TMI-09-009, Future Correspondence Concerning the License Renewal Application and a Revision to the License Renewal Commitment List

Future Correspondence Concerning the License Renewal Application and a Revision to the License Renewal Commitment List

ML090280368
Person / Time
Site:	Three Mile Island
Issue date:	01/26/2009
From:	Gallagher M Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MD9012, TAC MD9013, TAC MD9014, TMI-09-009
Download: ML090280368 (17)

Text

Michael P. Gallagher, PE Telephone 610.765.5958 Exelonm Nuclear Vice President www.exeloncorp.com License Renewal Projects michaelp.gallagher@exeloncorp.com 10 CFR 50 Exelon Nuclear 10 CFR 51 2oo Exelon Way 10 CFR 54 KSA/2-E Kennett Square, PA.19 348 TMI-09-009 January 26, 2009 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Three Mile Island Nuclear Station, Unit 1 Facility Operating License No. DPR-50 NRC Docket No. 50-289

Subject:

Future Correspondence Concerning the License Renewal Application of Three Mile Island, Unit 1, and a Revision to the License Renewal Commitment List

References:

1. Letter from M. Gallagher (AmerGen Energy Company, LLC) to U. S. Nuclear Regulatory Commission, "Three Mile Island Nuclear, Unit 1 License Renewal Application," dated January 8, 2008

2. Letter from C. Gratton (U. S. Nuclear Regulatory Commission) to Charles Pardee (AmerGen Energy Company, LLC, "Clinton Power Station, Unit No.1; Oyster Creek Nuclear Generating Station; and Three Mile Island Nuclear Station Unit 1 -Issuance of Conforming Amendments Re: Direct Transfer of Facility Operating License to Exelon Generation Company, LLC (TAC NOS.

MD9012, MD9013, AND MD9014)," dated January 8, 2009 In the Reference 1 letter, AmerGen Energy Company, LLC (AmerGen) submitted a License Renewal Application for Three Mile Island Nuclear Station, Unit 1, which would extend the term of the current operating license an additional 20 years.

In the Reference 2 letter, the U. S. Nuclear Regulatory Commission (USNRC) approved the formal transfer of the operating license for Three Mile Island Nuclear Station, Unit 1 from AmerGen to Exelon Generation Company, LLC (Exelon). Accordingly, all future correspondence and activities related to the License Renewal Application for Three Mile Island Nuclear Station, Unit 1 should be addressed to Exelon Generation Company, LLC.

In Attachment A ("Final Safety Analysis Report Supplement") to the Reference 1 letter, Three Mile Island, Unit 1 provided a "License Renewal Commitment List." This list (attached to this letter) has been modified as a result of the USNRC's Requests for Additional Information and the USNRC audit processes.

If you have any questions, please contact Fred Polaski, Manager License Renewal, at 610-765-5935.

3)5

January 26, 2009 Page 2 of 2 TMI-09-009 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2 6 th of January, 2009.

Respectfully, Michael P. Gallagher Vice President, License Renewal Exelon Generation Company, LLC

Attachment:

A.5 License Renewal Commitment List cc: Regional Administrator, USNRC Region I, w/Enclosure USNRC Project Manager, NRR - License Renewal, Safety, w/Enclosure USNRC Project Manager, NRR - License Renewal, Environmental, w/o Enclosure USNRC Project Manager, NRR - TMIGS, w/o Enclosure USNRC Senior Resident Inspector, TMIGS, w/o Enclosure File No. 08001

January 26, 2009 Page 1 of 15 TMI-09-009 Attachment Attachment A.5 License Renewal Commitment List Note: As a standard convention for Exelon, added text will be shown as bolded italics whereas deleted text will be shown as e*theuh.

January 26, 2009 Page 2 of 15 TMI-09-009 Attachment A.5 License Renewal Commitment List UFSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA Implementation Source Appendix A) Schedule

1. ASME Section XI Inservice Existing program is credited. A.2.1.1 Ongoing Section Inspection, Subsections IWB, B.2.1.1 IWC, and IWD

2. Water Chemistry Existing program is credited. The program will be A.2.1.2 Prior to the period of Section enhanced to incorporate the continuous monitoring of extended operation. B.2.1.2 sodium in steam generator blowdown, making it consistent with EPRI 1008224, Pressurized Water Reactor Secondary Water Chemistry Guidelines, Revision 6.

3. Reactor Head Closure Studs Existing program is credited. A.2.1.3 Ongoing Section The program will be enhanced to select an Priorto. the period of B.2.1.3 alternatestable lubricantthat is compatible extended operation.

with the fastenermaterial and the Letter 5928-environment. 08-20208 dated 10/30/2008

4. Boric Acid Corrosion Existing program is credited. A.2.1.4 Ongoing Section B.2.1.4

5. Nickel-Alloy Penetration Existing program is credited. A.2.1.5 Ongoing Section Nozzles Welded to the Upper B.2.1.5 Reactor Vessel Closure Heads of Pressurized Water Reactors

6. Flow-Accelerated Corrosion Existing program is credited. A.2.1.6 Ongoing Section B.2.1.6

7. Bolting Integrity Existing program is credited. A.2.1.7 Ongoing Section B.2.1.7

8. Steam Generator Tube Existing program is credited. A.2.1.8 Ongoing Section Integrity B.2.1.8

January 26, 2009 Page 3 of 15 TMI-09-009 Attachment UFSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA Implementation Source Appendix A) Schedule

9. Open-Cycle Cooling Water Existing program is credited. The program will be A.2.1.9 Prior to the period of Section System enhanced by adding a new river water chemical extended operation. B.2.1.9 treatment system to treat the river water systems for biofouling.

10. Closed-Cycle Cooling Water Existing program is credited. The program will be A.2.1.10 Prior to the period of Section System enhanced to include a one-time inspection of selected extended operation. B.2.1.10 components in stagnant flow areas to confirm the absence of aging effects resulting from exposure to closed cycle cooling water. Also, a one-time inspection of selected CCCW chemical mix tanks and associated piping components will be performed to verify corrosion has not occurred on the interior surfaces of the tanks and associated piping components.

11. Inspection of Overhead Heavy Existing program is credited. The program will be A.2.1.11 Prior to the period of Section Load and Light Load enhanced to include visual inspection of rails in the rail extended operation. B.2.1.11 (Related to Refueling) system for loss of material due to wear, and visual Handling Systems inspection of structural bolting for loss of material.

Acceptance criteria will be enhanced to require that significant loss of material due to wear will be evaluated or corrected to ensure the intended function of the crane or hoist is not impacted.

12. Compressed Air Monitoring Existing program is credited. The program will be A.2.1.12 Prior to the period of Section enhanced to include air quality testing for dew point, extended operation. B.2.1.12 particulates, lubricant content, and contaminants to ensure that the contamination standards of ANSI/ISAS7.0.01-1996, paragraph 5 are met. In addition the program will be enhanced to include air quality sampling on a representative sampling of headers on a yearly basis in accordance with the guidelines of ASME OM-S/G-1998, Part 17 and EPRI TR-108147.

January 26, 2009 Page 4 of 15 TMI-09-009 Attachment UFSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA Implementation Source Appendix A) Schedule

13. Fire Protection Existing program is credited. The program will be A.2.1 .13 Prior to the period of Section enhanced to include additional inspection criteria for extended operation. B.2.1.13 degradation of fire barrier walls, ceilings, and floors, and specific fuel supply line inspection criteria for diesel- Letter 5928-driven fire pumps during tests. 08-20204 In addition, implementing surveillanceprocedures dated for halon and carbon dioxide suppression systems 10/20/2008 will specificallyrequire inspection for corrosion, mechanical damage or damage to dampers, and will include acceptance criteria stating that detected signs of corrosionor mechanical damage be evaluated, with corrective action taken as appropriate.

14. Fire Water System Existing program is credited. The program will be A.2.1 .14 Prior to the period of Section enhanced to include sprinkler head testing in extended operation. B.2.1.14 accordance with NEPA 25, "Inspection, Testing and Maintenance of Water-Based Fire Protection Systems."

Samples will be submitted to a testing laboratory prior to being in service 50 years. This testing will be repeated at intervals not exceeding 10 years. Prior to the period of extended operation, the program will be enhanced to include periodic non-intrusive wall thickness measurements of selected portions of the fire water system at an interval not to exceed every 10 years.

15. Aboveground Steel Tanks Existing program is credited. The program will be A.2.1 .15 Prior to the period of Section enhanced to include one-time thickness measurements extended operation. B.2.1.15 of the bottom of the Condensate Storage Tanks, which are supported on concrete foundations. The measurements will be taken to ensure that significant degradation is not occurring and the component intended function will be maintained during the

_____ ______________________extended period of operation. The program will also be ________ ___________

January 26, 2009 Page 5 of 15 TMI-09-009 Attachment UFSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA Implementation Source Appendix A) Schedule enhanced to inspect the sealant at the tank-foundation interface.

16. Fuel Oil Chemistry Existing program is credited. The program will be A.2.1.16 Prior to the period of Section enhanced to include: extended operation. B.2.1.16

- The analysis of new fuel oil for specific or API gravity, kinematic viscosity, and water and sediment prior to filling the fuel oil storage tanks followed by full spectrum analysis within 31 days after the addition of the fuel oil into the fuel oil storage tanks.

- The determination of water and sediment and particulate contamination in accordance with ASTM standards.

" The analysis for bacteria in new and stored fuel oil.

" The addition of biocides, stabilizers, or corrosion inhibitors as determined by fuel oil analysis activities.

- Activities to periodically drain water and sediment from tank bottoms, and, activities to periodically drain, clean, and inspect fuel oil tanks.

- Manual sampling in accordance with ASTM standards and required frequencies.

- The use of ultrasonic techniques for determining tank bottom thicknesses should there be any evidence of loss of material due to general, pitting, crevice, and microbiologically influenced corrosion, and fouling found during visual inspection activities.

17. Reactor Vessel Surveillance Existing program is credited. The program will be A.2.1.17 Prior to the period of Section enhanced to address maintenance of the TMI-1 cavity extended operation. B.2.1.17 dosimetry exchange schedule. The program will also be enhanced to clarify that, if future plant operations exceed the limitations or bounds specified in Regulatory Position 1.3 of RG 1.99, Rev. 2, the impact of plant operation changes on the extent of reactor vessel

January 26, 2009 Page 6 of 15 TMI-09-009 Attachment UFSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA implementation Source Appendix A) Schedule embrittlement will be evaluated and the NRC will be notified.

18. One-Time Inspection Program is new. The program will be used to provide A.2.1 .18 Prior to the period of Section reasonable assurance that an aging effect is not extended operation. B.2.1.18 occurring, or that the aging effect is occurring slowly enough to not affect a components intended function during the period of extended operation, and therefore will not require additional aging management. The program will be credited for cases where either (a) an aging effect is not expected to occur but there is insufficient data to completely rule it out, (b)an aging effect is expected to progress very slowly in the specified environment, but the local environment may be more adverse than that generally expected, or (c) the characteristics of the aging effect include a long incubation period. This program will be used for the following:

- To confirm the effectiveness of the Water Chemistry program to manage the loss of material, cracking, and the reduction of heat transfer aging effects for steel, stainless steel, copper alloy, nickel alloy, and aluminum alloy in treated water, steam, and reactor coolant environments.

- To confirm the effectiveness of the Fuel Oil Chemistry program to manage the loss of material aging effect for steel, stainless steel, and copper alloy in a fuel oil environment.

- To confirm the effectiveness of the Lubricating Oil Analysis program to manage the loss of material and the reduction of heat transfer aging effects for steel, stainless steel, copper alloy, and aluminum alloy in a

_____ ________________________ lubricating oil environment. _________ ____________

January 26, 2009 Page 7 of 15 TMI-09-009 Attachment UFSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA Implementation Source Appendix A) Schedule

- To confirm the loss of material aging effect is insignificant for stainless steel and copper alloy in an air/gas - wetted environment.

Inspection methods will include visual examination or volumetric examinations. Acceptance criteria will be in accordance with industry guidelines, codes, and standards. The One-Time Inspection program provides for the evaluation of the need for follow-up examinations to monitor the progression of aging if age-related degradation is found that could jeopardize an intended function before the end of the period of extended operation. Should aging effects-be detected, the program triggers actions to characterize the nature and extent of the aging effect and determines what subsequent monitoring is needed to ensure intended functions are maintained during the period of extended oDeration.

19. Selective Leaching of Program is new. The program will be used to manage A.2.1 .19 Prior to the period of Section Materials the loss of material due to selective leaching. The extended operation. B.2.1.19 program includes inspection of a representative sample of susceptible components to determine if loss of material due to selective leaching is occurring. ýOne-time inspections will include visual examinations, supplemented by hardness tests, and other examinations, as required. If selective leaching is found, the condition will be evaluated to determine the need to expand inspection scope.

20. Buried Piping and Tanks Existing program is credited. The program will be A.2.1 .20 Prior to the period of Section Inspection enhanced to include: extended operation. B.2.1.20

- Inspection of buried stainless steel piping and components prior to entering the period of extended operation.

- Inspection of buried cast iron, carbon steel, concrete-

____ _______________________coated carbon steel, and stainless steel piping and _____________________ ______

January 26, 2009 Page 8 of 15 TMI-09-009 Attachment UFSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA Implementation Source Appendix A) Schedule components within ten years of entering the period of extended operation.

- Internal inspection and UT of the D.G. Fuel Storage 30,000 Gallon Tank prior to the period of extended operation, and within ten years of entering the period of extended operation.

21. External Surfaces Monitoring Program is new. The program will be used to manage A.2.1.21 Prior to the period of Section aging effects through visual inspection of external extended operation. B.2.1.21 surfaces for evidence of hardening and loss of strength and loss of material. The program directs visual inspections that are performed during system walkdowns. The program consists of periodic visual inspection of components such as piping, piping components, ducting, and other components within the scope of license renewal. Visual inspections may be augmented by physical manipulation to detect hardening and loss of strength of elastomers.

22. Inspection of Internal Surfaces Program is new. The program will be used to manage A.2.1.22 Prior to the period of Section in Miscellaneous Piping and cracking due to stress corrosion cracking; hardening extended operation. B.2.1.22 Ducting Components and loss of strength due to elastomer degradation; loss of material due to general, pitting, crevice, and Letter 5928-microbiologically influenced corrosion and fouling; and 08-20204 reduction of heat transfer due to fouling. The program dated includes provisions for visual inspections of the internal 10/20/2008 surfaces and volumetric testing of components not managed under any other aging management program.

Visual inspectionsmay be augmented by physical manipulation to detect hardeningand loss of strength of elastomers.

23. Lubricating Oil Analysis Existing program is credited. A.2.1.23 Ongoing Section B.2.1.23

January 26, 2009 Page 9 of 15 TMI-09-009 Attachment UFSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA Implementation Source Appendix A) Schedule

24. ASME Section Xl, Subsection Existing program is credited. A.2.1.24 Ongoing Section IWE B.2.1.24

25. ASME Section X1, Subsection Existing program is credited. A.2.1.25 Ongoing Section IWL B.2.1.25

26. ASME Section Xl, Subsection Existing program is credited. A.2.1.26 Ongoing Section IWF B.2.1.26

27. 10 CFR Part 50, Appendix J Existing program is credited. A.2.1.27 Ongoing Section B.2.1.27

28. Structures Monitoring Program Existing program is credited. The program will be A.2.1.28 Prior to the period of Section enhanced to include: extended operation. B.2.1.28

• In*p*ction of penetration seals- in The Service Letter 5928-Building, UPS Diesel Building, Mechanical Draft Cooling 08-20197 Tower Structures, afd Miscellaneous Yard Structures dated (Foundations for condensate storage tank, berated water storage diesel fuel storage tank, altitude 08/19/2008 tank, the borated waterstorage tank tunnel, duct banks, manholes) and the Storm Drainageand Flood Control Structure including the structuralplatform.

" Monitoring of Penetration Seals.

" Penetrationseals which perform a License Renewal intended function for an in-scope structure

- Monitoring of the Intake Canal for Loss of material and loss of form.

• Monitoring of electrical panels, junction boxes,

January 26, 2009 Page 10 of 15 TMI-09-009 Attachment UFSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA Implementation Source Appendix A) Schedule instrument panels, and conduits for loss of material due to corrosion.

- Monitoring of ground water chemistry by periodically sampling, testing, and analysis of ground water to confirm that the environment remains non-aggressive for buried reinforced concrete.

• Monitoring of reinforced concrete submerged in raw water associated with Intake Screen and Pumphouse, Circulating Water Pump House, Mechanical Draft Cooling Tower Structures, Natural Draft Cooling Tower Basins, and Dike!F~lod Control System Circulating Water Tunnel.

• Monitoring of vibration isolators, associated with component supports other than those covered by ASME XI, Subsection IWF, for reduction or loss of isolation function.

- Monitoring of HVAC duct supports for loss of material.

- Parameters monitored will be enhanced to include plausible aging effects and mechanisms.

- Monitoring of concrete structures for a reduction in anchor capacity due to local concrete degradation.

This will be accomplished by visual inspection of concrete surfaces around anchors for cracking, and spalling.

• Revised acceptance criteria to provide details specified in ACI 349.3R-96.

29. Protective Coating Monitoring Existing program is credited. A.2.1.29 Ongoing Section and Maintenance Program B.2.1.29

January 26, 2009 Page 11 of 15 TMI-09-009 Attachment UFSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA Implementation Source Appendix A) Schedule

30. Electrical Cables and Program is new. The program will be used to manage A.2.1.30 Prior to the period of Section Connections Not Subject to 10 aging of non-EQ cables and connections during the extended operation. B.2.1.30 CFR 50.49 Environmental period of extended operation. A representative sample Qualification Requirements of accessible cables and connections located in adverse localized environments will be visually inspected at least once every 10 years for indications of accelerated insulation aging such as embrittlement, discoloration, cracking, or surface contamination. An adverse localized environment is a condition in a limited plant area that is significantly more severe than the specified service environment for the cable or connection.

31. Electrical Cables and Existing program is credited. The program will be A.2.1.31 Prior to the period of Section Connections Not Subject to 10 enhanced to manage the aging of the cable and extended operation. B.2.1.31 CFR 50.49 Environmental connection insulation of the in scope radiation Qualification Requirements monitoring and nuclear instrumentation circuits inthe Used in Instrumentation Radiation Monitoring and Nuclear Instrumentation and Circuits Incore Monitoring Systems. The in scope radiation monitoring and nuclear instrumentation circuits are sensitive instrumentation circuits with low-level signals and are located in areas where the cables and connections could be exposed to adverse localized environments caused by heat, radiation, or moisture.

These adverse localized environments can result in reduced insulation resistance causing increases in leakage currents. Calibration testing and performance monitoring are currently being performed for in scope radiation monitoring circuits. Direct cable testing will be performed as an enhancement to ensure that the cable and connection insulation resistance is adequate for the nuclear instrumentation circuits to perform their intended functions.

January 26, 2009 Page 12 of 15 TMI-09-009 Attachment UFSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA Implementation Source Appendix A) Schedule

32. Inaccessible Medium Voltage Program is new. The program will be used to manage A.2.1.32 Prior to the period of Section Cables Not Subject to 10 CFR the aging effects and mechanisms of non-EQ, in scope extended operation. B.2.1.32 50.49 Environmental inaccessible medium voltage cables. These cables Qualification Requirements may at times be exposed to significant moisture Letter 5928-simultaneously with'significant voltage. The TMI-1 08-20208 cables in the scope of this aging management program dated will be tested using a proven test for detecting 10/30/2008 deterioration of the insulation system due to wetting, such as power factor, partial discharge, or polarization index, as described in EPRI TR-103834-P1-2, or other testing that is state-of-the-art at the time the test is performed. The cables will be tested at least once every 10 years. Manholes associated with the cables included in this aging management program will be inspected for water collection, initiallyat least twice a year, in accordance with existing practices, and drained as required. The frequency will be adjusted based on inspection results recognizing that the objective of the inspections, as a preventive action, is to keep the cables infrequently submerged, thereby minimizing their exposure to significantmoisture.

The maximum time between inspectionswill be 2 years, which is in alignment with the recommended frequency in the NUREG-1801 AMP XI.E3.

33. Metal Enclosed Bus Existing program is credited. The program will be A.2.1.33 Prior to the period of Section enhanced to include the following inspection criteria: extended operation. B.2.1.33

- The internal portion of the metal enclosed bus will be visually inspected for cracks, corrosion, foreign debris, excessive dust build-up and evidence of moisture intrusion.

_ The bus insulation will be visually inspected for signs

January 26, 2009 Page 13 of 15 TMI-09-009 Attachment UFSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA Implementation Source Appendix A) Schedule of embrittlement, cracking, melting, swelling, or discoloration, which may indicate overheating or aging degradation.

- The internal bus supports will be visually inspected for structural integrity and signs of cracks. The program will also be enhanced to perform internal visual inspections on the 480V Metal Enclosed Bus and the Station Black Out Metal Enclosed Bus.

34. Electrical Cable Connections Program is new. The program will be used to manage A.2.1.34 Prior to the period of Section Not Subject to 10 CFR 50.49 the aging effects of metallic parts of non-EQ electrical extended operation. B.2.1.34 Environmental Qualification cable connections within the scope of license renewal Requirements during the period of extended operation. A representative sample of non-EQ electrical cable connections will be selected for one-time testing considering application (medium and low voltage),

circuit loading (high loading) and location, with respect to connection stressors. The technical basis for the sample selected is to be documented. The specific type of test performed will be a proven test for detecting loose connections, such as thermography or contact resistance measurement, as appropriate to the application.

35. Nickel Alloy Aging Existing program is credited. TMI-1 commits to A.2.2.1 Ongoing Section Management Program implement applicable Bulletins, Generic Letters, and B.2.2.1 staff-accepted industry guidelines.

36. PWR Vessel Internals TMI-1 commits to the following activities for the PWR N/A Prior to the period of N/A Vessel Internals program: extended operation.

- Participate in the industry programs for investigating and managing aging effects on reactor internals.

- Evaluate and implement the results of the industry programs as applicable to the reactor internals.

- Upon completion of these programs, but not less than

January 26, 2009 Page 14 of 15 TMI-09-009 Attachment UPSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA Implementation Source Appendix A) Schedule 24 months before entering the period of extended operation, submit an inspection plan for reactor internals to the NRC for review and, approval.

37. Metal Fatigue of Reactor Existing program is credited. The program will be A.3.1 .1 Prior to the period of Section Coolant Pressure Boundary enhanced to add the statement: "Acceptable corrective extended operation. B.3.1.1 actions include: reanalysis of the component to demonstrate that the design code limit will not be exceeded prior to or during the period of extended operation; repair of the component; replacement of the component, or other methods approved by the NRC.'

In addition, the program will be enhanced to require a review of additional reactor coolant pressure boundary locations if the usage factor for one of the environmental fatigue sample locations approaches its design limit.

38. Concrete Containment Tendon Existing program is credited. A.3.1 .2 Ongoing Section Prestress B.3.1.2

39. Environmental Qualification Existing program is credited. A.3.1.3 Ongoing Section (EQ) of Electrical Components B.3.1.3

40. Steam Generators Install new Once Through Steam Generators (OTSGs) N/A Prior to the period of N/A prior to the period of extended operation. extended operation.

January 26, 2009 Page 15 of 15 TMI-09-009 Attachment UFSAR Supplement Enhancement or No. Program or Topic Commitment Location (LRA Implementation Source Appendix A) Schedule

41. New P-T Curves Revised pressure-temperature (P-T) limits and low- A.4.2.5 Prior t exc.eeng the 29 Section 4.2.5 temperature overpressurization (LTOP) limits for a 60 EFPY fluen,,e

........ upo year operating life have been prepared and will be ';-hich the current P T submitted to the NRC for approval. limits and LTOP limts a*re based.

Priorto the periodof extended operationor prior to exceeding 29 EFPY, whichever comes first.

42. ContainmentLiner Repair Priorto the periodof extended operation, N/A Priorto the period of Letter 5928-TMI-1 will restore the ReactorBuilding liner extended operation. 08-20208 to its nominalplate thickness by weld repair dated for the previously identified corrodedareas 10/30/2008 of the Reactor Building liner where the thickness of the base metal is reduced by more than 10% of the nominal plate thickness.

43. Boral Test Coupon Boral test coupon surveillance will continue N/A Ongoing Letter 5928-Surveillance through the period of extended operation. 08-20229 dated 11/12/2008