TMI-15-102, Clarification of Commitment Regarding Resolution of Generic Letter 2004-02

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Clarification of Commitment Regarding Resolution of Generic Letter 2004-02
ML15254A045
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 09/10/2015
From: Callan E
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-04-002, TMI-15-102
Download: ML15254A045 (2)


Text

A~NExeton Genera~tionm Three Mile Island Unit 1 Route 441 South, P.O. Box 480 Middletown, PA 17057 Telephone 71 7-948-8000 TMI1-15-102 September 10, 2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289

Subject:

Clarification of Commitment Regarding Resolution of Generic Letter 2004-02

References:

1. Letter from R. W. Libra (Exelon Generation Company, LLC) to U.S. NRC, "TMI, Unit 1 Plant-Specific Path and Schedule for Resolution of Generic Letter 2004-02," dated May 16, 2013 In a letter to the NRC dated May 16, 2013,, Three Mile Island Unit 1 provided the plant specific path and schedule for resolution of Generic Letter 2004-02 (Reference 1). Attachment 2 of this letter included the following commitment:

"Replace the Nukon insulation currently installed on the pressurizer with Reflective Metallic Insulation (RMI) for TMI, Unit 1."

This was a one-time action with a committed date of the T1R21 Refueling Outage in the fall of 2015.

The purpose of this letter is to provide the following clarification related to this commitment:

In Section 3.1 of Reference 1, it was stated that "replacing the pressurizer NUKON insulation with RMI will result in removal of an additional 454 ft 3 of NUKON insulation." During the T1R21 refueling outage this fall, TMI will be replacing approximately 80% of the NUKON insulation on the pressurizer. NUKON insulation will not be replaced on the pressurizer upper head or inside the pressurizer structural support. Preliminary debris analyses and strainer test results indicate that the reduction in fibrous debris due to the removal of approximately 80% of the pressurizer NUKON insulation will be adequate with respect to ECCS pump NPSH concerns. This reduction in NUKON insulation will also reduce the quantity of fibrous debris bypassing the strainer. As stated in Section 3.3 of Reference 1, TMI is continuing to participate in the PWROG efforts to determine the in-vessel debris limits.

As of the date of this letter, TMI does not anticipate that any further reductions in the amount of NUKON insulation remaining in the Reactor Building will be necessary.

U.S. Nuclear Regulatory Commission Clarification of Commitment Regarding Resolution of Generic Letter 2004-02 September 10, 2015 Page 2 There are no changes to the other commitments contained in Reference 1.

Should you have any questions concerning this letter, please contact Mike Fitzwater at (717) 948-8228.

Respectfully, Site Vice President, Three Mile Island Unit 1 Exelon Generation Company, LLC cc: USNRC Region I, Regional Administrator USNRC Project Manager, TMI, Unit 1 USNRC Senior Resident Inspector, TMI, Unit 1

Text

A~NExeton Genera~tionm Three Mile Island Unit 1 Route 441 South, P.O. Box 480 Middletown, PA 17057 Telephone 71 7-948-8000 TMI1-15-102 September 10, 2015 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRC Docket No. 50-289

Subject:

Clarification of Commitment Regarding Resolution of Generic Letter 2004-02

References:

1. Letter from R. W. Libra (Exelon Generation Company, LLC) to U.S. NRC, "TMI, Unit 1 Plant-Specific Path and Schedule for Resolution of Generic Letter 2004-02," dated May 16, 2013 In a letter to the NRC dated May 16, 2013,, Three Mile Island Unit 1 provided the plant specific path and schedule for resolution of Generic Letter 2004-02 (Reference 1). Attachment 2 of this letter included the following commitment:

"Replace the Nukon insulation currently installed on the pressurizer with Reflective Metallic Insulation (RMI) for TMI, Unit 1."

This was a one-time action with a committed date of the T1R21 Refueling Outage in the fall of 2015.

The purpose of this letter is to provide the following clarification related to this commitment:

In Section 3.1 of Reference 1, it was stated that "replacing the pressurizer NUKON insulation with RMI will result in removal of an additional 454 ft 3 of NUKON insulation." During the T1R21 refueling outage this fall, TMI will be replacing approximately 80% of the NUKON insulation on the pressurizer. NUKON insulation will not be replaced on the pressurizer upper head or inside the pressurizer structural support. Preliminary debris analyses and strainer test results indicate that the reduction in fibrous debris due to the removal of approximately 80% of the pressurizer NUKON insulation will be adequate with respect to ECCS pump NPSH concerns. This reduction in NUKON insulation will also reduce the quantity of fibrous debris bypassing the strainer. As stated in Section 3.3 of Reference 1, TMI is continuing to participate in the PWROG efforts to determine the in-vessel debris limits.

As of the date of this letter, TMI does not anticipate that any further reductions in the amount of NUKON insulation remaining in the Reactor Building will be necessary.

U.S. Nuclear Regulatory Commission Clarification of Commitment Regarding Resolution of Generic Letter 2004-02 September 10, 2015 Page 2 There are no changes to the other commitments contained in Reference 1.

Should you have any questions concerning this letter, please contact Mike Fitzwater at (717) 948-8228.

Respectfully, Site Vice President, Three Mile Island Unit 1 Exelon Generation Company, LLC cc: USNRC Region I, Regional Administrator USNRC Project Manager, TMI, Unit 1 USNRC Senior Resident Inspector, TMI, Unit 1