ML110540374

Request for Additional Information Regarding Proposed Relocation of Equipment Load List from the Technical Specifications to a Licensee Controlled Document

ML110540374
Person / Time
Site:	Three Mile Island
Issue date:	03/21/2011
From:	Bamford P J Plant Licensing Branch 1
To:	Pacilio M J Exelon Nuclear, Exelon Generation Co
Bamford, Peter J., NRR/DORL 415-2833
References
TAC ME4732
Download: ML110540374 (4)

Text

UNITED NUCLEAR REGULATORY WASHINGTON, D.C. 20555-0001 March 21, 2011 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 THREE MILE ISLAND NUCLEAR STATION, UNIT 1 -REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED RELOCATION OF EQUIPMENT LOAD LIST FROM THE TECHNICAL SPECIFICATIONS TO A LICENSEE CONTROLLED DOCUMENT (TAC NO. ME4732)

Dear Mr. Pacilio:

By letter dated September 22, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 102650392), Exelon Generation Company, LLC (Exelon, the licensee) submitted a license amendment request (LAR) proposing to revise the Technical Specifications (TSs) for Three Mile Island Nuclear Station, Unit 1. The proposed changes would relocate the equipment load list from TS 4.5.1.1.b to the Updated Final Safety Analysis Report. The Nuclear Regulatory Commission staff has been reviewing the submittal and has determined that additional information is needed to complete its review. The specific questions are found in the enclosed request for additional information (RAI). The questions were sent via electronic transmission on February 22,2011, to Mr. Frank Mascitelli, of your staff. The draft questions were sent to ensure that the questions were understandable, the regulatory basis was clear, and to determine if the information was previously docketed.

The draft questions were discussed in a teleconference with your staff on February 25, 2011. After the teleconference was held, the first two questions in the original draft RAI were combined into one question and sent to Mr. Mascitelli in draft form on March 3, 2011. The final version of the RAI questions is enclosed.

It was agreed that a response to this RAI would be submitted by April 7, 2011. Please contact me at 301-415-2833, if you have any questions.

Sincerely, Peter Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

As stated cc w/encl: Distribution via Listserv REQUEST FOR ADDITIONAL INFORMATION THREE MILE ISLAND NUCLEAR STATION, UNIT 1 PROPOSED TECHNICAL SPECIFICATION CHANGES REGARDING RELOCATION OF EQUIPMENT LOAD LIST FROM TECHNICAL SPECIFICATIONS TO A LICENSEE CONTROLLED DOCUMENT DOCKET NO. SO-289 By letter dated September 22, 2010 (Agencywide Documents Access and Management System Accession No. ML 1026S0392), Exelon Generation Company, LLC (the licensee), submitted a license amendment request (LAR) for Three Mile Island Nuclear Station, Unit 1 (TMI-1). The licensee proposes to relocate the equipment load list from Technical Specification (TS) 4.S.1.1.b, to the Updated Final Safety Analysis Report (UFSAR). In order for the NRC staff to complete its review of the LAR, a response to the following request for additional information is requested. Title 10 of the Code of Federal Regulations (10 CFR) Section SO.36(b) states, in part: "The technical specifications will be derived from the analysis and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to §SO.34." The LAR presents a brief description of how the requested changes meet the requirements of 10 CFR SO.36(c)(2)(ii), however it does not explain how relocating the equipment list back to the document from which TS is derived will comply with the above 10 CFR SO.36(b) requirement(s).

Additionally, TSs are required to contain surveillance requirements in accordance with the requirements at 10 CFR SO.36(c)(3) which states: "Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." Please explain how the surveillance will continue to ensure that the safety-related equipment proposed for relocation from the TS to the UFSAR will continue to be able to perform the specified safety functions and how continued compliance with 10 CFR SO.36(b) is met. The response should include, but not be limited to, an explanation of how the revised TS will ensure that all equipment described in TMI-1 UFSAR Chapter 14, which depends on the sequencer, will be properly tested. In the LAR, Attachment 1, Section 4.3, the LAR states that the proposed changes are consistent with Standard Technical Specifications (STS), NUREG-1430, "Standard Technical Specifications Babcock and Wilcox Plants." Section 3.0 of Attachment 1 states that the proposed changes are consistent with STS Enclosure

-2 surveillance test requirements contained in SR 3.8.1.19 and SR 3.8.1.11.

The LAR further states that while the performance of the Sequence and Power Test meets the criteria of 10 CFR 50.36( c)(2)(ii) for inclusion in the TS, the listing of equipment being relocated provides little or no safety benefit. However, the proposed relocation of the equipment load list does not include a high level description, in the TS, of the loads that the test is designed to cover, leaving very little description to ensure compliance with 10 CFR 50.36(c)(3).

Such a high level description is provided in NUREG-1430, which includes reference to energizing permanently connected Emergency Diesel Generator loads and energizing auto-connected emergency/shutdown loads through the automatic load sequencer.

Such a description would be needed to be consistent with the referenced STS, as the application purports.

Please provide an updated version of the proposed TS with a high level description of the equipment load list in the surveillance or provide justification as to why it is not provided.

March 21, 2011 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville,IL 60555 THREE MILE ISLAND NUCLEAR STATION, UNIT 1-REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED RELOCATION OF EQUIPMENT LOAD LIST FROM THE TECHNICAL SPECIFICATIONS TO A LICENSEE CONTROLLED DOCUMENT (TAC NO. ME4732)

Dear Mr. Pacilio:

By letter dated September 22, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 102650392), Exelon Generation Company, LLC (Exelon, the licensee) submitted a license amendment request (LAR) proposing to revise the Technical Specifications (TSs) for Three Mile Island Nuclear Station, Unit 1. The proposed changes would relocate the equipment load list from TS 4.5.1.1.b to the Updated Final Safety Analysis Report The Nuclear Regulatory Commission staff has been reviewing the submittal and has determined that additional information is needed to complete its review. The specific questiors are found in the enclosed request for additional information (RAI). The questiors were sent via electronic transmission on February 22, 2011, to Mr. Frank Mascitelli, of your staff. The draft questiors were sent to ensure that the questions were understandable, the regulatory basis was clear, and to determine if the information was previously docketed.

The draft questirns were discussed in a teleconference with your staff on February 25, 2011. After the teleconference was held, the first two questions in the origina draft RAI were combined into one question and sent to Mr. Mascitelli in draft form on March 3, 2011. The final version of the RAI questions is enclosed.

It was agreed that a response to this RAI would be submitted byApril 7, 2011. Please contact me at 301-415-2833, if you have any questions.

Sincerely, IRAJ Peter Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

As stated cc w/encl: Distribution via Listserv RidsNrrPMThreeMilelsland Resource PUBLIC LPLI-2 RtF RidsAcrsAcnw_MailCTR Resource RidsNrrLAABaxter Resource RidsOgcRp Resource RidsRgn1 MailCenter Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl1-2 Resouce GWaig, NRR RidsNrrDirsltsb Resource ADAMS Accession Number ML110540374

• OFFICE LPL 1-2/PM NAME PBamford ABaxter(SLittle RElliott*

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