TMI-12-169, Request for Amendment to Eliminate Certain Technical Specification Reporting Requirements

Request for Amendment to Eliminate Certain Technical Specification Reporting Requirements

ML13037A051
Person / Time
Site:	Three Mile Island
Issue date:	02/04/2013
From:	Jesse M Exelon Generation Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
TMI-12-169
Download: ML13037A051 (18)

Text

10 CFR 50.90 TMI-12-169 February 4, 2013 U. S. Nuclear Regulatory Commission ATIN: 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:

Request for Amendment to Eliminate Certain Three Mile Island Nuclear Station, Unit 1 Technical Specification Reporting Requirements In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (EGC) requests an amendment to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1 (TMI, Unit 1).

The proposed changes will delete various TMI, Unit 1 reporting requirements contained in TS. EGC has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92.

The proposed changes have been reviewed by the TMI, Unit 1 Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program. provides an evaluation of the proposed changes, including a detailed description, technical and regulatory evaluations, and an environmental consideration. provides the existing TS pages marked up to show the proposed changes.

There are no regulatory commitments contained in this submittal.

EGC requests approval of the proposed license amendment by February 4, 2014, with the amendment being implemented within 60 days of issuance.

u.s. Nuclear Regulatory Commission February 4, 2013 Page 2 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), EGC is notifying the State 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 regarding this submittal, please contact Ms. Stephanie J. Hanson at (610) 765-5143.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 4th day of February 2013 Respectfully, Michael D. Jesse Director -

Exelon Generation Attachments: 1. Evaluation of Proposed Changes

2. Markup of Technical Specifications Pages cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, TMI, Unit 1 USNRC Project Manager, TMI, Unit 1 R. R. Janati, Bureau of Radiation Protection

ATTACHMENT 1 Evaluation of Proposed Changes Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50

Subject:

Request for Amendment to Eliminate Certain Three Mile Island Nuclear Station, Unit 1 Technical Specification Reporting Requirements 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 Conclusions

6.0 REFERENCES

License Amendment Request Attachment 1 Eliminate Certain Technical Specification Reporting Requirements Page 1 of 9 Evaluation of Proposed Changes Docket No. DPR-50 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 (EGC) requests an amendment to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1 (TMI, Unit 1).

The proposed changes will delete the TMI, Unit 1 reporting requirements contained in the Administrative Controls Section of TS, specifically Section 6.9.1.A, Sections 6.9.1.B.3 through 6.9.1.B.5, and Section 6.17. Additionally, TS Section 3.10.1 will be revised to remove a special report requirement. The proposed amendment will delete the TMI, Unit 1 Sealed Source Contamination Special Report and the Startup Report as well as the plant-specific annual reports regarding periodic Leak Reduction Program tests, Pressurizer Power Operated Relief Valve (PORV) and Pressurizer (PZR) safety valve challenges, specific activity analysis in which the primary coolant exceeds the limits of TS 3.1.4.1, and major changes to radioactive waste treatment systems.

The proposed changes do not alter or change any existing reporting obligations required by 10 CFR and maintain consistency with applicable regulatory requirements.

2.0 DETAILED DESCRIPTION Section 50.36, "Technical Specifications," of 10 CFR Part 50, "Licensing of Production and Utilization Facilities, requires that each applicant for a license authorizing operation of a nuclear power plant II include in its application proposed TS. These TS, as issued by the NRC, are incorporated into the facility operating license as Appendix A. Specifically, Section c(5) of 10 CFR 50.36 requires that the Administrative Controls Section of TS include reporting requirements that assure operation of the facility in a safe manner.

In October of 1971, Regulatory Guide (RG) 1.16, "Reporting of Operating Information - Appendix A, Technical Specifications," (Reference 1) was published by the NRC to provide an acceptable basis for meeting the reporting requirements listed in Appendix A, "Technical Specifications Related to Health and Safety," of the facility operating license. In particular, this RG provided a description of each of the periodic reports, including annual reports and the Startup Report, that licensees are required to submit to demonstrate compliance with the TS reporting requirements. Subsequently, in August 2009, via the Federal Register, 74 FR 40244 (Reference 2), the NRC withdrew RG 1.16 because it was no longer needed on the basis that TS reporting requirements are contained in 10 CFR 50 as well as other parts of 10 CFR Chapter 1. In addition, guidance on the content and frequency of required reports are contained in Chapter 5, "Administrative Controls," of the Improved Standard Technical Specifications (ISTS) provided in NUREG -1430, Volume 1, "Standard Technical Specifications, Babcock and Wilcox Plants" (Reference 3). Even though TMI, Unit 1 is not formally committed to RG 1.16, the intent of this License Amendment Request (LAR) is to be consistent with the regulatory requirements as prescribed in 10 CFR as indicated in the Federal Register Notice which withdrew RG 1.16.

In May of 1997, Generic Letter (GL) 97-02, "Revised Contents of the Monthly Operating Report,"

(Reference 4) provided the results of the NRC's assessment of their information gathering needs, which identified duplicative reporting, and determined that some reports could be reduced in scope or eliminated. Although this GL was specific to the Monthly Operating Report, this LAR seeks to eliminate, in a similar fashion, redundant reports that are no longer considered warranted.

License Amendment Request Attachment 1 Eliminate Certain Technical Specification Reporting Requirements Page 2 of 9 Evaluation of Proposed Changes Docket No. DPR-50 The changes requested by this amendment application would delete the following TMI, Unit 1 reports as described below.

1. TS Table of Contents, page v for TMI, Unit 1, Section 6.17, will be revised to replace the words "Major Changes to Radioactive Waste Treatment Systems" with "Deleted" to indicate that this section will be deleted as part of the proposed change.

2. TS Section 3.10.1 on page 3-46, for TMI, Unit 1, will be revised to delete the special report requirement.

3. TS Section 6.9.1.A on page 6-12, for TMI, Unit 1, which is being deleted in its entirety, will be revised to replace the words regarding the plant Startup Report with the word "DELETED."

4. TS Section 6.9.1.B.3 on page 6-13, for TMI, Unit 1, which is being deleted in its entirety, will be revised to replace the words regarding periodic Leak Reduction Program tests with the word "DELETED."

5. TS Section 6.9.1.B.4 on page 6-13, for TMI, Unit 1, which is being deleted in its entirety, will be revised to replace the words regarding PORV and PZR safety valve challenges with the word "DELETED."

6. TS Section 6.9.1.B.5 on page 6-13, for TMI, Unit 1, which is being deleted in its entirety, will be revised to replace the words pertaining to the results of specific activity analysis in which the primary coolant exceeded limits of TS 3.1.4.1 with the word "DELETED."

7. TS Section 6.17 on page 6-25, for TMI, Unit 1, which is being deleted in its entirety, will be revised to replace the words regarding major changes to radioactive waste treatment systems with the word "DELETED."

Markups of the proposed TS page changes are provided in Attachment 2.

3.0 TECHNICAL EVALUATION

TS 3. 10. 1 - Miscellaneous Radioactive Materials Sources Special Report The limitations on removable contamination for sources requiring leak testing are based on 10 CFR 70.39(c), "Special licenses for the manufacture or initial transfer of calibration or reference sources" which states:

"Each person licensed under this section shall perform a dry wipe test upon each source containing more than 0.1 microcurie of plutonium prior to transferring the source to a general licensee under § 70.19. This test shall be performed by wiping the entire radioactive surface of the source with a filter paper with the application of moderate finger pressure. The radioactivity on the paper shall be measured by using radiation detection instrumentation capable of detecting 0.005 microcurie of plutonium. If any such test discloses more than 0.005 microcurie of radioactive material, the source shall be deemed to be leaking or losing plutonium and shall not be transferred to a general licensee under § 70.19."

License Amendment Request Attachment 1 Eliminate Certain Technical Specification Reporting Requirements Page 3 of 9 Evaluation of Proposed Changes Docket No. DPR-50 The focus of the requirement as specified above is to ensure that leakage from byproduct, source, and special nuclear material sources will not exceed allowable intake values. Additionally, TMI, Unit 1 TS requires that if the test reveals the presence of 0.005 microcurie or more of removable contamination, it shall immediately be withdrawn from use, decontaminated, and repaired, or be disposed of in accordance with the regulation.

The regulation prohibits the transfer of such material and current TMI, Unit 1 TS controls the potential for exposure and contamination of a leaking source. Additionally, identification of a source exceeding the allowable limits would be entered into the corrective action program, which would drive the determination of the cause and identify corrective actions. The proposed amendment would delete the requirement to submit a special report in the event radioactive material sources exceed the allowable limits for transfer. There is no requirement in 10 CFR 70 to submit the results of sealed source leak testing. Since the test results are general information in nature, and are not required by statute, the means and frequency of submittal of the sealed source leakage data is not restricted by 10 CFR 70.

Accordingly, this proposed change to delete the reporting requirement in TS 3.10.1 does not alter or change any existing reporting obligation required by 10 CFR and maintains consistency with applicable regulatory requirements.

TS 6.9.1.A - Startup Report In October of 1971, the NRC published RG 1.16 to provide an acceptable basis for meeting the reporting requirements listed in Appendix A, "Technical Specifications Related to Heath and Safety," of the facility operating license. This RG provided a description of each of the routine reports, including the plant Startup Report that the licensees are required to submit to demonstrate compliance with the TS reporting requirements. However, in August 2009, via the Federal Register, 74 FR 40244, the NRC withdrew RG 1.16 because it was no longer needed on the basis that TS reporting requirements are contained in 10 CFR 50 as well as other parts of 10 CFR Chapter 1.

Current TMI, Unit 1 TS includes a requirement to submit, on a periodic basis, a plant Startup Report.

Even though TMI, Unit 1 is not formally committed to RG 1.16, the intent of this LAR is to be consistent with the regulatory requirements as prescribed in 10 CFR as indicated in the Federal Register Notice which withdrew RG 1.16. Additionally, guidance on the content and frequency of required reports are contained in Chapter 5, "Administrative Controls," of the ISTS provided in NUREG - 1430, which does not include a requirement to submit a Startup Report. Further, information provided in the plant Startup Report is readily available to the NRC for inspection by the NRC Resident Inspectors. No information submitted in the Startup Report seeks NRC approval for plant operations. The proposed amendment would delete the requirement to provide, on a periodic basis, a plant Startup Report. This proposed change to delete TS 6.9.1.A does not alter or change any existing reporting obligations required by 10 CFR and maintains consistency with applicable regulatory requirements. As a result, the plant Startup Report is no longer warranted.

TS 6.9.1.B.3 - Periodic Leak Reduction Program tests By letter dated April 28, 1982, the NRC issued Amendment No. 77 for TMI, Unit 1 (Reference 5). This amendment added the requirement to report the results of the periodic leak reduction program testing on the basis that it satisfied the guidance provided in NUREG-0737, Item III.D.1.1 (Reference 6). Item III D.1.1 specifies that the results of the initial leak test performed under the leak reduction program for

License Amendment Request Attachment 1 Eliminate Certain Technical Specification Reporting Requirements Page 4 of 9 Evaluation of Proposed Changes Docket No. DPR-50 systems outside containment be submitted to the NRC. Although Item III.D.1.1 does require on-going periodic leak tests, it does not indicate that the periodic test results be submitted to the NRC.

In addition, the results of the tests performed on systems outside of primary containment are readily available to the NRC for inspection by the NRC Resident Inspectors. Significant leakage identified would be captured in the corrective action program which would drive a determination of cause and action to prevent reoccurrence; therefore, annual reporting is no longer warranted.

TS 6.9.1.804 - PORV and PZR Safety Valve Challenges The annual reporting of pressurizer safety and relief valve failures and challenges is based on the guidance provided in NUREG-0694, 'TMI-Related Requirements for New Operating Licenses" (Reference 7). In June 1980, the NRC published NUREG-0694, which states: "Assure that any failure of a PORV or safety valve to close will be reported to the NRC promptly. All challenges to the PORV or safety valves should be documented in the annual report." Current TMI, Unit 1 TS includes a requirement to provide, on an annual basis, any challenges to the PORV or PZR safety valves.

However, GL 97-02 provided the results of the NRC's assessment of their information gathering needs, which determined that some reports could be reduced in scope or eliminated. The GL identifies what needs to be reported to support the NRC Performance Indicator (PI) Program, and availability and capacity statistics. GL 97-02 does not specifically identify the need to report challenges to PORV or PZR safety valves.

Further, any challenges to the PORV or PZR safety valves would be captured in the corrective action program, which would drive a determination of the cause and actions to prevent recurrence of the challenge. Therefore, the proposed amendment would delete the requirement to provide, on an annual basis, documentation of all challenges to the PORV or PZR safety valves. This proposed change to delete TS 6.9.1.B.4 does not alter or change any existing reporting obligations required by 10 CFR and maintains consistency with applicable regulatory requirements. As a result, annual reporting of PORV and PZR safety valve challenges is no longer warranted.

TS 6.9.1.8.5 - Specific activity analysis in which the primary coolant exceeded limits of TS 3.104.1 TMI, Unit 1, TS 6.9.1.B.5 requires annual reporting of the results of specific activity analysis in which the primary coolant exceeds the limits of TS 3.1.4.1. However, specific activity analysis pertaining to primary coolant limits is reported to the NRC by means of the PI Program, under the Reactor Oversight Program (ROP). As part of the ROP PI Program, TMI, Unit 1 currently provides monthly reactor coolant specific activity data on a quarterly basis to the NRC in accordance with Regulatory Issue Summary (RIS) 2000-08, Revision 1, "Voluntary Submission of Performance Indicator Data" (Reference 8) following the guidelines provided in NEI 99-02, "Regulatory Assessment Performance Indicator Guideline" (Reference 9).

The reactor coolant specific activity concentration is provided more frequently than required by the TS, regardless of whether or not the TS limit is exceeded. Additionally, if the limit is exceeded, this would be evaluated within the corrective action program, which would drive a determination of the cause and identify appropriate corrective actions to prevent recurrence. Therefore, annual reporting of specific activity analysis in accordance with TS 6.9.1.B.5 is no longer warranted.

License Amendment Request Attachment 1 Eliminate Certain Technical Specification Reporting Requirements Page 5 of 9 Evaluation of Proposed Changes Docket No. DPR*50 TS 6. 17 - Major changes to radioactive waste treatment systems The radioactive waste treatment systems (gaseous, liquid and solid) are described in chapter 11 of the TMI, Unit 1 Updated Final Safety Analysis Report (USFAR). Major changes to the radioactive waste treatment systems would require an evaluation in accordance with 10 CFR 50.59, "Changes, tests, and experiments". If the changes are significant enough to be evaluated against the eight criteria specified in 50.59(c)(2), but do not require prior NRC approval, then a summary of the changes must be provided to the NRC in accordance with 50.59(d)(2), which states that "the licensee shall submit. .. a report containing a brief description of any changes, tests, and experiments, including a summary of the evaluation of each. A report must be submitted at intervals not to exceed 24 months." Major changes to radioactive waste treatment systems will be reported to the NRC via compliance with 10 CFR 50.59, and therefore, annual reporting is no longer warranted. Accordingly, this proposed change to delete TS 6.17 does not alter or change any existing reporting obligations required by 10 CFR and maintains consistency with applicable regulatory requirements.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria Section 50.36, "Technical Specifications," of 10 CFR Part 50, "Licensing of Production and Utilization Facilities," requires that each applicant for a license authorizing operation of a nuclear power plant include in its application proposed TS. These TS, as issued by the NRC, are incorporated into the facility operating license as Appendix A. Specifically, Section c(5) of 10 CFR 50.36 requires that the Administrative Controls Section of TS include reporting requirements that assure operation of the facility in a safe manner.

In October of 1971, Regulatory Guide (RG) 1.16, "Reporting of Operating Information - Appendix A, Technical Specifications," was published by the NRC to provide an acceptable basis for meeting the reporting requirements listed in Appendix A, "Technical Specifications Related to Health and Safety," of the license. In particular, this RG provided a description of each of the periodic reports, including annual reports and Startup Reports, that licensees are required to submit to demonstrate compliance with the TS reporting requirements. Subsequently, in August 2009, the NRC withdrew RG 1.16 because it was no longer needed on the basis that TS reporting requirements are contained in 10 CFR 50 as well as other parts of 10 CFR Chapter 1. In addition, guidance on the content and frequency of required reports are contained in Chapter 5, "Administrative Controls," of NUREG - 1430.

Even though TMI, Unit 1 is not formally committed to RG 1.16, the intent of this LAR is to be consistent with the regulatory requirements as prescribed in 10 CFR as indicated in the Federal Register Notice which withdrew RG 1.16.

10 CFR 50.59 requires an evaluation of changes to the facility or procedures as described in the UFSAR. 10 CFR 50.59(d)(2) states that the licensee shall submit ... a report containing a brief description of any changes, tests, and experiments, including a summary of the evaluation of each. A report must be submitted at intervals not to exceed 24 months."

The proposed change to delete the special report requirement contained in TS 3.10.1 regarding sealed source contamination has been evaluated and determined to be governed by 10 CFR 70.39(c).

Additionally, current TMI, Unit 1 TS controls the potential for exposure and contamination from sealed

License Amendment Request Attachment 1 Eliminate Certain Technical Specification Reporting Requirements Page 6 of 9 Evaluation of Proposed Changes Docket No, DPR-50 source leakage, Any radioactive material that exceeds the allowable intake values will be entered into the corrective action program.

The proposed change to delete TS 6,9.1 ,A, regarding the plant Startup Report, has been evaluated and determined to be governed by 10 CFR 50 as well as other parts of 10 CFR Chapter 1. Additionally, guidance on the content and frequency of required reports are contained in Chapter 5 of the ISTS provided in NUREG - 1430, which does not include a requirement to submit a Startup Report.

The proposed change to delete TS 6.9.1.B.3, pertaining to periodic Leak Reduction Program tests, has been evaluated and determined that the test results are readily available to the NRC for inspection by the NRC Resident Inspectors, Additionally, significant leakage is captured in the corrective action program.

The proposed change to delete TS 6.9.1.B.4 has been evaluated and determined that challenges to the PORV and PZR safety valves are captured in the corrective action program and are not required to be reported in accordance with the guidance provided in GL 97-02.

The proposed change to delete TS 6.9.1.B.5 has been evaluated and determined that specific activity analysis pertaining to primary coolant limits are reported to the NRC by means of the Performance Indicator (PI) Program under the Reactor Oversight Program (ROP).

The proposed change to delete TS 6.17, pertaining to major changes to radioactive waste treatment systems, has been evaluated and determined to be governed by the requirements of 10 CFR 50.59.

Major changes to radioactive waste treatment systems as described in the UFSAR will be evaluated against the eight criteria outlined in the regulation. Changes that do not require prior NRC approval must be documented and provided to the NRC in a summary report.

The proposed changes have been evaluated and it has been concluded that applicable regulations and requirements continue to be met. The proposed changes create no operational concerns. The proposed changes do not alter or change any existing reporting obligations required by 10 CFR and they maintain consistency with applicable regulatory requirements. Additionally, the proposed changes are consistent with the ISTS provided in NUREG - 1430.

4.2 Precedent None 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 (EGC) requests an amendment to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1 (TMI, Unit 1).

The proposed changes will delete the TMI, Unit 1 reporting requirements contained in the Administrative Controls Section of TS, specifically Section 6.9.1.A, Sections 6.9.1.B.3 through 6.9.1.B.5, and Section 6.17. Additionally, TS Section 3.10.1 will be revised to remove a special report requirement. The proposed amendment will delete the TMI, Unit 1 Sealed Source Contamination

License Amendment Request Attachment 1 Eliminate Certain Technical Specification Reporting Requirements Page 7 of 9 Evaluation of Proposed Changes Docket No. DPR-50 Special Report and the Startup Report as well as the plant-specific annual reports regarding periodic Leak Reduction Program tests, Pressurizer Power Operated Relief Valve (PORV) and Pressurizer (PZR) safety valve challenges, specific activity analysis in which the primary coolant exceeds the limits of TS 3.1.4.1, and major changes to radioactive waste treatment systems.

EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment 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 The proposed changes do not involve the modification of any plant equipment or affect plant operation. The proposed changes will have no impact on any safety related structures, systems, or components. The reporting requirements proposed for deletion are not required because the requirements are adequately addressed by other regulatory requirements, or are no longer warranted.

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 have no impact on the design, function or operation of any plant structure, system or component. The proposed changes do not affect plant equipment or accident analyses.

The reporting requirements proposed for deletion are not required because the requirements are adequately addressed by other regulatory requirements, or are no longer warranted.

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

Response: No The proposed changes do not adversely affect existing plant safety margins or the reliability of the equipment assumed to operate in the safety analyses. There is no change being made to safety analysis assumptions, safety limits or limiting safety system settings that would adversely affect plant safety as a result of the proposed changes. Margins of safety are unaffected by deletion of the reporting requirements.

license Amendment Request Attachment 1 Eliminate Certain Technical Specification Reporting Requirements Page 8 of 9 Evaluation of Proposed Changes Docket No. DPR-50 4.4 Conclusions 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 to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

The proposed amendment is confined to (i) changes to surety, insurance, and/or indemnity requirements; Oi) changes to recordkeeping, reporting, or administrative procedures or requirements; (iii) changes to the licensee's or permit holder's name, phone number, business or e-mail address; (iv) changes to the name, position, or title of an officer of the licensee or permit holder, including but not limited to, the radiation safety officer or quality assurance manager; or (v) changes to the format of the license or permit or otherwise makes editorial, corrective or other minor reviSions, including the updating of NRC approved references. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(1 0). 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

1. U.S. Nuclear Regulatory Commission, Office of Standard Development, Regulatory Guide 1.16, Revision 1, "Reporting of Operating Information - Appendix A, Technical Specifications," dated October 1971.

2. Federal Register, Volume 74, Page No. 40244, "Nuclear Regulatory Commission Withdrawal of Regulatory Guide 1.16, 'Reporting of Operating Information - Appendix A Technical Specifications'," dated August 11, 2009.

3. U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, NUREG - 1430, Revision 4, "Standard Technical Specifications, Babcock and Wilcox Plants," dated April 2012.

4. U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, NRC Generic Letter 97-02, "Revised Contents of the Monthly Operating Report," dated May 15,1997.

5. Letter from J. F. Stolz, U. S. Nuclear Regulatory Commission to H. D. Hukill, GPU Nuclear Corporation, [Issuance of Amendment No. 77, for Three Mile Island Nuclear Station, Unit 1]

dated April 28, 1982.

6. U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, NUREG - 0737 "Clarification of TMI Action Plan Requirements," Item D .111.1.1 , dated November 1980.

7. U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, NUREG - 0694

TMI-Related Requirements for New Operating licenses," Item C.3.3, dated June 1980.

License Amendment Request Attachment 1 Eliminate Certain Technical Specification Reporting Requirements Page 9 of 9 Evaluation of Proposed Changes Docket No. DPR-50

8. U.S. Nuclear Regulatory Commission, Office of Nuclear Reactor Regulation, NRC Regulatory Issue Summary 2000-08, Revision 1,"Voluntary Submission of Performance Indicator Data,"

dated February 19, 2009.

9. Nuclear Energy Institute, NEI 99-02, Revision 6, "Regulatory Assessment Performance Indicator Guideline," dated October 2009.

ATTACHMENT 2 Markup of Technical Specifications Pages Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 REVISED TECHNICAL SPECIFICATIONS PAGES v

3-46 6-12 6-13 6-25

5 5-1 5.1 5-1 5.2 CONTAINMENT 5-2 5.2.1 Reactor Building 5-2 5.2.2 Reactor Building Isolation System 5-3 5.3 REACTOR 54 5.3.1 Reactor Core 54 5.3.2 Reactor Coolant System 54 5.4 NEW AND SPENT FUEL STORAGE FACILITIES 5-6 5.4.1 New Fuel Storage 5-6 5.4.2 Spent Fuel Storage 5-6 5.5 AIR INTAKE TUNNEL FIRE PROTECTION SYSTEMS 5-8 6 ADMINISTRATIVE CONTROLS 6-1 6.1 RESPONSIBILITY 6-1 6.2 ORGANIZATION 6-1 6.2.1 Corporate 6-1 6.2.2 Unit Staff 6-1 6.3 UNIT STAFF QUALIFICATIONS 6-3 6.4 TRAINING 6-3 6.5 Deleted 6-3 6.5.1 Deleted 64 6.5.2 Deleted 6-5 6.5.3 Deleted 6-7 6.5.4 Deleted 6-8 6.6 REPORTABLE EVENT ACTION 6-10 6.7 SAFETY LIMIT VIOLATION 6-10 6.8 PROCEDURES AND PROGRAMS 6-11 6.9 REPORTING REQUIREMENTS 6-12 6.9.1 Routine Reports 6-12 6.9.2 Deleted 6-14 6.9.3 Annual Radiological Environmental Operating Report 6-17 6.9.4 Annual Radioactive Effluent Release Report 6-18 6.9.5 Core Operating Limits Report 6-19 6.9.6 Steam Generator Tube Inspection Report 6-19 6.10 RECORD RETENTION 6-20 6.11 RADIATION PROTECTION PROGRAM 6-22 6.12 HIGH RADIATION AREA 6-22 6.13 PROCESS CONTROL PROGRAM 6-23 6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM) 6-24 6.15 Deleted 6-24 6.16 Deleted 6-24 6.17 Deleted MAJOR CHANGES TO RADIOACTIVE WASTE TREATMENT SYSTEMS 6-25 6.18 TECHNICAL SPECIFICATION (TS) BASES CONTROL PROGRAM 6-25 6.19 STEAM GENERATOR (SG) PROGRAM 6-26 6.20 CONTROL ROOM ENVELOPE HABITABILITY PROGRAM 6-29 6.21 SURVEILLANCE FREQUENCY CONTROL PROGRAM 6-30 v

Amendment No. 11, 47,72,77,129,150,173,212,252,253,256,261,264,269, 274 ~

3.9 DELETED 3.10 MISCELLANEOUS RADIOACTIVE MATERIALS SOURCES Applicability Applies to byproduct, source, and special nuclear radioactive material sources.

Objective To assure that leakage from byproduct, source, and special nuclear radioactive material sources does not exceed allowable limits.

Specification 3.10.1 The source leakage test performed pursuant to Specification 4.13 shall be capable of detecting the presence of 0.005 j.JCi of radioactive material on the test sample. If the test reveals the presence of 0.005j.JCi or more of removable contamination, it shall immediately be withdrawn from use, decontaminated, and repaired, or be disposed of in accordance with Commission regulations; and a Special Report of the test results that show the presence of

~ .005 IJCi of removable contamination shall be prepared and submitted to the NRC Region I Administrator within gO days afl:er completion of the test. Sealed sources are exempt from such leak tests when the source contains 100 j.JCi or less of beta and/or gamma emitting material or 5 j.JCi or less of alpha emitting material.

3.10.2 A complete inventory of licensed radioactive materials in possession shall be maintained current at all times.

The limitations on removable contamination for sources requiring leak testing, including alpha emitters, are based on 10 CFR 70.39(c) limits for plutonium.

This limitation will ensure that leakage from byproduct, source, and special nuclear material sources will not exceed allowable intake values.

3-46 (Pages 3-47 to 3-54 deleted)

Amendment No. 94, ~

(3-31-81)

6.9 REPORTING REQUIREMENTS In addition to the applicable reporting requirements of Title 10, Code of Federal Regulations, the following identified reports shall be submitted to the Administrator of the NRC Region 1 Office unless otherwise noted.

6.9.1 Routine Reports A. DELETED Startup Report. A summary report of plant startup and power escalation testing shall be submitted follo'....lng (1) receipt of an operating license, (2) amendment to the license invol'Jing a planned increase in power le'Jel, (3) installation of fuel that has a different design or has been manufactured by a different fuel supplier, and (4) modifications that may have significantly altered the nuclear, thermal, or hydraulic performance of the plant. The report shall address each of the tests identified in the UFSAR, Chapter 13 and shall in general include a description of the measured lo'alues ef the operating conditions or characteristics obtained during the test program and a comparison of these values with design predictions and specifications. Any corrective actions that were required to obtain satisfactory operation shall also be described.

Any additional specific details required in license conditions based on other commitments shall be included in this report.

Startup reports shall be submitted 'Nithin (1) 90 days follo'Ning completion of the startup test program, (2) 90 days follo'.... ing resumption or commencement of commercial po'....er operation, or (3) 9 months following initial criticality, INhichelo'er is earliest. If the Startup Report does not cO'/er all three e'/ents (Le., initial criticality, completion of startup test program, and resumption or commencement of commercial power operation), supplementary reports shall be submitted at least elo'ery three months until all three events halo'e been completed.

B. Annual Reports. Annual reports covering the activities of the unit as described below during the previous calendar year shall be submitted prior to March 1 of each year. (A single submittal maybe made for the station. The submittal should combine those sections that are common to both units at the station.)

1. DELETED

2. The following information on aircraft movements at the Harrisburg International Airport:

a. The total number of aircraft's movements (takeoffs and landings) at the Harrisburg International Airport for the previous twelve-month period.

b. The total number of movements of aircraft larger than 200,000 pounds at the Harrisburg International Airport for the previous twelve-month period, broken down into scheduled and non-scheduled (including military) takeoffs and landings, based on a current estimate provided by the airport manager or his designee.

6-12 Amendment No. 12,37,77,157, 180, ~

DELETED The following information from the periodio Leak Reduotion Program tests shall be reported:

a. Results oj! leakage measurements,

b. Results oj! visual inspestions, and

c. Maintenance undertaken as a result of Leakage Redustion Pregram tests or inspestions.

4. DELETED The following information regarding pressurizer power operated relief '.'al'/e and pressurizer safelj' val\'e challenges shall be reported:

a. Date and time of inCident,

b. Description oj! ooourrence, and

o. Corresti'/e measures taken Ij! inoident resulted from an equipment 1!ailure.

DELETED The follo*....lng information regarding the results of specifio asti'/ity analysis in whioh the primaf)' ooolant e>Eoeeded limite oj! Teohnioal Speoifioations 3.1 A.1 shall be reported:

a. Reastor power histof){ starting 48 heurs prier te the first sample in

• ....hioh the limit was e>Eoeeded;

b. Results of the last isotopio analysis for radioiodine performed prior to e>Eoeedlng the limit, results of analysis 'l..hile limit '....as e>Eoeeded and results of one analysis after the radieiodine activity was reduoed to less than limit. Eaoh result should inolude date and time of sampling and the radioiodine astp.'ity was reduoed to less than limit.

Eaoh result should inolude date and time of sampling and the radioiodine oonoentrations;

o. Cleanup system flo'll history starting 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> prior to the first sample in '...,hioh the limit was e>Eoeeded;

d. Graph oj! the I 131 oonoentration and one other radioiodine isotope concentration in mioreouries per gram as a function of time for the duration oj! the specific acti\<ity abo\'e the steady state level; and

e. The time duration when the speoifio acti'/ilj' of the primary coolant e>Eoeeded the radioiodine limit C. DELETED 6.9.2 DELETED 6-13 (Pages 6-14,6-15, and 6-16 deleted)

Amendment No. 11, 37, 72, 77, 82, 117, 129, 254

6.17.1 Licensee initiated safety related changes to the radioactive waste system (liquid, gaseous and solid):

1. Shall be reported to the Commission in the Annual Report (Specification 6.9.19) fer the period in which the evaluation '.'las revie'.*Ied. The discussion of each change shall contain:

a. A summary of the evaluation that led to the determination that the change could be made in accordance '.*lith 10 CFR 50.59;

b. Sufficient detailed infermation to totally support the reason for the change

'.*Iithout benefit of additional or supplemental informatien;

c. A detailed description of the equipment, components and precesses invol'/ed and the interfaces *.*Iith other plant systems;

d. An e'/aluation of the change which sho,.*..s the predicted releases of radioactive materials in liquid and gaseous effluents and/or quantity of solid ",.'aste that differ from those pre'/iously predicted in the license application and amendments thereto;

e. An evaluation of the change which shows the expected maximum exposures to indi,.'iduals in the unrestricted area and to the general population that differ from those previously estimated in the license application and amendments thereto;

f. A comparison of the predicted releases of radioactive materials, in liquid and gaseous effluents and in solid 'Naste, to the actual releases for the period prior to *....hen the changes are to be made;

g. An estimate of the exposure to plant operating personnel as a result of the change; and

h. Documentation of the fact that the change was reviewed and appreved.

6.18 TECHNICAL SPECIFICATIONS (TS) BASES CONTROL PROGRAM This program provides a means for processing changes to the Bases of these Technical Specifications.

a. Changes to the Bases of the TS shall be made under appropriate administrative controls and reviews.

6-25 Amendment No. 72, 77, 102, 173, 207, 218, 256, ~