TMI-09-006, Response to NRC Request for Additional Information Related to License Renewal Application

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Response to NRC Request for Additional Information Related to License Renewal Application
ML090140339
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 01/12/2009
From: Gallagher M
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TMI-09-006
Download: ML090140339 (25)
v • d • e


Text

Telephone 610.765.5958 ExeI~n.)

Michael P.GallagheT, PE Vice President www.exeloncorp.com Nuclear License Renewal Projects michaelp.gallagher@exeloncorp.com 10 CFR 50 Exelon Nuclear 10 CFR 51 2oo Exelon Way 10 CFR 54 KSA/2-E Kennett Square, PA 19348 TMI-09-006 January 12, 2009 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:

Response to NRC Request for Additional Information related to Three Mile Island Nuclear Station, Unit 1, License Renewal Application.

Reference:

Letter from Mr. Jay Robinson (USNRC), to Mr. Michael P. Gallagher (AmerGen)

"Request for Additional Information for Three Mile Island Nuclear Station, Unit 1, License Renewal Application", dated January 5, 2009. (TAC No. MD7701)

In the referenced letter, the NRC requested additional information where additional information is needed to complete the review of the Three Mile Island Nuclear Station, Unit 1, License Renewal Application (LRA). Enclosed are the responses to this request for additional information.

This letter and its enclosure contain no commitments.

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 0 / / Z2. oO0 9 Michael P. Gallagher Vice President, License Renewal Exelon Generation Company, LLC

-//,Si k(e6

January 12, 2009 Page 2 of 2 TMI-09-006 Enclosure A: Response to Request for Additional Information for 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/o Enclosure USNRC Project Manager, NRR - TMIGS, w/o Enclosure USNRC Senior Resident Inspector, TMIGS, w/o Enclosure File No. 08001

January 12, 2009 Page 1 of 23 TMI-09-006 Enclosure - A Enclosure - A Response to Request for Additional Information for the Three Mile Island Nuclear Station, Unit 1, License Renewal Application.

Note: As a standard convention for Exelon RAI responses, added text will be shown as bolded italicswhereas deleted text will be shown as st.iketh.ei.gh.

January 12, 2009 Page 2 of 23 TMI-09-006 Enclosure - A 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 (i.e.; lines 3.1.1-23 and 3.2.1-17). For many of the line items, a subsection of the LRA is referenced (i.e.; "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. (i.e.: "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.

January 12, 2009 Page 3 of 23 TMI-09-006 Enclosure - A Exelon Response The Table below identifies the specific reason(s) why a Table 3.x.1 Item is not considered applicable to TMI for all Table 3.x. 1 Items where "Not Applicable" is listed in the "Discussion" column.

Table 1 Item Basis for Non-Applicability Number 3.1.1-16 Applies only to Recirculating Steam Generators. TMI-1 has Once-Through Steam Generators.

3.1.1-23 The components addressed by Item Number 3.1.1-23 are included with the Reactor Vessel System, Class 1 piping, fittings and branch connections <

NPS 4". The components are stainless steel with an external environment of Air with Borated Water Leakage and an internal environment of Reactor Coolant. The AMR results for these components are included in LRA Table 3.1.2-2, Reactor Vessel, Summary of Aging Management Evaluation, and are shown on pages 3.1-74 and 3.1-75 of the LRA. Refer to AmerGen's response to RAI 3.1.2.2.7-1.

3.1.1-24 With the exception of pump casings and valve bodies, there are no Class 1 CASS piping, piping components, or piping elements in the Reactor Vessel, Internals and Reactor Coolant System. Cracking due to stress corrosion cracking in Class 1 CASS pump casings and valve bodies is addressed by Item 3.1.1-68. Item 3.1.1-24 specifies Water Chemistry and a plant specific program while Item 3.1.1-68 specifies Water Chemistry and ASME XI IWB, IWC, and IWD. ASME XI IWB, IWC, and IWD is considered an acceptable plant specific program for managing cracking due to stress corrosion cracking in Class 1 CASS pump casings and valve bodies.

3.1.1-28 Applies only to Recirculating Steam Generators. TMI-1 has Once-Through Steam Generators.

3.1.1-32 Applies only to Recirculating Steam Generators. TMI-1 has Once-Through Steam Generators. Refer to AmerGen's response to RAI 3.1.2.2.14-1.

3.1.1-36 Refer to LRA Section 3.1.2.2.16.2 3.1.1-53 There are no steel piping, piping components, or piping elements exposed to closed cycle cooling water in the Reactor Vessel, Internals and Reactor Coolant System.

3.1.1-54 There are no copper alloy piping, piping components, or piping elements exposed to closed cycle cooling water in the Reactor Vessel, Internals and Reactor Coolant System.

January 12, 2009 Page 4 of 23 TMI-09-006 Enclosure - A Table 1 Item Basis for Non-Applicability Number 3.1.1-56 There are no copper alloy >15% Zn piping, piping components, or piping elements exposed to closed cycle cooling water in the Reactor Vessel, Internals and Reactor Coolant System.

3.1.1-57 With the exception of pump casings and valve bodies, there are no Class 1 CASS piping, piping components, or piping elements in the Reactor Vessel, Internals and Reactor Coolant System. The loss of fracture toughness due to thermal aging embrittlement in Class 1 CASS pump casings and valve bodies is addressed by Item 3.1.1-55.

3.1.1-59 FW and EFW nozzles are Nickel Alloy and are not susceptible to FAC. FW and EFW do not have safe ends. Main Steam nozzles are low alloy steel and Main Steam safe ends are carbon steel. FAC is not predicted for portions of the steam generator exposed to main steam, including these components. The Main Steam System is by design 35 degrees superheated and is therefore well above the optimum range for FAC.

3.1.1-60 Applies only to Westinghouse PWRs. TMI-1 is not a Westinghouse PWR.

3.1.1-63 Based on TMI-1 and Industry Operating Experience, the loss of material due to wear is not predicted for this component, material, and environment combination in the Reactor Vessel, Internals and Reactor Coolant System.

3.1.1-66 There are no steel steam generator secondary manways and handhold covers exposed to air with leaking secondary-side water and/or steam in the Reactor Vessel, Internals and Reactor Coolant System.

3.1.1-67 Cracking due to cyclic loading in stainless steel or steel with stainless steel cladding Reactor Vessel, Internals and Reactor Coolant System piping and components exposed to reactor coolant is addressed by Item 3.1.1-62.

Item 3.1.1-67 identifies Water Chemistry as an additional aging management program; however, Water Chemistry is not an appropriate program for managing cracking due to cyclic loading.

3.1.1-74 Applies only to Recirculating Steam Generators. TMI-1 has Once-Through Steam Generators.

3.1.1-76 There is no steel steam generator tube support plate, tube bundle wrapper exposed to secondary feedwater/steam in the Reactor Vessel, Internals and Reactor Coolant System. The TMI-1 tube support plate is stainless steel.

Tube bundle wrappers are associated only with Recirculating Steam Generators. TMI-1 has Once-Through Steam Generators.

January 12, 2009 Page 5 of 23 TMI-09-006 Enclosure - A Table 1 Item Basis for Non-Applicability Number 3.1.1-77 Applies only to Recirculating Steam Generators. TMI-1 has Once-Through Steam Generators.

3.1.1-78 Applies only to Recirculating Steam Generators. TMI-1 has Once-Through Steam Generators.

3.1.1-79 Applies only to Recirculating Steam Generators. TMI-1 has Once-Through Steam Generators.

3.1.1-81 Applies only to Recirculating Steam Generators. TMI-1 has Once-Through Steam Generators.

3.1.1-82 Applies only to Recirculating Steam Generators. TMI-1 has Once-Through Steam Generators.

3.1.1-85 There are no nickel alloy piping, piping components, and piping elements exposed to air - indoor uncontrolled (external) in the Reactor Vessel, Internals and Reactor Coolant System. The external environment of nickel alloy piping, piping components, and piping elements in the Reactor Vessel, Internals and Reactor Coolant System is air with borated water leakage.

3.1.1-87 There are no steel piping, piping components, and piping elements exposed to concrete in the Reactor Vessel, Internals and Reactor Coolant System.

3.2.1-2 There are no steel with stainless steel cladding pump casings exposed to treated borated water in Engineered Safety Features systems.

3.2.1-3 This component, material, environment, and aging effect/mechanism combination is addressed by Item 3.2.1-49. As discussed in the "Discussion" column for Item 3.2.1-49 in LRA Table 3.2.1, Water Chemistry is augmented by the One-Time Inspection aging management program for treated (borated) water in the Reactor Building Sump and Drain System. In the latter case, the Table 2 AMR line item was identified with an "E" Standard Note and a plant specific note stating: "Portions of the Reactor Building Sump and Drain System provide for drainage or reactor grade borated treated water. Based on plant operating experience, aging effects are expected to progress very slowly in this environment, but the local environment may be more adverse than generally expected. The One-Time Inspection program will augment the Water Chemistry program by verifying the absence of aging effects."

3.2.1-4 There are no stainless steel piping, piping components, and piping elements exposed to soil in Engineered Safety Features systems.

January 12, 2009 Page 6 of 23 TMI-09-006 Enclosure - A Table 1 Item Number Basis for Non-Applicability 3.2.1-7 There are no partially encased stainless steel tanks with breached moisture barriers exposed to raw water in Engineered Safety Features systems.

3.2.1-10 Component/material combination does not exist in Engineered Safety Features systems. Stainless ESF heat exchanger components exposed to treated water have been included in the Auxiliary Systems Closed Cycle Cooling Water System (refer to LRA Section 2.1.6.1). This component, material, environment, and aging effect combination is addressed by Item 3.3.1-3 from the Auxiliary Systems grouping.

3.2.1-16 TMI-1 predicts the additional aging effect/mechanism of loss of material/MIC for carbon steel in lubricating oil. This component, material, environment, and aging effect/mechanism combination is addressed by Item 3.4.1-12.

3.2.1-17 Steel (with or without coating or wrapping) piping, piping components, and piping elements exposed to soil in Engineered Safety Features systems is addressed by identical Item 3.3.1-19 from the Auxiliary Systems grouping.

3.2.1-21 There is no high-strength steel closure bolting exposed to air with steam or water leakage in Engineered Safety Features systems.

3.2.1-22 There is no steel closure bolting exposed to air with steam or water leakage in Engineered Safety Features systems.

3.2.1-25 There are no stainless steel piping, piping components, and piping elements exposed to closed cycle cooling water >60 0 C (>1400 F) in Engineered Safety Features systems.

3.2.1-26 There are no steel piping, piping components, and piping elements exposed to closed cycle cooling water in Engineered Safety Features systems.

3.2.1-27 Steel ESF heat exchanger components exposed to closed cycle cooling water have been included in the Auxiliary Systems Closed Cycle Cooling Water System (refer to LRA Section 2.1.6.1). This component, material, environment, and aging effect combination is addressed by Item 3.3.1-47 from the Auxiliary Systems grouping since galvanic corrosion as identified in Item 3.2.1-27 does not apply to these heat exchanger components.

3.2.1-29 Copper alloy ESF heat exchanger components exposed to closed cycle cooling water have been included in the Auxiliary Systems Closed Cycle Cooling Water System (refer to LRA Section 2.1.6.1). This component, material, environment, and aging effect combination is addressed by Item 3.3.1-51 from the Auxiliary Systems grouping.

January 12, 2009 Page 7 of 23 TMI-09-006 Enclosure - A Table 1 Item Basis for Non-Applicability Number 3.2.1-30 Stainless and copper alloy ESF heat exchanger components exposed to closed cycle cooling water have been included in the Auxiliary Systems Closed Cycle Cooling Water System (refer to LRA Section 2.1.6.1). This component, material, environment, and aging effect combination is addressed by Item 3.3.1-52 from the Auxiliary Systems grouping.

3.2.1-33 There are no steel encapsulation components exposed to air-indoor uncontrolled (internal) in Engineered Safety Features systems. Engineered Safety Features systems encapsulation components are stainless steel and not subject to aging effects in an air-indoor uncontrolled environment.

3.2.1-36 There are no steel heat exchanger components exposed to raw water in Engineered Safety Features systems.

3.2.1-37 TMI-1 predicts the additional aging effect/mechanism of loss of material/fouling for stainless steel in raw water. This component, material, environment, and aging effect/mechanism combination is addressed by Item 3.2.1-38.

3.2.1-39 There are no stainless steel heat exchanger components exposed to raw water in Engineered Safety Features systems.

3.2.1-40 There are no steel or stainless steel heat exchanger tubes (serviced by open-cycle cooling water) exposed to raw water in Engineered Safety Features systems.

3.2.1-42 There are no gray cast iron piping, piping components, and piping elements exposed to closed-cycle cooling water in Engineered Safety Features systems.

3.2.1-43 There are no gray cast iron piping, piping components, and piping elements exposed to soil in Engineered Safety Features systems.

3.2.1-44 There are no gray cast iron motor coolers exposed to treated water in Engineered Safety Features systems.

3.2.1-47 With the exception of valve bodies, there are no CASS piping, piping components, or piping elements in Engineered Safety Features systems.

The loss of fracture toughness due to thermal aging embrittlement in CASS valve bodies is addressed by Item 3.1.1-55.

3.2.1-54 There are no steel piping, piping components, and piping elements exposed to air - indoor controlled (external) in Engineered Safety Features systems.

January 12, 2009 Page 8 of 23 TMI-09-006 Enclosure - A Table 1 Item Basis for Non-Applicability Number 3.3.1-5 This component, material, environment, and aging effect/mechanism combination is addressed by Item 3.4.1-14 from the Steam and Power Conversion Systems grouping and Item 3.3.1-90. Item 3.3.1-5 specifies a plant specific aging management program. This is satisfied by Item 3.4.1-14, which specifies the Water Chemistry and One-Time Inspection aging management programs. It is also satisfied by Item 3.3.1-90, which specifies Water Chemistry. Item 3.3.1-90 has been augmented in the aging management reviews to also include the One-Time Inspection aging management program.

3.3.1-7 This line item is from GALL Section VII.E1 for PWR Chemical and Volume Control System stainless steel non-regenerative heat exchangers exposed to borated treated water > 140 OF. This GALL system has been included in the TMI-1 Makeup and Purification (MUP) License Renewal System.

The subject heat exchangers are the Letdown Coolers and the RC Pump Seal Return Coolers. The aging management review for the Letdown Coolers and the RC Pump Seal Return Coolers has been included in the Closed-Cycle Cooling Water (CCCW) License Renewal System. These components in the AMR do not currently include a treated water environment > 140 OF. A treated water environment > 140 OF should have been applied to these components.

The Water Chemistry aging management program will be used to manage these components for cracking due to SCC. The One-Time Inspection aging management program will also be applied as a verification program.

Cracking due to cyclic loading does not apply since these components are continuously in service and not subject to cyclic loading. The GALL recommended verification program for temperature and radioactivity monitoring of the shell side water, and eddy current testing of tubes for managing cyclic loading is therefore not applicable.

LRA changes associated with the addition of a treated water environment >

140 OF for the Letdown Coolers and the RC Pump Seal Return Coolers are included following this table.

3.3.1-8 There are no stainless steel regenerative heat exchanger components exposed to treated borated water >60'C (>140'F) in Auxiliary Systems.

The TMI-1 design does not include regenerative heat exchangers.

January 12, 2009 Page 9 of 23 TMI-09-006 Enclosure - A Table 1 Item Basis for Non-Applicability Number 3.3.1-9 This component, material, environment, and aging effect/mechanism combination does not exist. This line item is from GALL Section VII.E1 for PWR Chemical and Volume Control System stainless steel high pressure pumps. This GALL system has been included in the TMI-1 Makeup and Purification (MUP) License Renewal System.

The subject pumps are the MU-P-1A/B/C Make-up and Purification pumps.

These components are not subject to a treated water environment > 140 OF so cracking due to SSC does not apply. Cracking due to cyclic loading does not apply since these components are continuously in service and not subject to cyclic loading.

3.3.1-10 There is no high-strength steel closure bolting exposed to air with steam or water leakage in Auxiliary Systems.

3.3.1-14 TMI-1 predicts the additional aging effect/mechanism of loss of material/MIC for carbon steel in lubricating oil. This component, material, environment, and aging effect/mechanism combination is addressed by Item 3.4.1-12.

3.3.1-15 Component/material combination does not exist in Auxiliary Systems. The TMI-1 reactor coolant pump lubricating oil collection components are stainless steel. Line item 3.3.1-33 addresses the stainless steel reactor coolant pump lubricating oil collection components. See LRA Section 3.3.2.2.12.2.

3.3.1-16 Component/material combination does not exist in Auxiliary Systems. The TMI-1 reactor coolant pump lubricating oil collection components are stainless steel. Line item 3.3.1-33 addresses the stainless steel reactor coolant pump lubricating oil collection components. See LRA Section 3.3.2.2.12.2.

3.3.1-22 There are no steel with elastomer lining or stainless steel cladding piping, piping components, and piping elements exposed to treated water and treated borated water in Auxiliary Systems.

3.3.1-34 This component, material, environment, and aging effect/mechanism combination does not exist in Auxiliary Systems. Ventilation system elastomer components are not subject to relative motion between surfaces and therefore do not include the loss of material due to wear.

3.3.1-35 There are no steel with stainless steel cladding pump casings exposed to treated borated water in Auxiliary Systems.

January 12, 2009 Page 10 of 23 TMI-09-006 Enclosure - A Table 1 Item Basis for Non-Applicability Number 3.3.1-41 There is no high-strength steel closure bolting exposed to air with steam or water leakage in Auxiliary Systems.

3.3.1-42 There is no steel closure bolting exposed to air with steam or water leakage in Auxiliary Systems.

3.3.1-44 There is no steel compressed air system closure bolting exposed to condensation in Auxiliary Systems.

3.3.1-49 This component, material, environment, and aging effect/mechanism combination does not exist in Auxiliary Systems. Microbiologically Influenced Corrosion (MIC) is not predicted in closed cycle cooling water due to the lack of a MIC source.

3.3.1-53 This component, material, and environment combination is addressed by Item 3.3.1-71 since Item 3.3.1-53 does not include crevice corrosion, which is predicted for TMI-1 for this component, material, and environment combination. As discussed in the "Discussion" column for Item 3.3.1-71 in LRA Table 3.3.1, The Compressed Air Monitoring aging management program has been substituted for the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components program. In this case, the Table 2 AMR line item was identified with an "E" Standard Note and a plant specific note stating: "The aging effects of carbon steel in an air/gas -

wetted (internal) environment include loss of material due to general, pitting, and crevice corrosion. These aging effects/mechanisms are managed by the Compressed Air Monitoring program."

3.3.1-64 TMI-1 predicts the additional aging mechanisms of Microbiologically Influenced Corrosion and Fouling for steel components in fuel oil. This component, material, environment, and aging effect/mechanism combination is addressed by Item 3.3.1-20.

3.3.1-75 There are no elastomer seals and components exposed to raw water in Auxiliary Systems.

January 12, 2009 Page 11 of 23 TMI-09-006 Enclosure - A Table 1 Item Basis for Non-Applicability Number 3.3.1-77 This component, material, environment, and aging effect combination is addressed by Items 3.2.1-35, 3.3.1-68, and 3.3.1-76 since galvanic corrosion as identified in Item 3.3.1-77 does not apply to these heat exchanger components. The component, material, environment, and aging effect combination addressed by Items 3.2.1-35 and 3.3.1-76 are managed by the Open-Cycle Cooling Water System aging management program.

The raw water environment associated with floor and equipment drain systems and addressed by Item 3.3.1-68 are managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components since Open-Cycle Cooling Water System aging management program activities do not address waste raw water.

3.3.1-79 TMI-1 predicts the additional aging mechanism of Microbiologically Influenced Corrosion for stainless steel components exposed to raw water.

This component, material, environment, and aging effect/mechanism combination is addressed by Items 3.2.1-38 and 3.4.1-33. Circulating Water System components in raw water are managed by the Open-Cycle Cooling Water System aging management program. Components exposed to waste raw water environments are managed by the Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components since Open-Cycle Cooling Water System aging management program activities do not address waste raw water.

3.3.1-87 There are no boraflex spent fuel storage racks neutron-absorbing sheets exposed to treated borated water in Auxiliary Systems. The TMI-1 spent fuel storage racks are boral and are addressed by Item 3.3.1-13.

3.4.1-7 Refer to LRA Section 3.4.2.2.2.2.

3.4.1-21 There is no high-strength steel closure bolting exposed to air with steam or water leakage in Steam and Power Conversion Systems.

3.4.1-23 There are no stainless steel piping, piping components, and piping elements exposed to closed-cycle cooling water >60 0C (> 140 0 F) in Steam and Power Conversion Systems.

3.4.1-24 Steel Steam and Power Conversion Systems heat exchanger components exposed to closed cycle cooling water have been included in the Auxiliary Systems Closed Cycle Cooling Water System (refer to LRA Section 2.1.6.1). This component, material, environment, and aging effect combination is addressed by Item 3.3.1-47 from the Auxiliary Systems grouping since galvanic corrosion as identified in Item 3.4.1-24 does not apply to these heat exchanger components.

January 12, 2009 Page 12 of 23 TMI-09-006 Enclosure - A Table 1 Item Basis for Non-Applicability Number 3.4.1-25 There are no stainless steel piping, piping components, piping elements, and heat exchanger components exposed to closed cycle cooling water in Steam and Power Conversion Systems.

3.4.1-26 There are no copper alloy piping, piping components, and piping elements exposed to closed cycle cooling water in Steam and Power Conversion Systems.

3.4.1-27 There are no steel, stainless steel, or copper alloy heat exchanger tubes exposed to closed cycle cooling water with an intended function of heat transfer in Steam and Power Conversion Systems.

3.4.1-32 TMI-1 predicts the additional aging effect/mechanism of loss of material/fouling for stainless steel in raw water. This component, material, environment, and aging effect/mechanism combination is addressed by Item 3.4.1-33.

3.4.1-42 Refer to LRA Table 3.4.1 Item 3.4.1-42.

3.5.1-2 Refer to LRA Section 3.5.2.2.1.2.

3.5.1-3 Refer to LRA Section 3.5.2.2.1.2.

3.5.1-4 Refer to LRA Section 3.5.2.2.1.3.

3.5.1-10 Refer to LRA Section 3.5.2.2.1.7.

3.5.1-29 Refer to LRA Sections 3.5.2.2.2.1 and 3.5.2.2.2.2.3.

3.5.1-33 Refer to LRA Section 3.5.2.2.2.3.

3.5.1-38 Refer to LRA Section 3.5.2.2.2.5.

3.5.1-42 Refer to LRA Section 3.5.2.2.2.7.

3.5.1-51 Refer to LRA Table 3.5.1 Item 3.5.1-51.

3,5.1-57 Refer to LRA Table 3.5.1 Item 3.5.1-57.

3.6.1-6 Refer to LRA Section 3.6.2.3.1.

3.6.1-9 Refer to LRA Table 3.6.1 Item 9.

3.6.1-11 Refer to LRA Section 3.6.2.2.2.

January 12, 2009 Page 13 of 23 TMI-09-006 Enclosure - A Table 1 Item Basis for Non-Applicability Number 3.6.1-12 Refer to LRA Section 3.6.2.2.3.

During the review of Table 3.3.1 Item 3.3.1-7 it was identified that a treated water environment >

140 OF should have been applied to the Letdown Coolers and the RC Pump Seal Return Coolers in theaging management evaluation of the Closed Cycle Cooling Water System. The LRA changes associated with the addition of a treated water environment > 140 OF for the Letdown Coolers and the RC Pump Seal Return Coolers are included below.

LRA Table 3.3.2-4 Closed Cycle Cooling Water System Summary of Aging Management Evaluation should have included the following additional line items:

Component Intended Material Environment Aging Effect Aging NUREG- Table 1 Notes Type Function Requiring Management 1801 Item Management Programs Vol. 2 Item Heat Pressure Stainless Treated Cracking/Stress One-Time VII.E1-9 3.3.1-7 1, 5 exchanger Boundary Steel Water Corrosion Inspection components (Internal)> Cracking (B.2.1.18)

(Letdown 140 F Coolers)

Heat Pressure Stainless Treated Cracking/Stress Water VII.E1-9 3.3.1-7 1, 5 exchanger Boundary Steel Water Corrosion Chemistry components (Internal)> Cracking (B.2.1.2)

(Letdown 140 F Coolers)

Heat Pressure Stainless Treated Cracking/Stress One-Time VII.E1-9 3.3.1-7 I, 5 exchanger Boundary Steel Water Corrosion Inspection components (Internal)> Cracking (B.2.1.18)

(RC Pump 140 F Seal Return Coolers)

Heat Pressure Stainless Treated Cracking/Stress Water V1/.E1-9 3.3.1-7 1, 5 exchanger Boundary Steel Water Corrosion Chemistry components (Internal)> Cracking (B.2.1.2)

(RC Pump 140 F Seal Return Coolers)

The Plant Specific Notes should have included:

5. The Water Chemistry aging managementprogram will be used to manage these components for cracking due to SCC. The One-Time Inspection aging

January 12, 2009 Page 14 of 23 TMI-09-006 Enclosure - A management program will also be appliedas a verificationprogram. Crackingdue to cyclic loading does not apply since these components are continuously in service and not subject to cyclic loading. The GALL recommended verification program for temperature and radioactivitymonitoring of the shell side water, and eddy current testing of tubes for managingcyclic loading is therefore not applicable.

The "Discussion" column in LRA Table 3.3.1 Item 3.3.1-7 should have read:

Not Appfioable-Not consistent with NUREG-1801. The One-Time Inspection program, B.2. 1.18, will be used to verify the effectiveness of the Water Chemistry program,B.2.1.2, to manage cracking due to stress corrosioncracking in stainlesssteel nonregenerativeheat exchangercomponents exposed to treated borated water

>6O0 C (>1400 F). Cracking due to cyclic loading does not apply since these components are continuously in service and not subject to cyclic loading.

Subsection 3.3.2.2.4.1 should have read:

Itemn kmbr-A 3.31 7 is not app*i*cabl;to TM! 1. ThiS eMpGeornt, materaý;, *VnFirnMePt, and aging effeGt'moshanism does net apply to Auxiliary Syton~s.

TMI-1 will implement a One-Time Inspection program,B.2.1.18, to verify the effectiveness of the Water Chemistry program, B.2.1.2, to manage cracking due to stress corrosioncracking in stainless steel nonregenerativeheat exchanger components exposed to treatedborated water >600C (>140OF)in the Closed Cycle Cooling Water System. Crackingdue to cyclic loading does not apply since these components are continuously in service and not subject to cyclic loading. The GALL recommended verificationprogram for temperatureand radioactivity monitoring of the shell side water,and eddy currenttesting of tubes for managing cyclic loading is therefore not applicable. The Water Chemistry and One-Time Inspection programsare describedin Appendix B.

January 12, 2009 Page 15 of 23 TMI-09-006 Enclosure - A RAI AMR-Generic-3 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 RAls 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.

Exelon Response RAI 3.3.1.21-1 and RAI 3.3.2.2-3: Loss of Material due to fouling is not predicted because macroorganisms (e.g., barnacles, mussels, clams, algae, fungae, etc.) are not expected to be present in lubricating oil due to the relatively low volume of water contamination assumed present in lubricating oil systems. Small quantities of corrosion products are possible that could result from general corrosion where the water collects, but significant fouling deposits are not considered to be credible in this environment, nor are other sources of foreign material.

Even if a fouling deposit were present, and loss of material resulted, this could be considered to be loss of material due to crevice corrosion due to the formation of a crevice by the deposit. Crevice corrosion is identified as an applicable aging mechanism in each case and is managed by the Lubricating Oil Analysis Aging Management Program (AMP) (B.2.1.23) and the One-Time Inspection AMP (B.2.1.18), which are the same programs identified in NUREG-1801 for these line items.

RAIs 3.3.1.32-1 and 3.3.2.2-1: The loss of material due to pitting and crevice corrosion was not predicted for copper alloys with less than 15 percent zinc content in the fuel oil environment due to the relatively low susceptibility of these alloys to these aging mechanisms, consistent with EPRI Report 1010639, "Non-Class 1 Mechanical Implementation Guideline and Mechanical Tools",

Revision 4. However, TMI-1 conservatively predicted loss of material due to pitting and crevice

January 12, 2009 Page 16 of 23 TMI-09-006 Enclosure - A corrosion of these alloys in the lubricating oil environment. Therefore, in order to have a consistent approach for copper alloys in these two similar environments, and for consistency with NUREG-1801, TMI-1 elects to revise the affected Aging Management Reviews to add loss of material due to pitting and crevice corrosion for components made from copper alloys with less than 15 percent zinc in the fuel oil environment. The Fuel Oil Program and One-Time Inspection Program that are currently specified remain applicable, and will manage the loss of material due to pitting and crevice corrosion, in addition to managing the loss of material due to microbiologically influenced corrosion (MIC). The "I"Standard Note associated with the affected aging management review line item becomes a "B" Standard Note and the associated plant specific note is deleted.

The following aging management review component line items in the 3.3.2-y LRA Aging Management Review Results Tables are affected by the addition of loss of material due to pitting and crevice corrosion for components made from copper alloy with less than 15 percent zinc in a fuel oil environment:

1. Table 3.3.2-2 Auxiliary Steam System, Piping and fittings, page 3.3-113. Also, Plant Specific Note 3 is deleted on page 3.3-121.
2. Table 3.3.2-9 Emergency Diesel Generators and Auxiliary Systems, Piping and fittings, page 3.3-191, and Valve Body, page 3.3-199. Also, Plant Specific Note 9 is deleted on page 3.3-202.
3. Table 3.3.2-12 Fuel Oil System, Piping and fittings, page 3.3-239, and Valve Body, page 3.3-241. Also, Plant Specific Note 1 is deleted on page 3.3-243.
4. Table 3.3.2-24 Station Blackout and UPS Diesel Generator Systems, Piping and fittings, page 3.3-345. Also, Plant Specific Note 5 is deleted on page 3.3-353.

In addition, the discussion column for LRA Table 3.3.1, Item 3.3.1-32 and the Further Evaluation subsection 3.3.2.2.12.1 are affected by the addition of loss of material due to pitting and crevice corrosion for copper alloys with less than 15 percent zinc piping, piping components, and piping elements exposed to fuel oil.

LRA Table 3.3.1 Item 3.3.1-32 discussion column changes as follows:

Not cnciGstont with NUREG 1801. Consistent with NUREG-1801 with exceptions. The One-Time Inspection program, B.2.1.18, will be used to verify the effectiveness of the Fuel Oil Chemistry program, B.2.1.16, to manage loss of material due to pitting, crevice, and microbiologically influenced corrosion of the stainless steel and copper alloy with g~eateF than 15 Percent zinGc piping, piping components, and piping elements exposed to fuel oil.

Exceptions apply to the NUREG-1801 recommendations for Fuel Oil Chemistry and One-Time Inspection program implementation.

The One Time .n.pectionprogram, 3.2. 1.18, will be used to"crIfy the effectiveness of the Fuel 0.* Gehmitrly prFr*am, 13.2.1.16, to mnahge los of material duem* te iGrbiqo*g**ally ainfluoncod croso of the copper alloy With loss than 16 percent Aicppnppn comnponents, and piping elements exposed to fuel oil. The los6 of mnate-riasuet ptinn

January 12, 2009 Page 17 of 23 TMI-09-006 Enclosure - A ceIc corrosion ISno~t prodicted for this component, matorial, and envieroment See subsection 3.3.2.2.12.1.

Further Evaluation subsection 3.3.2.2.12.1 changes as follows:

TMI-1 will implement a One-Time Inspection program, B.2.11.18, to verify the effectiveness of the Fuel Oil Chemistry program, B.2.1.16, to manage the loss of material due to pitting, crevice, and microbiologically influenced corrosion of the stainless steel and copper alloy with greator than 15 percont z*in piping, piping components, and piping elements exposed to fuel oil in the Auxiliary Steam System, Emergency Diesel Generators and Auxiliary Systems, and Fuel Oil System, and Station Blackout and UPS Diesels and Auxiliary Systems. The Fuel Oil Chemistry program consists of surveillance and maintenance procedures to mitigate corrosion and measures to verify the effectiveness of an aging management program (AMP) and confirm the insignificance of an aging effect. Fuel oil quality is maintained by monitoring and controlling fuel oil contamination in accordance with the plant's technical specifications and the guidelines of the American Society for Testing Materials (ASTM) Standards D 1796, D 2276, D 2709, D6217, and D 4057. Exposure to fuel oil contaminants, such as water and microbiological organisms, is minimized by periodic draining or cleaning of tanks and by verifying the quality of new oil before its introduction into the storage tanks. The Fuel Oil Chemistry and One-Time Inspection programs are described in Appendix B.

TIVI 1 will implemont tho Fuel Oil ChomisEtry program, 13.2.1 .16, and Ono Tome InSPection program, B.2. 1.18, to manago the loss of mnatcrial dlue to Microbiologically inRfluend corson of the copper alloy with less than 15 percent zinc piping, piping componentS, and piping elmeRnts cxpeoed to fuel o1 in the Auxilia;,' Steam Sytem, Em-4rgenc Diosl G6enoators and Auxiliary Systems, Fuel Oil System, and Statin Bacot n UPS Diesols and Auxiliary Systems. The lo6s Of maeilduo to pitting and GreVico cOrro incpper alloy with less than 15 perent zinc e d to fuel o 6 not p.edictod. Th Fuel Oi Chemistry programA consists of s1_r.WPi11.anceP and mnaintenance proceduroS to mitigate corro.io and m,.asures to v..ify the effectiVon6e. of an aging anag%, me*t prF9ram (AMP) ana GOnRFiRm the inGignRic1ance of an aging effeai r-uei eai quaiy is mairiaieuc UY monitoIrng and the guidolines o-f thoAeria Socioty for Testing Matorials (ASTMV) Standards D 1796-D 2276, D 2709, D6217, and 0 4057. E~xposure to fuel oil contaminantS, such as woatoer andd microbiological organims is minmized by periodic draining Or cleaning of tanks and by oilefore itsintro)duction into the storage tanks. The Fuel Oil verfying the quality of.- new' Chomistry and One Time Inspection programs arc described in Appendix 9.

RAI 3.3.1-48-1: Galvanic corrosion occurs when two dissimilar materials are simultaneously in contact with each other and with an electrolyte, such as raw water. The electrochemical potential difference between two dissimilar materials is the driving force (voltage) that causes electron flow between the two materials that results in dissolution of the material with the lower electrochemical potential. Without this electrochemical potential difference, galvanic corrosion does not occur because there is no driving force to cause electron flow. Therefore, for RAI 3.3.1-48-1, galvanic

January 12, 2009 Page 18 of 23 TMI-09-006 Enclosure - A corrosion is not predicted because there is no potential difference between two dissimilar materials that would provide the necessary driving force to cause galvanic corrosion.

January 12, 2009 Page 19 of 23 TMI-09-006 Enclosure - A 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.

Exelon Response Risk informed ISI (RISI) selects inspection locations on a system by system basis so that each system with "High" risk category elements will have approximately 25% of the system's "High" risk elements selected for inspection and 10% of the elements in systems having "Medium" risk category welds selected. Examinations performed that reveal flaws or relevant conditions exceeding the applicable standards shall be extended to include additional examinations. The additional examinations shall include piping structural elements with the same postulated failure mode and the same or higher failure potential.

The license renewal Reactor Coolant System (RCS) includes portions of the small bore High Pressure Injection/Makeup Purification system. Both the RCS and the High Pressure Injection/Makeup Purification system contain "High" risk category welds. Volumetric examination has been performed with acceptable results on 2-1/2" butt welds in the high pressure injection/makeup lines (one weld during Fall 2005, eight welds during Fall 2007) and on the pressurizer spray line (one 2-1/2" weld during the Fall of 2007). Volumetric and penetrant examination has been performed with acceptable results on 2" butt welds on the RCS cold leg drain (two welds (volumetric) during Fall 2001, three welds (penetrant) during Fall 2003). VT-2 examination has been performed with acceptable results on the 1-1/2" auxiliary spray welds (three welds during Fall 2005, Fall 2007), 1-1/2" seal water injection to the Reactor Coolant Pumps (multiple welds, Fall 2005, Fall 2007). The Core Flood System does not contain any "High" risk welds, the system only contains "Medium" and "Low" risk welds. The TMI-1 RISI program has selected two medium risk Core Flood System welds that are both in large bore piping. Currently, no small bore welds are scheduled for inspection in the Core Flood System.

In addition, bare metal visual and volumetric exams are performed on Alloy 600 welds in accordance with the Alloy 600 program on the high pressure injection/makeup line piping safe end to cold leg nozzle welds.

January 12, 2009 Page 20 of 23 TMI-09-006 Enclosure - A In the Fall of 1995, a fatigue crack was identified in the 2" cold leg drain line off the B Cold Leg Reactor Coolant Piping. The fatigue crack was located in the 2" stainless steel weld connecting the 1-1/2" x 2" reducing elbow to the horizontal 2" drain line pipe. This weld and the drain line piping was replaced in 1995. An analysis was performed and the solution to eliminating the fatigue issue was to insulate the drain line and modify the supports. This line and the A and D cold leg drain lines were insulated and the supports were modified. Thermal fatigue is not an issue for the C cold leg drain line since this line includes a connection to the letdown line and has continuous flow. This fatigue crack is discussed in the LRA Tables for the Reactor Vessel, Internals, and Reactor Coolant System and the Engineered Safety Features (see LRA pages 3.1-36, 3.1-84, 3.2-40, 3.2-50 and 3.2-66).

Currently the replacement weld in the B drain line and the corresponding welds in the A and D drain lines are part of the RISI Augmented Inspection program in accordance with the requirements of MRP-146, Materials Reliability Program Management of Thermal Fatigue in Normally Stagnant Non-Isolable Reactor Coolant System Branch Lines. The B replacement weld has since been examined during the Fall of 2001 (volumetric) and the Fall of 2003 (penetrant) with acceptable results. It is scheduled for reinspection (volumetric and bare metal visual) during the Fall of 2009.

The corresponding weld on the D drain line was inspected during the Fall of 2003 (penetrant) with acceptable results. The welds on the A and D drain lines are scheduled for inspection during the Fall of 2009 (volumetric and bare metal visual).

January 12, 2009 Page 21 of 23 TMI-09-006 Enclosure - A 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 Xl 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.

Exelon Response 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.

The vessel closure head flange leak detection line is a 1" diameter blank flanged line. In accordance with ASME Section Xl, IWB-1220 and the TMI-1 Inservice Inspection (ISI) program, piping of NPS 1," and smaller is exempt from volumetric and surface examination requirements.

The line is a blank flanged line that does not contain reactor coolant and is not pressurized

January 12, 2009 Page 22 of 23 TMI-09-006 Enclosure - A during normal operation or during hydrotest. This line does not have instrumentation for indication of flow, temperature or pressure. Currently, there are no inspections performed on this line since it is not pressurized for a VT-2 inspection. This line would only see pressure if there was a leak at the inner o-ring or ifthe annulus between the o-rings was pressurized, which is not a normal configuration. Because this line is normally drained, it is not subject to stress corrosion cracking. The internal environment listed in the LRA is conservative. The internal environment is normally air with no aging effects. In addition, if the inner reactor vessel closure flange o-ring fails, and RCS fluid filled this line, the reduction of RCS fluid is well within the makeup capacity of the RCS.

A bare metal visual examination is performed on the bottom-mounted instrument guide tube nozzles in accordance with 10 CFR 50.55a. There has been no indication of bottom mounted instrumentation nozzle leakage, no lower RPV boric acid leakage, and no RPV base metal wastage observed. In addition, VT-2 examinations are performed every outage on the 1/2" instrument guide tubes external to the vessel.

If indications of cracking or leakage are found in these components, an Issue Report (IR) is initiated to document the concern in accordance with the 10 CFR Part 50, Appendix B Corrective Action Program. In addition, corrective actions required by the TMI-1 ISI program and ASME Section Xl are completed.

January 12, 2009 Page 23 of 23 TMI-09-006 Enclosure - A 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.

Exelon Response For the Diesel Generator Fuel Storage 30,000 Gallon Tank, a determination of average tank metal thickness between 75% and 85% of original metal thickness will be evaluated to determine if the loss of material occurred on the external surface of the tank. This can be determined due to the performance of the visual inspection of the tank internal surface in conjunction with the volumetric examination of the tank wall. Should the loss of material be attributable to corrosion on the tank external surface, a cathodic protection system will be installed to mitigate corrosion on the external surface of the tank.

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