ML082190781

Request for Additional Information, License Renewal Application, Section 2.1.5.2

ML082190781
Person / Time
Site:	Three Mile Island
Issue date:	08/22/2008
From:	Robinson J E NRC/NRR/ADRO/DLR
To:	Gallagher M P AmerGen Energy Co
Robinson, J NRR/DLR/RPB1 415-2878
References
TAC MD7701
Download: ML082190781 (8)

Text

August 22, 2008

Mr. Michael P. Gallagher Vice President License Renewal Projects AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR SECTION 2.1.5.2 OF THE THREE MILE ISLAND NUCLEAR STATION, UNIT 1, LICENSE RENEWAL APPLICATION (TAC NO. MD7701)

Dear Mr. Gallagher:

By letter dated January 8, 2008, AmerGen Energy Company, LLC (AmerGen) submitted an application pursuant to 10 CFR Part 54 to renew the operating license for Three Mile Island Nuclear Station, Unit 1 for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review. Further requests for additional information may be issued in the future.

Items in the enclosure were discussed with Chris Wilson, of your staff, and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me at 301-415-2878 or e-mail Jay.Robinson@nrc.gov. Sincerely, /RA/ Jay Robinson, Sr. Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation

Docket No. 50-289

Enclosure:

As stated

cc w/encl: See next page

ML082190781 OFFICE LA:DLR OGC DLR:RER2 PM:DLR:RPB1 BC:DLR:RPB1 NAME SFigueroa BMinuzo RAuluck JRobinson DPelton DATE 08/14/08 07/17/08 08/20/08 08/22/08 08/22/08 Letter to AmerGen Energy Company, LLC from J. Robinson dated August 22, 2008 DISTRIBUTION

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR SECTION 2.1.5.2 OF THE THREE MILE ISLAND NUCLEAR STATION, UNIT 1, LICENSE RENEWAL APPLICATION (TAC NO. MD7701)

HARD COPY: DLR RF E-MAIL: PUBLIC RidsNrrDlrRpb1 RidsNrrDlrRpb2 RdsNrrDlrRer1 RidsNrrDlrRer2 -------------

SLopas BRogers Three Mile Island Nuclear Station, Unit 1 cc: Site Vice President - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P. O. Box 480 Middletown, PA 17057

Senior Vice President - Operations, Mid-Atlantic AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Vice President - Licensing and Regulatory Affairs AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

Regional Administrator Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406

Chairman Board of County Commissioners of Dauphin County Dauphin County Courthouse Harrisburg, PA 17120 Chairman Board of Supervisors of Londonderry Township R.D. #1, Geyers Church Road Middletown, PA 17057 Senior Resident Inspector (TMI-1) U.S. Nuclear Regulatory Commission P.O. Box 219 Middletown, PA 17057

Director - Licensing and Regulatory Affairs AmerGen Energy Company, LLC Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Director Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Plant Manager - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P.O. Box 480 Middletown, PA 17057

Regulatory Assurance Manager - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P.O. Box 480 Middletown, PA 17057 Ronald Bellamy, Region I U.S. Nuclear Regulatory Commission

475 Allendale Road King of Prussia, PA 19406 Ronnie Gardner, PMP Manager, Site Operations and Corporate Regulatory Affairs AREVA NP Inc. 3315 Old Forest Road OF-16 Lynchburg, VA 24501

Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Eric Epstein TMI Alert 4100 Hillsdale Road Harrisburg, PA 17112 Three Mile Island Nuclear Station, Unit 1 cc: Correspondence Control Desk AmerGen Energy Company, LLC 200 Exelon Way, KSA 1-N-1 Kennett Square, PA 19348 Manager Licensing - Three Mile Island Nuclear Station, Unit 1 Exelon Generation Company, LLC Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Christopher M. Crane President and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

Mr. Charles G. Pardee Chief Nuclear Officer AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348

Associate General Counsel AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

Chief Operating Officer (COO) AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

Senior Vice President - Operations Support AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

Frederick W. Polaski Manager License Renewal Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348 Albert A. Fulvio, Senior Project Manager License Renewal Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348 Rich Janati, Chief Division of Nuclear Safety Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469

Michael Murphy Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Michael G. Brownell, Chief Water Resources Management Susquehanna River Basin Commission 1721 N. Front Street Harrisburg, PA 17102 Rachel Diamond, Regional Director Southcentral Regional Office Pennsylvania Department of Environmental Protection 909 Elmerton Avenue Harrisburg, PA 17110 Nancy Ranek Environmental Lead, License Renewal Exelon Nuclear 200 Exelon Way, KSA/2-E Kennett Square, PA 19348

Three Mile Island Nuclear Station, Unit 1 cc: Christopher Wilson KSQ License Renewal Exelon Nuclear 200 Exelon Way, KSA/2-E Kennett Square, PA 19348

Mr. Michael P. Gallagher Vice President License Renewal Projects AmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348 ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION (RAI)

SECTION 2.1.5.2 THREE MILE ISLAND NUCLEAR STATION, UNIT - 1 LICENSE RENEWAL APPLICATION LRA Section 2 - Scoping and Screening Methodology and Results 10 CFR 54.4(a)(2) requires that all nonsafety-related systems, structures, and components whose failure could prevent satisfactory accomplishment of any safety-related systems, structures, and components (SSCs) are included within the scope of license renewal.

RAI#: 2.1.5.2-1

License Renewal Application (LRA) Section 2.1.5.2 states on page 2.1-19, Afor a nonsafety-related piping system connected to a safety-related piping system, the nonsafety-related system was assumed to provide structural support to the safety-related system, unless otherwise confirmed by a review of the installation details. The entire nonsafety-related system was included in scope for 10 CFR 54.4(a)(2), up to one of the following:" and then lists the bounding criteria contained in NEI 95-10 "Industry Guideline on Implementing the Requirements of 10 CFR Part 54, The License Renewal Rule", (seismic anchor, base-mounted component, flexible connection, free end of non-safety related piping, buried end of piping, and nonsafety-related piping runs connected to safety-related piping on both ends). In addition, LRA Section 2.1.5.2 also states on page 2.1-19, "these scoping boundaries are determined from the physical installation details, and confirmed in cases by review of design drawings or visual inspection by plant walk-downs where necessary."

During the scoping and screening methodology audit, the staff reviewed the scoping results for the abandoned hydrogen purge system and was not able to determine that the applicant had applied the methods described in LRA Section 2.1.5.2 to determine the portion of the nonsafety-related piping, attached to safety-related SSCs, to be included within the scope of license renewal. The staff requests that the applicant describe the methods used and the basis for conclusions, in determining the portion of nonsafety-related abandoned system piping, attached to safety-related SSCs, to be included within the scope of license renewal.

RAI#: 2.1.5.2-2

During the scoping and screening methodology audit, the applicant stated that for certain systems, the portion of nonsafety-related piping, attached to safety-related SSCs, to be included within the scope of license renewal, had not been completely determined. The staff reviewed the scoping results for the make-up and purification system and determined that the scoping endpoints for attached piping had not been clearly defined in three instances due to a portion of the nonsafety-related piping being inaccessible to personnel while the plant was at power. The staff requests that the applicant describe the methods used and the basis for conclusions, in determining the portion of nonsafety-related inaccessible piping, attached to safety-related SSCs, to be included within the scope of license renewal. RAI#: 2.1.5.2-3 LRA Section 2.1.5.2 states on page 2.1-20, "the preventive option as implemented at TMI-1 is based on a "spaces" approach for scoping of nonsafety-related systems with potential spatial interaction with safety-related SSCs. Potential spatial interaction is assumed in any structure that contains active or passive safety-related SSCs. - For structures that contain safety-related SSCs, there may be selected rooms within the structure that do not contain any safety-related SSCs. Current Licensing Basis (CLB) document reviews and plant walk-downs were utilized as appropriate to confirm that these rooms did not contain safety-related SSCs, thereby eliminating spatial interaction concerns within these rooms."

During the scoping and screening methodology audit, the staff performed a walk-down of the turbine building. The staff determined that a portion of the turbine building contained fluid-filled, nonsafety-related systems which were not included within the scope of license renewal (referred to by the applicant as an Aexcluded area

@). However, since the turbine building is generally an open space, the excluded area was located in the same room as safety-related containment isolation valves (CA-V-5A and CA-V-5B). The staff determined that the nonsafety-related, fluid-filled SSCs were not separated from safety-related SSCs by a room as described in LRA Section 2.1.5.2 (see above). The staff requests that the applicant describe the methods used and the basis for conclusions, in determining to not include nonsafety-related, fluid-filled SSCs within the scope of license renewal when located in the same room as safety-related SSCs.

As part of your response for RAIs 2.1.5.2-1 through 2.1.5.2-3, please address the extent of condition and additional scoping reviews performed for nonsafety-related abandoned SSCs, nonsafety-related inaccessible SSCs, and nonsafety-related SSCs located within the same room as safety-related SSCs, with the potential to affect safety-related SSCs. List any additional SSCs included within the scope of license renewal as a result of the review, and list those structures and components for which aging management reviews were conducted. For each structure and component, describe the aging management programs, as applicable, to be credited for managing the identified aging effects.