ML20351A451

License Amendment Request, Proposed Revision to License Conditions and Permanently Defueled Technical Specifications for Permanent Removal of Irradiated Fuel from the Spent Fuel Pool (ISFSI-Only Tech Specs)

ML20351A451
Person / Time
Site:	Three Mile Island, 07201031
Issue date:	12/16/2020
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
TM-20-032
Download: ML20351A451 (84)

Text

Michael P. Gallagher Exelon Nuclear Vice President License Renewal and Decommissioning 200 Exelon Way Kennett Square, PA 19348 610 765 5958 Office 610 765 5658 Fax www.exeloncorp.com michaelp.gallagher@exeloncorp.com 10 CFR 50.90 TM-20-032 December 16, 2020 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:

License Amendment Request - Proposed Revision to License Conditions and Permanently Defueled Technical Specifications for Permanent Removal of Irradiated Fuel from the Spent Fuel Pool (ISFSI-Only Technical Specifications)

References:

1) Letter from J. Bradley Fewell (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Certification of Permanent Cessation of Power Operations for Three Mile Island Nuclear Station, Unit 1," dated June 20, 2017 (Accession No. ML17171A151)

2) Letter from Michael P. Gallagher (Exelon Generation Company, LLC), to U.S. Nuclear Regulatory Commission, Certification of Permanent Removal of Fuel from the Reactor Vessel for Three Mile Island Nuclear Station, Unit 1, dated September 26, 2019 (Accession No. ML19269E480)

3) Letter from Michael P. Gallagher (Exelon Generation Company, LLC), to U.S. Nuclear Regulatory Commission, Three Mile Island Nuclear Station, Unit 1 -

Post-Shutdown Decommissioning Activities Report, dated April 5, 2019 (Accession No. ML19095A041)

4) Letter from Michael P. Gallagher (Exelon Generation Company, LLC), to U.S.

Nuclear Regulatory Commission, Spent Fuel Management Plan for Three Mile Island Nuclear Station - Unit 1, dated April 5, 2019 (Accession No. ML19095A009)

5) Letter from John M. Goshen (U.S. Nuclear Regulatory Commission) to Wren Fowler (NAC International), Issuance of Certificate of Compliance No. 1031, Amendment No. 6

U.S. Nuclear Regulatory Commission TMI-1 License Amendment Request Docket Nos. 50-289 December 16, 2020 Page 2 for the MAGNASTOR Cask System (CAC NO. L25069), dated November 30, 2106 (ADAMS Accession No ML16319A068)

Pursuant to 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (Exelon) requests amendments to the Renewed Facility License (RFL) and Appendix A, Technical Specifications (TS), of RFL No. DPR-50 for Three Mile Island Nuclear Station, Unit 1 (TMI-1). The proposed amendment would revise the RFL and the Permanently Defueled Technical Specifications (PDTS) to align with those required for an Independent Spent Fuel Storage Installation (ISFSI) only, consistent with the permanent removal of all irradiated fuel from the Spent Fuel Pool (SFP).

By letter dated June 20, 2017 (Reference 1), Exelon provided formal notification to the U.S.

Nuclear Regulatory Commission (NRC) that Exelon had determined to permanently cease operations at TMI-1 on or about September 30, 2019. In Reference 2, Exelon provided formal notification in accordance with 10 CFR 50.82(a)(1)(ii) certifying all fuel has been permanently removed from the TMI-1 reactor vessel and placed in the SFP. Therefore, in accordance with 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for TMI-1 no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel.

TMI-1 is in the process of constructing an ISFSI with irradiated fuel beginning to be transferred in late 2021. On April 5, 2019 Exelon submitted the Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 3) and the Spent Fuel Management Plan (SFMP) (Reference 4) for TMI-1. The PSDAR documents the TMI-1 expectation that all irradiated fuel be completely transferred to the ISFSI by the end of 2022. Exelon is requesting the proposed changes to the TMI-1 RFL and associated PDTS to comport to a facility configuration with all irradiated nuclear fuel in dry storage within the ISFSI, in accordance with 10 CFR 50.36(c)(6).

TMI-1 will be using the NRC approved NAC International (NAC) MAGNASTOR Cask System to store their irradiated fuel. Amendment 6 to the standardized NAC MAGNASTOR Cask System Certificate of Compliance (CoC) No. 1031 revised the technical specifications so that there is no longer a requirement to return irradiated fuel to an SFP (Reference 5). Exelon is also proposing a revision to the Design Features chapter of the TMI-1 PDTS, Section 5.2.1, Spent Fuel Storage Facilities, which prohibits the storage of irradiated fuel in the TMI-1 SFPs.

As discussed in this submittal, the remaining design basis accidents (DBA) and transients associated with fuel analyzed in Chapter 6 of the TMI-1 Defueled Safety Analysis Report (DSAR) are no longer applicable for the condition where all irradiated nuclear fuel is transferred to dry cask storage within an ISFSI. to this letter provides a detailed description and evaluation of the proposed changes, including the no significant hazards determination. Attachment 2 contains a markup of the current RFL and TS pages, including Bases.

The proposed changes have been reviewed and approved by the TMI-1 Safety Review Committee in accordance with the requirements of the Exelon Decommissioning Quality Assurance Program.

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

U.S. Nuclear Regulatory Commission TMI-1 License Amendment Request Docket Nos. 50-289 December 16, 2020 Page 3 Exelon requests review and approval of this proposed amendment by February 26, 2022. Once approved, the amendment will be implemented within ninety (90) days following Exelon's submittal of written notification to the NRC that all irradiated nuclear fuel assemblies have been transferred out of the SFP and placed in dry storage within the ISFSI.

There are no regulatory commitments contained within this submittal.

In accordance with 10 CFR 50.91 "Notice for public comment; State consultation" paragraph (b),

Exelon 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.

If you have any questions concerning this submittal, please contact Leslie Holden at (630) 657-2524.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 16th day of December 2020.

Respectfully, Digitally signed by Gallagher, Gallagher, Michael P Michael P Date: 2020.12.16 15:52:25 -05'00' Michael P. Gallagher Vice President, License Renewal & Decommissioning Exelon Generation Company, LLC Attachments: 1. Evaluation of Proposed Changes

2. Markup of Proposed Technical Specifications Pages cc: w/Attachments Regional Administrator - NRC Region I NRC Project Manager, NMSS/DUWP/RDB - Three Mile Island, Unit 1 NRC Project Manager, NMSS/DUWP/RDB - Three Mile Island, Unit 2 Director, Bureau of Radiation Protection - PA Department of Environmental Resources

Attachment 1 License Amendment Request Three Mile Island Nuclear Station, Unit 1 Docket Nos. 50-289 EVALUATION OF PROPOSED CHANGES

Subject:

Proposed Changes to Renewed Facility License and Appendix A, Technical Specifications 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION AND BASIS FOR THE CHANGES

3.0 REGULATORY EVALUATION

3.1 Applicable Regulatory Requirements/Criteria 3.2 Precedent 3.3 No Significant Hazards Consideration 3.4 Conclusion

5.0 REFERENCES

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 1 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes 1.0

SUMMARY

DESCRIPTION Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes an amendment to the Renewed Facility License (RFL) No. DPR-50 and the associated Appendix A, Permanently Defueled Technical Specifications (PDTS), for Three Mile Island Nuclear Station, Unit 1 (TMI-1).

The proposed license amendment request (LAR) would revise the RFL and the PDTS to reflect removal of all TMI-1 irradiated nuclear fuel from the spent fuel pools (SFPs) and its transfer to dry cask storage within the onsite Independent Spent Fuel Storage Installation (ISFSI).

By letter dated June 20, 2017 (+ 5.1), Exelon provided formal notification to the U.S. Nuclear Regulatory Commission (NRC) that Exelon had determined to permanently cease operations at TMI-1 on or about September 30, 2019. In Reference 5.2, Exelon provided formal notification in accordance with 10 CFR 50.82(a)(1)(ii) certifying all fuel has been permanently removed from the TMI-1 reactor vessel and placed in the SFPs. Therefore, in accordance with 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for TMI-1 no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel.

Exelon previously submitted LARs to the NRC to revise the TMI-1 Technical Specifications (TS) administrative requirements (Reference 5.3) and technical requirements (References 5.4 and 5.5) to address the permanently defueled condition of TMI-1. The NRC subsequently approved these requests in References 5.6 and 5.7.

On April 5, 2019 Exelon submitted the Post-Shutdown Decommissioning Activities Report (PSDAR) (Reference 5.8) and the Spent Fuel Management Plan (SFMP) (Reference 5.9) for TMI-1. The PSDAR documents the TMI-1 expectation that all irradiated fuel will be completely transferred to the ISFSI by the end of December of 2022.

In support of this condition, the TMI-1 license and associated Permanently Defueled Technical Specifications (PDTS) are being proposed for revision, in accordance with 10 CFR 50.36(c)(6),

to comport to a facility configuration with all irradiated nuclear fuel in dry storage within the onsite ISFSI at TMI-1 using casks certified for use under a general 10 CFR 72 license.

The current TMI-1 license provides requirements for safe storage and management of irradiated fuel stored in the SFPs. As such, the existing License Conditions and PDTS provide a level of control in excess of that needed for safe storage and management of irradiated fuel after all irradiated fuel is stored within the ISFSI. Once all irradiated fuel assemblies have transferred to the ISFSI, several License Conditions and all remaining Limiting Conditions for Operations (LCOs) and associated Surveillance Requirements (SRs) are being proposed for deletion.

Additionally, the design feature describing the Spent Fuel Storage (Section 5.2.1) will be modified to no longer allow storage of irradiated fuel in the TMI-1 SFPs. The proposed changes also include relocating most administrative controls from Section 6, "Administrative Controls," of the PDTS to the Exelon Decommissioning Quality Assurance Program (DQAP). The DQAP was previously approved by the NRC (Reference 5.10) and is a licensee- controlled document controlled in accordance with 10 CFR 50.54(a). This relocation to the DQAP is being proposed pursuant to the criteria contained in 10 CFR 50.36 and in accordance with recommendations contained in NRC Administrative Letter 95-06, Relocation of Technical Specification Administrative Controls Related to Quality Assurance (Reference 5.11).

The proposed TSs will be referred to as the ISFSI Only Technical Specifications (IOTS).

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 2 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes 2.0 DETAILED DESCRIPTION AND BASIS FOR THE CHANGES 2.1 General Discussion Exelon is in the process of decommissioning TMI-1. In support of this activity, all the irradiated fuel will be transferred from the SFPs to the ISFSI. The proposed changes to the TMI-1 PDTS reflect the removal of all the irradiated fuel from the SFPs and provide a restriction that prohibits irradiated fuel from being stored in the SFPs.

TMI-1 is in the process of constructing an ISFSI with irradiated fuel beginning to be transferred in late 2021. As stated in section 1.0, TMI-1 expects that all irradiated fuel will be transferred to the newly constructed ISFSI by the end of 2022. TMI-1 will be using the NRC approved NAC International (NAC) MAGNASTOR Cask System to store their irradiated fuel. Amendment 6 to the standardized NAC MAGNASTOR Cask System Certificate of Compliance (CoC) No. 1031 revised the CoC technical specifications removing the requirement to return irradiated fuel to a SFP once it has been transferred to the ISFSI. The revised MAGNASTOR TS would not require a user to maintain spent fuel pool related programs when a spent fuel pool is no longer required or exists. (Reference 5.12).

Exelon is also proposing a revision to the Design Features chapter of the TMI-1 PDTS, Section 5.2.1, "Spent Fuel Storage Facilities," which prohibits the storage of irradiated fuel in the SFPs.

This is in alignment with the NAC MAGNASTOR Cask System CoC No. 1031 which no longer requires fuel to be returned to the SFP for inspection.

2.2 Technical Discussion The existing PDTS contain LCOs that provide for appropriate requirements for safe storage and management of irradiated fuel with fuel stored in the SFPs. As such, the existing PDTS provide a level of control in excess of that needed for safe storage and management of irradiated fuel after all irradiated fuel removed from the SFPs and stored in an ISFSI. Once all irradiated fuel assemblies have been transferred to the ISFSI, all remaining LCO (and associated SRs) will no longer be applicable and are being proposed for deletion. The proposed changes will result in Technical Specifications applicable to TMI-1 after the all irradiated fuel has been removed from the SFPs and placed within the ISFSI. As noted in section 1.0, the proposed TS will be referred to as the IOTS.

The cask storage system being used to store irradiated fuel in the ISFSI is a passive system that does not rely on electrical power for heat transfer. With removal of the irradiated fuel from the SFPs, there are no remaining irradiated fuel assemblies to be monitored and there will be no credible fuel related accidents that require actions of a Shift Manager, Certified Fuel Handler (CFH), or a Non-Certified Operator (NCO) to prevent occurrence or mitigate the consequences of any event.

As previously provided in the PSDAR (Reference 5.8), Exelon plans to continue using the SAFSTOR decommissioning method, in which fluid systems are drained and the plant is left in a stable condition until final dismantlement. Administrative controls that are required to be in place when decontamination or dismantling activities of radioactive systems, structures, and components are being performed are designed to minimize the likelihood of an off-normal or accident event, and thereby the consequences of such an event. The proposed changes do not

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 3 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes have an adverse impact on the remaining decommissioning activities or any of their postulated consequences.

The irradiated fuel will be stored in the ISFSI until it is shipped off site in accordance with the schedules described in the PSDAR and updated Spent Fuel Management Plan.

The proposed changes to the Section 6 of the TMI-1 PDTS involve relocating the majority of the administrative requirements to the DQAP and subsequently controlling them in accordance with 10 CFR 50.54(a). Maintaining control of the relocated information under established regulatory change processes provide adequate control based on the ISFSI-only status of the facility.

Relocation of information to the DQAP is being proposed pursuant to the criteria contained in 10 CFR 50.36(iii)(5) and in accordance with recommendations contained in NRC Administrative Letter 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance," (Reference 5.11). PDTS Section 6.12, High Radiation Area, will be maintained in the IOTS and renumbered to IOTS 6.1.

2.3 Applicable Design Bases Analysis In the submittal for the PDTS (Reference 5.4) three Design Basis Accidents (DBAs) were applicable to TMI-1 at the time of PDTS implementation. These included: (a) Fuel Handling Accident (FHA) in the Spent Fuel Pool (SFP); (b) the Waste Gas Tank Rupture Event (WGTR);

and (c) the Cask Drop Accident. These DBAs are addressed in Chapter 6 of the TMI-1 Defueled Safety Analysis Report (DSAR).

The WGTR event per Reference 5.4 was bounded by the source term analyzed in the FHA.

The Waste Gas Tanks were used during the shutdown and subsequent water transfer activities.

The contents of the Waste Gas Tanks were released, and the Waste Gas System has been isolated, permanently vented to atmosphere, and removed from service. Therefore, this accident analysis is no longer applicable to TMI-1.

The Cask Drop Accident has been deleted from the TMI-1 Design Basis. The Fuel Handling Building (FHB) crane has been replaced with a single-failure-proof crane. Reference 5.13 approved the removal of TS LCO 3/4.1.4 "Handling of Irradiated Fuel with the Fuel Handling Building Crane." Upgrading the FHB load handling system to a NUREG-0554 compliant single-failure-proof crane and operating the FHB crane in accordance with the Exelon Control of Heavy Loads Program improved the load handling system reliability to an acceptably low probability of a fuel cask drop such that the Fuel Cask Drop Accident is no longer considered to be credible.

The remaining DBA for TMI-1 in the permanently shutdown and defueled condition is the FHA in the SFP. The FHA in the SFP is predicated on irradiated fuel being stored in the SFPs.

However, upon transfer of all irradiated fuel to storage in the ISFSI, and the restriction that irradiated fuel can no longer be stored in the SFPs makes the FHA in the SFP no longer credible.

Based on the above, once all of the irradiated fuel has been removed from the SFPs, there will be no remaining design basis accidents or transients in Chapter 6 of the DSAR. Therefore, in this condition there are no credible accidents whose prevention or mitigation would need to be addressed by plant technical specifications.

The irradiated fuel storage dry casks used in the ISFSI are subject to their own CoC and associated storage canister TS.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 4 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes 2.4 Detailed Review of General Design Criteria TMI-1 was designed and constructed taking into consideration the general criteria for nuclear power plant construction permits as listed in the proposed Atomic Energy Commission (AEC)

General Design Criteria (GDC), dated July 1967 (Reference 5.14). The GDC criteria pertain to the design features of systems pertaining to the safe operation of and prevention of radiological releases as a result of nuclear fuel in the facility that are required in the interest of public health and safety.

In the submittal for the PDTS (Reference 5.4) TMI-1 provided a detailed review of the GDC and provided the basis for the limited applicability of the GDC to TMI-1 in a permanently shutdown condition. For the applicability of the remaining GDC identified in the PDTS submittal, TMI-1 conducted a similar review based on all of the irradiated fuel being placed in the ISFSI (ISFSI only condition).

Once all of the irradiated fuel has been permanently removed from the SFPs and stored in casks in the ISFSI, the GDC have limited applicability. After all the irradiated fuel has been transferred to the ISFSI, the potential radiation sources at the facility are greatly diminished.

Additionally, after the radwaste processing systems have been permanently removed from service, the possibility of radiological release from any radwaste system installed at the facility in accordance with the GDC is not possible. The applicability to TMI-1 of each of the remaining AEC criterion in the ISFSI-only condition may be categorized as follows:

A. Not Applicable (N/A) (ISFSI Only) - These design criteria were provided to protect the public from the hazards associated with the failure of irradiated fuel within the facility.

With the irradiated fuel stored in dry casks in the ISFSI, these design criteria are not needed. The AEC GDC is no longer applicable to TMI-1 since the intent and scope of the criteria are based on conditions no longer possible at TMI-1.

B. Not Applicable (N/A) (No Radwaste Processing) - These design criteria were provided to protect the public from the hazards associated with the processing of radwaste. With the termination of radwaste processing activities via the installed radwaste systems at TMI-1, these design criteria are no longer applicable. The installed radwaste systems are to be permanently removed from service once the final SFP water is processed and the SFPs is cleaned. The AEC GDC is no longer applicable to TMI-1 since the intent and scope of the criteria are based on conditions no longer possible at TMI-1.

Table 1 provides GDC that remained applicable as provided in the PDTS submittal (Reference 5.4) and the disposition of their applicability based on TMI-1 being in an ISFSI only condition or no radwaste processing condition. The justification for the determination of the applicability of the remaining GDC is provided following Table 1.

Table 1 - TMI-1 Compliance with AEC Proposed Design Criteria AEC General Design Criteria Applicability B. N/A (No Radwaste Criterion 1 Quality Standards Processing)

Criterion 2 Performance Standards B. N/A (No Radwaste Processing)

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 5 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes AEC General Design Criteria Applicability Criterion 3 Fire Protection A. N/A (ISFSI Only)

Criterion 4 Sharing of Systems B. N/A (No Radwaste Processing)

Criterion 5 Records Requirements B. N/A (No Radwaste Processing)

Criterion 11 Control Room A. N/A (ISFSI Only)

Criterion 17 Monitoring Radioactivity Release B. N/A (No Radwaste Processing)

Criterion 18 Monitoring Fuel and Waste Storage B. N/A (No Radwaste Processing)

Criterion 66 Prevention of Fuel Storage Criticality A. N/A (ISFSI Only)

Criterion 67 Fuel and Waste Storage Decay Heat A. N/A (ISFSI Only)

Criterion 68 Fuel and Waste Storage Shielding B. N/A (No Radwaste Processing)

Criterion 69 Protection Against Radioactivity Release A. N/A (ISFSI Only) from Spent Fuel and Waste Storage Criterion 70 Control of Releases of Radioactivity to the B. N/A (No Radwaste Environment Processing)

Criterion 1 - Quality Standards [N/A - No Radwaste Processing]

Those systems and components of reactor facilities which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences shall be identified and then designed, fabricated, and erected to quality standards that reflect the importance of the safety function to be performed. Where generally recognized codes or standards on design, materials, fabrication, and inspection are used, they shall be identified. Where adherence to such codes or standards does not suffice to assure a quality product in keeping with the safety function, they shall be supplemented or modified as necessary. Quality Assurance programs, test procedures, and inspection acceptance levels used shall be identified. A showing of sufficiency and applicability of codes, standards, Quality Assurance programs, test procedures, and inspection acceptance levels used is required.

Discussion:

This GDC is programmatic and administrative and remains applicable while there are other GDCs that remain applicable. After all irradiated fuel is in the ISFSI and radwaste processing systems have been permanently removed from service there will be no other GDCs applicable.

Removing this design criteria from the licensing basis has no effect on the applicability of 10 CFR 50 Appendix B. The quality requirements of the Exelon DQAP (Reference 5.15) will continue to apply to TMI-1.

Criterion 2 - Performance Standards [N/A - No Radwaste Processing]

Those systems and components of Reactor Building facilities which are essential to the prevention of accidents, which could affect the public health and safety or to mitigation of

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 6 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes their consequences shall be designed, fabricated, and erected to performance standards that will enable the facility to withstand, without loss of the capability to protect the public, the additional forces that might be imposed by natural phenomena such as earthquakes, tornados, flooding conditions, winds, ice, and other local site effects. The design bases so established shall reflect: (1) appropriate consideration of the most severe of these natural phenomena that have been recorded for the site and the surrounding area, and (2) an appropriate margin for withstanding forces greater than those recorded to reflect uncertainties about the historical data and their suitability as a basis for design.

Discussion:

After all of the irradiated fuel is moved to the ISFSI and radwaste processing systems have been permanently removed from service, there are no radioactive material sources within TMI-1 outside of the ISFSI where an external hazard could cause system damage and possibly affect the public health and safety. There will be no single mis-operation or credible accident which could cause a release of a radioactive liquid, gas, or solid which would exceed the limits on effluents specified in 10 CFR 20, "Standards for Protection Against Radiation." Design protection of plant systems, structures, and components (SSCs) "essential to the prevention of accidents, which could affect the public health and safety or to mitigation of their consequences" from external events (earthquake, aircraft impact, wind, snow or flooding) is no longer required for public safety.

Criterion 3 - Fire Protection [N/A - ISFSI Only]

The reactor facility shall be designed: (1) to minimize the probability of events such as fires and explosions, and (2) to minimize the potential effects of such events on safety.

Noncombustible and fire resistant materials shall be used whenever practical throughout the facility, particularly in areas containing critical portions of the facility such as containment, Control Room, and components of engineered safety features.

Discussion:

This GDC pertains to the design of the facility to minimize the probability of events such as fires and explosions, and to minimize the potential effects of such events on safety.

Removing this design criteria from the licensing basis has no effect on the applicability of 10 CFR 50.48, Fire protection. The TMI-1 Fire Protection Program will continue to be required and to comply with the requirements of 10 CFR 50.48(f) and the explanation of those requirements in Regulatory Guide 1.191, "Fire Protection Program for Nuclear Power Plants During Decommissioning and Permanent Shutdown" (Reference 5.16).

Criterion 4 - Sharing of Systems [N/A - No Radwaste Processing]

Reactor facilities shall not share systems or components unless it is shown safety is not impaired by the sharing.

Discussion:

After all irradiated fuel is in the ISFSI and radwaste processing systems have been permanently removed from service, there are no shared systems with a safety function which could be impaired by sharing.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 7 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes Criterion 5 - Records Requirements [N/A - No Radwaste Processing]

Records of the design, fabrication, and construction of essential components of the plant shall be maintained by the licensee or under corporate control throughout the life of the reactor.

Discussion:

This GDC is programmatic and administrative and remains applicable while there are other GDCs that remain applicable. After all irradiated fuel is in the ISFSI and radwaste processing systems have been permanently removed from service, there are no other applicable GDC.

Removing this design criteria from the licensing basis has no effect on the requirements for record retention. Records will be required to be maintained in accordance with the requirements of 10 CFR 50.71(c), 10 CFR 50.59(d)(3), and Criterion XVII of Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, except as exempted in Reference 5.17. The records retention requirements of the Exelon DQAP will continue to apply to TMI-1.

Criterion 1 - Control Room [N/ A - ISFSI Only]

The facility shall be provided with a Control Room from which actions to maintain safe operational status of the plant can be controlled. Adequate radiation protection shall be provided to permit access, even under accident conditions, to equipment in the Control Room or other areas as necessary to shut down and maintain safe control of the facility without radiation exposure of personnel in excess of 10 CFR 20 limits. It shall be possible to shut the reactor down and maintain it in a safe condition if access to the Control Room is lost due to fire or other cause.

Discussion:

This GDC ensure that the facility maintains a central command facility from which actions to maintain safe operation of the facility can be controlled. Adequate radiation protection shall be provided to permit access, even under accident conditions, to equipment in the Control Room or other areas as necessary to shut down and maintain safe control of the facility without radiation exposure of personnel in excess of 10 CFR 20 limits.

After all irradiated fuel moved to the ISFSI, as stated above there will be no credible DBAs and therefore no design basis mitigation actions will be required. Neither a Control Room nor a central command function are required to maintain safe control of the facility.

Criterion 17 - Monitoring Radioactivity Release [N/A - No Radwaste Processing]

Means shall be provided for monitoring the containment atmosphere, the facility effluent discharge paths, and the facility environs for radioactivity that could be released from normal operations, from anticipated transients, and from accident conditions.

Discussion:

After all irradiated fuel is in the ISFSI and radwaste processing systems have been permanently removed from service, there will be no means for radioactive gas (from the facility) to be generated or released, and all liquid releases will be deliberately controlled and released in

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 8 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes batches after sampling and analysis confirms compliance with 10 CFR 20 limits as required by the Radiological Effluent Controls Program (RECP).

Removing this design criteria from the licensing basis has no effect on the requirements for control of radioactive effluents. The requirements of the RECP described in Technical Specification 6.8.4.b, which is proposed for relocation to the DQAP per this LAR, will continue to apply.

Criterion 18 - Monitoring Fuel and Waste Storage [N/A - No Radwaste Processing]

Monitoring and alarm instrumentation shall be provided for fuel and waste storage and handling areas for conditions that might contribute to loss of continuity in decay heat removal and to radiation exposures.

Discussion:

After all irradiated fuel is in the ISFSI and radwaste processing systems have been permanently removed from service, there will be no means for radioactive gas (from the facility) to be generated, collected, or released, and the concentrations of radioactive material in liquids will be controlled such that they will not pose a serious personnel exposure hazard. There is no longer a requirement for decay heat removal and radiation exposure controls will be maintained by the Radiation Protection Program as required by 10 CFR 20.

Removing this design criteria from the licensing basis has no effect on the Radiation Protection Program and the requirements for the Radiation Protection Program described in 10 CFR 20 will continue to apply.

Criterion 66 - Prevention of Fuel Storage Criticality [N/A - ISFSI Only]

Criticality in new and spent fuel storage shall be prevented by physical systems or processes. Such means as geometrically safe configurations shall be emphasized over procedural controls.

Discussion:

This GDC ensures that criticality in new and spent fuel storage will be prevented by physical systems or processes. Such means as geometrically safe configurations shall be emphasized over procedural controls.

After all irradiated fuel moved to the ISFSI and no irradiated fuel in the SFP or otherwise within the facility, there is no need for criticality controls in the facility.

Criterion 67 - Fuel and Waste Storage Decay Heat [N/A - ISFSI Only]

Reliable decay heat removal systems shall be designed to prevent damage to the fuel in storage facilities that could result in radioactivity release to plant operating areas or the public environs.

Discussion:

This GDC ensures that reliable decay heat removal systems are designed to prevent damage to the fuel in storage facilities that could result in radioactivity release to plant operating areas or the public environs.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 9 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes After all irradiated fuel moved to the ISFSI and no irradiated fuel in the SFP or otherwise within the facility there is no need for decay heat removal systems in the facility.

Criterion 68 - Fuel and Waste Storage Shielding [N/A - No Radwaste Processing]

Shielding for radiation protection shall be provided in the design of spent fuel and waste storage facilities as required to meet the requirements of 10 CFR 20.

Discussion:

After all irradiated fuel is in the ISFSI and radwaste processing systems have been permanently removed from service, there will be no means for radioactive gas (from the facility) to be to be to be generated, collected, or released, and the concentrations of radioactive materials in liquids will be insufficient to pose a serious personnel exposure hazard. Radiation exposure controls, including shielding, will be maintained by the Radiation Protection Program as required by 10 CFR 20.

Removing this design criteria from the licensing basis has no effect on the requirements for a Radiation Protection Program and the requirements for the Radiation Protection Program described in 10 CFR 20 will continue to apply.

Criterion 69 - Protection Against Radioactivity Release from Spent Fuel and Waste Storage

[N/A - No Radwaste Processing]

Containment of fuel and waste storage shall be provided if accidents could lead to release of undue amounts of radioactivity to the public environs.

Discussion:

After all irradiated fuel is in the ISFSI, there will be no significant gas or liquid sources within the facility. The Fuel Handling Accident and Waste Gas Tank Rupture are no longer possible, and no containment will be required for public safety.

Criterion 70 - Control of Releases of Radioactivity to the Environs [N/A - No Radwaste Processing]

The facility design shall include those means necessary to maintain control over the plant radioactive effluents, whether gaseous, liquid, or solid effluents. Appropriate holdup capacity shall be provided for retention of gaseous, liquid, or solid effluents, particularly where unfavorable environmental conditions can be expected to require operational limitations upon the release of radioactive effluents to the environment. In all cases, the design for radioactivity control shall be justified (a) on the basis of 10 CFR 20 requirements for normal operations and for any transient situation that might reasonably be anticipated to occur and (b) on the basis of 10 CFR 100 dosage level guidelines for potential reactor accidents of exceedingly low probability of occurrence except that reduction of the recommended dosage levels may be required where high population densities or very large cities can be affected by the radiological effluents.

Discussion:

After all irradiated fuel is in the ISFSI and there are no further radwaste processing activities, there will be no measurable radioactive gas (from the facility) to be released and all liquid releases will be deliberately controlled and released in batches after sampling and analysis

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 10 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes confirms compliance with 10 CFR 20 limits as required by the RECP. Since the reactor has been permanently defueled, there are no design considerations needed to address 10 CFR 100.

Removing this design criteria from the licensing basis has no effect on the requirements for control of radioactive effluents. The requirements of the RECP required by Technical Specification 6.8.4.b, which is proposed for relocation to the DQAP per this LAR, will continue to apply.

2.5 10 CFR Part 50 Facility License and PDTS Proposed Changes The proposed changes to the Faculty License are as follows:

• Delete License Condition 1.j related to aging management

• Delete License Condition 2.c.(17) related to mitigation strategies

• Delete License Condition 2.c.(21) related to maintaining programs and activities for managing the effects of aging during the extended operation

• Delete License Condition 2.c.(22) to related to the restriction of handling irradiated fuel in the SFP for 60-days post permanent shutdown.

10 CFR 50.36, "Technical specifications," promulgates the regulatory requirements related to the content of TSs. As detailed in Section 3.1.4 of this attachment, this regulation lists four criteria to define the scope of equipment and parameters that must be included in the TSs. In a permanently defueled condition, the scope of equipment and parameters that must be included in the TMI-1 PDTS is limited to those needed to address the remaining applicable DBAs so that the consequences of the accident are maintained within acceptable limits.

The following table provides a summary of which PDTS sections are being deleted in their entirety and which sections are being revised based on the transfer of all irradiated fuel from the SFP to the ISFSI. The details of, and justification for the proposed changes follow in subsequent sections (arranged by 10 CFR Part 50 License Condition or PDTS Section).

Proposed for Revision (or Remaining Proposed for Deletion Unchanged)

1. Definitions (all terms)

2. [Previously Deleted]

3/4. Limiting Conditions for Operation and Surveillance Requirements 3/4.0 General Action Requirements and Surveillance Requirement Applicability 3/4.1 Handling and Storage of Irradiated Fuel in the Spent Fuel Pool 3/4.1.1 Spent Fuel Pool Water Level 3/4.1.2 Spent Fuel Pool Boron Concentration 3/4.1.3 Spent Fuel Assembly Storage 5.0 Design Features 5.1 Site

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 11 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes Proposed for Revision (or Remaining Proposed for Deletion Unchanged) 5.2 Spent Fuel Storage Facilities 6.0 Administrative Controls 6.1 Responsibility 6.2 Organization 6.3 Facility Staff Qualifications 6.4-7 [Previously Deleted]

6.8 Procedures and Programs 6.9 Reporting Requirements 6.10 Record Retention 6.11 [Previously Deleted]

6.12 High Radiation Area (renumbered to 6.1) 6.13 [Previously Deleted]

6.14 Offsite Dose Calculation Manual (ODCM) 6.15-17 [Previously Deleted]

6.18 Technical Specifications (TS) Bases Control Program The tables in the following subsections identify each RFL License Condition and PDTS that is being changed, the proposed change, and the basis for each change. Proposed revisions are shown in Bold-Italics. Where an entire License Condition or PDTS is being deleted Deleted is indicated in the Proposed section of the table, otherwise the deletions are shown using bold italicized strikethrough. provides the marked-up version of the TMI-1 Renewed Facility License and Technical Specifications.

Additionally, the proposed changes to the TS are considered a major rewrite. Revised formatting (margins, font, tabs, etc.) of content is used to create a continuous electronic file, revised numbering of pages; and the deletion of unused placeholders, is used to condense and reduce the number of pages in the TS without affecting the technical content. Since the changes to the TS are considered a major rewrite, revision bars will not be used.

The TS Table of Contents is revised to reflect the remaining applicable sections and new page numbering. These changes are considered administrative and are shown in the marked-up pages provided in Attachment 2.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 12 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes 2.5.1 Detailed Discussion of Proposed Renewed Facility License Changes License Condition 1.j Current:

j. Actions have been identified and have been or will be taken with respect to (1) managing the effects of aging during the period of extended operation on the functionality of structures and components that have been identified to require review under 10 CFR 54.21(a)(1); and (2) time-limited aging analyses that have been identified to require review under 10 CFR 54.21(c), such that there is reasonable assurance that the activities authorized by the renewed operating license will continue to be conducted in accordance with the current licensing basis, as defined in 10 CFR 54.3, for the facility, and that any changes made to the facility=s current licensing basis in order to comply with 10 CFR 54.29(a) are in accordance with the Act and the Commission's regulations.

Proposed:

Deleted Basis The proposed change removes the requirements to maintain the sites aging management program. The requirements within 10 CFR 54.4 associated with the plant systems, structures, and components (SSC) are no longer applicable to a station with all irradiated fuel stored in the ISFSI.

In the ISFSI only condition there will be no equipment meeting the requirements of NUREG-1928, "Safety Evaluation Report Related to the License Renewal of Three Mile Island Nuclear Station, Unit 1" (Reference 5.18). Therefore, none of the requirements associated with the scope 10 CFR 54.4 remain germane and the deletion is consistent with the requirements associated with the decommissioning plant can be removed from the License Conditions.

License Condition 2.c.(17)

Current:

(17) Mitigation Strategy License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 13 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders Proposed:

Deleted Basis This License Condition is proposed for deletion in its entirety. After all irradiated fuel is stored within the ISFSI, the mitigation strategy license condition is no longer required.

License Condition 2.c.(17) addresses requirements added to the license to assure the TMI-1 would be capable of mitigating large fires and explosions. This section is proposed for deletion in its entirety.

The NRC issued this License Condition on July 18, 2007 (Reference 5.20), to incorporate the requirements for the Interim Compensatory Measures (ICM) Order EA-02-026, Section B.5.b mitigation strategies (dated February 25, 2002) (Reference 5.21). The NRC has subsequently incorporated the strategies and guidelines directed under Order EA-02-026, into 10 CFR 50.155(b)(2), Extensive Damage Mitigation Guidelines (EDMGs) (Reference 5.22). 10 CFR 50.155(b)(2) provides strategies and guidelines to maintain or restore SFP cooling capabilities under the circumstances associated with loss of large areas of the plant impacted by the event, due to explosions or fire. However, as stated in 10 CFR 50.155(a)(2)(iv), this section does not apply after the certifications for permanent shutdown and removal of fuel under 10 CFR 50.82(a)(1) have been submitted, and all of the irradiated fuel has been removed from the SFPs.

On November 28, 2011, the NRC issued a letter that rescinded Item B.5.b of the ICM Order EA-02-026 (Reference 5.23). Therefore, neither the ICM Order nor 10 CFR 50.155(2)(b) continue to apply to TMI-1.

License Condition 2.c.(21)

Current:

The UFSAR supplement, as revised, submitted pursuant to 10 CFR 54.21(d), describes certain future activities to be completed prior to and/or during the period of extended operation. The licensee shall complete these activities in accordance with Appendix A of NUREG-1928, Safety Evaluation Report Related to the License Renewal of Three Mile Island, Unit 1, dated, October, 2009. The licensee shall notify the NRC in writing when activities to be completed prior to the period of extended operation are complete and can be verified by NRC inspection.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 14 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes Proposed:

Deleted Basis This License Condition is proposed for deletion in its entirety.

The proposed change removes the requirements to maintain the sites aging management program. The requirements within 10 CFR 54.4 associated with the plant SSCs are no longer applicable to a station with all irradiated fuel stored in the ISFSI.

In the original PDTS submittal (Reference 5.4) Exelon proposed deletion of this License Condition, but in a supplement dated March 6, 2019 (Reference 5.5) Exelon withdrew the request to delete License Condition 2.c.(21). The LC was determined to preserve obligations to complete certain future activities related to license renewal that would be applicable in decommissioning, particularly NUREG-1928 (Reference 5.18), Appendix A, Item 43, Boral and Metamic Test Coupon Surveillance.

In the ISFSI only condition there will be no equipment meeting the requirements of this NUREG-1928 (Reference 5.18) including the Boral and Metamic Test Coupon Surveillance Program. Therefore, none of the requirements associated with the scope 10 CFR 54.4 remain germane and the deletion is consistent with the requirements associated with the decommissioning plant can be removed from the License Conditions.

License Condition 2.c.(22)

Current:

Handling of irradiated fuel in the Spent Fuel Pool will not be permitted following implementation of the PDTS until a minimum of 60 days following the permanent shutdown.

Proposed:

Deleted Basis This License Condition is proposed for deletion in its entirety.

The current wording was added to address limiting the dose consequences in the Control Room, and at the Exclusion Area Boundary (EAB) and Low Population Zone (LPZ) to within allowable limits of 10 CFR 50.67 without relying on SSCs to remain functional for accident mitigation during and following the DBA FHA within 60 days after permanent shutdown.

This License Condition was applicable for the time period of 60 days after permanent shutdown, and therefore, is no longer required.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 15 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes 2.5.2 Detailed Discussion of Proposed PDTS Changes PDTS 1. Definitions Current:

1. DEFINITIONS The following terms are defined for uniform interpretation of these specifications.

1.1 ACTIONS ACTIONS shall be that part of a Specification that prescribes required actions to be taken under designated Conditions within specified completion times.

1.2 CERTIFIED FUEL HANDLER A CERTIFIED FUEL HANDLER is an individual who complies with provisions of the CERTIFIED FUEL HANDLER training program required by Specification 6.3.2.

1.3 NON-CERTIFIED OPERATOR A NON-CERTIFIED OPERATOR is a non-licensed operator who complies with the qualification requirements of Specification 6.3.1, but is not a CERTIFIED FUEL HANDLER.

1.4 OPERABLE A system, subsystem, train, component or device shall be OPERABLE or have OPERABILITY when it is capable of performing its specified function(s) and when all necessary attendant instrumentation, controls, electrical power, cooling or seal water, lubrication or other auxiliary equipment that are required for the system, subsystem, train, component, or device to perform its function(s) are also capable of performing their related support function(s).

1.5 STATION, UNIT, PLANT, AND FACILITY Station, unit, plant, and facility as used in these technical specifications all refer to TMI Unit 1.

Proposed:

Deleted Basis This PDTS is proposed for deletion in its entirety.

PDTS 1.1, "Definitions," provides defined terms that are applicable throughout the PDTS and PDTS Bases. After transfer of irradiated fuel from the SFPs to the ISFSI is complete, there will no longer be any applicable LCOs or SRs in the TMI-1 TS. As such, the definitions described above will no longer have relevance to the plant TS and are not needed.

Therefore, deleting these definitions from the TS after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 16 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes PDTS 3/4. LIMITING CONDITIONS FOR OPERATION AND SURVEILLANCE REQUIREMENTS PDTS 3/4.0 GENERAL ACTION REQUIREMENTS AND SURVEILLANCE REQUIREMENT APPLICABILITY Current:

3.0.1 LCOs shall be met during the specified conditions in the TS, except as provided in 3.0.2.

3.0.2 Upon discovery of a failure to meet an LCO, the required actions of the associated Conditions shall be met.

If the LCO is met or is no longer applicable prior to expiration of the specified completion time(s), completion of the required action(s) is not required, unless otherwise stated.

4.0.1 Surveillance requirements shall be met during the specified conditions in the applicability for individual LCOs, unless otherwise stated in the surveillance requirements. Failure to meet a surveillance, whether such failure is experienced during the performance of the surveillance or between performances of the surveillance, shall be failure to meet the LCO. Failure to perform a surveillance within the specified frequency shall be failure to meet the LCO except as provided in 4.0.2.

4.0.2 If it is discovered that a surveillance was not performed within its specified frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified frequency, whichever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed.

If the surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable condition(s) must be entered.

When the surveillance is performed within the delay period and the surveillance is not met, the LCO must immediately be declared not met, and the applicable condition(s) must be entered.

4.0.3 The specified frequency for each SR is met if the surveillance is performed within 1.25 times the interval specified in the frequency, as measured from the previous performance.

Proposed:

Deleted Basis This PDTS is proposed for deletion in its entirety.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 17 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes The existing PDTS Sections 3/4, "Limiting Condition for Operation and Surveillance Requirements" and 3/4.0, "General Action Requirements and Surveillance Requirement Applicability" contain general requirements applicable to all TS. Because storage of irradiated fuel in an ISFSI does not rely on plant systems or activities addressed by PDTS, all PDTS sections that contain LCOs and SRs are being proposed for deletion after all irradiated fuel is removed from the SFPs and stored in the onsite ISFSI. As such, these LCOs and SRs no longer have any relevance to the plant TS, and the requirements will no longer apply.

Therefore, deleting PDTS Sections 3/4 and 3/4.0, LCOs 3.0.1 and 3.0.2, SRs 4.01. through 4.03, and the corresponding Bases after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

PDTS 3/4.1 HANDLING AND STORAGE OF IRRADIATED FUEL IN THE SPENT FUEL POOL 3/4.1.1 SPENT FUEL POOL WATER LEVEL Current:

Applicability Applies to the minimum level of water in the Spent Fuel Pool during handling of irradiated fuel in the Spent Fuel Pool.

Objective Ensures that assumptions of Fuel Handling Accident are maintained during handling of irradiated fuel in the Spent Fuel Pool.

Specification 3.1.1.1 Maintain Spent Fuel Pool level greater than 342'4" elevation.

3.1.1.2 With Spent Fuel Pool level less than 342'4" elevation, immediately suspend handling of irradiated fuel in the Spent Fuel Pool.

SURVEILLANCE REQUIREMENTS 4.1.1.1 Verify Spent Fuel Pool level greater than or equal to 342'4" elevation every 7 days.

Proposed:

Deleted Basis This PDTS is proposed for deletion in its entirety.

PDTS 3/4.1.1, "Fuel Storage Pool Water Level," specifies requirements to ensure that the minimum water level in the SFPs meets the iodine decontamination factor assumptions used in the DBA FHA.

After all irradiated fuel stored in the ISFSI, and the proposed TS 5.2 that no irradiated fuel will be placed in the SFPs, there is no longer a need for the FHA analysis. Therefore, the LCO

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 18 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes and SR to maintain assumptions of the FHA during fuel movement are no longer required and may be deleted in their entirety with no impact on continued safe storage and maintenance of irradiated fuel in an ISFSI at TMI-1.

Irradiated fuel stored in dry canisters within the ISFSI are subject to the TS applicable to the associated storage canister system (i.e., NAC MAGNASTOR Cask System).

Therefore, deleting PDTS LCOs 3.1.1.1 and 3.1.1.2, SR 4.1.1.1, and the corresponding Bases after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

PDTS 3/4.1.2 SPENT FUEL POOL BORON CONCENTRATION Current:

Applicability Applies to the minimum boron concentration in the Spent Fuel Pool during storage and handling of irradiated fuel in the Spent Fuel Pool.

Objective Ensures that assumptions of Storage Limitations are maintained to prevent inadvertent criticality in the Spent Fuel Pool.

Specification 3.1.2.1 Maintain Spent Fuel Pool boron concentration greater than or equal to 600 ppm.

3.1.2.2 With Spent Fuel Pool boron concentration less than 600 ppm, immediately suspend handling of irradiated fuel in the Spent Fuel Pool and immediately restore boron concentration per 3.1.2.1.

SURVEILLANCE REQUIREMENTS 4.1.2.1 Verify Spent Fuel Pool boron concentration greater than or equal to 600 ppm every 7 days.

Proposed:

Deleted Basis This PDTS is proposed for deletion in its entirety.

PDTS 3/4.1.2, "Spent Fuel Pool Boron Concentration," specifies concentration of dissolved boron in the SFPs to preserve the assumptions used in the analyses of the potential criticality accident scenarios. For such events, credit is taken for the presence of boron in the SFP water. This concentration of dissolved boron is the minimum required for irradiated fuel assembly storage and movement within the SFPs. PDTS LCOs 3.1.2.1, 3.1.2.2, and SR 4.1.21 apply whenever fuel assemblies are stored in the SFPs.

After the transfer of irradiated fuel from the SFPs to the ISFSI, there will no longer be any storage of irradiated fuel assemblies in the SFPs. As such, these LCOs and SR no longer have any relevance to the plant TS, the requirements will no longer be applicable, and may be

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 19 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes deleted in their entirety with no impact on continued safe storage and maintenance of irradiated fuel in an ISFSI atTMI-1.

Irradiated fuel stored in dry canisters within the ISFSI are subject to the TS applicable to the associated storage canister system.

Therefore, deleting PDTS LCOs 3.1.2.1 and 3.1.2.2, SR 4.1.2.1, and the corresponding Bases after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

PDTS 3/4.1.3 SPENT FUEL ASSEMBLY STORAGE Current:

Applicability Applies whenever any fuel assembly is stored in Storage Pool A or Storage Pool B of the Spent Fuel Pool.

Objective Ensures that assumptions of Storage Limitations are maintained to prevent inadvertent criticality in the Spent Fuel Pool.

Specification 3.1.3.1 The combination of initial enrichment and burnup of each spent fuel assembly stored in Storage Pool A and Storage Pool B, shall be within the acceptable region of Figure 3.1.3-1 or 3.1.3-2.

3.1.3.2 When requirement of 3.1.3.1 is not met, immediately initiate action to move the noncomplying fuel assembly to an acceptable configuration.

[Including Figures 3.1.3-1 and 3.1.3-2]

SURVEILLANCE REQUIREMENTS 4.1.3.1 Verify by administrative means the initial enrichment and burnup of the fuel assembly is in accordance with Figure 3.1.3-1 or Figure 3.1.3-2 prior to storing irradiated spent fuel in the Spent Fuel Pool A or Spent Fuel Pool B.

Proposed:

Deleted Basis This PDTS is proposed for deletion in its entirety.

PDTS 3/4.1.3, "Spent Fuel Assembly Storage," was derived to establish limiting conditions on fuel storage to assure sufficient safety margin exists to prevent inadvertent criticality. The irradiated fuel assemblies are stored entirely underwater in a configuration that has been shown to result in a reactivity of less than or equal to a keff of 0.95 under worse case conditions. The spent fuel assembly enrichment requirements in this LCO are required to

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 20 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes ensure inadvertent criticality does not occur in the SFPs. Inadvertent criticality within the fuel storage area could result in offsite radiation doses exceeding 10 CFR 50.67 limits.

After the transfer of irradiated fuel from the SFPs to the ISFSI, there will no longer be any storage of irradiated fuel assemblies in the SFPs. As such, these LCOs and SR no longer have any relevance to the plant TS, the requirements will no longer be applicable, and may be deleted in their entirety with no impact on continued safe storage and maintenance of irradiated fuel in an ISFSI atTMI-1.

Irradiated fuel stored in dry canisters within the ISFSI are subject to the TS applicable to the associated storage canister system.

Therefore, deleting PDTS LCOs 3.1.3.1 and 3.1.3.2, SR 4.1.3, and the corresponding Bases after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

PDTS 5.0 DESIGN FEATURES PDTS 5.1 SITE Current:

Applicability Applies to the location and extent of the exclusion boundary, restricted area, and low population zone.

Objective To define the above by location and distance description.

Specification 5.1.1 The Three Mile Island Nuclear Station Unit 1 is located in an area of low population density about ten miles southeast of Harrisburg, PA. It is in Londonderry Township of Dauphin County, Pennsylvania, about two and one-half miles north of the southern tip of Dauphin County, where Dauphin is coterminal with York and Lancaster Counties.

The station is located on an island approximately three miles in length situated in the Susquehanna River upstream from York Haven Dam. Figure 5-1 is an extended plot plan of the site showing the plant orientation and immediate surroundings. The description of the Exclusion Area as defined in 10 CFR 100.3, is located in the Final Safety Analysis Report, as updated.

[Including Figure 5-1]

Proposed:

Applicability Applies to the location and extent of the exclusion boundary and, restricted area, and low population zone.

Objective To define the above by location and distance description.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 21 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes Specification 5.1.1 The Three Mile Island Nuclear Station Unit 1 is located in an area of low population density about ten miles southeast of Harrisburg, PA. It is in Londonderry Township of Dauphin County, Pennsylvania, about two and one-half miles north of the southern tip of Dauphin County, where Dauphin is coterminal with York and Lancaster Counties. The station is located on an island approximately three miles in length situated in the Susquehanna River upstream from York Haven Dam. Figure 5-1 is an extended plot plan of the site showing the plant orientation and immediate surroundings. The description of the Three Mile Island Unit 1 site, including Exclusion/Restricted Area as defined in 10 CFR 100.3, is located in the Final Defueled Safety Analysis Report, as updated.

[Including deletion of Figure 5-1]

Basis This PDTS is proposed to be modified.

PDTS 5.1, "Site," provides a brief description of the TMI site.

The "Applicability" and "Objective" sections no longer define a useable plant condition and are proposed to be deleted. These attributes are not required by 10 CFR 50.36(c)(4) and are not provided in NUREG-1430 Revision 4, Babcock and Wilcox Plants STS, Volume 1, Specification (Reference 5.19).

An administrative change is being proposed to Section 5.1.1 to remove excessive detail associated with the site boundary. This information is located within the stations DSAR Section 2.1. DSAR Section 2.1 provides a more detailed description of the TMI site, including the information proposed for deletion, including Figure 5-1 (DSAR Figure 2.1-3). License Section 2.a also provides the licensed facility description.

This change is administrative and will provide a more consistent reference and does not change the technical content.

Therefore, removing the PDTS 5.1. "Applicability" and "Objective" Sections and modifying Section 5.1.1 as proposed, after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

PDTS 5.2 SPENT FUEL STORAGE FACILITIES Current:

Applicability Applies to storage facilities for spent fuel assemblies.

Objective To assure that spent fuel assemblies will be stored in such a manner that an inadvertent criticality could not occur.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 22 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes Specification 5.2.1 SPENT FUEL STORAGE For Spent Fuel Pool "A", the fuel assemblies are stored in racks in parallel rows, having a nominal center to center distance of 11.1 inches in both directions for the Region I racks and 9.2 inches in both directions for the Region II racks. The spacing in the Spent Fuel Pool "A" storage locations for both Region I and II is adequate to maintain Keff less than 0.95. Region I will store fuel with a maximum 5.0 percent initial enrichment. When fuel is being moved in or over the Spent Fuel Storage Pool "A" and fuel is being stored in the pool, a boron concentration of at least 600 ppm must be maintained to meet the NRC maximum allowable reactivity value under the postulated accident condition.

For Spent Fuel Pool "B", the fuel assemblies are stored in racks in parallel rows, having nominal center to center distance of 13-5/8 inches in both directions. This spacing is sufficient to maintain a Keff less than 0.95 based on fuel assemblies with a maximum enrichment of 4.37 weight percent U235. When fuel is being moved in or over the Spent Fuel Storage Pool "B" and fuel is being stored in the pool, a boron concentration of at least 600 ppm must be maintained meet the NRC maximum allowable reactivity value under the postulated accident condition.

a. Irradiated fuel assemblies will be stored, prior to offsite shipment, in the stainless steel lined spent fuel pools, which are located in the fuel handling building.

b. The fuel assembly storage racks provided and the number of fuel elements each will store are listed by location below:

Spent Fuel Pool A Spent Fuel Pool B Dry New Fuel North End of Fuel South End of Fuel Storage Area Handling Building Handling Building Fuel Handling Building Fuel Assys. 1494

• 496 54 Cores 8.44 2.8 0.37 NOTE:

• Includes three spaces for accommodating failed fuel containers.

c. All of the fuel assembly storage racks provided are designed to Seismic Class 1 criteria to the accelerations indicated below:

Fuel Handling Building Fuel Handling Dry New Fuel Storage Area Building Spent And Spent Fuel Pool A Fuel Pool B Horiz. 0.38 g **

Vertical 0.25 g **

NOTE: ** The "B" pool fuel storage racks are designed using the floor response spectra of the Fuel Handling Building.

REFERENCES

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 23 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes (1) UFSAR, Section 9.7 - "Fuel Handling System" Proposed:

Delete entire section and replace with following:

Irradiated fuel shall not be stored in the "A" or "B" spent fuel pools.

Basis This PDTS is proposed for to be replaced in its entirety.

PDTS 5.2.1, "Spent Fuel Storage," provides a description and the requirements regarding prevention of criticality of spent fuel in the SFPs storage racks and new fuel in the new fuel storage racks, as well as seismic design considerations.

The "Applicability" and "Objective" sections no longer define a useable plant condition and are proposed to be deleted. These attributes are not required by 10 CFR 50.36(c)(4) and are not provided in NUREG-1430 (Reference 5.19).

After the transfer of irradiated fuel from the SFPs to the ISFSI, there will no longer be any fuel assemblies in the pools. Therefore, the design features associated with fuel storage in the SFPs and the new fuel storage racks have no relevance and are no longer applicable and therefore may be deleted.

Irradiated fuel stored in dry canisters within the ISFSI are subject to the TS applicable to the associated storage canister system.

Since this proposed amendment is premised on irradiated fuel no longer being stored in the SFPs, this TS is being proposed to be replaced to prohibit the storage of irradiated fuel in the SFPs.

Therefore, removing the PDTS 5.2. "Applicability" and "Objective" Sections and replacing Section 5.2.1 to prohibit the storage of irradiated fuel in the SFPs after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

PDTS 6.0 ADMINSTRATIVE CONTROLS PDTS 6.1 RESPONSIBILITY Current:

6.1.1 The Plant Manager shall be responsible for TMI-1 operations and shall delegate the succession of his responsibilities in writing during his absence.

6.1.2 The Shift Manager shall be responsible for the shift command function.

Proposed:

6.1.1 - Deleted from PDTS and relocated to DQAP 6.1.2 - Deleted

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 24 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes Basis This PDTS section is proposed for deletion in its entirety from the TS.

PDTS Section 6.1.1 related to the responsibilities of the Plant Manager is being proposed for deletion from the PDTS and relocation to the NRC approved DQAP.

NRC Administrative Letter 95-06 (Reference 5.11) provides a discussion concerning the relocation of TS administrative controls to an NRC approved Quality Assurance Program (QAP). Precedent shows the NRC considers relocating these requirements to the DQAP acceptable because of the controls imposed by 10 CFR 50, Appendix B, the existence of an NRC approved DQAP, and the DQAP change control process in 10 CFR 50.54(a).

Maintaining relocated requirements in accordance with the change control process in 10 CFR 50.54 provides adequate control based on the ISFSI-only condition of the facility.

PDTS Section 6.1.2 related to the responsibilities of the Shift Manager (SM) is proposed for deletion from the PDTS.

The SM responsibilities are being eliminated. With removal of all of the irradiated fuel from the SFPs, a need for a SM for irradiated fuel management no longer exists. The position of SM described in this section is a holdover from the function of supervising multiple functions of a nuclear power plant. With the limited requirements for supervision of the passive fuel storage at the ISFSI or with respect to the decommissioning of the former power generation facility, the SM position and shift command function are no longer required.

Therefore, deleting PDTS Section 6.1 after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

PDTS 6.2 ORGANIZATION PDTS 6.2.1 ONSITE AND OFFSITE ORGANIZATIONS Current:

Onsite and offsite organization shall be established for facility staff and corporate management. The onsite and offsite organization shall include the positions for activities affecting the safe storage and handling of spent nuclear fuel.

a. Lines of authority, responsibility and communication shall be established and defined from the highest management levels through intermediate levels to and including facility organization positions. These relationships shall be documented and updated as appropriate, in the form of organizational descriptions. These organizational descriptions will be documented in the Updated FSAR and updated in accordance with 10 CFR 50.71e.

b. The Plant Manager shall be responsible for overall facility safe operation and shall have control over those on-site activities necessary for safe storage and maintenance of spent nuclear fuel.

c. A responsible officer shall have corporate responsibility for the safe storage and handling of spent nuclear fuel and shall take measures to ensure acceptable performance of the

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 25 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes staff in operating, maintaining, and providing technical support to the facility to ensure safe management of spent nuclear fuel.

d. Individuals who train the CERTIFIED FUEL HANDLERS and those who carry out the health physics and quality assurance functions may report to the appropriate manager on site; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

Proposed:

6.2.1 Introduction - Deleted from PDTS and addressed as currently provided in the DQAP.

6.2.1.a - Deleted from PDTS and modified section relocated to the DQAP.

Lines of authority, responsibility and communication shall be established and defined from the highest management levels through intermediate levels to and including facility organization positions. These relationships shall be documented and updated as appropriate, in the form of organizational descriptions. These organizational descriptions necessary to show compliance with Section 1.3 Station Management will be documented in the Updated FDSAR and updated in accordance with 10 CFR 50.71e.

6.2.1.b-c - Deleted from PDTS and addressed as currently provided in the DQAP 6.2.1.d - Deleted from PDTS and modified section relocated to DQAP

d. Individuals who train the CERTIFIED FUEL HANDLERS and those who carry out the health physics and quality assurance functions may report to the appropriate manager on site; however, these individuals shall have sufficient organizational freedom to ensure their ability to perform their assigned functions.

Basis This PDTS section is proposed for deletion in its entirety from TS.

PDTS 6.2.1, Onsite and Offsite Organizations, provides a description and requirements regarding onsite and offsite organizations including lines of authority and staff responsibilities affecting the safe storage and handling of spent nuclear fuel.

Correspondingly, Section 1, "Organization," of the DQAP (Reference 5.15) describes the responsibilities and requirements for the corporate and station organization of an Exelon decommissioning facility. Exelon propose to revise and incorporate the organizational requirements of PDTS 6.2.1 into the DQAP.

PDTS Section 6.2.1 Introduction and 6.2.1.a PDTS Section 6.2.1 introduction and Section 6.2.1.a will be deleted from the PDTS and are either considered to be addressed as provided in DQAP Section 1, "Organization" or will be relocated to the DQAP.

DQAP Section 1.1, "Responsibilities," provides for the responsibilities of the authorities and duties of persons and organizations performing activities within the scope of the DQAP.

Additionally, Sections 1.2, "Corporate Organizations" and 1.3, "Station Management," provide for the organizational descriptions for fulfilling organizational functions and responsibilities.

Any changes to the responsibilities, authorities, duties, and organizational structures as

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 26 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes provided in the DQAP are subject to and will be reviewed in accordance with 10 CFR 50.54(a). Reviewing organizational changes is consistent with the requirements regarding changes to commitments through the 10 CFR 50.54(a) process, rather than the 10 CFR 50.59 process regarding changes that affect a design function, method of performing a controlling function, or an evaluation that demonstrates that intended function will be accomplished.

As concluded by the NRC in their review and acceptance (Reference 5.10) the DQAP provides a description of an organizational structure, functional responsibilities, levels of authority, and interfaces for establishing, executing, and verifying DQAP implementation and follows the applicable guidance in specified in NUREG-1536, "Standard Review Plan for Dry Cask Storage Systems," Revision 1 (Reference 5.24), Section 14.5.1, "Quality Assurance Organization," and NUREG-1757, "Consolidated Decommissioning Guidance," Volume 1, "Decommissioning Process for Materials Licensees," Revision 2 (Reference 5.25), Section 17.6.1, "Organization," for the decommissioning phase of plant life.

Exelon proposes the deletion of the introduction to PDTS 6.2, and the portion 6.2.1.a related to lines of authority, based on equivalent organizational requirements provided in DQAP Section 1 for the Corporate Organization. The corporate management structure is described in DQAP Sections 1.1 and 1.2. It is common to all Exelon decommissioning sites and will be appropriately maintained in the DQAP with changes addressed pursuant to 50.54(a).

Exelon proposes to modify the remaining portion of PDTS 6.2.1.a and relocate it to the DQAP. DQAP, Section 1.3, "Station Management," provides a description of the station management positions associated with various responsibilities. Since this Section of the DQAP does not address the requirement to provide the Station organizational descriptions in the UFSAR [DSAR] nor to provide updates per 10 CFR 50.71(e) the wording will be revised as indicated above and added to the DQAP to reflect these elements. The station management structure and responsibilities are currently described and will be maintained in in DSAR Section 5.1 "Organizational Structure," and are updated and reported to the NRC in accordance with 50.71(e).

The statement is also proposed to be revised to reference that the station management is described in DQAP Section 1.3 and change UFSAR to the DSAR. These proposed revisions are considered editorial.

Relocating these responsibilities to the DQAP is consistent with NRC Administrative Letter 95-06 (Reference 5.11). Therefore, the proposed deletion, modification, and relocation are acceptable.

PDTS Section 6.2.1.b Section 6.2.1.b will be deleted from the PDTS and the requirement will be modified as currently contained in the DQAP, Section 1.3.1 Station Management. DQAP Section 1.3.1 provides the requirements for the Decommissioning Plant Manager and states the following:

"The Decommissioning Plant Manager shall be responsible for overall safe operation of the facility and shall have control over those onsite activities necessary for safe storage and maintenance of spent nuclear fuel, including maintaining the facility within

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 27 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes the constraints of applicable regulatory requirements, license, DC technical specifications and training. "

The current DQAP Section 1.3.1 contains the requirements currently contained in TS 6.2.1.b, but with modified wording. This modified wording does not change the required responsibilities of the Decommissioning Plant Manager. Relocating these responsibilities to the DQAP is consistent with NRC Administrative Letter 95-06 (Reference 5.11). Therefore, the proposed deletion and use of the current DQAP sections are acceptable.

PDTS Section 6.2.1.c Section 6.2.1.c will be deleted from the PDTS and the requirement will be modified as currently contained in the DQAP, Section 1.1.3 Responsibilities. DQAP Section 1.1.3 provides the requirements for the Decommissioning Plant Manager and states the following:

"The overall responsibility for operation, maintenance, inspection, test, modification, decommissioning, and storage of spent fuel resides with the Sr. Executive Vice President, Exelon Generation and President and Chief Nuclear Officer (CNO), Exelon Nuclear. "

The current DQAP Section 1.1.3 contains the requirements currently contained in TS 6.2.1.c, but with modified wording. This modified wording does not change the required responsibilities of the responsible Corporate Office. In addition, Section 1.2, "Corporate Organizations," of the DQAP provides additional responsibilities for the Corporate Organization including the individuals responsible for technical support and oversight activities.

Relocating these responsibilities to the DQAP is consistent with NRC Administrative Letter 95-06, (Reference 5.11). Therefore, the proposed deletion and use of the current DQAP sections are acceptable.

PDTS Section 6.2.1.d Section 6.2.1.d will be modified to remove the requirement for individuals who train CFHs from the list of individuals who may report to an appropriate manager but maintain sufficient organization freedom to ensure their ability to perform their assigned functions. Following the transfer of all irradiated fuel to the ISFSI, and the proposed TS 5.2 prohibiting the storage of irradiated fuel in the SFPs, there will no longer be a need for CFHs. Therefore, this proposed deletion of the requirement for the CFH is acceptable.

The remainder of Section 6.2.1.d will be deleted from the PDTS and relocated to the DQAP to provide an equivalent description of the requirements for organizational freedom of the health physics and quality assurance personnel.

Relocating these responsibilities to the DQAP is consistent with NRC Administrative Letter 95-06 (Reference 5.11). Therefore, the proposed deletion and relocation are acceptable.

Therefore, deleting PDTS Section 6.2.1 after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 28 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes PDTS 6.2.2 FACILITY STAFF Current:

The facility staff organization shall meet the following:

a. Each on-duty shift shall be composed of at least one Shift Manager and one NON-CERTIFIED OPERATOR.

b. At all times when nuclear fuel is stored in the spent fuel pool, at least one person qualified to stand watch in the control room (NON-CERTIFIED OPERATOR or CERTIFIED FUEL HANDLER) shall be present in the control room.

c. The NON-CERTIFIED OPERATOR position may be filled by a CERTIFIED FUEL HANDLER.

d. The Shift Manager shall be a CERTIFIED FUEL HANDLER.

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

f. Oversight of fuel handling operations shall be provided by a CERTIFIED FUEL HANDLER.

g. Except for the Shift Manager, shift crew composition may be one less than the minimum requirement of Specification 6.2.2.a for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements and the following conditions are met:

1) No fuel movement is in progress;

2) No movement of loads over the spent fuel is in progress.

This provision does not permit any shift crew position to be unstaffed upon shift change due to an incoming shift crewman being late or absent.

Proposed:

Deleted Basis This PDTS is proposed for deletion in its entirety.

Section 6.2.2, "Facility Staff," currently specifies the organizations and positions for activities affecting the safe storage of irradiated fuel in the SFPs.

Following the transfer of all irradiated fuel to the ISFSI, and the proposed revision to TS 5.2 prohibiting the storage of irradiate fuel in the SFPs, there will no longer be a need for CFHs or other specified personnel requirements in this section.

Therefore, deleting PDTS Section 6.2.2 after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 29 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes PDTS 6.3 FACILITY STAFF QUALIFICATIONS Current:

6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications referenced for comparable positions specified in the Exelon Decommissioning Quality Assurance Program (DQAP).

6.3.2 The NRC-approved training and retraining program for CERTIFIED FUEL HANDLERs shall be maintained.

Proposed:

Deleted Basis PDTS 6.3 is proposed for deletion in its entirety.

PDTS 6.3.1, establishes the requirements for facility staff qualifications. The proposed change to this section removes the requirements from the PDTS to maintain staff qualification requirements as described in the DQAP. These requirements are already located in the DQAP so there is no reduction in the staff qualification requirements. The location of these requirements in the DQAP is consistent with NRC Administrative Letter 95-06 (Reference 5.11).

PDTS 6.3.2 specifies requirements for a CFH training program. Following the transfer of all irradiated fuel to the ISFSI, and the proposed revision to TS 5.2 prohibiting the storage of irradiate fuel in the SFPs, there will no longer be a need for CFHs, which obviates the need for the associated training program.

Therefore, deleting PDTS Section 6.3 after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

PDTS 6.4 DELETED [Previously]

PDTS 6.5 DELETED [Previously]

PDTS 6.6 DELETED [Previously]

PDTS 6.7 DELETED [Previously]

PDTS 6.8 PROCEDURES AND PROGRAMS PDTS 6.8.1 through 6.8.3 Current:

6.8.1 Written procedures shall be established, implemented and maintained covering the items referenced below:

a. The procedures applicable to safe storage of nuclear fuel recommended in Appendix "A" of Regulatory Guide 1.33, Revision 2, February 1978.

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b. Surveillance and test activities of equipment that affects nuclear safety and radioactive waste management equipment.

c. Fuel Handling Operations.

d. Security Plan Implementation.

e. Fire Protection Program Implementation.

f. Emergency Plan Implementation.

g. Process Control Program Implementation.

h. Offsite Dose Calculation Manual Implementation.

i. Quality Assurance Program for effluent and environmental monitoring using the guidance in Regulatory Guide 4.15, Revision 1.

j. Deleted 6.8.2 Further, each procedure required by 6.8.1 above, and substantive changes thereto, shall be reviewed and approved prior to implementation and shall be reviewed periodically as set forth in administrative procedures.

6.8.3 Temporary changes to procedures of 6.8.1 above may be made provided:

a. The intent of the original procedure is not altered;

b. The change is approved by two members of the licensee's management staff knowledgeable in the area affected by the procedure. For changes which may affect the operational status of facility systems or equipment, at least one of these individuals shall be a member of operations management or supervision who is a CERTIFIED FUEL HANDLER.

c. The change is documented, reviewed and approved within 14 days of implementation.

Proposed:

6.8.1 Deleted from PDTS and modified section relocated to DQAP

j. Deleted 6.8.2 Deleted from PDTS and modified section relocated to DQAP "procedure required by 6.8.1{to be replaced with appropriate DQAP section number addressing written procedures} above."

6.8.3 Deleted from PDTS and modified section relocated to DQAP "Temporary changes to procedures of 6.8.1{to be replaced with appropriate DQAP section number addressing written procedures} above..."

6.8.3.a Deleted from PDTS and relocated to DQAP 6.8.3.b Deleted from PDTS and modified section relocated to DQAP The change is approved by two members of the licensee's management staff knowledgeable in the area affected by the procedure. For changes which may affect the operational status of facility systems or equipment, at least one of these individuals shall be a member of operations management or supervision who is a CERTIFIED FUEL HANDLER.

6.8.3.c Deleted from PDTS and relocated to DQAP

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 31 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes Basis This PDTS is proposed for deletion in its entirety.

PDTS 6.8.1, regarding written procedures provides a description and requirements regarding administration of written procedures. The requirements of PDTS 6.8.1 are being removed from the PDTS and relocated to the DQAP. In a similar manner, PDTS 6.8.2 and 6.8.3 associated with changes to written procedures are being relocated to the DQAP.

The proposed deletion of PDTS 6.8.1.j is an editorial change.

The proposed changes to PDTS 6.8.2 and 6.8.3, to provide the proper DQAP reference section for written procedures when information is relocated to the DQAP, is an editorial change.

The proposed change to 6.8.3.b removes the requirement for the need for a CFH review operational status of facility systems or equipment. Following the transfer of all irradiated fuel to the ISFSI, and the proposed TS 5.2 prohibiting the storage of irradiate fuel in the SFPs, there will no longer be a need for CFHs, and the facility will have no longer have any operational systems, structures or components necessary to safety handle fuel in the SFPs.

Therefore, there is no longer a need for the requirement to have a CFH provide an operational review.

The transfer of the administrative controls in this section is consistent with the guidance in NRC Administrative Letter 95-06 (Reference 5.11) and therefore, is acceptable. After these administrative controls are incorporated into the DQAP any future changes will be controlled in accordance with§ 50.54(a). This will provide adequate control for the facility with all irradiated fuel located within the ISFSI.

Therefore, deleting PDTS Sections 6.8.1 through 6.8.3 after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

PDTS 6.8.4.a Current:

6.8.4 a. Radiological Environmental Monitoring Program A program shall be provided to monitor the radiation and radionuclides in the environs of the plant. The program shall provide (1) representative measurements of radioactivity in the highest potential exposure pathways, and (2) verification of the accuracy of the effluent monitoring program and modeling of environmental exposure pathways. The program shall (1) be contained in the ODCM, (2) conform to the guidance of Appendix I to 10 CFR Part 50, and (3) include the following:

(1) Monitoring, sampling, analysis, and reporting of radiation and radionuclides in the environment in accordance with the methodology and parameters in the ODCM,

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 32 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes Proposed:

Deleted from PDTS and relocate to DQAP Basis This PDTS is proposed for deletion in its entirety.

PDTS 6.8.4.a, Radiological Environmental Monitoring Program, specifies the requirements and controls for the site effluents. TMI-1 proposes to remove this requirement from the PDTS and relocate it to the DQAP.

The requirement for a RECP will be maintained in accordance with 10 CFR 50.54(a). Since the intent of this section is to ensure that the RECP continues to meet the requirements of 40 CFR 190, 10 CFR 20, 10 CFR 50.36(a), and 10 CFR 50, Appendix I, and since this requirement will be maintained in the DQAP, the relocated requirement will continue to be subject to regulatory controls.

Therefore, deleting PDTS Section 6.8.4.a after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

PDTS 6.8.4.b Current:

6.8.4 b. Radioactive Effluent Controls Program A program shall be provided conforming with 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable. The program (1) shall be contained in the ODCM, (2) shall be implemented by operating procedures, and (3) shall include remedial actions to be taken whenever the program limits are exceeded. The program shall include the following elements:

(1) Limitations on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM, (2) Limitations on the concentrations of radioactive material released in liquid effluents to unrestricted areas conforming to 10 times the concentrations specified in 10 CFR Part-20.1001 - 20.2402, Appendix B, Table 2, Column 2, (3) Monitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 20.1302 and with the methodology and parameters in the ODCM, (4) Limitations on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid effluents released from the unit to the site boundary conforming to Appendix I to 10 CFR Part 50,

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 33 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes (5) Determination of cumulative dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days.

Determination of projected dose contributions from radioactive effluents in accordance with the methodology in the ODCM at least every 31 days.

(6) Limitations on the operability and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for the annual dose or dose commitment conforming to Appendix I to 10 CFR Part 50, (7) Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas at, or beyond, the site boundary. The limits are as follows:

(a) For noble gases: less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin, and (b) For I-131, I-133, tritium and all radionuclides in particulate form with half lives greater than 8 days: less than or equal to 1500 mrem/yr to any organ.

(8) Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from the unit to areas beyond the site boundary conforming to Appendix I to 10 CFR Part 50, (9) Limitations on the annual quarterly doses to a member of the public from Iodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released from the unit to areas beyond the site boundary conforming to Appendix I to 10 CFR Part 50, and (10) Limitations on the annual dose or dose commitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.

Proposed:

Deleted from PDTS, modified as follows, and relocated to DQAP (7) Limitations on the dose rate resulting from radioactive material released in gaseous effluents to areas at, or beyond, the site boundary. The limits are as follows:

(a) For noble gases: less than or equal to 500 mrem/yr to the total body and less than or equal to 3000 mrem/yr to the skin, and (a) For I-131, I-133, tritium and all radionuclides in particulate form with half lives greater than 8 days: less than or equal to 1500 mrem/yr to any organ.

(8) Limitations on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from the unit to areas beyond the site boundary conforming to Appendix I to 10 CFR Part 50,

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 34 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes (8) Limitations on the annual quarterly doses to a member of the public from Iodine-131, Iodine-133, tritium, and all radionuclides in particulate form with half-lives greater than 8 days in gaseous effluents released from the unit to areas beyond the site boundary conforming to Appendix I to 10 CFR Part 50, and (9) Limitations on the annual dose or dose commitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle sources conforming to 40 CFR Part 190.

Basis This PDTS is proposed for deletion in its entirety.

PDTS 6.8.4.b, "Radioactive Effluent Controls Program," specifies requirements for the control of radioactive effluents and for maintaining doses to the public from effluents as low as reasonably achievable (ALARA). TMI-1 proposes to remove this requirement from the PDTS and relocate it to the DQAP, with the exception of the specific requirements associated with noble gas in PDTS 6.8.4.b(7)(a) and (8). These TS will not be relocated to the DQAP since once all irradiated fuel is placed within dry storage casks and transferred to the ISFSI there will no longer be a need to monitor for noble gases being potentially released from the facility.

The requirement for a Radioactive Effluent Controls Program will be maintained in accordance with 10 CFR 50.54(a). Since the intent of this section is to ensure that the Radioactive Effluent Controls Program continues to meet the requirements of 40 CFR 190, 10 CFR 20, 10 CFR 50.36(a), and 10 CFR 50, Appendix I, and since this requirement will be maintained in the DQAP, the relocated requirements will continue to be subject to regulatory controls.

Therefore, deleting PDTS Section 6.8.4.b after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

PDTS 6.9 REPORTING REQUIREMENTS Current:

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

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 35 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes

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.

6.9.2 ANNUAL RADIOLOGICAL ENVIRONMENTAL OPERATING REPORT 6.9.2.1 The Annual Radiological Environmental Operating Report covering the facility during the previous calendar year shall be submitted prior to May 1 of each year.

The Report shall include summaries, interpretations, and an analysis of trends of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in: (1) the ODCM; and, (2) Sections IV.B.2, IV.B.3, and IV.C of Appendix I to 10 CFR Part 50.

Note: A single submittal may be made for the station.

6.9.3 ANNUAL RADIOACTIVE EFFLUENT RELEASE REPORT 6.9.3.1 The Annual Radioactive Effluent Release Report covering the facility during the previous calendar year shall be submitted prior to May 1 of each year.

The Report shall include a summary of the quantities of radioactive liquid and gaseous effluent and solid waste released from the unit. The material provided shall be: (1) consistent with the objectives outlined in the ODCM and Process Control Program (PCP); and, (2) in conformance with 10 CFR 50.36(a) and Section IV.B.1 of Appendix I to 10 CFR Part 50.

Note: A single submittal may be made for the station. The submittal should combine those sections that are common to both units at the station.

Proposed:

Deleted from PDTS and relocated to DQAP Basis This PDTS is proposed for deletion in its entirety.

PDTS 6.9 provides a description and requirements regarding reports that are to be submitted to the NRC. PDTS 6.9, "Reporting Requirements," is proposed to be removed from the PDTS and relocate the requirements to the DQAP. The three requirements are PDTS 6.9.1, "Routine Reports," PDTS 6.9.2, "Annual Radiological Environmental Operating Report," and 6.9.3, "Annual Radioactive Effluent Release Report."

The proposed change is to delete PDTS Section 6.9 in its entirety and relocate the requirements verbatim to the DQAP. After these administrative controls are incorporated into the DQAP, any future changes will be controlled in accordance with 10 CFR 50.54(a). This will provide adequate control for the facility with all irradiated fuel located within the ISFSI.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 36 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes The relocation of administrative controls for reporting requirements to the DQAP is consistent with NRC Administrative Letter 95-06 (Reference 5.11) and will have no impact on safe storage and maintenance of irradiated fuel in the ISFSI, and therefore, is acceptable.

PDTS 6.10 RECORD RETENTION Current:

6.10.1 Records shall be retained as described by the Decommissioning Quality Assurance Program.

Proposed:

Deleted Basis This PDTS is proposed for deletion in its entirety.

PDTS 6.10, "Record Retention," establishes the requirements for retaining records. The proposed change to this section removes the requirements from the PDTS to maintain records as described in the DQAP. These requirements are already located in the DQAP in Section E.2, so there is no reduction in the record retention requirements. The location of these requirements in the DQAP is consistent with NRC Administrative Letter 95-06 (Reference 5.11).

Therefore, the proposed deletion and relocation are acceptable.

PDTS 6.11 DELETED [Previously]

PDTS 6.12 HIGH RADITION AREA

[To be renumbered to PDTS 6.1 - No additional changes proposed]

PDTS 6.13 DELETED [Previously))

PDTS 6.14 OFFSITE DOSE CALCULATION MANUAL (ODCM)

Current:

6.14.1 Licensee initiated changes to the ODCM:

1. Shall be submitted to the NRC in the Annual Radioactive Effluent Release Report for the period in which the changes were made. This submittal shall contain:

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 37 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes

a. sufficiently detailed information to justify the changes without benefit of additional or supplemental information;

b. a determination that the changes did not reduce the accuracy or reliability of dose calculations or setpoint determinations; and

c. documentation that the changes have been reviewed and approved pursuant to 6.8.2.

2. Shall become effective upon review and approval by licensee management.

Proposed:

DELETED from PDTS and relocated to DQAP Basis This PDTS is proposed for deletion in its entirety.

PDTS 6.14, "Offsite Dose Calculation Manual (ODCM)," currently specifies how to document, review, and approve changes to the ODCM. The proposed change to this section removes this requirement from the PDTS and relocates it to DQAP. This requirement will be maintained in accordance with 10 CFR 50.54(a).

Since the intent of this section is to ensure that the ODCM continues to meet the requirements of 40 CFR 190, 10 CFR 20, 10 CFR 50.36(a), and 10 CFR 50, Appendix I, and since this requirement will be maintained in the DQAP, the relocated requirement will continue to be subject to regulatory controls. The reference to Section 6.8.2 in Section 6.14.1.(c), associated with ODCM temporary change control will not be transferred to the DQAP. The remaining requirements for changes to the ODCM, including temporary changes, will be controlled by the DQAP.

The relocation of these administrative requirements to the DQAP is consistent with NRC Administrative Letter 95-06 (Reference 5.11) and will have no impact on safe storage and maintenance of irradiated fuel in the ISFSI, and therefore is acceptable.

PDTS 6.15 DELETED [Previously]

PDTS 6.16 DELETED [Previously]

PDTS 6.17 DELETED [Previously]

PDTS 6.18 TECHNICAL SPECIFICATIONS (TS) BASES CONTROL PROGRAM Current:

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.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 38 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes

b. Licensees may make changes to Bases without prior NRC approval provided the changes do not require either of the following:

1. A change in the TS incorporated in the license or

2. A change to the updated FSAR (UFSAR) or Bases that requires NRC approval pursuant to 10 CFR 50.59.

c. The Bases Control Program shall contain provisions to ensure that the Bases are maintained consistent with the UFSAR.

d. Proposed changes that meet the criteria of Specification 6.18.b.1 or 6.18.b.2 above shall be reviewed and approved by the NRC prior to implementation. Changes to the Bases implemented without prior NRC approval shall be provided to the NRC on a frequency consistent with 10 CFR 50.71 (e).

Proposed:

Deleted Basis This PDTS is proposed for deletion in its entirety.

PDTS 6.18, "Technical Specification (TS) Bases Control Program," establishes the requirements to update and maintain TS Bases. Currently, the TS Bases are all related to storage of irradiated fuel in the SFPs; specifically, the requirements in Section 3/4.1 which are proposed for deletion as described above. Following transfer of all irradiated fuel to the ISFSI, the SFPs will no longer be used for irradiated fuel storage. Since all the TS Bases will be deleted, there will no longer be a need for a TS Bases Control Program.

Therefore, deleting PDTS Section 6.18 after all the irradiated fuel is transferred from the SFPs to the ISFSI is acceptable.

3.0 REGULATORY EVALUATION

3.1 Applicable Regulatory Requirements/Criteria 3.1.1 General Design Criteria As discussed in DSAR Section 1.3 TMI-1 was designed and constructed taking into consideration the General Design Criteria (GDC) for nuclear power plant construction permits as listed in the proposed AEC GDC, dated July 1967 (Reference 5.14). The GDC that remain applicable are discussed in detail in DSAR Section 1.3. As systems, structures and components were abandoned, the detail describing those systems have been removed in accordance with the 10 CFR 50.59 regulatory process. Section 2.4 of this submittal addresses the applicability of the GDC as it relates to the ISFSI only condition.

3.1.2 10 CFR 50.82, Termination of License 10 CFR 50.82(a)(2) states "Upon docketing of the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel, or when a final legally effective order to permanently cease operations has come into effect, the 10 CFR Part 50

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 39 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes license no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel."

3.1.3 10 CFR 50.2, Definitions, Safety-Related Structures, Systems and Components 10 CFR 50.2 defines safety-related SSCs as those SSCs that are relied upon to remain functional during and following design basis events to assure:

1. The integrity of the reactor coolant pressure boundary;

2. The capability to shut down the reactor and maintain it in a safe shutdown condition; or

3. The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in

§50.34(a)(1) or §100.11 of this chapter, as applicable.

The first two criteria (integrity of the reactor coolant pressure boundary and safe shutdown of the reactor) are not applicable to a plant in a permanently defueled condition. The third criterion is related to preventing or mitigating the consequences of accidents that could result in potential offsite exposures exceeding limits. However, after all irradiated fuel assemblies have been transferred to the ISFSI, there are no longer any SSCs at TMI-1 that are required to be relied upon to prevent or mitigate an accident with the potential to exceed 10 CFR 100 limits.

Therefore, with no fuel stored in the SFPs, none of the SSCs at TMI-1 meet the definition of a safety-related SSC as stated in 10 CFR 50.2.

3.1.4 10 CFR 50.36, Technical Specifications In 10 CFR 50.36, the NRC established its regulatory requirements related to the content of TS.

In doing so, the NRC placed emphasis on those matters related to the prevention of accidents and mitigation of accident consequences; the NRC noted that applicants were expected to incorporate into their TS "those items that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity." (Statement of Consideration, "Technical Specification for Facility Licenses; Safety Analysis Reports," [33 FR 18610, December 17, 1968]) (Reference 5.26) Pursuant to 10 CFR 50.36, TS are required to include items in the following five categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls. However, the rule does not specify the particular requirements to be included in a plant's TS.

These criteria, which were subsequently codified in changes to 10 CFR 50.36 [60 FR 36953, July 19, 1995] (Reference 5.27), also pertain to the TS requirements for safe storage of irradiated fuel. However, the rule does not specify the particular requirements to be included in a plant's TS, as specified in 10 CFR 50.36(iii) "A licensee is not required to propose to modify technical specifications that are included in any license issued before August 18, 1995, to satisfy the criteria in paragraph (c)(2)(ii) of this section."

The following provides a discussion of the applicability of these four criteria in a permanently defueled condition with all fuel removed from the SFPs.

• Criterion 1 of 10 CFR 50.36(c)(2)(ii)(A) states that TS LCOs must be established for "installed instrumentation that is used to detect, and indicate in the control room, a significant abnormal degradation of the reactor coolant pressure boundary." Since no

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 40 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes irradiated fuel will be present in the SFPs at TMI-1 following permanent transfer to the ISFSI, this criterion is not applicable.

• Criterion 2 of 10 CFR 50.36(c)(2)(ii)(B) states that TS LCOs must be established for a "process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier." The purpose of this criterion is to capture those process variables that have initial values assumed in DBA and transient analyses, and which are monitored and controlled during power operation. While this criterion was developed for operating reactors, there are some DBAs which continue to apply to a plant authorized only to handle, store, and possess nuclear fuel. Once all of the irradiated fuel is permanently moved out of the SFPs into an ISFSI, there will no longer be any DBAs in applicable to the plant.

• Criterion 3 of 10 CFR 50.36(c)(2)(ii)(C) states that TS LCOs must be established for SSCs that are part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The intent of this criterion is to capture into TS those SSCs that are part of the primary success path of a safety sequence analysis. Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function. The primary success path of a safety sequence analysis consists of the combination and sequences of equipment needed to operate (including consideration of the single failure criterion), so that the plant response to DBA and transients limits the consequences of these events to within the appropriate acceptance criteria. There are no DSAR described transients that will assume the failure of or challenge a fission product barrier. The DSAR postulated accident will no longer continue to apply to the station with the irradiated fuel permanently removed from the SFPs and stored in the ISFSI.

• Criterion 4 of 10 CFR 50.36(c)(2)(ii)(D) states that TS LCOs must be established for SSCs that "operating experience or probabilistic risk assessment has shown to be significant to public health and safety." The intent of this criterion is that operating experience and risk insights be factored into the establishment of TS LCOs. There are no postulated accident sequences remaining at TMI-1 with the irradiated fuel permanently removed from the SFPs.

10 CFR 50.36(c)(5), "Administrative Controls, states that they "... are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner." The particular administrative controls to be included in the TS, therefore, are the provisions that the NRC deems essential for the safe operation of the facility that are not already covered by other regulations. Accordingly, the NRC staff determined that administrative control requirements that are not specifically required under 10 CFR 50.36(c)(5), and which are not otherwise necessary to obviate the possibility of an abnormal situation or an event giving rise to an immediate threat to the public health and safety, may be relocated to more appropriate documents (e.g., Quality Assurance Program, Security Plan, or Emergency Plan), which are subject to regulatory controls. Similarly, while the required content of TS administrative controls is specified in 10 CFR 50.36(c)(5),

particular details may be relocated to licensee-controlled documents, where other regulations provide adequate regulatory control.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 41 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes 10 CFR 50.36(c)(6), "Decommissioning," applies only to nuclear power reactor facilities that have submitted the certifications required by 10 CFR 50.82(a)(1). For such facilities, TS involving "safety limits, limiting safety system settings, and limiting control system settings; limiting conditions for operation; surveillance requirements; design features; and administrative controls will be developed on a case-by-case basis." [Emphasis added]

This proposed amendment deletes or moves the portions of the previous TMI-1 license requirements/conditions that are no longer applicable or can be contained in alternate locations associated with a permanently defueled facility while modifying the remaining portions to correspond to the ISFSI only condition.

3.1.5 10 CFR 50.51, Continuation of License 10 CFR 50.51(b) states "Each license for a facility that has permanently ceased operations, continues in effect beyond the expiration date to authorize ownership and possession of the production or utilization facility, until the Commission notifies the licensee in writing that the license is terminated. During such period of continued effectiveness the licensee shall--

(1) Take actions necessary to decommission and decontaminate the facility and continue to maintain the facility, including, where applicable, the storage, control and maintenance of the spent fuel, in a safe condition, and (2) Conduct activities in accordance with all other restrictions applicable to the facility in accordance with the NRC regulations and the provisions of the specific 10 CFR Part 50 license for the facility."

3.1.6 10 CFR 50.54(hh), Notification of potential aircraft threat 10 CFR50.54(hh)(1) establishes the requirements for developing, implementing and maintaining procedures for addressing notification of a potential aircraft threat.

10 CFR 50.54(hh)(2) states: "Paragraph (hh)(1) of this section does not apply to a licensee that has submitted the certifications required under § 50.82(a)(1) or § 52.110(a) of this chapter."

3.1.7 10 CFR 50.155(b)(2), Extensive damage mitigation guidelines 10 CFR 50.155(b)(2) establishes the requirements for developing, implementing and maintaining procedures and strategies for addressing large area fires or explosions.

10 CFR 50.155(a)(2)(iv) states; "Holders of operating licenses or combined licenses for which the certifications described in § 50.82(a)(1) or § 52.110(a) of this chapter have been submitted need not meet the requirements of this section once all irradiated fuel has been permanently removed from the spent fuel pool(s)."

3.1.8 10 CFR 50.54(a), Decommissioning Quality Assurance Program (DQAP)

DQAP which is a licensee-controlled document that has been previously reviewed and approved by the NRC (Reference 5.10), is an appropriate candidate for relocation of administrative controls due to the controls imposed by the existing NRC-approved DQAP and commitments to industry quality assurance (QA) standards, and the established QA program change control process of 10 CFR 50.54(a).

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 42 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes 3.1.9 Administrative Letter (AL) 95-06 NRC Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance," (Reference 5.11) provides guidance to licensees requesting amendments that relocate administrative controls to an NRC approved QA program, where subsequent changes will be controlled pursuant to 10 CFR 50.54(a). AL 95-06 provides specific guidance in the areas of: (1) independent safety engineering group, (2) reviews and audits, (3) procedure review process, and (4) records and record retention. Some relocations are specifically discussed in AL 95-06, while others are similar in nature. Relocations not specifically discussed in AL 95-06 were assessed with respect to the appropriateness of the relocation. Editorial changes are allowed without basis by 10 CFR 50.54(a)(3).

This proposed amendment deletes the portions of the previous TMI-1 PDTS that are no longer applicable and modifies other portions to correspond to a permanently defueled facility with all irradiated fuel in dry storage within an ISFSI.

3.2 Precedent The proposed changes are consistent with the intent of the license and accompanying IOTS issued to the following facilities that have removed all irradiated fuel from their SFPs: Fort Calhoun Station (Reference 5.28), Vermont Yankee Nuclear Power Station (Reference 5.29),

San Onofre Nuclear Generating Station (Reference 5.30), Crystal River Unit 3 Nuclear Generating Plant (Reference 5.31), and Kewaunee Power Station (Reference 5.32).

3.3 No Significant Hazards Consideration (NSHC)

Pursuant to 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon), proposes an amendment to the Renewed Facility License (RFL) and Appendix A, Technical Specifications (TS), of RFL No.

DPR-50-289 for Three Mile Island Nuclear Station, Unit 1 (TMI-1).

The proposed amendment would remove, relocate, and revise certain requirements contained within the RFL and the associated TS to a Renewed Facility License and ISFSI Only Technical Specifications (IOTS) consistent with the removal of all irradiated fuel from the spent fuel pools (SFPs) and NRC Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance" (ADAMS Accession No. ML19095A009).

By letter dated June 20, 2017 (Accession No. ML17171A151), Exelon Generation Company, LLC (Exelon) provided formal notification to the U.S. Nuclear Regulatory Commission (NRC) that Exelon had determined to permanently cease operations at TMI-1 on or about September 30, 2019. On September 26, 2019 (ADAMS Accession No. ML19269E480), Exelon provided formal notification in accordance with 10 CFR 50.82(a)(1)(ii) certifying all fuel has been permanently removed from the TMI-1 reactor vessel and placed in the SFPs. Therefore, in accordance with 10 CFR 50.82(a)(2), the 10 CFR Part 50 license for TMI-1 no longer authorizes operation of the reactor or emplacement or retention of fuel into the reactor vessel.

On April 5, 2019, Exelon submitted the Post-Shutdown Decommissioning Activities Report (PSDAR) (ADAMS Accession No. ML19095A041) and the Spent Fuel Management Plan (SFMP) (ADAMS Accession No. ML19095A009) for TMI-1. The PSDAR documents the TMI-1 expectation that all irradiated fuel be completely transferred to the Independent Spent Fuel

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 43 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes Storage Installation (ISFSI) by the end of December of 2022. In support of this condition, the TMI-1 license and associated Permanently Defueled Technical Specifications (PDTS) are being proposed for revision, in accordance with 10 CFR 50.36(c)(6), to comport to a facility configuration with all irradiated nuclear fuel in dry storage within the onsite ISFSI at TMI-1 using casks certified for use under a general 10 CFR 72 license. Exelon is also proposing to revise Technical Specification 5.2 to prohibit the storage of irradiated fuel in the SFPs to support the premise of this proposed license amendment.

The current PDTS provides appropriate functional capability of equipment required for safe storage and management of irradiated fuel stored in the SFPs. As such, the existing PDTS provide a level of control in excess of that needed for safe storage and management of irradiated fuel with fuel stored in an ISFSI. The majority of the existing PDTS are only applicable when irradiated fuel assemblies are within the SFPs.

The proposed changes also include relocating administrative controls from the PDTS, Section 6, to Exelons NRC approved Decommissioning Quality Assurance Program (DQAP). The DQAP is controlled in accordance with 10 CFR 50.54(a). This relocation is being proposed pursuant to the criteria contained in 10 CFR 50.36 and in accordance with recommendations contained in NRC Administrative Letter 95-06.

The proposed changes also include a renumbering of pages and sections, where appropriate, to condense and reduce the number of pages in the TS without affecting the technical content.

The TS table of contents is also accordingly revised.

Exelon 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 amendment would modify the TMI-1 RFL and PDTS by deleting the portions of the license and PDTS that are no longer applicable to a facility with no irradiated nuclear fuel stored in the SFPs, while modifying the remaining portions to correspond to all nuclear fuel stored within an ISFSI. This amendment will be not be implemented until all irradiated fuel assemblies have been transferred out of the SFPs and placed in dry storage within the ISFSI.

The definition of safety-related structures, systems, and components (SSCs) in 10 CFR 50.2 states that safety-related SSCs are those relied on to remain functional during and following design basis events to assure:

1. The integrity of the reactor coolant boundary;

2. The capability to shutdown the reactor and maintain it in a safe shutdown condition; or

3. The capability to prevent or mitigate the consequences of accidents which could result in potential offsite exposures comparable to the applicable guideline exposures set forth in 10 CFR 50.43(a}(1) or § 100.11.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 44 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes The first two criteria (integrity of the reactor coolant pressure boundary and safe shutdown of the reactor) are not applicable to a plant in a permanently defueled condition. The third criterion is related to preventing or mitigating the consequences of accidents that could result in potential offsite exposures exceeding limits. However, after all irradiated fuel assemblies have been transferred to dry cask storage within an ISFSI, none of the SSCs at TMI-1 are required to be relied on for accident mitigation. Therefore, none of the SSCs at TMI-1 meet the definition of a safety-related SSC stated in 10 CFR 50.2. The proposed deletion of requirements in the PDTS does not affect systems credited in any accident analysis at TMI-1.

Section 6 of the TMI-1 Defueled Safety Analysis Report (DSAR) describes the design basis accidents (DBAs) related to the SFPs. These postulated accidents are predicated on irradiated fuel being stored in the SFPs. With the removal of all the irradiated fuel from the SFPs, there are no remaining irradiated fuel assemblies to be monitored and there are no credible accidents that require the actions of a Shift Manager, Certified Fuel Handler, or a Non-certified Operator to prevent occurrence or mitigate the consequences of an accident.

The proposed changes do not have an adverse impact on the remaining decommissioning activities or any of their postulated consequences.

The proposed changes related to the relocation of certain administrative requirements do not affect operating procedures or administrative controls that have the function of preventing or mitigating any accidents applicable to the safe management of irradiated fuel or decommissioning of the facility.

Therefore, the proposed amendment does 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 eliminate the operational requirements and certain design requirements associated with the storage of the irradiated fuel in the SFPs and relocates certain administrative controls to the DQAP which is a licensee-controlled document with changes governed under the requirements of 10 CFR 50.54(a).

After the removal of the irradiated fuel from the SFPs and transfer to the ISFSI, there will be no irradiated fuel assemblies that remain in the SFPs. Coupled with the proposed Technical Specification 5.2 that prohibits storage of irradiated fuel in the SFPs, the potential for fuel related accidents is removed. The proposed changes do not introduce any new failure modes.

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.

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 45 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes The removal of all irradiated nuclear fuel from the SFPs into storage in casks within an ISFSI, coupled with proposed Technical Specification 5.2 prohibiting future storage of irradiated fuel within the SFPs, removes the potential for any fuel related accidents.

The design basis and accident assumptions within the TMI-1 DSAR and the need for PDTS relating to safe management and safety of irradiated fuel in the SFPs are no longer applicable. The proposed changes do not affect remaining plant operations, systems, or components supporting decommissioning activities.

The requirements for SSCs that have been removed from the TMI-1 PDTS are not credited in the existing accident analysis for any applicable postulated accident; and as such, do not contribute to the margin of safety associated with the accident analysis.

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

Based on the above, Exelon concludes that the proposed amendment does not involve a 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.

3.4 Conclusion In conclusion, based on the considerations of 10 CFR 50.92(c) 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 NRCs 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.

4.0 ENVIRONMENTAL CONSIDERATION

This amendment request meets the eligibility criteria for categorical exclusion from environmental review set forth in 10 CFR 51.22(c)(9) as follows. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

In addition, the proposed administrative changes involve changes to recordkeeping, reporting, or administrative procedures or requirements. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10).

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

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 46 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes

5.0 REFERENCES

5.1 Letter from J. Bradley Fewell (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Certification of Permanent Cessation of Power Operations for Three Mile Island Nuclear Station, Unit 1," dated June 20, 2017 (Accession No. ML17171A151) 5.2 Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, Certification of Permanent Removal of Fuel from the Reactor Vessel for Three Mile Island Nuclear Station, Unit 1, dated September 26, 2019 (ADAMS Accession No. ML19269E480) 5.3 Letter from Michael P. Gallagher (Exelon Generation Company, LLC), to U.S. Nuclear Regulatory Commission, "License Amendment Request - Proposed Changes to Technical Specification Section 1.0, "Definitions," and 6.0, "Administrative Controls" for Permanently Defueled Condition," dated November 10, 2017 (ADAMS Accession No. ML17314A024) 5.4 Letter from Michael P. Gallagher (Exelon Generation Company, LLC), to U.S. Nuclear Regulatory Commission, "License Amendment Request - Proposed Defueled Technical Specifications and Revised License Conditions for Permanently Defueled Condition,"

dated July 25, 2018 (ADAMS Accession No. ML18206A545) 5.5 Letter from Michael P. Gallagher (Exelon Generation Company, LLC), to U.S. Nuclear Regulatory Commission, " Supplement - License Amendment Request - Proposed Defueled Technical Specifications and Revised License Conditions for Permanently Defueled Condition ," dated March 6, 2019 (ADAMS Accession No. ML19065A217) 5.6 Letter from Justin C. Poole (U.S. Nuclear Regulatory Commission) to Bryan C. Hanson (Exelon Generation Company, LLC), "Three Mile Island Nuclear Station, Unit 1 - Issuance of Amendment No. 295 Re: Changes to Technical Specifications 1.0, "Definitions," and 6.0, "Administrative Controls," for Permanently Defueled Condition (EPID L-2017-LLA-0384)," dated December 14, 2018 (ADAMS Accession No. ML18305B419) 5.7 Letter from Justin C. Poole (U.S. Nuclear Regulatory Commission) to Bryan C. Hanson (Exelon Generation Company, LLC), "Three Mile Island Nuclear Station, Unit 1 - Issuance of Amendment No. 297 Re: Defueled Technical Specifications and Revised License Conditions (EPID L-2018-LLA-0204)," dated August 29, 2019 (ADAMS Accession No. ML19211D317) 5.8 Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, Three Mile Island Nuclear Station, Unit 1 - Post-Shutdown Decommissioning Activities Report, dated April 5, 2019 (ADAMS Accession No. ML19095A041) 5.9 Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, Spent Fuel Management Plan for Three Mile Island Nuclear Station - Unit 1, dated April 5, 2019 (ADAMS Accession No. ML19095A009) 5.10 Letter from John C. Lamb (U.S. Nuclear Regulatory Commission) to Bryan C. Hanson (Exelon Generation Company, LLC), Oyster Creek Nuclear Generating Station and Independent Spent Fuel Storage Installation - Review and Acceptance of Changes Re:

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 47 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes Decommissioning Quality Assurance Program (EPID L-2017-Llq-0003), dated June 27, 2018 (ADAMS Accession No. ML18165A136) 5.11 NRC Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance," dated December 12, 1995 (ADAMS Accession No. ML031110271) 5.12 Letter from John M. Goshen (U.S. Nuclear Regulatory Commission) to Wren Fowler (NAC International), Issuance of Certificate of Compliance No. 1031, Amendment No. 6 for the MAGNASTOR Cask System (CAC NO. L25069), dated November 30, 2106 (ADAMS Accession No ML16319A068) 5.13 Letter from Theodore Smith (U.S. Nuclear Regulatory Commission) to Bryan C. Hanson (Exelon Generation Company, LLC), "Three Mile Island Nuclear Station, Unit 1 Issuance of Amendment No. 300 Re: Deletion of Permanently Defueled Technical Specification 3/4.1.4, Handling of Irradiated Fuel With Fuel Handling Building Crane (EPID L-2019-LLA-0250)", dated December 3, 2020 (ADAMS Accession No. ML20297A635) 5.14 Federal Register, Volume 32, Atomic Energy Commission, 10 CFR Part 50, General Design Criteria for Nuclear Power Plant Construction Permits, dated July 11, 1967 (32 FR 10213) (ADAMS Accession No. ML043310029) 5.15 NO-DC-10, Exelon Generation Company, LLC, "Decommissioning Quality Assurance Program (DQAP)," Revision 1, dated 8/19/2019) 5.16 Regulatory Guide 1.191, "Fire Protection Program for Nuclear Power Plants During Decommissioning and Permanent Shutdown," Rev. 0, dated May 2001 (ADAMS Accession No. ML011500010) 5.17 Letter from Justin C. Poole (U.S. Nuclear Regulatory Commission) to Bryan C. Hanson (Exelon Generation Company, LLC), "Three Mile Island Nuclear Station, Unit 1 - Partial Exemption From Certain Record Retention Requirements (EPID L-2019-LLE-0018),"

dated May 19, 2019 (ADAMS Accession No. ML20107J648) 5.18 NUREG-1928, "Safety Evaluation Report Related to the License Renewal of Three Mile Island Nuclear Station, Unit 1," dated October 2009 (ADAMS Accession No. ML092950458) 5.19 NUREG-1430, "Standard Technical Specifications Babcock and Wilcox Plants,"

Revision 4, dated April 2012 (ADAMS Accession Nos. ML12100A177 and ML12100A178) 5.20 Letter form Peter J. Bamford (U.S. Nuclear Regulatory Commission) to Christopher M.

Crane (AmerGen Energy Company, LLC), "Three Mile Island Nuclear Station, Unit 1 -

Conforming License Amendment to Incorporate the Mitigation Strategies Required by Section B.5.b. of Commission Order EA-02-026 (TAC NO. MD4515), dated July 18, 2007 (ADAMS Accession No. ML071980016) 5.21 Letter from Samuel J. Collins (U.S. Nuclear Regulatory Commission) to Oliver D.

Kingsley, Jr. (Exelon Generation Company, LLC), Issuance of Order for Interim Safeguards and Security Compensatory Measures for - Three Mile Island Nuclear Station, Unit 1, dated February 25, 2002 (ADAMS Accession No. ML020510333 and ML020510635)

License Amendment Request Attachment 1 Proposed Changes RFL and Technical Specifications Page 48 of 48 Docket Nos. 50-289 Evaluation of Proposed Changes 5.22 Federal Register, Volume 84, No. 154, Nuclear Regulatory Commission, 10 CFR Parts 50 and 52, "Mitigation of Beyond-Design-Basis Events," dated August 9, 2019 (pages 39684-39722) 5.23 Letter from Eric J. Leads (U.S. Nuclear Regulatory Commission) to Holders of Licenses for Operating Power Reactors, "Rescission or Partial Rescission of Certain Power Reactor Security Orders Applicable to Nuclear Power Plants," dated November 28, 2011 (ADAMS Accession No. ML111220447) 5.24 NUREG-1536, Standard Review Plan for Dry Cask Storage Systems Revision 1, dated July 2010 (Adams Accession No. ML1010406201) 5.25 NUREG-1757, "Consolidated Decommissioning Guidance," Volume 1, "Decommissioning Process for Materials Licensees," Revision 2, dated September 2006 5.26 Federal Register, Volume 33, No. 244, Title 10-Atomic Energy, "Part 50-Licensing of Production and Utilization Facilities," dated December 17, 1968 (pages 18610-18613) 5.27 Federal Register, Volume 60, No. 138, Nuclear Regulatory Commission, 10 CFR Part 50, "Technical Specifications," dated July 19, 1995 (pages 36953-36959) 5.28 Letter from Jack D. Parrott (U.S. Nuclear Regulatory Commission) to Mary Fisher (Omaha Public Power District), "Fort Calhoun Station, Unit No. 1 - Issuance of Amendment to Revise the Permanently Defueled Technical Specifications to Align to The Requirements for Permanent Removal of Spent Fuel From the Spent Fuel Pool (EPID NO. L-2018-LLA-0274), dated December 11, 2019 (ADAMS Accession No. ML19297D677) 5.29 Letter from Jack D. Parrott (U.S. Nuclear Regulatory Commission) to Corey Daniels (Entergy Nuclear Operations, Inc.), Vermont Yankee Nuclear Power Station - Issuance of Amendment to Change the Permanently Defueled Technical Specifications to Reflect Permanent Removal of Spent Fuel From the Spent Fuel Pool (EPID NO. L-2017-LLA-0125), dated August 15, 2018 (ADAMS Accession No. ML18156A181) 5.30 Letter from Marlayna G. Vaaler (U.S. Nuclear Regulatory Commission) to Thomas J.

Palmisano (Southern California Edison Company), San Onofre Nuclear Generating Station, Units 1, 2, And 3 - Issuance of Amendments to Change the Defueled Technical Specifications to Reflect Permanent Removal of Spent Fuel From the Spent Fuel Pools (CAC Nos. L53157, L53158, AND L53159), " dated January 9, 2018 (ADAMS Accession No.ML17345A657) 5.31 Letter from John B. Hickman (U.S. Nuclear Regulatory Commission) to Terry D. Hobbs (Crystal River Nuclear Plant), Crystal River Unit 3 Nuclear Generating Plant - Issuance of Amendment 255 for the License and Permanently Defueled Technical Specifications to Reflect Permanent Removal of Spent Fuel From the Spent Fuel Pools (TAC Nos.

L53146), dated June 27, 2017 (ADAMS Accession No. ML17027A160) 5.32 Letter from Ted H. Carter (U.S. Nuclear Regulatory Commission) to David A. Heacock (Dominion Energy Kewaunee, Inc.), Kewaunee Power StationIssuance of Amendment for Proposed Changes to License and Technical Specifications to Reflect Permanent Removal of Spent Fuel From Spent Fuel Pool (CAC No. L53079), dated June 7, 2017 (ADAMS Accession No. ML17123A027)

Attachment 2 Proposed Technical Specifications (Marked-Up Pages)

Three Mile Island Nuclear Station, Unit 1 Renewed Facility License No. DPR-50 NRC Docket No. 50-289 Changes to the Renewed Facility License (RFL) and Appendix A, Permanently Defueled Technical Specification (PDTS)

(31 pages)

Section Pages RFL 2, 5 and 6 TS Table of Contents i through ii TS Section 1 Definitions 1-1 TS Section 3/4.0 Limiting Conditions for Operation and Surveillance Requirements 3/4-1 through 3/4-3 TS LCO 3/4.1 Handling and Storage of Irradiated Fuel in the Spent Fuel Pool 3/4-4 through 3/4-9 TS Section 5 Design Features Cover Sheet and 5-1 through 5-3 TS Section 6.0 Administrative Controls Cover Sheet, 6-1, 6-2, and 6-11 through 6-15







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