ML082190781

Request for Additional Information, License Renewal Application, Section 2.1.5.2

ML082190781
Person / Time
Site:	Three Mile Island
Issue date:	08/22/2008
From:	Jay Robinson NRC/NRR/ADRO/DLR
To:	Gallagher M AmerGen Energy Co
Robinson, J NRR/DLR/RPB1 415-2878
References
TAC MD7701
Download: ML082190781 (8)

Text

August 22, 2008 Mr. Michael P. Gallagher Vice President License Renewal Projects AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR SECTION 2.1.5.2 OF THE THREE MILE ISLAND NUCLEAR STATION, UNIT 1, LICENSE RENEWAL APPLICATION (TAC NO. MD7701)

Dear Mr. Gallagher:

By letter dated January 8, 2008, AmerGen Energy Company, LLC (AmerGen) submitted an application pursuant to 10 CFR Part 54 to renew the operating license for Three Mile Island Nuclear Station, Unit 1 for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Chris Wilson, of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-2878 or e-mail Jay.Robinson@nrc.gov.

Sincerely,

/RA/

Jay Robinson, Sr. Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

As stated cc w/encl: See next page

ML082190781 OFFICE LA:DLR OGC DLR:RER2 PM:DLR:RPB1 BC:DLR:RPB1 NAME SFigueroa BMinuzo RAuluck JRobinson DPelton DATE 08/14/08 07/17/08 08/20/08 08/22/08 08/22/08

Letter to AmerGen Energy Company, LLC from J. Robinson dated August 22, 2008 DISTRIBUTION:

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR SECTION 2.1.5.2 OF THE THREE MILE ISLAND NUCLEAR STATION, UNIT 1, LICENSE RENEWAL APPLICATION (TAC NO. MD7701)

HARD COPY:

DLR RF E-MAIL:

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SLopas BRogers

Three Mile Island Nuclear Station, Unit 1 cc:

Site Vice President - Three Mile Island Director Nuclear Station, Unit 1 Bureau of Radiation Protection AmerGen Energy Company, LLC Pennsylvania Department of P. O. Box 480 Environmental Protection Middletown, PA 17057 Rachel Carson State Office Building P.O. Box 8469 Senior Vice President - Operations, Harrisburg, PA 17105-8469 Mid-Atlantic AmerGen Energy Company, LLC Plant Manager - Three Mile Island Nuclear 200 Exelon Way, KSA 3-N Station, Unit 1 Kennett Square, PA 19348 AmerGen Energy Company, LLC P.O. Box 480 Vice President - Licensing and Regulatory Middletown, PA 17057 Affairs AmerGen Energy Company, LLC Regulatory Assurance Manager -

4300 Winfield Road Three Mile Island Nuclear Station, Warrenville, IL 60555 Unit 1 AmerGen Energy Company, LLC Regional Administrator P.O. Box 480 Region I Middletown, PA 17057 U.S. Nuclear Regulatory Commission 475 Allendale Road Ronald Bellamy, Region I King of Prussia, PA 19406 U.S. Nuclear Regulatory Commission 475 Allendale Road Chairman King of Prussia, PA 19406 Board of County Commissioners of Dauphin County Ronnie Gardner, PMP Dauphin County Courthouse Manager, Site Operations and Corporate Harrisburg, PA 17120 Regulatory Affairs AREVA NP Inc.

Chairman 3315 Old Forest Road OF-16 Board of Supervisors Lynchburg, VA 24501 of Londonderry Township R.D. #1, Geyers Church Road Dr. Judith Johnsrud Middletown, PA 17057 National Energy Committee Sierra Club Senior Resident Inspector (TMI-1) 433 Orlando Avenue U.S. Nuclear Regulatory Commission State College, PA 16803 P.O. Box 219 Middletown, PA 17057 Eric Epstein TMI Alert Director - Licensing and Regulatory Affairs 4100 Hillsdale Road AmerGen Energy Company, LLC Harrisburg, PA 17112 Correspondence Control P.O. Box 160 Kennett Square, PA 19348

Three Mile Island Nuclear Station, Unit 1 Frederick W. Polaski cc: Manager License Renewal Exelon Nuclear Correspondence Control Desk 200 Exelon Way AmerGen Energy Company, LLC Kennett Square, PA 19348 200 Exelon Way, KSA 1-N-1 Kennett Square, PA 19348 Albert A. Fulvio, Senior Project Manager License Renewal Manager Licensing - Three Mile Island Exelon Nuclear Nuclear Station, Unit 1 200 Exelon Way Exelon Generation Company, LLC Kennett Square, PA 19348 Correspondence Control P.O. Box 160 Rich Janati, Chief Kennett Square, PA 19348 Division of Nuclear Safety Bureau of Radiation Protection Christopher M. Crane Pennsylvania Department of President and Chief Executive Officer Environmental Protection AmerGen Energy Company, LLC Rachel Carson State Office Building 4300 Winfield Road P.O. Box 8469 Warrenville, IL 60555 Harrisburg, PA 17105-8469 Mr. Charles G. Pardee Michael Murphy Chief Nuclear Officer Bureau of Radiation Protection AmerGen Energy Company, LLC Pennsylvania Department of 200 Exelon Way Environmental Protection Kennett Square, PA 19348 Rachel Carson State Office Building P.O. Box 8469 Associate General Counsel Harrisburg, PA 17105-8469 AmerGen Energy Company, LLC 4300 Winfield Road Michael G. Brownell, Chief Warrenville, IL 60555 Water Resources Management Susquehanna River Basin Commission Chief Operating Officer (COO) 1721 N. Front Street AmerGen Energy Company, LLC Harrisburg, PA 17102 4300 Winfield Road Warrenville, IL 60555 Rachel Diamond, Regional Director Southcentral Regional Office Senior Vice President - Operations Support Pennsylvania Department of AmerGen Energy Company, LLC Environmental Protection 4300 Winfield Road 909 Elmerton Avenue Warrenville, IL 60555 Harrisburg, PA 17110 Nancy Ranek Environmental Lead, License Renewal Exelon Nuclear 200 Exelon Way, KSA/2-E Kennett Square, PA 19348

Three Mile Island Nuclear Station, Unit 1 cc:

Christopher Wilson KSQ License Renewal Exelon Nuclear 200 Exelon Way, KSA/2-E Kennett Square, PA 19348 Mr. Michael P. Gallagher Vice President License Renewal Projects AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348

REQUEST FOR ADDITIONAL INFORMATION (RAI)

SECTION 2.1.5.2 THREE MILE ISLAND NUCLEAR STATION, UNIT - 1 LICENSE RENEWAL APPLICATION LRA Section 2 - Scoping and Screening Methodology and Results 10 CFR 54.4(a)(2) requires that all nonsafety-related systems, structures, and components whose failure could prevent satisfactory accomplishment of any safety-related systems, structures, and components (SSCs) are included within the scope of license renewal.

RAI#: 2.1.5.2-1 License Renewal Application (LRA) Section 2.1.5.2 states on page 2.1-19, Afor a nonsafety-related piping system connected to a safety-related piping system, the nonsafety-related system was assumed to provide structural support to the safety-related system, unless otherwise confirmed by a review of the installation details. The entire nonsafety-related system was included in scope for 10 CFR 54.4(a)(2), up to one of the following: and then lists the bounding criteria contained in NEI 95-10 Industry Guideline on Implementing the Requirements of 10 CFR Part 54, The License Renewal Rule, (seismic anchor, base-mounted component, flexible connection, free end of non-safety related piping, buried end of piping, and nonsafety-related piping runs connected to safety-related piping on both ends). In addition, LRA Section 2.1.5.2 also states on page 2.1-19, these scoping boundaries are determined from the physical installation details, and confirmed in cases by review of design drawings or visual inspection by plant walk-downs where necessary.

During the scoping and screening methodology audit, the staff reviewed the scoping results for the abandoned hydrogen purge system and was not able to determine that the applicant had applied the methods described in LRA Section 2.1.5.2 to determine the portion of the nonsafety-related piping, attached to safety-related SSCs, to be included within the scope of license renewal. The staff requests that the applicant describe the methods used and the basis for conclusions, in determining the portion of nonsafety-related abandoned system piping, attached to safety-related SSCs, to be included within the scope of license renewal.

RAI#: 2.1.5.2-2 During the scoping and screening methodology audit, the applicant stated that for certain systems, the portion of nonsafety-related piping, attached to safety-related SSCs, to be included within the scope of license renewal, had not been completely determined. The staff reviewed the scoping results for the make-up and purification system and determined that the scoping endpoints for attached piping had not been clearly defined in three instances due to a portion of the nonsafety-related piping being inaccessible to personnel while the plant was at power. The staff requests that the applicant describe the methods used and the basis for conclusions, in determining the portion of nonsafety-related inaccessible piping, attached to safety-related SSCs, to be included within the scope of license renewal.

ENCLOSURE

RAI#: 2.1.5.2-3 LRA Section 2.1.5.2 states on page 2.1-20, the preventive option as implemented at TMI-1 is based on a spaces approach for scoping of nonsafety-related systems with potential spatial interaction with safety-related SSCs. Potential spatial interaction is assumed in any structure that contains active or passive safety-related SSCs. For structures that contain safety-related SSCs, there may be selected rooms within the structure that do not contain any safety-related SSCs. Current Licensing Basis (CLB) document reviews and plant walk-downs were utilized as appropriate to confirm that these rooms did not contain safety-related SSCs, thereby eliminating spatial interaction concerns within these rooms.

During the scoping and screening methodology audit, the staff performed a walk-down of the turbine building. The staff determined that a portion of the turbine building contained fluid-filled, nonsafety-related systems which were not included within the scope of license renewal (referred to by the applicant as an Aexcluded area@). However, since the turbine building is generally an open space, the excluded area was located in the same room as safety-related containment isolation valves (CA-V-5A and CA-V-5B). The staff determined that the nonsafety-related, fluid-filled SSCs were not separated from safety-related SSCs by a room as described in LRA Section 2.1.5.2 (see above). The staff requests that the applicant describe the methods used and the basis for conclusions, in determining to not include nonsafety-related, fluid-filled SSCs within the scope of license renewal when located in the same room as safety-related SSCs.

As part of your response for RAIs 2.1.5.2-1 through 2.1.5.2-3, please address the extent of condition and additional scoping reviews performed for nonsafety-related abandoned SSCs, nonsafety-related inaccessible SSCs, and nonsafety-related SSCs located within the same room as safety-related SSCs, with the potential to affect safety-related SSCs.

List any additional SSCs included within the scope of license renewal as a result of the review, and list those structures and components for which aging management reviews were conducted. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.