RS-15-016, Response to NRC Request for Additional Information, Set 1, Dated May 14, 2015 Related to the License Renewal Application

Response to NRC Request for Additional Information, Set 1, Dated May 14, 2015 Related to the License Renewal Application

ML15159A980
Person / Time
Site:	LaSalle
Issue date:	06/08/2015
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-15-0164, TAC MF5346, TAC MF5347
Download: ML15159A980 (8)

Text

Michael P. Gallagher Exelon Generation Vice President. License Renewal Exelon Nuclear 200 Exelon Way RS-15-164 June 08, 2015 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 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 50-374 Response to NRC Requests for Additional Information, Set 1, dated May 14, 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 May 14, 2015, "Requests for Additional Information for the Review of the LaSalle County Station, Units 1 and 2 License Renewal Application - Set 1 (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 responses to this request for additional information.

Enclosure B contains updates to sections of the LRA affected by the responses.

There are no new or revised regulatory commitments contained in this letter.

June 08, 2015 U.S. Nuclear Regulatory Commission Page 2 If you have any questions, please contact Mrs. Shannon Rafferty-Czincila, Manager, LaSalle License Renewal Project, at 610-765-5526.

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

Executed on ~ t-() 't-2..fJ IS'"

Respectfully,

~~

Vice President - License Renewal Projects Exelon Generation Company, LLC

Enclosures:

A: Responses to Set 1 Requests for Additional Information B: Updates to Affected LSCS LRA Sections 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-15-164 Enclosure A Page 1 of 3 Enclosure A Responses to Set 1 Requests for Additional Information Related to the LaSalle County Station (LSCS) License Renewal Application (LRA)

RAI 2.4-1 RAI 2.4-2

RS-15-164 Enclosure A Page 2 of 3 RAI 2.4-1

Background:

Section 3.4.1.4, Flood Protection Measures, of the updated final safety analysis report (UFSAR), states in part that additional protection is provided by means of waterproofing and waterstops. All exterior walls to grade level are sealed with a waterproof membrane, and all exterior construction joints are sealed with waterstops to grade level. Category I structures that house safety-related equipment are the reactor, auxiliary, diesel-generator, and the lake screen house. However, a review of the tables in the license renewal application (LRA) for these structures did not identify such components for in-scope structures as credited for flood protection and subject to an aging management review (AMR).

Issue:

The UFSAR includes components related to additional flood protection measures that are not included in the LRA tables for the relevant structures.

Request:

If the components are addressed in the LRA, identify the location. If they are not included in the LRA, please justify their exclusion from the scope of license renewal.

Exelon Response:

The Structural Commodity Group scoping evaluation did not specifically identify waterstops since NUREG-1800 Table 2.4-1, states waterstops need not be called out explicitly in the scoping or screening results if they are included as parts of structural components subject to an aging management review. Waterstops are included as integral parts of the reinforced concrete exterior below grade structural components which are subject to an aging management review, and therefore are not called out explicitly in the scoping and screening, or aging management review results, also in accordance with NUREG-1800 Table 2.4-1.

The waterproofing (waterproof membrane) applied to exterior below grade walls does not provide an intended function for license renewal. The above and below grade exterior reinforced concrete (walls) and foundations provide the flood protection intended function as identified in LRA Tables 3.5.2-1, 3.5.2-4, 3.5.2-5, and 3.5.2-9 for the Auxiliary Building, Diesel Generator Building, Lake Screen House, and the Reactor Building. UFSAR Section 3.4.1 addresses Flood Protection, and UFSAR subsection 3.4.1.3 describes structures in the context of flood protection and lists buildings that resist exterior floods both above and below grade. The waterproof membrane is identified in UFSAR subsection 3.4.1.4 as an additional protection feature provided only on exterior below grade walls. The above and below grade exterior reinforced concrete (walls) and foundations provide the flood protection intended function as identified in the screening and aging management review results for the structures.

RS-15-164 Enclosure A Page 3 of 3 RAI 2.4-2

Background:

UFSAR Section 9.4.10, Primary Containment Purge System, states in Section 9.4.10.2 that debris screens are provided for all purge penetrations. However, Section 2.4.7, Primary Containment, and Section 2.4.9, Reactor Building, of the LRA, do not discuss or include such components in their respective tables for components subject to an AMR.

Issue:

The UFSAR includes components that are not included in the LRA tables for components subject to an AMR.

Request:

If such component is relied upon to perform an intended function, please identify where it is covered in the LRA. If not included in the LRA, please justify its exclusion from the scope of license renewal.

Exelon Response:

The debris screens for the primary containment purge system are not scoped with either the Primary Containment (LRA Section 2.4.7) or the Reactor Building (LRA Section 2.4.9). Instead, they are part of the containment vent and purge portion of the Combustible Gas Control system (LRA Section 2.3.3.2). They are in the scope of license renewal, but were inadvertently omitted from the LRA. They perform an intended function to filter the air that passes through the containment vent and purge penetrations, and are shown on drawings LR-LAS-M-92-1 and LR-LAS-M-138-1. LRA Tables 2.3.3-2 and 3.3.2-2 are revised to include these components, as shown in Enclosure B.

An extent of condition review was performed to confirm other debris screens in similar configurations have been included in the LRA. No other omissions were identified.

RS-15-164 Enclosure B Page 1 of 3 Enclosure B Updates to Affected LSCS LRA Sections Resulting from the Response to the following RAI:

RAI 2.4-2 Note: To facilitate understanding, portions of the original LRA have been repeated in this Enclosure, with revisions indicated. Existing LRA text is shown in normal font. Changes are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

RS-15-164 Enclosure B Page 2 of 3 As a result of the response to RAI 2.4-2 provided in Enclosure A of this letter, LRA Table 2.3.3-2 on page 2.3-45 of the LRA is revised as follows:

Table 2.3.3-2 Combustible Gas Control System Components Subject to Aging Management Review Component Type Intended Function Blower Housing Pressure Boundary Bolting Mechanical Closure Debris Screens Filter Hoses Pressure Boundary Piping, piping components, and piping elements Leakage Boundary Pressure Boundary Structural Integrity Recombiners Pressure Boundary Valve Body Leakage Boundary Pressure Boundary Structural Integrity

RS-15-164 Enclosure B Page 3 of 3 As a result of the response to RAI 2.4-2 provided in Enclosure A of this letter, LRA Table 3.3.2-2 on page 3.3-99 of the LRA is revised to add new line items as shown below:

Table 3.3.2-2 Combustible Gas Control System Component Type Intended Function Material Environment Aging Effect Requiring Management Aging Management Programs NUREG-1801 Item Table 1 Item Notes Blower Housing Pressure Boundary Carbon Steel Air - Indoor Uncontrolled (External)

Loss of Material External Surfaces Monitoring of Mechanical Components (B.2.1.24)

VII.I.A-77 3.3.1-78 A

Condensation (Internal)

Loss of Material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

VII.F3.A-08 3.3.1-90 C

Bolting Mechanical Closure Carbon and Low Alloy Steel Bolting Air - Indoor Uncontrolled (External)

Loss of Material Bolting Integrity (B.2.1.11)

VII.I.AP-125 3.3.1-12 A

Loss of Preload Bolting Integrity (B.2.1.11)

VII.I.AP-124 3.3.1-15 A

Stainless Steel Bolting Air - Indoor Uncontrolled (External)

Loss of Material Bolting Integrity (B.2.1.11)

VII.I.AP-125 3.3.1-12 A

Loss of Preload Bolting Integrity (B.2.1.11)

VII.I.AP-124 3.3.1-15 A

Debris Screens Filter Stainless Steel Air - Indoor Uncontrolled (External)

None None VII.J.AP-17 3.3.1-120 A

Air - Indoor Uncontrolled (Internal)

None None VII.J.AP-17 3.3.1-120 A

Hoses Pressure Boundary Stainless Steel Air - Indoor Uncontrolled (External)

None None VII.J.AP-17 3.3.1-120 A

Condensation (Internal)

Loss of Material Inspection of Internal Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

V.D2.EP-61 3.2.1-48 A