ML12074A037

Letter Request for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555, ME6556) Buried Piping and FP Follow Up

ML12074A037
Person / Time
Site:	Limerick
Issue date:	03/22/2012
From:	Robert Kuntz License Renewal Projects Branch 1
To:	Gallagher M Exelon Generation Co
Kuntz R
References
TAC ME6555, TAC ME6556
Download: ML12074A037 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 March 22, 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, to renew the operating licenses for Limerick Generating Station, Units 1 and 2, 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 (RAls) were discussed with Christopher Wilson, and a mutually agreeable date for the respol1$e is within 30 days from the date of this letter. If you have any questions, please cortact me by telephone at 301 415,*3733 or bye-mail at Robert.Kuntz@nrc,go'v.

Sincerely.

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/---~*C RObit F. Kuntz Senior Project Manager Projects Branch 1 Division of License Renewal Office of NiJclear 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 RAI B.2.1.17-3.1

Background

The "detection of aging effects" program element of GALL Report AMP XI.M26 states that visual inspections are performed by fire protection qualified personnel of fire barrier penetration seals, walls, ceilings, floors, doors, and other fire barrier materials. LRA Section B.2.1.17 states that the personnel performing inspections are qualified and trained to perform the inspection activities. However, the staff noted that the personnel responsible for performing fire barrier inspections are maintenance qualified personnel; not fire protection qualified personnel. By letter dated January 17, 2012, the staff issued RAI B.2.17-3 requesting that the training and qualifications of the personnel responsible for performing fire barrier inspections be described.

The response to RAI B.2.17 -3, provided by letter dated February 15, 2012, stated that inspections are typically performed by personnel who are qualified by training and demonstration of installation and repair of fire barriers, the purpose of fire barriers, fire barrier types, and materials of construction, and that these typically qualified personnel inspect both new and repaired fire barriers.

Regulatory Guide 1.189, "Fire Protection for Nuclear Power Plants," states that personnel responsible for maintaining and testing fire protection systems should be qualified by training and experience for such work. The LRA does not discuss whether the personnel responsible for performing the inspections have been trained to identify fire barrier deficiencies.

It is not clear to the staff how the program will ensure only personnel who are trained and qualified to identify fire barrier deficiencies are assigned to perform fire barrier inspections given that the personnel are only typically qualified and that the typical qualifications do not include training in the identification of fire barrier deficiencies.

Request

1. Explain the minimum qualifications required for the personnel performing fire barrier inspections, not the typical qualifications.

2. Explain how the program will ensure that only personnel trained and qualified to identify fire barrier deficiencies are aSSigned to perform fire barrier inspections.

RAI B.2.1.29-2.1

Background

During its audit, the staff noted that the Buried and Underground Piping and Tanks program states that adverse conditions detected during inspections will be evaluated and the potential inspection expansion will be determined in accordance with the corrective action program.

ENCLOSURE

-2 The staff issued RAI B.2.1.29-2 requesting that the applicant state the basis for how the corrective action program inspection expansion size will be consistent with GALL Report AMP XI.M41, or state why the corrective action inspection expansion size will be sufficient to detect degradation prior to it causing an in-scope component to not be capable of meeting its current licensing basis function(s).

The response to RAI B.2.1.29-2 stated that:

The LGS Buried and Underground Piping and Tanks aging management program enhancement is revised to include criteria such that if adverse indications are detected during inspection of inscope buried piping, inspection sample sizes within the affected piping categories are doubled.

If adverse indications are found in the expanded sample, the inspection sample size is again doubled. This doubling of the inspection sample size continues as dictated by the corrective action program. This criterion is in accordance with GALL Report AMP XI.M41, "Buried and Underground Piping and Tanks."

The response states, in part that, "[t]his doubling of the inspection sample size continues as dictated by the corrective action program.>> It is not clear to the staff what is intended by the wording associated with the corrective action program. GALL Report AMP XI.M41, section 4.f.iv states that, U[i]f adverse indications are detected, inspection sample sizes within the affected piping categories are doubled. If adverse indications are found in the expanded sample, the inspection sample size is again doubled. This doubling of the inspection sample size continues as necessary." It is not clear if the corrective action program would require doubling of the inspection sample size until a subsequent set of inspections detected no adverse conditions.

Request State whether the corrective action program would require doubling of the inspection sample size until a subsequent set of inspections detected no adverse conditions, and if not, state the basis for consistency with GALL Report AMP XI.M41, or state the basis for why the expanded scope of inspections have identified the extent of condition and extent of cause of the adverse condition.

Letter to M. Gallagher from R Kuntz dated March 22,2012

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE.

LIMERICK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NOS. IVIE6555, ME6556)

DISTRIBUTION:

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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. to renew the operating licenses for Limerick Generating Station, Units 1 and 2. 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 (RAls) were discussed with Christopher Wilson. and a mutually agreeable date for the response is within 30 days from the date of this letter. If you have any questions, please contact me by telephone at 301-415-3733 or bye-mail at Robert. Kuntz@nrc.gov.

Sincerely.

IRAI Robert F. Kuntz, Senior Project Manager Projects Branch 1 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 DISTRIBUTION:

See next page ADAMS Accession No'.. ML12074a037 IOFFICE LA:RPB1:DLR PM:RPB1 :DLR BC:RPB1:DLR PM: RPB1: DLR NAME YEdmonds RKuntz DMorey RKuntz

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DATE 03/19 112 03/19/12 03/20/12 03/22/12 OFFICIAL RECORD COpy