ML18283A138

Supplement to License Amendment Request - Proposed Changes to Technical Specifications Sections 1.0, Definitions, and 6.0, Administrative Controls for Permanently Defueled Condition

ML18283A138
Person / Time
Site:	Three Mile Island
Issue date:	10/10/2018
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2018-LLA-0053, TMl-18-095
Download: ML18283A138 (9)

Text

Michael P. Gallagher Exelon Nuclear Exelon Generation . Vrce Presrdent Lrcense Renewal and 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 TMl-18-095 October 10, 2018 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 Nos. 50-289

Subject:

Supplement to License Amendment Request - Proposed Changes to Technical Specifications Sections 1.0, "Definitions," and 6.0, "Administrative Controls" for Permanently Defueled Condition

References:

1. Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, " License Amendment Request -

Proposed Changes to Technical Specifications Sections 1.0, "Definitions," and 6.0, "Administrative Controls" for Permanently Defueled Condition," dated November 10, 2017 (NRC Accession No. ML17314A024)

2. Letter from U.S. Nuclear Regulatory Commission to Bryan C. Hanson, (Exelon Generation Company, LLC) "Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; James A. Fitzpatrick Nuclear Power Plant; Lasalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; R. E. Ginna Nuclear Power Plant; and Three Mile Island Nuclear Station, Unit 1 - Issuance of Amendments to Relocate the Staff Qualification Requirements (EPID L-2018-LLA-0053) " dated August 2, 2018 (NRC Accession No. ML18206A282)

By letter dated November 10, 2017 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) for the Three Mile Island Nuclear Station, Unit 1 (TMl-1). The LAR proposed to revise or remove certain Technical Specifications (TS) Administrative Controls to reflect the permanently defueled condition.

U.S. Nuclear Regulatory Commission Supplement to TMI License Amendment Request Docket No. 50-289 October 10, 2018 Page 2 On August 2, 2018, the NRG issued Amendment Number 294 (AMO 294) to TMl-1 (Reference 2). The approved amendment revised TS 6.3 to relocate the licensee's staff qualification requirements to the Exelon Quality Assurance Topical Report (QATR). The implementation of AMO 294 altered TS 6.3 from what was originally submitted in Reference 1.

This Supplement is to align TS 6.3 submitted in the LAR (Reference 1) with the now current TS amended through AMO 294. to this letter provides a description of the proposed changes to the TS submitted in Reference 1 in order to reflect the revisions necessitated by the implementation of AMO 294. Attachment 2 contains the markup pages depicting the proposed changes to the TS.

The TS page being submitted in this letter supersedes in entirety the affected page submitted in Reference 1. Attachment 3 contains a regulatory commitment to ensure the Decommissioning Quality Assurance Program (DQAP) appropriately reflects the changes in this LAR.

Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRG in Reference 1. The additional information provided in this submittal does not affect the previously stated bases in Reference 1 for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There is one new regulatory commitment contained within this submittal.

If you have any questions concerning this submittal, please contact Paul Bonnett at (610) 765-5264.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 101h day of October 2018.

Respectfully, Supplement Information for License Amendment Request - Proposed Changes to Technical Specifications Sections 6.0, "Administrative Controls" for Permanently Defueled Condition

2. Markup of Proposed Technical Specifications Pages

3. Summary of Regulatory Commitments cc: w/Attachments Regional Administrator - NRG Region I NRG Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRG Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 NRG Project Manager, NRR -Three Mile Island Nuclear Station Director, Bureau of Radiation Protection - PA Department of Environmental Resources

Attachment 1 Three Mile Island Nuclear Station Docket No. 50-289 Supplement Information for License Amendment Request - Proposed Changes to Technical Specifications Sections 6.0, "Administrative Controls" for Permanently Defueled Condition

License Amendment Request Attachment 1 Supplement to Technical Specifications Section 6.0 Page 1 of 2 Docket No. 50-289 1.0

SUMMARY

DESCRIPTION By letter dated November 10, 2017 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC) for the Three Mile Island Nuclear Station, Unit 1(TMl-1 ). The LAR proposed to revise or remove certain Technical Specifications (TS) Administrative Controls to reflect the permanently defueled condition.

On August 2, 2018, the NRC issued Amendment Number 294 (AMO 294) to TMl-1 (Reference 2). The approved amendment revised TS 6.3 to relocate the licensee's staff qualification requirements to the Exelon Quality Assurance Topical Report (QATR). The implementation of AMO 294 altered TS 6.3 from what was originally submitted in Reference 1.

This Supplement is to align TS 6.3 that was submitted in the LAR (Reference 1) with the now current TS amended through AMO 294. The TS page being submitted in Attachment 2 supersedes in entirety the affected page submitted in Reference 1. Attachment 3 contains a regulatory commitment to ensure the changes in this LAR are appropriately reflected in the Decommissioning Quality Assurance Program (DQAP).

2.0 PROPOSED CHANGE

S The proposed TS revision in Reference 1 stated the following:

6.3 FACILITY STAFF QUALIFICATIONS 6.3.1 Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1 of 1978 for comparable positions unless otherwise noted in the Technical Specifications. Individuals who do not meet ANSI/ANS 3.1 of 1978, Section 4.5, are not considered technicians or maintenance personnel for purposes of determining qualifications but are permitted to perform work for which qualification has been demonstrated.

6.3.2 [No proposed changes]

6.3.3 The NRG-approved training and retraining program for CERTIFIED FUEL HANDLERs shall be maintained.

Approved TS revision in AMO 294 (Reference 2) is as follows:

6.3 UNIT STAFF QUALIFICATIONS 6.3.1 Each member of the unit staff shall meet or exceed the minimum qualifications referenced for comparable positions specified in the Exelon Quality Assurance Topical Report.

[6.3.2 and 6.3.3 were removed by AMO 294 and left blank.]

In order to reflect the revisions necessitated by the implementation of AMO 294 Exelon proposes to revise the TS submitted in Reference 1 to be as follows:

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

License Amendment Request Attachment 1 Supplement to Technical Specifications Section 6.0 Page 2 of 2 Docket No. 50-289 6.3.2 The NRG-approved training and retraining program for CERTIFIED FUEL HANDLERs shall be maintained.

The proposed TS markups are included in Attachment 2. Proposed revisions are shown in bold-italics and deletions are shown using strikethrough. The TS 6.4 and 6.5 remain unchanged from Reference 1 but are included as they are reflected on the marked-up page in Reference 1, . The page included in Attachment 2 is to replace in its entirety the same page as included in Reference 1, Attachment 2.

3.0 REFERENCES

1. Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, " License Amendment Request - Proposed Changes to Technical Specifications Sections 1.0, "Definitions," and 6.0, "Administrative Controls" for Permanently Defueled Condition," dated November 10, 2017 (NRC Accession No. ML17314A024)

2. Letter from U.S. Nuclear Regulatory Commission to Bryan C. Hanson, (Exelon Generation Company, LLC) "Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; James A. Fitzpatrick Nuclear Power Plant; Lasalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Units 1 and 2; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; R. E. Ginna Nuclear Power Plant; and Three Mile Island Nuclear Station, Unit 1 - Issuance of Amendments to Relocate the Staff Qualification Requirements (EPID L-2018-LLA-0053) " dated August 2, 2018 (NRC Accession No. ML18206A282)

Attachment 2 Proposed Technical Specifications (Marked-Up Pages)

6.3 YM+FAC/LITYSTAFF QUALIFICATIONS 6.3.1 Each member of the t!M-facility staff shall meet or exceed the minimum qualifications referenced for comparable positions specified in the Exelon Decommissioning Quality Assurance ProgramTopisal Report.

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

6.4 TRAINING DELETED 6.4.1 A training program for tho Firo Brigade shall be maintained and shall moot or mmood tho roquiromonts of Sostion 600 of tho NFPA Godo.

6.5 DELETED 6-d2 (Pages 6-3 through 6-81 O deleted)

Amendment Nos. 11,22,32,55,77,84 ,92,99,128,129,131,132,139,141,149,159,171,179,195,198, 207,212,218,239,241,252, 265, 269, 280, 294

Attachment 3 Summary of Regulatory Commitments

Summary of Regulatory Commitments The following table identifies commitments made in this document.

(Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

Commitment Type Committed Date Commitment or "Outage" One-Time Programmatic Action (Yes/No)

(Yes/No)

Per Amendment 294, the Prior to Yes No Staff Qualification implementation requirements were relocated of this License from TS 6.3 to the Quality Amendment.

Assurance Topical Report.

Consistent with Amendment 294, the Staff Qualification wording from TS 6.3.1 and 6.3.2 in the proposed LAR (License Amendment Request- Proposed Changes to Technical Specifications Section 1.0, "Definitions," and 6.0, "Administrative Controls," for Permanently Defueled Condition," dated November 10, 2017 (ADAMS No ML17314A024)) will be relocated to the DQAP.