ML12286A325

Review of the Safety Evaluation Report with Open Items Related Limerick License Renewal Application

ML12286A325
Person / Time
Site:	Limerick
Issue date:	10/12/2012
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC ME6555, TAC ME6556
Download: ML12286A325 (3)

Text

10 CFR 50 10 CFR 51 10 CFR 54 October 12, 2012 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353

Subject:

Exelon Generation Company, LLC Review of the Safety Evaluation Report with Open Items related to the Limerick Generating Station License Renewal Application

Reference:

1. Letter from Brian E. Holian (NRC) to Michael P. Gallagher (Exelon), Safety Evaluation Report with Open Items Related to the License Renewal of Limerick Generating Station, Units 1 and 2 (TAC Nos. ME6555, ME6556), dated July 31, 2012

2. Michael P. Gallagher (Exelon), Exelon Generation Company, LLC Review of the Safety Evaluation Report with Open Items related to the Limerick Generating Station License Renewal Application, dated September 12, 2012 In the Reference 1 letter, the U.S. Nuclear Regulatory Commission issued the Safety Evaluation Report with Open Items (SER) related to the LGS License Renewal Application and requested Exelon to review the SER and provide comments to the staff within 45 days of the date of that letter. In the Reference 2 letter, Exelon provided comments regarding the SER.

This letter supplements Reference 2 by providing additional comments on the SER regarding one of the two proposed license conditions.

The language that Exelon is commenting on is located on page 1-8 of the SER and states: The second license condition requires future activities described in the UFSAR supplement to be completed prior to the period of extended operation. The applicant shall complete these activities no later than six months prior to the period of extended operation, and shall notify the NRC in writing when implementation of these activities is complete.

This license condition is different from previous license conditions contained in renewed licenses issued for other Exelon plants in that it requires Aging Management Activities to be

U.S. Nuclear Regulatory Commission October 12, 2012 Page 2 completed six months prior to the period of extended operation (PEO), rather than simply prior to the PEO.

This new license condition appears contrary to the guidance provided within License Renewal guidance documents. Specifically, as part of the License Renewal Application (LRA), LGS provided an initial commitment list in the UFSAR Supplement which Exelon subsequently modified based on Licensing Correspondence and discussions with the Staff. This initial commitment list had implementation timeframes that were consistent with the recommendations in Generic Aging Lessons Learned (Gall) Report Revision 2, Standard Review Plan For Review Of License Renewal Applications For Nuclear Power Plants Revision 2 and NEI 95-10, Revision 6 (as endorsed by RG 1.188, Standard Format And Content For Applications To Renew Nuclear Power Plant Operating Licenses, Revision 1).

The recommended commitment implementation timeframes from the above cited documents are prior to PEO unless there is a valid technical reason for a different timeframe. These implementation time frames are agreed upon by the NRC staff as documented in the SER with Open Items, Appendix A. As per the Staffs own guidance provided in NRR Office Instruction LIC-101, Revision 4, License Amendment Review Procedures, license conditions (Obligations) should be based on a determination by the staff that the issue is of high safety or regulatory significance. Further it goes on to state to ensure no unintended consequences, it is strongly recommended that the NRC staff request Licensee agreement on language of NRC-proposed license conditions. This proposed license condition would require completion of most activities described in the license renewal commitment list six months earlier than Exelon committed to perform these activities.

The proposed license condition creates consequences that the Staff may not have intended or appreciated. The LGS Licenses for Units 1 and 2 expire on October 26, 2024 and June 22, 2029, respectively. Exelon performs LGS refueling outages in the spring. A license condition requiring that the activities be completed at least six months prior to entering the PEO would mean that Exelon would not have the opportunity to perform inspections during the last scheduled refueling outage prior to PEO for Units 1 or 2 (Spring 2024 and 2029).

Not allowing performing aging management activities in the last refueling outage prior to the PEO has additional undesirable consequences. For example, certain Aging Management Programs specifically require that inspections be done close to the PEO to allow more time for aging effects to develop and be detected by inspection. One example would be the One-Time Inspection of ASME Code Class 1 Small-Bore Piping Program (GALL XI M35), which GALL Revision 2 would require the inspections to be done within the six year period prior to PEO. The sample size for this program increased significantly from GALL Revision 1 to GALL Revision 2, which in turn requires more refueling outages to accomplish the work. Another example would be the Selective Leaching Program (GALL XI M33) where it states the following under the Detection of Aging Effects;. is a one-time inspection conducted within the last 5 years prior to entering the period of extended operation. Because selective leaching is a slow acting corrosion process, this measurement is performed just prior to the period of extended operation.

U.S. Nuclear Regulatory Commission October 12, 2012 Page 3 For the reasons cited above, unless the staff establishes appropriate basis (Le., safety benefit) for modifying the timing of commitments made by Exelon, we request that the proposed License Condition be revised to remove the six month modifier as follows:

The Exelon Generation Company Updated Final Safety Analysis Report supplement submitted pursuant to 10 CFR 54.21 (d) describes certain future inspection activities to be completed prior to the period of extended operation. The licensee shall complete these activities prior to the period of extended operation and shall notify the NRC in writing when activities to be completed prior to the period of extended operation can be verified by NRC inspection.

There are no new or revised regulatory commitments contained in this letter.

If you have any questions, please contact Mr. AI Fulvio, Manager, Exelon License Renewal, at 610-765-5936.

Respectfully, Michael P. Gallagher Vice President - License Renewal Projects Exelon Generation Company, LLC cc:

Regional Administrator - NRC Region I NRC Project Manager (Safety Review), NRR-DLR NRC Project Manager (Environmental Review), NRR-DLR NRC Project Manager, NRR-DORL Limerick Generating Station NRC Senior Resident Inspector, Limerick Generating Station R. R. Janati, Commonwealth of Pennsylvania