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Category:Letter type:TMI
MONTHYEARTMI-23-018, Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation2023-11-22022 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation TMI-23-013, Radiological Emergency Plan Document Revision2023-05-30030 May 2023 Radiological Emergency Plan Document Revision TMI-23-009, Submittal of Changes to Technical Specifications Bases2023-04-13013 April 2023 Submittal of Changes to Technical Specifications Bases TMI-23-004, Updated Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 12023-03-21021 March 2023 Updated Site-Specific Decommissioning Cost Estimate for Three Mile Island Nuclear Station, Unit 1 TMI-23-005, Updated Spent Fuel Management Plan2023-03-21021 March 2023 Updated Spent Fuel Management Plan TMI-23-002, Radiological Emergency Plan Document Revision2023-02-23023 February 2023 Radiological Emergency Plan Document Revision TMI-22-028, Radiological Emergency Plan Document Revisions2022-09-27027 September 2022 Radiological Emergency Plan Document Revisions TMI-22-016, 2021 Annual Radiological Effluent Release Report2022-04-25025 April 2022 2021 Annual Radiological Effluent Release Report TMI-22-017, 2021 Annual Radiological Environmental Operating Report2022-04-25025 April 2022 2021 Annual Radiological Environmental Operating Report TMI-22-018, 10 CFR 20.2206(b) Personnel Radiation Exposure Report for 20212022-04-19019 April 2022 10 CFR 20.2206(b) Personnel Radiation Exposure Report for 2021 TMI-22-015, Submittal of Changes to Technical Specifications Bases2022-04-13013 April 2022 Submittal of Changes to Technical Specifications Bases TMI-22-009, Registration of Use of Casks to Store Spent Fuel2022-03-0909 March 2022 Registration of Use of Casks to Store Spent Fuel TMI-22-008, 2021 Aircraft Movement Data Annual Report for TMI-12022-02-28028 February 2022 2021 Aircraft Movement Data Annual Report for TMI-1 TMI-22-004, Registration of Use of Casks to Store Spent Fuel2022-02-0606 February 2022 Registration of Use of Casks to Store Spent Fuel TMI-21-027, Supplement to License Amendment Request - Proposed Changes to the Three Mile Island Emergency Plan for Independent Spent Fuel Storage Installation Only Emergency Plan and Emergency Action Level Scheme2021-08-30030 August 2021 Supplement to License Amendment Request - Proposed Changes to the Three Mile Island Emergency Plan for Independent Spent Fuel Storage Installation Only Emergency Plan and Emergency Action Level Scheme TMI-21-024, 90-Day Notification Prior to First Storage of Spent Fuel2021-06-15015 June 2021 90-Day Notification Prior to First Storage of Spent Fuel TMI-21-025, Notification Pursuant to 10 CFR 72.140(d) of Intent to Apply Previously Approved 10 CFR 50, Appendix B, Quality Assurance Program to Independent Spent Fuel Storage Installation Activities2021-06-15015 June 2021 Notification Pursuant to 10 CFR 72.140(d) of Intent to Apply Previously Approved 10 CFR 50, Appendix B, Quality Assurance Program to Independent Spent Fuel Storage Installation Activities TMI-21-026, Demonstration of Compliance with NRC Order EA-20-103, Issuance of Order for Implementation of Additional Security Measures & Fingerprinting for Unescorted Access at Independent Spent Fuel Storage Installation2021-06-15015 June 2021 Demonstration of Compliance with NRC Order EA-20-103, Issuance of Order for Implementation of Additional Security Measures & Fingerprinting for Unescorted Access at Independent Spent Fuel Storage Installation TMI-21-018, License Amendment Request - Revised Three Mile Island Nuclear Station License in Support of Independent Spent Fuel Storage Installation (ISFSI) Only Security Plan2021-04-29029 April 2021 License Amendment Request - Revised Three Mile Island Nuclear Station License in Support of Independent Spent Fuel Storage Installation (ISFSI) Only Security Plan TMI-21-019, Submittal of 2020 Annual Radiological Environmental Operating Report2021-04-27027 April 2021 Submittal of 2020 Annual Radiological Environmental Operating Report TMI-21-017, Submittal of 2020 Annual Radiological Effluent Release Report2021-04-27027 April 2021 Submittal of 2020 Annual Radiological Effluent Release Report TMI-21-021, (TMI-1) and Unit 2 (TMI-2) - 10 CFR 20.2206(b) Personnel Radiation Exposure Report for 20202021-04-27027 April 2021 (TMI-1) and Unit 2 (TMI-2) - 10 CFR 20.2206(b) Personnel Radiation Exposure Report for 2020 TMI-21-009, License Amendment Request - Proposed Changes to the Three Mile Island Emergency Plan for Independent Spent Fuel Storage Installation Only Emergency Plan and Emergency Action Level Scheme2021-03-0404 March 2021 License Amendment Request - Proposed Changes to the Three Mile Island Emergency Plan for Independent Spent Fuel Storage Installation Only Emergency Plan and Emergency Action Level Scheme TMI-20-027, Request for Rescission of Security and Safeguards Order EA-02-026 ICM B.1.a from Three Mile Island Nuclear Station Renewed Facility License2020-10-0909 October 2020 Request for Rescission of Security and Safeguards Order EA-02-026 ICM B.1.a from Three Mile Island Nuclear Station Renewed Facility License TMI-20-026, Response to NRC Order EA-20-103, Issuance of Order for Implementation of Additional Security Measures & Fingerprinting for Unescorted Access at Three Mile Island Generating Station Independent Spent Fuel Storage Installation2020-09-15015 September 2020 Response to NRC Order EA-20-103, Issuance of Order for Implementation of Additional Security Measures & Fingerprinting for Unescorted Access at Three Mile Island Generating Station Independent Spent Fuel Storage Installation TMI-20-025, Letter Re Inadvertent Submittal of Exelon Generation Company, LLC - Rev. 95 to NO-AA-10, Quality Assurance Topical Report2020-07-16016 July 2020 Letter Re Inadvertent Submittal of Exelon Generation Company, LLC - Rev. 95 to NO-AA-10, Quality Assurance Topical Report TMI-20-021, Response to Request for Additional Information Regarding License Amendment Request - Deletion of PDTS 3/4.1.4, Handling of Irradiated Fuel with the Fuel Handling Building Crane, and Two Minor Administrative2020-07-0808 July 2020 Response to Request for Additional Information Regarding License Amendment Request - Deletion of PDTS 3/4.1.4, Handling of Irradiated Fuel with the Fuel Handling Building Crane, and Two Minor Administrative TMI-20-015, 2018-2019 Biennial 10 CFR 50.59 Summary Report and 2019 Commitment Revision Summary Report2020-04-30030 April 2020 2018-2019 Biennial 10 CFR 50.59 Summary Report and 2019 Commitment Revision Summary Report TMI-20-016, 2019 Annual Radiological Environmental Operating Report2020-04-30030 April 2020 2019 Annual Radiological Environmental Operating Report TMI-20-017, 2019 Annual Radiological Effluent Release Report2020-04-30030 April 2020 2019 Annual Radiological Effluent Release Report TMI-20-012, Island Nuclear Station, Unit 1 - Submittal of Changes to Technical Specifications Bases2020-04-13013 April 2020 Island Nuclear Station, Unit 1 - Submittal of Changes to Technical Specifications Bases TMI-20-002, Annual Notification of Property Insurance Coverage2020-03-25025 March 2020 Annual Notification of Property Insurance Coverage TMI-20-006, Notification of Revision of Commitment for Amended Post-Shutdown Decommissioning Activities Report (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10 CFR 50.82(a)(7)2020-03-0202 March 2020 Notification of Revision of Commitment for Amended Post-Shutdown Decommissioning Activities Report (PSDAR) for Three Mile Island, Unit 2 in Accordance with 10 CFR 50.82(a)(7) TMI-19-112, Application for Order Approving License Transfer and Conforming License Amendments2019-11-12012 November 2019 Application for Order Approving License Transfer and Conforming License Amendments TMI-19-097, License Amendment Request - License Condition Revision for Removal of Cyber Security Plan Requirements2019-10-31031 October 2019 License Amendment Request - License Condition Revision for Removal of Cyber Security Plan Requirements TMI-18-100, Supplement 2 to License Amendment Request - Proposed Changes to Technical Specifications Sections 1.0, Definitions, and 6.0, Administrative Controls for Permanently Defueled Condition2018-10-29029 October 2018 Supplement 2 to License Amendment Request - Proposed Changes to Technical Specifications Sections 1.0, Definitions, and 6.0, Administrative Controls for Permanently Defueled Condition TMI-18-088, Response to Request for Additional Information: TMI Fall 2017 Steam Generator Tube Inspection Report2018-08-21021 August 2018 Response to Request for Additional Information: TMI Fall 2017 Steam Generator Tube Inspection Report TMI-18-024, Biennial 10 CFR 50.59 and Pdms SAR Report2018-04-24024 April 2018 Biennial 10 CFR 50.59 and Pdms SAR Report TMI-18-044, Transmittal of Radiological Emergency Plans; EP-AA-1009, Revision 28, EP-TM-1000, Revision 0 and EP-AA-1000, Revision 292018-03-29029 March 2018 Transmittal of Radiological Emergency Plans; EP-AA-1009, Revision 28, EP-TM-1000, Revision 0 and EP-AA-1000, Revision 29 TMI-18-004, Decommissioning Funding Status Report for the Three Mile Island Nuclear Station, Unit 22018-03-16016 March 2018 Decommissioning Funding Status Report for the Three Mile Island Nuclear Station, Unit 2 TMI-18-017, Annual Report2018-02-12012 February 2018 Annual Report TMI-17-093, Transmittal of Radiological Emergency Plan Annex Procedure EP-AA-1009, Revision 252017-08-18018 August 2017 Transmittal of Radiological Emergency Plan Annex Procedure EP-AA-1009, Revision 25 TMI-17-060, Request for Approval of Certified Fuel Handler Training Program2017-07-10010 July 2017 Request for Approval of Certified Fuel Handler Training Program TMI-17-051, Supplement to Plant-Specific Path and Schedule for Resolution of Generic Letter 2004-02, Dated May 16, 20132017-05-16016 May 2017 Supplement to Plant-Specific Path and Schedule for Resolution of Generic Letter 2004-02, Dated May 16, 2013 TMI-17-035, Submittal of Changes to Technical Specifications Bases2017-04-13013 April 2017 Submittal of Changes to Technical Specifications Bases TMI-17-034, Submittal of 2016 Commitment Revision Report as Required by SECY-00-0045 (NEI 99-04)2017-03-31031 March 2017 Submittal of 2016 Commitment Revision Report as Required by SECY-00-0045 (NEI 99-04) TMI-17-006, Decommissioning Funding Status Report2017-03-24024 March 2017 Decommissioning Funding Status Report TMI-16-097, Supplemental Information Related to Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 172016-10-20020 October 2016 Supplemental Information Related to Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan, Revision 17 TMI-16-082, Notice of Transfer of Transmission Asset2016-09-15015 September 2016 Notice of Transfer of Transmission Asset TMI-16-091, Response to Draft Request for Additional Information Regarding the Submittal of Relief Request RR-16-01 Concerning the Use of ASME Code Case N-722-22016-09-0808 September 2016 Response to Draft Request for Additional Information Regarding the Submittal of Relief Request RR-16-01 Concerning the Use of ASME Code Case N-722-2 2023-05-30
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10 CFR 50.55a TMl-14-118 September 19, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289
Subject:
Submittal of Relief Request RR-14-01 Concerning Alternative Root Mean Square (RMS) Depth Sizing Requirements Attached for your review is a relief request associated with the fourth lnservice Inspection (ISi) interval for Three Mile Island Nuclear Station (TMI), Unit 1. TMI, Unit 1 is proposing alternative Root Mean Square (RMS) depth sizing requirements in accordance with 10 CFR 50.55a(g)(5)(iii). The fourth interval of the TMI, Unit 1 ISi program complies with the 2004 Edition, no Addenda, of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code. We request your approval by September 19, 2015 in support of the Fall 2015 TMI, Unit 1 refueling outage. Attachment 2 contains Relief Request RR-14-01.
One commitment is contained in Attachment 1.
If you have any questions concerning this letter, please contact Tom Loomis at (610) 765-5510.
Respectfully, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Summary of Commitments
- 2) Relief Request RR-14-01 cc: Regional Administrator, Region I, USNRC USNRC Senior Resident Inspector, TMI USNRC Project Manager, [TMI] USNRC
Attachment 1 Summary of Commitments
Attachment 1 Summary of Commitments The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)
COMMITMENT TYPE COMMITTED ONE-TIME COMMITMENT DATE OR Programmatic ACTION "OUTAGE" (Yes/No)
(Yes/No)
Inner Diameter (ID) surface Prior to plant Yes No breaking flaws greater than restart.
50% through-wall and subsurface flaws greater than 50% through-wall shall be repaired or evaluated prior to plant restart.
Evaluations shall be submitted to the NRC for review and approval prior to plant restart.
Attachment 2 Relief Request RR-14-01
10 CFR 50.55a RELIEF REQUEST RR-14-01 Revision O (Page 1 of 4}
Alternative Root Mean Square (RMS) Depth Sizing in Accordance with 10 CFR 50.55a(g)(5)(iii) 1.0 ASME CODE COMPONENT($) AFFECTED These examination categories and item numbers are from Code Case N-770-1 of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV)
Code, Section XI:
Examination Category Item No. Description Augmented (CC N-770-1) B Unmitigated Butt Weld at Cold Leg Operating Temperature
- RCT0001 RC0009BMWELD Core Flood "B" Nozzle to Safe-End Weld
- RCT0001 RC001 OBMWELD Core Flood "A" Nozzle to Safe-End Weld
- The Core Flood Nozzles are NPS 14 inch.
(Throughout this request the above examination categories are referred to as "the subject examinations" and ASME Section XI is referred to as "the Code".)
Full Penetration Weld NOZZLE SAFE-END Steel ASTM A508-64 Stainless Steel SA-336-65 Stainless Steel Weld Buildup Weld Onlay Clad Weld Buildup ER309l Alloy 82 ER309l Figure 1: Core Flood "B" Nozzle to Safe-End Weld (RCT0001 RC0009BMWELD)
10 CFR 50.55a RELIEF REQUEST RR-14-01 Revision O (Page 2 of 4)
Full Penetration Weld NOZZLE SAFE-END Weld Buildup Weld Onlay Buildup ER309l ER309L Figure 2: Core Flood "A" Nozzle to Safe-End Weld (RCT0001 RC0010BMWELD) 2.0 APPLICABLE CODE EDITION AND ADDENDA The Three Mile Island Nuclear Station (TMI), Unit 1, complies with the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, 2004 Edition, no Addenda.
3.0 APPLICABLE CODE REQUIREMENT As required by 10 CFR 50.55a(b)(2)(xv), ASME Section XI, 2001 Edition, Appendix VIII is utilized.
As required by 10 CFR 50.55a(g)(6)(ii)(F), ASME Code Case N-770-1, "Alternative Examination Requirements and Acceptance Standards for Class 1 PWR Piping and Vessel Nozzle Butt Welds Fabricated With UNS N06082 or UNS W86182 Weld Filler Material With or Without Application of Listed Mitigation Activities,Section XI, Division 1,"
is utilized as amended by 10CFR50.55a(g)(6)(ii)(F).
Code Case N-770-1, Table 1, Footnote (4) applies to volumetric examination of Inspection Items Band H, and requires that "Ultrasonic volumetric examination shall be used and shall meet the applicable requirements of Appendix VIII." ASME Section XI 2001 Edition, Appendix VIII, Supplement 10, Paragraph 3.2(b) requires that examination procedures, equipment, and personnel be qualified for depth sizing with a Root Mean Square (RMS) error less than or equal to 0.125 inches. Code Case N-695 provides alternatives to the qualification requirements of Appendix VIII, Supplement 10; however, Section 3.3(c) requires that examination procedures, equipment, and personnel are qualified for depth-sizing with an RMS error less than or equal to 0.125 inches.
The fourth ten-year ISi program plan for TMI includesSection XI Code Case N-695, "Qualification Requirements for Dissimilar Metal Piping Welds,Section XI, Division 1."
This Code Case is listed in Regulatory Guide 1.147, Revision 16, Table 1, "Acceptable Section XI Code Cases."
10 CFR 50.55a RELIEF REQUEST RR-14-01 Revision O (Page 3 of 4) 4.0 REASON FOR REQUEST This request is being submitted by TMI due to an impracticality of compliance in accordance with 10 CFR 50.55a(g)(5)(iii). TMI will be performing volumetric examinations of the Core Flood Nozzle to Safe-End Dissimilar Metal Welds from the inner diameter during the upcoming T1 R21 refueling outage (October 2015) and will implement the requirements of ASME Section XI, Code Case N-695. Code Case N-695, Section 3.3(c), requires that qualified procedures, equipment, and personnel shall demonstrate a flaw depth-sizing error less than or equal to 0.125 inch RMS. The nuclear power industry has attempted to qualify personnel, equipment, and procedures for depth-sizing examinations performed from the inside surface of dissimilar metal welds since November 2002. To date, no known inspection vendor has met the RMS error requirements.
The inability of examination procedures to achieve the required RMS error value is primarily due to a combination of factors such as surface condition (i.e., roughness), scan access, base materials, and the dendritic structure in the welds themselves. The combination of these factors has proven too difficult for vendors to achieve an RMS error value that meets the established requirements. The examination vendor TMI intends to utilize has demonstrated an RMS error of 0.224 inches.
5.0 PROPOSED ALTERNATIVE AND BASIS FOR USE Exelon Generation Company, LLC (Exelon) proposes to utilize an alternate depth-sizing RMS error value greater than the 0.125 inch RMS error value stated in ASME code case N-695 for the examination of the welds listed above. Exelon proposes to utilize an alternate RMS of 0.224 inch as demonstrated by AREVA for depth sizing. In the event of indications requiring depth-sizing, Exelon proposes to utilize the following approach:
- 1. The difference between the required RMS error (0.125 inch) and the demonstrated RMS error (0.224 inch) of 0.099 inch shall be added to the through-wall measurement for comparison with the applicable acceptance criteria.
- 2. Eddy Current examination techniques will be available to perform surface examinations as required to verify a flaw is not surface breaking.
- 3. Inner Diameter (ID) surface breaking flaws greater than 50% through-wall and subsurface flaws greater than 50% through-wall shall be repaired or evaluated prior to plant restart. Evaluations shall be submitted to the NRC for review and approval prior to plant restart.
- 4. If an improved depth-sizing RMS is demonstrated prior to examination performance, the excess of this new RMS error over the required RMS will be added to the measured value for comparison to the acceptance criteria.
- 5. For subsurface planar flaws, the difference between the RMS error and the demonstrated RMS error (0.099 inch) shall be added to both ends of the indication:
- a. 0.099 inches will be added to the lower tip towards the ID surface
- b. 0.099 inches will be added to the upper tip towards the OD surface All other requirements of the ASME Section XI Code and Code Cases N-695 and N-770-1 shall apply.
Based on the conclusions from EPRI Materials Reliability Program Letter MRP 2012-046, the proposed alternative will provide reasonable assurance that flaws detected during examination will be sized sufficiently for comparison with the acceptance criteria of Code Case N-770-1.
10 CFR 50.55a RELIEF REQUEST RR-14-01 Revision 0 (Page 4 of 4) 6.0 DURATION OF THE PROPOSED ALTERNATIVE The proposed relief request is applicable for the TMI, Unit 1 fourth ISi interval which ends April 19, 2022.
Prior to performance of examinations, TMI will review changes in the industry guidance with respect to dissimilar metal welds in addition to ASME Code Cases for applicability. If an approved Code Case allows a different method of depth sizing, then TMI shall utilize this in place of the proposed Relief Request.
7 .0 PRECEDENTS Similar relief requests were approved for: McGuire Nuclear Station, Unit 2; Comanche Peak Nuclear Power Plant, Unit 2; and Braidwood Station, Units 1 and 2 (References 6 thru 8 below).
8.0 REFERENCES
- 1. ASME Code,Section XI, "Rules for lnservice Inspection of Nuclear Power Plant Components," 2004 Edition, no Addenda.
- 2. ASME Code,Section XI, 2001 Edition, no Addenda, Appendix VIII, Supplement 10, "Qualification Requirements for Dissimilar Metal Piping Welds."
- 3. ASME Code Case N-695, "Qualification Requirements for Dissimilar Metal Piping WeldsSection XI, Division 1," dated May 21, 2003.
- 4. EPRI Policy/Procedure Directive 03-01, "Criteria for Issuing Documentation of Depth Sizing Errors That Exceed the 0.125-inch RMS Appendix VIII Criteria."
- 5. EPRI Materials Reliability Program Letter MAP 2012-046, "Flaw Depth Sizing Uncertainty Root Mean Square (RMS) Error Treatment for Ultrasonic Piping Examinations from the Inside Surface," dated November 26, 2012.
- 6. NRC Safety Evaluation Report for McGuire Nuclear Station, Unit 2, Relief Request 12-MN-003, dated September 24, 2012(ML12258A363).
- 7. NRC Safety Evaluation Report for Comanche Peak Nuclear Power Plant, Unit 2, Relief Request No. B-14, dated April 1, 2014(ML14073A544).
- 8. NRC Safety Evaluation Report for Braidwood Station, Units 1 and 2, Relief Request 13R-08, dated April 19, 2012 (ML12108A123).