View source for TMI-14-023, Application to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Permonth, Using the Consolidated Line Item Improvement Process

{{Adams
| number = ML14127A424
| issue date = 05/07/2014
| title = Application to Revise Technical Specifications to Adopt TSTF-522, Revise Ventilation System Surveillance Requirements to Operate for 10 Hours Permonth, Using the Consolidated Line Item Improvement Process
| author name = Barstow J
| author affiliation = Exelon Generation Co, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000289
| license number = DPR-050
| contact person = 
| case reference number = TMI-14-023
| document type = Letter type:TMI
| page count = 13
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:TMI-14-023                                                                            10 CFR 50.90 May 7, 2014 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:==
Application to Revise Technical Specifications to Adopt TSTF-522, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours per Month," using the Consolidated Line Item Improvement Process

==References:==
: 1.      TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours per Month," dated March 30, 2010
: 2.      Notice of Availability of the "Model Safety Evaluation for Plant-Specific Adoption of Technical Specification Task Force Traveler TSTF-522, Revision 0, 'Revise Ventilation System Surveillance Requirements to Operate for 10 Hours per Month,' Using the Consolidated Line Item Improvement Process" dated September 20, 2012 In accordance with the provisions of 10 CFR 50.90, Exelon Generation Company, LLC (EGC) is submitting a request for an amendment to the Technical Specifications (TS) for Three Mile Island Nuclear Station, Unit 1 (TMI, Unit 1).
The proposed amendment would replace an existing Surveillance Requirement to operate ventilation systems with charcoal filters for a 10-hour period every 31 days with a requirement to operate the systems for greater than or equal to 15 continuous minutes every 31 days in accordance with Technical Specification Task Force (TSTF) Traveler TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours per Month."
Attachment 1 provides a description and assessment of the proposed changes, the requested confirmation of applicability, and plant-specific verifications. Attachment 2 provides the existing TS pages marked up to show the proposed changes. Attachment 3 provides existing TS Bases pages marked up to show the proposed changes, for information only.
These proposed changes have been reviewed and approved by TMI, Unit 1's Plant Operations Review Committee and by the Nuclear Safety Review Board in accordance with the requirements of the EGC Quality Assurance Program.
EGC requests approval of the proposed license amendment by May 7, 2015, with the amendment being implemented within 60 days of issuance.
There are no regulatory commitments contained in this letter.

May 7, 2014 U.S. Nuclear Regulatory Commission Page2 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), EGC 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 letter please contact Wendy E. Croft at (610) 765-5726.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the th day of May 2014.
Respectf~, f\LO..; ~*
James sf!sf::::
Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:         1. Description and Assessment
: 2. Proposed Technical Specification Changes (Mark-Up)
: 3. Proposed Technical Specification Bases Changes (Mark-Up)
For Information Only cc:       USNRC Region I, Regional Administrator USNRC Project Manager, TMI, Unit 1 USNRC Senior Resident Inspector, TMI, Unit 1 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 Description and Assessment Page 1 of 4

==1.0     DESCRIPTION==

The proposed change revises the Surveillance Requirements (SRs) which currently require operating ventilation systems for a 10-hour period every 31 days, as controlled in accordance with the Surveillance Frequency Control Program (SFCP). The SRs are revised to require operation of the systems for greater than or equal to 15 continuous minutes every 31 days, as controlled in accordance with the SFCP.
The proposed amendment is consistent with the model application in Technical Specification Task Force (TSTF) Traveler TSTF-522, Revision 0, "Revise Ventilation System Surveillance Requirements to Operate for 10 hours per Month" (TSTF-522).
2.0     ASSESSMENT 2.1     Applicability of Published Safety Evaluation Exelon Generation Company, LLC (EGC) has reviewed the model safety evaluation dated September 20, 2012 as part of the Federal Register Notice for Comment. This review included a review of the U.S. Nuclear Regulatory Commission's (NRC's) evaluation, as well as the information provided in TSTF-522. As described in the subsequent paragraphs, EGC has concluded that the justifications presented in the TSTF-522 proposal and the model safety evaluation prepared by the NRC are applicable to Three Mile Island Nuclear Station, Unit 1 (TMI, Unit 1) and justify this amendment for the incorporation of the changes to the TMI, Unit 1 Technical Specifications (TSs).
2.2     Optional Changes and Variations EGC is not proposing any significant variations or deviations from the TS changes described in the TSTF-522, Revision 0, or the applicable parts of the NRC's model safety evaluation dated September 20, 2012. EGC is noting the following minor variations from the TS changes described in the TSTF-522:
* The TMI, Unit 1 TS utilize different numbering and titles than the Standard Technical Specifications (STS) on which TSTF-522 was based. Specifically, the STS Section 3.7.10, "Control Room Emergency Ventilation System (CREVS)," and 3.7.13, "Fuel Storage Pool Ventilation System (FSPVS)," correspond to TMI, Unit 1 TS Section 4.12.1, "Emergency Control Room Air Treatment System," and 4.12.4, "Fuel Handling Building [Engineered Safety Feature] ESF Air Treatment System," respectively.
These changes are administrative and do not affect the applicability of TSTF-522 to the TMI, Unit 1 TS.
* TMI, Unit 1 TS Section 4.12.1, "Emergency Control Room Air Treatment System,"
and 4.12.4, "Fuel Handling Building ESF Air Treatment System," do not currently require "continuous" operation for the duration of the SR. However, this requirement is stated in the STS wording. Therefore, this requirement is being added to the TMI, Unit 1 TS to conform to the STS wording. This change does not affect the applicability of TSTF-522 to the TMI, Unit 1 TS.
Description and Assessment Page 2 of 4
* The TMI, Unit 1 TS does not have an equivalent STS Section 3.7.12, "Emergency Ventilation System (EVS)." In the Reference 5.1 Safety Evaluation the NRC issued a TS Amendment approving the removal of TMI, Unit 1's equivalent emergency ventilation system for the Auxiliary Building from TS Section 3.15.3, "Auxiliary and Fuel Handling Building Air Treatment System." Therefore, EGC did not include the proposed changes to the EVS TS. This change does not affect the applicability of TSTF-522 to the remainder of the TMI, Unit 1 TS.
EGC is noting the inclusion/exclusion of the following bracketed options provided in TSTF-522 for the TS changes:
* EGC excluded the bracketed references to heaters in the proposed Emergency Control Room Air Treatment System and Fuel Handling Building ESF Air Treatment System SR and Bases. The TMI, Unit 1 Emergency Control Room Air Treatment System and Fuel Handling Building ESF Air Treatment System have heaters; however, EGC did not include the bracketed references to heaters in the proposed SR and Bases as justified by TSTF-522, Section 4.0, "Technical Analysis," and the TMI TS. TSTF-522, Section 4.0 "Technical Analysis," discusses the use of heaters during the ventilation system operation and the Ventilation and Filter Testing Program (VFTP) requirement to test charcoal adsorbers in accordance with ASTM D3803-1989 at 30&deg; C, 95 percent relative humidity. The TSTF-522 states, "Plants which test ventilation system adsorption at a relative humidity of 95o/o do not require heaters for the ventilation system to perform its specified safety function consistent with [Regulatory Guide 1.52, Revision 3, Regulatory Position 4.9), given above. These plants may eliminate the reference to heaters in the Surveillance Requirements and Bases." TMI, Unit 1 does not have a TS required VFTP as described in, but not required by, TSTF-522. However, TMI, Unit 1 SRs 4.12.1.2.a, 4.12.4.1.b, and 4.12.4.2.a require ASTM D3803-1989 testing per TSs 3.15.1.2 and 3.15.4.2, respectively. TSs 3.15.1.2.b and 3.15.4.2.b require, "The results of laboratory carbon sample analysis shall show ~ 95&deg;/o radioactive methyl iodide decontamination efficiency when tested in accordance with ASTM D3803-1989 at 30&deg;C, 95&deg;/o R.H." Based on the justification above, EGC did not include the bracketed references to heaters in the proposed SR and Bases.
* EGC included the bracketed references to the SFCP in the proposed Emergency Control Room Air Treatment System and Fuel Handling Building ESF Air Treatment System SR and Bases. As noted in the NRC's model safety evaluation, some plants have adopted TSTF-425, "Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5b," which relocated fixed SR frequencies to a licensee-controlled program, the SFCP. In the Reference 5.2 Safety Evaluation the NRC issued a TS Amendment approving the SFCP for TMI, Unit 1.

==3.0      REGULATORY ANALYSIS==

3.1      No Significant Hazards Consideration Determination Exelon Generation Company, LLC (EGC) requests adoption of an approved change to Three Mile Island Nuclear Station, Unit 1 Technical Specifications (TS) to replace the existing Surveillance Requirements (SRs) of 4.12.1, "Emergency Control Room Air Treatment System,"
and 4.12.4, "Fuel Handling Building [Engineered Safety Feature] ESF Air Treatment System," to Description and Assessment Page 3 of 4 operate the ventilation systems with charcoal filters for a 10-hour period every 31 days with a requirement to operate the systems for greater than or equal to 15 continuous minutes every 31 days, as controlled in accordance with the Surveillance Frequency Control Program (SFCP).
As required by 10 CFR 50.91 (a), an analysis of the issue of no significant hazards consideration is presented below:
: 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed change replaces an existing SR to operate the Emergency Control Room Air Treatment System and the Fuel Handling Building ESF Air Treatment System for a 10-hour period at a frequency controlled in accordance with the SFCP with a requirement to operate the systems for greater than or equal to 15 continuous minutes at a frequency controlled in accordance with the SFCP.
These systems are not accident initiators and therefore, these changes do not involve a significant increase in the probability of an accident. The proposed system and filter testing changes are consistent with current regulatory guidance for these systems and will continue to assure that these systems perform their design function, which may include mitigating accidents. Thus, the change does not involve a significant increase in the consequences of an accident.
Therefore, it is concluded that this change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
: 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed change replaces an existing SR to operate the Emergency Control Room Air Treatment System and the Fuel Handling Building ESF Air Treatment System for a 10-hour period at a frequency controlled in accordance with the SFCP with a requirement to operate the systems for greater than or equal to 15 continuous minutes at a frequency controlled in accordance with the SFCP.
The change proposed for these ventilation systems does not change any system operations or maintenance activities. Testing requirements will be revised and will continue to demonstrate that the Limiting Conditions for Operation are met and the system components are capable of performing their intended safety functions. The change does not create new failure modes or mechanisms and no new accident precursors are generated.
Therefore, it is concluded that this change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
Description and Assessment Page4 of4
: 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No.
The proposed change replaces an existing SR to operate the Emergency Control Room Air Treatment System and the Fuel Handling Building ESF Air Treatment System for a 10-hour period at a frequency controlled in accordance with the SFCP with a requirement to operate the systems for greater than or equal to 15 continuous minutes at a frequency controlled in accordance with the SFCP. The proposed change is consistent with regulatory guidance.
Therefore, it is concluded that this change does not involve a significant reduction in a margin of safety.
Based on the above, EGC concludes that the proposed change 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.
4.0     ENVIRONMENTAL EVALUATION The proposed change 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, or would change an inspection or surveillance requirement. However, the proposed change 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 change 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 change.

==5.0      REFERENCES==

5.1      U.S. Nuclear Regulatory Commission letter, "Three Mile Island Nuclear Station, Unit 1, Re: Delete Requirements for Auxiliary and Fuel Handling Air Treatment System (TAC No. MB6695)," dated December 12, 2003 5.2      U.S. Nuclear Regulatory Commission letter, "Three Mile Island Nuclear Station, Unit 1, Issuance of Amendment Re: Request to Relocate Surveillance Frequencies to a Licensee-Controlled Program (TAC No. ME3587)," dated January 12, 2011

ATTACHMENT 2 Proposed Technical Specifications Changes (Mark-Up)
Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 REVISED TECHNICAL SPECIFICATIONS PAGES Page 4-55 Page 4-55f

4.12    AIR TREATMENT SYSTEM 4.12.1 EMERGENCY CONTROL ROOM AIR TREATMENT SYSTEM Applicability Applies to the emergency control room air treatment system and associated components.
Objective To verify that this system and associated components will be able to perform its design functions.
Specification 4.12.1.1        At the frequency specified in the Surveillance Frequency Control Program, the pressure drop across the combined HEPA filters and charcoal adsorber banks of AH-F3A and 3B shall be demonstrated to be less than 6 inches of water at system design flow rate (+/-10&deg;/o).
4.12.1.2        a.      The tests and sample analysis required by Specification 3.15.1.2 shall be performed initially and at the frequency specified in the Surveillance Frequency Control Program for standby service or after every 720 hours of system operation and following significant painting, steam, fire or chemical release in any ventilation zone communicating with the system that could contaminate the HEPA filters or charcoal adsorbers.
: b.      DOP testing shall be performed after each complete or partial replacement of the HEPA filter bank or after any structural maintenance on the system housing which could affect the HEPA filter bank bypass leakage.
: c.      Halogenated hydrocarbon testing shall be performed after each complete or partial replacement of the charcoal adsorber bank or after any structural maintenance on the system housing which could effect the charcoal adsorber bank bypass leakage.
: d.       Each AH-E18A and B (AH-F3A and B) fan/filter circuit shall be operating at least 10 hour.:s at the frequency specified in the Surveillance Frequency Control Progra .
4.12.1.3        At the frequency specifie in the Surveillance Frequency Control Program, automatic initiation of the qui red Control Building dampers for isolation and recirculation shall be demo strated as operable.
4.12.1.4        An air distribution test shall     performed on the HEPA filter bank initially, and after any maintenance or test g that could affect the air distribution within the system. The air distribution a oss the HEPA filter bank shall be uniform within
                +/-20&deg;/o. The test shall be perfor ed at 40,000 cfm (+/-10&deg;/o) flow rate.
4.12.1.5        Control Room Envelope unfiltere air in leakage testing shall be performed in accordance with the Control Roo Envelope Habitability Program.
operated for:::: 15 continuous minutes 4-55 Amendment No.55, 68, 149, 175, 223, 264,-214

4.12.4      FUEL HANDLING BUILDING ESF AIR TREATMENT SYSTEM Applicability Applies to Fuel Handling Building (FHB) ESF Air Treatment System and associated components.
Objective To verify that this system and associated components will be able to perform its design functions.
Specification 4.12.4.1    Each refueling interval prior to movement of irradiated fuel:
: a.       The pressure drop across the entire filtration unit shall be demonstrated to be less than 7.0 inches of water at 6,000 cfm flow rate (+/-10&deg;/o).
: b.       The tests and sample analysis required by Specification 3.15.4.2 shall be performed.
4.12.4.2    Testing necessary to demonstrate operability shall be performed as follows:
: a.       The tests and sample analysis required by Specification 3.15.4.2 shall be performed following significant painting, steam, fire, or chemical release in any ventilation zone communicating with the system that could contaminate the HEPA filters or charcoal adsorbers.
: b.       DOP testing shall be performed after each complete or partial replacement of a HEPA filter bank, and after any structural maintenance on the system housing that could affect the HEPA filter bank bypass leakage.
: c.       Halogenated hydrocarbon testing shall be performed after each complete or partial replacement of a charcoal adsorber bank, and after any structural maintenance on the system housing that could affect charcoal adsorber bank bypass leakage.
4.12.4.3     Each filter train shall be operated at least 10 hours at the frequency specified in the Surveillance Frequency Control Program.
4.12.4.4    An air flow distribution test shall be performe on the HEPA filter bank initially and after any maintenance or te ting that could affect the air flow distribution within the syste . The distribution across the HEPA filter bank shall b uniform within
              +/-20o/o. The test shall be performed at 6,000 cf +/- 10&deg;/o flow rate.
                                                                                  ~ 15 continuous minutes 4-55f Amendment No.     ~, ~

ATTACHMENT 3 Proposed Technical Specification Bases Changes (Mark-Up),
For Information Only Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 REVISED TECHNICAL SPECIFICATION BASES PAGES Page 4-55a Page 4-55g

Insert 1 BASES Pressure drop across the combined HEPA filters and charcoal adsorbers of less than 6 inches of water at the system design flow rate will indicate that the filters and adsorbers are not clogged by excessive amounts of foreign matter. Pressure drop should be determined at the frequency specified in the Surveillance Frequency Control Program to show system performance capability.
The frequency of tests and sample analysis are necessary to show that the HEPA filters and charcoal adsorbers can perform as evaluated. Tests of the charcoal adsorbers with halogenated hydrocarbon shall be performed in accordance with approved test procedures.
Replacement adsorbent should be qualified according to ASTM D3803-1989. The charcoal adsorber efficiency test procedures should allow for the removal of one adsorber tray, emptying of one bed from the tray, mixing the adsorbent thoroughly and obtaining at least two samples.
Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. If test results are unacceptable all adsorbent in the system shall be replaced. Tests of the HEPA filters with DOP aerosol shall also be performed in accordance with approved test procedures. Any HEPA filters found defective should be replaced with filters qualified according to Regulatory Guide 1.52 March 1978.
Operation of the system for 10 hours at the frequency specified in the Surveillance Frequency Control Program will demonstrate operability of the filters and adsorber system and remove excessive moisture built up on the adsorber.
If significant painting, steam, fire or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals or foreign materials, the same tests and sample analysis shall be performed as required for operational use. The determination of significance shall be made by the Vice President-TMI Unit 1.
Demonstration of the automatic initiation of the recirculation mode of operation is necessary to assure system performance capability. Dampers required for control building isolation and recirculation are specified in UFSAR Sections 7.4.5 and 9.8.1.
Control Room Envelope unfiltered air in leakage testing verifies the OPERABILITY of the CRE boundary by testing for unfiltered air inleakage past the CRE boundary and into the CRE. The details of the testing are specified in the Control Room Envelope Habitability Program.
The CRE is considered habitable when the radiological dose to CRE occupants calculated in the licensing basis analyses of DBA consequences is no more than 5 rem TEDE and the CRE occupants are protected from hazardous chemicals and smoke. Air inleakage testing verifies that the unfiltered air inleakage into the CRE is no greater than the flow rate assumed in the licensing basis analyses of DBA consequences. When unfiltered air in leakage is greater than the assumed flow rate, Section 3.15.1.5 must be entered. The required actions allow time to restore the CRE boundary to OPERABLE status provided mitigating actions can ensure that the CRE remains within the licensing basis habitability limits for the occupants following an accident. Compensatory measures are discussed in Regulatory Guide 1.196, Section C.2.7.3, (Ref. 1) which endorses, with exceptions, NEI 99-03, Section 8.4 and Appendix F (Ref. 2).
These compensatory measures may also be used as mitigating actions as required by Section 3.15.1.5. Temporary analytical methods may also be used as compensatory measures to 4-55a Amendment No. 55, 179, 218,       22~,  226, 264, ~

Insert 1 The FHB ESF Air Treatment System is a system which is normally kept in a "standby" operating status.
Tests and sample analysis assure that the HEPA filters and charcoal adsorbers can perform as evaluated.
The charcoal adsorber efficiency test procedure should allow for the removal of a sample from one adsorber test canister. Each sample should be at least two inches in diameter and a length equal to the thickness of the bed. The in-place test criteria for activated charcoal will meet the guidelines of ANSI-N510-1980. The laboratory test of charcoal will be performed in accordance with ASTM 03803-1989. If laboratory test results are unacceptable, all adsorbent in the system shall be replaced with an adsorbent qualified in accordance with ASTM 03803-1989. Any HEPA filters found defective will be replaced with filters qualified in accordance with ANSI-N509-1980.
Pressure drop across the entire filtration unit of less than 7.0 inches of water at the system design flow rate will indicate that the filters and adsorbers are not clogged by excessive amounts of foreign matter.
Operation of the system for 10 hours at the frequency specified in the Surveillance Frequency Control Program '*'*'ill demonstrate operability of the filters and adsorber system and remove excessive moisture buildup on the adsorbers and !=I EPA filters.
If significant painting, steam, fire, or chemical release occurs such that the HEPA filter or charcoal adsorber could become contaminated from the fumes, chemicals or foreign material, the same tests and sample analysis shall be performed as required for operational movement of irradiated fuel. The determination of what is significant shall be made by the Vice President-TMI Unit 1.
4-55g Amendment No. 122, 157, 179, 218, 226, 2+4

Insert 1 Operation for 2: 15 continuous minutes at the frequency specified in the Surveillance Frequency Control Program demonstrates OPERABILITY of the system. Periodic operation ensures that blockage, fan or motor failure, or excessive vibration can be detected for corrective action.}}