ML102090135

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Response to Request for Additional Information - Relief Request I3R-13 Associated with Pressure Testing of the Primary Containment Instrument Gas (PCIG) Piping
ML102090135
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 07/27/2010
From: David Helker
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME3141, TAC ME3142
Download: ML102090135 (3)


Text

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I iii (an Way Nuciear Kennctt Squarn, PA lq48 10 CFR 50.55a July 27, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

Response to Request for Additional Information Relief Request l3R-1 3 Associated with Pressure Testing of the Primary Containment Instrument Gas (PCIG) Piping

References:

1)

Letter from P. B. Cowan (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, Relief Request 13R-13 Associated with Pressure Testing of the Primary Containment Instrument Gas (PCIG)

Piping, dated January 22, 2010 2)

Letter from P. Bamford (U.S. Nuclear Regulatory Commission) to M. J.

Pacilio (Exelon Nuclear), Limerick Generating Station, Units 1 and 2

Request for Additional Information Regarding Relief Request 13R-13, Pressure Testing of Primary Containment Instrument Gas Piping (TAC NOS. ME3141 and ME3142), dated July 14, 2010 In the Reference 1 letter, Exelon Generation Company, LLC (Exelon) submitted a relief request associated with the third 10-year interval Inservice Inspection (ISI) Program for Limerick Generating Station (LGS), Units 1 and 2. Specifically, this relief request concerns pressure testing of the Primary Containment Instrument Gas (PCIG) piping.

In the Reference 2 letter, the U.S. Nuclear Regulatory Commission requested additional information. Attached is our response to this request.

Should you have any questions concerning this letter, please contact Tom Loomis at (610) 765-5510.

Respectfully, David P. Helker Manager Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Response to Request for Additional Information

- Relief Request 13R-13 cc:

USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, LGS USNRC Project Manager, LGS R. R. Janati, PA Bureau of Radiation Protection www.exeloncorp.com Exelon Nuclear 10 CFR 50.55a July 27, 2010 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

Response to Request for Additional Information - Relief Request 13R-13 Associated with Pressure Testing of the Primary Containment Instrument Gas (PCIG) Piping

References:

1)

Letter from P. B. Cowan (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Relief Request 13R-13 Associated with Pressure Testing of the Primary Containment Instrument Gas (PCIG)

Piping, II dated January 22, 2010 2)

Letter from P. Bamford (U.S. Nuclear Regulatory Commission) to M. J.

Pacilio (Exelon Nuclear), "Limerick Generating Station, Units 1 and 2 -

Request for Additional Information Regarding Relief Request 13R-13, Pressure Testing of Primary Containment Instrument Gas Piping (TAC NOS. ME3141 and ME3142)," dated July 14,2010 In the Reference 1 letter, Exelon Generation Company, LLC (Exelon) submitted a relief request associated with the third 10-year intervallnservice Inspection (lSI) Program for Limerick Generating Station (LGS), Units 1 and 2. Specifically, this relief request concerns pressure testing of the Primary Containment Instrument Gas (PCIG) piping. In the Reference 2 letter, the U.S. Nuclear Regulatory Commission requested additional information. Attached is our response to this request.

Should you have any questions concerning this letter, please contact Tom Loomis at (610) 765-5510.

Respectfully, David P. Helker Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Response to Request for Additional Information - Relief Request 13R-13 cc:

USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, LGS USNRC Project Manager, LGS R. R. Janati, PA Bureau of Radiation Protection

Attachment Response to Request for Additional Information Relief Request 13R-1 3 Attachment Response to Request for Additional Information Relief Request 13R-13

Response to Request for Additional Information Attachment Relief Request 13R-13 Page 1 Question:

1.

For the proposed alternative pressure decay test, what would be an acceptable rate of pressure loss above which the licensee would initiate leak detection and perform necessary corrective action to repair/replace any leakage in the piping?

2.

What is the operating pressure for the PCIG piping to which the piping is required to be pressurized during system leakage test?

Response

The pressure decay test is performed by isolating and pressurizing the associated piping to the nominal operating pressure (90 110 psig). The decay in pressure is then monitored through pressure monitoring instrumentation.

If the acceptable pressure decay criteria of 10 psig or less in 5 minutes were not met, troubleshooting would be performed to locate the leak and correct as required.

Response to Request for Additional Information Relief Request 13R-13 Question:

Attachment Page 1 1.

For the proposed alternative pressure decay test, what would be an acceptable rate of pressure loss above which the licensee would initiate leak detection and perform necessary corrective action to repair/replace any leakage in the piping?

2.

What is the operating pressure for the PCIG piping to which the piping is required to be pressurized during system leakage test?

Response

The pressure decay test is performed by isolating and pressurizing the associated piping to the nominal operating pressure (90 - 110 psig). The decay in pressure is then monitored through pressure monitoring instrumentation. If the acceptable pressure decay criteria of 10 psig or less in 5 minutes were not met, troubleshooting would be performed to locate the leak and correct as required.