ML082520122

Request for Additional Information, License Renewal Application, Boral Neutron Absorbing Material in Spent Fuel Pool Racks

ML082520122
Person / Time
Site:	Three Mile Island
Issue date:	10/20/2008
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: ML082520122 (7)

Text

October 20, 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 BORAL NEUTRON ABSORBING MATERIAL IN SPENT FUEL POOL RACKS, 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 (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 continuing to review 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

ML082520122 OFFICE LA:DLR DCI:SGCB PM:DLR:RPB1 BC:DLR:RPB1 NAME SFigueroa AHiser (EMurphy for) JRobinson DPelton (JRobinson for) DATE 9/11/08 10/15/08 10/20/08 10/20/08 Letter to AmerGen Energy Company, LLC from J. Robinson dated October 20, 2008 DISTRIBUTION

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR BORAL NEUTRON ABSORBING MATERIAL IN SPENT FUEL POOL RACKS, 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 RidsNrrDlrRerb RidsNrrDciCsgb RidsOgcMailCenter ------------- EWongMModes, 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 BORAL NEUTRON ABSORBING MATERIAL IN SPENT FUEL POOL RACKS THREE MILE ISLAND NUCLEAR STATION, UNIT 1 LICENSE RENEWAL APPLICATION DOCKET NUMBER 50-289 RAI#: 3.3.2.2.6-1 Reduction of Neutron-Absorbing Capacity and Loss of Material due to General Corrosion

The Generic Aging Lessons Learned (GALL) Report recognizes the possibility of the existence of aging effects in the Boral used in the spent fuel storage racks and the need for having a plant specific aging management program (AMP). However, in the Three Mile Island Nuclear Station Unit 1 (TMI-1) License Renewal Application (LRA), Amergen Energy Company, LLC, (the applicant) has indicated that degradation of Boral is insignificant and no AMP is required. The applicant provided several justifications for not having an AMP, but has stated that they will continue to implement a surveillance program.

In order to complete its review, the staff requests that the applicant provide a description of the surveillance program that will be implemented during the period of extended and include the following information in the response:

1. Provide the scope of the program, including the structures and components that will be under surveillance.

2. Describe how the neutron-absorbing capacity and degradation of material will be monitored, including a description of the parameters, calculations, and acceptance criteria.

3. Discuss how the structures and components will be maintained for the period of extended operation, including the methods, techniques (e.g., visual, weight, volumetric, surface inspection), frequency, sample size, data collection and timing.

4. Confirm that TMI-1 has sufficient Boral coupon samples to maintain the sampling frequency through the period of extended operation. Also include: a. The location of coupons relative to the spent fuel racks. b. The mounting of the coupons and whether or not they are fully exposed to the spent fuel pool water. c. The specific testing procedures used for determining Boral-10 areal density, verifying surface corrosion, (if any), and examining for blister formation. d. The location of the coupons after removal from the pool for inspection and reinsertion in the pool.

5. Describe how Boral will be monitored and trended.

6. Describe the acceptance criteria of the program and how it ensures that Boral's structure and function are maintained over the period of extended operation.

7. Describe the corrective actions that would be implemented if coupon test results are not acceptable.

8. In September 2003, inspection of Boral test coupons at Seabrook Nuclear Station revealed bulging and blistering of the aluminum cladding. Discuss the impact, if any, that this event is considered to have on the Boral surveillance program at TMI-1. Industry experience has indicated that during longer exposure such blisters may form. Since formation of blisters may affect the efficiency of the Boral panels to attenuate neutrons (through flux trap formation) and may cause deformation of the fuel cells, explain why blistering will not be a safety concern.

9. Discuss any other operating experience of Boral that may be applicable to TMI-1 and describe why it will not be a safety concern.

10. Describe how the Water Chemistry program will be used to manage the loss of material due to general corrosion of Boral. Include the parameters that will be monitored, the parameters' acceptance criteria, and how they will effectively manage the loss of Boral.