ML25101A307

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March 17, 2025, Summary of Meeting with Constellation Energy Generation, LLC Plan to Submit a Request to Use Later Edition of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI at TMI, Unit 1 EPID L-202
ML25101A307
Person / Time
Site: Crane 
(DPR-050)
Issue date: 04/14/2025
From: Justin Poole
NRC/NRR/DORL/LPL3
To:
Constellation Energy Generation
Poole J, NRR/DORL/LPLI, 301-415-2048
Shared Package
ML25101A308 List:
References
EPID L-2025-LRM-0018
Download: ML25101A307 (5)


Text

April 14, 2025 LICENSEE:

CONSTELLATION ENERGY GENERATION, LLC FACILITIES: THREE MILE ISLAND NUCLEAR STATION, UNIT 1

SUBJECT:

SUMMARY

OF MARCH 17, 2025, MEETING WITH CONSTELLATION ENERGY GENERATION, LLC REGARDING PLAN TO SUBMIT A REQUEST TO USE LATER EDITION OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE, SECTION XI AT THREE MILE ISLAND NUCLEAR STATION, UNIT 1 (EPID L-2025-LRM-0018)

On March 17, 2025, an Observation meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Constellation Energy Generation, LLC (the licensee) remotely. The purpose of the meeting was to discuss the licensees plan to submit a request to use a later edition of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code,Section XI at Three Mile Island Nuclear Station, Unit 1 (TMI-1),

to support potential resumption of power operations, and to discuss how the licensee will implement its inservice testing (IST) and inservice inspection (ISI) programs during the restart project. The meeting notice and agenda, dated March 5, 2025, is available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML25070A266. A list of attendees is provided as an Enclosure. The licensees slide presentation is available in ADAMS at Accession No. ML25070A169.

The licensee began the presentation with some background information such as a brief timeline on recent plant milestones. The licensee then gave a background on the ISI and IST programs at TMI-1, including which start and end dates for the intervals for each program, as well as the code of record for each program. For the ISI program, the licensee stated that the fourth interval started on April 20, 2011, and was scheduled to end on April 19, 2022, with the 2004 Edition of the ASME B&PV Code Section XI being the code of record. For the IST program, the licensee stated that the fifth interval started on October 25, 2013, and was scheduled to end on September 22, 2024, with the 2004 Edition through 2006 Addenda of the ASME Operation and Maintenance Code being the code of record. The licensee stated that they intend to request approval to use the 2013 Edition of ASME Section XI for non-destructive examination (NDE) and repair and replacement activities. The licensee clarified that the 2004 Edition of ASME Section XI would remain as the fourth intervals code of record for selection of ISI examinations.

The NRC staff asked why the licensee was choosing the 2013 Edition and the licensee stated that this request would align TMI-1 with the rest of the Constellation fleet, since the fleet has been approved for the 2013 Edition for NDE and would allow them to use fleet procedures for NDE activities. The licensee pointed to previous examples where the NRC has granted similar requests, including for Constellation. The NRC staff asked about whether the licensee still had its records from previous examinations and the licensee stated that previous examinations were stored in its fleet database which still exists.

The licensees presentation then focused on the restoration plan for the ISI and IST programs at TMI-1. The licensee stated that they plan to extend the duration of the fourth ISI interval and the fifth IST interval in accordance with allowances in the code for plants out of service continuously for 6 months or more. Meaning during the period of restoration, the intervals and codes of records for the ISI and IST programs would be the same as when they shut down in 2019 (ISI - fourth interval, 2004 Edition; IST - fifth interval 2004 Edition through 2006 Addenda). There was some discussion between the NRC and the licensee around this topic as to whether those allowances in the code for plants to extend an interval would be applicable to TMI-1. Normally those plants that have used that allowance were still operating and still had ISI and IST programs in place. The licensee and NRC agreed that more discussion might be needed on this topic. The licensee then stated that by having these programs back in place, they will support TMI-1s overall plan to assess plant condition and restore equipment to operation. Should the NRC grant resumption of power operations, the licensee stated that the plant would begin the fifth ISI and sixth IST intervals. The licensee also stated that the new codes of record for the new intervals would be selected within 18 months of interval start dates in accordance with the regulations. The licensee ended its presentation with a timeline depicting the two programs and which interval each program was or would be in starting when the plant was operating in 2019, through the restoration phase, and out past their projected return to operation date sometime in 2027. The NRC staff asked some questions around snubbers and the licensee stated that they would be included in the restoration plans and they are looking at removal of snubbers from the technical specifications when they develop that request. The staff also asked about whether Code Case N-921, related to extended intervals, would be requested and the licensee said not for the restoration phase, but may look into incorporating that into their code of records if the plant becomes operational.

Members of the public were in attendance and a some of them had comments for the NRC staff.

One commenter worked as a vendor and provided some insight on the planned request. The remaining commenters were against the licensee moving forward with the project and were concerned about potential loss of institutional knowledge at the site, the agencys greater reliance on risk rather than defense in depth, availability for the plant to procure parts needed to replace components for a plant this old, the use of exemptions, potential loss of records at the site, and a belief that the quality assurance was lost and cannot be reestablished.

No Public Meeting Feedback Forms were received.

Please direct any inquiries to me at 301-415-2048, or via email at Justin.Poole@nrc.gov.

/RA/

Justin C. Poole, Project Manager Plant Licensing Branch 3 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-289

Enclosure:

List of Attendees cc: Listserv

Enclosure LIST OF ATTENDEES MARCH 17, 2025, MEETING WITH CONSTELLATION ENERGY GENERATION, LLC PLAN TO SUBMIT A REQUEST TO USE LATER EDITION OF THE AMERICAN SOCIETY OF MECHANICAL ENGINEERS BOILER AND PRESSURE VESSEL CODE, SECTION XI AT THREE MILE ISLAND NUCLEAR STATION, UNIT 1 NRC

Participants:

Jamie Pelton, Acting Director, Office of Nuclear Reactor Regulation (NRR)/Division of Operating Reactor Licensing (DORL)

Justin Poole, Senior Project Manager, NRR/DORL/ Plant Licensing Branch 3 (LPL3)

Luke Haeg, Project Manager, NRR/DORL/LPL3 Ray McKinley, Deputy Director, Region I/Division of Operating Reactor Safety (DORS)

Erin Carfang, Branch Chief, Region I/Engineering Branch I Nik Floyd, Senior Reactor Inspector, Region I/Engineering Branch I Khaing Hsu Wai, Reactor Engineer, Region I/Engineering Branch I Michael Smith, Reactor Engineer, Region I/Engineering Branch I Angie Buford, Branch Chief, NRR/Division of New and Renewed Licenses (DNRL)/Vessels and Internals Branch (NVIB)

Michael Benson, Materials Engineer, NRR/DNRL/NVIB Steven Levitus, Materials Engineer, NRR/DNRL/NVIB John Honcharik, Senior Materials Engineer, NRR/DNRL/NPHP Stewart Bailey, Branch Chief, NRR/Division of Engineering and External Hazards (DEX)/Mechanical Engineering and Inservice Testing Branch (EMIB)

Gurjendra Bedi, Mechanical Engineer, NRR/DEX/EMIB Nick Hansing, Mechanical Engineer, NRR/DEX/EMIB Brett Klukan, Office of General Counsel Diane Screnci, Senior Public Affairs Officer Mitchell Hoskins, Congressional Affairs Officer April Nguyen, Team Lead, Region III/DORS/PRT Julie Winslow, Senior Project Engineer, Region III/DORS/PRT Nick Armstrong, Project Engineer, Region IV/Division of Reactor Safety/Projects Branch D Zach Turner, Project Manager, NRR/DORL/LPL 2-1 Jennifer Beaton, General Engineer Grace Pennington, General Engineer Brittany Ford, Project Engineer, Region I Kris Smetana, Project Engineer, Region I Amanda Leatherman, Office of General Counsel Constellation Energy Generation, LLC:

Craig Smith, Senior Manager Regulatory Assurance Dennis Moore, Senior Manager, Licensing Mark J. Rogers Mark E. Weis Joshua J. Crow Romit Patel Dana J. DeAngelis Nathan D. Wortman Kyle Maguire Stephanie M. Bracke Public:

Donna Slivon James Davis David Bidwell Kimberly Patek Daniel Lamond Stephen Coleman James Rapp Jana Bergman Steve Catron David Shiner Mark Ferlisi Diane DArrigo Deric Tilson Joy Jiang Eric Epstein Ryan Fuld PJ Seel Paul Hansen Michael Keegan Colleen Coffey Alejandro Carrasquillo 161XXXXXX71 171XXXXXX15

Package: ML25101A308 Meeting Slides: ML25070A169 Meeting Notice: ML25070A266 Meeting Summary: ML25101A307 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME JPoole SRohrer IBerrios JPoole DATE 04/11/2025 04/14/2025 04/14/2025 04/14/2025