Supply Valves

-R. B. Cooling Pump

-R. B. Ventilators

-D. H. Closed Cycle Cooling Pump

-N. S. Closed Cycle Cooling Pump

-D. H. River Cooling Pump

-N. S. River Cooling Pump

-D. H. and N. S. Pump Area Cooling Fan

-Screen House Area Cooling Fan

-Spray Pump. (Initiated in coincidence with a 2 out of 3 R. B.

30 psig Pressure Test Signal.)

-Motor Driven Emergency Feedwater Pump To:

The test will be considered satisfactory if the pumps and fans listed in UFSAR Section 8.3 have been successfully started and the valves listed in UFSAR Section Page 2 of 10 Evaluation of Proposed Technical Specifications Changes 8.3 have completed their travel on preferred power and transferred to the emergency power.

Page 4 Modify TS 4.5.1.2b from:

The test will be considered satisfactory if the pumps and fans listed in 4.5.1.1b have been successfully started and the valves listed in 4.5.1.1b have completed their travel.

To:

The test will be considered satisfactory if the pumps and fans listed in UFSAR Section 8.3 have been successfully started and the valves listed in UFSAR Section 8.3 have completed their travel.

Page 4 Modify TS Bases (for information only) to add the following section:

The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the Emergency Diesel Generator loading logic. In certain circumstances, many of these loads can not actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, high pressure injection systems are not capable of being operated at full flow, or decay heat removal (DHR) systems performing a DHR function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the Emergency Diesel Generator system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

References UFSAR, Section 8.3, Tests and Inspections Page 4 Modify TS 4.5.2.2a from:

During each refueling period and following maintenance or modification that affects system flow characteristics, system pumps and high point vents shall be vented, and a system test shall be conducted to demonstrate that the system is operable. The auxiliaries required for low pressure injection are all included in the emergency loading sequence specified in 4.5.1.

To:

During each refueling period and following maintenance or modification that affects system flow characteristics, system pumps and high point vents shall be vented, and a system test shall be conducted to demonstrate that the system is operable. The auxiliaries required for low pressure injection are all included in the emergency loading sequence specified in UFSAR Section 8.3.

Page 3 of 10 Evaluation of Proposed Technical Specifications Changes Page 4 Modify TS 4.5.2.2b from:

The test will be considered satisfactory if the decay heat pumps listed in 4.5.1.1b have been successfully started and the decay heat injection valves and the decay heat supply valves have completed their travel as evidenced by the control board component operating lights. Flow shall be verified to be equal to or greater than the flow assumed in the Safety Analysis for the single corresponding RCS pressure used in the test.

To:

The test will be considered satisfactory if the decay heat pumps listed in UFSAR Section 8.3 have been successfully started and the decay heat injection valves and the decay heat supply valves have completed their travel as evidenced by the control board component operating lights. Flow shall be verified to be equal to or greater than the flow assumed in the Safety Analysis for the single corresponding RCS pressure used in the test.

3.0 TECHNICAL EVALUATION

The proposed changes would replace the TS 4.5.1.1b equipment load list with a reference to the proposed list of equipment contained in the UFSAR Section 8.3, Tests and Inspections (Attachment 4). The design features tested during the Sequence and Power Transfer Test and Sequence Test are described in UFSAR Sections 1, 7 and 8 (Reference 6.1). The proposed changes do not change the surveillance requirements (SRs) to perform a Sequence and Power Transfer Test and a Sequence Test of Engineered Safeguards equipment nor do they change the performance requirements of the SR. The current surveillance tests are not being revised. Future changes to the UFSAR Section 8.3 are controlled in accordance with 10 CFR 50.59.

NRC regulatory requirements related to the content of the TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items in eight specific categories, including (1) safety limits, limiting safety system settings and limiting control settings, (2) limiting conditions for operation, (3) surveillance requirements, (4) design features, (5) administrative controls, (6) decommissioning, (7) initial notification, and (8) written reports. The proposed deletion of the equipment load list from TS 4.5.1.1b is a change that affects TS contents that is categorized under 10 CFR 50.36(c)(3) surveillance requirements:

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.

10 CFR 36(c)(3) does not provide specific guidance on the level of detail to which an SR should be written. The TMI TS SRs currently provide a list of the specific loads to be tested during the Sequence and Power Transfer Test. This list of detailed loads is considered procedural in nature and does not include all equipment that is actually tested. These procedural type details are not required to ensure operability. The Page 4 of 10 Evaluation of Proposed Technical Specifications Changes requirements of the applicable Limiting Conditions for Operation (LCOs) and their corresponding SRs for these systems, as well as the definition of OPERABILITY, are adequate to ensure that the systems are maintained operable. The performance of the SRs will continue to use current testing methods to verify licensing basis acceptance criteria for testing the Engineered Safeguards systems pumps, fans and valves.

Therefore, these procedural type details are not necessary to ensure that the systems can perform their intended safety function, and are not required to be in the TS to provide adequate protection of the public health and safety. As discussed in the regulatory evaluation section of this submittal, when inclusion of such information has been shown to provide little or no safety benefit, its removal from the TS may be appropriate.

TS 4.5.1.2b, TS 4.5.2.2a and TS 4.5.2.2b will be revised to remove the references to equipment loads contained in TS 4.5.1.1b, and revised with a reference to UFSAR Section 8.3.

The TS Bases are being modified to be consistent with the TS Bases for STS SR 3.8.1.19, which references SR 3.8.1.11. Current verbatim compliance to TMI-1 TS SR and Bases interpretations requires that all the equipment loads be tested concurrently and does not provide the needed flexibility to allow for a series of sequential, overlapping, or total steps. The proposed changes to the TS and TS Bases may allow for future testing improvements under the 50.59 evaluation process that could avoid the extensive temporary power supplies, satisfy the test objective, simplify the test set up and performance, and eliminate unwarranted risk under the current testing methods.

The proposed TS Bases changes have been evaluated and do not change the intent of the current TS or SRs.

In summary, the list of required equipment to be tested during sequence and power transfer testing will be deleted from TS 4.5.1.1b. The list of required equipment to be tested for the Sequence and Power Transfer Test and for the Sequence Test will be relocated to the UFSAR Section 8.3. The UFSAR will continue to ensure adequate implementation of the SRs for the Sequence and Power Transfer Test and for the Sequence Test for the list of Engineered Safeguards equipment removed from the TS 4.5.1.1b. There are no changes to the surveillance technical requirements. The proposed changes are consistent with current industry practice of maintaining the list of required safeguards loads to be validated during the performance of the Sequence and Power Transfer Test and Sequence Test in the UFSAR, or other licensee controlled programs such as technical requirements manual, versus the TS. In addition, the proposed changes are consistent with STS surveillance test requirements contained in SR 3.8.1.19 and SR 3.8.1.11, which do not contain a specific list of equipment, but refer to permanently connected and auto connected shutdown loads.

4.0 REGULATORY EVALUATION

4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met. Exelon has determined that the proposed changes do not require any exemptions or relief from regulatory requirements, Page 5 of 10 Evaluation of Proposed Technical Specifications Changes other than the TS. The following applicable regulations and regulatory requirements were reviewed in making this determination:

Codes:

10 CFR 50.36, Technical specifications:

The U.S. Nuclear Regulatory Commissions (NRCs) regulatory requirements related to the content of TS are set forth in Title 10, Code of Federal Regulations (10 CFR),

Section 50.36. This regulation requires that the TS include items in eight specific categories. These categories include (1) safety limits, limiting safety system settings and limiting control settings, (2) limiting conditions for operation, (3) surveillance requirements, (4) design features, (5) administrative controls, (6) decommissioning, (7) initial notification, and (8) written reports. However, the regulation does not specify the particular TS to be included in a plants license.

Additionally, 10 CFR 50.36(c)(2)(ii) sets forth four criteria to be used in determining whether a limiting condition for operation (LCO) is required to be included in the TS.

These criteria are as follows:

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

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.

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.

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

Existing LCOs and related surveillances included as TS requirements which satisfy any of the criteria stated above must be retained in the TS, while those requirements that do not fall within or satisfy these criteria may be relocated to licensee-controlled documents.

The LCOs for the Electric Power System and their corresponding SRs that ensure the emergency loading sequence and automatic power transfer capability is operable by performance of a Sequence and Power Transfer Test and Sequence Test, satisfy criteria 3 and 4 above, and are, therefore, required to be in TS. However, the current TS SR includes details that are not required by 10 CFR 50.36. When inclusion of such information (i.e., equipment load list for the Sequence and Power Transfer Test and Sequence Test) has been shown to provide little or no safety benefit, its removal or relocation from the TS is appropriate. In previous cases (References 6.2 and 6.3), a TS revision has been granted to individual plants on a plant-specific basis to relocate such information to licensee controlled processes subject to 10 CFR 50.59 control as the Page 6 of 10 Evaluation of Proposed Technical Specifications Changes result of: (1) generic NRC action, (2) new staff positions that have developed from technological advancements and operating experience, or (3) resolution of industry comments on the STS.

10 CFR 50 Appendix A, GDC 37, Testing of emergency core cooling system, states:

The emergency core cooling system shall be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and performance of the active components of the system, and (3) the operability of the system as a whole and, under conditions as close to design as practical, the performance of the full operational sequence that brings the system into operation, including operation of applicable portions of the protection system, the transfer between normal and emergency power sources, and the operation of the associated cooling water system.

TMI-1 was designed to meet the requirements of the General Design Criteria applicable at the time of original licensing. The proposed Atomic Energy Commission (AEC)

Criterion 48 - Testing of operational sequence of emergency core cooling systems (Category A), states:

A capability shall be provided to test, under conditions as close to design as practical, the full operational sequence that would bring the emergency core cooling systems into action, including the transfer to alternate power sources.

TMI-1 UFSAR Section 1.4.48 discussion on satisfying this criterion stated:

The operational sequence that would bring the emergency core cooling systems into action, including transfer to alternate power sources, can be tested in parts.

4.2 PRECEDENT NRC has previously permitted relocation of surveillance requirement details that are not required by 10 CFR 50.36 to licensee controlled processes subject to 10 CFR 50.59 control, as evidenced in St. Lucie Units 1 and 2 Amendment Nos. 194 and 136 (Reference 6.2), and Seabrook Unit 1 Amendment No. 83 (Reference 6.3).

4.3 NO SIGNIFICANT HAZARDS CONSIDERATION Exelon Generation Company, LLC (Exelon) has evaluated whether or not a significant hazards consideration is involved with the proposed amendments by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

Page 7 of 10 Evaluation of Proposed Technical Specifications Changes The proposed license amendment does not add, delete or modify plant equipment.

The proposed changes are administrative in nature. The proposed amendment would relocate the list of pumps, fans and valves in Technical Specification (TS) 4.5.1.1b, Sequence and Power Transfer Test, to the TMI-1 Updated Final Safety Analysis Report (UFSAR) Section 8.3, Tests and Inspections.

The proposed changes relocate surveillance requirement details that are not required by 10 CFR 50.36, and are consistent with standard technical specifications, NUREG-1430, Standard Technical Specifications Babcock and Wilcox Plants. The proposed changes do not change current surveillance requirements. The subject list of pumps, fans and valves that will be relocated to the UFSAR Section 8.3 will continue to be administratively controlled and future changes will be controlled under 10 CFR 50.59.

The probability of an accident is not increased by these proposed changes because the Sequence and Power Transfer Test is not an initiator of any design basis event.

Additionally, the proposed changes do not involve any physical changes to plant structures, systems, or components (SSCs), or the manner in which these SSCs are operated, maintained, or controlled. The consequences of an accident will not be increased because the proposed administrative changes to the Sequence and Power Transfer Test and Sequence Test will continue to provide a high degree of assurance that the Electric Power System will meet its safety related function.

Therefore, the proposed changes do not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No.

The proposed changes do not alter the physical design, safety limits, safety analyses assumptions, or the manner in which the plant is operated or tested. The proposed changes are administrative in nature and the surveillance requirements remain the same. Accordingly, the proposed changes do not introduce any new accident initiators, nor do they reduce or adversely affect the capabilities of any plant SSC in the performance of their safety function.

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

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The margin of safety is associated with the confidence in the ability of the fission product barriers (i.e., fuel cladding, reactor coolant pressure boundary, and containment structure) to limit the level of radiation to the public. There are no physical changes to SSCs or operating and testing procedures associated with the proposed amendment.

Page 8 of 10 Evaluation of Proposed Technical Specifications Changes The proposed changes do not impact the assumptions of any design basis accident, and do not alter assumptions relative to the mitigation of an accident or transient event. The proposed changes are administrative in nature and the surveillance requirements remain the same.

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

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

4.4 CONCLUSION

S Exelon has determined that the proposed changes do not require any exemptions or relief from regulatory requirements (other than the TS) and do not affect conformance with any General Design Criteria.

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 Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment does not change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and does not change surveillance requirements. The proposed amendment revises technical specifications for TS 4.5.1, Emergency Loading Sequence, by relocating the list of pumps, fans and valves from the TS to the TMI-1 UFSAR. 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 the individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

6.1 TMI-1 UFSAR, Section 1.3.2.11, Engineered Safeguards Systems; 1.3.2.24 Electrical; 1.4.48, AEC Criterion 48 - Testing of Operational Sequence of Emergency Core Cooling Systems; 1.4.61, AEC Criterion 61 - testing of Operational Sequence of Containment Pressure-Reducing Systems; 1.4.65, Testing of Operational Sequence of Air Cleanup Systems; Section 7.1.3.2, Page 9 of 10 Evaluation of Proposed Technical Specifications Changes 6.2 St. Lucie Units 1 and 2 - Issuance of Amendments Regarding Relocation of Pump Technical Specification Surveillance Requirements (TAC Nos. MC1206 and MC1207), dated October 6, 2004 (ML042880073) 6.3 Seabrook Station, Unit 1 - Issuance of Amendment Re: Relocation of Certain Engineered Safety Features Pump Values from Technical Specifications to the Technical Requirements Manual (TAC No MB4258), dated May 2, 2002 (ML021080238)

Page 10 of 10

ATTACHMENT 2 Three Mile Island Nuclear Station, Unit 1 Technical Specification Change Request No. 348 Proposed Technical Specification Marked-up Pages The pages included in this attachment are:

4-39 4-41

4.5 EMERGENCY LOADING SEQUENCE AND POWER TRANSFER, EMERGENCY CORE COOLING SYSTEM & REACTOR BUILDING COOLING SYSTEM PERIODIC TESTING 4.5.1 Emergency Loading Sequence Applicability: Applies to periodic testing requirements for safety actuation systems.

Objective: To verify that the emergency loading sequence and automatic power transfer is operable.

Specifications:

4.5.1.1 Sequence and Power Transfer Test

a. During each refueling interval, a test shall be conducted to demonstrate that the emergency loading sequence and power transfer is operable.

b. The test will be considered satisfactory if the following pumps and fans listed in UFSAR Section 8.3 have been successfully started and the following valves listed in UFSAR Section 8.3 have completed their travel on preferred power and transferred to the emergency power.

-M. U. Pump

-D. H. Pump and D. H. Injection Valves and D. H. Supply Valves

-R. B. Cooling Pump

-R. B. Ventilators

-D. H. Closed Cycle Cooling Pump

-N. S. Closed Cycle Cooling Pump

-D. H. River Cooling Pump

-N. S. River Cooling Pump

-D. H. and N. S. Pump Area Cooling Fan

-Screen House Area Cooling Fan

-Spray Pump. (Initiated in coincidence with a 2 out of 3 R. B.

30 psig Pressure Test Signal.)

-Motor Driven Emergency Feedwater Pump

c. Following successful transfer to the emergency diesel, the diesel generator breaker will be opened to simulate trip of the generator then re-closed to verify block load on the reclosure.

4.5.1.2 Sequence Test

a. At intervals not to exceed 3 months, a test shall be conducted to demonstrate that the emergency loading sequence is operable, this test shall be performed on either preferred power or emergency power.

b. The test will be considered satisfactory if the pumps and fans listed in 4.5.1.1bUFSAR Section 8.3 have been successfully started and the valves listed in 4.5.1.1bUFSAR Section 8.3 have completed their travel.

4-39 Amendment No. 70, 78, 149, 167, 212

4.5.2 EMERGENCY CORE COOLING SYSTEM Applicability: Applies to periodic testing requirement for emergency core cooling systems.

Objective: To verify that the emergency core cooling systems are operable.

Specification 4.5.2.1 High Pressure Injection

a. During each refueling interval and following maintenance or modification that affects system flow characteristics, system pumps and system high point vents shall be vented, and a system test shall be conducted to demonstrate that the system is operable.

b. The test will be considered satisfactory if the valves (MU-V-14A/B

& 16A/B/C/D) have completed their travel and the make-up pumps are running as evidenced by system flow. Minimum acceptable injection flow must be greater than or equal to 431 gpm per HPI pump when pump discharge pressure is 600 psig or greater (the pressure between the pump and flow limiting device) and when the RCS pressure is equal to or less than 600 psig.

c. Testing which requires HPI flow thru MU-V16A/B/C/D shall be conducted only under either of the following conditions:

1) Indicated RCS temperature shall be greater than 329°F.

2) Head of the Reactor Vessel shall be removed.

4.5.2.2 Low Pressure Injection

a. During each refueling period and following maintenance or modification that affects system flow characteristics, system pumps and high point vents shall be vented, and a system test shall be conducted to demonstrate that the system is operable. The auxiliaries required for low pressure injection are all included in the emergency loading sequence specified in 4.5.1UFSAR Section 8.3.

b. The test will be considered satisfactory if the decay heat pumps listed in 4.5.1.1bUFSAR Section 8.3 have been successfully started and the decay heat injection valves and the decay heat supply valves have completed their travel as evidenced by the control board component operating lights. Flow shall be verified to be equal to or greater than the flow assumed in the Safety Analysis for the single corresponding RCS pressure used in the test.

4-41 Amendment No. 19, 57, 68, 149, 203, 225, 234

ATTACHMENT 3 Three Mile Island Nuclear Station, Unit 1 Technical Specification Change Request No. 348 Proposed Technical Specification Bases Marked-up Page for information only The page included in this attachment is:

4-40

Bases The Emergency loading sequence and automatic power transfer controls the operation of the pumps associated with the emergency core cooling system and Reactor Building cooling system.

Automatic start and loading of the emergency diesel generator to meet the requirements of 4.5.1.1b/c above is described in Technical Specification 4.6.1.b.

The requirement to verify the connection and power supply of permanent and auto-connected loads is intended to satisfactorily show the relationship of these loads to the Emergency Diesel Generator loading logic. In certain circumstances, many of these loads can not actually be connected or loaded without undue hardship or potential for undesired operation. For instance, Emergency Core Cooling Systems (ECCS) injection valves are not desired to be stroked open, high pressure injection systems are not capable of being operated at full flow, or decay heat removal (DHR) systems performing a DHR function are not desired to be realigned to the ECCS mode of operation. In lieu of actual demonstration of connection and loading of loads, testing that adequately shows the capability of the Emergency Diesel Generator system to perform these functions is acceptable. This testing may include any series of sequential, overlapping, or total steps so that the entire connection and loading sequence is verified.

References UFSAR, Section 8.3, Tests and Inspections 4-40 Amendment No. 70, 149, 157

ATTACHMENT 4 Three Mile Island Nuclear Station, Unit 1 Technical Specification Change Request No. 348 Proposed TMI-1 UFSAR Section 8.3, Tests and Inspections Marked-up Pages for information only 8.3-1 8.3-2

TMI-1 UFSAR 8.3 TESTS AND INSPECTIONS The diesel engine generators are controlled from a section of the main control console located in the Control Room. Provision has been made on the control console to manually initiate a fast start of any of the generators with closure of the associated air circuit breakers connecting the generator to its 4160 V engineered safeguards auxiliary bus with the bus deenergized. Testing of this system may be done by the Control Room operator at his convenience any time the units are not otherwise running, with due regard for reactor auxiliaries in use. Periodic testing of the diesel generators is required per the Technical Specifications.

In response to NRC Generic Letter 84-15 (Reference 19), the number of diesel generator cold fast starts has been reduced to enhance the reliability of the diesel generators by minimizing the degradation due to testing. Technical Specification surveillances require Diesels A and B to be cold fast started one time each on a refueling interval basis. Other planned tests or routine diesel starts follow the manufacturer's recommendations for pre-lube and warming in preparation for starting the diesels. TMI-1 Technical Specifications do not require tests of the emergency diesels for emergency cooling system operability.

The 230 kV circuit breakers can be inspected, maintained, and tested as follows:

a. The 230 kV transmission line circuit breakers are tested on a routine basis. This can be accomplished on the breaker-and-a- half scheme without removing the transmission line from service.

b. The 230 kV generator circuit breakers can be tested with the generator in service.

Transmission line protective relaying can be tested on a routine basis. Generator protective relaying will be tested when the generator is offline. The 4160 V circuit breakers, motor starters, and associated equipment can be tested in service by opening and closing the circuit breakers or starters so as not to interfere with operation of the station.

Emergency transfers to the various emergency power sources can be tested on a routine basis to prove the operational ability of these systems. At a minimum, the following electrical loads are tested during the Emergency Loading Sequence and Power Transfer Test:

-M. U. Pump

-D. H. Pump and D. H. Injection Valves and D. H. Supply Valves

-R. B. Cooling Pump

-R. B. Ventilators

-D. H. Closed Cycle Cooling Pump

-N. S. Closed Cycle Cooling Pump

-D. H. River Cooling Pump

-N. S. River Cooling Pump

-D. H. and N. S. Pump Area Cooling Fan

-Screen House Area Cooling Fan TMI-1 UFSAR CHAPTER 08 8.3-1 REV. 18, APRIL 2006

-Spray Pump. (Initiated in coincidence with a 2 out of 3 R. B.

30 psig Pressure Test Signal.)

-Motor Driven Emergency Feedwater Pump Each inverter for the 120 V vital power system can be tested by momentarily opening its normal ac source.

Station battery load testing and surveillance of voltage, specific gravity and liquid levels are required per the Technical Specification. The ungrounded DC system has detectors to indicate when there is a ground existing on any leg of the system. A ground on one leg of the DC system will not cause any equipment to malfunction.

Grounds can be located by a logical isolation of individual circuits connected to the faulted system, while taking the necessary precautions to maintain the integrity of the vital bus supplies.

CHAPTER 08 8.3-2 REV. 18, APRIL 2006