RS-15-306, Submittal of 10 CFR 54.21(b) Annual Amendment to the License Renewal Application

Submittal of 10 CFR 54.21(b) Annual Amendment to the License Renewal Application

ML15336A288
Person / Time
Site:	LaSalle
Issue date:	12/02/2015
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-15-306, TAC MF5346, TAC MF5347
Download: ML15336A288 (10)

Text

Michael P. Gallagher Vice President. License Renewal Exelon Generation Exelon Nuclear 200 Exelon Way 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 RS-15-306 December 2, 2015 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

10 CFR 54.21(b) Annual Amendment to the LaSalle County Station, Units 1 and 2, License Renewal Application (TAC Nos. MF5347 and MF5346)

Reference:

Letter from Michael P. Gallagher, Exelon Generation Company LLC (Exelon), to NRC Document Control Desk, dated December 9, 2014, "Application for Renewed Operating Licenses."

In the Reference letter, Exelon Generation Company, LLC (Exelon) submitted the License Renewal Application (LRA) for the LaSalle County Station (LSCS), Units 1 and 2.

Exelon has completed a review to identify any current licensing basis (CLB) changes made since submittal of the Reference letter, which have a material effect on the content of the LRA, including the FSAR Supplement. This amendment identifies three (3) changes to the current licensing basis (CLB) that are considered to materially affect the contents of the LSCS LRA.

Enclosure A contains a description of these CLB changes. Enclosure B contains updates to sections of the LRA affected by the changes.

This submittal satisfies the 10 CFR 54.21 (b) annual amendment requirement for 2015.

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

If you have any questions, please contact Mr. John Hufnagel, Licensing Lead, LaSalle License Renewal Project, at 610-765-5829.

December 2, 2015 U.S. Nuclear Regulatory Commission Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on

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Respectfully,

• Vice President - License Renewal Projects Exelon Generation Company, LLC

Enclosures:

A. Description of CLB Changes that Impact the LRA Associated with the 10 CFR 54.21 (b) Annual Amendment B. LSCS LRA Updates Resulting from CLB Changes Identified in 2015 10 CFR 54.21(b) Review 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-15-306 Enclosure A Page 1 of 2 Enclosure A Description of CLB Changes that Impact the LRA Associated with the 10 CFR 54.21(b) Annual Amendment

RS-15-306 Enclosure A Page 2 of 2

1) Change to Ownership Structure for Exelon Generation Company, LLC In Exelon letter RS-14-315 dated October 27, 2014, Exelon Generation Company, LLC, notified the NRC that Exelon Ventures Company, LLC was dissolved and that Exelon Generation Company, LLC became a direct wholly-owned subsidiary of Exelon Corporation.

This change affected the description of the ownership structure that is contained in LRA Section 1.1.3, Descriptions of Business or Occupation of Applicant. In addition, it was identified that LRA Section 1.1.3 had inadvertently stated that Exelon Generation Company, LLC is a Delaware company, instead of a Pennsylvania company. LRA Section 1.1.3 is revised as shown in Enclosure B to reflect these changes.

2) Addition of Storage Buildings In response to NRC Order EA 12-049 for implementation of Flexible Coping Strategies (FLEX) for external events beyond the original plant design basis (BDBEE) two storage buildings were installed to house FLEX equipment at LaSalle Station. The Robust FLEX Storage Building (Building #23) is a stand-alone cast-in-place reinforced concrete structure with a floating slab supported on concrete strip footings resting on soil and is located on the north portion of the LaSalle Station site outside of the plants main power block east of the Independent Spent Fuel Storage Installation (ISFSI) pad. The Commercial FLEX Storage Building (Building #24) is a steel framed structure with metal siding and roofing. The north side of the structure consists of a concrete masonry wall and metal siding. The building foundation is comprised of footings with an interior floating slab and is located south of the Hazardous/Mixed Waste Storage Facility (Building #20).

FLEX Storage Buildings #23 and #24 are not in scope as they are separated from safety-related systems, structures, and components such that the structures failure would not impact a safety-related function. These buildings have been included in the Miscellaneous Not In Scope Structures. LRA Table 2.2-1, Plant Level Scoping Results, Comment #1 is revised as shown in Enclosure B to add these buildings to the list of not in scope structures.

3) Addition of Metered Precoat Skid for the Reactor Water Cleanup System A modification to the Reactor Water Cleanup (RWCU) System was performed to improve the performance and reliability of the precoat applications to the RWCU filter/demineralizers.

The modification involved the installation of a metered precoat skid for resin precoat slurry application to the filter demineralizer filter septa. LRA Table 2.3.3-21, Reactor Water Cleanup System Components Subject to Aging Management Review, is revised as shown in Enclosure B to include the component types of Pump Casing (Slurry Prep Tank Eductor) and Tanks (Slurry Prep Tank) with an intended function of Leakage Boundary. LRA Table 3.3.2-21, Reactor Water Cleanup System Summary of Aging Management Evaluation, is revised as shown in Enclosure B to include the component types of Pump Casing (Slurry Prep Tank Eductor) and Tanks (Slurry Prep Tank) with an intended function of Leakage Boundary with the corresponding materials, environments and aging management line items.

RS-15-306 Enclosure B Page 1 of 6 Enclosure B LSCS LRA Updates Resulting from CLB Changes Identified in 2015 10 CFR 54.21(b) Review

RS-15-306 Enclosure B Page 2 of 6 As a result of the change associated with the ownership structure of Exelon Generation Company, LLC (Item 1 of Enclosure A), LRA Section 1.1.3 on page 1-1, is revised as shown below. Additions are shown in bolded italics and deletions are shown with strikethroughs.

1.

1.3 DESCRIPTION

S OF BUSINESS OR OCCUPATION OF APPLICANT Exelon Generation Company, LLC is a Delaware Pennsylvania limited liability company which is wholly owned by Exelon Ventures Company, a Delaware limited liability company, which in turn is wholly owned by Exelon Corporation, a corporation formed under the laws of the Commonwealth of Pennsylvania. Exelon Generation Company, LLC is the licensed operator of LaSalle County Station, Units 1 and 2, which is the subject of this application. The current LaSalle County Station, Units 1 and 2 operating licenses will expire as follows:

o At midnight on April 17, 2022 for Unit 1 (Facility Operating License No. NPF-11).

o At midnight December 16, 2023 for Unit 2 (Facility Operating License No. NPF-18).

Exelon Generation Company, LLC will continue as the licensed operator on the renewed operating licenses.

RS-15-306 Enclosure B Page 3 of 6 As a result of the response to NRC Order EA 12-049 (Item 2 of Enclosure A), LRA Table 2.2-1, Plant Level Scoping Results, Comment #1 starting on page 2.2-5, is revised as shown below.

Additions are shown in bolded italics and deletions are shown with strikethroughs.

1. The Miscellaneous Not In Scope Structures are nonsafety-related and provide support, shelter, and protection for personnel, stored materials, or nonsafety-related systems, structures, and components (SSCs) that do not perform an intended function for license renewal. These nonsafety-related structures are also separated from safety-related systems, structures, and components such that the structures failure would not impact a safety-related function. Therefore, the following structures are not within the scope of license renewal: Administration Building (also known as the South Service Building or New Service Building), Building #30 (Records Storage Vault or Records Storage Building), IDNS (Illinois Department of Nuclear Safety) Building, Project Management Field Office, Training Building, Maintenance Shop, Building #1 (contractor fab shop, radiological outage, equip storage), Road Maintenance Building, Weld Shop, Warehouse (Stores Warehouse), Warehouses 3 - 6, Contractor PreFab Shop, Shad Net Maintenance Building, In-Processing Facility, MAF (Main Access Facility), Security Checkpoint, Building #11 (TSC and Security Diesels), NAF (Old Permanent Gatehouse or Gatehouse), Sewage Treatment Plant, Water Softener Building (Building #41), MUDS (Makeup Demineralizer System) Trailers, Pump Houses: (Building #40), River Screen House, Lake Blowdown Outfall Structure, Transporter Building, Hazardous/Mixed Waste Storage Facility (Building #20), Radwaste Storage, Building #33, Filling Station, Station Heat Chiller Pad, and Fish Hatchery, Robust FLEX Storage Building (Building #23),

and Commercial FLEX Storage Building (Building #24).

RS-15-306 Enclosure B Page 4 of 6 As a result of a modification to the Reactor Water Cleanup System (Item 3 of Enclosure A), LRA Table 2.3.3-21, Reactor Water Cleanup System Components Subject to Aging Management Review on page 2.3-125, is revised as shown below. Additions are indicated with bolded italics.

Table 2.3.3-21 Reactor Water Cleanup System Components Subject to Aging Management Review Component Type Intended Function Bolting Mechanical Closure Heat Exchanger - (Clean-Up Leakage Boundary Regenerative Heat Exchangers) Shell Side Components Heat Exchanger - (Clean-Up Leakage Boundary Regenerative Heat Exchangers) Tube Side Components Heat Exchanger - (Clean-up Non- Leakage Boundary Regenerative Heat Exchanger) Tube Side Components Heat Exchanger - (RWCU Pump Heat Leakage Boundary Exchanger) Shell Side Components Piping, piping components, and piping Leakage Boundary elements Pressure Boundary Pump Casing (Clean-Up Filter Leakage Boundary Demineralizer Holding Pump)

Pump Casing (Clean-Up Filter Leakage Boundary Demineralizer Precoat Pump)

Pump Casing (Reactor Water Clean-Up Leakage Boundary Recirculation Pump)

Pump Casing (Slurry Prep Tank Leakage Boundary Eductor)

Tanks (Clean-Up Filter Demineralizer Leakage Boundary Precoat Tank)

Tanks (Clean-Up Filter Demineralizer) Leakage Boundary Tanks (Slurry Prep Tank) Leakage Boundary Valve Body Leakage Boundary Pressure Boundary

RS-15-306 Enclosure B Page 5 of 6 As a result of a modification to the Reactor Water Cleanup System (Item 3 of Enclosure A), LRA Table 3.3.2-21, Reactor Water Cleanup System Summary of Aging Management Evaluation starting on page 3.3-223, is revised as shown below. Additions are indicated with bolded italics.

Table 3.3.2-21 Reactor Water Cleanup System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Programs Item Management Pump Casing Leakage Boundary Carbon Steel Treated Water (Internal) Loss of Material One-Time Inspection VII.E3.AP-106 3.3.1-21 A (Clean-Up Filter (B.2.1.21)

Demineralizer Water Chemistry (B.2.1.2) VII.E3.AP-106 3.3.1-21 B Precoat Pump)

Pump Casing Leakage Boundary Carbon Steel Air - Indoor Loss of Material External Surfaces VII.I.A-77 3.3.1-78 A (Reactor Water Uncontrolled (External) Monitoring of Mechanical Clean-Up Components (B.2.1.24)

Recirculation Treated Water (Internal) Loss of Material One-Time Inspection VII.E3.AP-106 3.3.1-21 A Pump) (B.2.1.21)

Water Chemistry (B.2.1.2) VII.E3.AP-106 3.3.1-21 B Pump Casing Leakage Boundary Stainless Steel Air - Indoor None None VII.J.AP-17 3.3.1-120 A (Slurry Prep Tank Uncontrolled Eductor) (External)

Treated Water Loss of Material One-Time Inspection VII.E3.AP-110 3.3.1-25 A (Internal) (B.2.1.21)

Water Chemistry VII.E3.AP-110 3.3.1-25 B (B.2.1.2)

Tanks (Clean-Up Leakage Boundary Carbon Steel Air - Indoor Loss of Material External Surfaces VII.I.A-77 3.3.1-78 A Filter Demineralizer Uncontrolled (External) Monitoring of Mechanical Precoat Tank) Components (B.2.1.24)

Treated Water (Internal) Loss of Material One-Time Inspection VII.E3.AP-106 3.3.1-21 C (B.2.1.21)

Water Chemistry (B.2.1.2) VII.E3.AP-106 3.3.1-21 D

RS-15-306 Enclosure B Page 6 of 6 Table 3.3.2-21 Reactor Water Cleanup System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Programs Item Management Tanks (Clean-Up Leakage Boundary Carbon Steel Air - Indoor Loss of Material External Surfaces VII.I.A-77 3.3.1-78 A Filter Uncontrolled (External) Monitoring of Mechanical Demineralizer) Components (B.2.1.24)

Treated Water (Internal) Loss of Material One-Time Inspection VII.E3.AP-106 3.3.1-21 C (B.2.1.21)

Water Chemistry (B.2.1.2) VII.E3.AP-106 3.3.1-21 D Tanks (Slurry Leakage Boundary Stainless Steel Air - Indoor None None VII.J.AP-17 3.3.1-120 A Prep Tank) Uncontrolled (External)

Treated Water Loss of Material One-Time Inspection VII.E3.AP-110 3.3.1-25 C (Internal) (B.2.1.21)

Water Chemistry VII.E3.AP-110 3.3.1-25 D (B.2.1.2)