ML081010205

Corrections to the License Renewal Application

ML081010205
Person / Time
Site:	Crane
Issue date:	04/08/2008
From:	Gallagher M AmerGen Energy Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
5928-08-20079
Download: ML081010205 (13)

Text

AmerGen Michael P. Gallagher, PE Telephone 610.765.5958 An Exelon Company Vice President www.exeloncorp.com License Renewal Projects michaelp.gallagher@exeloncorp.com AmerGen 10 CFR 51 2oo Exelon Way 10 CFR 54 KSA/2-E Kennett Square, PA 19348 5928-08-20079 April 8, 2008 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:

Corrections to the Three Mile Island Nuclear Station Unit 1 License Renewal Application

Reference:

Three Mile Island Nuclear Station Unit 1 License Renewal Application, Submitted 1/8/2008 AmerGen Energy Company, LLC (AmerGen) has identified corrections to the Three Mile Island Nuclear Station Unit 1 (TMI-1) License Renewal Application, submitted 1/8/2008. As a supplement to the TMI-1 License Renewal Application, AmerGen is providing one enclosure that tabulates these corrections. For ease of review, deleted text is shown with a strikethrough, inserted text is shown in italics and inserted text within a table is shown in bolded italics.

These corrections have been discussed with the NRC License Renewal Project Manager for the TMI-1 License Renewal Application.

There are no commitments contained in this letter.

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

I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, Executed on 1-048 - L006 Michael Gallagher-

April 8, 2008 Page 2 of 2 Vice President, License Renewal AmerGen Energy Company, LLC Enclosure A: Tabulation of Corrections to the Three Mile Island Nuclear Station Unit 1 License Renewal Application.

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/ Enclosure.

USNRC Project Manager, NRR - TMI Unit 1, w/ Enclosure.

USNRC Senior Resident Inspector, TMI Unit 1, w/ Enclosure.

D. Allard, Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection, w/ Enclosure.

Chairman, Board of County Commissioners of Dauphin County, PA, w/ Enclosure.

Chairman, Board of Supervisors of Londonderry Township, Dauphin County, PA, w/

Enclosure.

File No. 08001

April 8, 2008 Page 1 of 11 5928-08-20079 Enclosure A Corrections in the Main Body of the TMI Unit I LRA Closed Cycle Cooling Water System Affected Section: 2.3.3.4 LRA Page No: 2.3-75 Paragraph: 6 th Paragraph, last sentence Change: Recent reassessment for the Industrial Cooler chemical feed tanks for (a)(2) spatial interaction identified that these tanks do not have the potential for spatial interaction with safety-related components, but were conservatively considered in scope during the original scoping process. Since these tanks have no intended functions for License Renewal, they will be removed from License Renewal scope. The following sentence will be added to the end of paragraph 6, which discusses the Industrial Coolers: "Similarly,the Industrial Cooler chemical feed tanks are not in scope because they have no potential for spatialinteraction with safety-related equipment."

The Industrial Cooler chemical feed tanks (AH-T-2A, AH-T-2B) are shown on License Renewal drawing LR-302-845 at coordinates C-3 and E-3. On this drawing, the tanks are colored red representing their original (a)(2) intended function of spatial interaction.

This drawing will be revised to show the tanks black, indicating no intended functions and not in scope for License Renewal.

Affected Section: 2.3.3.4 LRA Page No: 2.3-80 Paragraph: Table 2.3.3-4 Change: Delete "Industrial Cooler" from the "Component Type" column for the table row addressing the chemical mix tanks, as follows:

Component Type Intended Functions Tanks (Chemical Mix - Nuclear Service, Leakage Boundary Intermediate Cooling, Decay Closed, Industrial Cooler)

April 8, 2008 Page 2 of 11 5928-08-20079 Enclosure A Corrections in the Main Body of the TMI Unit I LRA Affected Section: 3.3.2 LRA Page No: 3.3-156, 3.3-157 Paragraph: Table 3.3.2-4 Change: Delete "Industrial Cooler" from the "Component Type" column for each of the three table rows addressing the chemical mix tanks, as follows:

Component Intended Material Environment Aging Effect Aging NUREG -1801 Table 1 Notes Type Function Requiring Management Vol. 2 Item Item Management Programs Tanks (Chemical Leakage Carbon Air with Borated Loss of Boric Acid VI1.1-10 3.3.1-89 A Mix - Nuclear Boundary Steel Water Leakage Material/ Boric Corrosion Service, (External) Acid Corrosion (B.2.1.4)

Intermediate Cooling, Decay Closed7 lRdustFa GeoeF Tanks (Chemical Leakage Carbon Air with Borated Loss of External Surfaces VII.I-4 3.3.1-43 E, 1 Mix - Nuclear Boundary Steel Water Leakage Material/ Monitoring Service, (External) General, (B.2.1.21)

Intermediate Pitting and Cooling, Decay Crevice Closed, Corrosion Tanks (Chemical Leakage Carbon Treated Water Loss of Closed-Cycle VIII.E-40 3.4.1-6 E, 2 Mix - Nuclear Boundary Steel (Internal) Material/ Cooling Water Service, General, System (B.2.1.10)

Intermediate Pitting and Cooling, Decay Crevice Closed, Corrosion Ilb ustoFal GGee-F)________

April 8, 2008 Page 3 of 11 5928-08-20079 Enclosure A Corrections in the Main Body of the TMI Unit I LRA Water Treatment & Distribution System Affected Section: 2.3.3.25 LRA Page Number: 2.3-169 Paragraph: System Intended Functions Change: The 3" pipe from SR-P-1A/B/C located outside between the Service Water Screen and Pump House and the Chlorinator House, as shown on LR-302-174 (D-1) and LR-302-202 (D-8), was originally included in scope for structural support. Further review concluded that this outdoor piping does not provide a Structural Support intended function and is not in scope. The portion of this 3" piping located inside the Service Water Screen and Pump House remains in scope for spatial interaction.

The intended function of structural support is deleted from System Intended Function 2 for the Water Treatment & Distribution System. System Intended Function 2 is revised to read as follows: "Resist nonsafety-related SSC failure that could prevent satisfactory accomplishment of a safety-related function. Portions of the system have the potential for spatial interaction or structural support. 10 CFR 54.4(a)(2)"

Affected Section: 2.3.3.25 LRA Page Number: 2.3-169 Paragraph: License Renewal Boundary Drawings Change: The list of License Renewal boundary drawings applicable to the Water Treatment & Distribution System is revised to delete drawing LR-302-174.

Affected Section: 2.3.3.25 LRA Page Number: 2.3-171 Paragraph: Table 2.3.3-25 Change: The intended function of Structural Support does not apply to the Water Treatment & Distribution System and is deleted from Table 2.3.3-25 as follows:

Component Type Intended Functions Pp~ng *ndfitt#Hý6+ .. + .. * ..

April 8, 2008 Page 4 of 11 5928-08-20079 Enclosure A Corrections in the Main Body of the TMI Unit 1 LRA Affected Section: 3.3.2.1.25 LRA Page Number: 3.3-31 Paragraph: Environments Change: The environment of "Air-Outdoor" does not apply to the Water Treatment &

Distribution System. The list of Environments in Section 3.3.2.1.25 is revised to read as follows:

Air - Indoor

,Air -Outdoor Air with Borated Water Leakage Raw Water Raw Water > 140 F Treated Water Treated Water > 140 F

April 8, 2008 Page 5 of 11 5928-08-20079 Enclosure A Corrections in the Main Body of the TMI Unit I LRA Affected Section: 3.3 LRA Page Number: 3.3-80 Paragraph: Table 3.3.1 Change: The environment of "Air - Outdoor (External)" is no longer applicable to the Water Treatment & Distribution System. Therefore, GALL Item Number 3.3.1-60 does not apply. Table 3.3.1 is revised to read as follows:

Item Component Aging Aging Further Discussion Number Effect/Mechanism Management Evaluation Programs Recommended 3.3.1-60 Steel piping, piping Loss of material External No Consistent with NUREG-1 801 with components, and due to general, Surfaces exceptions. The External Surfaces piping elements pitting, and crevice Monitoring Monitoring program, B.2.1.21, will be used exposed to air - corrosion to manage loss of material due to general, outdoor (external) pitting, and crevice corrosion of the steel piping, piping components, piping elements, and tanks exposed to outdoor air for the Auxiliary and Fuel Handling Building Ventilation Systems, Decay Heat Removal System, Emergency Diesel Generators and Auxiliary Systems, Emergency Feedwater System, Fire Protection System, Fuel Oil System, Miscellaneous Floor and Equipment Drains System, Open Cycle Cooling Water System, Station Blackout and UPS Diesel Generator Systems,--aRd Watin Trnatment n cDintributio SyStcm

________________________________________________(Remaining Text Unchanged)

April 8, 2008 Page 6 of 11 5928-08-20079 Enclosure A Corrections in the Main Body of the TMI Unit I LRA Affected Section: 3.3.2 LRA Page Number: 3.3-358 Paragraph: Table 3.3.2-25 Change: The intended function of Structural Support does not apply to the Water Treatment & Distribution System and is deleted from Table 3.3.2-25 as follows:

Component Intended Material Environment Aging Effect Aging Management NUREG - Table 1 Notes Type Function Requiring Programs 1801 Vol. 2 Item Management Item Piping ad. Structural Suppo.t GaFbeR A*F -AdeF Less eV Exte.ral SIurfa-es V*.i.Hi-8 3.3.-14 0 a Fittifigs Steel (-ExteMal) Matcrial/Genc MGontOorig (13.2. 1.22)

Fal Pitting*

Pitiig ate .... ..... ,

a Su..r ... *aw

^te Lessri aE l en . . i, ,*f -,.... 1- 3.3.e 76 E-,.4----"

ral,-PittWig, Miscellaneous Piping Fitti~~~~~gS~ Steel ('ReFa, MiGeb~ei~kj

,lintGee GeRmpeReRts SUfaesi a~y (B.2.122)

PRflueRG -

and Feuen

April 8, 2008 Page 7 of 11 5928-08-20079 Enclosure A Corrections in the Main Body of the TMI Unit 1 LRA 3.5.2.1 Materials, Environments, Aging Effects Requiring Management and Aging Management Programs for Structures and Component Supports The following items were inadvertently omitted from the LRA summaries in section 3.5.2.1. The associated section 3.5.2 tables for these structures correctly include these items.

Affected Section: 3.5.2.1.7 - Fuel Handling Building LRA Page No.: 3.5-10 Paragraph: Aging Effects Requiring Management Change: Add a bulleted Aging Effect Requiring Management that reads "Cumulative Fatigue Damage/Fatigue".

Affected Section: 3.5.2.1.7 - Fuel Handling Building LRA Page No.: 3.5-10 Paragraph: Aging Management Programs Change: Add a bulleted aging management program that reads "TLAA".

Affected Section: 3.5.2.1.9 - Intermediate Building LRA Page No.: 3.5-13 Paragraph: Aging Effects Requiring Management Change: Add a bulleted Aging Effect Requiring Management that reads, "IncreaseIn Porosityand Permeability,Loss of Strength/Leaching of Calcium Hydroxide".

Affected Section: 3.5.2.1.14- Reactor Building LRA Page No.: 3.5-18 Paragraph: Materials Change: Add a bulleted Material that reads "Epoxy".

Affected Section: 3.5.2.1.19 -Turbine Building LRA Page No.: 3.5-24 Paragraph: Aging Effects Requiring Management Change: Add a bulleted Aging Effect Requiring Management that reads, "Increase In Porosityand Permeability,Loss of Strength/Leaching of Calcium Hydroxide".

April 8, 2008 Page 8 of 11 5928-08-20079 Enclosure A Corrections in the Main Body of the TMI Unit I LRA Environmental Fatigue TLAA Affected Section: 4.3.2 - Evaluation of Reactor Water Environmental Effects on Fatigue Life of Piping and Components (Generic Safety Issue 190)

LRA Page Numbers: 4-32, 4-33 and 4-38 Table: Table 4.3.2 TMI-1 Pressurizer Surge Line Environmental Fatigue Results.

Table 4.3.2-5, Final Environmental Fatigue Analysis Summary for NUREG/CR-6260 Locations.

Change: This change incorporates updated analysis results for environmental fatigue of pressurizer surge line nozzles and safe ends (locations 3c and 3d). All environmentally adjusted cumulative usage factor (CUF) values remain acceptable, below the code limit of 1.0 for 60 years.

The change includes the following revisions to Table 4.3.2-2:

• An environmental correction factor of 1.74 was applied for the carbon steel hot leg nozzle and pressurizer surge nozzle materials, replacing a 2.455 value applicable for low alloy steel.

• Environmental fatigue results for an additional location on the hot leg nozzle and on the pressurizer surge nozzle are being added to the table for completeness.

These locations were previously analyzed but not included in the LRA table. The location is the nozzle-to-head corner, which is the blend radius of the nozzle forging. The entire surge line, including weld overlays and adjacent nozzles, has been evaluated satisfactorily for environmental effects.

• A revised CUF value for the hot leg nozzle safe end is used that is based upon 40-year design cycles. It replaces a previous value that was based upon reduced cycles. This was done for consistency purposes so that all of the analyzed locations associated with the nozzles, safe ends, and weld overlays are based upon the same number of transient cycles, which is the 40-year design numbers. Notes 3 and 6 have been used to clarify the numbers of cycles used for each component.

• Revised CUF values for the pressurizer surge nozzle and safe end are used that are based upon a revision to the pressurizer surge nozzle weld overlay analysis.

Note 8 was revised to explain that the bounding outside surface CUF value from the revised weld overlay analysis was conservatively applied for the inside surface CUF value in the environmental fatigue analysis.

Table 4.3,2-5 was revised to incorporate the changes affecting the bounding components for locations 3c and 3d, as described above.

April 8, 2008 Page 9 of 11 5928-08-20079 Enclosure A Corrections in the Main Body of the TMI Unit I LRA Table 4.3.2 TMI-1 Pressurizer Surge Line Environmental Fatigue Results Inside Fen Environmental Pass/

Location No. Component Material Type Surface Correction CUF Fail CUF Factor Surge Line - Piping Elbow 0.399 2.383 0.951 3a bounding elbow location (second Stainless Steel Note 1 Note 2 Note 6 Pass elbow from hot leg)

Surge Line - Bounding Piping 0.375 2.259 0.847 3b location (elbow-to-pipe weld for Stainless Steel Note 1 Note 2 Note 6 Pass second elbow from hot leg) 3c Surge Line - Hot Leg Nozzle-to-Safe End Weld with Full Structural Weld Overlay 0.180 1.740.313 Hot Leg Nozzle Carbon Steel Note 3 2 0.-42 Pass Note 4 Hot Leg Nozzle-to-head corner Carbon Steel 0.409 1.74 0.712 Pass Nickel Alloy 0.109 1.49 Hot Leg Nozzle-to-Safe End Weld 82/182 Weld Note 3 Note 5 0.162 Pass Metal 0.063 00315.35 0.967 Safe End Stainless Steel 015358 0.97 Pass NoteNoe~Note 3 6a 7 0===0 Nickel Alloy Weld Overlay (inside surface 52/152 Weld 0.107 1.49 Pass above the Alloy 82/182 weld) Metal Note 3 Note 5

April 8, 2008 Page 10 of 11 5928-08-20079 Enclosure A Corrections in the Main Body of the TMI Unit I LRA Table 4.3.2-2 -,TMI-1 Pressurizer Surge Line Environmental Fatigue Results Inside Fen Environmental Pass/

Location No. Component Material Type Surface Correction Factor *__ Fail

__CUF 3d Surge Line - Pressurizer Surge Nozzle-to-Safe End Weld with Full Structural Weld Overlay 0.3909 1.74 Pressurizer Surge Nozzle Carbon Steel 0 2 0.6017 Pass Notes 3, 8 Note 4 Surge Nozzle-to-head corner Carbon Steel 0.316 1.74 0.550 Pass Pressurizer Surge Nozzle-to-Safe Nickel Alloy 0.0031 1.49 Essrier 82/182 Weld Note 3 Note 5Pass End Weld Metal Note_3Note_

0.0082 15.35 0.126 Safe End Stainless Steel Note 7 Pass Note 3 Weld Overlay (inside surface Nickel Alloy 52/152 Weld 0.0009 0.0090.49Pass 1.49 above the Alloy 82/182 weld) Metal Note 3 Note 5 0.001 Note 1: This value is the current design CUF based upon 40-year design transients.

Note 2: This value is a composite Fen correction factor and cycle reduction factor, derived by dividing the EAF-adjusted CUF value by the original design CUF value. It represents the combined effects of CUF increase due to reactor water environmental effects and CUF decrease due to the reduced numbers of cycles shown in Table 4.3.2-3.

Note 3: This value is the CUF value from the weld overlay analysis using 40-year design cycles.

Note 4: This value is the Fen correction factor for carbon steels, derived from NUREG/CR-6583.

Note 5: This value is the Fen correction factor for nickel alloys, derived from Omesh Chopra paper.

Note 6: This CUF value is based upon reduced cycles shown in Table 4.3.2-3.

Note 7: This value is the maximum Fen correction factor for stainless steels, derived from NUREG/CR-5704.

Note 8: This CUF value is the bounding outside surface value conservatively applied for the inside surface CUF value. This Value based unon sunolemnent to weld oerelav analvsis for finside surfacc N2 pathtI and isbased uinon 40 year desiontAm set

April 8, 2008 Page 11 of 11 5928-08-20079 Enclosure A Corrections in the Main Body of the TMI Unit I LRA Table 4.3.2-5 Final Environmental Fatigue Analysis Summary for NUREG/CR-6260 Locations Location Limiting Inside Fen EAF Component Material Surface Fen Adjusted P/F No. Type CUF Multiplier CUF Reactor Vessel Shell la and Lower Head - Low Alloy 0.004 2.455 0.010 Pass Lower Head near Steel Support Skirt Reactor Vessel 1b 1bLower Head -

LwrHa-Nikl Nickel 0.564 1.49 0.840 Pass Instrument Nozzle Alloy 600 Penetration Weld 2a Reactor Vessel Inlet Low Alloy 0.008 2.455 0.020 Pass Nozzle Steel 2b Reactor Vessel Low Alloy 0.252 2.455 0.619 Pass Outlet Nozzle Steel 3a Pressurizer Surge Stainless 0.399 2.383 0.951 Pass Line (elbow) Steel Surge Line - Piping Stainless 3b Non-Elbow bounding Steel 0.375 2.259 0.847 Pass pipe location 3c Safe End Stainless 0.063 0.967 Pass Steel 150.35 35 3d Pressurizer Surge Carbon 0.3909 1.74 0.680 Pass Nozzle F-giai Steel O7OO5r 2-245 0,043.7 Makeup/High Nickel 4 Pressure Injection Alloy 600 0.656 1.49 0.977 Pass Nozzle 5 Reactor Vessel Core Low Alloy 0.198 2.455 0.486 Pass Flood Nozzle Steel Decay Heat Removal Stainless 6 System Return Line Steel 0.0213 15.35 0.327 Pass Class 1 Piping