ML15204A843

License Amendment Request -Temporary Restoration of Borated Water Storage Tank Cleanup and Recirculation Operation

ML15204A843
Person / Time
Site:	Crane
Issue date:	07/23/2015
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TMl-15-071
Download: ML15204A843 (131)

Text

Exelon 200 O O U.S. Nuclear Regulatory Commission LAR - Temporary Restoration of the Borated Water Storage Tank Cleanup and Recirculation Operation July 23, 2015 Page 3bcc: Sr. Vice President, Mid-Atlantic Operations w/o attachments Sr. Vice President, Engineering and Technical Services " Site Vice President - TMI " Plant Manager - TMI " Director, Operations - TMI " Director, Engineering - TMI " Director, Corporate Plant Engineering - Cantera " Manager, Regulatory Assurance - TMI " Manager, Licensing - KSA " Commitment Coordinator - KSA w/attachments Records Management - KSA " P. A. Bennett - TMI " H. C. Crawford - TMI " M. D. Fitzwater - TM " R. H. Freeman - TMI " S. J. Huddleston - TMI " G. P. McCarty - TMI " W. McSorley - TMI " J. J. Piazza - TMI " L. E. Ritz - TMI "

EVALUATION OF PROPOSED TECHNICAL SPECIFICATION CHANGES

SUBJECT:

License Amendment Request - Temporary Restoration of the Borated Water Storage Tank (BWST) Cleanup and Recirculation Operation CONTENTS

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

License Amendment Request - Temporary Restoration of Borated Water Storage Tank (BWST) Cleanup and Recirculation Operation This evaluation supports a request to amend Renewed Facility Operating License No. DPR-50 for Three Mile Island Nuclear Station, Unit 1 (TMI).

Exelon Generation Company, LLC (Exelon) requests NRC approval for temporary operations to clean up the water in the BWST and perform weekly boron surveillance tests while questions about the adequacy of the seismic design of the cleanup and recirculation piping paths are being resolved under a Technical Interface Agreement, TIA 2015-01, "Request for Technical Assistance Regarding Three Mile Island Licensing Bases and Acceptability to Use a Non-Seismic Qualified Cleanup Path for the Borated Water Storage Tank" (Reference 1). This License Amendment Request (LAR) is required to support the pre and post Fall 2015 Refueling Outage activities and Fuel Cycle 21 operation. The BWST water inventory is used as a clean source of borated water to support fuel transfer activities. The request is a temporary proposal to allow sufficient time for Exelon to identify the most optimal approach to permanently resolve the issue. Depending upon the outcome of the TIA 2015-01, several options are currently being evaluated with the intent to resolve the issue by the end of the temporary period requested (start of Fuel Cycle 22 operation).

Specifically, Exelon proposes to perform BWST cleanup using the same method that has been used historically at TMI, for a total duration of not more than 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> (30 days) prior to the scheduled start of the TMI Fall 2015 Refueling Outage and for a total duration of not more than 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> (60 days) during Fuel Cycle 21 operation.

In addition, Exelon proposes to use the BWST recirculation path for the performance of the weekly (and after each makeup) BWST boron concentration surveillance testing required by TS Table 4.1-3 Item 2. Currently, the weekly test involves entering a 72-hour Limiting Condition for Operation (LCO) action to use one of the Emergency Core Cooling System (ECCS) pumps to provide adequate BWST recirculation for boron sampling. This ECCS sampling path is a work around to avoid using the previous sampling path that involved seismic Class II piping. Using the BWST recirculation path for surveillance testing is expected to take approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />

per week.

The justification for temporary restoration of the BWST Cleanup and Recirculation operation is based on additional design and administrative controls. A seismic evaluation has been performed that concluded the Cleanup and Recirculation seismic Class II piping paths would maintain pressure boundary integrity during a Safe Shutdown Earthquake (SSE). The seismic Class I BWST would maintain its safety functions during an SSE. In addition, administrative controls using proceduralized operator manual action provide additional defense-in-depth actions during a seismic event.

Exelon requests approval of the proposed amendment by September 25, 2015, in order to support necessary pre-outage clean-up activities for the TMI Fall 2015 Refueling Outage. Once approved, the amendment shall be implemented immediately.

Technical Specification (TS) Change

TS 3.3.1 states:

"3.3.1 The reactor shall not be made critical unless the following conditions are met:

3.3.1.1 Injection Systems a. The borated water storage tank (BWST) shall contain a minimum of 350,000 gallons of water having a minimum concentration of 2,500 ppm boron at a temperature not less than 40°F. If the boron concentration or water temperature is not within limits, restore the BWST to OPERABLE within 8 hrs. If the BWST volume is not within limits, restore the BWST to OPERABLE within one hour. Specification 3.0.1 applies."

The proposed change will revise Technical Specification (TS) 3.3.1.1, "Injection Systems," by adding the following Note to TS 3.3.1.1.a. for the BWST:

Note:

TS Bases Change (for NRC information only)

The BWST can be placed on cleanup path, or recirculation path for weekly surveillance testing for boron concentration, on a temporary basis, until the end of the Fuel Cycle 21 operation. A seismic evaluation has been performed that concluded the cleanup and recirculation seismic Class II piping paths would maintain pressure boundary integrity during a Safe Shutdown Earthquake (SSE). The seismic Class I BWST would maintain its safety functions during an SSE. The limiting condition for operation (LCO) for BWST cleanup operation is a total duration of not more than 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> (30 days) prior to Fall 2015 Refueling Outage and is a total duration of not more than 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> (60 days) during Fuel Cycle 21 operation. BWST Cleanup can be started and stopped at any time as long as the total durations are not exceeded. The LCO for BWST Recirculation operation is limited to the time it takes to adequately recirculate the BWST volume to perform the boron sampling surveillance, which is approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> per week.

The temporary LCOs are in effect to allow time for a permanent solution to the issue of interconnecting seismic Class I and II piping during BWST Cleanup and Recirculation operation.

NOTE: 1. The BWST piping may be unisolated from seismic Class II Cleanup path piping for a total duration of not more than 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> prior to the scheduled start of the Fall 2015 Refueling Outage and for a total duration of not more than 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> during the following Fuel Cycle 21 operation under administrative and design controls for filtration and/or demineralization of the tank contents.

2. The BWST piping may be unisolated from seismic Class II Recirculation path piping to perform weekly (and after each makeup) BWST boron concentration surveillance testing until the end of Fuel Cycle 21 operation.

BWST Cleanup Operation Background The BWST contains greater than 350,000 gallons of water with a boron concentration above 2500 ppm. The BWST has design functions to provide the source for High Pressure Injection (HPI), Low Pressure Injection (LPI) and Reactor Building Spray (BS) systems, to provide an emergency boration water source, to provide the water volume to fill the refueling transfer canal and to provide reactor coolant system makeup water during cooldown.

Historically, TMI was periodically using its Spent Fuel Pool (SF) and Liquid Waste Disposal (WDL) systems to filter and demineralize the BWST water while in plant conditions and modes for which the BWST was required to be operable. See Attachment 3 for simplified flow diagrams of the BWST connected to the SF and WDL systems for filtration/demineralization. It was believed that this system alignment could render the BWST inoperable during a seismic event since WDL piping, filters, and demineralizers are not seismically-qualified to seismic Class I. This was the original design of the plant; TMI was designed before 10CFR50 Appendix A, GDC 2,Design bases for protection against natural phenomena," set a more conservative standard requiring additional seismically-designed piping at U.S. plants.

During resolution of GL 87-02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46," TMI evaluated the BWST Cleanup alignment and concluded that there was seismic adequacy of the system configuration, using administrative procedure controls and operated in this manner until

Information Notice (IN) 2012-01, "Seismic Consideration-Principally Issues Involving Tanks," was issued on January 26, 2012. Cleanup operation resumed after evaluation of IN 2012-01 and stopped after receiving a violation in May 2014 (Reference 2). Historically, isotopic concentrations in the BWST have fluctuated in accordance with outage activities, and subsequent to the NRC violation, they have ris en and are currently approximately one thousand times normal concentrations.

There are current procedures to respond to seismic events at the TMI site which address BWST Cleanup operation. Marked-up TMI procedure OP-TM-AOP-003, "Earthquake," (Attachment 6) requires that the control room operators ensure that the BWST is isolated from Cleanup operation through the WDL system if a seismic event occurs. Marked-up TMI procedure OP-TM-AOP-0031, "Earthquake Basis Document," (Attachment 7) provides a list of design or licensing basis requirements and earthquake mitigating strategies including isolating BWST Cleanup during a seismic event.

TMI's BWST is normally maintained with greater than 350,000 gallons and with a boron concentration of greater than 2500 ppm Boron. These are TS requirements under T.S. 3.3.1.1.

In addition, two BWST level instruments are required to be operable under T.S. 3.3.1.1. These two instruments, DH-LT-0808 and -0809, alarm if the BWST level increases to greater than 57.5 feet or decreases to less than 56.2 feet. These instruments would provide indication to the Control Room operators if a failure of a seismic Class II WDL system component resulted in a loss of BWST inventory.

The EPRI , in Appendix B.6, describe the requirements for plants to maintain their BWST chemistries, and also describes experience at plants where BWST water adversely affected plant operations. TMI has committed to comply with these EPRI Guidelines (for example, as conditions of its License Renewal Process and Steam Generator Program). TMI Procedure, CY-AP-120-170, "Refueling Water Storage Tank, Borated Water Storage Tank, Safety Injection Refueling Water Tank,"

describes the current chemistry analyses, limits, and analysis frequencies for water in the BWST.

The BWST is cleaned periodically for a number of reasons. While the plant operates, the BWST is required to be operable to maintain a borated water supply for accident mitigation purposes. Cleaning the contents of the tank minimizes the radiological dose rates to workers working near the tank. The contents of the BWST are used to flood the Fuel Transfer Canal during refueling outages. The BWST water during refueling outages is then intermingled with water from the Reactor Vessel, the Spent Fuel Pool, and the Fuel Transfer Canal. Cleaning the BWST contents prior to and post refueling outages helps to ensure that the optical clarity of the refueling water is maintained, and also minimizes the dose rates for workers in the area of the refueling water (i.e., above the Reactor Vessel, Fuel Transfer Canal, or Spent Fuel Pools). Based on the current isotopic level of Cobalt-58, and absent significant shielding modifications, if the BWST is not cleaned up, estimated dose to the refuel workers is between 3 Rem - 4 Rem compared to 1 Rem last outage. The dose impact to the Reactor Vessel 10-Year Inservice Inspection (ISI) workers is an additional 2 - 3 Rem. A lack of BWST cleanup will also add approximately 1 - 2 Rem of additional exposure to workers outside the Reactor Building in the yard area, while loading and unloading outage equipment.

BWST Cleanup and Recirculation Operation

Refer to Attachment 3, Flow Diagrams for BWST Cleanup and Recirculation operation, for the following discussion.

The BWST (shown on P&ID 302-640) is classified as a seismic Class I Engineered Safeguards System and serves as a source of emergency borated cooling water for HPI, LPI and BS systems. The BWST water inventory is normally used to fill the refueling transfer canal for refueling operations.

The WDL System (shown on P&ID 302-691) provides operating service functions to the reactor coolant system and spent fuel pools in addition to the collection, containment, and processing of miscellaneous wastes for reuse or disposal. The piping is designed to seismic Class II and is contained in a seismic Class I building.

In addition, interfacing seismic Class I piping of the SF system (shown on P&ID 302-630) is used to connect the BWST and WDL systems. The seismic Class I boundary manual valves, SF-V-40 (SF-P-2 Discharge Isolation Valve to LWDS System) and SF-V-43 (LWDS To Spent Fuel System Isolation Valve) can be used to isolate the seismic Class I and Class II systems.

When the BWST is aligned for Cleanup operation per procedure OP-TM-212-501 (Attachment 5) the water flows out of the BWST 8-inch line through the seismic Class I SF piping to the SF-P-2, Borated Water Recirculation Pump. SF-P-2 pumps the BWST water through seismic Class I boundary manual valve, SF-V-40, where the piping transitions to WDL seismic Class II 3-inch piping. Although several WDL cleanup configurations are possible, typically the BWST water is first routed through the WDL-F-1A, Precoat Filter, and then through the two Cation Demineralizers, WDL-K-2A and 2B. The filtered water is returned from the Demineralizers via 3-inch WDL piping through seismic Class I boundary manual valve, SF-V-43, to seismic Class I SF 4-inch piping back to the BWST.

When the BWST is aligned for Recirculation operation per OP-TM-212-252 (Attachment 9), it uses essentially the same path as cleanup as described above, except the Cation Demineralizers are bypassed. After approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of recirculating the BWST water, the BWST weekly surveillance sample can be taken by opening DH-V-31 and DH-V-153.

The piping and components of the WDL systems used for BWST Cleanup and Recirculation operation have no accident mitigation purposes and accordingly are designed to seismic Class II requirements. The WDL system design compli es with Regulatory Guide 1.143 requirements.

Piping and Piping Support Seismic Analysis A technical evaluation (Attachment 4) was completed for the subject Seismic Class II piping in the WDL system used for the BWST Cleanup and Recirculation operation. Class II structures, components, and systems are important to reactor operation but not essential to safe shutdown and isolation of the reactor and whose failure could not result in the release of substantial amounts of radioactivity. Those structures, components, and systems, including instruments and controls, whose failure might cause or increase the severity of a loss of coolant accident or result in an uncontrolled release of radioactivity, and those structures and components which are vital to safe shutdown and isolation of the reactor are designated Class I.

The technical evaluation provided a seismic evaluation of the existing, as installed, WDL cleanup and recirculation piping, including pipe stress and pipe support structural capacity. It evaluated the current Seismic Class II (Operating Basis Earthquake (OBE)) piping and supports' response to Seismic Class I (Safe Shutdown Earthquake (SSE)) event. An SSE earthquake subjects the plant to accelerations twice that of an OBE. The piping system in question must withstand an SSE without loss of pressure boundary integrity. The technical evaluation was not intended to support a permanent design change. The technical evaluation provided the basis for reassurance to support the limited period time TS LCO (approximately September 2015 - September 2017). The seismic evaluation concluded that the seismic Class II piping would maintain pressure boundary integrity during an SSE.

The piping stress analysis concluded that the maximum piping stresses are below their respective allowables and are acceptable. The maximum seismic displacements are within the analysis boundary, and less than one inch, and are acceptable. The maximum valve accelerations of all subject valves are less than 1g and are acceptable. The equipment nozzle loads are within the analysis boundary and are acceptable. All pipe supports evaluated were determined to be structurally adequate for the applied loads. In summary, the qualifications of all associated piping stresses, valve accelerations, pipe seismic displacements, equipment nozzle loads and pipe support loads, as documented in more detail in the attached technical evaluation, demonstrate that liquid radwaste piping (WDL) used for cleanup or recirculation of the BWST will withstand an SSE without loss of pressure boundary integrity. Should the site experience an SSE during BWST Cleanup or Recirculation operation, it is expected that there will be no leakage in the interconnected WDL system and piping, and the BWST will remain operable throughout the seismic event.

Defense in Depth-Isolating BWST Cleanup during a Seismic Event

As an additional defense-in-depth measure during an SSE or OBE seismic event, to support this temporary period of recirculation and cleanup of the BWST during on-line operation, current administrative actions through established procedures require the timely removal of the BWST from Cleanup or Recirculation operation. Should a seismic event occur, during BWST Cleanup or Recirculation operation, the Control Room Supervisor will implement a step in OP-TM-AOP-003, directing the BWST be taken off of Cleanup or Recirculation operation, thereby isolating the BWST from seismic Class II piping. The proposed changes to the existing operation procedures provides additional assurance that the isolation of the BWST from the Class II piping is given very high priority among a list of operator actions immediately following ground motion felt by station personnel. The manual seismic Class I boundary valves SF-V-40, SF-V-43 will be closed and SF-P-2 pump will be secured, after ground motion is detected, and is not dependent on confirmation if an OBE or SSE level acceleration were reached. As an additional line of defense against boundary valve failures, double valve isolation is provided by also closing seismic Class I manual valves, SF-V-20 and SF-V-45, which are in series with the boundary

isolation valves.

The use of defense-in-depth administrative actions would be limited to 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of BWST Cleanup operation and approximately 150 hours0.00174 days <br />0.0417 hours <br />2.480159e-4 weeks <br />5.7075e-5 months <br /> of BWST Recirculation operation for Fuel Cycle 20 and 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> of Cleanup operation and approximately 3000 hours0.0347 days <br />0.833 hours <br />0.00496 weeks <br />0.00114 months <br /> of BWST Recirculation operation in Fuel Cycle 21.

An operating experience and precedence review for BWST Cleanup operation indicated that Farley and Indian Point Nuclear Stations (See Section 4.2, Precedent) used only administrative controls, via license amendments, for a limited period during on-line operation for cleanup of their Refuel Water Storage Tanks (RWST). No negative trends or significant operating events were identified.

Since removing the BWST from Cleanup or Recirculation operation are not new actions for TMI operators, functional requirement analysis and function allocation are not necessary. Prior experience has shown that operators, when assigned this task under non-transient daily plant operations that are not part of the AOP or EOP procedures, had sufficient time and resources available to perform it reliably for approximately 40 years. Staffing and operator qualification are not affected by the proposed LAR. No new or additional operators are required, nor are there any new or additional qualifications or training required to perform the action sequence required to isolate the BWST from Cleanup or Recirculation operation.

==

Conclusion:==

A combination of interim design controls (interim seismic evaluation) and administrative controls (isolating BWST Cleanup or Recirculation operation during seismic event) ensures that interconnected seismic Class II WDL systems used during BWST Cleanup or Recirculation operation will not impact the operability and safety functions of the BWST during normal plant operation, should an OBE or SSE occur.

4.1 APPLICABLE

REGULATORY REQUIREMENTS/CRITERIA The proposed changes have been evaluated to determine whether applicable regulations and requirements continue to be met. Exelon has determined that the proposed changes do not require any exemptions or relief from regulatory requirements. Note that TMI was designed and constructed taking into consideration the general design criteria for nuclear power plant construction permits as listed in the proposed AEC General Design Criteria, dated July 1967.

The following current applicable regulations and regulatory requirements were reviewed in making this determination:

10 CFR 50, Appendix A, General Design Criteria Criterion 2, "Design bases for protection against natural phenomena," requires TMI meets the following Atomic Energy Commission (AEC) GDC 2 - Performance Standards (Category A):

Note that TMI is a USI A-46 plant and current licensing and design basis does not require the plant be designed for concurrent LOCA and SSE events.

The filtration/demineralization of the seismic BWST will use the seismic piping meeting the AEC GDC 2 criterion but will also use the non-seismic WDL piping which does not meet the Appendix A GDC 2 criterion. Thirty days prior to the scheduled start of the Fall 2015 Refuel Outage, and for 60 days during the following Fuel Cycle 21, and for approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> per weekly BWST boron surveillance testing, operation of BWST Cleanup and Recirculation paths will use interim compensatory design and administrative controls to assure operability of the BWST during an SSE.

Criterion 35, "Emergency core cooling," requires

Under this proposed LAR, the BWST will maintain its operability during an SSE. The plant will continue to meet Criterion 35 by using proven procedures and design features in place for the past 40 years coupled with additional interim design analysis and administrative controls for BWST Cleanup or Recirculation isolation that will ensure the BWST maintains its safety related functions.

10CFR50.36(c)(2)(ii)(b) Criterion 3

Criterion 3 requires

The use of interim design controls and operator action to isolate the BWST to maintain seismic qualification and operability of the BWST while in Cleanup or Recirculation operation requires a limiting condition for operation. This LAR provides for a total time of 90 days of BWST Cleanup operation on-line to support pre 2015 Fall Refueling Outage activities and Fuel Cycle 21 operation. In addition, this LAR provides approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of BWST Recirculation operation per test to support the weekly BWST boron sampling surveillance requirement to the end of the Fuel Cycle 21 operation.

Relevant Guidance:

Regulatory Guide 1.143, "Design Guide for Radiological Waste Management Systems, Structures, and Components Installed in Light-Water-Cooled Nuclear Power Plants" The WDL design complies with RG 1.143, Rev 1, dated October 1979, requirements.

Generic Letter 87-02, "Verification of Seismic Adequacy of Mechanical and Electrical Equipment in Operating Reactors, Unresolved Safety Issue (USI) A-46," dated February 19, 1987

Information Notice (IN) 2012-01, "Seismic Considerations -Principally Issues Involving Tanks," dated January 26, 2012

NUREG-1764, "Guidance for the Review of Changes to Human Action," Rev 1

The U.S. Nuclear Regulatory Commission (NRC) reviews changes in human actions, such as those that are credited in nuclear power plant safety analyses. This document provides guidance for reviewing those changes. This LAR provides a qualitative assessment that addresses several applicable factors such as operating experience review, task analysis, staffing, and procedure design.

4.2 PRECEDENT

License Amendment No. 309 for TMI Amendment Re: Exigent Technical Specification Change Request No. 309, Nuclear Services River Water System (TAC NO. MB1187), dated February

23, 2001 (ML010570083).

This amendment allowed a one-time except ion to the system configuration and maintenance requirements in Technical Specification (TS) 3.3.2 related to the nuclear service river water (NR) system at TMI, in order to allow a proposed up to 14-day repair of a leaking underground concrete pipe. The requirements of TS 3.3.1.4 to have two NR pumps OPERABLE were unchanged. During the 14-day repair period, the NR pumps' flows were realigned to pass through a portion of the non-seismic secondary services river water system.

License Amendment No. 250 for Indian Point Nuclear Generating Station Unit No. 3, Issuance of Amendment re: Connecting Non-seismic Purification System Piping to the Refueling Water Storage Tank (TAC No. ME9263), dated February 22, 2013 (ML13046A166)

This amendment revised TS 3.5.4, "Refueling Water Storage Tank," to permit non-seismically qualified piping of the Spent Fuel Pool purification system to be connected to the Refueling Water Storage Tank seismic piping under administrative controls for a limited period of time in order to purify the contents of the Refueling Water Storage Tank.

License Amendment Nos. 188 and 183 to Joseph M. Farley Nuclear Plant (FNP), Units 1 and 2, respectively, Issuance of Amendments Regarding Refueling Water Storage Tank (TAC NOS. ME8005 AND ME8006), dated March 24, 2012 (ML120730610)

These amendments revised the FNP TS 3.5.4, "Refueling Water Storage Tank," to permit the use of a seismically qualified boundary valve under administrative controls for limited periods of time.

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 use of the Liquid Waste Disposal System (WDL) and the Spent Fuel Pool Cooling System (SF) to re-circulate and cleanup the BWST contents does not involve any changes or create any new interfaces with the reactor coolant system. Therefore, the connection of the WDL and SF to the BWST would not affect the probability of Large and Small Break Loss of Coolant Accidents occurring. The WDL and the applicable components of the SF are not credited for safe shutdown of the plant or accident mitigation. A technical evaluation was performed to validate the seismic adequacy of the

WDL piping to withstand a Safe Shutdown Earthquake (SSE). The evaluation determined sufficient margin exists in the installed piping and supports such that during an SSE, the WDL system and piping would not lose pressure boundary integrity. In addition, as additional defense-in-depth measure, administrative controls ensure that the BWST can be isolated from seismic Class II WDL piping following an SSE. Since the BWST will continue to perform its safety functions and overall system performance is not affected, the consequences of an accident are not increased.

Therefore, the proposed change 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 design of the BWST, WDL and SF systems to allow recirculation and filtration / demineralization has not been altered. No procedure changes are required to start or end BWST Cleanup or Recirculation operation. Since the seismic adequacy of the interconnected WDL system and piping has been evaluated for an SSE and validated by calculations to maintain pressure boundary integrity, the BWST safety functions are not affected.

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 WDL and applicable components of the SF are not credited for safe shutdown of the plant or accident mitigation. The seismic adequacy of the BWST is maintained. The seismic evaluation determined that sufficient margin exists in the installed piping and supports such that during an SSE, the seismic Class II WDL system and piping would not lose pressure boundary integrity. Maximum piping and piping support stresses are below their respective allowables, are acceptable, and no pipe leakage will occur.

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.

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 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.

1. NRC Internal Memorandum from Michael L. Scott, Deputy Director, Division of Reactor Projects - Division I to Mirela Gavrilas, Deputy Director, Division of Policy and Rulemaking, NRR, "Request for Technical Assistance Regarding Three Mile Island Licensing Bases and Acceptability to Use a Non-Seismic Qualified Cleanup Path for the Borated Water Storage Tank (TIA 2015-01)," dated April 10, 2015

2. Three Mile Island Station, Unit 1 - NRC Integrated Inspection Report 5000289/2014002, dated May 14, 2014

NOTE: . 1 The BWST i in may be unisolated from seismic Class 11 Cleanup path piping for a total duration of not more than 720. hours pnor to the *scheduled

f the Fall 2015 Refueling outage and for a total duration of not more than 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> during the following Fuel Cycle 21 operation under administrative and design controls for filtration

.and/or dem1nerahzat1on of the tank contents. k ) BWST 2.The BWST piping may be unisolated from seismic Class II Recirculation path. piping to perform weekly (and after each ma eup ' boron concentration surveillance testing until the end of Fuel Cycle 21 operation.

• 3.3 REACTOR BUILDING SPRAY Applicability Applies to the operating status of the emerge cy core cooling, reactor building emergency cooling, and reactor building spray systems. Objective To define the conditions necessary to assure immediate availability of the emergency core cooling, reactor building emergency cooling nd reactor building spray systems. Specification 3.3.1 The reactor shall not be made critic unless the following conditions are met: 3.3.1.1 Injection Systems a. The borated water storage tank (BWST) shall contain a minimum of 350,000 gallons of water having a minimum con entration of 2,500 ppm boron at a temperature not less than 40°F. If the boron co centration or water temperature is not within limits, restore the BWST to OPERAS E within 8 hrs. If the BWST volume is not within limits, restore the BWST to OP. RABLE within one hour. Specification 3.0.1 applies. b . c. d. e. f. g. Two Makeup and Purification (MU)/High Pressure Injection (HPI) pumps are OPERABLE in the engineered safeguards mode powered from independent essential buses. Specification 3.0.1 applies. Two dE!cay heat removal pumps are OPERABLE.

Specification 3.0.1 applies. Two decay heat removal coolers and their cooling water supplies are OPERABLE. (See Specification 3.3.1.4) Specification 3.0.1 applies. Two BWST level instrument channels are OPERABLE.

The two reactor building sump isolation valves (DH-V-6A/B) shall be manually OPERABLE.

Specification 3.0.1 applies. MU Tank (MUT) pressure and level shall be maintained within the Unrestricted Operating Region of Figure 3.3-1. 1) With MUT conditions outside of the Unrestricted Operating Region of Figure 3.3-1, restore MUT pressure and level to within the Unrestricted Operating Region within 72 hrs. Specification 3.0.1 applies. 2) Operation with MUT conditions within the Prohibited Region of Figure 3.3-1 is prohibited.

Specification 3.0.1 applies. 3.3.1.2 Core Flooding System a. Two core flooding tanks (CFTs) each containing 940 +/- 30 ft 3 of borated water at 600 +/- 25 psig shall be available.

Specification 3.0.1 applies. 3-21 Amendment No. 21, 98,178, 203, 211, 229, 227 278 GorFOsteel by letter dtd July 8, 1999

c 8 302-711 8-4 302-711 8-6 302-690 H-5 302-650 G-6 302-690 H-5 2500-4 302-651 D-3 LINER FOR CONT.

302-713 7 !310 lEST E.D. 320Sj ,! J/4"1 1/2" J 14" P-352 VALVE GUARD P-354 6 14* SCH 10 5 3" 4" jii LJFE\

1/2" OD 4 5938 1 3 1/2" 302-671 (F-6) 2 6" 2'

---12-" **

O" !

14" 1/2

14" TO BED PLATE 1 .. Lou1cK 12"

-;:i;-iii"-.__

302-630 0-1 D D

3)

DETECTOR FC 1/2" IN THE

4.

I 5.

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1/2" 1-81 3/4" L..J

3) 3/4' 3/4' FC 1" 302-670 E-9 14" 04 10" 24" 6" ,. 1 302-661 A-4 302-661 A-2 3/4" DRAIN "

A c 7 TAGGED VALVE D,. 8 O LO FlJEL TRANSFER CANA 6 .. .. .. .. TUBES \ ! SF-V73 1 SF-V24 8 .. o.-o--ED { ISO l}---j l-s1 4 .. 8 .. 6 5 4 3 2 OESCRIPT 1 0N (4" SF-V26 .w ..

8 .. !s1 sF-4 .. / , .. r:::J 4 ,, .. r:::; ,, .. r:::; Ir r:::; SIPHON /'

____ ,.4_ ..

BREAK"'-WEST SIOE (OUTLETS)

,_,-... .. .W. "" r*

SF-V38 4 .. BYS R l ll SF-V27 1/2 .. 4 .. 4" T .w .. 8.. SF-V50

.... sF-v34 4 ..

... 4" TE 798 4" 4 .. c---@ Sf9 2 SF-V2B 1 8 .. ... 4" 4 .. ""<:::) 4 .. ... TE 799 c-@

CASK 20.000 GAL ELEV 303'-6" 4 .. y, 1/2" 8 ..

Gp Si.J. sr-vszI 8 .. 8 .. .. ;SF V47 1/4 .. 4.. & 4" SF-V68'ff:-302 669 (E 3/*j_ "-----'----,8..

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SF-V78 S F-V 8 ..

w 1-,.. ,.r_. ;, Sl S F-V53 ________ ef-.::!_67_ _ _ _ _ _ _ _

TYP SF-V60 OWG

L sF-V62 '.-C-' -... SF-VlO 4" ,. SF-v;;_RVl

,-= 4:"TORAGE TANK 4' I J02-670 (O J) TO F0 SF-V69 SF-V71 (). 4.. TO OECAY HEAT 3/8" .'+'.. 3 '4.. ) SF-V44 J PUMP .. A. SUCTION 7 )3" S-1 SF-Vs 6 SF-\16 1 3/4j_ 8.. 8.. -1/--ls __ ,,,, .. "

...........

3 .. SF-V4 1 8 ..

LWO

-302 691 S-1 EL 323'-6.. -F9 FE1 8 ..

l SF-v21 sf-v11 J sF-vss lsF-v161 1 SF-v3s ,

.\.J.J. Fil 3 .. TO LWO CLEANUP c 8 SF-V80 SF-V70 ... -...

s F-vla SF-V19 8 .. -( .302 640 F-2 7 TO sF-v37 sF-v49

4.

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ll*llS G-8 302-692 302-669 (E-3) 2 1/2" 302-690 C-8 2* ($! /2" 1 1/2" 2* 2" 1 1/2" S-11 S-11 11/2" ...

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2 1/2" ,. 2 , 1/2" 2" 1 1/2" .. 1 1/2" t--@ 11/2"321 1* 2" 6 302-690 D-8 l/2" 302-669 FROM WDL-V 2 302-690 E-6 2 1 302-690 C-7 1 1/2" FILTER 3" 302-692 H-7

/2' E-3 1 1 1 1 2" l 1 2* 1 1/2" t--..--1;2* Ynf.

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2" 302-003 302-002 3 y 2" 1 1/4 1 2" 12 4 WO mu 1 1 2" 302-692 C-10 302-660 F-10 302-690 A-3 302-670 D-8 Am G er en 2 TM l-1 302-691 G c

PAGE 0001 E C R Printout NUMBER: --'Ž-15*00252 000 ECR TYPE: EEC ASSIGNED ORG: TEDM PRINT DATE/TIME:

06L24Lls 13:43 ASSIGNED INDV: ZEPPOS,VP REQUIRED DATE: 01Lo2L1s INITIATOR:

ZEPPOS ECR STATUS: APPVD REQUEST ORG: TED STATUS DATE: 06L24[1s A/R NO: A2258102 INIT. DATE: 06L16Lls PROJECT NO: ----A/R STATUS: ASIGND A/R

SUBJECT:

TECHNICAL EVALUATION TO ASSESS BWST CLEANUP PATH PIPE STRESS A. IDENTIFICATION:

SYSTEM: 212 COMP ID:_TM_ _1_ 212 _lL _T ........ K....__ __ D=-'H--....._-T;;;;.__;-1=---------

INIT OPER: QA CLASS: POTL REPT: _N._ TECH SPEC: _ REQD IN MODES: PAGES ATTACHED:

_L NO. OF PAGES: 737 ID/DATE: DRYO 06/24/15 PROBLEM DESCRIPTION and PROPOSED DISPOSITION:

THIS TECHNICAL EVALUATION SUPPORTS RESOLUTION OF IR 2506588. IR 2506588 TRACKS ACTIONS FOR THE TEMPORARY RESTORATION OF THE BWST CLEANUP FLOWPATH WHILE ONLINE. SPECIFICALLY IR 2505688-26 IDENTIFIES THE NEED FOR A TECh'NICAL EVALUTION

'I1HAT DEMONSTRATES

'rI-IE BWST CLEAN-UP PIPING AS BEING CAPABLE OF wrrHSTANDING AN SSE wrrHOUT LOSS OF PRESSURE BOUND1'_RY IN'rEGRITY.

B. EVALUATION:

50.59 REVIEW REQD: _£L ORIG 50.59 REVIEW AFFECTED:

_N_ 50.59 SE REQD: _lL REPORTABLE:

_N__ DATE/TIME:

STATION PROC/PROGRAM REVIEW COMP.LT:

CAUSE: I -------FINAL OPERABILI'I1Y:

COMP: Y SYSTEM: Y PLANT: _l SSV SSV DATE/TIME-;-

_____ SCHED CODE/WINDW:

232 VPZO 08/25/10 ADVANCED WORK AU 1 rH: __N_ FINAL DISP: ..JI.8..._

INTERIM DISP: UA APPROVED DISPOSITION:

THIS TECHNICAL EVALUATION IS PROCESSED PER CC-AA-309-101, "ENGINEERING TECHNICAL EVALUA'rIONS 11* PER SECTION 1. 2. 4, rl'ECHNICAL EVALt.JA'l1IONS SHALL BE USED FOR: RESPOl\TS.ES

• ro QUES'.PIONS ON ISSUES WHERE A TECHNICAL INTERPORETA'rION I rrECHNICAI.J EVALAUTION I OR TECHNICAL GUIDANCE IS NEEDED, REGARDLESS OF DISCIPLINE.

11 E C R Printout:

ECR NUMBER: J-5 -0 0 2 5 2 Q_Q_Q *-E CR 'l'Y PE : .......

IND. DESIGN REVIEW COMMENTS:

I HAVE l*-'L:fffOHl\'iE:D i\.N Ol*lNER i\CCEPTANCE:

PEP /\t\* l03 .1..003.

HEEN PROVTDi:*.:D TO Trn*:

TO i\SSESS PT.PINC rN'ITCW1 TY F\_m 1 l 1 H.J.:S TECHNICl\L E'Ji\LUA'.l'.I ON Al-U-: .I.NC.LUD1:: PRECOA'l' THJ:; CAT.TON IHU\W I Li\ls i\i.)EQUt\li'l*:LY BOUND't: .. RY 1.NT:::G1UTY AN SSE. 'l'HIS TECifl\JICt\L EVi\LUi\T'ION IS A::iSI<SSED AS i\PPROlYJUA'l1E t.3i\SED GN CC-f\i\ 309 101 SSCTION

'T1Hl\'1' NOT THE DCSIGN UF T!lf; .i\l'D TO lt-JHICH THIS CONCLUSION. m"n\JER.'

s

rnv.r Al\* 1()1 I

1 A[JD 1 LY. PIP!*:

FCH '['li.l.:3 A.Rl*:

11TllE AND CONCLUSTOJ\1S CH' TETS TECHNICAL EVi.\LUA'l' IUN

'JTfF:

DEMONS'.l'.H.i\T

µ El*.:v:u:*:W COMPlil*:TE.

A TECl-1NTC!\L EVALUATION PE!{ !

VEHICLE TU: >JOH.K .] s 'tl*:CHl\JTCi\LLY i\.ND PROCEDlJHAl.,LY

/\Cc:lrn:\TE AND Al1li POHATl<D.

C. DOCUMENT CHANGES:

PAGE 0002 E C R Printout ECR NUMBER:

000 ECR TYPE:

D .. APPROVALS:

Name INTERFACING GROUPS: AECOM CREATED THIS DOCUMENT SEE TECH EVAL FOR SIGNAGE FROM VENDOR CAQ: __ ISSUE NBR: RESP ENGINEER:

ZEPPOS,VP (MECHANICAL OAR) IND REVIEWER:

YERKES,DR (CIVIL/STRUC OAR) MANAGER: BENNETT I p. A. ( TMI ENGR MGR) . E. ECR WORK COMPLETION NOTIFICATION:

WORK REQUIRED:

_:j__ AUTO CLOSE: _N_ VPZO FILM ID: BLIP BOX NBR: A2258102 ACCEPT 06/18/15 User ID VPZO VPZO VPZO VPZO DRYO PABO DESC: ENSURE EEC 15-00252 DOES NOT GO TO HISTORY UNTIL DESIR PAGE 0003 Date 06/22/15 06/22/15 06/22/15 06/22/15 06/24/15 06/24/15

I 06/23/15

1.

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1 -EEC 15-00252, 0

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p. WDE-109, 07-07-1972.

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07-07-1972.

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07-07-1972.

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2. bb. cc.

07-07-1972.

Capability gg.

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04-09-1981, 22.

15.0. 23.

6. 26.

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29.

30.

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Page 6of11

1. 3 ). by

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a. ft. ft. 8,000

= 2.T

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A 17 46 003 63 17 11 46 23 88 24 18 71 23 88 24 18 71 A16 51 26 57 12 22 ADO 80 27 48 11 I

9.0 if

)..

0, Attachment A.pdf 0, Attachment C-3, Ar 0, TOD

)-

O, Attachment C-4, Pii O, Attachment C-1, Co 15-00252, 0,

C-5, H o, Page 11 of 11 No. pages Attachment A-Attachment Cl -

Observation Record Attachment C2-List of Piping Areas & \"1/alkdovm Summary tsometric Shovving CS -List of Pipe Supports VJalkdovvn JJtl 1 551 10 1 2 AutoPIPE Analyses EEC 15-00252 Rev 0 Attachment A, Page Al of A651 INPUT/OUTPUT FILE NAME Description Outlet (AECOM) Model of the large bore outlet piping for precoat filters WDL-Fl-A and WDL-Fl-B.

Inlet (AECOM) Model of the large bore inlet piping for precoat filters WDL-Fl-A and WDL-Fl-B.

Inlet piping model with support WDH-272 removed at Node F02 to detennine the Inlet-Uplift (AECOM) acceptability of the system without crediting this rod hanger support, which experiences uplift. Drain (AECOM) Model of the large bore drain piping for prccoat filters WDL-Fl-A and WDL-Fl-B.

Reviewed By: Jeffrey Ross/

Date: Prepared By: Date: Review Method and Results of Review: A detailed independent technical review was performed.

Inputs and reasonableness of the output have been verified.

The correct design considerations were utilized.

The evaluation results are consistent with the purpose.

CLEANUP OF THE BWST 1.0 PURPOSE OP-TM-212-501 Revision 3A Level1-Continuous Use

2.0 MATERIAL

AND SPECIAL EQUIPMENT 3.0 PRECAUTIONS, LIMITATIONS, AND PREREQUISITES

VERIFY OP-TM-212-501 Revision 3A VERIFY VERIFY .!12 VERIFY

VERIFY OPEN OP-TM-212-501 Revision 3A VERIFY If then OPEN OP-TM-212-501 Revision 3A If then OPEN If then OPEN If then OPEN If then OPEN If then OPEN OP-TM-212-501 Revision 3A If then OPEN If then OPEN THROTTLE OPEN START RECORD PRESS and HOLD When then RELEASE RECORD and

IAAT not OP-TM-212-501 Revision 3A then GO TO

OP-TM-212-501 Revision 3A If then CLOSE If then CLOSE If then CLOSE If then CLOSE then CLOSE OP-TM-212-501 Revision 3A then CLOSE then CLOSE CLOSE CLOSE OPEN CLOSE CLOSE OP-TM-212-501 Revision 3A RECORD CALCULATE If then VERIFY and I INITIATE

6.0 REFERENCES

7.0 ATTACHMENTS

• • .. : <{*****:*;

.. : *. .;{

ELEV **

• • .*

'.*.) DEVICE

ATTACHMENT

7.1 Device

Locator List DESCRIPTION.

'

..*

BI..DG OP-TM-212-501 Revision 3A .* >c AREA y

Page 1 of 29 Any of the following:

- Yellow EVENT indicator Lit on front panel of Strong Motion Accelerometer System (CR). - PRF-1-2, "Threshold Se ismic Condition" actuated. - Red OBE indicator Lit on front panel of Strong Motion Accelerometer System (CR). - PRF-1-3, "Operating Ba sis Earthquake" actuated. - Ground motion felt by station personnel.

None Page 2 of 29 THIS PAGE INTENTIONALLY BLANK Page 3 of 29

___ 3.1 entry into OP-TM-AOP-003, "Earthquake," over the plant

page radio. ___ 3.2 an Operating Basis Earthquake (OBE) has

occurred plant damage levels warrant a plant

shutdown, perform the following:

___ 1. a plant shutdown IAW 1102-4, "Power

Operation" 1102-10, "Plant Shutdown".

___ 1. the reactor EOP-001. ___ 2. 1102-11, "Plant Cooldown".

___ 3.3 Emergency Action Levels (EALs). 3.4 BWST is on Clean up IAW OP-TM-212-501 or Recirc IAW OP-TM-212-252 Section 4.2, the following:

___ 1.

SF-P-2 ___ 2. SF-V-43 ___ 3. SF-V-40 ___ 4. SF-V-20 ___ 5. SF-V-45 ___ 3.5 an event at above the Threshold Seismic Condition (TSC) has occurred, Step 3.8.

Page 4 of 29

An OBE has occurred plant damage levels warrant a shutdown 3.2 An event at above the Threshold Seismic C ondition (TSC) has occurred 3.5 Page 5 of 29

___ 3.6 bothof the following conditions exist - Seismic instrumentation is inoperable does indicate a seismic event.

- A seismic event is felt by on-site personnel.

Attachment 1, Seismic Instrumentation Inoperable. ___ 3.7 either of the following conditions exist: Following an Operating Basis Earthquake (OBE), the OBE indicator and PRF-1-3 will actuate until recording is complete (po ssibly several minutes after the event). - EVENT OBE indicator Lit on seismic

instrumentation.

- PRF-1-2 PRF-1-3 Actuated.

Attachment 2, Determining Validity of Seismic

Instrumentation/Alarms. ___ 3.8 a TSC OBE has been declared, Attachment 3, Actions for a Valid Seismic Condition. ___ 3.9 Section 4.0, "Return To Normal".

Page 6 of 29 THIS PAGE INTENTIONALLY BLANK Page 7 of 29 NOTE: The following steps may be performed in any order or concurrently.

1. the earthquake magnitude was determi ned to be less than a Threshold Seismic Condition, the PDMS Manager that no response is required.___ 2. the Technical Support Cent er (TSC) was activated, recovery directions from the TSC.___ 3. an earthquake was determine to have occurred, I&C to perform the following Appendices of 1105-17, Earthquake Monitoring System:___ - Appendix 1, Backup Of Recorded Events ___ - Appendix 2, Retrieval and Processing of PRA Erasure Tape ___ 4. the seismic event exce eded the OBE criteria, perform the following prior to plant restart (based on the results of the restart walkdown required by Step 4.15.2 of Attachment 3): ___ -

concurrence from the Plant Manager. ___ - permission from the NRC. ___ 5. Perform the following to reset TSC and OBE alarms:

1.

RESET on the Strong Motion A ccelerometer System (CR). ___ 2. PRF-1-2 and PRF-1-3 are clear. ___

Attachment 1, Seismic Instrumentation Inoperable Attachment 2, Determining Validity of Seismic Instrumentation/Alarms Attachment 3, Actions for a Valid Seismic Condition Attachment 4, Criteria For SSE Exceedance

Page 8 of 29 THIS PAGE INTENTIONALLY BLANK

Page 9 of 29 Page 1 of 3 To confirm and classify a seismic event in the absence of installed seismic instrumentation/alarms.

None 3.1 Precautions:

None 3.2 Limitations:

None

3.3 Prerequisites

None

Page 10 of 29 THIS PAGE INTENTIONALLY BLANK Page 11 of 29 Page 2 of 3 4.1 the U.S. Geological Survey's National Earthquake Center (USGS) to confirm the earthquake (303-273-8500).

___ 4.2 the earthquake is confirmed, perform the following:

___ 1.

the following from the Earthquake Center:

- Epicenter Location:

_________________________

_____________

(latitude & longitude)

________________________

______________

(nearest town & state)

- Magnitude: ______________

_____ (Richter scale)

2. it is determined that a nearby nuclear site is closer to the epicenter, perform the following:___ A.

that facility (using an applicable phone number below),

the seismic data from their instrumentation.___ Peach Bottom (717) 456-3477 / 4687 / 4223 Limerick (610) 718-2840 / 2128 / 2125 Salem - Hope Creek (856) 339-2636 / 5200 / 5201 (5202)

Susquehanna (570) 542-3907 / 1971 / 3903 Beaver Valley (724) 682-5198 / 5302 (5102) / 5110 (5313)

B. the alternate site's seismic data (if available) to determine declare the earthquake classification (OBE or TSC).___

Page 12 of 29 THIS PAGE INTENTIONALLY BLANK Page 13 of 29 Page 3 of 3 4.2 (Continued)

3. data from a closer nearby site can be used, perform the following:___ A. the earthquake had a magnitude 6.0 (Richter Scale), an OPERATING BASIS EARTHQUA KE (OBE) has occurred.___ B. the earthquake was > 5.0 but

< 6.0 (Richter Scale), perform the following:___ NOTE: If required, TMI's location, (40° 9' 14.17"N, 76° 43' 30.69"W), can be used to determine the distance to the earthquake epicenter. This can be performed by the USGS Earthquake Cent er staff or by using internet web sites (such as Google Earth).

1) the distance from TMI to the epicenter (using any available means). ___ 2) the earthquake was within 125 miles of TMI, an OPERATING BASIS EARTHQUA KE (OBE) has occurred. ___ 4. data from a closer nearby site can be used an OBE has occurred, a THRESHOLD SEISMIC CONDITION (TSC) has occurred.___ None Page 14 of 29 THIS PAGE INTENTIONALLY BLANK Page 15 of 29 Page 1 of 4 To determine the validity of a seismic instrument alarm.

None 3.1 Precautions:

None 3.2 Limitations:

None

3.3 Prerequisites

None

Page 16 of 29 THIS PAGE INTENTIONALLY BLANK Page 17 of 29 Page 2 of 4 NOTE: The steps of this section may be performed in any order or concurrently.

4.1 Seismic

Monitor computer printouts using Figures 1 2 of this Attachment.___ 4.2 the Control Room staff did feel ground motion, Security other station personnel fo r reports of ground motion.___ 4.3 one of the following for an indepe ndent confirmation of earthquake intensity: - Peach Bottom Atomic Po wer Station (717-456-4687/4221) ___ - Limerick Generating Station (610-718-2125) ___ - National Earthquake Center (303-273-8500) ___ 4.4 the seismic monitor printouts indicate an OBE has occurred the earthquake is confirmed by either of the following: - Felt by station personnel, - Independently confirmed by any of the facilities in Step 4.3 above, an OPERATING BASIS EARTHQUAKE (OBE) has occurred. ___ 4.5 the seismic monitor printouts indicate an OBE has occurred the earthquake is confirmed by either of the following: - Felt by station personnel

- Independently confirmed by any of the facilities in Step 4.3 above a THRESHOLD SEISMIC CONDI TION (TSC) has occurred. ___ None Page 18 of 29 THIS PAGE INTENTIONALLY BLANK Page 19 of 29 Page 3 of 4

Page 20 of 29 THIS PAGE INTENTIONALLY BLANK Page 21 of 29 Page 4 of 4

1. There will be two separate printouts of this chart, one for each triaxial accelerometer. 2. An alarm is VALID if two or more channels have at least one measurement exceeding 0.010g. 3. An alarm is potentially VALID if one channel has a measured value of 0.010g, and any other channel has measurements approaching 0.010g. 4. If only one channel shows any significant measurements, (as in the example below), the alarm is VALID and is likely due to induced electrical noise. 5. OBE criteria is: At least one measurement in any frequency in any channel exceeds design, and at least 1 measurement in any other frequency in any other channel exceeds 2/3 design.

RESPONSE SPECTRA ANALYSIS FOR SSA-3 RECORDER B (S/N 31272)

EVENT DATE: 04/11/1999 16:29:51 ACCELEROMETER RB 455-8 EL SELECTED EXCEEDANCE CRITERIA: NONE Computed CAV = 0.000 g - s, CAV Design Limit = 0.160 g - s, OBE Limit Value = 0.010 g, Damping = 0.050 Spectral acceleration exceeded OBE design criteria at 0 periods Spectral acceleration greater than 2/3 OBE design criteria at 0 periods Computed CAV = 0.001 g - s, CAV Design Limit = 0.160 g - s, OBE Limit Value = 0.010 g, Damping = 0.050 Spectral acceleration exceeded OBE design criteria at 0 periods Spectral acceleration greater than 2/3 OBE design criteria at 0 periods Computed CAV - 0.000 g - s, CAV Design Limit = 0.160 g - s, OBE Limit Value = 0.010 g, Damping = 0.050 Spectral acceleration exceeded OBE design criteria at 0 periods Spectral acceleration greater than 2/3 OBE design criteria at 0 periods

• • • • OBE CRITERIA WAS NOT EXCEEDED ****

0.100 0.125 0.250 0.001 0.350 0.001 0.260 0.040 0.200 0.032 0.270 0.004 0.360 0.001 0.133 0.143 0.380 0.001 0.400 0.001 0.190 0.030 0.190 0.029 0.380 0.001 0.420 0.001 0.154 0.200 0.400 0.001 1.060 0.001 0.180 0.027 0.160 0.020 0.480 0.001 1.190 0.001 0.250 0.333 1.130 0.001 0.600 0.000 0.130 0.016 0.120 0.012 1.160 0.001 0.530 0.000 0.400 0.500 0.370 0.000 0.250 0.000 0.120 0.010 0.100 0.008 0.350 0.000 0.230 0.000

Page 22 of 29 THIS PAGE INTENTIONALLY BLANK Page 23 of 29 Page 1 of 3 To provide the actions required to respond to a valid seismic condition.

None 3.1 Precautions:

None 3.2 Limitations:

None

3.3 Prerequisites

None

Page 24 of 29 THIS PAGE INTENTIONALLY BLANK Page 25 of 29 Page 2 of 3

4.1 performance

of this procedure has resulted in the declaration of an Operating Basis Earthquake (OBE) a Threshold Seismic Condition (TSC). ___ NOTE: The remaining Steps of this se ction may be perform ed in any order or concurrently.

4.2 the earthquake plant damage was severe enough to have potentially caused unreported personnel injury, perform either both of the following: ___ - Security other available personnel to search for victims. ___ - personnel assembly/accountability.___ 4.3 OP-TM-108-111-1001, "TMI Severe Weather and Site Inaccessibility Guidelines." ___ 4.4 OP-AA-108-111-1001, "Severe Weather and Natural Disaster Guidelines."___

NOTE: The intent of Step 4.5 is to determine the effects of the earthquake on SSCs. This information is needed to deter mine if the plant can continue to operate or should be shutdown for additional inspections.

4.5 the plant is in operation, a visual inspection of all accessible areas of the plant IAW EPRI NP-6695, "Guidelines for Nuclear Power Plant Earthquake Response." ___ 4.6 the PDMS Manager to perform the following: - Inspect TMI-2 for damage. ___ - Initiate 2301-1.1, "TMI-2 Reactor Vessel Fuel Removal/Rearrangement". ___ 4.7 the BWST is on cleanup IAW OP-TM-212-501 "Cleanup of the BWST" or Recirc IAW OP-TM-212-252 Section 4.2 ___ 4.8 releases in progress. ___

Page 26 of 29 THIS PAGE INTENTIONALLY BLANK Page 27 of 29 Page 3 of 3 4.9 any of the following: - Spent Fuel Pool Temperature (A0419 A0420) is >160°F - Spent Fuel Pool Level is < 343'6" (PLB-2-9 PLB-2-10 in alarm) - Spent Fuel Pool Temperat ure and/or level is unknown, OP-TM-AOP-035, Loss of S pent Fuel Pool Cooling.

___ 4.10 there is steam leakage in the Auxiliary Building, the following are Closed:___ - AS-V-17 (TB 355: W of 8B heater 7 ft up). ___ - EX-V-23 (TB 355: S end of AB steam header). ___ 4.11 ISPH ventilation is lost, OP-TM-535-901, "Emergency Ventilation of Screen House". ___ 4.12 DG Building ventilation is lost, the following for the affected building: ___ - OP-TM-861-910, "Emergency Ventilation of EG-Y-1A Room" ___ - OP-TM-861-911, "Emergency Ventilation of EG-Y-1B Room" ___ 4.13 Control Building ventilation is lost, OP-TM-AOP-034, "Loss of Control Building Cooling". ___ 4.14 EFW Pump Room ventilation is degraded, the recommendations of SA-AA-111, "Heat Stress Control". ___ 4.15 OBE limits have been exceeded, perform the following: ___ 1. inspection of the Spent Fuel Po ol "A" racks to ve rify rack-to-rack rack-to-wall gaps are maintained. ___ 2. the plant is shutdown, perform the following: ___ - the post-shutdown plant inspections and tests IAW EPRI NP-6695, "Guidelines for Nuclear Power Plant Earthquake Response."___ - OTSG inspection per EP-AP-420-003, "TMI Unit 1: Steam Generator Eddy Current Activities." ___ 3. if the SSE criteria was exceeded using Attachment 4. ___ None Page 28 of 29 THIS PAGE INTENTIONALLY BLANK Page 29 of 29Page 1 of 1

Page 1 of 15 1.1 UFSAR: 1.1.1 Section 2.8.1 states:

1.1.2 Section

5.1.2.1 describes the design bases for Class I, II, and III structures, systems, and components (SSC), and includes the followin g definitions of t he Operating Basis Earthquake (OBE) and Safe Shutdown Earthquake (SSE):

OBE: SSE: 1.1.3 Section 5.1.2.1.1.

b states that a Class I design ensures that the stress resulting from an SSE 1.1.4 Section 5.1.2.1.2.

b states that a Class I design ensures that the stresses resulting from an SSE 1.1.5 Table 5.4.1 provides a listing of the Cla ss I structures, systems, and components at TMI. 1.2 FHAR:

None 1.3 Technical Specifications:

1.3.1 Unit 2 Technical Specifications:

Page 2 of 15 1.3.2 Unit 1 Technical Specifications: While there are numerous technical specifications that could potentially be affected due

to damage sustained from an earthquake, there are no Unit 1 Technical Specifications directly relevant to seismic events or instrumentation or this procedure. 1.4 Critical Safety Function Review 1.4.1 CSF 1, Reactivity & Reactor Power Control: Maintain control of the fission process, maintain the capability to shutdown the reacto r and the capability to maintain the reactor in a shutdown condition. Control energy production and reactor power distribution based on design limits and current core heat removal capability.

EARTHQUAKE: For all earthquakes at or below the Safe Shutdown Earthquake (SSE), all systems designed Class I (including those required for Reactivity and Reactor Power Control), remain operable. Earthquakes above the SSE are outside design basis events. 1.4.2 CSF 2, Reactor Vessel Inventory Control:

Provide the means to maintain the core covered with sub cooled water. EARTHQUAKE: For all earthquakes at or below the SSE, all systems designed Class I (including those required for Reactor Vesse l Inventory Control), remain operable. Earthquakes above the SSE are outside design basis events. 1.4.3 CSF 3, RCS Integrity: Maintain the capability to cont rol heatup and cooldown rates and control RCS pressure prevent reactor vessel brittle fracture or LTOP events. Maintain RCP seal cooling to prevent excessive loss of RCS inventory through RCP seals. EARTHQUAKE: For all earthquakes at or below the SSE, all systems designed Class I (including those required for RCS Integrity), remain operable. Earthquakes above the SSE are outside design basis events. 1.4.4 CSF 4, Core Heat Removal: Provide the capability to remove core heat production at all times. EARTHQUAKE: For all earthquakes at or below the SSE, all systems designed Class I (including those required for Core Heat Removal), remain operable. Earthquakes above the SSE are outside design basis events. 1.4.5 CSF 5, Containment Integrity: Provide means to pr event or minimize fission product release to the environment. (1) Maintain containment pressure below design and (2)

Provide capability to isolate the containment when required. EARTHQUAKE: For all earthquakes at or below the SSE, all systems designed Class I (including those required for Containment In tegrity), remain operable. Earthquakes above the SSE are outside design basis events.

Page 3 of 15 1.4.6 CSF 6, Radiation Control

& Control Room Habitability:

Monitor and control the release of radiation to the environment. Maintain access to critical plant equipment and use of the Control Room. EARTHQUAKE: For all earthquakes at or below the SSE, all systems designed Class I (including those required for Radiation Cont rol & Control Room Habitability), remain operable. Earthquakes above the SSE are outside design basis events. 1.4.7 CSF 7, Electrical Power: Provide electr ical power as required to accomplish the other Critical Safety Functions. Provide AC and DC power for emergency equipment operation and instrumentation systems. EARTHQUAKE: For all earthquakes at or below the SSE, all systems designed Class I (including those required for Electric Power), remain operable. Earthquakes above the SSE are outside design basis events. 1.4.8 CSF 8, Auxiliary Emergency Systems: Provide equipment cooling (closed cooling &

ventilation), and other support requirements to accomplish the other Critical Safety Functions. Provide Instrument Air for operation of EFW, ADVs, RCP Support Systems and some containment isolation valves. EARTHQUAKE: For all earthquakes at or below the SSE, all systems designed Class I (including those required for Auxiliary Emergency Systems), remain operable. Earthquakes above the SSE are outside design basis events. 1.4.9 CSF 9, Fire Protection & Remote Shut down Capability: Mainta in means to prevent, detect and suppress fires, as well as the cap ability to perform a plant shutdown without access to the Control Room. EARTHQUAKE: For all earthquakes at or below the SSE, all systems designed Class I (including those required for Remote Shutdow n Capability), remain operable. Per A.4 and A.5 of Section 5.0 of t he FHAR, TMI complies with the requirements that: 1) a single failure in the fire suppression syst em should not impair both the primary and backup fire suppression capability, and 2) failu re of the fire suppression system should not incapacitate safety related systems or components. Ea rthquakes above the SSE are outside design basis events. 1.4.10 CSF 10, Chemistry Contro l: Provide the means to monitor and control primary and secondary water chemistry in order to ensur e the long term reliability of plant systems and limit the potential release of radioactive materials. EARTHQUAKE: For all earthquakes at or below the SSE, all systems designed Class I remain operable. The ability to operate non-seismic systems (s uch as primary and secondary sampling) may be lost. However, pressure boundaries of sample systems within the containment will remain intac

t. Earthquakes above the SSE are outside design basis events.

Page 4 of 15 Paragraph (V)(a)(2) of 10CFR1 00, Appendix A, Seismic And Geologic Siting Criteria For Nuclear Power Plants, requires that a nuclear power plant be shut down and inspected if an earthquake motion occurs at the site which exceeds the Operating Basis Earthquake (OBE). The principal concern associated with exc eeding the OBE is potential damage which could preclude continued safe operation.

Per EPRI NP-6695, Guidelines for Nuclear Plant Response to an Earthquake, the objectives of an earthquake response are to: 1. Determine the immediate effects of an earthquake on the physical condition of the plant. 2. Determine if shutdown is appropriate bas ed on the observed damage to the plant or because the OBE has been exceeded. 3. Determine the readiness of the plant to resume operation, if shutdown. Since earthquake damage can range anywhere from none (or insignificant), to catastrophic, this procedure is designed to work in conjunction with the remainder of the EOP/AOP network to accomplish objective s 1 and sometimes 2 above. (i.e., Damage from a seismic event may result in plant sym ptoms - up to and including a plant trip -

that require concurrent entry into appr opriate abnormal/emergen cy procedure(s). For these cases, performance of the appropriate abnormal/

emergency procedure(s) will resolve the situation(s) resulting from t he damage that occurred. Absence of such damage-induced symptoms indicates less sustained or immediate damage, thus reducing the urgency of the response and allowing time for this AOP to carry out walkdown inspections to determi ne the extent of the damage.)

For objective 2, if the damage from the event does not result in an automatic or forced

plant shutdown/trip, the procedure determines if an OBE was exceeded. If so, then plant shutdown for further inspection and test s is accomplished. If the OBE was not exceeded, and no significant da mage was found during the walkdown inspections, then shutdown of the plant is not considered necessary.

Finally, if the plant is shutdown (either initially or as a result of the event), guidance is provided to determine restart readiness per objective 3.

Page 5 of 15

3.1 Entry

Conditions:

Any of the following: - Yellow EVENT indicator Lit on front panel of Strong Motion Accelerometer System (CR) - PRF-1-2, "Threshold Se ismic Condition" actuated - Red OBE indicator Lit on front panel of Strong Motion Accelerometer System (CR) - PRF-1-3, "Operating Ba sis Earthquake" actuated - Ground motion felt by station personnel This procedure is designed for entry during all modes of plant operation. The primary indications of a seismic event are the seismic monitoring system and it's annunciators (PRF-1-2 and PRF-1-3). However, since the seismic monitoring system is not safety related, it may not be available to diagnose the event. Theref ore, entry into this AOP is also made whenever station personnel feel ground motion.

If an event is not strong enough to be sensed by the installed instrumentation or felt by station personnel, then entry into this procedur e is not required. This would include events reported by or from o ff-site sources, including t he National Earthquake Center. However, since this procedure is structured to diagnose and categorize the event before taking any action, entry under any circumstance s is acceptable, (such as when station personnel are unsure whether or not they felt an earthquake). None - Memorized operator response before accessing the procedure is not required to successfully mitigate this event.

Page 6 of 15 The primary function of this procedure is to evaluate seismic events in order to screen out false alarms and minor earthquakes with a magnitude less than the Threshold Seismic Condition. Seismic events that ar e not screened out are then classified to determine the appropriate response. (Screening is accomplished by using dual confirmation between internal, external, and National Earthquake center data.

Classification is accomplished using site-specif ic data, [if available], or by making conservative estimates from off-site data.)

Once an earthquake is classified, the proce dure implements the appropriate actions to inspect for and correct any damage, perform a shutdown/cooldown if necessary, and evaluate the plant for conti nued operation and/or restart.

Specific steps are discussed below. Step 3.1 Entry into any EO P or AOP is announced to ens ure all operators are aware of major changes in plant conditions. This action also makes chemistry, maintenance and radiation prot ection personnel aware. Step 3.2 This continuous action step acco mplishes the primary objective of this procedure which is to implement a plant shutdown and cooldown, if procedurally determined to be requir ed. If plant damage from the earthquake allows, a controlled shutdown and cooldown is preferred, but provision is made to initiate and/or respond to a plant trip if required. (This step was placed as an IAAT early in the main text - instead of Attachment 3

- due to its importance.) Step 3.3 This step initiates evaluation of the Emergency Action Levels (EALs).

NOTE: The EAL criteria is slightly differ ent from that in this AOP, in that the EAL classifications are solely based on functioning seismic instrumentation (with confirmation). The AOP goes beyond this limitation, and classifies the event regardless the seismic instrumentation status. Classification by the AOP will result in appropriate impl ementation of the EALs for either circumstance.

Step 3.4 This step directs operator action if a seismic event occurs while the BWST is on cleanup IAW OP-TM-212-501 or Reci rc IAW OP-TM-212-252 Step 4.2.

This step is performed as a priority to isolate BWST cleanup in the event of a seismic event IAW TMI LAR TMI-15-071 Step 3.5 This continuous action step directs the user to step 3.7 (for performance of ), if it is determined that a TSC or greater ev en has occurred.

Page 7 of 15 Step 3.6 This step directs the user to At tachment 1 if the plant seismic instrumentation or alarms are inoperable or did not respond to the event. (Thus, the only indication of the event would be that it was felt by station personnel.) Attachment 1 confirms and classifies the earthquake using sources external to the plant.

Step 3.7 This step directs the user to At tachment 2 if the plant seismic instrumentation did respond to the ev ent. Attachment 2 confirms the earthquake using one additional source (e ither a nearby facility, the National Earthquake Center, or confirmation by station personnel). It then classifies the earthquake using information provi ded on the seismic instrumentation printout.

NOTE in step

3.7 This note is provided to alert the oper ator that a change in alarm status during procedure performance is a possibility, and does not necessarily indicate a new event that r equires re-entry in the AOP.

Step 3.8 This step directs the user to Attachm ent 3 whenever it is determined that a TSC or greater earthquake has occurred. This Attachment is where the majority of the event response is performed.

Step 3.9 This is the end of the Follow Up actions of the main text and directs the user to Section 4.0. Attachment 1 This attachment is entered for ea rthquakes that are felt by station personnel but where seismic instrumentation/alarms are not available or did not respond. It uses the National Earthquake Center both to confirm the earthquake and provide its epicenter loca tion and magnitude (Richter scale).

Once confirmed, it conservatively cla ssifies the earthquake as either an OBE or TSC, (using the distance between the epicenter and TMI), via either of

two methods:

Method 1: If a nearby facility is determined to be closer to the epicenter, that facility is contacted and their seismic dat a is used to classify the earthquake.

Method 2: If data from a nearby faci lity cannot be used, the earthquake's magnitude and distance from the plant are used. If the earthquake was over a 6.0 magnitude at any distance from t he plant, or over

5.0 magnitude

within 125 miles of TMI, then it is classified as an OBE. Otherwise, it is classified as a TSC. (per Appen dix A of RG 1.66)

Note that, since the earthquake was not alarmed, but rather felt and then confirmed, this attachment results in a declaration of either an OBE or TSC. This is necessary for adequate EAL classification, since their threshold values are based on an alarm and confirmation - which cannot occur if the

instrumentation is OOS.

Page 8 of 15 Attachment 2 This attachment is entered for earthquakes that actuate the installed seismic instrumentation/alarms. It evalua tes the earthquake using the information provided on seismic instrumentation pr intouts (with two figures provided as examples). It then confirms the earthquake using one additional source (either a nearby facility, the National Earthquake Center, or confirmation by station personnel). The classification can result in a TSC or OBE declaration, or, (in contrast to Attachment 1), no declaration at all. Attachment 3 This attachment is entered whenever it is determined that a TSC or larger magnitude earthquake has occurred. This attachment contains the actions necessary to respond to a confirmed earthquake. The individual steps of this attachment are described below: ,

Step 4.1 To prevent unnecessary performance of the included steps, the first step directs the user to verify that perform ance of this procedure has resulted in the declaration of either an Operating Basis Earthquake (OBE) or a Threshold Seismic Condition (TSC). ,

Step 4.2 NOTE This note informs the user that the remainder of the steps may be performed in any order or concurrently. ,

Step 4.2 This step determines if the eart hquake or damage was severe enough to have potentially caused personnel injury.

It then takes action by dispatching personnel to search for vi ctims or performing personnel assembly/accountability. ,

Step 4.3 This step directs the user to initiate OP-TM-108-111-1001, TMI Severe

Weather and Site Inaccessibility Guidelines. In case the earthquake affects access to the site, this procedure will provide adequate staffing for plant operations and E-Plan implementati on while allowing unnecessary personnel to leave the site. ,

Step 4.4 This step, (performed regardless of ev ent classification or plant operating condition), directs the user to initiate OP-AA-108-111-1001, "Severe Weather and Natural Disaster Guidelines (per Action 2 of AR 00777761). The section for seismic event provides guidelines for walkdowns and plant inspections, using CC-AA-5001, Post Transient or Scram Walkdown, and

ER-AA-330-004, Visual Examination of Snubbers, as applicable. The purpose of CC-AA-5001 is to identify any failures or degradation that could affect system operation and integrit

y. This will ensu re deficiencies are identified and corrected. The purpose of ER-AA-330-004 is to inspect snubbers (in this case, following a potentially damaging transient event) to ensure deficiencies are identified and corrected.

Page 9 of 15 Attachment 3, Step 4.5 and

its NOTE If the plant is in operation, this step, (in conjunction with the walkdowns from Step 4.4), implements the recommendatio ns of EPRI NP-6695, "Guidelines for Nuclear Power Plant Earthquake Response, by walking down all

accessible areas to determine if earthquake damage requires a plant shutdown, or if conti nued operation is allowed. ,

Step 4.6 This step directs the user to notify t he PDMS Manager to inspect TMI-2 for damage and to initiate 2301-1.1, "TMI-2 Reactor Vessel Fuel

Removal/Rearrangement". (A valid seis mic condition which triggers the U1 Earthquake Detection System is an ent ry condition to 2301-1.1) This ensures compliance with Unit 2 Technical Specification 3.2.1.2. Attachment 3,

Step 4.7 The step ensures the BWST is not on cleanup IAW OP-TM-212-501or Recirc IAW OP-TM-212-252 Step 4.2. Si nce the Spent Fuel portion of the BWST piping that is used for these evolutions is not seismic, this minimizes the potential for loss of ECCS inventory. ,

Step 4.8 The step ensures that releases are in progress. Since portions of the release systems are non-seismic, this minimized the potential for undesired/unmonitored releases. (per Action 2 of AR 00730406 from operations review of SEN 269) ,

Step 4.9 This step provides the action to be taken if the Spent Fuel Pool or the Spent

Fuel Pool cooling system has been damaged. This step will also direct initiation of AOP-35 if the ability to monitor the Spent Fuel Pool has been lost. Attachment 3,

Step 4.10 This step ensures adequate isolati on for any steam leakage into the Auxiliary Building. ,

Step 4.11 This step provides the action to be taken ifISPH ventilation is lost. ,

Step 4.12 This step provides the action to be taken ifDG Building ventilation is lost. ,

Step 4.13 This step provides the action to be taken if Control Building v entilation is lost. ,

Step 4.14 IfEFW Pump Room ventilation is degraded, this stepevaluates the recommendations of SA-AA-111, "Heat Stress Control".

Page 10 of 15 Attachment 3, Step 4.15 This step only applies if OBE limits were exceeded (thus requiring a plant shutdown).

Substep 1 initiates an inspection to verify the rack-to-rack and rack-to-wall gaps are maintained in Spent Fuel Pool A.

Substep 2 initiates the following when the plant is shutdown: The post-shutdown plant inspecti ons and tests IAW EPRI NP-6695, "Guidelines for Nuclear Power Plant Earthquake Response OTSG inspection per EP-AP-420-003, TMI Unit 1:

Steam Generator Eddy Current Activities Substep 3 determines if t he SSE criteria was exceed ed using Attachment 4, Criteria for SSE Exceedance Attachment 4 This is a logic drawing that c an be used to determine if the SSE criteria has been exceeded. It requires operability of the seismic instrumentation, (specifically the printout following an ev ent), so may not be available in all cases. However, knowledge of SSE exceedence is only required for restart readiness evaluation, and is not, in any way, required for implementation of the response actions of this procedure.

RTN Step 4.1 NOTE This note informs the user that the remainder of the steps may be performed in any order or concurrently. RTN Step 4.1 If the earthquake was determined to be less than a Threshold Seismic Condition, then the PDMS Manager is notified that no action is

required RTN Step 4.2 If the Technica l Support Center was activated, then recovery directions are obtained from the TSC. This will be the case for all

earthquakes determined to have a magnitude at or above a Threshold Seismic Condition. RTN Step 4.3 This step has I&C perfo rm Appendix 1 and 2 of 1105-17 to backup the Strong Motion Accelerometer and to Retrieve and Process the PRA Erasure Tapes. The backup will provide a historical file. The PRA tapes will provide an i ndependent measure of the peak accelerations for each of the three planes on the three installed peak reading accelerographs. (These devices provide actual peak readings regardless of the availability or actuation status of the seismic instrumentation.) This also installs new PRA tapes to allow collection of subsequent readings on any aftershocks. While not directly applicable to the immediat e classification of the event, this information will be useful in the post-event analysis relating to restart readiness (particularly if the seismic instrumentation was inoperable Page 11 of 15 during the event). RTN Step 4.4 If the seismic event exceeded the OBE criteria, then the user is directed to obtain concurrence fr om the Plant Manager and the NRC prior to restart. RTN Step 4.5 This step provides direction for resetting all alarms associated with a seismic event.

Page 12 of 15

7.1 Developmental

References 7.1.1 1230-30, Earthquake, (R44) 7.1.2 EPRI NP-6695, Guidelines for Nuclear Plant response to an Earthquake 7.1.3 EPRI NP-5930, A Criterion for Determining Exceedance of the Operating Basis Earthquake 7.1.4 Unit 2 Technical Specification 3.2.1.2 7.1.5 RG 1.165, Identification And Characterization Of Se ismic Sources And Determination Of Safe Shutdown Earthquake Ground Motion 7.1.6 RG 1.166, Pre-Earthquake Planning And Immediate Nucl ear Power Plant Operator Post-earthquake Actions 7.1.7 RG 1.167, Restar t Of A Nuclear Power Plant Shut Down By A Seismic Event 7.2 Implementing References 7.2.1 1102-4, Power Operation 7.2.2 1102-10, Plant Shutdown 7.2.3 1102-11, Pl ant Cooldown 7.2.4 1105-17, Earthquake Monitoring System 7.2.5 EOP-001, Reactor Trip Or Safety Injection 7.2.6 OP-TM-AOP-034, Loss of Control Building Cooling 7.2.7 OP-AA-108-111-1001, Severe Weather and Natural Disaster Guidelines 7.2.8 OP-TM-108-111-1001, TMI Severe Weather and Site Inaccessibility Guidelines 7.2.9 OP-TM-212-501, Cleanup of the BWST 7.2.10 OP-TM-535-901, Emergency Ventilation of Screen House 7.2.11 OP-TM-861-910, Emergency Ventilation of EG-Y-1A Room 7.2.12 OP-TM-861-911, Emergency Ventilation of EG-Y-1B Room 7.2.13 SA-AA-111, Heat Stress Control 7.2.14 EP-AP-420-003, TM I Unit 1: Steam Generator Eddy Current Activities Page 13 of 15 7.2.15 2301-1.1, TMI-2 Reactor Vessel Fuel Removal/Rearrangement

7.3 Commitment

7.3.1 Action

Tracking Item AR00603573.28 License Renewal Structures Monitoring Program (Step 4.6 "Attachment 3", OP-TM-AOP-003 Step 4.6). 8.1 Scenario #1: 8.1.1 100% RTP, no OOS equipment. PRF 1-2, Threshold Seismic Condition actuates.

Various high vibration alarms actuate, but clear when silenced. Various tank levels show oscillations. No other abnormalities are readily apparent. Report received from the field personnel that an earthquake occurred. 8.1.2 Three minutes after the event starts, PRF 1-3, Operating Basis Earthquake actuates and the crew is provided the se ismic printout for Scenario #1.

This printout should show that an OBE was exceeded. Fifteen mi nutes after the original earthquake, a slightly smaller aftershock occurs and re-alarms PRF 1-2. 8.2 Scenario #2:

8.2.1 100% RTP, the Strong Motion Accelerometer System is deenergized for maintenance.

One or more control room st aff "feel" an earthquake. Vari ous tank levels show minor oscillations. No other abnormalities are readily apparent. Repor t received from the field personnel that we may have had an earthquake. 8.2.2 The National Earthquake Center reports that the magnitude was 5.7 and the location was 41°25'45"N by 74°30'40"W (5 miles W-SW of Middletown, NY) Susquehanna plant is determined to be the closest facilit y and reports that they did experience an earthquake, but it had a magni tude less than an OBE.

Page 14 of 15

PRF-1-2, Threshold Seismic Condition (TSC) 0.01g Confirmation via one of the following: "Felt" by station personnel IV'd from an external source PRF-1-3, Operating Basis

Earthquake (OBE) Calculated value, based on seismic spectra curve for TMI Confirmation via one of the following: "Felt" by station personnel IV'd from an external source TSC with TMI seismic instrumentation inoperable &

site closer to epicenter Anything below the OBE setpoints in use at the closer site Confirmation: "Felt" by station personnel OBE with TMI seismic instrumentation inoperable &

site closer to epicenter OBE setpoints in use at the closer site Confirmation: "Felt" by station personnel TSC with TMI seismic instrumentation inoperable &

site closer to epicenter Magnitude reported by the

National Earthquake Center (NEC) < the OBE limits listed in

the row below Confirmation: "Felt" by station personnel OBE with TMI seismic instrumentation inoperable &

site closer to epicenter Magnitude reported by NEC

either: 6.0 (Richter Scale) at any distance from plant 5.0 (Richter Scale) within 125 miles of TMI Confirmation: "Felt" by station personnel SSE based on TMI seismic instrumentation Any frequency > twice the OBE limit (as shown on the seismic instrumentation printout)

Confirmation: Any other frequency > 2/3 the OBE limit

OBE 0.06g horizontal and 0.04g vertical Safe Shutdown Earthquake (SSE) 0.12g horizontal and 0.08g vertical

Page 15 of 15 This AOP concludes at one of three end points, based on the severity of the earthquake: 1. Earthquake causing minimal damage and determined to be less than TSC; Unless the event caused an automatic shut down, no plant manipulation is taken and no emergency action level is entered. 2. Earthquake causing minimal damage and de termined to be > TSC, but < OBE; Unless the event caused an automatic shut down, plant operation remains in it's pre-earthquake condition. Unusual Event is declared and applicable actions are taken per Attachment 3. 3. Earthquake causing damage sufficient to warrant a shutdown or determined to be > OBE; Plant is shutdow n (or tripped). Alert is declared and all actions are taken per Attachment 3. Plant restart requires NRC concurrence.

3.3 EMERGENCY

CORE COOLING. REACTOR BUILDING EMERGENCY COOLING AND REACTOR BUILDING SPRAY SYSTEMS {Contd.} 3.3.2 Maintenance or testing shall be allowed during reactor operation on any component(s) in the makeup and purification, decay heat, RB emergency cooling water , RB spray, BWST level instrumentation, or cooling water systems which will not remove more than one train of each system from service. Components shall not be removed from service so that the affected system train is inoperable for more than 72 consecutive hours. If the system is not restored to meet the requirements of Specification

3.3.1 within

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the reactor shall be placed in a HOT SHUTDOWN condition within six hours. 3.3.2.1 If the CFT boron concentration is outside of limits, or if the TSP baskets contain amounts of TSP outside the l imits specified in 3. 3.1. 3. b. restore the system to operable status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. If the system is not restored to meet the requirements of Specification

3.3.1 within

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the reactor shall be placed in a HOT SHUTDOWN condition within six hours. 3.3.3 Exceptions to 3.3.2 shall be as follows: a. Both CFTs shall be OPERABLE at all times. b. Both the motor operated valves associated with the CFTs shall be fully open at all times. c. One reactor building cooling fan and associated cooling unit shall be permitted to be service for seven days. 3.3.4 Prior to initiating maintenance on any of the components, the duplicate

{redundant) component shall be verified to be OPERABLE. The requirements of Specificat i on 3.3.1 assure tnat, before the reactor can be made critical, adequate engineered safety features are operab l e. Two engineered safeguards makeup pumps, two decay heat removal pumps and two decay heat removal coolers (along with their respective cooling water systems components) are specified.

However, only one of each is necessary to supply emergency coolant to the reactor in the event of a loss-of-coolant accident.

Both CFTs are required because a single CFT has insufficient inventory to reflood the core for hot and cold line breaks (Reference 1 ). The operability of the borated water storage tank (BWST) as part of the ECCS ensures that a sufficient supply of borated water is available for injection by the ECCS in the event of a LOCA (Reference 2). The limits on BWST minimum volume and boron concentration ensure that 1) sufficient water is available within containment to permit recircu l ation cooling flow to the core , and 2) the reactor will remain at l east one percent subcritical following a Loss-of-Coolant Accident (LOCA). The contained water volume limit of 350,000 gallons includes an allowance for water not usable because of tank discharge location and sump recirculation switchover setpoint.

Redundant heaters maintain the borated water supply at a temperature greater than 40°F. The Rea Building emergency sump pH control system ensures a sump pH between 7.3 and 8.0 during the rec 1 tion phase of a postulated LOCA. A minimum pH level of 7.3 is required to reduce the potential for chloride ced stress corrosion cracking of austenitic sta i nless steel and assure the retention of elemental iodin

• the recircu l ating fluid. A maximum pH value of a.a minimizes the 3-23 The BWST can be placed on cleanup path , or recirculation path for weekly surveillance testing for boron concentration , on a temporary basis , until the end of the Fuel Cycle 21 operation. A seismic evaluation has been performed that concluded the cleanup and recirculation seismic Class II piping paths would maintain pressure boundary integrity during a Safe Shutdown Earthquake (SSE). The seismic Class I BWST would maintain its safety functions during an SSE. The limiting condition for operation (LCO) for BWST cleanup operation is a total duration of not more than 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> (30 days) prior to Fall 2015 Refueling Outage and is a total duration of not more than 1440 hours0.0167 days <br />0.4 hours <br />0.00238 weeks <br />5.4792e-4 months <br /> (60 days) during Fuel Cycle 21 operation. BWST Cleanup can be started and stopped at any time as long as the total durations are not exceeded. The LCO for BWST recirculation operation is limited to time it takes to adequately recirculate the BWST volume to perform the boron sampling surveillance , which is approximately 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> per week. The temporary LCOs are in effect to allow time for a permanent solution to the issue of interconnecting seismic Class I and II piping during BWST cleanup and recirculation operation.

OP-TM-212-252 Revision 8Page 1 of 16Level 1 - Continuous UseRECIRCULATION AND SAMPLING OF BWST (DH-T-1)1.0PURPOSE1.1Recirculate and sample Borated Water Storage Tank (DH-T-1) for weekly sample or following makeup / chemical additions to ensure compliance with the following:

!BWST boron 2550 ppm Boron (Technical Specification 3.3.1.1.a minimum plus 2% analysis uncertainty) and < 2750 ppm Boron.

!BWST temperature > 40

1. F.!T/S Table 4.1-3, Item 22.0MATERIAL AND SPECIAL EQUIPMENT None 3.0PRECAUTIONS, LIMITATIONS, AND PREREQUISITES3.1Precautions None 3.2Limitations None 3.3Prerequisites

3.3.1 VERIFY

BWST level greater than 9.5'.

____3.3.2 If using SF System for recirc IAW Step 4.2, then VERIFY Spent Fuel Iined up IAW 1104-6, Spent Fuel Cooling System.

____3.3.3 If using DH System for recirc IAW Step 4.3 or4.4, then VERIFY DH Trains A and B in ES Standby Mode IAW OP-TM-212-000, Decay Heat Removal System.

____3.3.4 If using BS for recirc IAW Step 4.5 or4.6, then VERIFY BS Trains A and B in ES Standby Mode IAWOP-TM-214-000, Building Spray System.

____

OP-TM-212-252 Revision 8Page 2 of 164.0MAIN BODY

4.1 VERIFY

all prerequisites have been met.

____NOTE:Only one section (4.2, 4.3, 4.4, 4.5, or 4.6) is performed to recirculate and sample the BWST.

4.2 If sampling BWST using recirculation via SF-P-2, then perform the following:

____4.2.1PLACE BWST on recirc IAW OP-TM-212-501, Cleanup of the BWST.

____4.2.2 RECORD date and time BWST placed on recirc.Date____________________Time______________

4.2.3 When BWST recirculation time meets one of the following:

!BWST level has been within 1 foot () of current reading during last 7 days (PPC A0486 or A0487) and minimum recirc time > 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,!BWST level has exceeded a 1 foot change from current reading

during last 7 days (PPC A0486 or A0487) and minimum recirc

time > 6 days, then NOTIFY Chemistry to sample BWST (DH-T-1) IAW CY-TM-551-807, Chemistry Primary Sampling.

____4.2.4 GO TOStep 4.7.____

OP-TM-212-252 Revision 8Page 3 of 16 4.3 If sampling BWST using recirculation via DH Train A, then perform the following:

____4.3.1 VERIFY DH Train B in ES Standby Mode and all support systems are available.

____4.3.2 ENSURE DC-P-1A operating (CC).

____4.3.3ENSUREOPEN DH-V-5A (CC).

____4.3.4 REQUEST Shift Management to declare DH-P-1A Inoperable andINITIATE a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time clock per T.S. 3.3.2.

____4.3.5 UNLOCK and OPEN DH-V-21.____NOTE:Substep 4.3.6.3 is to be quickly performed after pump start.4.3.6Start DH-P-1A as follows:

1.UNLOCK DH-V-20A.____2.START DH-P-1A (CC).

____3.THROTTLE OPEN DH-V-20A to obtain ~ 800 gpm on DH-FI-802A (CC).

____4.3.7 When > 30 minutes recirculation has elapsed, then NOTIFY Chemistry to sample Decay Heat Removal Cooler Outlet sample point IAWCY-TM-551-807, Primary Chemistry Sampling.

____4.3.8 When sample has been obtained, then secure recirc as follows:

____1.SECURE DH-P-1A (CC) andPLACE in Normal After Stop.

________ ____IVDate 2.LOCKCLOSED DH-V-20A.________ ____IVDate 3.LOCK CLOSED DH-V-21.________ ____IVDate 4.REQUEST Shift Management to declare DH-P-1A Operable.

____

OP-TM-212-252 Revision 8Page 4 of 16 4.3.9 If DC Train A is not required for component cooling, then STOPDC-P-1A andPLACE in Normal After Stop (CC).

________ ____IVDate 4.3.10 GO TOStep 4.7.____

OP-TM-212-252 Revision 8Page 5 of 16 4.4 If sampling BWST using recirculation via DH Train B, then perform the following:

____4.4.1 VERIFY DH Train A in ES Standby Mode and all support systems are available.

____4.4.2 ENSURE DC-P-1B operating (CR).

____4.4.3ENSUREOPEN DH-V-5B (CR).

____4.4.4 REQUEST Shift Management to declare DH-P-1B Inoperable andINITIATE a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time clock per T.S. 3.3.2.

____4.4.5 UNLOCK and OPEN DH-V-21.____NOTE:Substep 4.4.6.3 is to be quickly performed after pump start.4.4.6Start DH-P-1B as follows:

1.UNLOCK DH-V-20B.____2.START DH-P-1B (CR).

____3.THROTTLE OPEN DH-V-20B to obtain ~ 800 gpm on DH-FI-803A (CR).

____4.4.7 When > 30 minutes recirculation has elapsed, then NOTIFY Chemistry to sample Decay Heat Removal Cooler Outlet sample point IAWCY-TM-551-807, Primary Chemistry Sampling.

____4.4.8 When sample has been obtained, then secure recirc as follows:

____1.SECURE DH-P-1B (CR) andPLACE in Normal After Stop.

________ ____IVDate 2.LOCKCLOSED DH-V-20B.________ ____IVDate 3.LOCK CLOSED DH-V-21.________ ____IVDate 4.REQUEST Shift Management to declare DH-P-1B Operable.

____

OP-TM-212-252 Revision 8Page 6 of 16 4.4.9 If DC Train B is not required for component cooling, then STOPDC-P-1B (CR) andPLACE in Normal After Stop.

________ ____IVDate 4.4.10 GO TOStep 4.7.____

OP-TM-212-252 Revision 8Page 7 of 16 4.5 If sampling BWST using recirculation via BS Train A, then perform the following:

4.5.1 VERIFY

BS Train B in ES Standby Mode and all support systems are available.

____4.5.2 ENSURE DC-P-1A operating (CC).

____4.5.3 ENSURE OPEN DH-V-5A (CC).

____4.5.4 REQUEST Shift Management to declare BS-P-1A inoperable andINITIATE a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time clock per T.S. 3.3.2.

____4.5.5 OPEN BS-V-3A (CC).

____4.5.6 VERIFY BS-V-1A is Closed.

____4.5.7PLACE 1A ES Valves MCC, Unit 5C (BS-V-1A) in Off.

____NOTE:An Operator must remain in the area near BS-V-47A anytime the valve is open. The Operator is responsible to close BS-V-47A prior to leaving the area or if 4 psig ESAS actuates.

4.5.8 REMOVE

cap at BS-V-47A andATTACH tubing to drain funnel.

____4.5.9IAAT BS-V-47A is Open and 4 psig ESAS actuates, thenCLOSE BS-V-47A.____NOTE:BS-V-47A is maintained open to prevent any leakage past BS-V-1A from filling the BS header.

4.5.10 OPEN BS-V-47A.

____4.5.11UNLOCKandOPEN BS-V-60A.____4.5.12UNLOCKand THROTTLEOPEN BS-V-59 21/2 turns.

____4.5.13 VERIFY adequate BS-P-1A lube oil level in bearing sight glasses.

____4.5.14PLACE BS-P-1A in Normal-After-Start.

____4.5.15 If flow through BS-V-47A is greater than 1/8 inch pencil stream, then 1.NOTIFY Shift Management to evaluate continued use of BS-P-1A for BWST recirculation.

____2.INITIATE IR which describes BS-V-1A leakage.

____

OP-TM-212-252 Revision 8Page 8 of 16NOTE:L2672, BS-P-1A Flow - Lo, will be in alarm with BS-P-1A flow less than 900 gpm.CAUTIONMaximum allowable flow is 1700 gpm with suction from the BWST.

Minimum allowable flow is 60 gpm. Maximum allowable time for operation at a flow < 60 gpm is 60 seconds.

4.5.16 THROTTLE BS-V-59 to obtain ~ 800 gpm on BS1-FI-1.

____4.5.17 When > 30 minutes recirculation has elapsed, thenNOTIFY Chemistry tosample BWST (DH-T-1) IAW CY-TM-551-807, Chemistry Primary Sampling.____4.5.18 When sample has been obtained, then secure recirc as follows:

____1.SECURE BS-P-1A (CC) and PLACE in Normal After Stop.

________ ____IVDate 2.CLOSE BS-V-47A.________ ____IVDate 3.REMOVE the drain tubing from BS-V-47A and REPLACE the cap.________ ____IVDate 4.LOCK CLOSED BS-V-60A.

________ ____IVDate 5.LOCKCLOSED BS-V-59.________ ____IVDate 6.CLOSE BS-V-3A.________ ____IVDate 7.CLOSEbreaker for BS-V-1A (1A ES valves MCC, Unit 5C).

________ ____IVDate OP-TM-212-252 Revision 8Page 9 of 16 8.REQUEST Shift Management to declare BS-P-1A Operable.

____4.5.19 If DC Train A is not required for component cooling, then STOPDC-P-1A (CC) andPLACE in Normal After Stop.________ ____IVDate 4.5.20 GO TO Step 4.7.____

OP-TM-212-252 Revision 8Page 10 of 16 4.6 If sampling BWST using recirculation via BS Train B, then perform the following:

4.6.1 VERIFY

BS Train A in ES Standby Mode and all support systems are available.

____4.6.2 ENSURE DC-P-1B operating (CR).

____4.6.3 ENSURE OPEN DH-V-5B (CR).

____4.6.4 REQUEST Shift Management to declare BS-P-1B Inoperable andINITIATE a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> time clock per T.S. 3.3.2.

____4.6.5 OPEN BS-V-3B.____4.6.6 VERIFY BS-V-1B is Closed.

____4.6.7PLACE 1B ES Valves MCC, Unit 7B (BS-V-1B) in Off.

____NOTE:An Operator must remain in the area near BS-V-47B any time the valve is open. The Operator is responsible to close BS-V-47B prior to leaving the area or if 4 psig ESAS actuates.

4.6.8 REMOVE

cap at BS-V-47B andATTACH tubing to drain funnel.

____4.6.9IAAT BS-V-47B is Open and 4 psig ESAS actuates,thenCLOSE BS-V-47B.____NOTE:BS-V-47B is maintained open to prevent any leakage past BS-V-1B from filling the BS header.

4.6.10 OPEN BS-V-47B.

____4.6.11 UNLOCK and OPEN BS-V-60B.

____4.6.12 UNLOCK and THROTTLE OPEN BS-V-59 21/2 turns.

____4.6.13 VERIFY adequate BS-P-1B lube oil level in bearing sight glasses.

____4.6.14PLACE BS-P-1B in Normal-After-Start.

____4.6.15 If flow through BS-V-47B is greater than 1/8 inch pencil stream, then 1.NOTIFY Shift Management to evaluate continued use of BS-P-1B for BWST recirculation.

____2.INITIATE IR which describes BS-V-1B leakage.

____

OP-TM-212-252 Revision 8Page 11 of 16NOTE:L2674, BS-P-1B Flow - Lo, will be inalarm with BS-P-1B flow less than 900 gpm.CAUTIONMaximum allowable flow is 1700 gpm with suction from the BWST.

Minimum allowable flow is 60 gpm. Maximum allowable time for operation at a flow < 60 gpm is 60 seconds.

4.6.16 THROTTLE BS-V-59 to obtain ~ 800 gpm on BS1-FI-2.

____4.6.17 When > 30 minutes recirculation has elapsed, thenNOTIFY Chemistry to sample BWST (DH-T-1) IAWCY-TM-551-807, Chemistry Primary Sampling.____4.6.18 When sample has been obtained, then secure recirc as follows:

____1.SECURE BS-P-1B (CR) and PLACE in Normal After Stop.

________ ____IVDate 2.CLOSE BS-V-47B.________ ____IVDate 3.REMOVE the drain tubing from BS-V-47B and REPLACE the cap.________ ____IVDate 4.LOCK CLOSED BS-V-60B.

________ ____IVDate 5.LOCKCLOSED BS-V-59.________ ____IVDate 6.CLOSE BS-V-3B.________ ____IVDate 7.CLOSEbreaker for BS-V-1B (1B ES valves MCC, Unit 7B).

________ ____IVDate OP-TM-212-252 Revision 8Page 12 of 16 8.REQUEST Shift Management to declare BS-P-1B operable.

____4.6.19 If DC Train B is not required for component cooling, then STOPDC-P-1B (CR) andPLACE in Normal After Stop.

________ ____IVDate 4.6.20 GO TO Step 4.7____

OP-TM-212-252 Revision 8Page 13 of 16 4.7 When BWST boron results are obtained, then perform the following:

____4.7.1 RECORD Boron results on Attachment 7.1, BWST (DH-T-1) Analysis Results.____4.7.2CONTACT Control Room for information andRECORD BWST temperature on Attachment 7.1, BWST (DH-T-1) Analysis Results, using one of the following based on current BWST level:

____!> 3' but < 26' - PPC A0105

!> 26' but < 52' - PPC A0104

!> 52' - DH4-TE (CC)

4.7.3 RECORD

sample results in CR Log.

____4.7.4Compare new boron value to previous boron concentration as follows:

1.OBTAIN most recent boron concentration for BWST.

____2.REPORT new boron number and previous boron number to Shift Manager.____3.If BWST boron concentration is less than 2550 ppm, and Reactor is critical, thenRESTORE BWST to operable within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (See T.S. 3.3.1.1a).

____4.If BWST temperature is < 40

1. F, and Reactor is critical, then RESTORE BWST to operable within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (See T.S. 3.3.1.1a).____

5.If BWST boron concentration is < 2600 ppm,then FORWARD a copy of the data sheet to Chemistry Supervision.

____6.If BWST boron concentration is > 2750 ppm, then NOTIFY Shift Manager to restore boron concentration to <2750 ppm.

____4.8 When BWST sample results are acceptable, then NOTIFY the Control Room that the BWST may be taken off recirc. IAW OP-TM-212-501, Cleanup of the BWST.

____

OP-TM-212-252 Revision 8Page 14 of 16(INITIAL ONE)DATEPRINTED NAMESIGNATUREINITIALS IV/CVINITIALS5.0RETURN TO NORMAL None

6.0REFERENCES

6.1Developmental References6.1.1OP-TM-212-000, Decay Heat Removal System6.2Implementing References6.2.1CY-TM-551-807, Primary Chemistry Sampling 6.2.2OP-TM-212-501, Cleanup of the BWST 6.2.3OP-TM-212-000, Decay Heat Removal System 6.2.41104-6, Spent Fuel Cooling System 6.3Commitments None7.0ATTACHMENTS7.1BWST (DH-T-1) Analysis Results 7.2Device Locator List OP-TM-212-252 Revision 8Page 15 of 16ATTACHMENT 7.1BWST (DH-T-1) Analysis Results Page 1 of 1 Date/Time of Sample Analysis: Boron, ppm Acceptance Criteria: Boron 2550 ppm and < 2750 ppmBWST temperature Acceptance Criteria: > 40

1. F Performed By Date/Time/

Approved By Date/Time/

OP-TM-212-252 Revision 8Page 16 of 16ATTACHMENT 7.2 Device Locator List Page 1 of 1LOCATION DEVICE DESCRIPTION ELEV BLDGAREABS-V-47ABS-P-1A Disch Test Valve 281 AB Above small leakoff funnel along RB wall 8 ft above floorBS-V-47BBS-P-1B Disch Test Valve 281 AB Above small leakoff funnel along RB wall 8 ft above floorBS-V-59BS Pump to BWST Isolation Valve 281 ABChain valve near RB wall 6 ft NW of large leakoff funnel 8 ft above floorBS-V-60ABS-P-1A Recirc to BWST Isolation 281 AB Near small leakoff funnel along RB wall 5 ft West of funnel 6 ft above floorBS-V-60BBS-P-1B Recirc to BWST Isolation 281 ABNear small leakoff funnel along RB wallDH-V-153BWST Recirc Line Sample Isol281AB6' North of BS-P-1A Vault HatchDH-V-180BWST Sample Valve281AB4' East of Spray Vault A entranceDH-V-20ADH-P-1A Cleanup/ Recirc to BWST281AB Between Large & Sm Leakoff Funnel S, 6ft from RB wall, 7ft off floorDH-V-20BDH-P-1B Cleanup/ Recirc to BWST281AB 7' N of entrance to B DH Vault, 8' above floorDH-V-21DH-P-1s Recirc to the BWST281AB 6ft E of ent to B Spray Vlt, 9ft above floor Chain Operated ValveDH-V-31BWST Recirc Line Sample Isol281AB 4' East of entrance to A Spray Vault, 4' above floorDH-V-5A-EX1DHV5A Control Switch355CR(CR)DH-V-5B-EX1DHV5B Control Switch355CR(CR)