ML12338A321

Lr - Exelon Letter Dated November 6, 2012

ML12338A321
Person / Time
Site:	Limerick
Issue date:	11/29/2012
From:	Office of Nuclear Reactor Regulation
To:	Division of License Renewal
References
Download: ML12338A321 (6)

Text

LimerickNPEm Resource From: Milano, Patrick Sent: Thursday, November 29, 2012 1:12 PM To: LimerickHearingFile Resource

Subject:

Exelon Letter dated November 6, 2012 Attachments: 11 6 12 - LIM - SER with Open Items re LGS LRA.pdf 1

Hearing Identifier: Limerick_LR_NonPublic Email Number: 1546 Mail Envelope Properties (9C2386A0C0BC584684916F7A0482B6CAB9E9F1FEEF)

Subject:

Exelon Letter dated November 6, 2012 Sent Date: 11/29/2012 1:11:37 PM Received Date: 11/29/2012 1:12:00 PM From: Milano, Patrick Created By: Patrick.Milano@nrc.gov Recipients:

"LimerickHearingFile Resource" <LimerickHearingFile.Resource@nrc.gov>

Tracking Status: None Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 3 11/29/2012 1:12:00 PM 11 6 12 - LIM - SER with Open Items re LGS LRA.pdf 577976 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

U.S. Nuclear Regulatory Commission November 6, 2012 Page 2 As stated in the reference 2 letter, Not allowing performing aging management activities in the last refueling outage prior to the PEO has additional undesirable consequences. As a result of this proposed License condition, 2.5 years of opportunity to perform outage related inspections is lost as well as the potential impacts on LGS Aging Management Programs implementation detailed in the following table:

LGS AMP NUREG 1801 (GALL Rev. 2) Basis LGS Impact from proposed License NUREG 1800 (SRP Rev. 2) Basis Condition B.2.1.22 NUREG 1801: With respect to inspection Last Refueling Outage prior to PEO not timing, Specifically, inspections need to be available to perform outage related One-Time completed early enough to ensure that the aging inspections.

Inspection effects that may affect intended functions early in the period of extended operation are appropriately Less time available to allow aging GALL XI. M32 managed. Conversely, inspections need to be effects to develop prior to inspections.

timed to allow the inspected components to attain sufficient age to ensure that the aging effects with Per GALL it is optimal to perform long incubation periods (i.e., those that may affect one-time inspections as late as intended functions near the end of the period of possible to detect aging effects.

extended operation) are identified. Within these constraints, the applicant should schedule the inspection no earlier than 10 years prior to the period of extended operation and in such a way as to minimize the impact on plant operations. As a plant will have operated for at least 30 years before inspections under this program begin, sufficient time will have elapsed for any aging effects to be manifested.

NUREG 1800, Table 3.0-1 FSAR Supplement for Aging Management of Applicable Systems Implementation Schedule: Program should be implemented prior to period of extended operation B.2.1.23 NUREG 1801: The visual inspection and Last Refueling Outage prior to PEO not hardness measurement or other mechanical available to perform outage related Selective examination techniques, such as destructive inspections.

Leaching testing (when the opportunity arises), chipping, or scraping, is a one-time inspection conducted Less time available to allow aging GALL XI. M33 within the last 5 years prior to entering the period effects to develop prior to inspections.

of extended operation. Because selective leaching is a slow acting corrosion process, this Per GALL it is optimal to perform measurement is performed just prior to the period one-time inspections as late as of extended operation. Follow-up of unacceptable possible to detect aging effects.

inspection findings includes an evaluation using the corrective action program and a possible expansion of the inspection sample size and Location.

NUREG 1800, Table 3.0-1 FSAR Supplement for Aging Management of Applicable Systems Implementation Schedule: Program should be implemented prior to period of extended operation

U.S. Nuclear Regulatory Commission November 6, 2012 Page 3 B.2.1.24 NUREG 1801: The one time inspection should be Last Refueling Outage prior to PEO not completed within the six year period prior to the available to perform outage related ASME period of extended operation. inspections.

Code Class 1 Small-Bore NUREG 1800, Table 3.0-1 FSAR Supplement Less time available to allow aging Piping Program for Aging Management of Applicable Systems effects to develop prior to inspections.

Implementation Schedule: Program should be GALL XI. M35 implemented prior to period of extended operation Per GALL it is optimal to perform one-time inspections as late as possible to detect aging effects.

Sample population increased from GALL Rev 1 to GALL Rev 2 so significantly more inspections must be performed during each outage (2 vs. 3 available outages).

A.2.1.40 NUREG 1801: The first tests for license renewal Last Refueling Outage prior to PEO not are to be completed prior to the period of available to perform outage related Inaccessible extended operation with subsequent tests inspections.

Power Cables performed at least every 6 years thereafter.

Not Subject to Less time available to allow aging 10 CFR 50.49 NUREG 1800, Table 3.0-1 FSAR Supplement effects to develop prior to inspections.

Environmental for Aging Management of Applicable Systems Qualification Implementation Schedule: First tests or first Electrical inspections are normally Requirements inspections for license renewal completed prior to spread out over several refuel outages the period of extended operation to coordinate with specific Electrical GALL XI.E3 bus outages in order to minimize outage risk. Loss of one Refuel outage could result in multiple Electrical bus outages in a refuel outage which would increase Refuel Outage risk.

A.2.1.41 NUREG 1801: The first inspection using Last Refueling Outage prior to PEO not thermography or measuring connection resistance available to perform outage related Metal Enclosed is completed prior to the period of extended inspections.

Bus operation and every 10 years thereafter provided visual inspection is not used to inspect bolted Less time available to allow aging GALL XI.E4 connections. effects to develop prior to inspections.

NUREG 1800, Table 3.0-1 FSAR Supplement Electrical inspections are normally for Aging Management of Applicable Systems spread out over several refuel outages Implementation Schedule: First inspection for to coordinate with specific Electrical license renewal completed prior to the period of bus outages in order to minimize extended operation Refuel Outage risk. Loss of one Refuel outage could result in multiple Electrical bus outages in a refuel outage which would increase Refuel Outage risk.

Other potential impacts:

x Any inspection linked to a performance frequency of once every ISI interval could be an issue. For Unit 1, this means that anything scheduled for the last period of the third 10 year interval (outages in 2024 and 2026) would need to be scheduled to be performed in