ML14143A015
| ML14143A015 | |
| Person / Time | |
|---|---|
| Site: | Byron, Braidwood  |
| Issue date: | 05/29/2014 |
| 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: ML14143A015 (5) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 May 29, 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 28 (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 e-mail Lindsay.Robinson@nrc.gov Sincerely,
/RA Richard Plasse for/
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
ML14143A015 *concurred via email OFFICE LA:DLR* PM:RPB1:DLR BC:RPB1:DLR PM:RPB1:DLR NAME YEdmonds LRobinson (RPlasse for) YDiazSanabria LRobinson (RPlasse for)
DATE 5/29/14 5/29/14 5/29/14 5/29/14
Letter to M.P. Gallagher from Lindsay R. Robinson dated May 29, 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 28 (TAC NOS. MF1879, MF1880, MF1881, AND MF1882)
DISTRIBUTION EMAIL:
PUBLIC RidsNrrDlr Resource RidsNrrDlrRpb1 Resource RidsNrrDlrRarb Resource RidsNrrDlrRasb Resource RidsOgcMailCenter RidsNrrPMByron Resource RidsNrrPMBraidwood Resource
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 28 (TAC NOS. MF1879, MF1880, MF1881, MF1882)
RAI 3.0.3-2b Applicability:
Byron Station (Byron) and Braidwood Station (Braidwood), all units
Background:
- 1. The response to request for additional information (RAI) 3.0.3-2a, dated May 5, 2014, Request (4) states that the diesel oil storage tanks are designed such that coating debris will not cause flow blockage of downstream components because the suction lines for the fuel oil transfer pumps are located greater than a foot above the bottom of the tanks and the tank bottoms are sloped such that any debris would accumulate away from the suction line for the fuel oil transfer pumps. In addition, it states that a review of the results of completed tank inspections indicates that significant coating peeling, delamination, blistering, rusting, or unacceptable cracking and flaking have not occurred.
- 2. The response to RAI 3.0.3-2a Request (8) included changes to license renewal application (LRA) Sections A.2.1.11, A.2.1.18, B.2.1.11, and B.2.1.18 to address acceptance criteria and followup inspections when coating inspections reveal peeling and delamination and other indications.
- 3. The response to RAI 3.0.3-2a Request (1) states that the safety injection pump oil system includes an oil filter that removes debris and particulate prior to the oil reaching the bearings and the differential pressure across the oil filter is monitored during quarterly surveillances of the pumps.
- 4. The response to RAI 3.0.3-2 dated January 13, 2014, states that coating inspections for the foam concentrate tanks are performed every 15 years during replacement of the internal bladder.
- 5. The response to RAI 3.0.3-2a Request (7) discussed qualifications of the individual who will approve post-inspection reports for coatings and the key information that will be included in the reports.
Issue:
- 1. Insufficient details were provided for the staff to conclude that a 10-year inspection interval for the diesel oil storage tanks is acceptable. For example: (a) even though the tank is sloped and the suction lines are a foot above the tank bottom, depending on the specific gravity of coating debris and the flow velocity, debris could be transported; (b) although corrosion is unlikely for bare metal exposed to fuel, debris and water can collect on the tank bottom and result in loss of material and the RAI response did not address design minimum wall thickness and corrosion allowances; and (c) current inspections are not necessarily an effective indicator of degradation that could occur in the period of extended operation.
ENCLOSURE
- 2. The changes to LRA Sections A.2.1.11, A.2.1.18, B.2.1.11, and B.2.1.18 are internally inconsistent because one portion would allow degraded coatings that exhibit delamination and peeling to remain in service while an enhancement states that signs of delamination of the coating from the base metal (e.g., peeling and blistering) are not acceptable. In addition peeling, delamination, and blistering are intermixed, resulting in unclear guidance.
- 3. The staff has concluded that the quarterly monitoring of the differential pressure across the lubricating oil filter for the safety injection pump lubricating oil system is an important feature of managing loss of coating integrity of the internal coatings on the oil reservoirs.
However, neither the updated final safety analysis report (UFSAR) supplement nor the Lubricating Oil Analysis program credits monitoring the differential pressure across the oil filter.
- 4. The Fire Water System program and UFSAR supplement does not include key aspects and the program does not include summary descriptions of activities associated with managing loss of coating integrity as described in RAI 3.0.3-2a Request (2).
- 5. Appendix B for the Open-Cycle Cooling Water, Fuel Oil Chemistry, and Fire Water System programs do not include key aspects of the post-inspection reports for coatings, as described in the response to RAI 3.0.3-2a Request (7).
Request:
- 1. Provide sufficient information for the staff to conclude that neither loss of material nor coating debris would result in loss of the current licensing basis intended functions of the diesel oil storage tanks and downstream in-scope components.
- 2. Clarify LRA Sections A.2.1.11, A.2.1.18, B.2.1.11, and B.2.1.18 in regard to acceptability of peeling, delamination, and blistering.
- 3. Revise LRA Sections A.2.1.26 and B.2.1.26 to credit monitoring the differential pressure across the safety injection pump lubricating oil system oil filter.
- 4. Provide a similar level of detail in the Fire Water System program and UFSAR supplement as described in the response to RAI 3.0.3-2a Request (2).
- 5. For the Open-Cycle Cooling Water, Fuel Oil Chemistry, and Fire Water System programs include the key information that will be included in the post inspection reports.
For the Fire Water System program include a summary description in the LRA of qualifications of the individual who will approve post-inspection reports for coatings.