ML18108A287

Submittal of Response to Request for Additional Information Regarding Inspection Plan for Reactor Internals Action Item 7

ML18108A287
Person / Time
Site:	Three Mile Island
Issue date:	04/18/2018
From:	David Helker Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
Shared Package
ML18108A287	List: ML18108A287
References
EPID L-2016-LLL-0002, TMl-18-049
Download: ML18108A287 (12)

Text

ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION

- WITHHOLD UNDER 10 CFR 2.390 -

WHEN SEPARATED FROM ATTACHMENT 1, THIS LETTER IS DECONTROLLED.

200 Exelon Way Kennett Square, PA 19348 Exelon Generation www.exeloncorp.com 10 CFR Part 54 TMl-18-049 April 18, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 (TMI)

Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289

Subject:

Response to Request for Additional Information Three Mile Island Nuclear Station, Unit 1 - Request for Additional Information Regarding Inspection Plan for Reactor Internals Action Item 7 (EPID L-2016-LLL-0002)"

References:

1. Letter from Justin C. Poole, NRC Project Manager to Bryan C. Hanson (Exelon Generation Company, LLC), "Three Mile Island Nuclear Station, Unit 1 - Request for Additional Information Regarding Inspection Plan for Reactor Internals Action Item 7 (EPID L-2016-LLL-0002)," dated February 26, 2018 (ADAMS Accession No. ML180438134).

2. Letter from Edward W. Callan (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Submittal of Inspection Plan for Reactor Internals, A/LAI #7 Component Evaluation," dated September 16, 2016 (ADAMS Accession No. ML16263A318).

By letter dated September 16, 2016 (Reference 2) Exelon submitted the inspection plan for reactor internals, A/LAI Component Evaluation in accordance with MRP-227-A Action Item 7.

The NRC staff reviewed the information provided that supports the inspection plan and identified the need for additional information in order to complete their evaluation of the submitted inspection plan . The request for additional information (RAI) was sent from the NRC to Exelon on February 26, 2018 (Reference 1). It was agreed that the RAI response would be provided by April 12, 2018.

ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION

-WITHHOLD UNDER 10 CFR 2.390-WHEN SEPARATED FROM ATTACHMENT 1, THIS LETTER IS DECONTROLLED.

AITACHMENT 1 TRANSMIITED HEREWITH CONTAINS PROPRIETARY INFORMATION

- WITHHOLD UNDER 10 CFR 2.390 -

WHEN SEPARATED FROM ATTACHMENT 1, THIS LEITER IS DECONTROLLED.

U.S. Nuclear Regulatory Commission Response to Request for Additional Information Regarding Inspection Plan for Reactor Internals Action Item 7 April 18, 2018 Page 2 On April 11, 2018 Exelon contacted the NRC Project Manager for TMI and discussed the need for a new affidavit for the proprietary information contained in the RAI response. It was agreed that additional time would be afforded to secure an affidavit and the response would be delayed about a week. to this letter provides a restatement of the RAI questions followed by our responses. Attachment 1 contains proprietary information. Attachment 2 contains the non-proprietary version. contains the Framatome, Inc. Affidavit for withholding proprietary information in accordance with 10 CFR 2.390. The Framatome affidavit references their proprietary document, "Engineering Information Record, 51-9282772-000, 'Three Mile Island Unit 1 MRP-227-A Applicant/Licensee Action Item 7 RAI Response Support'," which identifies the proprietary information contained in the specific RAI questions and responses in Attachment 1.

There are no regulatory commitments in this response.

If you have any questions or require additional information, please contact Frank Mascitelli at 610-765-5512.

Respectfully, David P. Helker Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. Response to Request for Additional Information Three Mile Island Nuclear Station, Unit 1 - Request for Additional Information Regarding Inspection Plan for Reactor Internals Action Item 7 (EPID L-2016-LLL-0002}," Proprietary Version

2. Response to Request for Additional Information Three Mile Island Nuclear Station, Unit 1 - Request for Additional Information Regarding Inspection Plan for Reactor Internals Action Item 7 (EPID L-2016-LLL-0002)," Non-Proprietary Version

3. Framatome, Inc. Affidavit ATTACHMENT 1 TRANSMIITED HEREWITH CONTAINS PROPRIETARY INFORMATION

- WITHHOLD UNDER 10 CFR 2.390 -

WHEN SEPARATED FROM AITACHMENT 1, THIS LEITER IS DECONTROLLED.

ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION

- WITHHOLD UNDER 10 CFR 2.390 -

WHEN SEPARATED FROM ATTACHMENT 1, THIS LETTER IS DECONTROLLED.

U.S. Nuclear Regulatory Commission Response to Request for Additional Information Regarding Inspection Plan for Reactor Internals Action Item 7 April 18, 2018 Page 3 cc: Regional Administrator - NRC Region I w/ Attachment 2 Only NRC Senior Resident Inspector-Three Mile Island Nuclear Station, Unit 1 (TMI) w/ Attachment 2 Only NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 (TMI) w/ Attachments 1, 2 and 3 Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection w/ Attachment 2 Only ATTACHMENT 1 TRANSMITTED HEREWITH CONTAINS PROPRIETARY INFORMATION

- WITHHOLD UNDER 10 CFR 2.390 -

WHEN SEPARATED FROM ATTACHMENT 1, THIS LETTER IS DECONTROLLED.

ATTACHMENT 2 Three Mile Island Nuclear Station, Unit 1 NRC Docket No. 50-289 Response to Request for Additional Information - Three Mile Island Nuclear Station, Unit 1 - Request for Additional Information Regarding Inspection Plan for Reactor Internals Action Item 7 (EPID L-2016-LLL-0002) - Non-Proprietary Version

U.S. Nuclear Regulatory Commission Attachment 2 Response to Request for Additional Information Page 1 of 4 Regarding Inspection Plan for Reactor Internals Action Item 7 NRC Docket No.: 50-289 By letter dated September 16, 2016 Exelon submitted the inspection plan for reactor internals, A/LAI Component Evaluation in accordance with MRP-227-A Action Item 7.

The NRC staff reviewed the information provided that supports the inspection plan and identified the need for additional information in order to complete their evaluation of the submitted inspection plan. The request for additional information (RAI) was sent from the NRC to Exelon on February 26, 2018.

RAl-1 Provide the details of the evaluation that concluded that the CRGT tube spacer casting material will [ ]. Provide the saturated saturated fracture toughness value that was determined.

Response to RAl-1

[

] The CRGT Spacer Castings are Grade CF3M, [

]

A saturated fracture toughness value was not determined. The time to saturation [

] was determined relative to the reduction in Charpy impact energy [3]. The saturation in the reduction of Charpy impact energy correlates to saturation in the reduction of fracture toughness [4].

RAl-2 ANP-3479P describes the location and type of the peak stresses in the CRGT spacer castings determined by stress analysis, but not the magnitude of these stresses. Provide the peak stress values for the CRGT spacer castings.

Response to RAl-2

[

U.S. Nuclear Regulatory Commission Attachment 2 Response to Request for Additional Information Page 2 of 4 Regarding Inspection Plan for Reactor Internals Action Item 7 NRC Docket No.: 50-289

]

RAl-3 For the lncore Monitoring Instrumentation (IMI) Guide Tube Spider Castings, provide details of the structural analysis that show the [ ]:

a) How were the stresses determined (e.g., finite element method, hand calculations.

b) Provide the stress levels with all four legs intact compared to stress levels with one or more legs failed; c) Provide the displacement of hub with one failed leg, compared with displacement that could prevent instrumentation insertion).

Response to RAl-3

[

]

RAl4 The lice~see stated in ANP-3479P that [

] However, the licensee did not discuss how it made this determination and did not discuss the reference for the lower bound fracture toughness value.

U.S. Nuclear Regulatory Commission Attachment 2 Response to Request for Additional Information Page 3 of 4 Regarding Inspection Plan for Reactor Internals Action Item 7 NRC Docket No.: 50-289 The NRC staff therefore requests the licensee provide a discussion of how the licensee determined that fracture toughness of the TMI, Unit 1, vent valve retaining rings [

] and a discussion of the reference for the lower bound fracture toughness value it provided.

Response to RAl-4

[

]

4.0 REFERENCES

1. Framatome Topical Report ANP-3479P, Revision 0, "MRP-227-A Applicant/Licensee Action Item 7 Analysis for Three Mile Island Unit 1."

2. [

]

3. [

]

4. EPRI Report TR-100034, Project 2643-5, "Cast Austenitic Stainless Steel Sourcebook,"

October 1991 .

5. [

]

6. [

]

7. [

]

U.S. Nuclear Regulatory Commission Attachment 2 Response to Request for Additional Information Page 4 of 4 Regarding Inspection Plan for Reactor Internals Action Item 7 NRC Docket No.: 50-289

8. [

]

9. [

]

10. [

]

ATTACHMENT 3 Three Mile Island Nuclear Station, Unit 1 NRC Docket No. 50-289 Framatome Affidavit

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) SS.

CITY OF LYNCHBURG )

1. My name is Philip A Opsal. I am Manager, Product Licensing, for Framatome Inc., (formally known as AREVA Inc.), and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by Framatome Inc., to determine whether certain Framatome Inc. information is proprietary. I am familiar with the policies established by Framatome Inc. to ensure the proper application of these criteria.

3. I am familiar with the Framatome Inc. information contained in the following document: Framatome Inc. Engineering Information Record, 51-9282772-000, "Three Mile Island Unit 1 MRP-227-A Applicant /Licensee Action Item 7 RAI Response Support," referred to herein as "Document." Information contained in this Document has been classified by Framatome Inc.

as proprietary in accordance with the policies established by Framatome Inc. for the control and protection of proprietary and confidential information.

4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by Framatome Inc. and not made available to the public. Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in

accordance with 10 CFR 2.390. The information for which withholding from disclosure is requested qualifies under 10 CFR 2.390{a)(4) "Trade secrets and commercial or financial information."

6. The following criteria are customarily applied by Framatome Inc. to determine whether information should be classified as proprietary:

(a) The information reveals details of Framatome lnc.'s research and development plans and programs or their results.

(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for Framatome Inc.

(d) The information reveals certain distinguishing aspects of a process, methodology, or component, the exclusive use of which provides a competitive advantage for Framatome Inc. in product optimization or marketability.

(e) The information is vital to a competitive advantage held by Framatome Inc.,

would be helpful to competitors to Framatome Inc., and would likely cause substantial harm to the competitive position of Framatome Inc.

The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(b), 6(c) and 6(d) above.

7. In accordance with Framatome lnc.'s policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside Framatome Inc. only as required and under suitable agreement providing for nondisclosure and limited use of the information.

8. Framatome lnc.'s policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.

9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me this \lotb day of l\Jn-1 I 2018, Sherry L. Mcf aden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/18 Reg. # 7079129 SHERRYL. MCFADEN Notary Publlc Commonwealth of Virginia 7079129 My Comml11lon Expires Oct 31, 201 e