ML102570677

Request for Additional Information Regarding Relief Request I3R-13, Pressure Testing of Primary Containment Instrument Gas Piping

ML102570677
Person / Time
Site:	Limerick
Issue date:	09/21/2010
From:	Peter Bamford Plant Licensing Branch 1
To:	Pacilio M Exelon Nuclear
Bamford, Peter J., NRR/DORL 415-2833
References
TAC ME3141, TAC ME3142
Download: ML102570677 (3)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 21, 2010 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

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)

Dear Mr. Pacilio:

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,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 piping.

The Nuclear Regulatory Commission staff has been reviewing the response and has determined that additional information is needed to complete its review. The specific question is found in the enclosed request for additional information (RAI). The question was sent via electronic transmission on September 13, 2010, to Mr. Thomas Loomis, of your staff. The draft question was sent to ensure that the question was understandable, the regulatory basis for the question was clear, and to determine if the information was previously docketed. In a teleconference with Mr. Loomis on September 14, 2010, it was agreed that a response to this RAI would be submitted by October 15, 2010. If a response is not received by that date, the request will be subject to denial, pursuant to Title 10 of the Code of Federal Regulations, Section 2.108, "Denial of application for failure to supply information."

Please contact me at 301-415-2833, if you have any questions.

Sincerel~,? I /J (fkt?~

Peter Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosure:

As stated cc w/encl: Distribution via Listserv

REQUEST FOR ADDITIONAL INFORMATION LIMERICK GENERATING STATION, UNITS 1 AND 2 RELIEF REQUEST 13R-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

September 21, 2010 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 SUB"IECT: 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)

Dear Mr. Pacilio:

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,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 piping.

The Nuclear Regulatory Commission staff has been reviewing the response and has determined that additional information is needed to complete its review. The specific question is found in the enclosed request for additional information (RAI). The question was sent via electronic transmission on September 13, 2010, to Mr. Thomas Loomis, of your staff. The draft question was sent to ensure that the question was understandable, the regulatory basis for the question was clear, and to determine if the information was previously docketed. In a teleconference with Mr. Loomis on September 14, 2010, it was agreed that a response to this RAI would be submitted by October 15, 2010. If a response is not received by that date, the request will be subject to denial, pursuant to Title 10 of the Code of Federal Regulations, Section 2.108, "Denial of application for failure to supply information."

Please contact me at 301-415-2833, if you have any questions.

Sincerely, Peter Bamford, Project Manager Plant Licensing Branch 1-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosure:

As stated cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC RidsOgcRp Resource LPLI-2 R/F RidsAcrsAcnw_MailCTR Resource RidsNrrLAABaxter Resource PPatnaik, NRR RidsRgn1 MailCenter Resource RidsNrrDorlDpr Resource RidsNrrDorlLpl1-2 Resouce RidsNrrPMLimerick Resource ADAMS Accession Number' ML102570677

• via email OFFICE LPLI-2/PM LPLI-2/LA LPL1-2/BC NAME PBamford ABaxter

• HChernoff DATE 9/14/10 9/16/10 9/21/10 OFFICIAL RECORD COpy