ML14155A144

10 CFR 54.21(b) Annual Amendment to the Renewal Application and Revision to UFSAR Supplement Related to the Response to RAI 3.0.3.4-1

ML14155A144
Person / Time
Site:	Limerick
Issue date:	06/04/2014
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML14155A144 (9)

Text

Michael P. Gallagher Vice President. License Renewal Exelon Generation Exelon Nuclear 200 Exelon Way Kennett Square , PA 19348 610 765 5958 Office 610 765 5956 Fax www.exeloncorp.com michaelp.gallagher@exeloncorp.com 10 CFR 50 10 CFR 51 10 CFR 54 June 4, 2014 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:

10 CFR 54.21(b) Annual Amendment to the Limerick Generating Station License Renewal Application and Revision to UFSAR Supplement Related to the Response to RAI 3.0.3.4-1

References:

1. Exelon Generation Company, LLC letter from Michael P. Gallagher to NRC Document Control Desk, "Application for Renewed Operating Licenses", dated June 22, 2011

2. Exelon Generation Company, LLC letter from Michael P. Gallagher to NRC Document Control Desk, "10 CFR 54.21(b) Annual Amendment to the Limerick Generating Station License Renewal Application", dated June 14, 2012

3. Letter from John W. Lubinski (NRC) to Michael P. Gallagher (Exelon), "Safety Evaluation Report Related To The License Renewal of Limerick Generating Station, Units 1 and 2", dated January 10, 2013

4. Exelon Generation Company, LLC letter from Michael P. Gallagher to NRC Document Control Desk, "10 CFR 54.21(b) Annual Amendment to the Limerick Generating Station License Renewal Application and Review of Interim Staff Guidance", dated June 17, 2013

5. Exelon Generation Company, LLC letter from Michael P. Gallagher to NRC Document Control Desk, "Response to Requests for Additional Information and Minor Changes to the LRA Supplement dated March12, 2014 for the review of the Limerick Generating Station, Units 1 and 2, License Renewal Application",

dated May 21, 2014 In Reference 1, Exelon Generation Company, LLC (Exelon) submitted the License Renewal Application (LRA) for the Limerick Generating Station , Units 1 and 2 (LGS). In Reference 2, Exelon Generation Company, LLC (Exelon) submitted the first annual amendment required by

U.S. Nuclear Regulatory Commission June 4, 2014 Page 2 10 CFR 54.21 (b) for LGS. In Reference 3, the U.S. Nuclear Regulatory Commission issued the Safety Evaluation Report related to the LGS License Renewal Application (LRA). In Reference 4, Exelon Generation Company, LLC (Exelon) submitted the second annual amendment required by 10 CFR 54.21(b) for LGS.

Enclosure A to this letter provides a summary of the third annual review of the LGS License Renewal Application in accordance with 10 CFR 54.21 (b). The review identified no changes to the current licensing basis (CLB) of LGS that materially affect the contents of the License Renewal Application, including the FSAR supplement.

Separate from the annual review, Exelon is providing a revision to the UFSAR Supplement related to the RAI 3.0.3.4-1 response in the reference 5 letter. These changes are shown within .

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

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

I declare under penalty of perjury that the foregoing is true and correct.

Executed on

Enclosures:

A: Annual Update Review per 10 CFR 54.21 (b) for the Limerick Generating Station License Renewal Application B: Revision to UFSAR Supplement related to the RAI 3.0.3.4-1 Response 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

Enclosure A Page 1 of 1 Enclosure A Annual Update Review per 10 CFR 54.21(b) for the Limerick Generating Station License Renewal Application Introduction The License Renewal Rule, 10 CFR 54.21(b), requires that each year following submittal of a License Renewal Application (LRA) and at least 3 months before scheduled completion of the NRC review, an amendment to the renewal application must be submitted that identifies any change to the CLB of the facility that materially affects the contents of the License Renewal Application, including the FSAR supplement. In accordance with this requirement, Exelon Generation Company, LLC (Exelon) has completed the review of the Limerick Generating Station CLB changes since the submittal of the second annual update.

Review Process The review period for this process was from the end date of the last annual update review until the end date of this review (May 1, 2013 to April 30, 2014).

The LGS annual update review is a procedurally controlled process to satisfy the requirements of 10 CFR 54.21(b). Specifically, the process is used to identify and evaluate changes to the plant CLB by reviewing plant documents, which include but are not limited to the following:

Design Change Packages (DCPs)

UFSAR Updates Licensing Correspondence Piping & Instrumentation Drawings (P&IDs)/Boundary Drawings Generic Safety Issues TLAAs Procedure Reviews These changes are then reviewed by a technical verification team to determine those changes to the CLB that materially affect the LRA.

Review Results The review identified no changes to the CLB of the Limerick Generating Station that materially affect the contents of the LGS License Renewal Application, including the FSAR supplement.

Enclosure B Page 1 of 6 Enclosure B Revision to UFSAR Supplement related to the RAI 3.0.3.4-1 Response The following changes to the UFSAR Supplement (Appendix A) are made in relation to the RAI 3.0.3.4-1 response contained within Exelon Generation Company, LLC letter, Response to Requests for Additional Information and Minor Changes to the LRA Supplement dated March12, 2014 for the review of the Limerick Generating Station, Units 1 and 2, License Renewal Application, dated May 21, 2014.

Notes:

To facilitate understanding, portions of the original LRA (as modified through RAI responses) have been repeated in this Enclosure, with revisions indicated.

Existing LRA text is shown in normal font. Changes are highlighted with bold italics for inserted text and strikethroughs for deleted text.

Enclosure B Page 2 of 6 A.2.1.12 Open-Cycle Cooling Water System The Open-Cycle Cooling Water System (OCCWS) aging management program is an existing program that manages heat exchangers, piping, piping elements and piping components in safety-related and nonsafety-related raw water systems that are exposed to raw water and air/gas-wetted environments for loss of material, reduction of heat transfer, and hardening and loss of strength of elastomers. This is accomplished through tests and inspections per the guidelines of NRC Generic Letter 89-13. System and component testing, visual inspections, non-destructive examination (i. e. Radiographic Testing, Ultrasonic Testing and Eddy Current Testing), and chemical injection are conducted to ensure that aging effects are managed such that system and component intended functions and integrity are maintained.

The OCCWS includes those systems that transfer heat from safety-related structures, systems and components to the ultimate heat sink as defined in GL 89-13 as well as those raw water systems which are in scope for license renewal for spatial interaction but have no safety-related heat transfer function. Periodic heat transfer testing or inspection and cleaning of heat exchangers with a heat transfer intended function is performed in accordance with LGS commitments to GL 89-13 to verify heat transfer capabilities. Heat exchangers which have no safety-related heat transfer function are periodically inspected and cleaned.

Periodic volumetric inspections will be performed in the non-buried portions of the Safety Related Service Water System to provide a sufficient understanding of the buried service water piping conditions throughout the period of extended operation. The inspection locations are selected to ensure that conditions are similar (e. g. flow, temperature) to those in the buried portions of the Safety Related Service Water System piping.

The OCCWS aging management program also manages the loss of coating integrity in a raw water environment. Internal coatings in the service water side of the Main Control Room Chiller Condensers and Reactor Enclosure Cooling Water Heat Exchangers, and in circulating water system piping are visually inspected to ensure that loss of coating integrity is detected. The inspections of the Main Control Room Chiller Condensers and circulating water system piping will be performed by inspectors qualified to international standards endorsed in RG 1.54, including, ASTM D 4537-91 and ANSI N45.2.6-1978 to a minimum of level II. The inspections of the Reactor Enclosure Cooling Water Heat Exchangers will be performed by inspectors with a demonstrated working knowledge of EPRI Report 1019157, Guideline on Nuclear Safety-Related Coatings. Inspections are performed for signs of coating failures and precursors to coating failures including peeling, delamination, blistering, cracking, flaking, chipping, rusting, and mechanical damage.

When acceptance criteria are not met, visual inspection is supplemented by additional testing such as DFT (Dry Film Thickness), adhesion, continuity, or other inspection technique as determined by the qualified inspector to accurately assess coating condition.

Adhesion testing will be performed using international standards endorsed in RG 1.54. A coatings specialist qualified to ASTM D-7108 will evaluate the results of the coating inspections. Evaluations are performed for inspection results that do not satisfy established acceptance criteria and the conditions are entered into the LGS 10 CFR 50 Appendix B corrective action program. The corrective action program ensures that conditions adverse to quality are promptly corrected. Corrective actions may include coating repair or replacement prior to the component being returned to service.

The Open-Cycle Cooling Water System aging management program will be enhanced to:

Enclosure B Page 3 of 6

1. Perform internal inspection of buried Safety Related Service Water Piping when it is accessible during maintenance and repair activities

2. Perform periodic inspections for loss of material in the Nonsafety-Related Service Water System at a minimum of five locations on each unit once every refueling cycle.

3. Replace the supply and return piping for the Core Spray pump compartment unit coolers.

4. Replace degraded RHRSW piping in the pipe tunnel.

5. Perform periodic inspections for loss of material in the Safety Related Service Water System at a minimum of ten locations every two years.

The enhancements will be implemented prior to the period of extended operation.

Enclosure B Page 4 of 6 A.2.1.20 Fuel Oil Chemistry The Fuel Oil Chemistry aging management program is an existing mitigation and condition monitoring program that includes activities which provide assurance that contaminants are maintained at acceptable levels in fuel oil for systems and components within the scope of license renewal. The Fuel Oil Chemistry program manages loss of material in piping, piping elements, piping components and tanks in a fuel oil environment. The fuel oil tanks within the scope of license renewal are maintained by monitoring and controlling fuel oil contaminants in accordance with the Technical Specifications, Technical Requirements Manual, and ASTM guidelines. Fuel oil sampling and analysis is performed in accordance with approved procedures for new fuel oil and stored fuel oil. Fuel oil tanks are periodically drained of accumulated water and sediment, cleaned, and internally inspected. These activities effectively manage the effects of aging by maintaining potentially harmful contaminants at low concentrations.

The Fuel Oil Chemistry program also manages the loss of coating integrity in a fuel oil environment. Fuel oil tank internal coatings are visually inspected to ensure that loss of coating integrity is detected. The inspections will be performed by inspectors qualified to international standards endorsed in RG 1.54, including, ASTM D 4537-91 and ANSI N45.2.6-1978 to a minimum of level II. Inspections are performed for signs of coating failures and precursors to coating failures including peeling, delamination, blistering, cracking, flaking, chipping, rusting, and mechanical damage. When acceptance criteria are not met, visual inspection is supplemented by additional testing such as DFT (Dry Film Thickness), adhesion, continuity, or other inspection technique as determined by the qualified inspector to accurately assess coating condition. Adhesion testing will be performed using international standards endorsed in RG 1.54. A coatings specialist qualified to ASTM D-7108 will evaluate the results of the coating inspections.

Evaluations are performed for inspection results that do not satisfy established acceptance criteria and the conditions are entered into the LGS 10 CFR 50 Appendix B corrective action program. The corrective action program ensures that conditions adverse to quality are promptly corrected. Corrective actions may include coating repair or replacement prior to the component being returned to service.

The Fuel Oil Chemistry aging management program will be enhanced to:

1. Periodically drain water from the Fire Pump Engine Diesel Oil Day Tank and the Fire Pump Diesel Engine Fuel Tank.

2. Perform internal inspections of the Fire Pump Engine Diesel Oil Day Tank, the Fire Pump Diesel Engine Fuel Tank, and the Diesel Generator Day Tanks at least once during the 10-year period prior to the period of extended operation, and, at least once every 10 years during the period of extended operation. Each diesel fuel tank will be drained, cleaned and the internal surfaces either volumetrically or visually inspected. If evidence of degradation is observed during visual inspections, the diesel fuel tanks will require follow-up volumetric inspection.

3. Perform periodic analysis for total particulate concentration and microbiological organisms for the Fire Pump Engine Diesel Oil Day Tank and the Fire Pump Diesel Engine Fuel Tank.

Enclosure B Page 5 of 6

4. Perform periodic analysis for water and sediment and microbiological organisms for the Diesel Generator Diesel Oil Storage Tanks.

5. Perform periodic analysis for water and sediment content, total particulate concentration, and the levels of microbiological organisms for the Diesel Generator Day Tanks.

6. Perform analysis of new fuel oil for water and sediment content, total particulate concentration and the levels of microbiological organisms for the Fire Pump Engine Diesel Oil Day Tank and the Fire Pump Diesel Engine Fuel Tank.

7. Perform analysis of new fuel oil for total particulate concentration and the levels of microbiological organisms for the Diesel Generator Diesel Oil Storage Tanks.

These enhancements will be implemented prior to the period of extended operation.

Enclosure B Page 6 of 6 A.2.1.27 Lubricating Oil Analysis The Lubricating Oil Analysis aging management program is an existing program that provides oil condition monitoring activities to manage the loss of material and the reduction of heat transfer in piping, piping components, piping elements, heat exchangers, and tanks within the scope of license renewal exposed to a lubricating oil environment.

Sampling, analysis, and condition monitoring activities identify specific wear products and contamination and determine the physical properties of lubricating oil within operating machinery. These activities are used to verify that the wear product and contamination levels and the physical properties of lubricating oil are maintained within acceptable limits to ensure that intended functions are maintained.

The Lubricating Oil Analysis program also manages the loss of coating integrity in a lube oil environment. The RCIC turbine bearing pedestals and HPCI turbine bearing pedestals and oil reservoir internal coatings are visually inspected to ensure that loss of coating integrity is detected. The inspections will be performed by inspectors qualified to international standards endorsed in RG 1.54, including, ASTM D 4537-91 and ANSI N45.2.6-1978 to a minimum of level II. Inspections are performed for signs of coating failures and precursors to coating failures including peeling, delamination, blistering, cracking, flaking, chipping, rusting, and mechanical damage. When acceptance criteria are not met, visual inspection is supplemented by additional testing such as DFT (Dry Film Thickness), adhesion, continuity, or other inspection technique as determined by the qualified inspector to accurately assess coating condition. Adhesion testing will be performed using international standards endorsed in RG 1.54. A coatings specialist qualified to ASTM D-7108 will evaluate the results of the coating inspections.

Evaluations are performed for inspection results that do not satisfy established acceptance criteria and the conditions are entered into the LGS 10 CFR 50 Appendix B corrective action program. The corrective action program ensures that conditions adverse to quality are promptly corrected.