ML12167A276
| ML12167A276 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/14/2012 |
| From: | - No Known Affiliation |
| To: | Division of License Renewal |
| References | |
| Download: ML12167A276 (13) | |
Text
1 LimerickNPEm Resource From:
Christopher.Wilson2@exeloncorp.com Sent:
Thursday, June 14, 2012 11:36 AM To:
Kuntz, Robert
Subject:
letters transmitted to DCC Attachments:
6.14.12 - LIM - Response to NRC RAI dated 6.5.12 re LGS LRA-a.pdf; 6.14.12 - LIM -
10CFR54.21(b) Annual Amendment to LRA.PDF Rob These two letters were just sent to DCCadvance copy for your review
- This e-mail and any of its attachments may contain Exelon Corporation proprietary information, which is privileged, confidential, or subject to copyright belonging to the Exelon Corporation family of Companies. This e-mail is intended solely for the use of the individual or entity to which it is addressed. If you are not the intended recipient of this e-mail, you are hereby notified that any dissemination, distribution, copying, or action taken in relation to the contents of and attachments to this e-mail is strictly prohibited and may be unlawful. If you have received this e-mail in error, please notify the sender immediately and permanently delete the original and any copy of this e-mail and any printout. Thank You. **************************************************
Hearing Identifier:
Limerick_LR_NonPublic Email Number:
1189 Mail Envelope Properties (9A15F707EB47A04D882D9FEB352EDDF803F46CB3)
Subject:
letters transmitted to DCC Sent Date:
6/14/2012 11:36:29 AM Received Date:
6/14/2012 11:36:44 AM From:
Christopher.Wilson2@exeloncorp.com Created By:
Christopher.Wilson2@exeloncorp.com Recipients:
"Kuntz, Robert" <Robert.Kuntz@nrc.gov>
Tracking Status: None Post Office:
cccmsxch12.energy.power.corp Files Size Date & Time MESSAGE 920 6/14/2012 11:36:44 AM 6.14.12 - LIM - Response to NRC RAI dated 6.5.12 re LGS LRA-a.pdf 370438 6.14.12 - LIM - 10CFR54.21(b) Annual Amendment to LRA.PDF 399729 Options Priority:
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Enclosure Page 1 of 3 Enclosure Response to Requests for Additional Information related to various sections of the LGS License Renewal Application (LRA)
RAI B.2.1.32-2.1
Enclosure Page 2 of 3 RAI B.2.1.32-2.1
=
Background===
The Limerick Generating Station (LGS) license renewal application (LRA) section B.2.1.32 states that the ASME Section XI, Subsection IWF program, with enhancement, will be consistent with GALL Report AMP XI.S3. The response to RAI B.2.1.32-2, provided by letter dated February 28, 2012, stated that there are no ASTM A325, F1852, or A490 bolts within the scope of the ASME Section XI, Subsection IWF program. Therefore, the response stated that the GALL Report recommended preventive actions in Section 2 of Research Council for Structural Connections (RCSC) publication "Specification for Structural Joints Using ASTM A325 or A490 Bolts" do not apply.
The response to RAI 3.5.2.1.1-1, provided by letter dated February 16, 2012, regarded stress corrosion cracking (SCC) in high strength bolts. The response stated that A325 or A490 bolts are used for high strength structural bolts and that structural bolting is within the scope of license renewal and is managed by the Structures Monitoring Program. The response further stated that SCC potential need not be evaluated for these bolts based on guidance in SRP-LR Table 3.5-1, ID 69.
Issue The staff agrees that SCC potential need not be evaluated for ASTM A325 and A490 structural bolts; however, the preventive actions discussed in Section 2 of RCSC publication "Specification for Structural Joints Using ASTM A325 or A490 Bolts," should still be addressed if A325 or A490 bolts are in the scope of a program.
The staff reviewed Table 3.9-6, "Loading Combinations, Stress Limits, and Allowable Stresses,"
in the LGS UFSAR and noted several components which appear to be within the scope of ASME Section XI, Subsection IWF that either called out SA325 bolts, which are equivalent to ASTM A325 bolts, or referenced ASME Division III, Subsection NF, which allows the use of SA325 bolts. It appears to the staff that there may be a discrepancy between the information in the UFSAR, and the information provided in the response to RAI B.2.1.32-2. The UFSAR appears to allow the use of SA325 bolts, and in at least one instance calls out SA325 bolts, while the RAI B.2.1.32-2 response claims there are no ASTM A325 bolts within the scope of the program. Based on the information in the UFSAR, along with the RAI responses, it is not clear to that staff whether or not there are A325 or A490 bolts within the scope of the ASME Section XI, Subsection IWF program.
Request Verify that there are no ASTM A325, F1852, or A490, or ASME equivalent, bolts in the scope of the ASME Section XI, Subsection IWF program. If there are no ASTM A325, F1852, or A490 bolts within the scope of the program, explain the discrepancy in the UFSAR. If the bolts are within the scope of the ASME Section XI, Subsection IWF program, explain how the preventive actions discussed in Section 2 of "Specification for Structural Joints Using ASTM A325 or A490 Bolts" are addressed, or why they are unnecessary. If ASTM A325, F1852, or A490 bolts typically within the scope of ASME Section XI, Subsection IWF program are being managed by a different program (e.g. Structures Monitoring) explain how that program addresses the recommendations of the GALL Report ASME Section XI, Subsection IWF program.
Enclosure Page 3 of 3 Exelon Response UFSAR Table 3.9-6 contains only one entry for SA325 bolting which indicates that the RCIC (Reactor Core Isolation Cooling) Pump hold down bolting is SA325 material. The vendor documents and a walkdown in LGS Unit 2 identify hold down bolts which mount the RCIC pump to the base plate support as ASTM A449 bolts, with bolt head markings consistent with ASTM A449 material, rather than ASTM A325 bolts. These bolts are within the scope of ASME Section XI, Subsection IWF.
Corrective Action Program issue report 01375064 was initiated to identify and resolve this discrepancy. UFSAR Table 3.9-6 Loading Combinations, Stress Limits, and Allowable Stresses is not intended to identify the materials of construction but rather loads and stresses.
Vendor supplied equipment supports, such as for the RCIC pump, utilize material that is equivalent to ASTM A325 (i.e., ASTM A449). ASTM A325 or ASTM equivalent bolting material is not prohibited for future installations or maintenance by the ASME B&PV Code Section III, Division I, Subsection NF or LGS procedures. Therefore, ASTM A325, F1852, A490 and ASME equivalent bolts are in the scope of the ASME Section XI, Subsection IWF program.
Appendix A, Table A.5, Commitment 35 for the Structures Monitoring program regarding bolting, addresses the preventive actions discussed in RCSC Specification for Structural Joints Using ASTM A325 or A490 Bolts, Section 2. The storage and handling requirements for high strength bolts in Commitment 35 applies to all carbon steel high strength structural bolting. These bolts may be used for applications that are within the scope of the Structures Monitoring program or the ASME Section XI, Subsection IWF program. Therefore, Commitment 35 is adequate to address the storage and handling requirements for carbon steel high strength structural bolting identified by RCSC, irrespective of the ultimate use of the bolting material, and a new commitment for the ASME section XI, Subsection IWF program is not necessary.
Enclosure Page 1 of 4 ENCLOSURE 10 CFR 54.21(b) Update Amendment to License Renewal Application for Limerick Generating Station
Enclosure Page 2 of 4 Introduction The License Renewal Rule, 10 CFR 54.21(b), requires that each year following submittal of a License Renewal Application (LRA), an amendment must be submitted to identify changes to the facility current licensing basis (CLB) that materially impact the content of the LRA. In accordance with this requirement, Exelon Generation Company, LLC (Exelon) has completed the review of the Limerick Generating Station CLB changes since the submittal of the LRA. This Enclosure provides its results and identifies the section of the LRA that is impacted by the CLB changes.
Review Process The annual update review is a procedurally controlled process to satisfy the requirements of 10 CFR 54.21(b). Specifically, the process is used to identify and evaluate changes to the plant CLB by reviewing plant documents, which include but are not limited to the following:
Design Change Packages (DCPs)
UFSAR Updates Licensing Correspondence Piping & Instrumentation Drawings (P&IDs)/Boundary Drawings Generic Safety Issues TLAAs Changes to the text or supporting license renewal boundary drawings of the LRA as submitted on June 22, 2011 are identified as part of the review. These changes are then reviewed by a technical verification team to determine those changes to the CLB that materially affect the LRA for inclusion in this Enclosure. Changes to the LRA described in formal Exelon correspondence to the NRC, including RAI responses, are not included in the annual update because 1) these changes were not initiated due to changes in the Limerick CLB, and 2) this information has already been incorporated into the NRCs LRA review.
Review Results The review identified one (1) design change that impacts the LRA. This design change resulted in a new material being added to the High Pressure Coolant Injection System (HPCI). The change and its impact on the LRA are discussed below.
High Pressure Coolant Injection System (HPCI) Engineering Change Subsequent to the June 22, 2011, submittal of the LRA, Limerick implemented a design change that impacts the content of Table 3.2.2-3, High Pressure Coolant Injection System (HPCI). As a result of the addition of stainless steel high point vents and ball valves on the HPCI header, LRA Table 3.2.2-3 has been modified as shown below.
There were no other impacts to the LRA identified during this review.
Enclosure Page 3 of 4 As a result of the annual update review, LRA Table 3.2.2-3, pages 3.2-44 and 3.2-50, are revised as shown below with inserted text shown in bold italics:
Table 3.2.2-3 High Pressure Coolant Injection System (Continued)
Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Item Table 1 Item Notes Air - Indoor, Uncontrolled (External)
Loss of Material External Surfaces Monitoring of Mechanical Components (B.2.1.25)
V.D2.E-26 3.2.1-40 A
Air/Gas - Wetted (Internal)
Loss of Material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.26)
V.D2.E-27 3.2.1-46 A
One-Time Inspection (B.2.1.22)
V.D2.EP-60 3.2.1-16 A
Loss of Material Water Chemistry (B.2.1.2)
V.D2.EP-60 3.2.1-16 A
Steam (Internal)
Wall Thinning Flow-Accelerated Corrosion (B.2.1.10)
V.D2.E-07 3.2.1-11 A, 3 One-Time Inspection (B.2.1.22)
V.D2.EP-60 3.2.1-16 A
Carbon Steel Treated Water (Internal)
Loss of Material Water Chemistry (B.2.1.2)
V.D2.EP-60 3.2.1-16 A
Air - Indoor, Uncontrolled (External)
None None V.F.EP-18 3.2.1-63 A
One-Time Inspection (B.2.1.22)
V.D2.EP-73 3.2.1-17 A
Leakage Boundary Stainless Steel Treated Water (Internal)
Loss of Material Water Chemistry (B.2.1.2)
V.D2.EP-73 3.2.1-17 A
Air - Indoor, Uncontrolled (External)
Loss of Material External Surfaces Monitoring of Mechanical Components (B.2.1.25)
V.D2.E-26 3.2.1-40 A
Air/Gas - Wetted (Internal)
Loss of Material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.26)
V.D2.E-27 3.2.1-46 A
Piping, piping components, and piping elements Pressure Boundary Carbon Steel Air - Indoor, Uncontrolled (External)
Loss of Material External Surfaces Monitoring of Mechanical Components (B.2.1.25)
V.D2.E-26 3.2.1-40 A
Enclosure Page 4 of 4 Table 3.2.2-3 High Pressure Coolant Injection System (Continued)
Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Item Table 1 Item Notes Lubricating Oil (Internal)
Loss of Material One-Time Inspection (B.2.1.22)
V.D2.EP-77 3.2.1-49 A
One-Time Inspection (B.2.1.22)
V.D2.EP-60 3.2.1-16 A
Loss of Material Water Chemistry (B.2.1.2)
V.D2.EP-60 3.2.1-16 A
Steam (Internal)
Wall Thinning Flow-Accelerated Corrosion (B.2.1.10)
V.D2.E-07 3.2.1-11 A, 3 One-Time Inspection (B.2.1.22)
V.D2.EP-60 3.2.1-16 A
Treated Water (External)
Loss of Material Water Chemistry (B.2.1.2)
V.D2.EP-60 3.2.1-16 A
One-Time Inspection (B.2.1.22)
V.D2.EP-60 3.2.1-16 A
Carbon Steel Treated Water (Internal)
Loss of Material Water Chemistry (B.2.1.2)
V.D2.EP-60 3.2.1-16 A
Air - Indoor, Uncontrolled (External)
None None V.F.EP-18 3.2.1-63 A
One-Time Inspection (B.2.1.22)
V.D2.EP-73 3.2.1-17 A
Pressure Boundary Stainless Steel Treated Water (Internal)
Loss of Material Water Chemistry (B.2.1.2)
V.D2.EP-73 3.2.1-17 A
Air - Indoor, Uncontrolled (External)
Loss of Material External Surfaces Monitoring of Mechanical Components (B.2.1.25)
V.D2.E-26 3.2.1-40 A
Valve Body Structural Support Carbon Steel Air/Gas - Wetted (Internal)
Loss of Material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.26)
V.D2.E-27 3.2.1-46 A