ML082330192
| ML082330192 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 08/26/2008 |
| From: | Jay Robinson NRC/NRR/ADRO/DLR |
| To: | Office of Nuclear Reactor Regulation |
| Robinson, J NRR/DLR/RPB1 415-2878 | |
| References | |
| TAC MD7701 | |
| Download: ML082330192 (7) | |
Text
REQUEST FOR ADDITIONAL INFORMATION LICENSE RENEWAL APPLICATION THREE MILE ISLAND NUCLEAR STATION, UNIT 1 DOCKET NO.: 50-289 TAC NO.: MD7701 LRA Section: 2.2, Plant Level Scoping Results Table 2.2-1, Page 2.2-6 RAI#: D-2.2-1 Table 2.2-1, Plant Level Scoping Results, lists the Chemical Cleaning Building as NOT being within the scope of license renewal. However, the TMI UFSAR, Section 5.1.1.1.a, lists the Chem Cleaning Building Basin as a Class I structure. If it is not included as an oversight, please provide a description of the scoping and aging management review. If it is covered somewhere else in the LRA, please indicate the location, or provide the basis for its exclusion from the scope of license renewal.
LRA Section: 2.3, Scoping and Screening Results: Mechanical 2.3.3, Auxiliary Systems 2.3.3.10, Fire Protection System The staff reviewed the Three Mile Island Nuclear Station (TMI), Unit 1, license renewal application (LRA); updated final safety analysis report (UFSAR), Section 9.9, Plant Fire Protection Program; NRC-approved fire protection program; fire hazard analysis Volumes 1 and 2; point-by-point comparison with Appendix A to Branch Technical Position (BTP) Auxiliary and Power Conversion Systems Branch (APCSB) 9.5-1, ?Guidelines for Fire Protection for Nuclear Power Plants,@ May 1, 1976, documented in the TMI1 UFSAR, Section 9.9; and fire protection current licensing basis documents listed in the TMI Unit 1 Operating License Condition 2.c.4.
The staff found that the fire protection systems and components discussed in the following sections have been excluded from the scope of license renewal and an aging management review (AMR). These systems and components were not included in the license renewal boundaries and appear to have fire protection intended functions required for compliance with Title 10, Energy, of the Code of Federal Regulations (CFR) 50.48, Fire protection, as stated in 10 CFR 54.4. Therefore, in order to complete our review, the staff requires responses to the following requests for additional information (RAIs):
RAI#: D-2.3.3.10-1 Section 4.3.1.2 of the TMI1 SER dated September 19, 1978, discusses fire pumps for fire water supply systems. The SER states that the water supply is delivered by a combination of three centrifugal fire pumps, each with a rating of 2500 gpm at 125 psig. One pump, located in the intake screen and pump house, is an electric motor-driven vertical shaft centrifugal pump, taking suction from one of the intake bays beneath the intake screen and pump house LRA Section 2.3.3.10 discusses requirements for the fire water supply system but does not mention trash racks and traveling screens for the fire pump suction water supply.
ENCLOSURE 2
Trash racks and traveling screens are located upstream of the fire pump suctions to remove any major debris from the fresh or raw water. Trash racks and traveling screens are necessary to remove debris from and prevent clogging of the fire protection water supply system. Trash racks and traveling screens are typically considered to be passive, long-lived components. Both the trash racks and traveling screens are located in a fresh or raw water/air environment and are typically constructed of carbon steel. Carbon steel in a fresh or raw water environment or water/air environment is subject to loss of material, pitting, crevice formation, and microbiologically influenced corrosion and fouling. Explain the apparent exclusion of the trash racks and traveling screens that are located upstream of the fire pump suctions from the scope of license renewal, (see 10 CFR 54.4(a)), and explain why they are not subject to an AMR, (see 10 CFR 54.21(a)(1)).
RAI#: D-2.3.3.10-2 Section 4.3.1.5 of the TMI1 SER dated September 19, 1978, discusses turbine building automatic wet pipe sprinkler and deluge systems used to protect lube oil systems, the hydrogen seal oil system, the basement and mezzanine areas, and feedwater pump turbine bearings.
This section also lists automatic sprinkler systems used to protect the 306-foot elevation of the control building, part of the adjacent fuel handling building, each of the two diesel generator rooms, the diesel fire pump house, the intake screen and pump house, the circulating water pump house, the machine shop, the service building, air intake tunnel, combustion and cooling air intakes for the diesel generators, and penetration area at the 281-foot elevation of the auxiliary building.
The automatic sprinkler systems do not appear in LRA Section 2.3.3.10 as being within the scope of the license renewal and subject to an AMR. The staff requests that the applicant state whether the above automatic sprinkler systems are within the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1).
If they are excluded from the scope of license renewal and are not subject to an AMR, the staff requests that the applicant justify the exclusion.
RAI#: D-2.3.3.10-3 Section 4.3.1.5 of the TMI1 SER dated September 19, 1978, discusses automatic water spray systems to protect the oil filled transformers located outside the turbine building.
The automatic water spray systems do not appear in LRA Section 2.3.3.10 as being within the scope of the license renewal and subject to an AMR. The staff requests that the applicant verify whether the above water spray systems are within the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and are not subject to an AMR, the staff requests that the applicant provide justification for the exclusion.
RAI#: D-2.3.3.10-4 Section 4.3.2 of the TMI1 SER dated September 19, 1978, discusses total flooding automatic Halon 1301 extinguishing systems to protect the subfloor of the computer room on the 355-foot elevation of the control building, adjacent to the control building and chemical supervisor office at the 322-foot elevation of the control building.
The total flooding automatic Halon 1301 extinguishing systems do not appear in LRA Section
2.3.3.10 as being within the scope of the license renewal and subject to an AMR. The staff requests that the applicant state whether the above total flooding automatic Halon 1301 extinguishing systems are within the scope of license renewal in accordance with 10 CFR 54.4(a) and subject to an AMR in accordance with 10 CFR 54.21(a)(1). If they are excluded from the scope of license renewal and are not subject to an AMR, the staff requests that the applicant justify the exclusion.
RAI#: D-2.3.3.10-5 LRA Tables 2.3.3-10 and 3.3.2-10 exclude several types of fire protection components that are discussed in the SERs and/or UFSAR. These components are listed below:
- hose connections
- hose racks
- yard hose houses
- interior fire hose stations
- pipe supports
- buried piping
- filter housing
- flexible hose
- dikes for oil spill confinement
- buried underground fuel oil tanks for emergency diesel generators
- fire water main loop valves
- post indicator valves
- lubricating oil collection system components for each reactor coolant pump
- lubricating oil cooler
- auxiliary lubricating oil makeup tank
- floor drains and curbs for fire-fighting water
- backflow prevention devices
- flame retardant coating for cables
- fire retardant coating for structural steel supporting walls and ceilings
- thermal insulation on valves
- engine intake and exhaust silencers/muffler (diesel driven fire pump)
- heat exchanger (bonnet)
- heat exchangers (shell)
- heat exchangers (tube)
For each, determine whether the component should be included in Tables 2.3.3.10 and 3.3.2-10, and, if not, justify the exclusion.
LRA Section: 2.4, Scoping and Screening Results: Structures RAI#: D-2.4.0-1 To clarify the component identified as Steel Components: All Structural Steel in various LRA Tables 2.4-XX, please confirm that the connection components (e.g. gusset plates, welds, etc.)
are in-scope for license renewal and subject to an AMR.
LRA Section: 2.4, Scoping and Screening Results: Structures 2.4.2, Auxiliary Building RAI#: D-2.4.2-1 Section 2.6.5.d.4 of the TMI UFSAR states, Flood Gate (TMI-FG-B1) at 306 foot floor elevation between Aux Building and Turbine Building areas.
Table 2.4-2 for the Auxiliary Building Components Subject to Aging Management Review does not list Flood Gate specifically in any row. If it is not included as an oversight, please provide a description of the scoping and aging management review. If it is covered somewhere else in the LRA, please indicate the location. If it is excluded from the scope of license renewal, please provide the basis for the exclusion.
LRA Section: 2.4, Scoping and Screening Results: Structures 2.4.4, Control Building RAI#: D-2.4.4-1 Section 2.6.5.c of the TMI UFSAR states, Flood Gate (TMI-FG-B2) at 306 foot floor elevation between Turbine Building and Control Building areas.
Table 2.4-4 for the Control Building Components Subject to Aging Management Review does not list Flood Gate specifically in any row. If it is not included as an oversight, please provide a description of the scoping and aging management review. If it is covered somewhere else in the LRA, please indicate the location. If it is excluded from the scope of license renewal, please provide the basis for the exclusion.
LRA Section: 2.4, Scoping and Screening Results: Structures 2.4.5, Diesel Generator Building RAI#: D-2.4.5-1 Section 2.6.5.f.1 of the TMI UFSAR states,
- 1. Flood Gates (TMI-FG-D1/D2A/D2B/D3) at 305 foot floor elevation.
Table 2.4-5 for the Diesel Generator Building Components Subject to Aging Management Review does not list Flood Gates specifically in any row. Please clarify if the Flood Gates fall into the Metal components: All structural members category. If they are not included as an oversight, please provide a description of the scoping and aging management review. If they are covered somewhere else in the LRA, please indicate the location. If they are excluded from the scope of license renewal, please provide the basis for the exclusion.
RAI#: D-2.4.5-2 Section 2.4.5 of the LRA, regarding the Diesel Generator Building, states, Steel panels are installed in the equipment access openings on the west side of the building for protection from flood and tornado loads including tornado missiles.
Table 2.4-5 for the Diesel Generator Building Components Subject to Aging Management Review does not list Missile Protection as an intended function for any components other than Concrete. Please address the absence of the Missile Protection function of the aforementioned steel panels from Table 2.4-5.
LRA Section: 2.4, Scoping and Screening Results: Structures 2.4.6, Dike/Flood Control System RAI#: D-2.4.6-1 Section 2.4.6 of the LRA, regarding the Dike/Flood Control System, states, This structure also contains a sluice gate and associated operator supported by a structural steel platform on the inboard side of the dikeThe sluice gate and associated operator on the inboard side of the dike are active components and, therefore, are not subject to aging management review.
The aforementioned structural steel platform is not listed in Table 2.4-6, Components Subject to Aging Management Review, nor is it explicitly excluded from the scope by the Section 2.4.6 evaluation. If it is not included as an oversight, please provide a description of the scoping and aging management review. If it is covered somewhere else in the LRA, please indicate the location. If it is excluded from the scope of license renewal, please provide the basis for the exclusion.
LRA Section: 2.4, Scoping and Screening Results: Structures 2.4.10, Mechanical Draft Cooling Tower Structures RAI#: D-2.4.10-1 Section 2.4.10 of the LRA, Mechanical Draft Cooling Tower (MDCT) Structures, states that the intended function of the MDCT basin is to provide structural support and a flow path for the inlet
and outlet river discharge piping. Within the current licensing basis, please justify the LRA statement that the failure of the building, adjoining TMI-2 structure, and sodium bisulfate tank foundation and dike does not affect the intended functions of the MDCT basin.
LRA Section: 2.4, Scoping and Screening Results: Structures 2.4.12, Natural Draft Cooling Towers RAI#: D-2.4.12-1 Section 2.4.12 of the LRA, Natural Draft Cooling Towers, states that the intended function of the reinforced concrete basin is to provide structural support and a flow path for the Circulating Water Pump House. Within the current licensing basis, please justify the LRA statement that the failure of the reinforced concrete hyperbolic towers, the wooden fill structure, and the canopy at the base of the towers does not affect the intended functions of the basin.
LRA Section: 2.4, Scoping and Screening Results: Structures 2.4.14, Reactor Building RAI#: D-2.4.14-1 Section 2.4.14, Reactor Building, of the LRA states, The foundation matis a nominal 9 feet thick with a 2 foot thick concrete slab above the bottom 1/4 -inch liner plate.
Please confirm that the inaccessible floor liner plate of the base mat including the leak chase system and the concrete fill slab above this liner are included in the components listed in Table 2.4-14.
LRA Section: 2.4, Scoping and Screening Results: Structures 2.4.16, Service Building RAI#: D-2.4.16-1 Section 2.4.16, Service Building, of the LRA states, The evaluation boundary for the Service Building includes the Service Building and Machine Shop, which are classified as Class III structures and designed to withstand the effects of normal operating loads.
The purpose of the Service Building is to provide structural support, shelter, and protection for safety-related mechanical components required for safe operation of the plant, including safe shutdown of the reactor.
Per UFSAR Section 5.1.1.3, Class III structures, systems, and components (SSC) are those SSC which are not related to reactor operation. As such, the staff finds the above statements within the LRA contradictory and in need of clarification.
RAI#: D-2.4.16-2 Section 2.4.16, Service Building, of the LRA states, Some of the interior reinforced concrete piers and a portion of the exterior reinforced concrete grade beam are supported on the reinforced concrete circulating water pipe tunnel which passes under the Service Building concrete floor slab at elevation 305-0.
Table 2.4-16 does not explicitly refer to the reinforced concrete circulating water pipe tunnel, nor does Section 2.4.11, Miscellaneous Yard Structures. Please confirm that the reinforced concrete circulating water pipe tunnel which provides support for the Service Building is included in the scope of license renewal. If it is not included as an oversight, please provide a description of the scoping and aging management review. If it is covered somewhere else in the LRA, please indicate the location. If it is excluded from the scope of license renewal, please provide the basis for the exclusion.
LRA Section: 2.4, Scoping and Screening Results: Structures 2.4.19, Turbine Building RAI#: D-2.4.19-1 Section 2.4.19, Turbine Building, of the LRA states, The purpose of the buildings is to provide structural support, shelter and protection for mechanical and electrical equipment required for safe operation of the plant, including safe shutdown of the reactor.
Section 5.4.3.2.5 of the TMI UFSAR states, There is no equipment located in the Turbine Building that is required for safe shutdown of the plant.
The staff finds these statements contradictory and in need of clarification.
LRA Section: 2.5, Scoping and Screening Results: Electrical Systems/Commodity Groups RAI #: D-2.5-1 Operating experience has shown that cable tie-wraps can fail as a result of age- related brittleness of the plastic material. These cable tie-wraps would be considered long-lived passive components depending on whether they have a credited design function. Some possible intended design functions include: maintaining spacing for power cable ampacity; maintaining stiffness in unsupported lengths of wire bundles to ensure minimum bending radius; and maintaining cables within vertical raceways, among others. Most recently, at Point Beach, the regional inspectors identified an unresolved item (Inspection Report 05000266/2006006; 05000301/2006006) after noticing that the current configuration of the plant may not be consistent with plant design documents due to the age-related breakage of a large number of plastic tie-wraps used to fasten wires and cables. At Point Beach, cable tie-wraps are used to
maintain cable ampacity or are used to seismically qualify the cable tray system. Explain how Three Mile Island manages the aging of cable tie-wraps if they are credited in the plant design basis. In addition, justify the exclusion of cable tie-wraps from the scope of license renewal (see 10 CFR 54.4).