ML18263A199

License Amendment Request-Administrative Changes to Tendon Surveillance Program Technical Specifications

ML18263A199
Person / Time
Site:	Three Mile Island
Issue date:	09/20/2018
From:	Jim Barstow Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TMl-18-092
Download: ML18263A199 (12)

Text

200 Exelon Way Exelon Generation Kennett Square . PA 19348 www.exeloncorp com 10 CFR 50.90 TMl-18-092 September 20, 2018 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289

Subject:

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

The proposed amendment revises Technical Specification (TS) 4.4.2.1 ("lnservice Tendon Surveillance Requirements"). The surveillance requirements and inspection frequencies for the tendons are mandated by 10 CFR 50.55a. Currently, the TS does not allow exceptions to the requirements of 10 CFR 50.55a. This administrative change will add the words "except where an alternative, exemption, or relief has been authorized by the NRC" to allow NRG-approved exceptions to the 10 CFR 50.55a requirements. Additionally, a note to exempt from the requirements of Surveillance Requirement 4.0.1 is being added.

Attachment 1 provides the Evaluation of Proposed Changes. Attachment 2 provides the Proposed Technical Specification Marked-Up Pages.

The proposed changes have been reviewed by the TMI Plant Operations Review Committee.

Exelon requests approval of the proposed amendment by September 20, 2019. Once approved, the amendment shall be implemented within 60 days.

There are no regulatory commitments contained in this submittal.

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

U.S. Nuclear Regulatory Commission License Amendment Request - Administrative Changes to Tendon Surveillance Program Technical Specifications September 20, 2018 Page2 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," Exelon is notifying the Commonwealth of Pennsylvania of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated state official.

Should you have any questions concerning this submittal, please contact Tom Loomis at (610) 765-5510.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 201h day of September 2018.

Respectfully,

~~wt:

James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Evaluation of Proposed Technical Specification Changes

2) Proposed Technical Specification Marked-Up Pages cc: USNRC Regional Administrator, Region I USNRC Project Manager, TMI USNRC Senior Resident Inspector, TMI Director, Bureau of Radiation Protection - PA Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, Dauphin County, PA R. R. Janati, Pennsylvania Bureau of Radiation Protection

ATTACHMENT 1 EVALUATION OF PROPOSED TECHNICAL SPECIFICATION CHANGES

SUBJECT:

License Amendment Request-Administrative Changes to Tendon Surveillance Program Technical Specifications 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION

4.0 REGULATORY EVALUATION

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

4.4 CONCLUSION

S

6.0 REFERENCES

Evaluation of Proposed Attachment 1 Technical Specification Changes Page 1of6 1.0

SUMMARY

DESCRIPTION The proposed amendment revises Technical Specification (TS) 4.4.2.1 ("lnservice Tendon Surveillance Requirements"). The surveillance requirements and inspection frequencies for the tendons are mandated by 10 CFR 50.55a. Currently, the TS does not allow exceptions to the requirements of 10 CFR 50.55a. This administrative change will add the words "except where an alternative, exemption, or relief has been authorized by the NRC" to allow NRG-approved exceptions to the 10 CFR 50.55a requirements. Additionally, a note to exempt from the requirements of Surveillance Requirement 4.0.1 is being added.

Exelon requests approval of the proposed amendment by September xx, 2019. Once approved, the amendment shall be implemented within 60 days.

2.0 DETAILED DESCRIPTION TS 4.4.2.1 will be revised as follows:

"4.4.2.1 lnservice Tendon Surveillance Requirements The surveillance program for structural Integrity and corrosion protection conforms to the requirements of Subsection IWL of Section XI of the ASME Boiler and Pressure Vessel Code, as incorporated by reference into 10 CFR 50.55a, except where an alternative, exemption, or relief has been authorized by the NRC. The detailed surveillance program for the prestressing system tendons shall be based on periodic inspection and mechanical tests to be performed on selected tendons.

The surveillance interval extension allowed per Surveillance Requirement 4.0.1 is not permitted."

3.0 TECHNICAL EVALUATION

TMI TS 3.19.1 requires the periodic verification of containment structural integrity in accordance with the inservice tendon surveillance program for the reactor building prestressing system. TS 4.4.2.1 specifies the inservice tendon surveillance requirements to ensure the structural integrity of the reactor building in accordance with TS 3.19.1.

In the U.S. Nuclear Regulatory Commission (NRC) Safety Evaluation Report (SER) dated July 13, 2004 (Reference 1), the NRC approved revisions to TS 4.4.2.1 for TMI to allow the use of Section XI, Subsection IWL of the ASME Boiler and Pressure Vessel Code, as incorporated by reference in 10 CFR 50.55a, for its tendon surveillance requirements.

As stated in the SER:

"In a letter dated February 13, 2004, the licensee clarified its intent to use Subsection IWL of Section XI of the ASME Code, as incorporated by reference in 10 CFR 50.55a, for its tendon surveillance requirements. The February 13, 2004, letter deleted reference to RG 1.35.

This change provides consistency between the TS tendon surveillance program requirements and the regulatory requirement specified in 10 CFR 50.55a(b)(2)(vi) by invoking the applicable ASME Code,Section XI, Subsection IWL, for TMl-1 containment examinations and inspections. The NRC staff finds the use of the 1992 edition and the 1992

Evaluation of Proposed Attachment 1 Technical Specification Changes Page 2 of 6 addenda of Subsection IWL of the ASME Code as modified by 10 CFR 50.55a(b)(2)(viii),

acceptable for establishing the reactor building prestressing tendon surveillance program at TMl-1."

Since that time, Subsection IWL has been updated to later NRG-approved editions of the ASME Code as modified by 10 CFR 50.55a.

However, this previous TS revision did not provide for provisions to incorporate alternatives, exemptions, or relief approved by the U.S. Nuclear Regulatory Commission. This License Amendment Request is intended to add this provision.

The proposed wording is contained in the standard Improved Technical Specifications (ITS)

NUREG. As discussed in NUREG-1430, "Standard Technical Specifications Babcock and Wilcox Plants Revision 4.0," Section 5.5.6, "Pre-Stressed Concrete Containment Tendon Surveillance Program" (Reference 2):

"The Tendon Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with Section XI, Subsection IWL of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR50.55a, except where an alternative, exemption, or relief has been authorized by the NRC."

This change is an administrative change. All exceptions will be approved by the U.S. Nuclear Regulatory Commission as discussed in the TS.

Additionally, as discussed in the Safety Evaluation Report for South Texas Project, Units 1 and 2, dated May 27, 2011 (Reference 3):

"During its review of the Reference 2 submittal, however, the NRC staff identified areas where additional information was needed to complete its review. The revised wording proposed in Reference 2 also stated that the provisions of SR 4.0.3 are applicable to the TS 6.8.3.I surveillance program inspection frequencies. SR 4.0.3 further invokes SR 4.0.2.

SR 4.0.2 states that, Each Surveillance Requirement shall be performed within the specified surveillance interval with a maximum allowable extension not to exceed 25 percent of the specified surveillance interval.

This statement presented an apparent conflict between grace periods in the proposed TS language and the ASME Code for performing the surveillances that are part of the Containment Post-Tensioning System Program, as discussed below.

Since 1996, the requirements for the CISI program, which includes tendon surveillance, is mandated by the regulations (1 O CFR 50.55a(g)) to be performed in accordance with Subsections IWE (for Class MC components and metallic liners) and Subsection IWL (for Class CC components) of ASME Section XI, as incorporated by reference and conditioned in 10 CFR 50.55a. For the tendon surveillance program of Class CC containment, the Code provisions in Subsection IWL include reasonable grace periods for licensees to conduct the inspections required, as stated in IWL-2400. The grace period of 25 percent, of the Code specified surveillance frequency of 5 years for tendon surveillance, allowed by SR 4.0.2 would result in a grace period of 1.25 years, which is not consistent with the grace period

Evaluation of Proposed Attachment 1 Technical Specification Changes Page 3 of 6 allowed in the Subsection IWL provisions. Therefore, allowing the use of an extension period as stated in SR 4.0.2 creates a deviation from the ASME Code requirements incorporated by reference in 10 CFR 50.55a. This would be inconsistent with the regulations."

Accordingly, the wording "The surveillance interval extension allowed per Surveillance Requirement 4.0.1 is not permitted" has been added to address the concerns identified in the U.S. Nuclear Regulatory Commission's Safety Evaluation Report (Reference 3).

4.0 REGULATORY EVALUATION

4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met. The proposed changes are administrative changes that have no impact on systems, structures, or components. These proposed changes do not impact the U.S. Nuclear Regulatory Commission Staff's authority to review and grant exceptions.

10 CFR 50.36 establishes the requirements related to the content of the Technical Specifications for operating power plants: (1) Safety limits, limiting safety system settings, and limiting control settings, (2) Limiting conditions for operation, (3) Surveillance requirements, (4)

Design features, (5) Administrative controls, (6) Decommissioning, (7) Initial notification, and (8)

Written Reports.

TS 4.4.2.1 is contained in the Surveillance Requirements section of the TMI TS. For Surveillance Requirements, 10 CFR 50.36 states that:

"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."

These proposed changes are administrative changes to add the words "except where an alternative, exemption, or relief has been authorized by the NRC" to Technical Specification (TS) 4.4.2.1 ("lnservice Tendon Surveillance Requirements"). Additionally, a note to exempt from the requirements of Surveillance Requirement 4.0.1 is being added. These proposed changes to the TS do not affect conformance with 10 CFR 50.36 requirements because this change is administrative and is not intended to impact any systems, structures, or components (SSCs).

TS 4.4.2.1 references 10 CFR 50.55a. This regulation provides provisions under 10 CFR 50.55a{z) ("Alternatives to codes and standards requirements") by which a licensee can request relief by demonstrating: 1) an acceptable level of quality and safety, or; 2) hardship without a compensating increase in quality and safety. In addition, 10 CFR 50.55a provides impracticality provisions in 10 CFR 50.55a(g)(5)(iii). Other alternate provisions, such as, but not limited to, an exemption request (10 CFR 50.12 "Specific exemptions") can be utilized. In each case, the U.S. Nuclear Regulatory Commission will still authorize exceptions with the proposed change.

Evaluation of Proposed Attachment 1 Technical Specification Changes Page 4 of 6 The proposed wording is contained in the standard Improved Technical Specifications (ITS)

NUREG. As stated in NUREG-1430, "Standard Technical Specifications Babcock and Wilcox Plants, Revision 4.0," Section 5.5.6, "Pre-Stressed Concrete Containment Tendon Surveillance Program":

"The Tendon Surveillance Program, inspection frequencies, and acceptance criteria shall be in accordance with Section XI, Subsection IWL of the ASME Boiler and Pressure Vessel Code and applicable addenda as required by 10 CFR50.55a, except where an alternative, exemption, or relief has been authorized by the NRC."

Additionally, the wording "The surveillance interval extension allowed per Surveillance Requirement 4.0.1 is not permitted" has been added to address the concerns identified in the U.S. Nuclear Regulatory Commission's Safety Evaluation Report (Reference 3).

4.2 PRECEDENT Letter from B. Singal (U.S. Nuclear Regulatory Commission) to E. Halpin (STP Nuclear Operating Company), "South Texas Project, Units 1 and 2 - Issuance of Amendments RE:

Containment Post-Tensioning System Surveillance Program (TAC Nos. ME3969 and ME3970),"

dated May 27, 2011 (ML111370277).

4.3 NO SIGNIFICANT HAZARDS CONSIDERATION 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 addition of the words "except where an alternative, exemption, or relief has been authorized by the NRC" to Technical Specification (TS) 4.4.2.1 ("lnservice Tendon Surveillance Requirements") and the addition of the wording "The surveillance interval extension allowed per Surveillance Requirement 4.0.1 is not permitted" are administrative changes that have no impact on the accidents analyzed and are not an accident initiator. Since the changes do not impact any conditions that would initiate an accident, the probability or consequences of previously analyzed events is not increased.

The proposed changes do not involve the modification of any plant equipment or affect plant operation. The proposed changes will have no impact on any safety-related structures, systems, or components.

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

Evaluation of Proposed Attachment 1 Technical Specification Changes Page 5 of 6

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

Response: No.

No safety-related equipment, safety function, or plant operation will be altered as a result of these proposed administrative changes. No new operator actions are created as a result of the proposed changes. These administrative changes have no impact on the accidents analyzed in the Updated Final Safety Analysis Report (UFSAR) and are not accident initiators. These proposed changes do not impact the U.S. Nuclear Regulatory Commission Staff's authority to review and grant exceptions. The addition of the wording The surveillance interval extension allowed per Surveillance Requirement 4.0.1 is not permitted" has been added to address the concerns identified in the U.S. Nuclear Regulatory Commission's Safety Evaluation Report (Reference 3).

Since these proposed changes do not impact any conditions that would initiate an accident, there is no possibility of a new or different kind of accident resulting from these changes. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response: No.

The proposed administrative changes do not affect any margins of safety. The margins of safety presently provided by the Technical Specifications remain unchanged. The proposed amendment does not affect the design of the facility or system operating parameters, does not physically alter safety-related systems, structures, or components (SSCs) and does not affect the method in which safety-related systems perform their functions.

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

Based on the above, Exelon concludes that the proposed amendment 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.

4.4 CONCLUSION

S In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Evaluation of Proposed Attachment 1 Technical Specification Changes Page 6 of 6

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6.0 REFERENCES

1. Letter from T. Colburn (U.S. Nuclear Regulatory Commission) to C. Crane (AmerGen Energy Company, LLC (now Exelon Generation Company, LLC)), "Three Mile Island Nuclear Station, Unit 1, RE: Reactor Building Tendon Surveillance Criteria (TAC No.

MC0361)," dated July 13, 2004 (ML041660364).

2. NUREG-1430, Standard Technical Specifications, Babcock and Wilcox Plants, Revision 4, Volume 1, Specifications, dated April 2012.

3. Letter from B. Singal (U.S. Nuclear Regulatory Commission) to E. Halpin (STP Nuclear Operating Company), "South Texas Project, Units 1 and 2 - Issuance of Amendments RE: Containment Post-Tensioning System Surveillance Program (TAC Nos. ME3969 and ME3970)," dated May 27, 2011 (ML111370277).

ATTACHMENT2 PROPOSED TECHNICAL SPECIFICATION MARKED-UP PAGES Pages 4-35 4-37

, except where an 4.4.2 §tructural !ntegriJJl alternative, exemption, or relief has been authorized Specification by the NRC 4.4.2.1 The surveillance program for structural Integrity a d corrosion protection confonns to the requirements of Subsection IWL of Section XI of e ASME Boiler and Pressure Vessel Code, as incorporated by reference into 10CFR 50.55a. The detailed surveillance program for the prestressing system tendons shall be based on periodic Inspection and mechanical tests to be performed on selected tendons.

The surveillance interval extension allowed per Surveillance Requirement 4.0.1 is not permitted.

4-35 Amendment No. 69, 96, 129, 157, 187, 251

4.4.2.1.6 Reports

a. Within 3 months after the completion of each tendon surveillance a special report shall be submitted to the NRC Region I Administrator. This Report will include a section dealing with trends for the rate of prestress loss as compared to the predicted rate for the duration of the plant life (after an adequate number of surveillances have been completed).

b. Reports submitted In accordance with 10 CFR 50.73 shall Include a description of the tendon condition, the condition of the concrete (especially at tendon anchorages), the Inspection procedures, the tolerances on cracking, and any corrective actions taken* . . . . - - - - - - - - - - - - .

The surveillance interval

• excep~ where an .

4.4.3 DELETED extension allowed per alt~rnat1ve, exemption.' or surveillance Requirement 4.0. 1 rehef has been authorized BASES is not permitted. ._b..;;..y_t_he_N_R_C_ _ _ _ __.

For ungrouted, post* nsioned tendons, this surveillance requirement ensur. s that the structural integrity of the con inment will be maintained In accordance with the provi ions of the TMl-1 Reactor Building tructural Integrity Tendon Surveillance Program. Testln and frequency are consistent with e requirements of Subsection IWL of Section XI of the A ME Boiler and Pressure Ve el Code, as Incorporated by reference Into 10 CFR 50.55a, and as described in the FSAR.

The modified visual inspection requirements pertaining to the dome tendons in the ring girder

"---". were implemented as a result of: 1) discovery of ring girder voids in 1977 and the potential that more undetected voids in the ring girder could exist, and 2) the number of dome tendon bearing areas having cracks appeared to be growing with time (Reference Amendment No. 59).

REFERENCES (1} UFSAR, Section 5.7.5 ~Tendon Stress Surveillances 4-37 Amendment No. 108, 129, 168, 187, 251