ML12018A035

Requests for Addtional Information for the Review of the Limerick Generating Station, Units 1 & 2, License Renewal Application (TAC ME6555 and ME6556)

ML12018A035
Person / Time
Site:	Limerick
Issue date:	02/23/2012
From:	Robert Kuntz License Renewal Projects Branch 1
To:	Gallagher M Exelon Generation Co
Kuntz R
References
TAC ME6555, TAC ME6556
Download: ML12018A035 (12)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 February 23,2012 Mr. Michael P. Gallagher Vice President License Renewal Projects Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE LIMERICK GENERATING STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. ME6555 AND ME6556)

Dear Mr. Gallagher:

By letter dated June 22, 2011, Exelon Generation Company, LLC submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54 (10 CFR Part 54), to renew the operating licenses for Limerick Generating Station, for review by the U.S. Nuclear Regulatory Commission (NRC or the staff). The staff is reviewing the information contained in the license renewal application and has identified, in the enclosure, areas where additional information is needed to complete the review.

These requests for additional information were discussed with Christopher Wilson, and a mutually agreeable date for the response is within 45 days from the date of this letter. If you have any questions, please contact me at 301-415-3733 or bye-mail at Robert.Kuntz@nrc.gov.

Sincerely,

~enior Projects Branch 1 Project Manager Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosure:

Requests for Additional Information cc w/encl: Listserv

LIMERICK GENERATING STATION LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION The scoping criteria are described in Section 2.1 of license renewal application (LRA). LRA Section 2.2, Table 2.2-1, "Scoping Results," provides the results of applying the license renewal scoping criteria to systems, structures, and components (SSCs). The following systems, as described in the Updated Final Safety Analysis Report (UFSAR), could not be located in LRA Table 2.2-1.

UFSAR Section System 1.2.4.3.1.7 Plant Monitoring System (PMS) Plant Monitoring System 7.1.2.1.12 Area Radiation Monitoring Area Radiation Monitoring System System 7.1.2.1.46 Emergency Response Facility Emergency Response Facility Data System Data System

-_.

Chemistry Laboratory Air Supply and Exhaust 9.4.3.2.4 Chemistry Laboratory Expansion Systems Justify the exclusion of the above systems from Table 2.2-1.

RAI2.3.3-1 For the license renewal boundary drawing locations identified in the table below, the staff could not determine the basis for the change in scoping criteria from 10 CFR 54.4 (a)(1) to 10 CFR 54.4 (a){2).

Nonsafety-related/Safety- I License Renewal Boundary Explanation of Issue Related Interface Item

• Drawin Number & Location

~~~--~~----~--~--------------------~

2.3.3.17 Process Radiation Monitoring System

~mm* a ILR--M---2-6--"'s'---~e-'e'-t-4-,-lo-c-a-tio-n--H--6---.-----------------------1 2.3.3.4

(-m Containment Enclosure

_ _.....

Ventilation System

_ _ _ _ _ _ _ _--=-__________- - - - - ______

. At valves 0001A, 0002A, a LR-M-78 Sheet 1, locations 0-5 I 0003A, 0005A and 00018, thru D_-7_a_nd ___ F-:t_hr_u_F-7 _ _ .* 00028, 00038,00058.

LR-M-90 Sheet 1, locations 0- Several %" lines to vent and 1" b

---

~.~

2, 0-4, 0-7, E-3, G-4, I drain lines.

-2 LR-M-90 Sheet 2, Multiple All capped %" vent and drain c

locations lines.

2.3.3.8 Emergency Diesel Generator System LR-M-20 Sheets 7 and 13, At valves 1430A, 1406A, locations C-3, E-3. E-5, D-5 1415A, 1437A, 1413A 1154A, a

and E-8 2430A,2406A,2415A,2437A, 2413A and 2154A.

LR-M-20 Sheets 4 and 10, At valves 1511A. 1510A, b locations C-3 and C-4 1509A, 2511 A, 2510A and 2509A.

LR-M-20 Sheets 5 and 11, valves 1608A, 1604A, c

locations F-3 and E-5 OBA, and 2604A.

2.3.3.19 Radwaste System a ~~d~~1Sheet 1, locati~~~5~~mvalves 1081 and 1082.

2.3.3.21 Reactor Water Cleanup System

• LR-M-44 Sheet 1, Multiple Several (12 locations) 1" a

locations capped lines.

2.3.3.22 Safety Related Service Water System a

• LR-M-51 Sheet 8, location D-5 At valve 214B.

At valve 1141 Band %" GBB-LR-M-51 Sheet 4, locations D-4 b 123 line at valve HV-C

& D-5 1F103B.

c LR-M-13 Sheet 2, location G-5 At valve 2066A.

LR-M-12 Sheet 1, Multiple Multiple 1" flush, drain and d

locations (35 locations) capped lines.

LR-M-11 Sheet 2, Multiple Multiple %" flush, drain and e

locations (16 locations) capped lines.

LR-M-11 Sheet 3, Multiple Multiple %" flush, drain and f

locations (17 locations) capped lines.

LR-M-11 Sheet 4, Multiple Multiple %" and 1" flush. drain g

locations (32 locations)

• and capped lines.

LR-M-11 Sheet 5, Multiple Multiple %" and 1" flush, drain h

I 100;ations {34 locations} and ca~~ed lines.

-3 Water Treatment and Distribution (WTD) System A, 0002A, 0003A, 0005A and 00018, LR-M-78 Sheet 1, locations 0-5 a 00028, 00038, 00058 without thru 0-7 and F-5 thru F-7 classification break at SR-NSR interface.

Several %" lines to vent and 1" lines to Orain without LR-M-90 Sheet 1, Locations 0 b classification break at the 2, 0-4, 0-7, E-3, F-4, G-4 valves where there is a SR I NSR interface.

All capped %" lines to vent and 1 n lines to Orain without LR-M-90 Sheet 2, Several c locations

. classification break at the

• valves where there is a SR NSR interface.

Clarify the scoping classification of the pipe lines identified in the above table as within the scope of license renewal based on the criteria in 10 CFR 54.4(a)(2).

RAJ 2.3.3.8-1 License renewal boundary drawings LR-M-20 Sheets 8 and 14, location F-5, depict ejector casings that are within the scope of license renewal for 10 CFR 54.4(a)(1). However, the ejector casing is not listed in Table 2.3.3-8 as a component type subject to an aging management review (AMR).

Justify the exclusion of the ejector casing component type from LRA Table 2.3.3-8.

RAJ 2.3.3.8-2 License renewal boundary drawings LR-M-20 Sheets 8 and 14, locations 8-4 and 0-4, depict turbo charger casings that are within the scope of license renewal for 10 CFR 54.4(a)(1).

However, the turbo charger casing is not listed in Table 2.3.3-8 as a component type subject to an AMR.

Justify the exclusion of the turbo charger casing as component types from LRA Table 2.3.3-8.

RAJ 2.3.3.8-3 License renewal boundary drawings LR-M-20 Sheets 8 and 14, location F-3, depict exhaust silencer housings that are within the scope of license renewal for 10 CFR 54.4(a)(1). However,

- 4 the exhaust silencer housing is not listed in Table 2.3.3-8 as a component type subject to an AMR.

Justify the exclusion of the exhaust silencer component type from LRA Table 2.3.3-8.

RAI 2.3.3.8-4 License renewal boundary drawings LR-M-20 Sheets 3 and 9, locations 0-3 and 0-7, depict flame arrestor housings that are within the scope of license renewal for 10 CFR 54.4(a)(1).

However, the flame arrestor housing that is not listed in Table 2.3.3-8 as a component type subject to an AMR.

Justify the exclusion of the flame arrestor housing component type from LRA Table 2.3.3-8.

RAI2.3.3.8-5 LRA Section 2.1.1 states that the in-scope portions of mechanical systems and structures are highlighted in color on the license renewal boundary drawings. For the Emergency Diesel Generator System, the applicant includes the diesel engines within the license renewal scoping boundary.

License renewal boundary drawings LR-M-20 Sheets 3 and 9, location F-5, depict diesel engines 1AG501 and 2AG501 as not being within the scope of license renewal. Although the applicant states in Note 7 that the in-scope fuel oil supply system boundary stops at the fuel injectors of the diesel generator due to the fuel injectors being excluded from aging management review, the license renewal boundary drawings appear to contradict the applicant's methodology for highlighting the in-scope components (the diesel engines) as described in LRA Section 2.1.1.

Justify why the diesel engines depicted on license renewal boundary drawings LR-M-20 Sheets 3 and 9 are indicated as not being within the scope of license renewal.

RAI 2.3.3.12-1 License renewal boundary drawings LR-M-10 Sheets 5 and 10, locations H-2 and H-4, depict the 6" JBO-107/207 and 6" JBO-132/232 lines as being within the scope of license renewal based on the criteria in 10 CFR 54.4(a)(2) with continuations to and from license renewal boundary drawings LR-M-10 Sheets 3 and 8. However, the continuations of these lines on license renewal boundary drawings, LR-M-10 Sheets 3 and 8, are depicted as not being within the scope of license renewal.

Clarify the correct scoping classification of these pipe lines.

-5 RAI 2.3.3.13-1 On license renewal boundary drawing, LR-M-64 Sheet 1, location G-8, the continuation of the pipe line depicted within the scope of license renewal could not be found in any other license renewal boundary drawings.

Locate the continuation line for the above location. If the continuation line cannot be shown on license renewal boundary drawings, then provide additional information describing the extent of the scoping boundary and verify whether or not there are additional AMR component types between the continuation and the termination of the scoping boundary. If the scoping classification of a section of the piping changes over the continuation, provide additional information to clarify the change in scoping classification.

RAI 2.3.3.14-1 LRA Section 2.1 describes the applicant's scoping methodology, which specifies how systems or components were determined to be included in scope of license renewal. The staff confirms the inclusion of all components subject to AMR by reviewing the results of the screening of components within the license renewal boundary.

On license renewal boundary drawing LR-M-59 Sheet 1, location C-6, the applicant depicts Note 5, which states "This piping is included in scope out to the seismic anchor credited for structural support of the safety-related piping located as shown. The nonsafety-related piping beyond this anchor location is not in scope." However, the 1" JCD-109 pipe continues in red, designating the piping as being within the scope of license renewal for 10 CFR 54.4(a)(2), from Note 5 to the end of the pipe and including the drawing continuation marker to drawing LR-M-59 Sheet 2, at location F-1. The continuation marker on Sheet 2 also shows the pipe still in scope for 10 CFR 54.4(a)(2) and has another Note 5, the same as Sheet 1, where the transition is actually made from red to black to indicate the 1" JCD-109 pipe continuation changed to not being in scope for license renewal. For LGS, Unit 2, LRA drawing LR-M-59 Sheet 3, location C-6, the 1" JCD-209 pipe has the same Note 5 and there is an immediate transition from red to black, so the remainder of the pipe up to and including the continuation marker is no longer in scope as the Note 5 indicates. There also is no duplicate Note 5 on Sheet 4.

Clarify why the 1" JCD-109 pipe scope does not agree with Note 5 on LRA drawing LR-M-59 Sheet 1. Also clarify why there are differences in scoping between the 1" JCD-1 09 pipeline on Sheets 1 and 2 and the 1" JCD-209 pipeline on Sheets 3 and 4.

RAI 2.3.3.14-2 License renewal boundary drawing LR-M-59 Sheet 3, location H-6, depicts a line not highlighted within the scope of license renewal. However, the line is connected to a continuation marker from drawing LR-M-42 Sheet 3, location A-3, which depicts the continuation marker to be highlighted green and in scope for 10 CFR 54.4(a)(1).

Clarify the scoping classification of the pipe line.

-6 RAI 2.3.3.17-1 License renewal boundary drawings LR-M-26' Sheets 1 and 7, location C-2, and LR-M-26 Sheet 4, location B-7, depict sample chambers in Detail K that are within the scope of license renewal for 10 CFR 54.4(a)(2), but are not listed in Table 2.3.3-17 as a component type subject to an AMR.

Justify the exclusion of the sample chamber component type from LRA Table 2.3.3-17 RAI 2.3.3.17-2 License renewal boundary drawing LR-M-26 Sheet 5, location E-3, depicts filter and detector housings in Detail G that are within the scope of license renewal for 10 CFR 54.4(a)(1), but are not listed in Table 2.3.3-17 as a component type subject to an AMR.

Justify the exclusion of the filter and detector housing component types from LRA Table 2.3.3-17.

RAI 2.3.3.18-1 License renewal boundary drawings LR-M-23 Sheets 4 and 7, location H-4, depict a continuation line from the feedwater to reactor 10 CFR 54.4{a)(2) pipelines respectively to license renewal boundary drawings LR-M-06 Sheets 3 and 6, location G-8, where the pipeline continuations are shown excluded from scope of license renewal.

Clarify the scoping classification of these pipe lines.

RAI 2.3.3.22-1 License renewal boundary drawing LR-M-13 Sheet 2, locations D-2 and E-7,depicts 1'X!"

JBD-419 lines as being within the scope of license renewal based on the criteria in 10 CFR 54.4(a){2), with continuations to license renewal boundary drawing LR-M-23, Sheet 7.

However, the continuations of these lines on license renewal boundary drawing LR-M-23, Sheet 7 are shown as not within the scope of license renewal.

Clarify the scopil1g classification of these pipe lines.

RAI 2.3.3.22-2 License renewal boundary drawing LR-M-13, Sheet 1, locations D-2 and D-4, shows the 1'X!"

JBD-319 lines to be within the scope of license renewal for 10 CFR 54.4{a){2), with continuations to and from the license renewal boundary drawing LR-M-23, Sheet 4. However the continuations of these lines on drawing LR-M-23, Sheet 4 are shown as not within the scope of license renewal.

Clarify the scoping classification of these pipe lines.

- 5 RAI2.3.4-1 For the license renewal boundary drawing locations identified in the table below, the staff could not determine the basis for the change in scoping criteria from 10 CFR 54.4 (a)(1) to 10 CFR 54.4 (a)(2).

Nonsafety-related/Safety- License Renewal Boundary Related Interlace Item Drawing Number & Explanation of I s s u e l location 2.3.4.2 Condensate System LR-M-51 Sheet 1, Multiple a At all test connections.

locations At valves 1F041A, 1F041 8,

• LR-M-52 Sheet 1, Multiple b 10218, 1075A, 10758, 1076A I locations I and 10768.

LR-M-52 Sheet 2, locations %u S80-152 drain out of pumps c I i

F-3 and G-3 1AP256 and 18P256.

i LR-M-52 Sheet 3, locations d At valves 2F041A and 2F0418.

E-7 and F-7 At valves 2004, 2023A, 20238, 20278,2027C,20270,20320, LR-M-52 Sheet 4, Multiple e 2066, 2069,2075A, 20758, locations 2076,2082,2083,2084,2085, I

?086, 2087 and 2088.

2.3.4.6 Main Steam System LR-M-01 Sheet 1, location a At valve 1030.

I C-6 LR-M-01 Sheet 3, location I

b At valve 2030.

A-6 LR-M-41 Sheet 1, location

• c At valves 1038 and 1051.

A-6 At valves 1066A, 1067A, 1068A, LR-M-41 Sheet 2, locations d 1069A, 1070A, 1071A, 1072A, E-4, 0-3, 0-1 and G-8 1073A, 1037, 1040, and 1034E.

LR-M-41 Sheet 4, locations At valves 2038, 2F0828, 2063 e

A-6 & 8-5 thru 0-5 and 2F083A.

LR-M-41 Sheet 5, locations f At valves, 2037, 2070, 2034E.

E-4, 0-3, 0-1 and G-8 At valves 1F053, 1F082, 1F083, 1F085, 1004, 1005, 1020, 1026, LR-M-49 Sheet 1, Multiple g 1042, 1043, 1048A, 10488, I locations

• 10488, 10480, 10498, 10498 10498, 10490, and 1055.

- 6 LR-M-50 Sheet 1, location G-h At valve 1043.

6 LR-M-50 Sheet 2, location H i At valve 2043.

6 At valves 1F013, 1F015, 1F044, 1F056, 1F065, 1F090, 1F091, 1F092, 1030, 1034, 1036, 1037, LR-M-55 Sheet 1, Multiple 1040,1041,1050,1053,1054, j

locations 1056, 1057, 1066, 1067, 1070A, 1070B, 1070C, 10700, 1071A, 1071B, 1071C, and 10710, 1045. I Clarify the scoping classification of the 10 CFR 54.4(a){2) pipe lines identified in the above table.

RAI 2.3.4.3-1 License renewal boundary drawings LR-M-07 Sheets 1 and 3, location H-2, depict air inlets with screens that are within the scope of license renewal for 10 CFR 54.4(a)(2), but are not listed in Table 2.3.4-3 as a component type subject to an AMR.

Justify the exclusion of the air inlet with screen component type from LRA Table 2.3.4-3.

RAI 2.3.4.6-1 On license renewal boundary drawing, LR-M-05 Sheet 1, locations G-3, G-4 and G-6, the continuation of the 1 ~n "Bearing Drain to Oily Waste" pipe from the condenser could not be found on the following license renewal boundary drawings because the drawings were not included in the license renewal boundary drawings package:

• M-19 Sheet 3

• M-19 Sheet 6 Provide the license renewal boundary for the 1 ~I! "Bearing Drain to Oily Waste" pipe for the license renewal boundary drawings described above. If the continuation line cannot be shown on these license renewal boundary drawings, then provide additional information describill9 the extent of the scoping boundary and verify whether or not there are additional AMR component types between the continuation and the termination of the scoping boundary. If the scoping classification of a section of the piping changes over the continuation, provide additional information to clarify the change in scoping classification.

-7 RAI 2.3.4.7-1 Drawing LR-M-07 Sheet 2, location F-6, shows in scope pipeline 1 HBD-359, however the II continuation on this same drawing at location B-4 shows this pipeline as not in scope.

Clarify the scoping boundary of this pipe section.

RAI 2.3.4.7-2 License renewal boundary drawings LR-M-07 Sheets 2 and 4, location E-7, depict drain pipelines 1" HBD-359, and 1" HBD-459 within the scope of license renewal for 10 CFR 54.4(a)(2}. However, license renewal boundary drawings LR-M-06 Sheets 2 and 5, location 0-8, depict the continuation lines as not being within the scope of license renewal.

Clarify the scoping boundaries for the pipe lines.

Letter to M. Gallagher from R. Kuntz dated February 23, 2012

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE LIMERICK GENERATING STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION (TAC NOS. ME6555 AND ME6556)

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PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDlrRerb Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsNrrDlrRapb Resource RidsNrrDlrRpob Resource RidsNrrPMLimerick Resource RidsOgcMailCenter Resource RKuntz DMorey LPerkins MSmith,OGC RConte, RI MModes, RI GDiPaolo, RI NSieller, RI

..'ML12018A035 OFFICE LA:RPB1 :DLR PM:RPB1 :DLR BC: RPB1: DLR PM:RPB1 :DLR NAME Y. Edmonds R. Kuntz D. Morey R. Kuntz DATE 02/06/12 02/09/12 02/09/12 02/23/12