ML072831319

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Electronic Transmission, Draft Request for Additional Information Regarding Third Interval Inservice Inspection Relief Requests
ML072831319
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 10/11/2007
From: Peter Bamford
NRC/NRR/ADRO/DORL/LPLI-2
To: Chernoff H
NRC/NRR/ADRO/DORL/LPLI-2
Bamford, Peter J., NRR/DORL 415-2833
References
TAC MD5200, TAC MD5201
Download: ML072831319 (2)


Text

October 11, 2007 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:

Peter Bamford, Project Manager /ra/

Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

LIMERICK GENERATING STATION, UNIT NOS 1 AND 2 -

ELECTRONIC TRANSMISSION, DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING THIRD INTERVAL INSERVICE INSPECTION RELIEF REQUESTS (TAC NOS. MD5200 AND MD5201)

The attached draft request for additional information (RAI) was sent by electronic transmission on October 10, 2007, to Mr. Thomas Loomis, at Exelon Generation Company, LLC (Exelon). This draft RAI was transmitted to facilitate the technical review being conducted by the Nuclear Regulatory Commission (NRC) staff and to support a conference call with Exelon in order to clarify certain items in the licensee=s submittal. The draft RAI is related to Exelon=s submittal dated March 6, 2007, regarding relief requests associated with the third inservice inspection interval. The draft questions were sent to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. Additionally, review of the draft RAI would allow Exelon to determine and agree upon a schedule to respond to the RAI. This memorandum and the attachment do not represent an NRC staff position.

Docket Nos. 50-352 and 50-353

Enclosure:

As stated

October 11, 2007 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:

Peter Bamford, Project Manager /ra/

Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

LIMERICK GENERATING STATION, UNIT NOS 1 AND 2 -

ELECTRONIC TRANSMISSION, DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING THIRD INTERVAL INSERVICE INSPECTION RELIEF REQUESTS (TAC NOS. MD5200 AND MD5201)

The attached draft request for additional information (RAI) was sent by electronic transmission on October 10, 2007, to Mr. Thomas Loomis, at Exelon Generation Company, LLC (Exelon). This draft RAI was transmitted to facilitate the technical review being conducted by the Nuclear Regulatory Commission (NRC) staff and to support a conference call with Exelon in order to clarify certain items in the licensee=s submittal. The draft RAI is related to Exelon=s submittal dated March 6, 2007, regarding relief requests associated with the third inservice inspection interval. The draft questions were sent to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. Additionally, review of the draft RAI would allow Exelon to determine and agree upon a schedule to respond to the RAI. This memorandum and the attachment do not represent an NRC staff position.

Docket Nos. 50-352 and 50-353

Enclosure:

As stated DISTRIBUTION:

Public RidsNrrPMPBamford LPL1-2 R/F SDinsmore, NRR DChung, NRR Accession No.: ML072831319

  • via memorandum OFFICE LPL1-2/PM CPTB/BC NAME PBamford MRubin*

DATE 10/11/2007 09/24/2007 OFFICIAL RECORD COPY

ENCLOSURE DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING RELIEF REQUESTS ASSOCIATED WITH THE THIRD INSERVICE INSPECTION INTERVAL LIMERICK GENERATING STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-352 AND 50-353 By letter dated March 6, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML070660108), Exelon Generation Company, LLC, submitted a set of relief requests associated with the Third Inservice Insepection (ISI) interval for Limerick Generating Station (LGS), Units 1 and 2.

The Nuclear Regulatory Commission (NRC) Staff has been reviewing the submittal and has determined that additional information is needed to complete its review.

Relief Request 13R-02:

1. In section 4.0 of relief request 13R-02, you state that, the original risk impact assessment is not a necessary element of the implementing process and is not required to be continually updated.

The risk assessment need not be continually updated. Limerick is, however, requesting to use a risk-informed alternative in accordance with Title 10 of the Code of Federal Regulations 50.55a(a)(3)(i) for the third ISI interval that began on February 1, 2007, and that is based on Electric Power Research Institute (EPRI) TR-112657. A vital element of the staffs conclusion that your proposed alternative satisfies the EPRI guidelines and provides an acceptable level of quality and safety is the evaluation of the change in risk between the ASME inspection program and your proposed program. The staff has previously determined that there is no need to develop an American Society of Mechanical Engineers (ASME) program based on the current ASME code of record that is used only to estimate the change in risk; and then discarded. Therefore, the staff accepts a change in risk estimate between the ASME ISI program in place at your facility prior to the implementation of the first risk-informed inservice inspection (RI-ISI) program, and the RI-ISI program that you are proposing for the third ISI interval. Please provide this information. The estimate should include all changes to the facility and to the Probabilistic Risk Assessment models that might affect the change in risk estimate.

2. Is your proposed RI-ISI program the same program as the prior program authorized by the U.S. Nuclear Regulatory Commission letter dated March 3, 2003 (i.e., are the number and locations of the exams the same or have they changed)? If the number or locations of the exams have changed, please provide a brief summary of the changes.