ML083510040

Unit - 1, License Renewal Application, Request for Additional Information

ML083510040
Person / Time
Site:	Three Mile Island
Issue date:	01/05/2009
From:	Robinson J E License Renewal Projects Branch 1
To:	Gallagher M P AmerGen Energy Co
Robinson, J NRR/DLR/RPB1 415-2878
References
TAC MD7701
Download: ML083510040 (3)

Text

January 5, 2009

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 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 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).

By letter dated October 16, 2008 (ADAMS Accession No. ML082520614) the staff requested additional information. By letter dated November 12, 2008 (ADAMS Accession No.

ML083190038) you replied to the request.

Based on the review of your response, the staff 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

ML082520614) the staff requested additional information. By letter dated November 12, 2008 (ADAMS Accession No.

ML083190038) you replied to the request.

Based on the review of your response, the staff 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 DISTRIBUTION: See next page ADAMS Accession No.: ML083510040 OFFICE LA:DLR DLR:RER1 PM:DLR:RPB1 BC:DLR:RPB1 NAME SFigueroa JDozier JRobinson DPelton DATE 12/31/08 1/5/09 1/5/09 1/5/09 Letter to M. Gallagher from J. Robinson dated January 5, 2009

DISTRIBUTION

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THREE MILE ISLAND NUCLEAR STATION, UNIT 1, LICENSE RENEWAL APPLICATION (TAC NO.

MD7701) HARD COPY: DLR RF E-MAIL: PUBLIC RidsNrrDlr RidsNrrDlrRpb1 RidsNrrDlrRpb2

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MModes, RI

DKern JBrand RConte RBellamy PBamford 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 (RAI)

THREE MILE ISLAND NUCLEAR STATION, UNIT - 1 LICENSE RENEWAL APPLICATION RAI#: AMR-GENERIC-2 LRA Section: 3.X.1 Tables, Associated Evaluation Paragraphs

Background

In the Three Mile Island, Unit - 1, (TMI-1), License Renewal Application, section 3.X.1 tables, "Not Applicable" is listed in the discussion column for many line items (ie; lines 3.1.1-23 and 3.2.1-17). For many of the line items, a subsection of the LRA is referenced (ie; "See Subsection 3.1.2.2.7," and "See Subsection 3.2.2.2.9"). In many cases, the referenced subsection does not provide a specific reason why the item is not applicable. (ie: "Item Number 3.2.1-17 is not applicable to TMI-1. This component, material, environment, and aging effect/mechanism does not apply to Engineered Safety Features").

In AmerGen Energy Company, LLCs (the applicant) response to RAI-AMR-GENERIC-1 (ADAMS Accession No. ML083190038), the applicant indicated that "Not Applicable" has been used when the component, material and environment combination does not exist in the identified GALL system grouping and also when the component, material and environment combination does exist but the LRA Table 3.x.1 item was not used because a different Table 3.x.1 item was selected to manage the identified aging effect/mechanism.

Issue:

Based on the response to RAI-AMR-GENERIC-1, the staff cannot determine the specific reason why certain items are not applicable and therefore, cannot complete its evaluation. The two reasons cited in the response to RAI-AMR-GENERIC-1 are general reasons and not specific to each item.

Request:

For each of the LRA Table 3.x.1 items where "Not Applicable" is listed in the "Discussion" column, indicate the specific reason why the item is considered not applicable to TMI-1. For example, one reason may be that the component, material, environment combination does not exist at TMI-1. Items that are listed as "Not Applicable" due to reactor type (BWR vs. PWR) do not have to be listed.

If the component, material and environment does exist but the LRA Table 3.x.1 item was not used, indicate what other 3.x.1 item was selected to manage the identified aging effect/

mechanism.

RAI#: AMR-GENERIC-3

Background:

In AmerGens responses to RAIs 3.3.1.21-1, 3.3.1.32-1, 3.3.1-48-1, 3.3.2.2-1, and 3.3.2.2-3 (ADAMS Accession No. ML083190038), Electric Power Research Institute (EPRI) Report 1010639, "Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools", Revision 4, is used to justify elimination of aging mechanisms from evaluation. Issue: Only citing EPRI Report 1010639 as the basis to justify elimination of aging mechanisms from evaluation does not provide sufficient information to enable the staff to complete its evaluation.

Request: Provide the following:

For RAIs 3.3.1.21-1 and 3.3.2.2-3, state the reasons why the loss of material due to fouling is not predicted in steel components in a lubricating oil environment.

For RAIs 3.3.1.32-1 and 3.3.2.2-1, state the reasons why pitting and crevice corrosion is not predicted for copper alloy with less than 15% zinc in a fuel oil environment.

For RAI 3.3.1-48-1, state the reasons why galvanic corrosion is not predicted for component, material, and environment combinations when the material subject to aging management review (AMR) is not in contact with a material of different electrochemical potential.

RAI# 3.1.1-2

Background:

In AmerGens response to RAI# 3.1.1-1 (ADAMS Accession No. ML083190038) it is stated that the ISI program includes examination of small bore piping welds and that under the RISI program, socket welds have been selected for VT-2 examination. The response further states that the RISI program includes small bore piping welds.

Issue: Welds selected for inspection are based on RISI, however, it is not clear if welds specific to the reactor coolant system (RCS) and Core Flooding System will be subject to inspection.

Request: Provide information indicating which small bore piping welds of the RCS and Core Flooding System receive volumetric or VT-2 inspection. Identify inspections and the schedule for welds in small bore piping where cracking has been discovered.

RAI#: 3.1.2.2.7-2 LRA Section: 3.1.2.2.7, Cracking due to Stress Corrosion Cracking, and AmerGen Response to RAI# 3.1.2.2.7-1

Background:

In AmerGens response to RAI 3.1.2.2.7-1 (ADAMS Accession No. ML083190038) it was stated that the stainless steel reactor vessel closure head flange leak detection line and the stainless steel bottom-mounted instrument guide tubes exist and are in scope for license renewal. The response also stated that the components are stainless steel with an external environment of Air in Borated Water Leakage and an internal environment of Reactor Coolant. The response also stated that the aging management review (AMR) results for these components are included in LRA Table 3.1.2-2 and are shown on pages 3.1-74 and 3.1-75 of the LRA. Issue: The Standard Review Plan for Review of License Renewal Applications for Nuclear Power Plants, NUREG-1800, Rev. 1, (SRP-LR), Section 3.1.2.2.7, paragraph 1, states that cracking due to stress corrosion cracking (SCC) could occur in the stainless steel reactor vessel flange leak detection line and the bottom-mounted instrument guide tubes exposed to reactor coolant.

The GALL Report recommends further evaluation of a plant specific aging management program (AMP) to ensure that the aging effects are adequately managed.

The AMPs credited in the LRA to manage the aging effect of cracking due to SCC in the stainless steel reactor vessel flange leak detection line and the bottom-mounted instrument guide tubes are Water Chemistry and the ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD.

Request: Explain how the aging effect of cracking due to SCC in the stainless steel reactor vessel closure head flange leak detection line and the stainless steel bottom-mounted instrument guide tubes will be detected by the ASME Section XI Inservice Inspection, Subsections IWB, IWC and IWD and what corrective actions would be taken if indications of cracking or leakage are found in these components.

RAI# B.2.1.20-2

Background:

The staff reviewed API Standard 1631 and noted that Section 10.6.2 provides a requirement to install cathodic protection if UT examination determines the wall thickness to be between 75% and 85% of the original wall thickness.

Issue: The staff noted that wall thicknesses between 75% and 85% of the original wall thickness indicates active loss of material and measures should be implemented to mitigate corrosion.

Request: Confirm that cathodic protection will be implemented if wall thicknesses between 75% and 85%

of the original wall thickness are detected, or indicate what measures will be taken to mitigate corrosion if cathodic protection will not be implemented.