ML083170038

License Renewal Application, Request for Additional Information, Sections 2.3 & 2.4

ML083170038
Person / Time
Site:	Three Mile Island
Issue date:	11/24/2008
From:	Jay Robinson License Renewal Projects Branch 1
To:	Gallagher M AmerGen Energy Co
Robinson, J NRR/DLR/RPB1 415-2878
References
TAC MD7701
Download: ML083170038 (9)

Text

November 24, 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 SECTIONS 2.3 & 2.4 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 Title 10 of the Code of Federal Regulation Part 54 (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 by e-mail at 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

ML083170038 OFFICE LA:DLR DSS:SBPB PM:DLR:RPB1 BC:DLR:RPB1 NAME IKing MRahimi JRobinson DPelton DATE 11/14/08 11/18/08 11/20/08 11/24/08 Letter to M. Gallagher from J. Robinson dated November 24, 2008 DISTRIBUTION

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR SECTIONS 2.3 & 2.4 OF THE THREE MILE ISLAND NUCLEAR STATION, UNIT 1, LICENSE RENEWAL APPLICATION (TAC NO. MD7701)

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SGardocki 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 Michael A. Schoppman

Framatome ANP

Suite 705

1911 North Ft. Myer Drive

Rosslyn, VA 22209 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 Correspondence Control Desk AmerGen Energy Company, LLC 200 Exelon Way, KSA 1-N-1

Kennett Square, PA 19348 Three Mile Island Nuclear Station, Unit 1 cc:

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

Frederick W. Polaski Manager License Renewal

Exelon Nuclear

200 Exelon Way

Kennett Square, PA 19348 Albert A. Fulvio License Renewal Senior Project Manager

Exelon Nuclear

200 Exelon Way

Kennett Square, PA 19348 REQUEST FOR ADDITIONAL INFORMATION SECTIONS 2.3 & 2.4 THREE MILE ISLAND NUCLEAR STATION, UNIT 1 LICENSE RENEWAL APPLICATION License Renewal Application (LRA) Section 2.3.3.17 - Liquid and Gas Sampling System

RAI 2.3.3.17-4

Background:

On the following license renewal drawings the applicant shows the same components highlighted in different colors, reflecting the components being included in scope for license renewal for different reasons:

(a) On license renewal drawing LR-302-181 at locations H-2 through H-5, components CE10 through CE16 and their associated piping are shown highlighted in red; indicating that they are within the scope of license renewal for 10 CFR 54.4(a)(2) criteria. However, on license renewal drawing LR-302-111 at locations G-6, G-7, C-7, and E-5, and on LR-302-011 at locations E-9 and E-10, these same components and their associated piping are shown highlighted in green; indicating that they are within the scope of license renewal for 10 CFR 54.4(a)(1) or (a)(3)

criteria.

(b) On license renewal drawing LR-302-182 at locations H-8 through H-10, components CE17, CE18, CE25 through CE27 and their associated piping are shown highlighted in red; indicating that they are within the scope of license renewal for 10 CFR 54.4(a)(1) or (a)(3) criteria.

However, these same components and their associated piping, CE17 and CE18 (license renewal drawing LR-302-111 at location C-3), CE25 (license renewal drawing LR-302-101 at location E-3) and CE26 and CE 27 (license renewal drawing LR-302-101 at location D-2), are shown highlighted in green; indicating that they are within the scope of license renewal for 10 CFR 54.4(a)(2) criteria.

(c) On license renewal drawing LR-302-671 at location E-5, components CE118, CE119 and their associated piping, are shown in black; indicating that they are not within the scope of license renewal. However, on license renewal drawing LR-302-640 at locations F-3 and F-8, these same components and their associated piping are shown highlighted in red; indicating that they are within the scope of license renewal for 10 CFR 54.4(a)(2) criteria.

(d) On license renewal drawing LR-302-671 at locations D-7 through F-8, components CE100 through CE106 and their associated piping are shown highlighted in red; indicating that they are within the scope of license renewal for 10 CFR 54.4(a)(2) criteria. However, these same components and their associated piping, CE100 through CE104 (license renewal drawing LR-302-719 at location F-7 through G-8), CE104 (license renewal drawing LR-302-660 at location G-2), and CE105 and CE 106 (license renewal drawing LR-302-650 at location F-7), are shown highlighted in green; indicating that they are within the scope of license renewal for 10 CFR 54.4(a)(1) or (a)(3) criteria.

Issue:

Proper identification of components included within the scope of license renewal is necessary to properly identify the intended function and whether additional attached or surrounding equipment needs to be included within scope of license renewal to support or protect the ability of a safety-related component to perform its safety function.

Request:

For components and their associated piping described above, the staff request the applicant to clarify which criteria the components are scoped under 10 CFR 54.4(a) and determine whether additional components are necessary to be brought within the scope of license renewal as a result.

RAI 2.3.3.17-5

Background:

On license renewal drawing LR-302-671 at location E-4, the piping leading to and the valves CA-V99B, CA-V99A, CA-V95 and CA-V109 are shown in black; indicating that they are not within the scope of license renewal. This piping connects directly to various 3/8" piping shown highlighted in red; indicating that this other various piping segments are within the scope of license renewal for 10 CFR 54.4(a)(2) criteria.

Issue: The abovementioned piping and valves are directly attached to piping that is included in scope for license renewal under 10 CFR 54.4 (a)(2). Since there is no apparent physical barrier, then the abovementioned piping and valves should also be included in scope.

Request:

Justify the exclusion of the abovementioned piping and valves from the scope of license renewal and subject to an aging management review (AMR) with the intended function of leakage boundary.

RAI 2.3.3.17-6

Background:

On license renewal drawing LR-302-671 the applicant shows many valves in black; indicating that they are not within the scope of license renewal. However, immediately before these valves, the piping is shown highlighted in red; indicating that the piping is within the scope of license renewal for 10 CFR 54.4(a)(2) criteria. The following is an itemized list of these valves and their location on the drawing:

(a) At location B-6, valves CA-V32A and CA-V32B (b) At location F-2, valve CA-V337

(c) At location E-2, valves CA-V47 and CA-V48 (d) At location E-2 through E-4, valves CA-V53, CA-V59, CA-V61, CA-V64A, CA-V67A, CA-V64B, CA-67B, CA-V70, CA-V73, CA-V78, CA-V75, CA-V82A, CA-V82B, CA-V80, CA-V85A, and CA-V85B

Issue:

The piping immediately before these valves is within the scope of license renewal for 10 CFR 54.4(a)(2) criteria with an intended function of leakage boundary. There needs to be a method of isolating the piping components that are within the scope of license renewal for leakage boundary from the piping components that are not within scope. This isolation can be achieved by a valve which can be closed and is within scope or by a physical barrier.

Request: Justify the exclusion of these abovementioned valves from the scope of license renewal and subject to aging management for an intended function of leakage boundary.

LRA Section 2.3.3.19 - Open Cycle Cooling Water System RAI 2.3.3.19-3

Background:

On river water system license renewal drawing LR-302-202, at location D-8, a six-inch pipe is highlighted in red, indicating that the piping is within the scope of license renewal. This piping is shown to continue onto license renewal drawing 302-161 to a "Clarifier." The continuation arrow is not highlighted, indicating the downstream components were not included in the scope of license renewal. License renewal drawing 302-161 has not been provided as a license renewal drawing.

Issue:

Structures and components shown on license renewal drawing 302-161 as part of this continued piping may be required to be included in scope for license renewal. The staff's needs to review the structures and components on this drawing to verify the applicant has properly included the components in scope and subject to an AMR as required by 10 CFR 54.21.

Request: The staff requests the applicant to provide the continuation license renewal drawing 302-161 identifying the structures and components within the scope of license renewal and subject to an AMR, or provide a basis for the exclusion of the structures and components on this

drawing.

LRA Section 2.3.4.3 - Emergency Feedwater System RAI 2.3.4.3-1

Background:

On license renewal drawing LR-302-082 the safety-related emergency feedwater control valves to the steam generators, EF-V30A, EF-V30B, EF-V30C, and EF-V30D, at locations F-4, B-4, B-5, and G-5, respectively, are shown within the scope of license renewal. However, the air operators for these valves are not highlighted, indicating the operator is not within the scope of license renewal. In LRA Section 2.3.4.3 the applicant states that these valves will initially fail closed with loss of air supply to reduce the potential for severe overcooling transients, but there is adequate time available to the operator to take action to open a flow control valve and restore flow, should the flow control valves fail closed. There are multiple sources of air available to ensure their proper positioning during a design basis event in accordance with 10 CFR 54.4(a)(1). License renewal drawing LR-302-273 for the instrument air system shows the instrument air supply up to these emergency feedwater control valves highlighted in green, indicating they are within the scope of license renewal in accordance with 10 CFR 54.4(a)(1) and/or (a)(3).

Issue:

The emergency feedwater control valves' air operators perform a function to change position to regulate flow during a design-basis event, which would require them to be included within the scope of license renewal under 10 CFR 54.4(a). Even though the operator is an active component, the valve body is passive and requires an AMR in accordance with 10 CFR 54.21.

Request:

Justify the exclusion of the emergency feedwater control valves' air operators from the scope of license renewal and an AMR.

LRA Section 2.3.4.8 - Steam Turbine and Auxiliaries RAI 2.3.4.8-2

Background:

In LRA Section 2.3.4.2, Condensers and Air Removal System, the applicant states that the condenser shell has the intended function of pressure boundary in accordance with 10 CFR 54.4(a)(2) for iodine partitioning. Typically on the turbine pedestal, there are drain lines originating in each of the wells where the turbine shaft penetrates the low pressure turbine housings for the purpose of draining condensate from excessive gland sealing steam.

These drain lines penetrate the condenser housing where they originate and where they exit. Neither LRA Section 2.3.4.2 nor Section 2.3.4.8, discuss this drain piping usually referred to as "slop drains." The failure of this piping is routinely seen in the industry and noted as a source of air inleakage to the condenser affecting vacuum.

Issue:

This drain piping would be a part of the pressure boundary for the condenser and included within the scope of license renewal in accordance with 10 CFR 54.4(a)(2) as a functional (a)(2) because its failure would affect the condenser shell's pressure boundary intended

function.

Request:

Clarify whether the turbine pedestal "slop drains" lines are present at Three Mile Island and justify their exclusion from the scope of license renewal under 10 CFR 54.4(a)(2).

LRA Section 2.4.6 - Dike/Flood Control System RAI 2.4.6-2

Background:

On license renewal drawing LR-1E-120-01-001, the Storm Drainage and Flood Control Structure is shown outlined in black, indicating that the structure is not within the scope of license renewal. In LRA Section 2.4.6, "Dike/Flood Control System," the applicant states that the Dike/Flood Control System is in scope under 10 CFR 54.4(a)(2).

Issue: The Storm Drainage and Flood Control Structure was identified as being in scope of license renewal and should be highlighted as such on the license renewal drawing.

Request: Justify the exclusion of the Storm Drainage and Flood Control Structure from the scope of license renewal on the license renewal drawing.