ML083090053

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License Renewal Application, Summary of Conference Call with Amergen Energy Company Regarding Responses to Request for Additional Information for Sections 2.3.3 and 2.3.4
ML083090053
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 11/17/2008
From: Jay Robinson
License Renewal Projects Branch 1
To:
Office of Nuclear Reactor Regulation
Robinson, J NRR/DLR/RPB1 415-2878
References
TAC MD7701
Download: ML083090053 (8)


Text

November 17, 2008 LICENSEE: AmerGen Energy Company, LLC

FACILITY: Three Mile Island Nuclear Station, Unit 1

SUBJECT:

SUMMARY

OF CONFERENCE CALL WITH AMERGEN ENERGY COMPANY, LLC, TO DISCUSS RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION FOR SECTIONS 2.3.3 AND 2.3.4 OF THE THREE MILE ISLAND NUCLEAR STATION, UNIT 1, LICENSE RENEWAL APPLICATION (TAC NO. MD7701)

On October 23, 2008, the U.S. Nuclear Regulatory Commission (NRC or the staff) conducted a conference call (teleconference) with representatives from AmerGen Energy Company, LLC (AmerGen), to discuss AmerGen's response to the request for additional information (RAI) regarding Sections 2.3.3 and 2.3.4 of the Three Mile Island Nuclear Station, Unit 1 (TMI-1),

license renewal application (LRA). The enclosure lists the participants in the conference call.

By letter dated August 20, 2008, the staff requested additional information from the applicant in regards to the TMI-1 LRA (ADAMS Accession No. ML082180499). By letter dated September 16, 2008, the applicant submitted their reply to the RAI (ADAMS Accession No. ML082630030).

After the introductions, representatives of AmerGen and NRC discussed the purpose of the phone call which was to clarify several of the responses in the applicants reply to the RAI as follows: RAI-2.3.3.14-1 During the staffs review of the applicants response to RAI 2.3.3.14-1 the staff questioned the applicant depicting "lubricating oil" under "Materials" for section 3.3.2.1.14 Instrument and Control Air System where they indicated the "Environments List" should have shown "lubricating oil" (see page 22 of 44 of ML082630030).

The applicant agreed that "lubricating oil" should have been listed under "Environments List" and not "Materials."

RAI-2.3.3.17-1

During the staffs review of the applicants response to RAI 2.3.3.17-1, the staff questioned why the actual revision to Table 3.3.1, Item number 3.3.1-58 to include the Liquid and Gas Sampling System in the Discussion list of applicable systems for the External Surfaces Monitoring Program was not included in the RAI response. The applicant included a description of the revision (see page 25 of 44 of ML082630030). The applicant indicated that for table revisions that only include one item or a minor change that they have not been showing the table revisions in the RAI response, rather providing a description of the revision instead.

RAI 2.3.3.17-3 During the staffs review of the applicants response to RAI 2.3.3.17-3, the staff questioned why the response appears to invoke the "mitigative" option which is contrary to the information provided in the LRA on pages 2.1-20 and 2.1-21 that states this option is not used. (see page 29 of 44 of ML082630030).

The applicant provided feedback on this concern. The enclosure is not credited as a part of the current licensing basis for mitigative equipment to safety-related equipment. They further stated that piping inside the enclosure does not have a potential for spatial interaction with safety-related equipment because the enclosure protects the safety-related equipment from spray originating from the nonsafety-related components. The applicant compared the enclosure to a wall, where an (a)(2) pipe penetrated to another room, but the wall would not be included in scope for (a)(2).

The staff indicated that they would review the additional information discussed during the teleconference and provide additional feedback to the applicant.

RAI 2.3.3.19-1 During the staffs review of the applicants response to RAI 2.3.3.19-1, the staff questioned the dimensions of the bar grids since in paragraph 2 of the response it is stated that the bar grids are "2-foot by 2-foot," but in paragraph 5 of the response it is states "bar grids, with a 2-foot horizontal spacing and a 3.5-foot vertical spacing" (see page 30 of 44 of ML082630030).

The applicant indicated that 2-foot horizontal spacing and 3.5 foot vertical spacing are the correct values.

The staff also questioned whether or not a word was missing from the next to last sentence in the first paragraph on page 31 of 44 of ML082630030. Specifically the staff questioned the wording of "included the OCCW System," and whether or not a word was missing between the word "included" and the word "the."

The applicant indicated that the word "in" was missing between the words "included" and "the" and that the sentence should read: "included in the OCCW System."

The staff also questioned whether or not the environment of "raw water internal" was correct for the strainer element bar grids and bar racks in revised Table 3.3.2.19 (see page 33 of 41 of ML082630030).

The applicant indicated that "internal" is incorrect and that the correct environment is "raw water external."

The staff also questioned whether or not the discussion section would be revised for Item 3.3.1-79 in Table 3.3.1 based on the response to the RAI (see page 33 of 44 of ML082630030).

The applicant indicated that the discussion section for Item 3.3.1-79 in Table 3.3.1 would be revised to reflect the structures monitoring program.

RAI 2.3.3.14-2 & RAI 2.3.3.17-2

During the staffs review of the applicants responses to RAIs 2.3.3.14-2 and RAI 2.3.3.17-2, the staff questioned whether or not the applicable drawings were going to be corrected based on the responses to the RAIs (see page 23 of 44 and 27 of 44 of ML082630030).

The applicant indicated that drawing changes would be made but that they would not be submitted as part of the responses to RAIs. The applicants position is that a description of needed drawing changes is sufficient for an RAI response.

The staff generally agreed with the applicant, but indicated that additional RAIs would be forthcoming to account for several other drawing issues.

The applicant further commented that for license renewal drawings, the color green indicates systems, structures, and components in scope for 10 CFR 54.4 (a)(2) "functional."

\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

ML083090053 OFFICE LA:DLR DSS:SBPB PM:DLR:RPB1 BC:DLR:RPB1 NAME IKing SGardocki JRobinson DPelton DATE 11/6/08 11/7/08 11/17/08 11/17/08 Letter to AmerGen Energy Company, LLC from J. Robinson dated November 17, 2008 DISTRIBUTION

SUBJECT:

SUMMARY

OF CONFERENCE CALL WITH AMERGEN ENERGY COMPANY, LLC, TO DISCUSS RESPONSES TO REQUEST FOR ADDITIONAL INFORMATION FOR SECTIONS 2.3.3 AND 2.3.4 OF THE THREE MILE ISLAND NUCLEAR STATION, UNIT 1, LICENSE RENEWAL APPLICATION (TAC NO. MD7701)

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

SGardocki ENCLOSURE Conference Call between the U.S. Nuclear Regulatory Commission and AmerGen Energy Company, LLC To Discuss the Response to Request for Additional Information for Sections 2.3.3 and 2.3.4 of the Three Mile Island Nuclear Station, Unit 1 License Renewal Application List of Participants October 23, 2008

PARTICIPANTS AFFILIATION Jay Robinson U.S. Nuclear Regulatory Commission (NRC) Stanley Gardocki NRC John Woodfield Information Systems Laboratories (ISL)

Cliff Marks ISL Chris Wilson AmerGen Energy Company, LLC (AmerGen) Al Fulvio AmerGen Fred Polaski AmerGen Mark Miller AmerGen Jack Cockroft AmerGen Dan Christiana AmerGen Bill Ford AmerGen

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 1911north Fr. 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 Kennet 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 License Renewal Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348