RS-15-238, Response to NRC Requests for Additional Information, Set 10, Dated August 27, 2015 Related to License Renewal Application

Response to NRC Requests for Additional Information, Set 10, Dated August 27, 2015 Related to License Renewal Application

ML15260A319
Person / Time
Site:	LaSalle
Issue date:	09/17/2015
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-15-238, TAC MF5346, TAC MF5347
Download: ML15260A319 (15)

Text

Michael P. Gallagher Exelon Generation Vice President. License Renewal Exelon Nuclear 200 Exelon Way RS-15-238 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 September 17, 2015 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001

References:

LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-37 4 Response to NRC Requests for Additional Information, Set 10, dated August 27, 2015 related to the LaSalle County Station, Units 1 and 2, License Renewal Application (TAC Nos. MF5347 and MF5346)

1. Letter from Michael P. Gallagher, Exelon Generation Company LLC (Exelon),

to NRC Document Control Desk, dated December 9, 2014, "Application for Renewed Operating Licenses"

2. Letter from Jeffrey S. Mitchell, US NRC to Michael P. Gallagher, Exelon, dated August 27, 2015, "Requests for Additional Information for the Review of the LaSalle County Station, Units 1 and 2 License Renewal Application - Set 10 (TAC Nos. MF5347 and MF5346)"

In Reference 1, Exelon Generation Company, LLC (Exelon) submitted the License Renewal Application (LRA) for the LaSalle County Station (LSCS), Units 1 and 2. In Reference 2, the NRC requested additional information to support staff review of the LRA.

Enclosure A contains the response to this request for additional information.

Enclosure B contains updates to sections of the LRA (except for the License Renewal Commitment List) affected by the response.

Enclosure C provides an update to the License Renewal Commitment List (LRA Appendix A, Section A.5). There are no other new or revised regulatory commitments contained in this letter.

September 17, 2015 U.S. Nuclear Regulatory Commission Page 2 If you have any questions, please contact Mr. John Hufnagel, Licensing Lead, LaSalle License Renewal Project, at 610-765-5829.

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

Executed on P9.,,..17.,,.. 2.<J /J-Respectfully, Vice President - License Renewal Projects Exelon Generation Company, LLC

Enclosures:

A: Responses to Set 10 Requests for Additional Information B: LSCS License Renewal Application Updates C: LSCS License Renewal Commitment List Updates cc:

Regional Administrator-NRC Region Ill NRC Project Manager (Safety Review), NRR-DLR NRC Project Manager (Environmental Review), NRR-DLR NRC Project Manager, NRR-DORL-LaSalle County Station NRC Senior Resident Inspector, LaSalle County Station Illinois Emergency Management Agency - Division of Nuclear Safety

RS-15-238 Enclosure A Page 1 of 4 Enclosure A Response to Set 10 Request for Additional Information Related to various sections of the LaSalle County Station (LSCS)

License Renewal Application (LRA)

Follow-up RAI 2.3.3.12-2a

RS-15-238 Enclosure A Page 2 of 4 Follow-up RAI 2.3.3.12-2a

Background:

In its response to RAI 2.3.3.12-2, dated July 1, 2015, regarding scoping and screening related to the smoke and heat vent housings, the applicant stated the following:

Smoke and heat vent housings are located in the LSCS Turbine Building roof.

These smoke and heat vent housings are not relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commissions regulations for Fire Protection, specifically considering the regulations applicable to LSCSs current licensing basis: 10 CFR 50.48, Branch Technical Position (BTP) ASB 9.5-1, Appendix R to Part 50 - Fire Protection Program for Nuclear Power Facilities, and the associated Safety Evaluation Report for LSCS Fire Protection. The BTP discusses smoke and heat vents in support of manual fire fighting for some areas, such as cable spreading rooms, diesel fuel oil storage areas, and switchgear rooms. It does not discuss the Turbine Building smoke and heat vents in this regard. The Turbine Building roof smoke and heat vent housings are discussed in the UFSAR and Fire Protection Report. There is no connection between the BTP manual fire fighting support statement and the Turbine Building roof vent housing discussions. The UFSAR and Fire Protection report information is provided for completeness of the area description and does not imply that the vent housings are required or credited for implementation of regulatory requirements. The smoke and heat vent housings are not safety-related nor relied upon to remain functional during design basis events, and the failure of these nonsafety-related components would not prevent the accomplishment of safety-related functions. The smoke and heat vent housings are not relied upon to demonstrate compliance with the Commissions regulations for Environmental Qualification, Anticipated Transient Without Scram, or Station Blackout. Therefore, the smoke and heat vent housings do not perform a license renewal intended function. They are not in scope for license renewal and therefore are not subject to AMR.

Issue:

The applicant stated that the turbine building smoke and heat vents do not have fire protection intended functions required for compliance with Title 10 of the Code of Federal Regulations (10 CFR), Part 50.48, Fire Protection. Additionally, the applicant stated that the turbine building smoke and heat vents are not relied upon in safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commissions regulations for Fire Protection, specifically considering the regulations applicable to LaSalle County Stations (LSCSs) current licensing basis (CLB). The licensee concluded that the smoke and heat vent housings are not within the scope of license renewal and not subject to an aging management review (AMR).

The staff finds the applicants response contrary to the Updated Final Safety Analysis Report (UFSAR) and Fire Protection Report (FPR), Rev. 6, which include the original LSCS Fire Protection program as the CLB. FPR Section H.3.5.3, Turbine Operating Floor and Heater Bay

- Fire Zone 5A3, subsection Description, states, in part:

RS-15-238 Enclosure A Page 3 of 4 Fusible link type heat and smoke vents are provided on the turbine building roof.

The criteria for sizing these vents is a vent ratio of one to one hundred for the combined floor area of the main turbine floor and the heater bay. Motorized outside doors are provided for intake air for heat and smoke venting.

FPR Section H.3.5.3, subsection Safety-Related Equipment, states that [t]his zone contains safety related HVAC monitoring instrumentation.

Additionally, FPR Section H.3.5.3, subsection Design-Basis Fire states:

The design-basis fire would be contained within the turbine building. It is possible for oil, in the unlikely event of a line rupture, to leak down to the zone below; however, that zone is completely protected by automatic sprinklers. The automatic sprinklers are designed to extinguish an oil fire and the automatic smoke and heat vents would prevent heat from building up and causing any flashover.

Fire Zone 5A3 contains safety related HVAC monitoring instrumentation and equipment, and the fire protection system consists of the automatic sprinkler system and automatic smoke and heat vents noted above. According to LSCSs FPR, following an oil fire in Fire Zone 5A3, automatic smoke and heat vents would prevent heat from building up and causing any flashover. Based on the LSCS CLB, turbine building smoke and heat vents were credited to meet the guidance of BTP ASB 9.5-1. The turbine building automatic smoke and heat vent housings should not be excluded from the scope of license renewal on the basis that they are not required to function during a fire, or on not being required for compliance to 10 CFR 50.48, without factoring in the CLB.

For the above reasons, the staff determined that the turbine building smoke and heat vent housings in question must be managed during the period of extended operation to-comply with 10 CFR 50.48 (in accordance with the current licensing basis) as stated in 10 CFR 54.4(a)(3).

Request:

Provide information to demonstrate that the effects of aging will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation as required by 10 CFR 54.21(a)(3).

RS-15-238 Enclosure A Page 4 of 4 Exelon Response:

The Turbine Building smoke and heat vents are added to the scope of license renewal. They are active components, and are not subject to aging management review. The Turbine Building smoke and heat vent housings are passive components, and are added to the scope of the Structures Monitoring (B.2.1.34) aging management program to specifically identify these components. The program is enhanced to include the smoke and vent housings in the program scope. These components will be inspected for loss of material.

LRA Sections 2.3.3.12 and 2.4.13, LRA Table 2.4-13, LRA Table 3.5.2-13, LRA Appendix A, Section A.2.1.34, and LRA Appendix B, Section B.2.1.34 are revised as shown in Enclosure B to include aging management of these components. LRA Table A.5, Commitment 34 is revised as shown in Enclosure C to reflect this change.

RS-15-238 Enclosure B Page 1 of 7 Enclosure B LSCS License Renewal Application Updates Resulting from the Response to the following RAI:

Follow-up RAI 2.3.3.12-2a Note: To facilitate understanding, portions of the LRA have been repeated in this Enclosure, with revisions indicated. Previously submitted information is shown in normal font.

Changes are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

RS-15-238 Enclosure B Page 2 of 7 As a result of the response to Follow-up RAI 2.3.3.12-2a provided in Enclosure A of this letter, the third paragraph of the Boundary subsection of LRA Section 2.3.3.12, beginning on the bottom of page 2.3-82 of the LRA, is revised as follows:

2.3.3.12 Fire Protection System Also included in the system evaluation boundary are the physical plant design features that consist of fire barrier walls and slabs, fire barrier penetration seals, fire doors and dampers, Turbine Building smoke and heat vents, fire wraps, and flammable fluid retention curbs and walls. This includes fire dampers in the Reactor Buildings, Turbine Buildings, Auxiliary Building, Lake Screen House, Radwaste Building, and Diesel Generator Buildings. The fire damper housings are subject to aging management review. The fire barrier function of all fire damper housings is evaluated with the Fire Protection System for license renewal aging management review. The pressure boundary function of the fire damper housings, if applicable, is evaluated with the appropriate ventilation system. However, the dampers are active components and are not subject to aging management review. Similarly, the Turbine Building smoke and heat vents are active components and are not subject to aging management review. The Turbine Building smoke and heat vent housings are evaluated with the Turbine Building structure. The Fire Protection System includes fire rated doors in the Reactor Buildings, Turbine Buildings, Auxiliary Building, and Diesel Generator Buildings. Air supervised preaction sprinkler systems are provided with individual air compressors to maintain air pressure. These compressors are active components and are not subject to aging management review.

As a result of the response to Follow-up RAI 2.3.3.12-2a provided in Enclosure A of this letter, the first sentence of the sixth paragraph of LRA Section 2.4.13, on page 2.4-59 of the LRA, is revised as follows:

2.4.13 Turbine Building Included in the boundary of the Turbine Building and determined to be within the scope of license renewal are the blowout panels, concrete anchors, concrete embedments, curbs, equipment supports and foundations, hatches, plugs, masonry walls, metal decking, metal siding, pipe whip restraints, reinforced concrete elements of the building, smoke and heat vent housings, steel components, steel elements, and structural bolting.

RS-15-238 Enclosure B Page 3 of 7 As a result of the response to Follow-up RAI 2.3.3.12-2a provided in Enclosure A of this letter, a new component type is added to LRA Table 2.4-13, which begins on page 2.4-61 of the LRA, as shown below:

Table 2.4-13 Turbine Building Components Subject to Aging Management Review Component Type Intended Function Blowout Panels Pressure Relief Bolting (Structural)

Structural Support Concrete Anchors Structural Support Concrete Curbs Flood Barrier Concrete Embedments Structural Support Concrete: Above-grade Exterior (accessible areas)

Flood Barrier Shelter, Protection Structural Support Concrete: Above-grade Exterior (inaccessible areas)

Flood Barrier Shelter, Protection Structural Support Concrete: Below-grade Exterior (inaccessible areas)

Flood Barrier Shelter, Protection Structural Support Concrete: Foundation, Subfoundation (inaccessible areas)

Flood Barrier Shelter, Protection Structural Support Concrete: Interior Flood Barrier Shelter, Protection Shielding Structural Support Equipment Supports and Foundations Structural Support Hatches/Plugs Shelter, Protection Shielding Structural Support Masonry Walls: Above-grade Exterior Shelter, Protection Shielding Structural Support Masonry Walls: Interior Shelter, Protection Shielding Structural Support Metal Decking Shelter, Protection Structural Support Metal Siding Pressure Relief Shelter, Protection Pipe Whip Restraints Pipe Whip Restraint Smoke and Heat Vent Housings Direct Flow Shelter, Protection

RS-15-238 Enclosure B Page 4 of 7 As a result of the response to Follow-up RAI 2.3.3.12-2a provided in Enclosure A of this letter, a new component type is added to the affected portion of LRA Table 3.5.2-13, which was contained on LRA page 3.5-234, as shown below:

Table 3.5.2-13 Turbine Building (Continued)

Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Item Table 1 Item Notes Pipe Whip Restraints Pipe Whip Restraint Carbon Steel Air - Indoor Uncontrolled Loss of Material Structures Monitoring (B.2.1.34)

III.A3.TP-302 3.5.1-77 C

Stainless Steel Air - Indoor Uncontrolled None None III.B5.TP-8 3.5.1-95 A

Smoke and Heat Vent Housings Direct Flow Galvanized Steel Air - Indoor Uncontrolled None None III.B5.TP-8 3.5.1-95 C

Air - Outdoor Loss of Material Structures Monitoring (B.2.1.34)

III.B2.TP-6 3.5.1-93 C

Shelter, Protection Galvanized Steel Air - Indoor Uncontrolled None None III.B5.TP-8 3.5.1-95 C

Air - Outdoor Loss of Material Structures Monitoring (B.2.1.34)

III.B2.TP-6 3.5.1-93 C

Steel Components:

Structural Steel Structural Support Carbon Steel Air - Indoor Uncontrolled Loss of Material Structures Monitoring (B.2.1.34)

III.A3.TP-302 3.5.1-77 A

RS-15-238 Enclosure B Page 5 of 7 As a result of the response to Follow-up RAI 2.3.3.12-2a provided in Enclosure A of this letter, LRA Appendix A, Section A.2.1.34, beginning on page A-34 of the LRA is revised to add an item to Enhancement 1 as shown below:

A.2.1.34 Structures Monitoring The Structures Monitoring aging management program is an existing condition monitoring program that was developed to implement the requirements of 10 CFR 50.65 and is based on NUMARC 93-01, Revision 2 Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, and Regulatory Guide 1.160, Revision 2 Monitoring the Effectiveness of Maintenance at Nuclear Power Plants. The program includes elements of the Masonry Walls (A.2.1.33) program and the RG 1.127, Inspection of Water-Control Structures Associated with Nuclear Power Plants (A.2.1.35) program. The program consists of periodic inspection and monitoring the condition of structures and structural component supports, to ensure that aging degradation leading to loss of intended functions will be detected and the extent of degradation can be determined. The inspections are conducted on a frequency not to exceed five years. Groundwater will be periodically sampled on a five-year frequency, and tested to ensure the groundwater remains non-aggressive.

The Structures Monitoring aging management program will be enhanced to:

1. Add the following components and commodities:

a. Pipe, electrical, and equipment component support members

b. Pipe whip restraints and jet impingement shields

c. Panels, racks, cabinets, and other enclosures

d. Sliding surfaces

e. Sumps

f.

Electrical cable trays and conduits

g. Electrical duct banks

h. Tube tracks

i.

Transmission tower (including takeoff towers) and foundation (including cycled condensate storage tank foundations)

j.

Penetration seals and sleeves

k. Blowout panels

l.

Permanent drywell shielding

m. Transformer foundation

n. Bearing pads

RS-15-238 Enclosure B Page 6 of 7

o. Compressible joints

p. Hatches, plugs, handholes, and manholes

q. Metal components (decking, vent stack, and miscellaneous steel)

r. Building features - doors and seals, bird screens, louvers, windows, and siding

s. Concrete curbs and anchors

t. Turbine Building smoke and heat vent housings

RS-15-238 Enclosure B Page 7 of 7 As a result of the response to Follow-up RAI 2.3.3.12-2a provided in Enclosure A of this letter, the Enhancements subsection of LRA Appendix B, Section B.2.1.34, beginning on page B-146 of the LRA is revised to add an item to Enhancement 1 as shown below:

B.2.1.34 Structures Monitoring Enhancements Prior to the period of extended operation, the following enhancements will be implemented in the following program elements:

1. Add the following components and commodities:

a. Pipe, electrical, and equipment component support members

b. Pipe whip restraints and jet impingement shields

c. Panels, racks, cabinets, and other enclosures

d. Sliding surfaces

e. Sumps

f.

Electrical cable trays and conduits

g. Electrical duct banks

h. Tube tracks

i.

Transmission tower (including takeoff towers) and foundation (including cycled condensate storage tank foundations)

j.

Penetration seals and sleeves

k. Blowout panels

l.

Permanent drywell shielding

m. Transformer foundation

n. Bearing pads

o. Compressible joints

p. Hatches, plugs, handholes, and manholes

q. Metal components (decking, vent stack, and miscellaneous steel)

r. Building features - doors and seals, bird screens, louvers, windows, and siding

s. Concrete curbs and anchors

t. Turbine Building smoke and heat vent housings

RS-15-238 Enclosure C Page 1 of 2 Enclosure C LSCS License Renewal Commitment List Updates This Enclosure identifies commitments made in this document and is an update to the LSCS LRA Appendix A, Table A.5 License Renewal Commitment List. Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRCs information and are not regulatory commitments.

Changes to the LSCS LRA Appendix A, Table A.5 License Renewal Commitment List are as a result of the Exelon response to the following RAI:

Follow-up RAI 2.3.3.12-2a Note: To facilitate understanding, relevant portions of the previously submitted License Renewal Commitment List have been repeated in this Enclosure, with revisions indicated.

Previously submitted information is shown in normal font. Changes due to this submittal are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

RS-15-238 Enclosure C Page 2 of 2 As a result of the response to Follow-up RAI 2.3.3.12-2a provided in Enclosure A of this letter, LRA Appendix A, Section A.5, Commitment 34, beginning on page A-74 of the LRA is revised to add an item to Enhancement 1 as shown below:

A.5 License Renewal Commitment List NO.

PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE SOURCE 34 Structures Monitoring Structures Monitoring is an existing program that will be enhanced to:

1. Add the following components and commodities:

a.

Pipe, electrical, and equipment component support members

b.

Pipe whip restraints and jet impingement shields

c.

Panels, racks, cabinets, and other enclosures

d.

Sliding surfaces

e.

Sumps

f.

Electrical cable trays and conduits

g.

Electrical duct banks

h.

Tube tracks

i.

Transmission tower (including takeoff towers) and foundation (including cycled condensate storage tank foundations)

j.

Penetration seals and sleeves

k.

Blowout panels

l.

Permanent drywell shielding

m. Transformer foundation

n.

Bearing pads

o.

Compressible joints

p.

Hatches, plugs, handholes, and manholes

q.

Metal components (decking, vent stack, and miscellaneous steel)

r.

Building features - doors and seals, bird screens, louvers, windows, and siding

s.

Concrete curbs, and anchors

t. Turbine Building smoke and heat vent housings Program to be enhanced prior to the period of extended operation.

Section A.2.1.34 Exelon Letter RS-15-180 7/15/2015 Exelon Letter RS-15-238 09/17/2015