ML20195D149
| ML20195D149 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 11/13/1998 |
| From: | Buckley B NRC (Affiliation Not Assigned) |
| To: | Geoffrey Edwards PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| References | |
| TAC-M83636, TAC-M83637, NUDOCS 9811170302 | |
| Download: ML20195D149 (5) | |
Text
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November 13, 1998 l
l Mr. Garrett D. Edwards Director-Licensing, MC 62A-1 PECO Energy Company Nuclear Group Headquarters
' Correspondence Control Desk P.O. Box No.195 Wayne, PA 19087-0195
SUBJECT:
LIMERICK GENERATING STATION (LGS), UNITS 1 AND 2, INDIVIDUAL PLANT EXAMINATION FOR EXTERNAL EVENTS (IPEEE), REQUEST FOR ADDITIONAL INFORMATION (RAl) (TAC NOS. M83636 AND M83637)
Dear Mr. Edwards:
The NRC staff is continuing its on-going review of your IPEEE submittal dated October 14,1995, and your responses to our requests for additional information. Based on our review, we find that additional information, as described in the enclosure, is required to proceed with our evaluation.
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On October 30,1998, we discussed the requested information with your staff and a 90-day response from your receipt of this letter was mutually acceptable. We understand that you will Inform us, in writing, by November 30,1998, on how you will address the second question of the i
enclosure regarding the effects of the new probable maximum precipitation at LGS, Units 1 and 2.
If you have any questions, please contact me at (301) 415-1483.
Sincerely, original signed by Bartholomew C. Buckley, Senior Project Manager Project Directorate 1-2 Division of Reactor Projects - 1/Il Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353
Enclosure:
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November 13, 1998 Mr. Garrett D. Edwards l
Director Licensing, MC 62A 1 I-PECO Energy Company Nuclear Group Headquar1ers Correspondence Control Desk P.O. Box No.195 Wayne, PA 19087-0195
SUBJECT:
LIMERICK GENERATING STATION (LGS), UNITS 1 AND 2, INDIVIDUAL PLANT EXAMINATION FOR EXTERNAL EVENTS (IPEEE), REQUEST FOR ADDITIONAL INFORMATION (RAI) (TAC NOS. M83636 AND M83637)
Dear Mr. Edwards:
The NRC staff is continuing its on going review of your IPEEE submittal dated October 14,1995, and your responses to our requests for additionalinformation. Based on our review, we find that additional information, as described in the enclosure, is required to proceed with our evaluation.
On October 30,1998, we discussed the requested information with your staff and a 90-day response from your receipt of this letter was mutually acceptable. We understand that you will inform us, in writing, by November 30,1998, on how you will address the second question of the enclosure regarding the effects of the new probable maximum precipitation at LGS, Units 1 and 2.
If you have any questions, please contact me at (301) 415-1483.
Sincerely, 6
,g gql b, R Bartholomew C. Buckley, Senior Project Manager Project Directorate 12 Division of Reactor Projects -l!Il 04 ice of Nuclear Reactor Regulation Docket Nos 50-352 and 50-353
Enclosure:
RAI cc w/ encl: See next page
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l Mr. Garrett D. Edwards Limerick Generating Station, Units 1 & 2 PECO Energy Company cc:
J. W. Durham, Sr., Esquire Chief-Division of Nuclear safety Sr. V.P. & General Counsel PA Dept. of Environmental Resources i
PECO Energy Company P.O. Box 8469 2301 Market Street Harrisburg, PA 17105-8469 Philadelphia, PA 19101 Manager-Limerick Licensing,62A-1 Director-Site Engineering PECO Energy Company Limerick Generating Station 965 Chesterbrook Boulevard P.O. Box A Wayne, PA 19087-5691 Sanatoga, PA 19464 Mr. James D. von Suskil, Vice President Limerick Generating Station Manager-Experience Assessment Post Office Box A Limerick Generating Station Sanatoga, PA 19464 P.O. Box A Sanatoga, PA 19464 Plant Manager i
Limerick Generating Station Library P.O. Box A U.S. Nuclear Regulatory Commission Sanatoga, PA 19464 Region 1 475 Allendale Road Regional Administrator, Region i King of Prussia, PA 19406 U.S. Nuclear Regulatory Commission 475 Allendale Road Senior Manager-00erations King of Prussia, PA 19406 Limerick Generating Station P.O. Box A Senior Resident inspector Sanatoga, PA 19464 U.S. Nuclear Regulatory Commission Limerick Generating Station Dr. Judith Johnsrud P.O. Box 596 National Energy Committee Pottstown, PA 19464 Sierra Club 433 Orlando Avenue Director-Site Support Services State College, PA 16803 Limerick Generating Station P.O. Box A Sanatoga, PA 19464 Chairman Board of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468 i
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LIMERICK IPEEE Supple' mental Request for AdditionalInformation QUESTION ON SEISMIC ANALYSIS In your response, dated July 24,1997, to a request for additional information on the seismic analysis, you note, in your response to Odestion 1d, that the units 1 and 2 condensate storage tanks (CST) and the refueling water storage tank (RWST) are seismic category ll.
Furthermore, you state that failure of these tanks, or of the auxiliary boiler fuel oil tank, will not result in flooding of safety related structures, systems, or components because the contents of these tanks would be contained within seismic category ll A earth dikes, which are designed to maintain their integrity during a SSE event. You state that, in accordance with the guidelines of supplement 5 to Generic Letter 88 20, soil-related failures of earthen dikes at 0.3g need not be evaluated. We believe this is a misapplication of supplement 5, and that the soil-related failures mentioned in supplement 5 refer to foundation failure from soilliquefaction.
The high confidence low probability of failure (HCLPF) capacities of each tank / dike pair has not been shown to be greater than the review level earthquake (RLE) of.3g. The impact of flooding from failures of these tanks (with concomitant failure of the corresponding dike) on the equipment in the safe shutdown equipment list (SSEL), including the effects of these failures on the preferred and altemate success paths, have not been evaluated.
Ifit cannot be shown that the HCLPF capacities for the units 1 and 2 CST, the RWST, and the auxiliary boiler fuel oil tank / dike pairs are equal to or greater than the RLE of.3g, please provide an evaluation of the effects of flooding from failures of each tank / dike pair (whose HCLPF value has not been shown to be greater than.3g) on the equipment in the SSEL, including the effects on the p1eferred and alternate success paths.
QUESTION ON THE HIGH WINDS, FLOODS, AND OTHER EXTERNAL EVENTS The Limerick Generating Station (LGS) IPEEE states, on page 5-29, that the intent of Generic Letter (GL) 89-22, " Potential for increased Roof Loads and Plant Area Flood Runoff Depth at Licensed Nuclear Power Plants due to Recent Change in Probable Maximum Precipitation Criteria Developed by the National Weather Service,"is met by LGS. The IPEEE submittal does show that the changes in the probable maximum flood caused by changes in the Probable Maximum Precipitation (PMP) will not affect the plant. The submittal also shows that the changes in PMP will not result in the failure of any safety-related roof, since the roofs are designed to withstand the loadings from water up to the top of the roof parapets. However, the submittal does not show that the flood runoff depth and site ponding from the revised PMP will not affect safety related equipment. We note further that, even without the revised PMP, the Updated Final Safety Analysis Report (UFSAR), in Section 2.4.2.3.3.1, found that peak water levels at the collection points CP-3, CP-4, and CP-6 in the power block area were greater than 218 feet, while there are openings to safety related buildings below this level. For example, there are personnel doors to the outside from the diesel generator building at elevation 217 feet (see the UFSAR, table 2.41). The UFSAR does not indicate what the water levels are at the location of the personnel doors to the diesel generator building, or at the other openings to the safety related buildings in the power block, or what the effects of water leakage through these ENCIOSURE
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openings would be. For example, water could leak under the doors to the diesel generator building, if the water level at the door were greater than 217 feet.
NUREG-1407, in Section 2.4 and Section 6.2.2.3, requests that licensees assess the effects of the revised PMP criteria on onsite flooding, in their IPEEE submittal, Please provide an assessment of the effects of the revised PMP on the flood runoff depth at the i
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site, and the effects of the flood runoff depth on safety-related equipment. Include the effects of site ponding.
Please provide, in your response, the waterlevels at the location of the openings to the safety-relatedbuildings in the power block, such as the personneldoors to the dieselgenerator building.
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