ML102560488

Electronic Transmission, Draft Request for Additional Information Regarding Relief Request l3R-13, Pressure Testing of Primary Containment Instrument Gas Piping

ML102560488
Person / Time
Site:	Limerick
Issue date:	09/14/2010
From:	Peter Bamford Plant Licensing Branch 1
To:	Chernoff H Plant Licensing Branch 1
Bamford, Peter J., NRR/DORL 415-2833
References
TAC ME3141, TAC ME3142
Download: ML102560488 (3)

Text

September 14, 2010 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, UNITS 1 AND 2 - ELECTRONIC TRANSMISSION, DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING RELIEF REQUEST I3R-13, PRESSURE TESTING OF PRIMARY CONTAINMENT INSTRUMENT GAS PIPING (TAC NOS.

ME3141 AND ME3142)

The attached draft request for additional information (RAI) was transmitted by electronic transmission on September 13, 2010, 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 (if needed) with Exelon in order to clarify the licensees submittal. The draft RAI is related to Exelons submittal dated January 22, 2010, regarding a relief request submitted for Limerick Generating Station, Units 1 and 2. The request proposes an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, concerning a system leakage test with a VT-2 visual examination for the Primary Containment Instrument Gas (PCIG) piping. The draft question was sent to ensure that it was understandable, the regulatory basis was clear, and to determine if the information was previously docketed. Additionally, review of the draft RAI would allow Exelon to evaluate 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

September 14, 2010 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, UNITS 1 AND 2 - ELECTRONIC TRANSMISSION, DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING RELIEF REQUEST I3R-13, PRESSURE TESTING OF PRIMARY CONTAINMENT INSTRUMENT GAS PIPING (TAC NOS.

ME3141 AND ME3142)

The attached draft request for additional information (RAI) was transmitted by electronic transmission on September 13, 2010, 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 (if needed) with Exelon in order to clarify the licensees submittal. The draft RAI is related to Exelons submittal dated January 22, 2010, regarding a relief request submitted for Limerick Generating Station, Units 1 and 2. The request proposes an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, concerning a system leakage test with a VT-2 visual examination for the Primary Containment Instrument Gas (PCIG) piping. The draft question was sent to ensure that it was understandable, the regulatory basis was clear, and to determine if the information was previously docketed. Additionally, review of the draft RAI would allow Exelon to evaluate 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 RidsNrrPMLimerick LPL1-2 R/F Accession No.: ML102560488 OFFICE LPL1-2/PM NAME PBamford DATE 9/14/10 OFFICIAL RECORD COPY

REQUEST FOR ADDITIONAL INFORMATION LIMERICK GENERATING STATION, UNITS 1 AND 2 RELIEF REQUEST I3R-13 PRESSURE TESTING OF PRIMARY CONTAINMENT INSTRUMENT GAS PIPING DOCKET NOS. 50-352 AND 50-353 By letter dated January 22, 2010 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML100261546), supplemented by letter dated July 27, 2010 (ADAMS Accession No. ML102090135), Exelon Generation Company, LLC, submitted a relief request for Limerick Generating Station (LGS), Units 1 and 2. The request proposes an alternative to the requirements of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI, Rules for Inservice Inspection of Nuclear Power Plant Components, Table IWD-2500-1, as referenced by paragraph IWD-5210, concerning a system leakage test with a VT-2 visual examination. The proposed alternative would apply to the Primary Containment Instrument Gas (PCIG) piping, as specified in the submittal. The Nuclear Regulatory Commission staff has been reviewing the submittal and has determined that additional information is needed to complete its review.

1. In the attachment to your letter dated January 22, 2010, Section 5.0, you stated that the proposed PCIG pressure decay test will provide the same level of quality and safety as the VT-2 pressure testing required by the ASME Code. In your letter dated July 27, 2010 you provided the test pressure and acceptance criteria for the proposed pressure decay test. Please identify the technical basis for how the acceptance criteria for the proposed test provides the same level of quality and safety as the ASME Code required test, as you have asserted in your application. For example, you could identify what code or standard was used in developing the test criteria and/or you could demonstrate how, considering the volume of piping involved, the proposed test identifies leakage at a level consistent with what would be identified in the ASME Code required test.

When developing your response, consider that in order for the NRC to approve your request, it must make a determination that reasonable assurance of structural integrity or leak tightness of the subject components has been demonstrated.

Enclosure