ML102640279

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Non-Acceptance, with Opportunity to Supplement, for TMI-1 RR-I4R-02, TAC No. ME4519
ML102640279
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 09/21/2010
From: Peter Bamford
Plant Licensing Branch 1
To: Tom Loomis
Exelon Corp
Bamford, Peter J., NRR/DORL 415-2833
References
TAC ME4519
Download: ML102640279 (1)


Text

From: Bamford, Peter Sent: Tuesday, September 21, 2010 11:09 AM To: 'thomas.loomis@exeloncorp.com' Cc: 'david.helker@exeloncorp.com'

Subject:

Non-Acceptance, With Oppoutunity to Supplement, for TMI-1 RR-I4R-02, TAC ME4519 By letter dated August 10, 2010, (Agencywide Documents Access and Management System (ADAMS) Accession Number ML102290162), Exelon Generation Company, LLC (Exelon) submitted a package of six relief requests associated with the fourth inservice inspection (ISI) interval for Three Mile Island Nuclear Station, Unit 1 (TMI-1). Relief Request I4R-02 requests approval for alternate risk-informed selection and examination criteria for certain pressure retaining piping welds in lieu of meeting requirements specified in the code of record for the TMI-1 fourth ISI interval. The fourth interval program is based on the American Society of Mechanical Engineers, Boiler and Pressure Vessel Code,Section XI, 2004 Edition, no Addenda. The purpose of this email is to provide the draft results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this relief request. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the request has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

The NRC staff has reviewed your submittal and concluded that the following information is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed request in terms of regulatory requirements and the protection of public health and safety and the environment.

Relief Request I4R-02 neither discusses the technical adequacy of its fire, seismic, and external events probabilistic risk assessment (PRA) nor provides a justification that these hazard groups are insignificant to the applications risk-informed decision making, and therefore is not demonstrated to be consistent with Regulatory Guide (RG) 1.200, revision 2 and RG 1.174, revision 1, both of which are referenced in the application.

Without this information, the NRC staff does not have sufficient information to begin its review.

Relief Request I4R-02 must be modified to provide a discussion confirming that either RG 1.200, revision 2, guidelines on the technical adequacy have been evaluated and satisfied, or provide a justification that these hazard groups are insignificant to the applications risk-informed decision making consistent with RG 1.174, revision 1, guidelines.

In order to make the submittal complete, the NRC staff requests that Exelon supplement the submittal by providing the information requested above. This will enable the NRC staff to begin its detailed technical review. If information responsive to the NRC staffs request is not received by October 13, 2010, the request will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with Relief Request I4R-02. Please note that the acceptance review status of the relief requests other than I4R-02, contained in the August 10, 2010, submittal, have been communicated to you separately.

Please confirm your availability for a teleconference to discuss this issue on the afternoon of Thursday, September 23, 2010. Please call me at the number listed below with that information and/or if you have any questions regarding this matter.

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Peter Bamford NRR/DORL/LPL 1-2 Limerick & TMI-1 Project Manager 301-415-2833