TMI-20-015, 2018-2019 Biennial 10 CFR 50.59 Summary Report and 2019 Commitment Revision Summary Report: Difference between revisions

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: 2. Exelon Letter to NRC, "Certification of Permanent Removal of Fuel from the Reactor Vessel for Three Mile Island Nuclear Station, Unit 1," dated September 26, 2019 (ADAMS Accession No. ML19269E480)
: 2. Exelon Letter to NRC, "Certification of Permanent Removal of Fuel from the Reactor Vessel for Three Mile Island Nuclear Station, Unit 1," dated September 26, 2019 (ADAMS Accession No. ML19269E480)
This letter submits the 2018-2019 Biennial 10 CFR 50.59 Summary Report required by 10 CFR 50.59(d)(2) and the 2019 Annual Commitment Revision Summary Report required by SECY-00-0045 (NEI 99-04).
This letter submits the 2018-2019 Biennial 10 CFR 50.59 Summary Report required by 10 CFR 50.59(d)(2) and the 2019 Annual Commitment Revision Summary Report required by SECY-00-0045 (NEI 99-04).
By letter dated June 20, 2017 (Reference 1), Exelon provided formal notification to the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.4(b)(8) and 10 CFR 50.82(a)(1)(i) of Exelon's determination to permanently cease operations at Three Mile Island Nuclear Station, Unit 1 (TMl-1) on or about September 30, 2019. On September 20, 2019, Exelon permanently ceased power operations at TMI-1. On September 26, 2019, pursuant to 10 CFR 50.82(a)(1)(ii) and 10 CFR 50.4(b)(9), Exelon provided certification to the NRC that all fuel had been permanently removed from the TMI-1 reactor vessel and placed in the spent fuel pool (SFP) (Reference 2). Since the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC pursuant to 10 CFR 50.82(a)(1)(i) and (ii), then pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license no longer authorizes operation of the reactor or placement or retention of fuel in the reactor vessel.
By {{letter dated|date=June 20, 2017|text=letter dated June 20, 2017}} (Reference 1), Exelon provided formal notification to the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.4(b)(8) and 10 CFR 50.82(a)(1)(i) of Exelon's determination to permanently cease operations at Three Mile Island Nuclear Station, Unit 1 (TMl-1) on or about September 30, 2019. On September 20, 2019, Exelon permanently ceased power operations at TMI-1. On September 26, 2019, pursuant to 10 CFR 50.82(a)(1)(ii) and 10 CFR 50.4(b)(9), Exelon provided certification to the NRC that all fuel had been permanently removed from the TMI-1 reactor vessel and placed in the spent fuel pool (SFP) (Reference 2). Since the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC pursuant to 10 CFR 50.82(a)(1)(i) and (ii), then pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license no longer authorizes operation of the reactor or placement or retention of fuel in the reactor vessel.


U.S. Nuclear Regulatory Commission Biennial 50.59 and Annual Commitment Change Reports April 30, 2020 Page 2 Based on the possession only status, a review of prior commitments was conducted and determined that several commitments are no longer applicable. The results of the review are attached.
U.S. Nuclear Regulatory Commission Biennial 50.59 and Annual Commitment Change Reports April 30, 2020 Page 2 Based on the possession only status, a review of prior commitments was conducted and determined that several commitments are no longer applicable. The results of the review are attached.
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Letter Source:                                            Various - Refer to Table 1 for each item Exelon Tracking Number                                    Various - Refer to Table 1 for each item Nature of Commitment:                                    Table 1 list onetime open commitments that are related to inspections, analysis or responses to NRC generic communications (e.g. Bulletins, and Generic Letters), The table contains the commitment number, the commitment source, a summary of the commitment, and basis for the deletion of the commitment.
Letter Source:                                            Various - Refer to Table 1 for each item Exelon Tracking Number                                    Various - Refer to Table 1 for each item Nature of Commitment:                                    Table 1 list onetime open commitments that are related to inspections, analysis or responses to NRC generic communications (e.g. Bulletins, and Generic Letters), The table contains the commitment number, the commitment source, a summary of the commitment, and basis for the deletion of the commitment.
Each of the original regulatory commitments listed in Table 1 will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.
Each of the original regulatory commitments listed in Table 1 will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.
Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 10 CFR 50.82(a)2 TMI1 is no longer permitted to operate or place fuel in the reactor vessel. The only risk is the safe storage of irradiated fuel in the Spent Fuel Pool. The regulatory commitments in Table 1 no longer afford the original intent and protection. Table 1 provides additional basis for each action item.
Justification for Change By {{letter dated|date=September 26, 2019|text=letter dated September 26, 2019}}, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 10 CFR 50.82(a)2 TMI1 is no longer permitted to operate or place fuel in the reactor vessel. The only risk is the safe storage of irradiated fuel in the Spent Fuel Pool. The regulatory commitments in Table 1 no longer afford the original intent and protection. Table 1 provides additional basis for each action item.
Table 1 OneTime Commitments that are no longer applicable based on Permanent Shutdown Status Commitment          Commitment              Commitment Details                            Basis for Deletion Tracking            Source Number            Document 0135661904          Updated          TMI has elected to delay                T1R23 was a defueling outage in which the Commitment        implementation of the final scope      station certified per 50.82 that the station Schedule  RVI    of RVI MRP227A examinations          was completely defueled, and pursuant to MRP227A        from the T1R22 (2017) refueling        50.82 TMI is no longer permitted to Examinations      outage to the T1R23 (2019)              operate, or store fuel in the reactor vessel.
Table 1 OneTime Commitments that are no longer applicable based on Permanent Shutdown Status Commitment          Commitment              Commitment Details                            Basis for Deletion Tracking            Source Number            Document 0135661904          Updated          TMI has elected to delay                T1R23 was a defueling outage in which the Commitment        implementation of the final scope      station certified per 50.82 that the station Schedule  RVI    of RVI MRP227A examinations          was completely defueled, and pursuant to MRP227A        from the T1R22 (2017) refueling        50.82 TMI is no longer permitted to Examinations      outage to the T1R23 (2019)              operate, or store fuel in the reactor vessel.
refueling outage.                      The need to perform RVI MRP227A examinations of Reactor Vessel internals were required to support long term operation, however since operation is no longer permitted the need to complete this vessel inspection is no longer germane.
refueling outage.                      The need to perform RVI MRP227A examinations of Reactor Vessel internals were required to support long term operation, however since operation is no longer permitted the need to complete this vessel inspection is no longer germane.
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Bulletins, and Generic Letters), The table contains the commitment number, the commitment source, a summary of the commitment, and basis for the deletion of the commitment.
Bulletins, and Generic Letters), The table contains the commitment number, the commitment source, a summary of the commitment, and basis for the deletion of the commitment.
Each of the original regulatory commitments listed in Table 1 will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.
Each of the original regulatory commitments listed in Table 1 will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.
Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. The only risk is the safe storage of irradiated fuel in the Spent Fuel Pool. The commitments in Table 1 no longer afford the original intent and protection. Table 1 provides additional basis for each action item.
Justification for Change By {{letter dated|date=September 26, 2019|text=letter dated September 26, 2019}}, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. The only risk is the safe storage of irradiated fuel in the Spent Fuel Pool. The commitments in Table 1 no longer afford the original intent and protection. Table 1 provides additional basis for each action item.


Commitment Change Summary Report                                                                    Attachment Part B - Programmatic Commitments tied to Generic Communications                                  Page 5 of 44 Table 2 Generic Communications Commitments that are subject to deletion based on Change of Plant Status to Permanently Shutdown Commitment      Commitment              Commitment Details                        Basis for Deletion Tracking        Source Number        Document 0112207201  6710962097      The original commitment is            Based on PDTS the Control Building GL 89013:        described in the updated response    Ventilation System will no longer be REVISED            provided to the NRC for GL 8913      classified as Safety Related.
Commitment Change Summary Report                                                                    Attachment Part B - Programmatic Commitments tied to Generic Communications                                  Page 5 of 44 Table 2 Generic Communications Commitments that are subject to deletion based on Change of Plant Status to Permanently Shutdown Commitment      Commitment              Commitment Details                        Basis for Deletion Tracking        Source Number        Document 0112207201  6710962097      The original commitment is            Based on PDTS the Control Building GL 89013:        described in the updated response    Ventilation System will no longer be REVISED            provided to the NRC for GL 8913      classified as Safety Related.
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Letter Source:                                          Various - Refer to Table 3 for each item Exelon Tracking Number                                  Various - Refer to Table 3 for each item Nature of Commitment:                                    Table 3 lists open programmatic regulatory commitments for Three Mile Island, Unit 1 (TMI1), that are related to licensing actions (e.g. LARs). Technical Specification Amendments 295 and 297 were implemented on September 27, 2019 and represents the Permanently Defueled Technical Specifications (PDTS). The table contains the commitment number, the commitment source, a summary of the commitment, and basis for the deletion of the commitment.
Letter Source:                                          Various - Refer to Table 3 for each item Exelon Tracking Number                                  Various - Refer to Table 3 for each item Nature of Commitment:                                    Table 3 lists open programmatic regulatory commitments for Three Mile Island, Unit 1 (TMI1), that are related to licensing actions (e.g. LARs). Technical Specification Amendments 295 and 297 were implemented on September 27, 2019 and represents the Permanently Defueled Technical Specifications (PDTS). The table contains the commitment number, the commitment source, a summary of the commitment, and basis for the deletion of the commitment.
Each of the original regulatory commitments listed in Table 3 will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.
Each of the original regulatory commitments listed in Table 3 will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.
Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 10 CFR 50.82(a)2 TMI1 is no longer permitted to operate or place fuel in the reactor vessel. The only risk is the safe storage of irradiated fuel in the Spent Fuel Pool. The regulatory commitments in Table 3 no longer afford the original intent and protection. Table 3 provides additional basis for each action item.
Justification for Change By {{letter dated|date=September 26, 2019|text=letter dated September 26, 2019}}, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 10 CFR 50.82(a)2 TMI1 is no longer permitted to operate or place fuel in the reactor vessel. The only risk is the safe storage of irradiated fuel in the Spent Fuel Pool. The regulatory commitments in Table 3 no longer afford the original intent and protection. Table 3 provides additional basis for each action item.
Table 3 Programmatic Commitments tied to Licensing Actions that are no longer applicable based on Permanent Shutdown Status Commitment        Commitment          Commitment Details                              Basis for Deletion Tracking          Source Number            Document 0112207204      59280420162      TSCR NO. 326  ELIMINATION OF                  No longer permitted to perform TSCR NO. 326        CONTAINMENT EQUIPMENT HATCH                    fuel emplacement in the RPV. TS CLOSURE DURING REFUELING                        3.8 Fuel Loading and Refueling was Procedures will be in place which will          deleted in TS Amendment 297.
Table 3 Programmatic Commitments tied to Licensing Actions that are no longer applicable based on Permanent Shutdown Status Commitment        Commitment          Commitment Details                              Basis for Deletion Tracking          Source Number            Document 0112207204      59280420162      TSCR NO. 326  ELIMINATION OF                  No longer permitted to perform TSCR NO. 326        CONTAINMENT EQUIPMENT HATCH                    fuel emplacement in the RPV. TS CLOSURE DURING REFUELING                        3.8 Fuel Loading and Refueling was Procedures will be in place which will          deleted in TS Amendment 297.
require the placement of continuously operated particulate and radioiodine air sampling equipment inboard of the open containment equipment hatch opening during fuel loading and refueling activities.
require the placement of continuously operated particulate and radioiodine air sampling equipment inboard of the open containment equipment hatch opening during fuel loading and refueling activities.
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0112235530  10 CFR 50 Appendix R - Loss of HVAC. The licensee committed to monitor diesel engine parameters during diesel generator operations to ensure EDG is adequately cooled during loss of ventilation in the diesel rooms due to an Appendix R Fire.
0112235530  10 CFR 50 Appendix R - Loss of HVAC. The licensee committed to monitor diesel engine parameters during diesel generator operations to ensure EDG is adequately cooled during loss of ventilation in the diesel rooms due to an Appendix R Fire.
Each of the original regulatory commitments will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.
Each of the original regulatory commitments will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.
Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. As a result, the requirements of 10 CFR 50.47.(b)(2) and Appendix R are no longer applicable and fire protection for a decommissioning plant is covered by 10 CFR 50.48(f).
Justification for Change By {{letter dated|date=September 26, 2019|text=letter dated September 26, 2019}}, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. As a result, the requirements of 10 CFR 50.47.(b)(2) and Appendix R are no longer applicable and fire protection for a decommissioning plant is covered by 10 CFR 50.48(f).
Letter Source:        5211842015 LTR to NRC GL 8233 RESPONSE NUREG 0737 ITEM IC1 ATOG IMPLEMENTATION 5211842154  LTR to NRC: NUREG 0737 ITEM I.C.1 RESPONSE TO SER QUESTIONS Exelon Tracking      0112207264 Number                0112207277 Nature of            Both listed commitments are associated with implementation Abnormal Transient Commitment:          Operating Guidelines (ATOG) in Emergency Operating Procedures (EOPs).
Letter Source:        5211842015 LTR to NRC GL 8233 RESPONSE NUREG 0737 ITEM IC1 ATOG IMPLEMENTATION 5211842154  LTR to NRC: NUREG 0737 ITEM I.C.1 RESPONSE TO SER QUESTIONS Exelon Tracking      0112207264 Number                0112207277 Nature of            Both listed commitments are associated with implementation Abnormal Transient Commitment:          Operating Guidelines (ATOG) in Emergency Operating Procedures (EOPs).
0112207264 - Abnormal Transient Operating Guidelines (ATOGs). The licensee committed to the NRC that the ATOGs would be integrated into the Abnormal Transient Procedures, which ultimately become the EOPs. The guidance to follow the ATOGs was placed in AP 1001E, "Writers Guide for Abnormal Transient Procedures."
0112207264 - Abnormal Transient Operating Guidelines (ATOGs). The licensee committed to the NRC that the ATOGs would be integrated into the Abnormal Transient Procedures, which ultimately become the EOPs. The guidance to follow the ATOGs was placed in AP 1001E, "Writers Guide for Abnormal Transient Procedures."
0112207277 - EOP Upgrade Program. The licensee committed to correct NRC concerns on Writers Guide Administrative Procedures for Abnormal Transient Procedures.
0112207277 - EOP Upgrade Program. The licensee committed to correct NRC concerns on Writers Guide Administrative Procedures for Abnormal Transient Procedures.
Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. As a result, the need for EOPs that meet the ATOGs are no longer necessary, since the transients in question are not applicable to a defueled facility that is no longer licensed to operate. In addition, the requirement to maintain a writer's guide procedure for the maintenance of these procedures is no longer required.
Justification for Change By {{letter dated|date=September 26, 2019|text=letter dated September 26, 2019}}, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. As a result, the need for EOPs that meet the ATOGs are no longer necessary, since the transients in question are not applicable to a defueled facility that is no longer licensed to operate. In addition, the requirement to maintain a writer's guide procedure for the maintenance of these procedures is no longer required.


Commitment Change Summary Report                                                                      Attachment Part D - Miscellaneous Programmatic Commitments                                                    Page 38 of 44 Letter Source:        TMI15120 - LTR to NRC: Fleet Commitment to Maintain Severe Accident Management Guidelines (SAMGs)
Commitment Change Summary Report                                                                      Attachment Part D - Miscellaneous Programmatic Commitments                                                    Page 38 of 44 Letter Source:        TMI15120 - LTR to NRC: Fleet Commitment to Maintain Severe Accident Management Guidelines (SAMGs)
Exelon Tracking        0261101222 Number Nature of              0261101222Fleet Commitment to Maintain Severe Accident Management Guidelines Commitment:            (SAMGs). The licensee committed to implement the Nuclear Energy Institute (NEI) Nuclear Strategic Issues Advisory Committee (NSIAC) approved initiative to implement SAMGs. The SAMGs would be used by emergency response personnel during accident conditions that progress beyond the mitigation capabilities described in EOPs. SAMG strategies are intended to arrest the progression of fuel damage, maintain the capability of the containment as long as possible, and minimize radiological releases.
Exelon Tracking        0261101222 Number Nature of              0261101222Fleet Commitment to Maintain Severe Accident Management Guidelines Commitment:            (SAMGs). The licensee committed to implement the Nuclear Energy Institute (NEI) Nuclear Strategic Issues Advisory Committee (NSIAC) approved initiative to implement SAMGs. The SAMGs would be used by emergency response personnel during accident conditions that progress beyond the mitigation capabilities described in EOPs. SAMG strategies are intended to arrest the progression of fuel damage, maintain the capability of the containment as long as possible, and minimize radiological releases.
The original regulatory commitment listed above will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.
The original regulatory commitment listed above will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.
Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. As a result, the need for EOPs that meet the ATOGs are no longer necessary, since the transients in question are not applicable to a defueled facility that is no longer licensed to operate. Therefore, the need to provide SAMGs to provide strategies to arrest the progression of fuel damage or maintain the capability of containment. Although the SAMGs provided spent fuel mitigation strategies in the event of a loss of water to the spent fuel pool, these Extensive Damage Mitigation Strategies to ensure water sources to the Spent Fuel Pool are already built into the Abnormal Operating procedure to address the loss of spent fuel pool cooling.
Justification for Change By {{letter dated|date=September 26, 2019|text=letter dated September 26, 2019}}, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. As a result, the need for EOPs that meet the ATOGs are no longer necessary, since the transients in question are not applicable to a defueled facility that is no longer licensed to operate. Therefore, the need to provide SAMGs to provide strategies to arrest the progression of fuel damage or maintain the capability of containment. Although the SAMGs provided spent fuel mitigation strategies in the event of a loss of water to the spent fuel pool, these Extensive Damage Mitigation Strategies to ensure water sources to the Spent Fuel Pool are already built into the Abnormal Operating procedure to address the loss of spent fuel pool cooling.
Letter Source:        TMI15120 - LTR to NRC: Response Providing Information Regarding Implementation Details for the B.5.b Phases 2 and 3 Mitigation Strategies Exelon Tracking        0112207215 Number                0112207217 Nature of              112207215 B.5.b Commitments  Three Mile Island Nuclear Station Unit 1 will include the Commitment:            command and control enhancement strategies as described in the general description in Attachment 1 in plant procedures (Tables A.31) 112207217 B.5.b Commitments  Three Mile Island Nuclear Station Unit 1 will list the viable sitespecific reactor/containment strategies described in Attachment 1 that could be used by emergency response organization or plant personnel in appropriate procedures (Table A.6.1).
Letter Source:        TMI15120 - LTR to NRC: Response Providing Information Regarding Implementation Details for the B.5.b Phases 2 and 3 Mitigation Strategies Exelon Tracking        0112207215 Number                0112207217 Nature of              112207215 B.5.b Commitments  Three Mile Island Nuclear Station Unit 1 will include the Commitment:            command and control enhancement strategies as described in the general description in Attachment 1 in plant procedures (Tables A.31) 112207217 B.5.b Commitments  Three Mile Island Nuclear Station Unit 1 will list the viable sitespecific reactor/containment strategies described in Attachment 1 that could be used by emergency response organization or plant personnel in appropriate procedures (Table A.6.1).
The original regulatory commitment listed above will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.
The original regulatory commitment listed above will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.
Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. The B.5.b commitments are part of the broader Extensive Damage Mitigation Strategies that are required by 10 CFR 50.155, Mitigation of beyonddesignbasis events. Pursuant to 50.155.(a)2(i), once the certifications described in 50.82 are submitted, the licensee need only comply with the by EDGM strategies associated with spent fuel pool cooling capabilities.
Justification for Change By {{letter dated|date=September 26, 2019|text=letter dated September 26, 2019}}, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. The B.5.b commitments are part of the broader Extensive Damage Mitigation Strategies that are required by 10 CFR 50.155, Mitigation of beyonddesignbasis events. Pursuant to 50.155.(a)2(i), once the certifications described in 50.82 are submitted, the licensee need only comply with the by EDGM strategies associated with spent fuel pool cooling capabilities.


Commitment Change Summary Report                                                                        Attachment Part D - Miscellaneous Programmatic Commitments                                                        Page 39 of 44 Letter Source:        GPUN letters to NRC C311902073, 5211853262 and C311903248 concerning TMI Fire Brigade Training.
Commitment Change Summary Report                                                                        Attachment Part D - Miscellaneous Programmatic Commitments                                                        Page 39 of 44 Letter Source:        GPUN letters to NRC C311902073, 5211853262 and C311903248 concerning TMI Fire Brigade Training.

Revision as of 22:24, 22 September 2022

2018-2019 Biennial 10 CFR 50.59 Summary Report and 2019 Commitment Revision Summary Report
ML20121A006
Person / Time
Site: Crane Constellation icon.png
Issue date: 04/30/2020
From: Orth T
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TMI-20-015
Download: ML20121A006 (40)
v • d • e


Text

Three Mile Island Nuclear Station, Unit 1 441 S. P.O. Box 480 Middletown, PA 17057 10 CFR 50.59(d)(2)

NEI 99-04 TMI-20-015 April 30, 2020 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility License No. DPR-50 NRC Docket No. 50-289

Subject:

2018-2019 Biennial 10 CFR 50.59 Summary Report and 2019 Commitment Revision Summary Report

References:

1. Exelon Letter to NRC, "Certification of Permanent Cessation of Operations for Three Mile Island Nuclear Station," dated June 20, 2017 (ADAMS Accession No. ML17171A151)
2. Exelon Letter to NRC, "Certification of Permanent Removal of Fuel from the Reactor Vessel for Three Mile Island Nuclear Station, Unit 1," dated September 26, 2019 (ADAMS Accession No. ML19269E480)

This letter submits the 2018-2019 Biennial 10 CFR 50.59 Summary Report required by 10 CFR 50.59(d)(2) and the 2019 Annual Commitment Revision Summary Report required by SECY-00-0045 (NEI 99-04).

By letter dated June 20, 2017 (Reference 1), Exelon provided formal notification to the U.S. Nuclear Regulatory Commission (NRC) pursuant to 10 CFR 50.4(b)(8) and 10 CFR 50.82(a)(1)(i) of Exelon's determination to permanently cease operations at Three Mile Island Nuclear Station, Unit 1 (TMl-1) on or about September 30, 2019. On September 20, 2019, Exelon permanently ceased power operations at TMI-1. On September 26, 2019, pursuant to 10 CFR 50.82(a)(1)(ii) and 10 CFR 50.4(b)(9), Exelon provided certification to the NRC that all fuel had been permanently removed from the TMI-1 reactor vessel and placed in the spent fuel pool (SFP) (Reference 2). Since the certifications for permanent cessation of operations and permanent removal of fuel from the reactor vessel were submitted to the NRC pursuant to 10 CFR 50.82(a)(1)(i) and (ii), then pursuant to 10 CFR 50.82(a)(2), the 10 CFR 50 license no longer authorizes operation of the reactor or placement or retention of fuel in the reactor vessel.

U.S. Nuclear Regulatory Commission Biennial 50.59 and Annual Commitment Change Reports April 30, 2020 Page 2 Based on the possession only status, a review of prior commitments was conducted and determined that several commitments are no longer applicable. The results of the review are attached.

There were no procedure changes, tests or experiments, or facility modifications that required a 50.59 evaluation during the 2018-2019 reporting period.

There are no new regulatory commitments established by this submittal.

Should you have any questions concerning this letter, please contact Mr. Robert Brady at (717) 948-8776.

Respectfully, Trevor L. Orth Decommissioning Plant Manager Three Mile Island Nuclear Station, Unit 1

Attachment:

TMI-1 2019 Commitment Change Summary Report

U.S. Nuclear Regulatory Commission Biennial 50.59 and Annual Commitment Change Reports April 30, 2020 Page 3 cc: w/ Attachments NRC Regional Administrator - NRC Region I NRC Project Manager, NRR Three Mile Island, Unit 1 NRC Project Manager, NMSS Three Mile Island Unit 1 Director, Bureau of Radiation Protection - PA Department of Environmental Resources

ATTACHMENT Three Mile Island Description of 2019 Commitment Revisions Part A: - One-Time Commitments Part B: - Programmatic Commitments tied to Generic Communications Part C: - Programmatic Commitments tied to Licensing Actions Part D: - Miscellaneous Programmatic Commitments Part E: - Items Classified as no longer being Regulatory Commitments

Commitment Change Summary Report Attachment Part A - One-Time Commitments Page 1 of 44 The following provides the update of one-time commitments that will be deleted based on the TMI-1 no longer being permitted to operate in accordance with 10 CFR 50.82(a)(2).

Letter Source: Various - Refer to Table 1 for each item Exelon Tracking Number Various - Refer to Table 1 for each item Nature of Commitment: Table 1 list onetime open commitments that are related to inspections, analysis or responses to NRC generic communications (e.g. Bulletins, and Generic Letters), The table contains the commitment number, the commitment source, a summary of the commitment, and basis for the deletion of the commitment.

Each of the original regulatory commitments listed in Table 1 will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.

Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 10 CFR 50.82(a)2 TMI1 is no longer permitted to operate or place fuel in the reactor vessel. The only risk is the safe storage of irradiated fuel in the Spent Fuel Pool. The regulatory commitments in Table 1 no longer afford the original intent and protection. Table 1 provides additional basis for each action item.

Table 1 OneTime Commitments that are no longer applicable based on Permanent Shutdown Status Commitment Commitment Commitment Details Basis for Deletion Tracking Source Number Document 0135661904 Updated TMI has elected to delay T1R23 was a defueling outage in which the Commitment implementation of the final scope station certified per 50.82 that the station Schedule RVI of RVI MRP227A examinations was completely defueled, and pursuant to MRP227A from the T1R22 (2017) refueling 50.82 TMI is no longer permitted to Examinations outage to the T1R23 (2019) operate, or store fuel in the reactor vessel.

refueling outage. The need to perform RVI MRP227A examinations of Reactor Vessel internals were required to support long term operation, however since operation is no longer permitted the need to complete this vessel inspection is no longer germane.

Therefore, this commitment is being placed in history.

Commitment Change Summary Report Attachment Part A - One-Time Commitments Page 2 of 44 Table 1 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Number Document 0151677404 TMI1 Resolution The Commitment due date of June T1R23 was a defueling outage in which the of Generic Letter 1, 2017, has been extended based station certified per 50.82 that the station 200402 on the following excerpt from TMI was completely defueled, and pursuant to Letter to USNRC (TMI17051): TMI 50.82 TMI is no longer permitted to (Commitment 4) is an Option 2A plant with a operate, or store fuel in the reactor vessel.

calculated invessel fiber debris The scoped of Design Basis Accidents have bypass of 19.66 grams/fuel been reduced to the Fuel Handling assembly, which exceeds the NRC Accident in the Spent Fuel Pool. Loss of acceptance limit of 15 grams/fuel Coolant Accident is no longer a credible assembly. Therefore, WCAP17788, event based on the fact the unit is no "Comprehensive Analysis and Test longer permitted to operate, and Program for GSI191 Y Generic subsequent Emergency Core Cooling Safety Issue191 Closure," System response is no longer required to methodology is required to mitigate a credible event. Therefore, this properly close out GL 200402 and commitment is being placed in history.

GSI191. WCAP17788 is currently under NRC review with forecasted approval in 2018. The final calculations for invessel fiber debris, as well as the existing ECCS flow sump performance final calculations, will be performed together to allow efficient utilization of engineering resources.

The final updated supplemental response to support closure of GL 200402 for TMI, Unit 1 will be submitted within nine months following NRC approval of WCAP17788.

0242869301 TMI15038, Ltr The full LBLOCA reanalysis will be T1R23 was a defueling outage in which the to NRC dated completed within 21 months station certified per 50.82 that the station April 6, 2015 following NRC issuance of the final was completely defueled, and pursuant to Safety Evaluation Report (SER) for 50.82 TMI is no longer permitted to 10 CFR 50.46 BAW10179 Revision 9, which operate, or store fuel in the reactor vessel.

30Day Report incorporates by reference the The scoped of Design Basis Accidents have supplement to BAW10192PA been reduced to the Fuel Handling TMI 1 Thermal Revision 0. Accident in the Spent Fuel Pool. The Large Conductivity Break Loss of Coolant Accident is no longer Degradation a credible event based on the fact the unit (TCD) is no longer permitted to operate, and Commitment subsequent Emergency Core Cooling System analysis is no longer required to mitigate a credible event. Therefore, this commitment is being placed in history.

Commitment Change Summary Report Attachment Part A - One-Time Commitments Page 3 of 44 Table 1 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Number Document 0256770802 NRC Ltr dated Inner Diameter (ID) surface T1R23 was a defueling outage in which the September breaking flaws greater than 50% station certified per 50.82 that the station 15,2015 throughwall and subsurface flaws was completely defueled, and pursuant to greater than 50% throughwall shall 50.82 TMI is no longer permitted to Approval of be repaired or evaluated prior to operate, or store fuel in the reactor vessel.

Relief Request plant restart. Evaluations shall be Since this is a restart commitment and is RR1401 and submitted to the NRC for review no longer applicable this item will be SER and approval prior to plant restart. placed in history.

0256941701 NRC Ltr dated Inner Diameter (ID) surface T1R23 was a defueling outage in which the September breaking flaws greater than 50% station certified per 50.82 that the station 15,2015 throughwall and subsurface flaws was completely defueled, and pursuant to greater than 50% throughwall shall 50.82 TMI is no longer permitted to Approval of be repaired or evaluated prior to operate, or store fuel in the reactor vessel.

Relief Request plant restart. Evaluations shall be Since this is a restart commitment and is RR1401 and submitted to the NRC for review no longer applicable this item will be SER (RMS) and approval prior to plant restart. placed in history.

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 4 of 44 The following provides the update of programmatic commitments tied to Generic Communication responses that will be deleted based on the TMI-1 no longer being permitted to operate in accordance with 10 CFR 50.82(a)(2).

Letter Source: Various - Refer to Table 2 for each item Exelon Tracking Number Various - Refer to Table 2 for each item Nature of Commitment: Table 2 list programmatic open commitments that are related to responses to NRC generic communications (e.g.

Bulletins, and Generic Letters), The table contains the commitment number, the commitment source, a summary of the commitment, and basis for the deletion of the commitment.

Each of the original regulatory commitments listed in Table 1 will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.

Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. The only risk is the safe storage of irradiated fuel in the Spent Fuel Pool. The commitments in Table 1 no longer afford the original intent and protection. Table 1 provides additional basis for each action item.

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 5 of 44 Table 2 Generic Communications Commitments that are subject to deletion based on Change of Plant Status to Permanently Shutdown Commitment Commitment Commitment Details Basis for Deletion Tracking Source Number Document 0112207201 6710962097 The original commitment is Based on PDTS the Control Building GL 89013: described in the updated response Ventilation System will no longer be REVISED provided to the NRC for GL 8913 classified as Safety Related.

RESPONSE (6710962097 dated 6/6/1996):

The Control Building Chillers are not Nuclear Safety Related by design, however we acknowledge the important function they provide; thus we feel it is prudent to monitor their performance. The building cooled by this system is continually occupied. As such, degraded performance of a chiller would be detected through increased temperature in the Control Building. It should be noted that GL 8913 allows an alternative action of frequent regular maintenance in lieu of testing for degraded performance of the heat exchanger. Both regular maintenance (bimonthly PM and annual overhaul) and performance trending will be done for the Control Building Chillers.

0112207203 59280320148 The plant will improve the Containment Integrity is no longer SIXTYDAY containment closeout inspection required, and Containment Closeout will RESPONSE TO procedure to specifically address no longer be required. There are no NRC BULLETIN dirt, dust, and small debris safety related components housed in the 200301 accumulation. RB.

0112207227 6710972253 GL 8910 closeout letter 671097 Based on Permanent Shutdown Status at GL 8910 CLOSE 2253 committed to: TMI, and implementation of the PDTS, OUT LETTER 1. TMI1 maintenance procedures there are no active safety system at TMI.

for the MOVs will be revised to The MOV program is no longer required ensure that any work on valve and will be abandoned.

internals is evaluated for potential effects on stem thrust requirements. This will ensure that post maintenance dynamic testing is considered when appropriate.

These changes will be completed during the next operating cycle, TMI1 Operating Cycle 12.

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 6 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112207228 19209820242 In response to NRC Generic Letter Based on Permanent Shutdown Status at RESPONSE TO 9605, Three Mile Island Unit 1 TMI, and implementation of the PDTS, NRC'S SAFETY committed to implement the Joint there are no active safety system at TMI.

EVALUATION Owners Group (JOG) Program for The JOG MOV program is no longer JOINT OWNER'S Motor Operated Valve Periodic required and will be abandoned.

GROUP Verification in accordance with MPR PROGRAM ON 1807 (Interim) and MPR2524A PERIODIC Rev.1 (Final). Note: Not all GL9605 VERIFICATION OF MOV Program Valves are within the MOVS scope of the Final JOG Program.

0112207230 GL 96005: RAI In response to item 3 of the NRC Based on Permanent Shutdown Status at REGARDING Request for Additional Information TMI, and implementation of the PDTS, GPUN'S dated 11/5/1998, the licensee there are no active safety system at TMI.

RESPONSE TO GL committed to address potential age The JOG MOV program is no longer 96005 FOR related degradation by performing required and will be abandoned.

TMINS TMI1 the periodic static diagnostic or PERIODIC preventive maintenance of MOV as VERIFICATION OF required by the JOG program.

DESIGNBASIS CAPABILITY OF SAFETYRELATED MOTOR OPERATED VALVES (M97111) 0112207232 19209820605 GPUN letter (19209820605) Containment is no longer a safety related GL 9804, GPUN committed to evaluate the guidance component and maintaining Safety RESPONSE provided in EPRI TR109937, Related coatings program is no longer "Guideline on Nuclear SafetyRelated required.

Coatings," dated April 1998 and implement any changes by 12/31/99.

0112207235 GQL 1202 GPUN COMMITTED TO THE NRC IN Based on Permanent Shutdown Status at IEB 7901A: ASCO RESPONSE TO THE ORIGINAL TMI, and implementation of the PDTS, SOLENOID VALVE BULLETIN THAT MAINTENANCE there are no active safety system at TMI.

SERVICE LIFE PROCEDURE 1401P14 APPROVED The need to maintain ASCO solenoid TO IMPROVE FUTURE valve controls are no longer required.

MAINTENANCE. MP 1410P14 PROVIDED UPGRADED DETAILED OVERHAUL AND ALIGNMENT INSTRUCTIONS AND REQUIRED MORE DETAILED DOCUMENTATION OF BOTH "ASFOUND" AND "AS LEFT" PUMP CONDITIONS.

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 7 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112207237 IEB 7915: DEEP GPUN COMMITTED TO THE NRC IN Based on Permanent Shutdown DRAFT PUMP RESPONSE TO THE ORIGINAL BULLETIN Status at TMI, and implementation DEFICIENCIES THAT MAINTENANCE PROCEDURE of the PDTS, there are no active 1401P14 APPROVED TO IMPROVE safety system at TMI. These systems FUTURE MAINTENANCE. MP 1410P14 are no longer required to meet PROVIDED UPGRADED DETAILED ASME Section XI IST requirements.

OVERHAUL AND ALIGNMENT INSTRUCTIONS AND REQUIRED MORE DETAILED DOCUMENTATION OF BOTH "ASFOUND" AND "ASLEFT" PUMP CONDITIONS.

01122072 IEB 8012: DECAY GPUN COMMITTED TO THE NRC TO: 1) This will no longer be required since 3800 HEAT REMOVAL MODIFICATION OF OP 11044 TO Decay Heat and the BWST are no SYSTEM PROVIDE ADDITIONAL longer TS required functions to OPERABILITY ADMINISTRATIVE CONTROL OVER THE protect. There will no longer be fuel POSITION OF DHV6A AND DHV6B stored in the RPV to protect.

(REACTOR BUILDING SUMP ISOLATION VALVES). DURING COLD SHUTDOWN AND REFUELING SHUTDOWN CONDITIONS, THE VALVES (EXCEPT DURING TESTING) WILL BE TAGGED CLOSED WITH THEIR BREAKERS OPEN TO PREVENT INADVERTENT OPENING AND POTENTIAL DRAINING OF THE BORATED WATER STORAGE TANK (BWST) TO THE REACTOR BUILDING SUMP.

0112207242 IEB 7925: GPUN COMMITTED TO THE NRC Based on Permanent Shutdown FAILURE OF WITHIN TLL 005 DATED 1/10/80 THAT: Status at TMI, and implementation WESTINGHOUSE (1) TMI1 USED WESTINGHOUSE TYPE of the PDTS, there are no active BFD RELAYS IN BFD, STYLE 5072A49, COIL STYLE safety system at TMI. The SAFETY RELATED 1271C50G01 RELAYS AS CONTROL Emergency Diesel Generators are no SYSTEMS RELAYS FOR THE 1A AND 1B longer safety related and this EMERGENCY DIESEL GENERATORS. commitment is no longer applicable.

(2) THE DIESEL GENERATOR ANNUAL INSPECTION PROCEDURE WAS REVISED TO INCLUDE A FUNCTIONAL TEST ON EACH RELAY.

(3) THE DOCUMENTATION OF ALL RELAY FAILURES FOUND DURING THE INITIAL OR FOLLOWUP PROGRAM TESTING IN ACCORDANCE WITH THE REQUIREMENTS SET FORTH IN THE BULLETIN.

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 8 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Number Document 0112207244 GL 8121: NATURAL CIRCULATION COOLDOWN With certification required by 50.82 NATURAL PROCEDURES & TRAINING. submitted, TMI is no longer permitted to CIRCULATION operate or store fuel in the reactor COOLDOWN vessel. The protection afforded by this commitment is no longer required.

0112207247 5211822149 TOTAL AND PARTIAL LOSS OF With certification required by 50.82 IEB 7927: LOSS ICS/NNI POWER EMERGENCY submitted, TMI is no longer permitted to OF NONCLASS PROCEDURES. operate or store fuel in the reactor 1E vessel. The protection afforded by this INSTRUMENTATI commitment is no longer required.

ON AND CONTROL 0112207249 5211832040 COV10A/B LOCKED OPEN EFW is no longer required. With GL 8114: EFW REQUIREMENT. certification required by 50.82 SEISMIC submitted, TMI is no longer permitted to QUALIFICATION operate or store fuel in the reactor ATTACHMENTS vessel. The protection afforded by this ITEM 4 commitment is no longer required.

0112207250 5211832055 EFW SEISMIC QUALIFICATION EFW is no longer required. With GL 8114: EFW Attachment(s): GPUN COMMITTED certification required by 50.82 SEISMIC TO THE NRC TO LOCK OPEN THE submitted, TMI is no longer permitted to QUALIFICATION RECIRCULATION LINES ON THE operate or store fuel in the reactor ATTACHMENTS EMERGENCY FEEDWATER (EFW) vessel. The protection afforded by this ITEM 4 PUMPS. commitment is no longer required.

0112207252 5211832133: EFW SEISMIC QUALIFICATION CO EFW is no longer required. With EFW SEISMIC V27A/B certification required by 50.82 QUALIFICATION Attachment(s): GPUN COMMITTED submitted, TMI is no longer permitted to TO THE NRC TO LOCK CLOSE THE operate or store fuel in the reactor VALVES COV27A AND COV27B vessel. The protection afforded by this DURING OPERATION. commitment is no longer required.

0112207254 5211832330 ATWS REVIEW ITEMS FROM GL 83 This event requires the reactor to be in GL 8328 ITEM 28. operations. With certification required 3.1.1: POSTTRIP by 50.82 submitted, TMI is no longer REVIEW permitted to operate or store fuel in the reactor vessel. The protection afforded by this commitment is no longer required.

0112207256 5211833222: NATURAL CIRCULATION COOLDOWN Natural Circulation cooldown requires NATURAL PROCEDURE. the plant to be in operations. With CIRCULATION certification required by 50.82 COOLDOWN submitted, TMI is no longer permitted to (GENERIC LETTER operate or store fuel in the reactor 8121) vessel. The protection afforded by this commitment is no longer required.

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 9 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Number Document 0112207257 5211832330 ITEM 2.1 REQUIRED THE Since no longer permitted to operate or GL 8328 ITEM CONFIRMATION THAT ALL place fuel in the reactor vessel, Reactor 2.1: EQUIPMENT COMPONENTS WHOSE FUNCTIONING Protection/Trip is no longer required.

CLASSIFICATION WAS REQUIRED TO TRIP THE Reactor Protection is no longer a safety AND VENDOR REACTOR WERE IDENTIFIED AS related system.

INTERFACE (RTS) SAFETY RELATED ON ALL DOCUMENTATION AND IN INFORMATION HANDLING SYSTEMS THAT WERE USED TO CONTROL ALL ACTIVITIES PERFORMED ON THAT SAFETY RELATED EQUIPMENT. THE NRC.

SER 5211873170 ACCEPTED THE GPUN RESPONSE AND CLOSED THE ITEM.

0112207258 5211832330 GPUN COMMITTED TO THE NRC THAT Since no longer permitted to operate or GL 8228 SEC SP 13134.1 PERFORMED ON LINE place fuel in the reactor vessel, Reactor 4.5.1: REACTOR TESTING OF THE REACTOR TRIP Protection/Trip is no longer required.

TRIP SYSTEM SYSTEM (RTS) ON A MONTHLY BASIS:

ONLINE SP 13134.4 INCORPORATED THE FUNCTIONAL CRDCS SCR TRIP TEST GUIDELINES TESTING PROVIDED BY BABCOCK & WILCOX: SP 13034.1 WAS REVISED TO INCORPORATE TESTING OF TRIPPING THE CRDM POWER FEED CIRCUIT BREAKERS VIA THEIR SHUNT TRIP DEVICES.

0112207259 5211832330 PLANT COMPUTER SYSTEM POSTTRIP Since no longer permitted to operate or GL 8328 ITEM CHECKLIST GPUN COMMITTED TO place fuel in the reactor vessel, Reactor 1.2: POST TRIP THE NRC TO INCORPORATE A Protection/Trip is no longer possible and REVIEW (DATA CHECKLIST OF PLANT COMPUTER post trip review is not required.

AND SYSTEM PARAMETERS FOR REACTOR INFORMATION TRIP INTO TMI1 PROCEDURES TO CAPABILITY) ENSURE ASSEMBLY OF COMPLETE DATA PACKAGE.

0112207260 5211832330 GPUN COMMITTED TO THE NRC TO Since no longer permitted to operate or GL 8228 ITEM INCORPORATE METHODS AND place fuel in the reactor vessel, Reactor 1.2: POST TRIP CRITERIA FOR COMPARING THE Protection/Trip is no longer possible and REVIEW (DATA EVENT INFORMATION WITH KNOWN post trip review is not required.

AND OR EXPECTED BEHAVIOR.

INFORMATION CAPABILITY)

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 10 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112207261 5211832330 POSTTRIP REVIEW & ANALYSIS Since no longer permitted to operate or GL 8328 ITEM ROLE & RESPONSIBILITY. place fuel in the reactor vessel, Reactor 1.1: POSTTRIP Protection/Trip is no longer possible and REVIEW post trip review is not required.

(PROGRAM DESCRIPTION AND PROCEDURE)

ROLES 0112207262 5211832330 RESTART DECISION PREREQUISITE Since no longer permitted to operate or GL 8228 ITEM ACTIONS. place fuel in the reactor vessel, Reactor 1.1: POSTTRIP Protection/Trip is no longer possible and REVIEW post trip review is not required.

(PROGRAM DESCRIPTION AND PROCEDURE)

RESTART 0112207263 5211832330 INDEPENDENT REVIEW INITIATING Since no longer permitted to operate or GL 8228 ITEM CRITERIA. place fuel in the reactor vessel, Reactor 1.1: POSTTRIP Protection/Trip is no longer possible and REVIEW post trip review is not required.

(PROGRAM DESCRIPTION AND PROCEDURES) 0112207265 5211822229 POTENTIAL OF ERRONEOUS LEVEL The temperature effect on the Steam IEB 7921: INDICATIONS Generators or Pressurizer are related to TEMPERATURE Attachment(s): GPUN COMMITTED Normal Operating Pressure and EFFECTS ON TO THE NRC TO REVISE Temperatures conditions with respect to LEVEL PROCEDURES 12026A, 12026B, cold conditions. Both of the instruments MEASUREMENTS 12026C AND 120324 TO REMIND are in the Reactor Coolant System which is THE OPERATORS OF THE no longer safety related. The conditions POTENTIAL OF are no longer plausible since TMI is no ERRONEOUS STEAM GENERATOR longer permitted to operate or place fuel AND PRESSURIZER LEVEL in the reactor vessel.

INDICATIONS.

0112207266 5211832330 REACTOR TRIP SYSTEM TRIP Since no longer permitted to operate or GL 8328 ITEM FEATURE TESTING. place fuel in the reactor vessel, Reactor 4.5.1: REACTOR Protection/Trip is no longer required.

TRIP SYSTEM RELIABILITY (SYSTEM FUNCTIONAL TESTING)

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 11 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112207271 5211842286 REFUELING CAVITY WATER SEAL Since Fuel is no longer permitted to be IEB 8403: FAILURE placed in the reactor vessel, this action is POTENTIAL FOR Attachment(s): GPUN COMMITTED IN no longer required to protect the decay REFUELING THE RESPONSE 5211842286 THAT heat removal or protection of fuel in the CAVITY WATER THE POTENTIAL FOR AND reactor pressure vessel.

SEAL FAILURE CONSEQUENCES OF A REFUELING CAVITY SEAL GASKET FAILURE HAS BEEN REVIEWED AND SUBMITTED A

SUMMARY

REPORT TO THE NRC.

0112207274 5211842072 HEAVY LOADS INCORE Since fuel is no longer permitted to be NUREG 0612: INSTRUMENTATION placed in the reactor pressure vessel, CONTROL OF Attachment(s): GPUN COMMITTED heavy loads protection is no longer HEAVY LOADS TO THE NRC TO REVISE PROCEDURE required in the Reactor Building.

15081 ON INCORE INSTRUMENTATION PER ITEM 3 OF THE GPU CONTROL OF HEAVY LOADS IMPLEMENTATION SCHEDULE SO THAT THE PROCEDURE SATISFIED THE REQUIREMENTS OF 5.1.1(2) OF NUREG0612.

0112207276 5211842156 NATURAL CIRCULATION COOLDOWN No longer permitted to operate reactor GL 8121: PROCEDURE CHANGE. or place fuel in the reactor pressure GENERIC LETTER vessel, therefore this mitigation strategy 8121 NATURAL is no longer required.

CIRCULATION COOLDOWN 0112207278 5211852182 THREADED FASTENER DEGRADATION The RCS pressure boundary is no longer IEB 8202: IN RCS BOUNDARY. safety related, per 50.82(a)2 TMI is no DEGRADATION OF longer permitted to operate or place fuel THREADED in reactor vessel.

FASTENERS IN RC PRESSURE BOUNDARY 0112207279 5211842147 HEAVY LOADS PROCEDURE SLING Since fuel is no longer permitted to be NUREG 0612: SELECTION/APPROVAL placed in the reactor pressure vessel, CONTROL OF Related to RPV Seal Plate. heavy loads protection is no longer HEAVY LOADS required in the Reactor Building.

0112207281 5211842200 POLAR CRANE OP PROC CRANE Since fuel is no longer permitted to be NUREG 0612: INSPECTION REQUIREMENT placed in the reactor pressure vessel, CONTROL OF Attachment(s): GPUN COMMITTED heavy loads protection is no longer HEAVY LOADS TO THE NRC TO REVISE PROCEDURE required in the Reactor Building.

RP 15071 POLAR CRANE OPERATION TO INCLUDE A REQUIREMENT FOR INSPECTION PRIOR TO EACH LIFT USING SLINGS OR OTHER APPROVED DEVICES.

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 12 of 44 Table 2 (Continued)

Commitment Commitment Source Commitment Details Basis for Deletion Tracking Number Document 011220728300 5211842242 DIESEL GENERATOR RELIABILITY Once the certification of GL 8415: PROPOSED IMPROVEMENTS. 50.82(a)2 were completed, TMI is STAFF ACTIONS TO no longer permitted to operate or IMPROVE & MAINTAIN place fuel in the reactor vessel, DG RELIABILITY therefore with the implementation of the PDTS the Emergency Diesel Generators are no longer safety related.

011220728500 5211842179 BORON PRECIPITATION SHIELDING Once the certification of NUREG 0737 II.B.2: TMI GPUN COMMITTED TO THE NRC TO 50.82(a)2 were completed, TMI is ACTION PLANT LOCK OPEN THE VALVE DHV12B no longer permitted to operate or SECTION II.B.2 DH AND TO INSTALL A REACH ROD FOR place fuel in the reactor vessel, PLANT SHIELDING DHV64 SO THAT SUFFICIENT Post LOCA conditions are no OPTION FLOW IS AVAILABLE FOR CORE longer applicable therefore the COOLING AND BORON protection afforded by this PRECIPITATION PREVENTION commitment is no longer UNDER WORST CASE SINGLE required.

FAILURES WITHOUT REQUIRING MANUAL ACTION IN AN INACCESSIBLE HIGH RADIATION AREA.

011220728600 5211842153: ATP COMMITMENTS FROM ATOG Once the certification of CONTROL ROOM COMMITTEE 50.82(a)2 were completed, TMI is DESIGN REVIEW GPUN COMMITTED TO THE NRC no longer permitted to operate or SUPPLEMENTAL THE FOLLOWING ACTIONS: place fuel in the reactor vessel, REPORT (NUREG 0737 (1) REVISE PROCEDURE 12107 STEP and there are no transients/ATP I.D.1) 10 TO REDUCE THE RUNOUT LIMIT required for the protection of the OF 1800 GPM TO A VALUE OF 1750 spent fuel pool.

GPM. (Historical see UPDATE 8/16/07 below)

(2) REVISE PROCEDURE 12107 SECTION 2.0 STEP 10 THAT THE PROCEDURAL LIMIT BE STATED IN TERMS OF THE NET PUMP FLOW AS INDICATED ON THE CONTROL ROOM INDICATOR. (Ongoing)

(3) REVISE PROCEDURE 121010 THAT THE MAKEUP PUMP PROCEDURAL LIMITS BE STATED IN TERMS OF NET INJECTION THROUGHT THE VIG'S.

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 13 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112207288 5211832149 SG SHELL TO TUBE DIFFERENTIAL Once the certification of 50.82(a)2 were NUREG 1019 TEMPERATURE LIMIT. completed, TMI is no longer permitted to SUPP 1: STEAM operate or place fuel in the reactor GENERATOR TUBE vessel, therefore the Steam Generators REPAIR AND are no longer safety related, and the RETURN TO protections provided by this OPERATION commitment is no longer required.

0112207289 5211832149 ISOLATED STEAM GENERATOR Once the certification of 50.82(a)2 were NUREG 1019 PRESSURE CONTROL. completed, TMI is no longer permitted to SUPP 1: STEAM operate or place fuel in the reactor GENERATOR TUBE vessel, therefore the Steam Generators REPAIR AND are no longer safety related, and the RETURN TO protections provided by this OPERATION commitment is no longer required.

0112207291 5211843249: CRDM CIRCUIT BREAKER TRIPPING Once the certification of 50.82(a)2 were SER ACCEPTANCE MECHANISM TESTING. completed, TMI is no longer permitted to OF RESPONSE TO operate or place fuel in the reactor GL 8328 ATWS vessel, therefore Anticipated Transient ITEM 4.3 without SCRAM protection is no longer REACTOR TRIP; required.

5211843249:

SYSTEM RELIABILITY 0112207294 5211842013 PROCEDURES FOR HEAVY LOADS IN Since fuel is no longer permitted to be NUREG 0612: REACTOR BUILDING. placed in the reactor pressure vessel, CONTROL OF heavy loads protection is no longer HEAVY LOADS required in the Reactor Building 0112207295 5211842013 RV HEAD REMOVAL & INSTALLATION Since fuel is no longer permitted to be NUREG 0612: LIFT HEIGHT RESTRICTION. placed in the reactor pressure vessel, CONTROL OF heavy loads protection is no longer HEAVY LOADS required in the Reactor Building.

0112207296 5211842013 RB POLAR CRANE SPECIAL LIFTING Since fuel is no longer permitted to be NUREG 0612: DEVICES. placed in the reactor pressure vessel, CONTROL OF heavy loads protection is no longer HEAVY LOADS required in the Reactor Building.

0112235501 5211862034 EFW PUMP STEAM BINDING PUMP Once the certification of 50.82(a)2 were IEB 8501: STEAM RESTORATION. completed, TMI is no longer permitted to BINDING OF operate or place fuel in the reactor AUXILIARY vessel, therefore emergency feedwater is FEEDWATER no longer a safety related system.

PUMP 0112235502 5211862034 EFW PUMP STEAM BINDING Once the certification of 50.82(a)2 were IEB 8501: STEAM TEMPERATURE CHECKS. completed, TMI is no longer permitted to BINDING OF operate or place fuel in the reactor AUXILIARY vessel, therefore emergency feedwater is FEEDWATER no longer a safety related system.

PUMP

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 14 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Number Document 0112235504 5211842200 HEAD & INTERNALS HANDLING FIXTURE Since fuel is no longer permitted NUREG 0612: WELD ISI PROG. to be placed in the reactor CONTROL OF pressure vessel, heavy loads HEAVY LOADS protection is no longer required in the Reactor Building.

0112235506 5211852092 REACTOR TRIP BREAKER MAINTENANCE. Once the certification of 50.82(a)2 Source were completed, TMI is no longer Document

Title:

permitted to operate or place fuel GL 8328 ITEM in the reactor vessel, therefore 4.2.1: PERIODIC Anticipated Transient without MAINTENANCE SCRAM protection is no longer PROGRAM FOR required.

REACTOR TRIP BREAKERS 0112235509 5211842013 HEAVY LOADS PROCEDURE HEAD & Since fuel is no longer permitted NUREG 0612: INTERNALS HANDLING. to be placed in the reactor CONTROL OF pressure vessel, heavy loads HEAVY LOADS protection is no longer required in the Reactor Building.

0112235518 5211862186 GPUN COMMITTED TO THE NRC THAT TMI1 Once the certification of 50.82(a)2 IEB 8603: DOES HAVE A SINGLE RECIRCULATION LINE were completed, TMI is no longer POTENTIAL FOR THE HIGH PRESSURE INJECTION (HPI) permitted to operate or place fuel FAILURE OF PUMPS WHICH ARE ISOLATED in the reactor vessel, therefore MULTIPLE ECCS AUTOMATICALLY ON EMERGENCY any requirement related to ECCS PUMPS DUE TO SAFEGUARDS (ES) ACTUATION. performance criteria are no longer SINGLE FAILURE required.

0112235522 5211862021 CHECK VALVE FAILUREDIESEL GENERATOR EDG no longer safety related which references COOLING SYSTEM.

521183176 IEB 8303:

CHECK VALVE FAILURE IN DIESEL GENERATOR COOLING SYSTEM 0112235531 5211842013: POLAR CRANE SAFE LOAD PATH FOR RB Since fuel is no longer permitted RESPONSE TO REGION D2. to be placed in the reactor NUREG 0612 pressure vessel, heavy loads CONTROL OF protection is no longer required in HEAVY LOADS the Reactor Building.

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 15 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112235535 C311882087 IEB 8804 ITEM 3: POTENTIAL SAFETY Once the certification of 50.82(a)2 IEB 8804: RELATED PUMP LOSS were completed, TMI is no longer POTENTIAL GPUN COMMITTED INTERNALLY THAT permitted to operate or place fuel in SAFETY RELATED IN RESPONSE TO IEB 8804 ITEM 3 AN the reactor vessel, there are no longer PUMP LOSS INDEPTH STUDY TO PREDICT PUMP any safety related pumps and the DAMAGE AND VERIFY PUMP protection provided by this MINIMUM FLOW REQUIREMENTS WAS commitment is no longer required.

NOT NECESSARY WHEN CONSIDERING THAT THE CURRENT INSERVICE TEST (IST) PROGRAM WAS IN PLACE TO DETECT SUCH DAMAGE.

0112235537 C311882138 EXAMINATION OF THREADED The RCS pressure boundary is no IEB 8202: FASTENERS PRIOR TO REUSE longer safety related, per 50.82(a)2 DEGRADATION OF GPUN COMMITTED TO THE NRC TO TMI is no longer permitted to operate THREADED PERFORM VISUAL EXAMINATIONS ON or place fuel in reactor vessel.

FASTENERS IN ALL REACTOR COOLANT PRESSURE THE RCPB OF BOUNDARY (RCPB) FASTENERS PRIOR PWR PLANTS TO REUSE AND TO PERFORM MAGNETIC PARTICLE (MT) OR PENETRANT EXAMINATIONS (PT) ALSO UNLESS THE RCPB FASTENER HAS ONLY EXPERIENCED SHORT TERM SERVICE LESS THAN OR EQUAL TO 3 MONTHS SINCE ITS LAST MT OR PT AND THE FASTENER WAS FOUND DRY AND WITHOUT EVIDENCE OF BORIC ACID CRYSTALS OR RUST.

0112235534 C311882087 ADEQUATE MINIMUM PUMP Once the certification of 50.82(a)2 IEB 8804: RECIRCULATION FLOW were completed, TMI is no longer POTENTIAL GPUN COMMITTED TO THE NRC THAT permitted to operate or place fuel in SAFETY RELATED ALL PUMPS IN TMI1 SAFETYRELATED the reactor vessel, there are no longer PUMP LOSS SYSTEMS EVALUATED WITHIN IEB 88 any safety related pumps and the 04 RESPONSE WHICH HAD THE protection provided by this MINIMUM RECIRCULATION commitment is no longer required.

REQUIREMENT HAD ADEQUATE MINIMUM RECIRCULATION FLOW IN ACCORDANCE WITH THE PUMP SPECIFICATIONS.

0112235538 C311882165 GL 8817: GENERIC LETTER 8817 Once the certification of 50.82(a)2 GL 8817: EXPEDITIOUS ACTION 2. were completed, TMI is no longer GENERIC LETTER permitted to operate or place fuel in 8817 the reactor vessel, therefore Decay EXPEDITIOUS Heat in the reactor vessel is no longer ACTION 2 required. Therefore, any protection provided by this commitment is no longer required.

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 16 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Number Document 0112235539 C311882165 CONTINUOUS CORE EXIT Once the certification of 50.82(a)2 were GL 8817: TEMPERATURE MONITORING. completed, TMI is no longer permitted GENERIC LETTER to operate or place fuel in the reactor 8817 vessel, therefore Decay Heat in the EXPEDITIOUS reactor vessel is no longer required.

ACTION 3 AND Therefore, any protection provided by PROGRAMMED this commitment is no longer required.

ENHANCEMENT; GL 8817: 1(B) 0112235540 C311882165 GL 8817: GENERIC LETTER 8817 Once the certification of 50.82(a)2 were GL 8817: EXPEDITIOUS ACTION 4 AND completed, TMI is no longer permitted GENERIC LETTER PROGRAMMED ENHANCEMENT; GL to operate or place fuel in the reactor 8817 8817: 1(A). vessel, therefore Decay Heat in the EXPEDITIOUS reactor vessel is no longer required.

ACTION 4 AND Therefore, any protection provided by PROGRAMMED this commitment is no longer required.

ENHANCEMENT; GL 8817: 1(A) 0112235541 C311882165 PROCEDURAL OPS GUIDANCE Once the certification of 50.82(a)2 were GL 8817: REDUCED INVENTORY completed, TMI is no longer permitted GENERIC LETTER PERTURBATIONS TO THERCS to operate or place fuel in the reactor 8817 vessel, therefore Decay Heat in the EXPEDITIOUS reactor vessel is no longer required.

ACTION 5 Therefore, any protection provided by this commitment is no longer required.

0112235542 C311892015 RCS INVENTORY ADDITION OTHER Once the certification of 50.82(a)2 were GL 8817: THAN DHR SYSTEM PUMPS. completed, TMI is no longer permitted GENERIC LETTER to operate or place fuel in the reactor 8817 vessel, therefore Decay Heat in the EXPEDITIOUS reactor vessel is no longer required.

ACTION 6 AND Therefore, any protection provided by PROGRAMMED this commitment is no longer required.

ENHANCE

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 17 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112235543 C311892015 GPUN COMMITTED TO THE NRC TO Once the certification of 50.82(a)2 GL 8817: MAKE PROCEDURAL CHANGES IN were completed, TMI is no longer GENERIC LETTER ADDITION TO THOSE COMMITTED TO permitted to operate or place fuel 8817 WITHIN 5211872188 AND 521188 in the reactor vessel, therefore PROGRAMMED 2165 BY JULY 1989 TO IMPROVE Decay Heat in the reactor vessel is ENHANCEMENT 2 OPERATOR GUIDANCE IN THE no longer required. Therefore, any (PROCEDURES) FOLLOWING FOUR AREAS: protection provided by this BASED ON; GL 88 1) THE TIME BEFORE CORE BOILING AND commitment is no longer required.

17: ANALYSIS CORE UNCOVERY FOLLOWING A LOSS OF DECAY HEAT REMOVAL (DHR).

2) PROVIDING SUFFICIENT REACTOR COOLANT SYSTEM (RCS) VENT AREA TO PERMIT ADEQUATE MAKEUP FLOW.
3) CONTAINMENT CLOSURE REQUIREMENTS.
4) RESTART OF DHR FROM SATURATED CONDITIONS.

0112235544 GENERIC LETTER GPUN COMMITTED TO THE NRC THE Once the certification of 50.82(a)2 8817 FOLLOWING VISUAL OR AUDIBLE were completed, TMI is no longer PROGRAMMED INDICATORS WERE AVAILABLE IN THE permitted to operate or place fuel ENHANCEMENT CONTROL ROOM TO ASSIST THE in the reactor vessel, therefore 1(D) OPERATOR IN THE IDENTIFICATION OF Decay Heat in the reactor vessel is (INSTRUMENTATI ABNORMAL CONDITIONS WHICH AFFECT no longer required. Therefore, any ON) HEAT REMOVAL. protection provided by this commitment is no longer required.

0112235546 GL 8904: GPUN IS COMMITTED TO THE GUIDANCE Once the certification of 50.82(a)2 GUIDANCE ON IN GL 8904 "GUIDANCE ON DEVELOPING were completed, TMI is no longer DEVELOPING ACCEPTABLE IST PROGRAMS" BY VIRTUE permitted to operate or place fuel ACCEPTABLE IST OF THE FACT THAT THIS GL WAS ISSUED in the reactor vessel, therefore with PROGRAMS TO LICENSEES. THE GL CONTAINS the implementation of the PDTS INTERPRETATIONS AND ADDITIONAL there are no longer any safety GUIDANCE THAT MAY DIFFER FROM TMI related pumps or valves and the IST 1 PROGRAMS AND PROCEDURES. program is no longer required.

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 18 of 44 Table 2 (Continued)

Commitment Commitment Source Commitment Details Basis for Deletion Tracking Document Number 0112235547 C311892032 GPUN COMMITTED TO THE NRC: Once the certification of IEB 8804: POTENTIAL 1) THE DHR PUMP MINIMUM 50.82(a)2 were completed, TMI SAFETY RELATED RECIRCULATION CAPACITY WAS is no longer permitted to PUMP LOSS ADEQUATE TO ENSURE THAT PUMP operate or place fuel in the OPERABILITY WAS NOT AFFECTED BY reactor vessel, therefore with MINIMUM RECIRCULATION OPERATION. the implementation of PDTS

2) ADDITIONAL VIBRATION READINGS Decay Heat is not safety WERE INCORPORATED INTO THE related, and the protection SURVEILLANCE TEST PROCEDURES OPTM provided by this commitment is 212201 / 202 / 203 / 204 / 205 / 206 no longer required.

13035.2 AND 13003A/B.

3) THE REVISION BY JUNE 1989 OF PROCEDURES TO PROVIDE ADDITIONAL GUIDANCE THAT WILL APPLY WHEN HIGHER VIBRATION LEVELS ARE ENCOUNTERED AT BLADE PASSING FREQUENCY WHILE OPERATING OR TESTING THE DHR PUMPS AT MINIMUM RECIRCULATION FLOW RATE.
4) THE COMPLETION OF STEPS TO MINIMIZE THE TIME THAT DHR PUMPS ARE OPERATED AT MINIMUM FLOW DURING TESTING.
5) THE NOTIFICATION OF THE NRC BY LETTER OF ANY ADDITIONAL ACTIONS THAT MAY BE REQUIRED IN THE FUTURE.

ALSO, TO PROVIDE THE JUSTIFICATION FOR CONTINUED OPERATION AS REQUESTED BY IEB 8804.

0112235548 5450890103 NRC COMMITTED GPUN TO USE SPECIFIC Once the certification of GL 8331: SE OF GENERIC GUIDANCE AS PROVIDED BY THE 50.82(a)2 were completed, TMI ABNORMAL B&W OWNERS GROUP WHEN AVAILABLE. is no longer permitted to TRANSIENT DEVIATIONS FROM THAT GUIDANCE TO BE operate or place fuel in the OPERATING ADDRESSED BY EACH LICENSEE. reactor vessel, there are no GUIDELINES longer any design basis threats that require any abnormal transient guidelines.

0112235550 C311892078 GPUN COMMITTED TO THE NRC TO Once the certification of GL 8908: GL 8908 MODIFY THE EXISTING 50.82(a)2 were completed, TMI EROSION/CORROSION EROSION/CORROSION MONITORING is no longer permitted to INDUCED PIPE WALL PROGRAM AT TMI1 TO PROVIDE A LONG operate or place fuel in the THINNING TERM CORPORATE LEVEL APPROACH. THIS reactor vessel, therefore there WILL BE COMPLETE IN TIME TO SUPPORT is no condition that in the spent 09R OUTAGE SCHEDULED INSPECTIONS. fuel pool that would create a erosion/corrosion or pipe wall thinning event.

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 19 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Number Document 0112235551 C311892068: GPUN COMMITTED TO THE NRC TO INCLUDE Once the certification of 10CFR50 A NOTE IN EP 120237, ITEM 13.K, TO THE 50.82(a)2 were completed, TMI is APPENDIX R GL OPERATOR THAT A FAILED OPEN RCV1 MAY no longer permitted to operate or 8112 RESPONSE BE INDICATED BY RAPID RCS place fuel in the reactor vessel, TO NRC DEPRESSURIZATION, IN ORDER TO ENSURE Appendix R fire protection is no QUESTIONS CORRECTION OF SPURIOUS OPENING OF RC longer required, and in the V1 DUE TO A FIRE. decommissioning state fire GPUN ALSO COMMITTED TO EXERCISING protection is bounded by 480V MOLDED CASE BREAKERS IN 50.48(f).

ACCORDANCE WITH PROCEDURES; TO PROVIDE GUIDANCE IN 1420Y13 TO MAINTENANCE PERSONNEL THAT WHEN REPLACING FUSES, THEY ARE TO BE REPLACED WITH THE SAME SIZE AND TYPE AS THE FUSE REMOVED, TO REFER TO DRAWINGS, VENDOR MANUALS, OR OTHER REFERENCES IF THE SIZE AND TYPE CANNOT BE DETERMINED, OR REQUEST PLANT ENGINEERING TO PROVIDE APPROPRIATE RESOLUTION; TO UTILIZE THE GPUN OPERATIONAL QA PLAN FOR COMMERCIAL GRADE DEDICATION OF FUSES FOR SAFETY RELATED APPLICATIONS.

0112235552 C311902001 GPUN COMMITTED TO THE NRC TO REVISE Once the certification of IEB 8903: PROCEDURES GOVERNING FUEL LOADING TO 50.82(a)2 were completed, TMI is POTENTIAL LOSS REFLECT THE FACT THAT FUEL ASSEMBLIES no longer permitted to operate or OF REQUIRED WILL NORMALLY ONLY BE LOADED INTO place fuel in the reactor vessel, SHUTDOWN THEIR FINAL CORE LOCATIONS; HOWEVER, IF therefore the protection provided MARGIN DURING A FUEL ASSEMBLY IS TO BE PLACED INTO ANY by this commitment is no longer REFUELING OPS OTHER CORE LOCATION DUE TO FUEL required.

HANDLING CONSTRAINTS, IT SHALL ONLY BE PLACED INTO CORE LOCATIONS THAT WOULD CONTAIN AN ASSEMBLY OF EQUAL OR HIGHER REACTIVITY AS DETERMINED BY THE APPROVED CORE RELOAD DESIGN.

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 20 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112235553 C311893246 GL 8112: POSTFIRE SAFE SHUTDOWN Once the certification of 50.82(a)2 GL 8112: POST METHODOLOGY NRC. were completed, TMI is no longer FIRE SAFE permitted to operate or place fuel SHUTDOWN in the reactor vessel, Appendix R METHODOLOGY fire protection is no longer NRC TECHNICAL required, and in the EVALUATION; GL decommissioning state fire 8112: REPORT protection is bounded by 50.48(f).

0112235555 C311902031 GPUN COMMITTED TO THE NRC THAT Once the certification of 50.82(a)2 GL 8919: TMI1 OTSG OVERFILL PROTECTION IS were completed, TMI is no longer REQUEST FOR ADEQUATE BECAUSE OF THE OTSG HIGH permitted to operate or place fuel ACTION RELATED LEVEL ALARM RESPONSE PROCEDURES

  • in the reactor vessel, therefore the TO RESOLUTION AVAILABLE TO THE OPERATORS (MAIN Steam Generators are no longer OF USI A47 ANUNCIATOR PANEL H, H11 (REV 12)) safety related, and the protections AND BECAUSE OF THE FOLLOWING provided by this commitment is no SURVEILLANCES VERIFY THE OPERABILITY longer required.

AND CALIBRATION OF THE OTSG HIGH LEVEL MFW ISOLATION FEATURE OF THE HSPS.

0112235558 C311912015 GPUN COMMITTED TO THE NRC TO Once the certification of 50.82(a)2 IEB 8811: REDUCE FUTURE SURGE LINE THERMAL were completed, TMI is no longer PRESSURIZER CYCLES BY ADOPTING THE B&W permitted to operate or place fuel SURGE LINE RECOMMENDED LOWER (APPENDIX G) in the reactor vessel, therefore the THERMAL RCS SUBCOOLING MARGINS IN PLANT protection provided by this STRATIFICATION OPERATING AND PROCEDURES commitment is no longer required.

DECEMBER 20, PURSUANT TO ITS TOPICAL REPORT NO 1988 BAW2127 (FIGURE 8) AND "WHEN THE PREFERRED LOWER RCS SUBCOOLING MARGIN IS NOT MAINTAINED, (CONDUCT) AN EVALUATION OF ACTUAL PLANT PERFORMANCE, IN A PROGRAMMATIC MANNER, TO DETERMINE THE IMPACT(S) ON FATIGUE LIFE."

0112235559 C311912015 GPUN COMMITTED TO THE NRC TO Once the certification of 50.82(a)2 IEB 8811: ATAKE STEPS TO REDUCE FUTURE were completed, TMI is no longer PRESSURIZER (PRESSURIZER) SURGE LINE THERMAL permitted to operate or place fuel SURGE LINE CYCLES. in the reactor vessel, therefore the THERMAL protection provided by this STRATIFICATION commitment is no longer required.

DECEMBER 20, 1988

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 21 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112235561 C311922003: GPUN COMMITTED TO THE NRC THAT: Once the certification of STAFF REVIEW OF 1. STROKE TESTING IS PERFORMED AT 50.82(a)2 were completed, TMI is GL 9006 WYLE LABORATORIESA CERTIFIED OFFSITE no longer permitted to operate or FACILITY IN ACCORDANCE WITH place fuel in the reactor vessel, SPECIFICATION SP 110112087. TESTING IS therefore the protection provided PERFORMED AT NORMAL STEAM INLET by this commitment is no longer CONDITIONS AND VERIFIES BOTH required.

SETPOINTS; 2450 PSIG FOR POWER OPERATION AND 5592 PSIG FOR LTOP, CONDITIONS THAT ARE REPRESENTATIVE OF THE PORV OPERATING ENVIRONMENT.

2. 14012.1A, "REMOVE/INSTALL RCRV2 (PORV)" AND 13026.16 "SETPOINT AND REMOVE POSITION CHECK OF THE PORV (RCRV2)"," PROVIDES VERIFICATION OF PROPER REINSTALLATION OF THE PORV AND CONTROLS.
3. ALTHOUGH BENCH TESTING IS THE PREFERRED METHOD OF PORV TESTING, OPTM220203 PERMITS ACTUATION OF THE PORV IN PLACE AS AN ALTERNATIVE TEST METHOD. IN PLACE STROKE TESTING OF THE PORV USES STEAM AT RCS TEMPERATURE GREATER THAN 32913 DEGREES F AND RCS PRESSURE AT 500700 PSIG, CONDITIONS EQUIVALENT TO OR GREATER THAN STS MODE 3 AND MODE 4.

0112235562 C311932086 GPUN COMMITTED EXTERNALLY TO THE Once the certification of IEB 9302: DEBRIS NRC IN RESPONSE TO BULLETIN 9302 THAT 50.82(a)2 were completed, TMI is PLUGGING OF FIBROUS AIR FILTERS WHICH ARE no longer permitted to operate or ECCS SUCTION INSTALLED INSIDE CONTAINMENT ARE place fuel in the reactor vessel, STRAINERS PROTECTED FROM MIGRATING INTO THE therefore the protection provided REACTOR BUILDING SUMP PRIOR TO, OR by this commitment is no longer DURING A LOCA EVENT DUE TO ADEQAUTE required.

FILTER MAINTENANCE PROCEDURES, PROCEDURAL CONTROLS AND ENGINEERING EVALUATIONS WHICH DOCUMENT TEMPORARY SOURCES OF FIBROUS MATERIAL STORED IN CONTAINMENT, PROCEDURES WHICH REQUIRE REACTOR BUILDING WALKDOWNS AND INSPECTIONS PRIOR TO SETTING CONTAINMENT FOR PLANT OPERATIONS, AND PROCEDURAL CONTROLS

Commitment Change Summary Report Attachment Part B - Programmatic Commitments tied to Generic Communications Page 22 of 44 Table 2 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112235570 59280320148 The plant will develop a specific Once the certification of 50.82(a)2 were SIXTYDAY procedure for cleaning and completed, TMI is no longer permitted to RESPONSE TO inspecting the floor drains in operate or place fuel in the reactor NRC BULLETIN containment and will coordinate vessel, therefore there is no need to 200301 this work with the containment perform a containment close out closeout procedure. inspection. The protection provided by this commitment is no longer required.

0112235572 RESPONSE TO RAI TMI will revise the site EOPs to Once the certification of 50.82(a)2 were BULLETIN 2003 incorporate interim measures to completed, TMI is no longer permitted to 01 "POTENTIAL include initiating BWST refill after operate or place fuel in the reactor IMPACT OF switchover to recirculation from the vessel, the need for LOCA protection in DEBRIS containment sump. the RCS is no longer required.

BLOCKAGE ON EMERGENCY SUMP RECIRCULATION AT PRESSURIZED WATER REACTORS

Commitment Change Summary Report Attachment Part C - Programmatic Commitments tied to Licensing Actions Page 26 of 44 The following provides the update of programmatic commitments associated with Licensing Actions that impacted Technical Specifications (TS) that will be deleted based on the TMI-1 no longer being permitted to operate in accordance with 10 CFR 50.82(a)(2) and implementation of TS Amendment 297, which implemented the Permanently Defueled Technical Specifications.

Letter Source: Various - Refer to Table 3 for each item Exelon Tracking Number Various - Refer to Table 3 for each item Nature of Commitment: Table 3 lists open programmatic regulatory commitments for Three Mile Island, Unit 1 (TMI1), that are related to licensing actions (e.g. LARs). Technical Specification Amendments 295 and 297 were implemented on September 27, 2019 and represents the Permanently Defueled Technical Specifications (PDTS). The table contains the commitment number, the commitment source, a summary of the commitment, and basis for the deletion of the commitment.

Each of the original regulatory commitments listed in Table 3 will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.

Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 10 CFR 50.82(a)2 TMI1 is no longer permitted to operate or place fuel in the reactor vessel. The only risk is the safe storage of irradiated fuel in the Spent Fuel Pool. The regulatory commitments in Table 3 no longer afford the original intent and protection. Table 3 provides additional basis for each action item.

Table 3 Programmatic Commitments tied to Licensing Actions that are no longer applicable based on Permanent Shutdown Status Commitment Commitment Commitment Details Basis for Deletion Tracking Source Number Document 0112207204 59280420162 TSCR NO. 326 ELIMINATION OF No longer permitted to perform TSCR NO. 326 CONTAINMENT EQUIPMENT HATCH fuel emplacement in the RPV. TS CLOSURE DURING REFUELING 3.8 Fuel Loading and Refueling was Procedures will be in place which will deleted in TS Amendment 297.

require the placement of continuously operated particulate and radioiodine air sampling equipment inboard of the open containment equipment hatch opening during fuel loading and refueling activities.

Commitment Change Summary Report Attachment Part C - Programmatic Commitments tied to Licensing Actions Page 27 of 44 Table 3 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Number Document 0112207233 GQL0036 PERIODIC REACTOR COOLANT FLOW Based on the fact that TMI is no longer TS AMENDMENT VERIFICATION permitted to operate or place fuel in 17: NRC SER Licensee committed to verify the the vessel this verification would no DATED 5/18/76 reactor coolant flow rate will be verified longer be required. TS 3.5.1 for RPS every 6 months, plus or minus 30 days, inputs and its associated SRs were to be done by the heat balance deleted in Amendment 297.

technique described in the MetEd letter dated 4/8/76.

0112207245 NRC SER DATED ATMOSPHERIC STEAM DUMP VALVES With certification required by 50.82 8/28/81: ADV SPURIOUS OPENING. submitted, TMI is no longer permitted SPURIOUS to operate or store fuel in the reactor OPENING UPON vessel. TS 3.4.1 Decay Heat Removal LOSS OF NNI OR with T>250F was deleted by ICS Amendment 297.

0112207267 5211832014 FHB ISOLATION DAMPER INTERLOCK Technical Specification Amendment PERIODIC TESTING 297 provided a new Fuel Handling TESTING OF AUX Attachment(s): GPUN COMMITTED TO Accident in the Spent Fuel Pool, and AND FHB THE NRC TO REVISION OF THE concluded that Aux. Building and Fuel VENTILATION SURVEILLANCE PROCEDURE (SP) 1303 Handling Building ESF Ventilation is not SYSTEM 4.15 TO INCLUDE THE TESTING OF THE required for mitigation. TS 3.15.4 Fuel MODIFICATIONS FUEL HANDLING BUILDING Handling Building ESF Air Treatment (FHB) ISOLATION DAMPER INTERLOCKS System was deleted in TS Amendment WITH THE FHB VENTILATION SUPPLY 297.

FAN. THE EQUIPMENT WAS TESTED MONTHLY TO VERIFY PROPER OPERATION OF THE INTERLOCKS FOR THE ISOLATION DAMPERS AND THE SUPPLY FAN. THAT WAS ACCOMPLISHED BY SIMULATING A HIGH RADIATION SIGNAL FOR RMA4 (THE ATMOSPHERIC RADIATION MONITOR INTERLOCK) AND RMG9 (AREA RADIATION MONITOR INTERLOCK) WHICH TRIPPED THE FHB SUPPLY FAN AND CLOSED THE ISOLATION DAMPERS.

0112235525 5211962168 FUEL HANDLING BUILDING ESF Technical Specification Amendment TS AMENDMENT VENTILATION SYSTEM Ensure system is 297 provided a new Fuel Handling 122: NRC SER in service prior to Fuel Handling. Accident in the Spent Fuel Pool, and DATED 12/12/86 concluded that Fuel Handling Building ESF Ventilation is not required for mitigation. TS 3.15.4 Fuel Handling Building ESF Air Treatment System was deleted in TS Amendment 297.

Commitment Change Summary Report Attachment Part C - Programmatic Commitments tied to Licensing Actions Page 28 of 44 Table 3 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112235563 C311933140: GPUN COMMITTED TO THE NRC TO Once the certification of 50.82(a)2 TECH SPEC INCORPORATE A MODIFIED BATTERY were completed, TMI is no longer AMENDMENT 175 PERFORMANCE TEST AS DESCRIBED IN permitted to operate or place fuel in IEEE STANDARD 4501993. the reactor vessel, implementation of the PDTS the electrical power system including the DC and battery systems are no longer safety related. TS 3.7 Electrical Power was deleted by Amendment 297.

0112235564 592800 99096 TSCR 283 DEGRADED GRID Once the certification of 50.82(a)2 20120.001 TSCR SETPOINT TOLERANCE AND TURBINE were completed, TMI is no longer NO. 283 RAI PLANT LOADING DESIGN LIMIT permitted to operate or place fuel in RESPONSE REVISIONS. the reactor vessel, implementation of CLARIFICATIONS the PDTS the electrical power system PURSUANT TO including the Degraded Grid TELEPHONE protection are no longer safety CONFERENCE CALL related. TS 3.5.3 was deleted by Amendment 297.

0112235567 59280120209 TMI Unit 1 Procedure 15051 will be Once the certification of 50.82(a)2 RESPONSE TO revised to reflect the proposed Technical were completed, TMI is no longer REQUEST FOR Specification change and ensure permitted to operate or place fuel in ADDITIONAL continued awareness by the Shift the reactor vessel. TS 3.6.1 INFORMATION Operating/Refueling crews of the OPEN Containment Integrity was deleted by LICENSE status of the containment during core Amendment 297.

AMENDMENT alterations and fuel handling.

REQUEST NO. 249 CONTAINMENT INTEGRITY DURING REFUELING OPERATIONS 0112235568 59280120209 Operating Procedure 11013, Once the certification of 50.82(a)2 RESPONSE TO "Containment Integrity and Access were completed, TMI is no longer REQUEST FOR Limits," will be revised to provide for the permitted to operate or place fuel in ADDITIONAL placement of continuously operated the reactor vessel. TS 3.6.1 INFORMATION particulate and radioiodine air sampling Containment Integrity was deleted by LICENSE equipment inboard open airlocks during Amendment 297.

AMENDMENT core alteration and fuel handling REQUEST NO. 249 activities.

CONTAINMENT INTEGRITY DURING REFUELING OPERATIONS

Commitment Change Summary Report Attachment Part C - Programmatic Commitments tied to Licensing Actions Page 29 of 44 Table 3 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112235569 59280230061 The NRC's Safety Evaluation based its Once the certification of 50.82(a)2 SAFETY acceptance of the tendon surveillance were completed, TMI is no longer EVALUATION OF and inspections as meeting the permitted to operate or place fuel in PROCEDURES FOR requirements of 10CFR50.55a(b)(2)(ix) the reactor vessel, with PERFORMING on the following AmerGen commitment implementation of the PDTS the TS AND EVALUATING from the 25th Year Tendon Surveillance 3.19 and SR 4.4.2 for RB Tendon THE REACTOR Report (TR136) submittal dated Surveillance were deleted in BUILDING 2/25/00 (59280020066): "the Amendment 297.

TENDON Mechanical/Structural Engineer shall SURVEILLANCE perform continued monitoring of the (TAC NO. grease leakage as part of its Repetitive MA9460) Preventive Maintenance Task No.

9641." Therefore, performance of this PM Task becomes an ongoing commitment.

0112235571 59280510223 The asfound and asleft values will Once the certification of 50.82(a)2 TSCR NO. 324 continue to be recorded and reviewed were completed, TMI is no longer REACTOR for consistency with the assumptions of permitted to operate or place fuel in PROTECTION the surveillance interval extension the reactor vessel, the reaction SYSTEM TEST analysis. The review will verify the test protection system is no longer INTERVAL results meet acceptance criteria. Outof required to support protection of fuel EXTENSION tolerance results will be clad and RCS pressure boundary. TS evaluated to determine if they meet the 3.5.1 was deleted by Amendment requirements outlined in BAW10167. 297.

0112235576 59280520253 Procedural controls will ensure that Once the certification of 50.82(a)2 ADDITIONAL during the movement of irradiated fuel were completed, TMI is no longer INFORMATION the Equipment Hatch/Missile Shield permitted to operate or place fuel in TECHNCIAL area will be manned 24 Hours/Day, 7 the reactor vessel, implementation of SPECIFICATION Days/Week in support of the outage the PDTS removed any controls or CHANGE unless the Equipment Hatch is closed constraints on refueling operations REQUEST NO. and 4 bolts are installed. The since it no longer permitted. TS 3.8 326: "committed date or outage" for this Fuel Loading and Refueling was ELIMINATION OF item is T1R16. deleted in TS Amendment 297.

CONTAINMENT EQUIPMENT HATCH CLOSURE DURING REFUELING

Commitment Change Summary Report Attachment Part C - Programmatic Commitments tied to Licensing Actions Page 30 of 44 Table 3 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112235577 59280520253 TMI Unit 1 procedures will include Once the certification of 50.82(a)2 were ADDITIONAL the following requirements to completed, TMI is no longer permitted to INFORMATION ensure that General Design Criterion operate or place fuel in the reactor TECHNCIAL (GDC) 64 requirements will continue vessel, implementation of the PDTS SPECIFICATION to be met during the movement of removed any controls or constraints on CHANGE irradiated fuel: refueling operations since it no longer REQUEST NO. permitted. TS 3.8 Fuel Loading and 326: Refueling was deleted in TS Amendment ELIMINATION OF 297.

CONTAINMENT EQUIPMENT HATCH CLOSURE DURING REFUELING 0112235578 59280720006 The VLPT Nominal Setpoint (NSP) Once the certification of 50.82(a)2 were TSCR NO. 335 and Total Loop Uncertainty (TLU) are completed, TMI is no longer permitted to REACTOR determined using the methodology operate or place fuel in the reactor COOLANT SYSTEM provided by ANSI/ISAS67.04Part 1 vessel. TS 2.3 Limiting Safety System PRESSURE 1994. The predefined limits for NSP Settings were deleted in Amendment TEMPERATURE asfound tolerance will be 297.

SAFETY LIMITS determined in accordance with the NRC accepted methodology described in NRC RIS 200617.

0112235581 59280720097 Install TSP buffer modification and Once the certification of 50.82(a)2 were TECHNICAL isolate NaOH tank BST2. At least completed, TMI is no longer permitted to SPECIFICATION one manual valve in each supply operate or place fuel in the reactor CHANGE train will be locked closed providing vessel, LOCA is no longer a credible DBA, REQUEST NO. 337 permanent isolation of the NaOH therefore there is no need to provide "CHANGE OF tank. post LOCA ph control in containment. TS CONTAINMENT 3.3.1.3 RB Spray and RB Emergency EMERGENCY Cooling System was deleted in SUMP SPRAY PH Amendment 297.

CONTROL" 0112235582 59280720164 With regard to the VLPT setpoint Once the certification of 50.82(a)2 were RESPONSE TO RAI calculation and the references of completed, TMI is no longer permitted to TSCR # 335: Sections 7 and 8 of Part 1 of ISA operate or place fuel in the reactor REACTOR S67.041994, TMI Unit 1 is in vessel. TS 2.3 Limiting Safety System COOLANT SYSTEM agreement with this Regulatory Settings were deleted in Amendment PRESSURE Position and commits to implement 297.

TEMPERATURE Reg. Guide 1.105, Rev. 3.

SAFETY LIMIT

Commitment Change Summary Report Attachment Part C - Programmatic Commitments tied to Licensing Actions Page 31 of 44 Table 3 (Continued)

Commitment Commitment Commitment Details Basis for Deletion Tracking Source Document Number 0112235583 59280720202 1) The elements and methodology Once the certification of 50.82(a)2 were RESPONSE TO of the proposed TS Table 4.15, completed, TMI is no longer permitted to REQUEST FOR Item 2.b surveillance testing will be operate or place fuel in the reactor vessel, ADDITIONAL clearly delineated in station LOCA is no longer a credible DBA, INFORMATION surveillance procedures. therefore there is no need to provide post TECHNICAL (Programmatic) LOCA ph control in containment. TS 3.3.1.3 SPECIFICATION 2) Procedures will ensure that RB Spray and RB Emergency Cooling CHANGE samples are taken within the basket System was deleted in Amendment 297.

REQUEST NO. at both interior and peripheral 337: REACTOR locations to obtain a representative BUILDING sample. (Programmatic)

EMERGENCY 3) Use of the WCAP 16530NP SUMP PH model is being considered, and if CONTROL SYSTEM utilized, this issue (ref. Q.9) will be BUFFER CHANGE addressed in the TMI Unit 1 Generic Letter 200402 response. (One Time Action) 0112235593 59280820132 Control rod patch verification will Once the certification of 50.82(a)2 were AmerGen Energy be performed by moving each completed, TMI is no longer permitted to Co. LLC (Exelon) control rod to verify correct operate or place fuel in the reactor vessel, to U. S. Nuclear group/rod assignment following inadvertent criticality or reactivity Regulatory any software recompiling and management is no longer a concern. SR Commission download. 4.7 Reactor Control Rod System Test were dated September deleted in Amendment 297.

29, 2008. See also Technical Specification Amendment 273.

0256938101 TMI14121 TMI Periodic Leak Reduction Once the certification of 50.82(a)2 were Response to Program Incorporate a description completed, TMI is no longer permitted to Request for of the Periodic Leak Reduction operate or place fuel in the reactor vessel, Additional Program into the licensing basis by since a LOCA is no longer a credible DBA, Information revising UFSAR Section 6.4, quantifying leakage into the Aux Building Regarding License "Engineered Safeguards Leakage in the event of sump recirculation Amendment and Radiation Considerations." exceeding Part 100 limits is no longer a Request to concern. SR 4.5.4 ESF system leakage was Eliminate Certain deleted in Amendment 297.

Technical Specification Reporting Requirements.

Commitment Change Summary Report Attachment Part D - Miscellaneous Programmatic Commitments Page 37 of 44 The following provides the update of Miscellaneous Programmatic Commitments that will be deleted based on the TMI-1 no longer being permitted to operate in accordance with 10 CFR 50.82(a)(2).

Letter Source: 5211872059 - LTR to NRC: RCPS Thermal Barrier Cooling and Injection.

C311882010 - LTR to NRC: 10 CFR 50 APPENDIX R LOSS OF HVAC Exelon Tracking 0112235527 Number 0112235530 Nature of Both listed commitments are associated with compliance with 10 CFR 50, Appendix R.

Commitment:

0112235527 Reactor Coolant Pumps Appendix R exemption. The licensee committed to the NRC that in the event of a control room or relay room fires, mitigation response procedures to restore reactor coolant pump seal barrier coolant at the remote shutdown panel.

0112235530 10 CFR 50 Appendix R - Loss of HVAC. The licensee committed to monitor diesel engine parameters during diesel generator operations to ensure EDG is adequately cooled during loss of ventilation in the diesel rooms due to an Appendix R Fire.

Each of the original regulatory commitments will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.

Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. As a result, the requirements of 10 CFR 50.47.(b)(2) and Appendix R are no longer applicable and fire protection for a decommissioning plant is covered by 10 CFR 50.48(f).

Letter Source: 5211842015 LTR to NRC GL 8233 RESPONSE NUREG 0737 ITEM IC1 ATOG IMPLEMENTATION 5211842154 LTR to NRC: NUREG 0737 ITEM I.C.1 RESPONSE TO SER QUESTIONS Exelon Tracking 0112207264 Number 0112207277 Nature of Both listed commitments are associated with implementation Abnormal Transient Commitment: Operating Guidelines (ATOG) in Emergency Operating Procedures (EOPs).

0112207264 - Abnormal Transient Operating Guidelines (ATOGs). The licensee committed to the NRC that the ATOGs would be integrated into the Abnormal Transient Procedures, which ultimately become the EOPs. The guidance to follow the ATOGs was placed in AP 1001E, "Writers Guide for Abnormal Transient Procedures."

0112207277 - EOP Upgrade Program. The licensee committed to correct NRC concerns on Writers Guide Administrative Procedures for Abnormal Transient Procedures.

Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. As a result, the need for EOPs that meet the ATOGs are no longer necessary, since the transients in question are not applicable to a defueled facility that is no longer licensed to operate. In addition, the requirement to maintain a writer's guide procedure for the maintenance of these procedures is no longer required.

Commitment Change Summary Report Attachment Part D - Miscellaneous Programmatic Commitments Page 38 of 44 Letter Source: TMI15120 - LTR to NRC: Fleet Commitment to Maintain Severe Accident Management Guidelines (SAMGs)

Exelon Tracking 0261101222 Number Nature of 0261101222Fleet Commitment to Maintain Severe Accident Management Guidelines Commitment: (SAMGs). The licensee committed to implement the Nuclear Energy Institute (NEI) Nuclear Strategic Issues Advisory Committee (NSIAC) approved initiative to implement SAMGs. The SAMGs would be used by emergency response personnel during accident conditions that progress beyond the mitigation capabilities described in EOPs. SAMG strategies are intended to arrest the progression of fuel damage, maintain the capability of the containment as long as possible, and minimize radiological releases.

The original regulatory commitment listed above will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.

Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. As a result, the need for EOPs that meet the ATOGs are no longer necessary, since the transients in question are not applicable to a defueled facility that is no longer licensed to operate. Therefore, the need to provide SAMGs to provide strategies to arrest the progression of fuel damage or maintain the capability of containment. Although the SAMGs provided spent fuel mitigation strategies in the event of a loss of water to the spent fuel pool, these Extensive Damage Mitigation Strategies to ensure water sources to the Spent Fuel Pool are already built into the Abnormal Operating procedure to address the loss of spent fuel pool cooling.

Letter Source: TMI15120 - LTR to NRC: Response Providing Information Regarding Implementation Details for the B.5.b Phases 2 and 3 Mitigation Strategies Exelon Tracking 0112207215 Number 0112207217 Nature of 112207215 B.5.b Commitments Three Mile Island Nuclear Station Unit 1 will include the Commitment: command and control enhancement strategies as described in the general description in Attachment 1 in plant procedures (Tables A.31) 112207217 B.5.b Commitments Three Mile Island Nuclear Station Unit 1 will list the viable sitespecific reactor/containment strategies described in Attachment 1 that could be used by emergency response organization or plant personnel in appropriate procedures (Table A.6.1).

The original regulatory commitment listed above will be closed, since the actions are no longer applicable as a result of TMI1 being in a permanent shutdown state.

Justification for Change By letter dated September 26, 2019, Exelon provided certification that TMI1 was permanently shut down and defueled with all irradiated fuel being stored in the Spent Fuel Pool. In accordance with 50.82(a)(2), TMI1 is no longer permitted to operate or place fuel in the reactor vessel. The B.5.b commitments are part of the broader Extensive Damage Mitigation Strategies that are required by 10 CFR 50.155, Mitigation of beyonddesignbasis events. Pursuant to 50.155.(a)2(i), once the certifications described in 50.82 are submitted, the licensee need only comply with the by EDGM strategies associated with spent fuel pool cooling capabilities.

Commitment Change Summary Report Attachment Part D - Miscellaneous Programmatic Commitments Page 39 of 44 Letter Source: GPUN letters to NRC C311902073, 5211853262 and C311903248 concerning TMI Fire Brigade Training.

Exelon Tracking 0112235510 Number 0112235557 Nature of In letter to NRC, 5211853262 GPUN committed THAT INDIVIDUALS WHO SERVE ON THE Commitment: FIRE BRIGADES OF BOTH UNIT 1 AND UNIT 2 ARE (1) COGNIZANT OF CHANGES IN THE FIRE PROTECTION PLAN, PROCEDURES, AND EQUIPMENT OF EACH UNIT (2) PARTICIPATED IN DRILLS ON BOTH UNITS (3) PERIODICALLY EVALUATED ON A SCHEDULE COMMENSURATE WITH CURRENT EVALUATION CRITERIA.

In C311902073, GPUN COMMITTED TO THE NRC THAT EACH FIRE BRIGADE MEMBER SHALL PARTICIPATE IN:

1) AT LEAST TWO DRILLS PER YEAR AT TMI1 TO REMAIN QUALIFIED
2) AT LEAST ONE DRILL PER YEAR FOR EACH TMI1 OPERATING SHIFT SHALL BE CONDUCTED IN TMI2.

THESE DRILLS SHALL BE SCHEDULED SUCH THAT AT LEAST ONE DRILL PER QUARTER TAKES PLACE IN TMI2.

In C311903248, dated 11/21/90, documents the NRC Staff review and approval of the GPU proposed commitment. The new commitment required one fire drill per shift per year in Unit 2.

These commitments will be closed. Training requirements for the Incipient Fire Brigade will conform to RG 1.191 and NFPA 600 requirements as described in the TMI Incipient Fire Brigade Evaluation. The TMI Fire Protection Program procedure 1038 will describe the training, qualification and drill requirements for the Incipient Fire Brigade.

Justification for Change In 1985 and 1990 when these commitments were made, the regulatory framework for Fire Protection was being developed. By 2000, NRC had issued Regulatory Guide 1.189 to provide guidance for Fire Protection at an operating facility. In May 2001, NRC issued Regulatory Guide 1.191 to provide guidance for compliance with 10CFR50.48(f) for a permanently defueled facility.

In September 2019, TMI1 was permanently defueled and the TMI1 Fire Hazards Analysis (9901745) was modified to ensure compliance with 10CFR50.48(f) and Regulatory Guide 1.191. In January 2020, the TMI2 Fire Protection Program Evaluation (9903017) was modified to ensure compliance with 10CFR50.48(f) and Regulatory Guide 1.191.

The operating plant requirements for fire brigade training will be maintained until the Incipient Fire Brigade is implemented. The Incipient Fire Brigade Evaluation (Technical Evaluation 421497115) identified how the requirements of RG 1.191 would be satisfied when TMI transitions to an Incipient Fire Brigade. This included fire brigade training, qualification and drill requirements.

The program requirements of Reg Guide 1.191 supersede the purpose for the original commitments. The original commitments should be eliminated when the Incipient Fire Brigade is implemented. The TMI Fire Protection program will continue to comply with Reg Guide 1.191.

Commitment Change Summary Report Attachment Part E - Items Classified as no longer being Regulatory Commitments Page 40 of 44 Letter Source: NUREG1928, Safety Evaluation Report Related to the License Renewal of Three Mile Island Nuclear Station, Unit 1, Appendix A dated October 2009.

Exelon Tracking See Table 4 Number Nature of Table 4 list all of the open License Renewal Commitments provided in NUREG1928, Safety Commitment: Evaluation Report Related to the License Renewal of Three Mile Island Nuclear Station, Unit 1, Appendix A dated October 2009.

Each of the original commitments listed in Table 4 will be reassigned as aging management items and no longer be categorized as regulatory commitments as they no longer meet the NEI definition of a regulatory commitment.

Justification for Change Upon approval of the license renewal license amendment request, the NRC issued a license condition to the TMI 1s Renewed Facility Operating License (2.c.(20)), that required that the regulatory commitments related to license renewal be incorporated into the station UFSAR. This condition was satisfied in Revision 20 of the UFSAR and provided in Appendix A of the TMI UFSAR. License Condition 2.c.(20) was deleted in TS Amendment 297, Permanently Defueled Technical Specifications. Since these items are no in the UFSAR, they are controlled under the 50.59 change process and reported to the NRC in accordance with 50.71(e).

Table 4 License Renewal Commitments ReClassified as No Longer being Regulatory Commitments Commitment Commitment Commitment Details Tracking Number 0060357301 ASME Sec XI ISI IWB, IWC, This assignment captures the License Renewal commitments and IWD Aging Mgmt associated with the ASME Section XI Inservice Inspection, Subsections Program IWB, IWC, and IWD Aging Management Program (Reference TMI1 License Renewal Application sections A.2. 1.1 and B.2.1.1) 0060357302 Water Chemistry Aging This assignment captures the License Renewal commitments Management Program associated with the Water Chemistry Aging Management Program (Reference TMI1 License Renewal Application sections A.2.1.2 and B.2.1.2). When all of the sub assignments due on or before 4/19/2014 are completed, the due date for this assignment shall be changed to 4/19/2034.

0060357303 Reactor Head Closure Studs This assignment captures the License Renewal commitments Aging Management associated with the Reactor Head Closure Studs Aging Management Program B.2.1.3 Program (Reference TMI1 License Renewal Application sections A.2.1.3 and B.2.1.3) 0060357304 Boric Acid Corrosion Aging This assignment captures the License Renewal commitments Management Program associated with the Boric Acid Corrosion Aging Management Program (Reference TMI1 License Renewal Application sections A.2.1.4 and B.2.1.4) 0060357305 Ni Alloy Rx Head Nozzle This assignment captures the License Renewal commitments Penetration AMP associated with the NickelAlloy Penetration Nozzles Welded to the Upper Reactor Vessel Closure Heads of Pressurized Water Reactors Aging Management Program (Reference TMI 1 License Renewal Application sections A.2.1.5 and B.2.1.5)

Commitment Change Summary Report Attachment Part E - Items Classified as no longer being Regulatory Commitments Page 41 of 44 Table 4 (Continued)

Commitment Commitment Commitment Details Tracking Number 0060357306 FlowAccelerated This assignment captures the License Renewal commitments Corrosion Aging associated with the FlowAccelerated Corrosion Aging Management Management Program Program (Reference TMI1 License Renewal Application sections A.2.1.6 and B.2.1.6) 0060357307 Bolting Integrity Aging This assignment captures the License Renewal commitments Management Program associated with the Bolting Integrity Aging Management Program (Reference TMI1 License Renewal Application sections A.2.1.7 and B.2.1.7) 0060357308 Steam Generator Tube This assignment captures the License Renewal commitments Integrity Aging Mgmt associated with the Steam Generator Tube Integrity Aging Program Management Program (Reference TMI1 License Renewal Application sections A.2.1.8 and B.2.1.8) 0060357309 OpenCycle Cooling This assignment captures the License Renewal commitments Aging Management associated with the OpenCycle Cooling Water System Aging Program Management Program (Reference TMI1 License Renewal Application sections A.2.1.9 and B.2.1.9). Includes implementation of programmatic work orders.

0060357310 ClosedCycle Cooling This assignment captures the License Renewal commitments Aging Management associated with the ClosedCycle Cooling Water System Aging Program Management Program (Reference TMI1 License Renewal Application sections A.2.1.10 and B.2.1.10). Includes implementation of programmatic work orders.

0060357311 Cranes & Hoists Aging This assignment captures the License Renewal commitments Management Program associated with the Inspection of Overhead Heavy Load and Light Load (Related to Refueling) Handling Systems Aging Management Program (Reference TMI 1 License Renewal Application Sections A.2.1.11 and B.2.1.11).

0060357312 Compressed Air This assignment captures the License Renewal commitments Monitoring Aging Mgmt associated with the Compressed Air Monitoring Aging Management Program Program (Reference TMI1 License Renewal Application sections A.2.1.12 and B.2.1.12). When all of the sub assignments due on or before 4/19/2014 are completed, the due date for this assignment shall be changed to 4/19/2034.). Includes implementation of programmatic work orders.

0060357313 Fire Protection Aging This assignment captures the License Renewal commitments Management Program associated with the Fire Protection Aging Management Program (Reference TMI1 License Renewal Application sections A.2.1.13 and B.2.1.13). Includes implementation of programmatic work orders.

0060357314 Fire Water System Aging This assignment captures the License Renewal commitments Management Program associated with the Fire Water System Aging Management Program (Reference TMI1 License Renewal Application sections A.2.1.14 and B.2.1.14). When all of the sub assignments due on or before 4/19/2014 are completed, the due date for this assignment shall be changed to 4/19/2034). Includes implementation of programmatic work orders.

Commitment Change Summary Report Attachment Part E - Items Classified as no longer being Regulatory Commitments Page 42 of 44 Table 4 (Continued)

Commitment Commitment Commitment Details Tracking Number 0060357315 Aboveground Steel This assignment captures the License Renewal commitments Tanks Aging associated with the Aboveground Steel Tanks Aging Management Management Program Program (Reference TMI1 License Renewal Application sections A.2.1.15 and B.2.1.15). Includes implementation of programmatic work orders.

0060357316 Fuel Oil Chemistry Aging This assignment captures the License Renewal commitments Management Program associated with the Fuel Oil Chemistry Aging Management Program (Reference TMI1 License Renewal Application sections A.2.1.16 and B.2.1.16). When all of the sub assignments due on or before 4/19/2014 are completed or extended, the due date for this assignment should be changed to 4/19/2034. Includes implementation of programmatic work orders.

0060357317 Reactor Vessel This assignment captures the License Renewal commitments Surveillance Aging associated with the Reactor Vessel Surveillance Aging Management Management Program Program (Reference TMI1 License Renewal Application sections A.2.1.17 and B.2.1.17). Includes implementation of programmatic work orders.

0060357320 Buried Piping and Tanks This assignment captures the License Renewal commitments Aging Management associated with the Buried Piping and Tanks Inspection Aging Program Management Program (Reference TMI1 License Renewal Application sections A.2.1.20 and B.2.1.20). When all of the sub assignments due on or before 4/19/2024 are completed or extended, the due date for this assignment should be changed to 4/19/2034. Includes implementation of programmatic work orders.

0060357321 External Surfaces This assignment captures the License Renewal commitments Monitoring Aging associated with the External Surfaces Monitoring Aging Management Management Program Program (Reference TMI1 License Renewal Application sections A.2.1.21 and B.2.1.21). Includes implementation of programmatic work orders.

0060357322 Internal Surfaces This assignment captures the License Renewal commitments Inspection Aging associated with the Inspection of Internal Surfaces in Miscellaneous Management Program Piping and Ducting Components Aging Management Program (Reference TMI 1 License Renewal Application sections A.2.1.22 and B.2.1.22) When all of the specific commitment activities required to be performed by 4/19/2014 are completed, this commitment due date should be reset to coincide with the termination of the operating license in 2034. Includes implementation of programmatic work orders and volumetric Exams of SS of SCCs.

0060357323 Lubricating Oil Analysis This assignment captures the License Renewal commitments Aging Management associated with the Lubricating Oil Analysis Aging Management Program Program (Reference TMI1 License Renewal Application sections A.2.1.23 and B.2.1.23). Includes implementation of programmatic work orders.

0060357324 ASME Section XI, This assignment captures the License Renewal commitments Subsection IWE Aging associated with the ASME Section XI, Subsection IWE Aging Management Program Management Program (Reference TMI1 License Renewal Application sections A.2.1.24 and B.2.1.24).

Commitment Change Summary Report Attachment Part E - Items Classified as no longer being Regulatory Commitments Page 43 of 44 Table 4 (Continued)

Commitment Commitment Commitment Details Tracking Number 0060357325 ASME Section XI, This assignment captures the License Renewal commitments Subsection IWL Aging associated with the ASME Section XI, Subsection IWL Aging Management Program Management Program (Reference TMI1 License Renewal Application sections A.2.1.25 and B.2.1.25) When all the implementing document changes required by 4/19/2014 have been made, the due date for this commitment should be changed to 4/19/2034, the end of the operating period.

0060357326 ASME Section XI, This assignment captures the License Renewal commitments Subsection IWF Aging associated with the ASME Section XI, Subsection IWF Aging Management Program Management Program (Reference TMI1 License Renewal Application sections A.2.1.26 and B.2.1.26) When all of the procedure changes required by 4/19/2014 have been completed, reset the due date for this commitment to 4/19/2034, the end of the operating period.

0060357327 10 CFR Part 50, This assignment captures the License Renewal commitments Appendix J Aging associated with the 10 CFR Part 50, Appendix J Aging Management Management Program Program (Reference TMI1 License Renewal Application sections A.2.1.27 and B.2.1.27).

0060357328 Structures Monitoring This assignment captures the License Renewal commitments Program Aging associated with the Structures Monitoring Program Aging Management Program Management Program (Reference TMI1 License Renewal Application sections A.2.1.28 and B.2.1.28) When all of the assignments with due dates on or before 4/19/2014 have been completed, this assignment should be changed to 04/19/2034, the end of the operating period.

Includes implementation of programmatic work orders.

0060357329 Protective Coatings This assignment captures the License Renewal commitments Aging Management associated with the Protective Coating Monitoring and Maintenance Program Program Aging Management Program (Reference TMI 1 License Renewal Application sections A.2.1.29 and B.2.1.29). Includes implementation of programmatic work orders.

0060357330 NonEQ Cables and This assignment captures the License Renewal commitments Connections Aging associated with the Electrical Cables and Connections Not Subject to Management Program 10 CFR 50.49 Environmental Qualification Requirements Aging Management Program (Reference TMI 1 License Renewal Application sections A.2.1.30 and B.2.1.30) When all of the sub assignments due on or before 4/19/2014 are completed or extended, the due date for this assignment should be changed to 4/19/2034. Includes implementation of programmatic work orders.

Commitment Change Summary Report Attachment Part E - Items Classified as no longer being Regulatory Commitments Page 44 of 44 Table 4 (Continued)

Commitment Commitment Commitment Details Tracking Number 0060357331 NonEQ Instrument This assignment captures the License Renewal commitments Cables and Connections associated with the Electrical Cables and Connections Not Subject to AMP 10 CFR 50.49 Environmental Qualification Requirements Used in Instrumentation Circuits Aging Management Program (Reference TMI 1 License Renewal Application sections A.2.1.31 and B.2.1.31). When all of the sub assignments due on or before 4/19/2014 are completed or extended, the due date for this assignment should be changed to 4/19/2034. Includes implementation of programmatic work orders.

0060357332 Inaccessible Medium This assignment captures the License Renewal commitments Voltage Cable AMP associated with the Inaccessible Medium Voltage Cables Not Subject to 10 CFR 50.49 Environmental Qualification Requirements Aging Management Program (Reference TMI 1 License Renewal Application sections A.2.1.32 and B.2.1.32). Includes implementation of programmatic work orders.

0060357333 Metal Enclosed Bus This assignment captures the License Renewal commitments Aging Management associated with the MetalEnclosed Bus Aging Management Program Program (Reference TMI1 License Renewal Application sections A.2.1.33 and B.2.1.33). Includes implementation of programmatic work orders.

0060357335 Nickel Alloy Aging This assignment captures the License Renewal commitments Management Program associated with the Nickel Alloy Aging Management Program (Reference TMI1 License Renewal Application sections A.2.2.1 and B.2.2.1).

0060357336 PWR Vessel Internals This assignment captures the License Renewal commitments Aging Management associated with the PWR Vessel Internals Aging Management Program Program (Reference TMI1 License Renewal Application Section A.5 No. 36).

Includes Reactor Internals Inspection Plan.

0060357337 RC Pressure Boundary This assignment captures the License Renewal commitments Metal Fatigue AMP associated with the Metal Fatigue of Reactor Coolant Pressure Boundary Aging Management Program (Reference TMI1 License Renewal Application sections A.3.1.1 and B.3.1.1).

0060357338 Concrete Containment This assignment captures the License Renewal commitments Tendon PreStress Aging associated with the Concrete Containment Tendon Prestress Aging Mgmt Program Management Program (Reference TMI1 License Renewal Application sections A.3.1.2 and B.3.1.2).

0060357339 EQ of Electrical This assignment captures the License Renewal commitments Components Aging associated with the Environmental Qualification (EQ) of Electrical Management Program Components Aging Management Program (Reference TMI 1 License Renewal Application sections A.3.1.3 and B.3.1.3).

0060357343 Boral and Metamic Test This assignment captures the License Renewal commitment Coupon Surveillance associated with the Boral Test Coupon Surveillance as committed in RAI response letter # 59280820229 and the 2010 10 CFR 54.37b report identifying the Metamic fuel racks as a "newly identified SCC" that require aging management review.

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