ML24201A166
| ML24201A166 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/19/2024 |
| From: | Para W Constellation Energy Generation |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| Download: ML24201A166 (1) | |
Text
200 Energy Way Kennett Square, PA 19348 www.constellation.com 10 CFR 50.90 July 19, 2024 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353
Subject:
Response to Request for Additional Information for License Amendment Request for Proposed Changes to the Technical Specification Isolation Actuation Instrumentation Tables and New Turbine Enclosure Main Steam Line Tunnel Temperature TS 3/4.7.9
References:
- 1. Letter from David P. Helker, Constellation Energy Generation, LLC to the U.S. Nuclear Regulatory Commission, License Amendment Request for Proposed Changes to the Technical Specification Isolation Actuation Instrumentation Tables and New Turbine Enclosure Main Steam Line Tunnel Temperature TS 3/4.7.9, dated June 13, 2024 (ADAMS Accession No. ML24165A264).
- 2. Email from Elena Herrera Torres, U.S. Nuclear Regulatory Commission to Stephen Flickinger, Constellation Energy Generation, LLC, RAI-LAR for Limerick EPID: L-2024-LLA-0079, dated July 15, 2024 (ADAMS Accession No. ML24199A184).
By letter dated June 13, 2024, Constellation Energy Generation, LLC (CEG) submitted an application for amendment to the Technical Specifications (TS) for Limerick Generating Station, Units 1 and 2 (Reference 1). CEG requested a license amendment to revise the Technical Specifications (TS) isolation actuation instrumentation tables and to add a new TS 3/4.7.9, Turbine Enclosure - Main Steam Line Tunnel Temperature. By email dated July 15, 2024, the U.S. Nuclear Regulatory Commission (NRC) notified CEG that additional information was needed to complete the review of the license amendment request (Reference 2). CEGs response to the NRCs Request for Additional Information is provided in Attachment 1.
CEG has reviewed the information supporting the No Significant Hazards Consideration and the Environmental Consideration that was previously provided to the NRC in Reference 1. The information in this response does not impact the conclusion that the
U.S. Nuclear Regulatory Commission Response to Request for Additional Information - LGS MSL Tunnel Temperature July 19, 2024 Page 2 proposed license amendments do not involve a significant hazards consideration. The information also does not impact the conclusion that there is no need for an environmental assessment to be prepared in support of the proposed amendments.
There are no regulatory commitments contained in this response.
In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"
paragraph (b), CEG is notifying the Commonwealth of Pennsylvania of this response to request for additional information by transmitting a copy of this letter to the designated State Official.
If you have any questions regarding this submittal, then please contact Steve Flickinger at 267-533-5302.
I declare under penalty of perjury that the foregoing is true and correct. Executed on this 19th day of July 2024.
Respectfully, Wendi Para Sr. Manager - Licensing Constellation Energy Generation, LLC
Attachment:
Response to Request for Additional Information cc:
Regional Administrator - NRC Region I w/ attachment NRC Senior Resident Inspector - Limerick Generating Station NRC Project Manager, NRR - Limerick Generating Station "
Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection "
ATTACHMENT Response to Request for Additional Information License Amendment Request for Proposed Changes to the Technical Specification Isolation Actuation Instrumentation Tables and New Turbine Enclosure Main Steam Line Tunnel Temperature TS 3/4.7.9 Docket Nos. 50-352 and 50-353 By letter dated June 13, 2024, Constellation Energy Generation, LLC (CEG) submitted an application for amendment to the Technical Specifications (TS) for Limerick Generating Station, Units 1 and 2 (Reference 1). CEG requested a license amendment to revise the Technical Specifications (TS) isolation actuation instrumentation tables and to add a new TS 3/4.7.9, Turbine Enclosure - Main Steam Line Tunnel Temperature. By email dated July 15, 2024, the U.S. Nuclear Regulatory Commission (NRC) notified CEG that additional information is needed to complete the review of the license amendment request (Reference 2). CEGs response to the NRCs Request for Additional Information is provided in below.
Request for Additional Information:
The license amendment request (LAR) indicates that if the turbine enclosure (TE) main steam line (MSL) tunnel maximum temperature exceeds 175°F, then operators would be alerted to take action. The proposed Action would require immediate action to verify that there is no leakage from the MSL pressure boundary within the TE MSL tunnel (i.e., to determine whether there is an MSL pressure boundary leak), and periodic verification every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter.
The Technical Specification Bases provided in the LAR states that operators would determine if there is a leak from the MSL pressure boundary and lists possible indications of an MSL leak.
The LAR states that the area monitored in the TE MSL tunnel has elevated radiation levels and adverse environmental conditions and that the 12-hour completion time balances the small likelihood of a MSL pressure boundary leak occurring since the last verification against the risks of exposing workers to the radiological and environmental conditions to perform the verification.
Confirm whether detecting MSL pressure boundary leakage involves any of the following and, if yes, please describe the actions, context, or training:
A. any new or modified actions required for operators that are not similar to other actions with which operators are familiar B. any new context (e.g., environmental conditions or indications) in which operators must perform actions C. any new or modified required training on how to verify MSL pressure boundary leakage
Response
A. No. There are no new or modified actions required for plant personnel to verify MSL pressure boundary leakage. The new Surveillance Requirements manual action is similar to already established actions in which plant personnel are familiar in visually verifying pressure boundary leakage.
Attachment:
Response to Request for Additional Information Page 2 of 2 B. No. There are no Human Factor activities that are new or different for identifying and monitoring a leak from plant structures, systems and components or establishing stay time limits for personnel environmental habitability/radiation exposure using existing procedures and processes.
C. No. There is no new or modified required training on how plant personnel verify there is or is not a MSL pressure boundary leak.
References:
- 1. Letter from David P. Helker, Constellation Energy Generation, LLC to the U.S. Nuclear Regulatory Commission, License Amendment Request for Proposed Changes to the Technical Specification Isolation Actuation Instrumentation Tables and New Turbine Enclosure Main Steam Line Tunnel Temperature TS 3/4.7.9, dated June 13, 2024 (ADAMS Accession No. ML24165A264).
- 2. Email from Elena Herrera Torres, U.S. Nuclear Regulatory Commission to Stephen Flickinger, Constellation Energy Generation, LLC, RAI-LAR for Limerick EPID: L-2024-LLA-0079, dated July 15, 2024 (ADAMS Accession No. ML24199A184).