ML031400855

RAI, Request for Amendment to Technical Specifications Related to TS 5.5.13, Primary Containment Leakage Rate Testing Program.

ML031400855
Person / Time
Site:	LaSalle
Issue date:	05/21/2003
From:	Macon W NRC/NRR/DLPM/LPD3
To:	Skolds J Exelon Generation Co, Exelon Nuclear
Macon W, NRR/DLPM,415-3965
References
TAC MB6574, TAC MB6575
Download: ML031400855 (6)

Text

May 21, 2003 Mr. John L. Skolds, President Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MB6574 AND MB6575)

Dear Mr. Skolds:

By letter dated October 24, 2002, you submitted a request for amendment to Technical Specifications (TS) related to TS 5.5.13, "Primary Containment Leakage Rate Testing Program." The U.S. Nuclear Regulatory Commission (NRC) staff has performed an initial review of your request and finds that it needs additional information to complete its review.

Therefore, it is requested that you respond to the enclosed request for additional information by June 20, 2003, for the NRC staff to expedite its review. The response date was agreed upon by members of your staff on May 16, 2003. The enclosed questions are unchanged from those sent by e-mail to a member of your staff on May 8, 2003.

Sincerely,

/RA/

William A. Macon, Jr., Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-373 and 50-374

Enclosure:

As stated cc w/encl: See next page

May 21, 2003 Mr. John L. Skolds, President Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MB6574 AND MB6575)

Dear Mr. Skolds:

By letter dated October 24, 2002, you submitted a request for amendment to Technical Specifications (TS) related to TS 5.5.13, "Primary Containment Leakage Rate Testing Program." The U.S. Nuclear Regulatory Commission (NRC) staff has performed an initial review of your request and finds that it needs additional information to complete its review.

Therefore, it is requested that you respond to the enclosed request for additional information by June 20, 2003, for the NRC staff to expedite its review. The response date was agreed upon by members of your staff on May 16, 2003. The enclosed questions are unchanged from those sent by e-mail to a member of your staff on May 8, 2003.

Sincerely,

/RA/

William A. Macon, Jr., Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-373 and 50-374

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION:

PUBLIC PD3-2 r/f AMendiola PCoates WMacon SBloom OGC ACRS DHills, RIII ADAMS Accession Number: ML031400855 OFFICE PM:LPD3-2 LA:LPD3-2 SC:LPD3-2 NAME WMacon PCoates AMendiola DATE 05/21/03 05/21/03 05/21/03 OFFICIAL RECORD COPY

LaSalle County Station Units 1 and 2 cc:

Site Vice President - LaSalle Regional Administrator Exelon Generation Company, LLC U.S. NRC, Region III 2601 North 21st Road 801 Warrenville Road Marseilles, IL 61341-9757 Lisle, IL 60532-4351 LaSalle County Station Plant Manager Illinois Department of Nuclear Safety Exelon Generation Company, LLC Office of Nuclear Facility Safety 2601 North 21st Road 1035 Outer Park Drive Marseilles, IL 61341-9757 Springfield, IL 62704 Regulatory Assurance Manager - LaSalle Document Control Desk-Licensing Exelon Generation Company, LLC Exelon Generation Company, LLC 2601 North 21st Road 4300 Winfield Road Marseilles, IL 61341-9757 Warrenville, IL 60555 U.S. Nuclear Regulatory Commission Senior Vice President - Nuclear Services LaSalle Resident Inspectors Office Exelon Generation Company, LLC 2605 North 21st Road 4300 Winfield Road Marseilles, IL 61341-9756 Warrenville, IL 60555 Phillip P. Steptoe, Esquire Vice President Sidley and Austin Mid-West Operations Support One First National Plaza Exelon Generation Company, LLC Chicago, IL 60603 4300 Winfield Road Warrenville, IL 60555 Assistant Attorney General 100 W. Randolph St. Suite 12 Senior Vice President Chicago, IL 60601 Mid-West Regional Operating Group Exelon Generation Company, LLC Chairman 4300 Winfield Road LaSalle County Board Warrenville, IL 60555 707 Etna Road Ottawa, IL 61350 Vice President - Licensing and Regulatory Affairs Attorney General Exelon Generation Company, LLC 500 S. Second Street 4300 Winfield Road Springfield, IL 62701 Warrenville, IL 60555 Chairman Illinois Commerce Commission 527 E. Capitol Avenue, Leland Building Springfield, IL 62706 Robert Cushing, Chief, Public Utilities Division Illinois Attorney Generals Office 100 W. Randolph Street Chicago, IL 60601

LaSalle County Station Units 1 and 2 Director - Licensing Mid-West Regional Operating Group Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Senior Counsel, Nuclear Mid-West Regional Operating Group Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager - Licensing -Clinton and LaSalle Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Mr. John L. Skolds, President Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

REQUEST FOR ADDITIONAL INFORMATION LASALLE COUNTY STATION, UNITS 1 AND 2

Reference:

Letter from K. R. Jury (Exelon Nuclear) to NRC, Request for Amendment to Technical Specification 5.5.13, Primary Containment Leakage Rate Testing Program, October 24, 2002.

1. Section 5.5 of Attachment 2 of the reference provides a summary of the containment inservice inspection. The summary indicates that the first period inspections were performed in accordance with the 1992 Edition and the 1992 Addenda (1992 E & A) of Subsections IWE and IWL of Section XI of the American Society of Mechanical Engineers (ASME) Code and were completed in 2000. The summary also notes that the future inspections will be performed using the 1998 Edition of the ASME Code as approved by NRC relief requests. The staff requests the licensee to clarify (1) if the 1992 E & A will continue to be used until the end of the current inspection interval or whether a new interval will be established for the use of 1998 Edition of the ASME Code, and (2) if the licensee is planning to use the 1998 Edition of the ASME Code, its extent of compliance with the amended rule to 10 CFR 50.55a (67 FR 60520) which incorporates by reference the 1998 Edition through the 2000 Addenda of the Code including any modifications and limitations in 10 CFR 50.55a(b)(2).

2. The staff requests the licensee to provide a summary of significant findings (pits in excess of 10 percent of the nominal liner thickness) in the submerged areas of the wet-well.

3. The staff requests the licensee to provide a summary of findings of the examination of containment concrete performed in accordance with 10 CFR 50.55a and Subsection IWL including the acceptance criteria used for concrete and reinforcing bar degradation.

4. Recognizing the hardship associated with examining seals, gaskets, and pressure retaining bolts during each inspection period, and that the examination will be performed prior to Type B testing as required by Option A of Appendix J, the staff had approved such relief to a number of licensees. However, implementation of Option B of Appendix J allows flexibility in performing Type B testing based on the leak rate performance of the penetrations. Because the performance-based testing allows certain leak rate through the penetrations, minor initial degradation of the associated seals, gaskets and bolting can go undetected, and the 10-year examination interval could be too long for the degraded components. Thus, examination of seals, gaskets, and pressure retaining bolting should be scheduled based on their performance (i.e., plant-specific experience, replacement schedules for resilient seals, etc.) to ensure that, if Type B testing is not performed during the ILRT extension period, the examination schedule will detect degradation of these components. In view of this discussion staff requests the licensee to provide a schedule for examination (testing) of these components; especially for equipment hatches and other penetrations with resilient seals.

ENCLOSURE

5. Based on the write-up in Section 5.6 of Attachment 2 of the submittal, the staff assumes that there are no containment pressure boundary bellows at LaSalle Units 1 and 2. The staff requests the licensee to confirm this assumption.

6. The October 24, 2002, submittal provides risk impacts for a change in test frequency from 1 test in 10 years to 1 test in 15 years. The staff requests the licensee to provide the corresponding risk results (for person-rem, LERF, and CCFP) for a change in test frequency from 3 tests in 10 years to 1 test in 15 years.

7. The staff requests the licensee to provide the technical justification for the assumption in the risk analysis that no long-term station blackout scenarios contribute to LERF. If this justification is based on timing arguments, provide a timeline for a representative scenario that includes consideration of the time at which the various emergency action levels are declared, the decision to evacuate is made, and the evacuation is initiated and completed. If this justification is based on source term magnitude, provide the estimated source terms for a representative scenario, and the definition of LERF used for this determination.

8. The staff requests the licensee to provide an assessment of the impact on risk results

( person-rem, LERF, and CCFP) if long-term station blackouts were not removed from the residual core damage frequency when determining the Category 3a and 3b frequencies.

9. Inspections of some reinforced and steel containments (e.g., North Anna, Brunswick, D. C. Cook, and Oyster Creek) have indicated degradation from the uninspectable (embedded) side of the steel shell and liner of primary containments. The staff requests the licensee to describe the uninspectable areas of the LaSalle containments, and the programs used to monitor their condition. Provide a quantitative assessment of the impact on LERF due to age-related degradation in these areas, in support of the requested ILRT interval extension from 10 to 15 years.