RS-17-157, Supplemental Information Regarding the Third Interval Containment Inservice Inspection (Cisi) Schedule for LaSalle County Station License Amendment Request for Extension of Type a and Type C Containment Leak Rate Test Intervals

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Supplemental Information Regarding the Third Interval Containment Inservice Inspection (Cisi) Schedule for LaSalle County Station License Amendment Request for Extension of Type a and Type C Containment Leak Rate Test Intervals
ML17312B441
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 11/08/2017
From: Simpson P
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-17-157
Download: ML17312B441 (5)


Text

4300 Winfield Road MW Warrenville, I L 60555 Exelon Generation 630 657 2000 Office RS-17-157 10 CFR 50.90 November 8, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Supplemental Information Regarding the Third Interval Containment Inservice Inspection (CISI) Schedule for LaSalle County Station License Amendment Request for Extension of Type A and Type C Containment Leak Rate Test Intervals

Reference:

1) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request to Revise Technical Specifications 5.5.13, 'Primary Containment Leakage Rate Testing Program,' for Permanent Extension of Type A and Type C Leak Rate Test Frequencies," dated October 26, 2016 (ADAMS Accession No. ML16300A200)

By a letter to the U.S. Nuclear Regulatory Commission (NRC) dated October 26, 2016, (Reference 1), Exelon Generation Company, LLC (EGC) submitted an amendment request for LaSalle County Station (LSCS), Units 1 and 2. The proposed amendment would revise the Technical Specifications (TS) 5.5.13, "Primary Containment Leakage Rate Testing Program,"

to allow for the permanent extension of the Type A integrated leak rate testing (ILRT) and Type C leak rate testing frequencies.

As discussed during a conference call with the NRC on November 2, 2017, supplemental information is being provided to support the NRC's review of the EGC request submitted on October 26, 2016 (Reference 1). The Attachment to this letter provides the supplemental information.

EGC has reviewed the information supporting a finding of no significant hazards consideration that was previously provided to the NRC in Attachment 1 of Reference 1. The supplemental information provided in this submittal does not affect the bases for concluding that the proposed license amendment request does not involve a significant hazards consideration. In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), EGC is notifying the State of Illinois of this application for license amendment by transmitting a copy of this letter and its Attachment to the designated State Official.

November 8, 2017 U.S. Nuclear Regulatory Commission Page 2 There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Ms. Lisa A. Simpson at (630) 657-2815.

declare under penalty of perjury that the foregoing is true and correct. Executed on the 8th day of November 2017.

Res ectfully, Patrick R. Simpson Manager Licensing Exelon Generation Company, LLC

Attachment:

Supplemental Information cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector, LaSalle County Station Illinois Emergency Management Agency Division of Nuclear Safety

ATTACHMENT Supplemental Information By a letter to the U.S. Nuclear Regulatory Commission (NRC) dated October 26, 2016, Exelon Generation Company, LLC (EGC) submitted a license amendment request (LAR) to revise the Technical Specifications (TS) 5.5.13, "Primary Containment Leakage Rate Testing Program," to allow for the permanent extension of the Type A integrated leak rate testing (ILRT) and Type C leak rate testing frequencies for LaSalle County Station (LSCS), Units 1 and 2.

As discussed during a conference call with the NRC on November 2, 2017, supplemental information is being provided to support the NRC's review of the October 2016 EGC request.

The following information is provided for the purpose of clarification.

References:

1) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request to Revise Technical Specifications 5.5.13, 'Primary Containment Leakage Rate Testing Program,' for Permanent Extension of Type A and Type C Leak Rate Test Frequencies," dated October 26, 2016 (ADAMS Accession No. ML16300A200)
2) Letter from Mark. J. Maxin (U.S. Nuclear Regulatory Commission) to J. C. Butler (U.S. Nuclear Regulatory Commission), "Final Safety Evaluation for Nuclear Energy Institute (NEI) Topical Report JR) 94-01, Revision 2,

'Industry Guideline for Implementing Performance-Based Option of 10 CFR Part 50, Appendix J' and Electric Power Research Institute (EPRI)

Report No. 1009325, Revision 2, August 2007, 'Risk Impact Assessment of Extended Integrated Leak Rate Testing Intervals' JAC No. MC9663)," dated June 25, 2008 The LSCS LAR (Reference 1) included a statement in Section 3.4.3 of Attachment 1 relative to the LSCS Third Interval Containment Inservice Inspection (CISI) Program Plan that was under development at the time of submittal of the LAR (i.e., October 26, 2016). The Third Interval CISI Interval is effective as of October 1, 2017, through September 30, 2027 for LSCS, Units 1 and 2.

In response to discussions with the NRC, EGC has evaluated the Safety Evaluation (SE) for NEI TR 94-01, Revision 2 (Reference 2), Limitations and Conditions 2 and SE Section 3.1.1.3.

Limitations and Conditions 2 for NEI TR 94-01, Revision 2, states the following:

The NRC staff finds that the use of NEI TR 94-01, Revision 2, is acceptable for referencing by licensees proposing to amend their TSs to permanently extend the ILRT surveillance interval to 15 years, provided the following conditions are satisfied:

2. The licensee submits a schedule of containment inspections to be performed prior to and between Type A tests. (Refer to SE Section 3.1.1.3).

Included in Tables 1 and 2 are the LSCS Third Interval CISI schedules, which were not originally provided in Reference 1. The schedule information provided in these tables demonstrates LaSalle's compliance with Limitations and Conditions 2 for NEI TR 94-01, Revision 2 (Reference 2).

Page 1 of 3

ATTACHMENT Supplemental Information Table 2 ISI Class CC-Concrete Component Examinations for LaSalle 2nd and 3rd Ten-Year Inspection Interval Unit 1 Unit 2 CISI Interval (ILRT 2008) (ILRT 2009)

L1 R12 2/2008 L2R12 2/2009 2nd Interval Pre- and Post- ILRT Examinations Pre- and Post- ILRT Examinations 10/1/07 to 9/30/17 completed 2/2008 completed 2/2009 L1 R13 2/2010 L2R13 2/2011 2nd Interval (30th Year) (25th Year) 10/1/07 to 9/30/17 Examination #1 completed Examination #1 completed 9/2010 3/2011 L1 R15 2/2014 L2R15 2/2015 2nd Interval (35th Year) (30th Year) 10/1/07 to 9/30/17 Examination #2 completed I Examination #2 completed 9/2014 4/2015 L1 R18 --2/2.020 L2R18 2/2021 3rd Interval (40th Year) (35th Year) 10/1/17 to 9/30/27 Examination #3 scheduled Examination #3 scheduled Ll R19 2/2022 L2R19 2/2023 3rd Interval Pre- and Post- ILRT Examinations Pre- and Post- ILRT Examinations 10/1/17 to 9/30/27 scheduled scheduled 3rd Interval L1 R20 2/2024 L2R20 2/2025 (45th Year) (40th Year) 10/1/17 to 9/30/27 Page 3 of 3

ATTACHMENT Supplemental Information Table 1 ISI Class MC Metal Component Examinations for LaSalle 2nd and 3rd Ten-Year Inspection Interval Unit 1 Unit 2 CISI Interval / Period (ILRT 2008) (ILRT 2009) 2nd Interval / L1 R13 2/2010 L2R12 2/2009 1st Period Pre- and Post- ILRT Examinations Pre- and Post- ILRT Examinations 10/1/07 to 9/30/10 completed 2/2008 completed 2/2009 L1 R14 2/2012 L2R13 2/2011 2nd Interval /

L1 R15 2/2014 L2R14 2/2013 2nd Period Examination #1 completed Examination #1 completed 10/1/10 to 9/30/14 3/2012 and 2/2014 3/2011 and 3/2013 L2R15 2/2015 2nd Interval / L1 R16 2/2016 L2R16 2/2017 3rd Period Examination #2 completed Examination #2 completed 10/1/14 to 9/30/17 3/2016 2/2015 3rd Interval / L1 R17 2/2018 L2R17 2/2019 1st Period L1 R18 2/2020 Examination #3 scheduled 10/1/17 to 9/30/20 Examination #3 scheduled L1 R19 2/2022 L2R18 2/2021 3rd Interval /

L1 R20 2/2024 L2R19 2/2023 2nd Period Pre- and Post- ILRT Examinations Pre- and Post- ILRT Examinations 10/1/20 to 9/30/24 scheduled in L1 R19 scheduled in L2R19 3rd Interval /

3rd Period L2R20 2/2025 L1 R21 2/2026 L2R21 2/2027 10/1/24 to 9/30/27 Page 2 of 3