ML14134A172

Draft RAIs in Support of NRC Staff Review of TMI Cycle 20 COLR

ML14134A172
Person / Time
Site:	Crane
Issue date:	05/14/2014
From:	Jeffrey Whited Plant Licensing Branch 1
To:
Whited J, NRR/DORL/LPLI-2
References
GL-88-16
Download: ML14134A172 (2)

Text

DRAFT DRAFT REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO THE REVIEW OF THE THREE MILE ISLAND NUCLEAR STATION UNIT 1 CYCLE 20 CORE OPERATING LIMITS REPORT THREE MILE ISLAND NUCLEAR STATION - UNIT 1 DOCKET NO. 50-289 By letter dated November 8, 2013, 1 Exelon Generation Company, LLC (Exelon) submitted the Three Mile Island Nuclear Station Unit 1 Cycle 20 (TMI C20) Core Operating Limits Report (COLR). To complete its review of the TMI C20 COLR, the Nuclear Regulatory Commission (NRC) staff requests a response to the questions below.

Generic Letter (GL) 88-16 "Removal of Cycle-Specific Parameter Limits from Technical Specifications" provides guidance for the prepar ation of a license amendment request (LAR) to modify Technical Specifications (TSs) that have cy cle-specific parameter limits. An acceptable alternative to specifying the values of cycle-specific parameter limits in TS consists of: (1) the addition of the definition of a named formal report that includes the values of cycle-specific parameter limit that have been established using an NRC-approved methodology and consistent with all applicable limits of the safety analysis, (2) the addition of an administrative reporting requirement to submit the formal report on cycle-specific parameter limits to the Commission for information, and (3) the modification of individual TS to note that cycle-specific parameters shall be maintained within the limits provided in the defined formal report. GL 88-16 further clarifies that in COLR TS [6.x.x] core operating limits shall be established and documented in the COLR before each reload cycle or any remaining part of a reload cycle. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC staff.

Based on the GL 88-16 guidance, TMI C20 TS 6.9.5.2 lists all approved methodologies to support the cycle-specific core operating parameters specified in TS 6.9.5.1. Therefore, both TS 6.9.5.1 and 6.9.5.2 in the TMI COLR TS are associated with the acceptable alternative stated in item (1) above. The current TMI C20 COLR is associated with the acceptable

alternative stated in item (2) above. While TS 6.9.5.2 lists six NRC approved methodology references, TMI C20 COLR lists 3 references in "REFERENCES". The staff found that: (1) there are no cycle-specific core operating limits listed in TS 6.9.5.1; (2) there is no clear identification for cycle-specific core operating limits in the TMI C20 COLR but only mentioned in

the ABSTRACT; and (3) there are no clear cycle-specific operating limits in the TMI C20 COLR.

RAI-1: Please identify plant and cycle specific parameters for TS 6.9.5.1 and show those core operating limits in the TMI C20 COLR.

1 Agencywide Documents Access and Management System (ADAMS) Accession No. ML13317A073.

RAI-2: Please justify that the use of any methodologies referenced in REFERENCES of the TMI C20 COLR to support the cycle specific core operating limits (to be provided in RAI-1) is in consistent with the TS 6.9.5.2.

RAI-3: Please organize the TMI C20 COLR in accordance to the TS 6.9.5.4 to include the proper TSs for cycle specific core operating limits, the detailed limits and their supporting methodologies listed in TS 6.9.5.2.