ML070170158
| ML070170158 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 05/17/2007 |
| From: | Peter Bamford NRC/NRR/ADRO/DORL/LPLI-2 |
| To: | Crane C Exelon Generation Co |
| Bamford, Peter J., NRR/DORL 415-2833 | |
| References | |
| GL-03-001, TAC MB9818, TAC MB9819 | |
| Download: ML070170158 (5) | |
Text
May 17, 2007 Mr. Christopher M. Crane President and Chief Nuclear Officer Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348
SUBJECT:
NRC CLOSURE OF LIMERICK GENERATING STATION, UNITS 1 AND 2 -
RESPONSES TO GENERIC LETTER 2003-01, CONTROL ROOM HABITABILITY (TAC NOS. MB9818 AND MB9819)
Dear Mr. Crane:
The Nuclear Regulatory Commission (NRC) has reviewed the documentation you have submitted for Limerick Generating Station (LGS), Units 1 and 2 regarding Generic Letter (GL) 2003-01, Control Room Habitability and has concluded that you have provided an adequate response. A summary of the documents that comprise your response for LGS is provided in.
GL 2003-01 requested that you confirm that your control rooms meet the design bases (e.g.,
General Design Criterion (GDC) 1, 3, 4, 5, and 19, draft GDC, or principal design criteria), with special attention to: (1) determination of the most limiting unfiltered and/or filtered inleakage into the control room and comparison to values used in the licensees design bases for meeting control room operator dose limits from accidents (GL 2003-01, Item 1a); (2) determination that the most limiting unfiltered inleakage is incorporated into your hazardous chemical assessments (GL 2003-01, Item 1b); and (3) determination that reactor control capability is maintained in the control room or at the alternate shutdown location in the event of smoke (GL 2003-01, Item 1b). GL 2003-01 further requested information on any compensatory measures in use to demonstrate control room habitability (CRH), and plans to retire them (GL 2003-01, Item 2).
By letter dated December 10, 2004, you reported the results of American Society for Testing and Materials E741, Standard Test Method for Determining Air Change in a Single Zone by Means of a Tracer Gas Dilution tracer gas tests for the LGS control room, which is pressurized for accident mitigation.
The maximum tested value for unfiltered inleakage into the control room envelope (CRE) was 77 actual cubic feet per minute (acfm) with the control room emergency fresh air supply system in radiation/pressurization mode. This value was above the value of 50 standard cubic feet per minute (scfm) assumed in the design basis radiological analyses for CRH at the time the test was conducted. On August 23, 2006, Amendment numbers 185 and 146 were issued to LGS, Units 1 and 2, respectively (ADAMS Accession No. ML062210214), revising the LGS technical specifications (TSs) to support application of an alternative source term and use of a new assumed value of 215 cubic feet per minute (cfm) unfiltered inleakage in the radiological analysis for CRH which is more than the maximum tested value for unfiltered inleakage stated above.
Mr. Crane You also determined that the maximum tested value for unfiltered inleakage into the CRE was 75 acfm in chlorine/toxic gas isolation mode (pressure neutral mode), which is less than the value of 525 scfm assumed in the design basis toxic chemical analyses for CRH. You also provided information that indicated reactor control capability is maintained from either the control room or the alternate shutdown panel in the event of smoke.
GL 2003-01 further requested that you assess your TSs to determine if they verify the integrity of the CRE, including ongoing verification of the inleakage assumed in the design basis analysis for CRH in light of the demonstrated inadequacy of only a delta () P measurement to provide such verification (GL 2003-01, Item 1c). You stated that you currently have a TS for P testing. By letter dated July 11, 2005, you withdrew your previous license amendment request (LAR) for administrative controls and indicated you would evaluate the submittal with respect to the elements contained in TS Task Force Traveler No. 448 (TSTF-448), and resubmit a proposed LAR based on that evaluation. As permitted by GL 2003-01, you provided a schedule for revising the surveillance requirement in the TSs to reference an acceptable surveillance methodology. Your proposed fleet based LAR, which includes LGS, Units 1 and 2, dated April 12, 2007, was submitted within 90 days of NRC approval of TSTF-448 and is currently being evaluated.
The information you provided also supported the fact that there are no compensatory measures in place to demonstrate CRH. Additionally, the information provided supported the conclusion that the facility design, as documented in the LGS Updated Final Safety Analysis Report is consistent with the GDC regarding CRH.
Your action taken to submit a proposed LAR based on the approved version of TSTF-448 is acceptable for purposes of closing out the responses to GL 2003-01, for LGS, Units 1 and 2.
The NRC staff will interact with you as necessary during the amendment process.
If you have any questions regarding this correspondence, please contact me at (301) 415-2833, or pjb1@nrc.gov.
Sincerely,
/ra/
Peter Bamford, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353
Enclosures:
As stated cc: See next page
You also determined that the maximum tested value for unfiltered inleakage into the CRE was 75 acfm in chlorine/toxic gas isolation mode (pressure neutral mode), which is less than the value of 525 scfm assumed in the design basis toxic chemical analyses for CRH. You also provided information that indicated reactor control capability is maintained from either the control room or the alternate shutdown panel in the event of smoke.
GL 2003-01 further requested that you assess your TSs to determine if they verify the integrity of the CRE, including ongoing verification of the inleakage assumed in the design basis analysis for CRH in light of the demonstrated inadequacy of only a delta () P measurement to provide such verification (GL 2003-01, Item 1c). You stated that you currently have a TS for P testing. By letter dated July 11, 2005, you withdrew your previous license amendment request (LAR) for administrative controls and indicated you would evaluate the submittal with respect to the elements contained in TS Task Force Traveler No. 448 (TSTF-448), and resubmit a proposed LAR based on that evaluation. As permitted by GL 2003-01, you provided a schedule for revising the surveillance requirement in the TSs to reference an acceptable surveillance methodology. Your proposed fleet based LAR, which includes LGS, Units 1 and 2, dated April 12, 2007, was submitted within 90 days of NRC approval of TSTF-448 and is currently being evaluated.
The information you provided also supported the fact that there are no compensatory measures in place to demonstrate CRH. Additionally, the information provided supported the conclusion that the facility design, as documented in the LGS Updated Final Safety Analysis Report is consistent with the GDC regarding CRH.
Your action taken to submit a proposed LAR based on the approved version of TSTF-448 is acceptable for purposes of closing out the responses to GL 2003-01, for LGS, Units 1 and 2.
The NRC staff will interact with you as necessary during the amendment process.
If you have any questions regarding this correspondence, please contact me at (301) 415-2833, or pjb1@nrc.gov.
Sincerely,
/ra/
Peter Bamford, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353
Enclosures:
As stated cc: See next page DISTRIBUTION:
PUBLIC LPL1-2 R/F RidsNrrDorlLpl1-2 RidsNrrPMPBamford RidsOgcRp JRobinson, NRR RidsAcrsAcnwMailCenter RidsRgn1MailCenter RidsDssScvb RidsDprPgcb RidsNrrLAEWhitt RidsNrrPMREnnis ADAMS Accession Number: ML070170158 OFFICE LPL1-2/PM LPL1-2/PM LPL3-2/LA SCVB/BC PGCB/BC LPL1-2/BC NAME PBamford REnnis EWhitt RDennig CJackson HChernoff DATE 5/17/07 5/10/2007 5/17/07 5/10/2007 5/11/2007 5/17/07 OFFICIAL RECORD COPY Summary of LGS GL 2003-01 Responses Submittal Date ADAMS Accession No.
August 11, 2003 ML032310390 December 9, 2003 ML033560302 March 19, 2004 ML040890545 September 30, 2004 ML042740704 November 29, 2004 ML043420211 December 10, 2004 ML043510210 July 11, 2005 ML051920406 April 12, 2007 ML071090282
Limerick Generating Station, Unit Nos. 1 and 2 cc:
Site Vice President Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Plant Manager Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Regulatory Assurance Manager - Limerick Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Senior Vice President - Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Operations, Mid-Atlantic Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Vice President Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director Licensing and Regulatory Affairs Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Manager Licensing Limerick Generating Station Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Assistant General Counsel Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348 Correspondence Control Desk Exelon Generation Company, LLC P.O. Box 160 Kennett Square, PA 19348 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector U.S. Nuclear Regulatory Commission Limerick Generating Station P.O. Box 596 Pottstown, PA 19464 Library U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Director, Bureau of Radiation Protection Pennsylvania Dept. of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Chairman Board of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803