ML12089A377

Request for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6556 and ME6555) Fluence and FP Followup RAIs

ML12089A377
Person / Time
Site:	Limerick
Issue date:	04/13/2012
From:	Robert Kuntz License Renewal Projects Branch 1
To:	Gallagher M Exelon Generation Co
Kuntz R
References
TAC ME6555, TAC ME6556
Download: ML12089A377 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 April 13, 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 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, yJ. 1";;';:

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RoJert F. -l~~tz, 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

LIMERICK GENERATING STATION LICENSE RENEWAL APPLICATION REQUESTS FOR ADDITIONAL INFORMATION RAJ 2.3.3.9-2.1

Background

The response to RAI 2.3.3.9-2, dated February 16, 2012, stated for passive components in lightning plant protection system (NFPA 78, Lightning Protection Code), that Limerick Generating Station (LGS) does not have a lightning plant protection system. Passive lightning protection components (NFPA 78) are provided for equipment and personnel protection. They are not relied upon to demonstrate compliance with 10 CFR 50.48 and as such do not perform an intended function for license renewal. Therefore, the lightning protection components are not in the scope of license renewal.

Issues The response excluded some passive lightning protection components (NFPA 78). The response stated that the equipment passive lightning protection components have no function that supports 10 CFR 50.48 requirements; therefore, they are not within the scope of license renewal and subject to an AMR.

Request Provide clarification on how the passive lightning protection components are required per the NFPA 78 Code but are not required for compliance with 10 CFR 50.48. If the components are required for compliance with 10 CFR 50.48 then provide information to demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the current licensing basis for the period of extended operation as required by 10 CFR 54.21 (a)(3).

RAJ B.2.1.28-2

Background

The GALL Report recommends that loss of material and degradation of the neutron absorbing material capacity be determined through coupon and/or direct in situ testing.

The response to RAI B.2.1.28-1, provided by letter dated February 28, 2012, stated that the coupons in the Limerick Generating Station (LGS), Unit 2 spent fuel pool had experienced only two cycles of high fluence from freshly discharged fuel. The response also stated that the coupons in the LGS, Unit 1 spent fuel pool had not experienced high fluence from freshly discharged fuel since re-racking.

In order for the coupons to obtain environmental conditions bounding of all Boral spent fuel pool racks, the response to RAI B.2.1.28-1 proposes to resume an accelerated exposure

- 2 configuration for the Boral coupons (Le., surround the coupons by freshly discharged fuel assemblies) at each of the next five refueling cycles, beginning with the refueling outage in 2014 and 2013 for LGS, Units 1 and 2, respectively.

The coupons in the LGS, Units 1 and 2 spent fuel pools have not experienced long exposure to high radiation fluence from freshly discharged fuel, making the exposure time potentially non conservative and/or not bounding of all the LGS, Unit 1 and 2 Boral spent fuel pool racks. The environmental conditions of the coupons are not bounding of all Boral racks and; therefore, may not provide acceptable testing data for monitoring loss of material and degradation of the neutron absorbing material capacity.

Request Provide justification on how resuming a five cycle radiation exposure period will place the coupons in a bounding condition for all Boral spent fuel pool racks for the LGS, Units 1 and 2 for the period of extended operation. If there is not ample justification that the coupons will be bounding of all the Boral panels in the spent fuel pool (SFP), discuss if another method of monitoring will be used, such as in situ testing.

Letter to M. Gallag her from R Kuntz dated April 13, 2012

SUBJECT:

REQUESTS FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE.

LIMERICK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC NOS. ME6555, 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 ofFederal 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, IRAJ 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:

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