ML14055A532

From kanterella
Jump to navigation Jump to search

Summary of Telephone Conference Call Held on January 30, 2014. Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC, Concerning Requests for Additional Information Pertaining to the Limerick Generating Station,
ML14055A532
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 03/11/2014
From: Leslie Perkins
License Renewal Projects Branch 2
To:
Perkins L, 415-2375
References
TAC ME7346, TAC ME7347
Download: ML14055A532 (8)
v • d • e


Text

LICENSEE:

FACILITY:

SUBJECT UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 11, 2014 Exelon Generation Company, LLC Limerick Generating Station

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON JANUARY 30, 2014. BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND EXELON GENERATION COMPANY, LLC, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE LIMERICK GENERATING STATION LICENSE RENEWAL APPLICATION (TAG NOS. ME7346 AND ME7346)

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Exelon Generation Company, LLC, held a telephone conference call on January 30, 2014, to discuss and clarify the staff's requests for additional information (RAis) concerning the Limerick Generating Station license renewal application. The telephone conference call was useful in clarifying the intent of the staff's RAis. provides a listing of the participants and Enclosure 2 contains a listing of the RAis discussed with the applicant, including a brief description on the status of the items.

The applicant had an opportunity to comment on this summary.

Docket Nos.50-352 and 50-353

Enclosures:

1. List of Participants
2. List of Requests for Additional Information cc w/encls: Listserv c.t~~*

Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation

March 11, 2014 LICENSEE:

Exelon Generation Company, LLC FACILITY:

Limerick Generating Station

SUBJECT:

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON JANUARY 30, 2014. BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND EXELON GENERATION COMPANY, LLC, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE LIMERICK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC. NOS. ME7346 AND ME7346)

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Exelon Generation Company, LLC, held a telephone conference call on January 30, 2014, to discuss and clarify the staff's requests for additional information (RAis) concerning the Limerick Generating Station license renewal application. The telephone conference call was useful in clarifying the intent of the staff's RAis. provides a listing of the participants and Enclosure 2 contains a listing of the RAis discussed with the applicant, including a brief description on the status of the items.

The applicant had an opportunity to comment on this summary.

Docket Nos.50-352 and 50-353

Enclosures:

1. List of Participants
2. List of Requests for Additional Information cc w/encls: Listserv DISTRIBUTION See next page ADAMS Accessio N ML14055A532 n o.:

IRA/

Leslie Perkins, Project Manager Projects Branch 2 Division of License Renewal Office of Nuclear Reactor Regulation

  • concurred via email OFFICE LA:DLR PM:RPB2:DLR BC:RPB2:DLR PM:RPB2:DLR NAME I King LPerkins BWittick LPerkins DATE 314114 315114 317114 3111114 OFFICIAL RECORD COPY

SUBJECT*

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON JANUARY 30, 2014 BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND EXELON GENERATION COMPANY, LLC, CONCERNING REQUESTS FOR ADDITIONAL INFORMATION PERTAINING TO THE LIMERICK GENERATING STATION LICENSE RENEWAL APPLICATION (TAC. NOS. ME7346 AND ME7347)

DISTRIBUTION:

HARDCOPY:

DLR RF E-MAIL:

PUBLIC RidsNrrDir Resource RidsNrrDirRpb1 Resource RidsNrrDlrRpb2 Resource RidsNrrDirRerb Resource RidsNrrDirRarb Resource RidsNrrDirRasb Resource RidsNrrDirRapb Resource RidsNrrDirRpob Resource RidsNrrPMLimerick Resource RidsOgcMaiiCenter Resource RKuntz DMorey LPerkins MSmith, OGC RConte, Rl MModes, Rl GDiPaolo, Rl NSieller, Rl

PARTICIPANTS Leslie Perkins Jerry Dozier Chris Wilson AI Fulvia Don Vanover Don Macleod Jeff Gabor TELEPHONE CONFERENCE CALL LIMERICK GENERATING STATION LICENSE RENEWAL APPLICATION LIST OF PARTICIPANTS January 30, 2014 AFFILIATIONS U.S. Nuclear Regulatory Commission (NRC)

NRC Exelon Generation Company, LLC (Exelon)

Exelon ERIN Engineering ERIN Engineering ERIN Engineering ENCLOSURE 1

REQUESTS FOR AODITIONAL INFORMATION LICENSE RENEWAL APPLICATION January 30, 2014 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Exelon Generation Company, LLC, held a telephone conference call on January 30, 2014, to discuss and clarify the following requests for additional information (RAis) concerning the license renewal application (LRA).

Background

In accordance with the Commission's regulations, the Environmental Report (ER) Exelon Generation Company, LLC (Exelon) submitted as part of its Limerick Generating Station (LGS) license renewal application did not include a site-specific severe accident mitigation alternatives (SAMA) analysis, because the Staff previously considered severe accident mitigation design alternatives (SAMDAs) in the Final Environmental Statement (FES) supporting issuance of the LGS operating licenses. See 10 CFR 51.53(c)(3)(ii)(L) and CLI~ 13~07. Exelon's ER did include an analysis of new and significant information with respect to 10 CFR 51.53(c)(3)(ii)(L) and the SAMOA Analysis in the FES, as required by 10 CFR 51.53(c)(3)(iv).

The Natural Resources Defense Council (NRDC) submitted a hearing request, which proposed three SAMA contentions and one no~action alternative contention.ln CLI-12~19, as relevant here, the Commission held that the SAMA contentions were impermissible challenges to 10 CFR 51.53(c)(3)(ii)(L). The Commission did allow NRDC to submit a subsequent waiver petition to litigate the SAMA contentions. As summarized in CLI~13-07, NRDC's waiver petition raised three challenges to the consideration of new and significant information with respect to SAMAs in Exelon's ER. NRDC claimed that Exelon (and, ultimately, the NRC in the supplemental Environmental Impact Statement (EIS)) must: (1) consider potential new SAMAs that have been considered for other Mark II boiling water reactors; (2) use economic cost information specific to LGS, rather than Three Mile Island; and (3) use "modern techniques for assessing whether the newly considered [SAMAs] are cost-beneficial."

In CLI-13-07, the Commission affirmed the Board's denial of NRDC's waiver petition but referred NRDC's waiver petition to the Staff as additional comments on the Staffs draft supplemental EIS for the Staffs consideration and response. 1 The Commission directed the Staff to review the significance of any new SAMA-related information in its environmental review of Exelon's LGS license renewal application, including the information presented in NRDC's waiver petition, and to discuss its review in the final supplemental EIS.

The following table provides a list of Potentially Cost Beneficial SAMAs that have been identified at other Mark II boiling water reactors (BWRs) that have completed license renewal. Additional information regarding these Potentially Cost Beneficial SAMAs is provided in the NRC's Final Environmental Impact Statements and the applicants' environmental reports. See References.

ENCLOSURE 2 Potential Cost Beneficial SAM As at other Mark II BWRs Nine Mile Point 2

  • Improve Procedure SOP-14 and provide training Protect critical fire targets
  • Hard pipe diesel fire pump to the reactor pressure vessel Reduce unit cooler contribution to emergency diesel generator (EDG) unavailability by increasing testing frequency Reduce unit cooler contribution to EDG unavailability by providing redundant means of cooling Improve procedure for loss of instrument air Improve control building flooding scenarios Susquehanna Install minimal hardware changes and modify procedures to provide across-tie capability between the 4 kilovolt (kV) alternating current (AC) emergency buses Procure an additional portable 480 volt (V) AC station diesel generator to power battery chargers I

in scenarios where AC power is unavailable Improve the cross-tie capability between 4 kV AC emergency buses, i e., between A or D emergency buses and B or C emergency buses (a more flexible cross-tie option than SAMA 2a)

  • Modify procedures to stagger reactor pressure vessel (RPV) depressurization when fire protection system injection is the only available make-up source Modify portable station diesel generator to automatically align to 125 V direct current (DC) battery chargers Columbia
  • AC/DC-28-Reduce common cause failures (CCFs) between EDG-3 and EDG-1/2
  • CC-03b-Raise reactor core isolation cooling system (RCIC) backpressure trip set points FR-07a-lmprove the fire resistance of critical cables for containment venting FR-07b-lmprove the fire resistance of critical cables for transformer E-TR-S FR-OB-Improve the fire resistance of cables to residual heat removal (RHR) and standby SW HV-02-Provide a redundant train or means of ventilation SR-05R-Improve seismic ruggedness of MCC-7F and MCC-8F FL-05R-Ciamp on flow instruments to certain drain lines in the control building L__._

of the radwaste bu1ld1ng and alarm 1n the control room

_FL-04R-Add one isolation valve in the SW, turbine SW, and fire rotection lines in the control building area of the radwaste building FL-OSR-Additional nondestructive evaluation (NDE) and inspections (in the control building)

CC-24R-Backfeed the high pressure core spray system (HPCS) system with SM-8 to provide a third power source for HPCS CC-25R-Enhance alternate injection reliability by including RHR, SW and fire water cross-tie in the maintenance program OT-07R-Increase operator training on systems and operator actions determined to be important from the PSA FW-05R-Examine the potential for operators to control reactor feedwater (RFW) and avoid a reactor trip OT -09R-For the non-LOCA initiating events, credit the Z (power conversion system recovery) function FR-11 R-lnstall early fire detection in the following analysis units: RC-02, RC-03, RC-04, RC-05, RC-07, RC-08, RC-11, RC-13, RC-14, and RC-1A Exelon's ER does not specifically discuss whether these potentially cost beneficial SAMAs constitute new and significant information pertaining to the 1 989 SAMOA analysis. Please provide a discussion of how, if at all, Exelon considered whether these potentially cost beneficial SAMAs impact the conclusions in the 1989 SAMOA regarding the risk and environmental impacts of severe accidents at LGS. Please indicate whether these SAMAs were discussed in Table A of Exelon's December 14, 2012. Counter Affidavit (ADAMS Accession No, ML12349A328) If so, what is the basis for Exelon's conclusions with respect to those SAMAs in Table A? If not, please provide the basis for why these SAMAs are not new and significant information with respect to the 1989 SAMOA Discussion: The applicant indicated that the first four potential cost beneficial SAMAs listed for Nine Mile Point 2 in the table above were actually for Nine Mile Point 1, which is not a Mark II BWR. The applicant requested that the NRC remove the first four potential cost beneficial SAMAs listed for Nine Mile Point 2 in the final RAl. The applicant also indicated that some of the descriptions of potential cost beneficial SAMAs listed for Susquehanna in the table had been inadvertently split into multiple bullets and requested that the bullets for Susquehanna be combined in the final RAI to have five bulleted SAMA descriptions, instead of eight.

The staff agreed to revise the final table in the RAI by removing the first four potential cost beneficial SAMAS listed for Nine Mile point 2 and to combine the bullets for Susquehanna to have five bulleted SAMA descriptions, instead of eight.

Additionally, the applicant indicated that their response to RAl 1 will analyze the significance of potential cost beneficial SA MAs for Nine Mile Point 2, Susquehanna, and Columbia that are listed in the RAI, but were not previously analyzed. The analysis will be presented in the form of an explanation of methodology and a table having the following column headings, unless NRC suggests additional columns Nuclear Power Plant Item#

List of Titles of SAMAs Found to be Cost Beneficial or Potentially Cost Beneficial Implemented at Limerick?

Base Case Maximum Averted Cost Risk Base Case Averted Cost Risk Percent Change Comments The staff understood the applicant's plans for responding to RAI 1 and did not request that additional information to be included.

On page 5-6 of the ER, Exelon provides a history of the reductions in core damage frequency (CDF). Exelon further states that "the reduction in CDF reflects improvements in reliability data, improvements in procedural guidance and plant capabilities, and a reduction in the number of reactor trips." Furthermore Exelon states, "Reductions in CDF reflect implementation of the IPE, IPEEE, and CPI program."

What is the status of these improvements and mitigation measures? Please indicate which have been implemented and when. Describe other mitigation activities that have been implemented at LGS to substantially reduce the CDF or Large Early Release Frequency since the 1989 SAMOA.

Discussion: The applicant indicated that their response to the first sub-question in draft RAI 2 will be limited to improvements and mitigation measures implemented as a result of the IPE, IPEEE, and CPI program, unless NRC suggests additional content.

The staff understood the applicant's plans for responding to RAI 2 and did not request additional content to be included.

Retrieved from "https://kanterella.com/w/index.php?title=ML14055A532&oldid=5215106"