ML25097A176
| ML25097A176 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 04/10/2025 |
| From: | Constellation Energy Generation |
| To: | Division of Operating Reactor Licensing |
| References | |
| EPID L-2025-LRM-0024 | |
| Download: ML25097A176 (1) | |
Text
Limerick One-Time Extension of Type A (ILRT) LAR April 10, 2025
- Introductions
- Meeting Objectives
- Background Information
- Scope of Technical Specification Changes
- Justification
- Review of Proposed LAR Submittal
- Overview of Submittal Schedule
- Summary and Wrap-up
- Questions Agenda 1
Limerick One-Time Extension of Type A (ILRT) LAR
Corporate Licensing Engineers - Ronnie Reynolds, Lane Oberembt Corporate Licensing Senior Manager - Wendi Para Corporate/Limerick Risk Engineer - Connelly Richards Limerick Regulatory Assurance Manager - Jordan Rajan Limerick Regulatory Assurance Engineers - George Budock, Renee Guy Corporate Engineering - Brian Mast, Mark Weis Limerick Coatings Engineer - Mark Legutko
Introductions
2 Limerick One-Time Extension of Type A (ILRT) LAR
- Present information to the NRC to provide a clear understanding of the overall project and proposed Limerick License Amendment Request (LAR)
- One-time extension to TS 6.8.4.g Primary Containment Leakage Rate Testing Program and corresponding extension of TS 4.6.2.1.e Drywell-to-Suppression Chamber Bypass Leak Test (DWBT).
- TS 4.6.2.1.e does not require a revision since it states the DWBT will be conducted to coincide with the Type A test, but no specific frequency is listed.
- Obtain feedback from the NRC on the proposed LAR to ensure a high-quality submittal and minimize Requests for Additional Information (RAIs)
- Establish a mutual understanding of the proposed schedule and corresponding need date to ensure adequate NRC resource availability Meeting Objectives 3
Limerick One-Time Extension of Type A (ILRT) LAR
- TS 3/4.6.1.2 requires the overall integrated leakage rate (ILRT) Type A test to be performed in accordance with the Primary Containment Leakage Rate Testing Program, described in TS 6.8.4.g.
- TS 3/4.6.2.1.e requires the drywell-to-suppression chamber bypass leak test to coincide with the Type A test.
- TS 6.8.4.g requires the Primary Containment Leakage Rate Testing Program to be in accordance with NEI 94-01 Industry Guideline for Implementing Performance-Based Option of 10 CFR 50, Appendix J, Rev. 3-A, dated July 2012, and the Limitations and Conditions specified in NEI 94-01, Rev. 2-A, dated October 2008.
- Limerick TS Amendments 241/204 (U1/U2) extended the interval between Type A tests from 10 years to 15 years and updated the associated references.
- The U1 ILRT was last performed in March 2012 and is due March 2027; it is scheduled April 2026 (Li1R21).
- The U2 ILRT was last performed in April 2013 and is due April 2028; it is scheduled April 2027 (Li2R19).
- Limerick Digital Modernization Project is currently scheduled for implementation during Li1R21 & Li2R19.
Background Information 4
Limerick One-Time Extension of Type A (ILRT) LAR
The LAR for a one-time extension to TS 6.8.4.g is proposing a change to Limerick TS 6.8.4.g to extend the performance of the next Type A test to no later than April 2028 for Unit 1 (13-month extension) and April 2029 for Unit 2 (12-month extension).
In addition, the proposed change would allow the Type A test to be extended indefinitely if the test interval ends while primary containment integrity is not required (i.e., TS 3.6.1, "Primary Containment," does not require the primary containment to be operable in Modes 4 and 5). In this case, the Type A test would be performed prior to entering Mode 2.
The proposed change would also administratively update the impacted TS Sections with minor formatting changes to align Unit 1 and Unit 2 TS requirements.
Scope of Technical Specification Changes 5
Limerick One-Time Extension of Type A (ILRT) LAR
- Prior performance of Type A (ILRT) tests have confirmed that the containment is acceptable with considerable margin to the TS acceptance criteria.
- No modifications requiring a post-maintenance verification Type A test are planned prior to the Spring 2028 (U1) and Spring 2029 (U2) refueling outages.
- Type B and Type C tests (part of the Primary Containment Leakage Rate Program but not being modified with this LAR) have also demonstrated acceptable results.
- Due to the extensive impact on various systems, CEG is maintaining focus on implementing a first-in-the-industry Digital Modernization Project Justification Limerick One-Time Extension of Type A (ILRT) LAR 6
- Prior LAR approval to disable the Redundant Reactivity Control Systems (RRCS) 30 days prior to start of DMP outage to assist in an efficient and safe installation of the digital upgrades.
- Independent risk assessment determined that increasing the interval between ILRTs resulted in a risk increase that fell well below the very small risk change as defined in RG 1.174.
- Various Containment Inspection Programs including the Protective Coatings Program (both Drywell and Suppression Pool) and In-Service Inspection Programs (Liner, Concrete, Penetrations) have shown continuing acceptable results.
Justification cont.
Limerick One-Time Extension of Type A (ILRT) LAR 7
Unit 1 Unit 2 Limerick One-Time Extension of Type A (ILRT) LAR 8
Review of Proposed LAR Submittal
- Pre-submittal Meeting with NRC to Discuss LAR - April 10, 2025
- Request NRC approval by March 31, 2026, to support implementation of the Digital Modernization Project changes in Li1R21 (spring 2026) and Li2R19 (spring 2027).
- Performance of the next ILRT Type A test in Li1R22 (spring 2028) and Li2R20 (spring 2029).
Overview of Submittal Schedule 9
Limerick One-Time Extension of Type A (ILRT) LAR
- Extend Type A (ILRT) interval by 13 months for Unit 1 and 12 months for Unit 2 to allow performance during the refueling outages immediately after installation of the Digital Modernization Project.
- Continue to perform other scheduled inspections in support of Primary Containment Leakage Rate Testing Program as planned during upcoming refueling outages.
Summary and Wrap-up 10 Limerick One-Time Extension of Type A (ILRT) LAR
Questions Limerick One-Time Extension of Type A (ILRT) LAR 11
Supplemental Information Limerick One-Time Extension of Type A (ILRT) LAR 12
TS 3.6.1.2 TS 4.6.2.1.e Supplemental Information 13 Limerick One-Time Extension of Type A (ILRT) LAR
TS 6.8.4.g Supplemental Information cont.