ML14126A806

Request for Additional Information for the Review of the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, License Renewal Application, Set 25 (TAC Nos. MF1879, MF1880, MF1881, and MF1882)

ML14126A806
Person / Time
Site:	Byron, Braidwood
Issue date:	05/19/2014
From:	Robinson L License Renewal Projects Branch 1
To:	Gallagher M Exelon Generation Co
Robinson L, 415-4115
References
TAC MF1879, TAC MF1880, TAC MF1881, TAC MF1882
Download: ML14126A806 (5)

Text

May 19, 2014 Mr. Michael P. Gallagher Vice President, License Renewal Projects Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION, SET 25 (TAC NOS. MF1879, MF1880, MF1881, AND MF1882)

Dear Mr. Gallagher:

By letter dated May 29, 2013, Exelon Generation Company, LLC, submitted an application pursuant to Title 10 of the Code of Federal Regulations Part 54, to renew the operating licenses NPF-37, NPF-66, NPF-72, and NPF-77 for Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2, respectively, 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 were discussed with John Hufnagel, 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 at 301-415-4115 or by e-mail at Lindsay.Robinson@nrc.gov.

Sincerely,

/RA/

Lindsay R. Robinson, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-454, 50-455, 50-456, and 50-457

Enclosure:

Request for Additional Information cc w/encl: Listserv

ML14126A806 *concurred via email OFFICE LA:DLR* PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME IKing LRobinson YDiazSanabria LRobinson DATE 5/14/14 5/14/14 5/15/14 5/19/14

Letter to M.P. Gallagher from Lindsay R. Robinson dated May 19, 2014

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION FOR THE REVIEW OF THE BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION, SET 25 (TAC NOS. MF1879, MF1880, MF1881, AND MF1882)

DISTRIBUTION EMAIL:

PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsOgcMailCenter RidsNrrPMByron Resource RidsNrrPMBraidwood Resource

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LRobinson DMcIntyre, OPA JMcGhee, RIII EDuncan, RIII JBenjamin, RIII AGarmoe, RIII JRobbins, RIII VMitlyng, RIII PChandrathil, RIII

BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION REQUEST FOR ADDITIONAL INFORMATION, SET 25 (TAC NOS. MF1879, MF1880, MF1881, MF1882)

RAI 3.5.2.3.15-1 Applicability:

Byron Station (Byron) and Braidwood Station (Braidwood), all units

Background:

License renewal application (LRA) Table 3.5.2-15, Structural Commodity Group: Structural Commodity Group Summary of Aging Management Evaluation, includes two plant-specific aging management review (AMR) items: lead (Pb) penetrations seals that are exposed to (1) indoor uncontrolled air and (2) indoor air with borated water leakage. The LRA identifies that there are no aging effects that are applicable to the exposure of these seals to these environments. The AMR items cite generic Note J, which states that neither the component nor the materials and environment are evaluated in the Generic Aging Lessons Learned (GALL)

Report. The AMR items also a reference a plant-specific Note 9 on the AMR table, which states:

This material and environment applies to the lead wool used for packing penetrations for radiation shielding. Operating experience has shown the air-indoor uncontrolled and air with borated water leakage environments to contain insignificant quantities of moisture, humidity, condensation, and contaminants during normal operation. Therefore, there are no aging effects associated with the lead material in the normal dry, air - indoor uncontrolled and air with borated water leakage environments.

Per Title 10 of the Code of Federal Regulations (10 CFR) 54.21(a)(3), the licensee is required to demonstrate that the effects of aging will be adequately managed during the period of extended operation for each structure or component that is scoped in for license renewal in accordance with the requirements in 10 CFR 54.4 and has been screened in for an AMR in accordance with the requirement in 10 CFR 54.21(a)(1). Since the applicant has identified air with borated water leakage environment as an applicable environment for these seal materials, the applicant must evaluate the seal materials applicable aging effects under exposure to the both containment air environment and postulated sources of borated water.

Issue:

The applicable plant-specific AMR item in LRA Table 3.5.2-15 identifies the indoor air with borated water leakage environment as an applicable environment for these containment penetration seals. However, plant-specific Note 9 for the AMR item only addressed the impacts of moisture, humidity, condensation and impurity contaminants in the containment air would have on the lead (Pb) seal materials (i.e., lead packing wool). The plant-specific Note for the AMR item did not address the impact that borated water would have on these seal materials if the borated water were to leak onto these penetration seal materials. It is not clear to the staff whether the aging effect of loss of material due to boric acid corrosion would not be ENCLOSURE

considered if the lead packing wool is exposed to an indoor air with borated water leakage environment.

Request:

Provide the technical basis as to why loss of material due to boric acid corrosion of the lead packing wool used in the penetration seals has not been identified as an aging effect requiring management for the applicable AMR item in LRA Table 3.5.2-15. Amend the application, accordingly, if it is determined that loss of material due to postulated boric acid corrosion is an applicable aging effect requiring management for these penetration seals.