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| issue date = 07/21/2014
| issue date = 07/21/2014
| title = Draft Request for Additional Information (Tac Nos. MF3085 and MF3086)
| title = Draft Request for Additional Information (Tac Nos. MF3085 and MF3086)
| author name = Ennis R B
| author name = Ennis R
| author affiliation = NRC/NRR/DORL/LPLI-2
| author affiliation = NRC/NRR/DORL/LPLI-2
| addressee name = Schaaf R G
| addressee name = Schaaf R
| addressee affiliation = NRC/NRR/DORL/LPLI-2
| addressee affiliation = NRC/NRR/DORL/LPLI-2
| docket = 05000352, 05000353
| docket = 05000352, 05000353
| license number = NPF-039, NPF-085
| license number = NPF-039, NPF-085
| contact person = Ennis R B
| contact person = Ennis R
| case reference number = TAC MF3085, TAC MF3086
| case reference number = TAC MF3085, TAC MF3086
| document type = Memoranda, Request for Additional Information (RAI)
| document type = Memoranda, Request for Additional Information (RAI)
Line 18: Line 18:


=Text=
=Text=
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 21, 2014  
{{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 21, 2014 MEMORANDUM TO:           Robert G. Schaaf, Acting Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:                     Richard B. Ennis, Senior Project Manager /RA/
 
Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
MEMORANDUM TO: Robert G. Schaaf, Acting Chief Plant Licensing Branch I-2  
 
Division of Operating Reactor Licensing  
 
Office of Nuclear Reactor Regulation FROM:   Richard B. Ennis, Senior Project Manager  
/RA/ Plant Licensing Branch I-2  
 
Division of Operating Reactor Licensing  
 
Office of Nuclear Reactor Regulation  


==SUBJECT:==
==SUBJECT:==
LIMERICK GENERATING STATION, UNITS 1 AND 2, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MF3085  
LIMERICK GENERATING STATION, UNITS 1 AND 2, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MF3085 AND MF3086)
 
The enclosed draft request for additional information (RAI) was transmitted on July 21, 2014, to Mr. Frank Mascitelli of Exelon Generation Company, LLC (Exelon, the licensee). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensees amendment request for Limerick Generating Station (LGS), Units 1 and 2 dated November 15, 2013. The proposed amendment would revise the Technical Specification requirements related to the response time for the main steam line flow-high isolation function.
AND MF3086)  
The draft RAI was sent to Exelon to ensure that the questions are understandable, the regulatory basis for the questions is clear, and to determine if the information was previously docketed. This memorandum and the enclosure do not convey or represent an NRC staff position regarding the licensee's request.
 
Docket Nos. 50-352 and 50-353
The enclosed draft request for additional information (RAI) was transmitted on July 21, 2014, to  
 
Mr. Frank Mascitelli of Exelon Generation Company, LLC (Exelon, the licensee). This  
 
information was transmitted to facilitate an upcoming conference call in order to clarify the  
 
licensee's amendment request for Limerick Generating Station (LGS), Units 1 and 2 dated  
 
November 15, 2013. The proposed amendment would revise the Technical Specification  
 
requirements related to the response time for the main steam line flow-high isolation function.  
 
The draft RAI was sent to Exelon to ensure that the questions are understandable, the  
 
regulatory basis for the questions is clear, and to determine if the information was previously  
 
docketed. This memorandum and the enclosure do not convey or represent an NRC staff  
 
position regarding the licensee's request.  
 
Docket Nos. 50-352 and 50-353  


==Enclosure:==
==Enclosure:==
Draft RAI  
Draft RAI
 
July 21, 2014
 
MEMORANDUM TO: Robert G. Schaaf, Acting Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing
 
Office of Nuclear Reactor Regulation FROM:  Richard B. Ennis, Senior Project Manager 
/RA/ Plant Licensing Branch I-2
 
Division of Operating Reactor Licensing


Office of Nuclear Reactor Regulation  
July 21, 2014 MEMORANDUM TO:            Robert G. Schaaf, Acting Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM:                    Richard B. Ennis, Senior Project Manager /RA/
Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation


==SUBJECT:==
==SUBJECT:==
LIMERICK GENERATING STATION, UNITS 1 AND 2, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MF3085  
LIMERICK GENERATING STATION, UNITS 1 AND 2, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MF3085 AND MF3086)
 
The enclosed draft request for additional information (RAI) was transmitted on July 21, 2014, to Mr. Frank Mascitelli of Exelon Generation Company, LLC (Exelon, the licensee). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensees amendment request for Limerick Generating Station (LGS), Units 1 and 2 dated November 15, 2013. The proposed amendment would revise the Technical Specification requirements related to the response time for the main steam line flow-high isolation function.
AND MF3086)  
The draft RAI was sent to Exelon to ensure that the questions are understandable, the regulatory basis for the questions is clear, and to determine if the information was previously docketed. This memorandum and the enclosure do not convey or represent an NRC staff position regarding the licensee's request.
 
Docket Nos. 50-352 and 50-353
The enclosed draft request for additional information (RAI) was transmitted on July 21, 2014, to  
 
Mr. Frank Mascitelli of Exelon Generation Company, LLC (Exelon, the licensee). This  
 
information was transmitted to facilitate an upcoming conference call in order to clarify the  
 
licensee's amendment request for Limerick Generating Station (LGS), Units 1 and 2 dated  
 
November 15, 2013. The proposed amendment would revise the Technical Specification  
 
requirements related to the response time for the main steam line flow-high isolation function.  
 
The draft RAI was sent to Exelon to ensure that the questions are understandable, the  
 
regulatory basis for the questions is clear, and to determine if the information was previously  
 
docketed. This memorandum and the enclosure do not convey or represent an NRC staff  
 
position regarding the licensee's request.  
 
Docket Nos. 50-352 and 50-353  


==Enclosure:==
==Enclosure:==
Draft RAI  
Draft RAI DISTRIBUTION PUBLIC                                             GThomas, NRR/DSS/SRXB LPL1-2 R/F RidsNrrDorlLpl1-2 Resource RidsNrrDorlDpr Resource RidsNrrPMLimerick Resource ACCESSION NO.: ML14202A518 OFFICE           LPL1-2/PM NAME               REnnis DATE               7/21/14 OFFICIAL RECORD COPY
 
DISTRIBUTION PUBLIC GThomas, NRR/DSS/SRXB LPL1-2 R/F RidsNrrDorlLpl1-2 Resource RidsNrrDorlDpr Resource RidsNrrPMLimerick Resource ACCESSION NO.: ML14202A518 OFFICE LPL1-2/PM NAME REnnis DATE 7/21/14     OFFICIAL RECORD COPY DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT MAIN STEAM LINE FLOW-HIGH ISOLATION RESPONSE TIME EXELON GENERATION COMPANY, LLC LIMERICK GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353
 
By application dated November 15, 2013, as supplemented by letter dated April 16, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.
ML13322A448 and ML14106A642, respectively), Exel on Generation Company, LLC (Exelon, the licensee), submitted a license amendment request for Limerick Generating Station (LGS),
Units 1 and 2. The proposed amendment would revise the Technical Specification (TS)
 
requirements related to the response time for the main steam line flow-high isolation function.
 
The Nuclear Regulatory Commission (NRC) staff has reviewed the information the licensee
 
provided that supports the proposed amendment and would like to discuss the following issues
 
to clarify the submittal. 
: 1. Section 3.0 of Attachment 1 to the application dated November 15, 2013, states that the current analysis of record for the LGS main steam line break (MSLB) loss-of-coolant
 
accident peak cladding temperature response is documented in General Electric topical
 
report NEDC-32170P, Revision 2, day May 1995. If this topical report has already been
 
submitted to the NRC, please identify the document which submitted the report, otherwise
 
submit the report.
: 2. Section 4.1 of Attachment 1 to the application lists 10 CFR Part 50, Appendix A, General Design Criterion (GDC) 46 as "Acceptance criteria for emergency core cooling systems for
 
light-water nuclear power reactors."  That title pertains to 10 CFR 50.46, not GDC 46. 
 
Please clarify the applicable regulatory requirements/criteria that pertain to this amendment
 
request. 
: 3. As discussed in Section 3.0 of Attachment 1 to the application, GE Hitachi Nuclear Energy (GEH) performed a MSLB outside of containm ent (STMO) analysis using the evaluation model SAFER04A. The licensee stated that the SAFER simulation of the analysis provides
 
fuel heat-up and long-term cooling system response. The NRC staff requests that the
 
licensee provide additional information to support the following statement in the submittal: 
 
"This methodology is more accurate than the current method which is based on simplifying
 
assumptions as described in UFSAR [Updated Final Safety Analysis Report] Section
 
15.6.4." In addition, Attachment 4 to the application, GEH document 0000-0158-9651-NP, states on page 3 that: 
 
Enclosure LGS UFSAR 15.6.4.4.f: "Level rise time is conservatively assumed to be
 
1 second. Mixture quality is conservatively taken to be a constant 7% (steam
 
weight percentage) during mixture flow."  This assumption is not necessary.
 
SAFER is a systems code and can calculate the time varying two phase break
 
flow during the STMO event.
The original and the newly submitted analysis are based on SAFER evaluation model. Why
 
is the above assumption not necessary now?  Describe the SAFER code changes, if any, to
 
justify the deletion of this key assumption.
Confirm whether or not the following assumptions currently listed in UFSAR Section
 
15.6.4.4, and discussed in Attachment 1 to the application, will be revised as part of the


implementation of the proposed amendment:  
DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT MAIN STEAM LINE FLOW-HIGH ISOLATION RESPONSE TIME EXELON GENERATION COMPANY, LLC LIMERICK GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 By application dated November 15, 2013, as supplemented by letter dated April 16, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.
: d. Isolation valves start to close at 0.5 seconds on high flow signal and are fully closed at 5.5 seconds.  
ML13322A448 and ML14106A642, respectively), Exelon Generation Company, LLC (Exelon, the licensee), submitted a license amendment request for Limerick Generating Station (LGS),
: f. Level rise time is conservatively assumed to be 1 second. Mixture quality is conservatively taken to be a constant 7% (steam weight percentage)  
Units 1 and 2. The proposed amendment would revise the Technical Specification (TS) requirements related to the response time for the main steam line flow-high isolation function.
The Nuclear Regulatory Commission (NRC) staff has reviewed the information the licensee provided that supports the proposed amendment and would like to discuss the following issues to clarify the submittal.
: 1. Section 3.0 of Attachment 1 to the application dated November 15, 2013, states that the current analysis of record for the LGS main steam line break (MSLB) loss-of-coolant accident peak cladding temperature response is documented in General Electric topical report NEDC-32170P, Revision 2, day May 1995. If this topical report has already been submitted to the NRC, please identify the document which submitted the report, otherwise submit the report.
: 2. Section 4.1 of Attachment 1 to the application lists 10 CFR Part 50, Appendix A, General Design Criterion (GDC) 46 as Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors. That title pertains to 10 CFR 50.46, not GDC 46.
Please clarify the applicable regulatory requirements/criteria that pertain to this amendment request.
: 3. As discussed in Section 3.0 of Attachment 1 to the application, GE Hitachi Nuclear Energy (GEH) performed a MSLB outside of containment (STMO) analysis using the evaluation model SAFER04A. The licensee stated that the SAFER simulation of the analysis provides fuel heat-up and long-term cooling system response. The NRC staff requests that the licensee provide additional information to support the following statement in the submittal:
This methodology is more accurate than the current method which is based on simplifying assumptions as described in UFSAR [Updated Final Safety Analysis Report] Section 15.6.4. In addition, Attachment 4 to the application, GEH document 0000-0158-9651-NP, states on page 3 that:
Enclosure


during mixture flow.}}
LGS UFSAR 15.6.4.4.f: Level rise time is conservatively assumed to be 1 second. Mixture quality is conservatively taken to be a constant 7% (steam weight percentage) during mixture flow. This assumption is not necessary.
SAFER is a systems code and can calculate the time varying two phase break flow during the STMO event.
The original and the newly submitted analysis are based on SAFER evaluation model. Why is the above assumption not necessary now? Describe the SAFER code changes, if any, to justify the deletion of this key assumption.
Confirm whether or not the following assumptions currently listed in UFSAR Section 15.6.4.4, and discussed in Attachment 1 to the application, will be revised as part of the implementation of the proposed amendment:
: d. Isolation valves start to close at 0.5 seconds on high flow signal and are fully closed at 5.5 seconds.
: f. Level rise time is conservatively assumed to be 1 second. Mixture quality is conservatively taken to be a constant 7% (steam weight percentage) during mixture flow.}}

Latest revision as of 03:19, 4 November 2019

Draft Request for Additional Information (Tac Nos. MF3085 and MF3086)
ML14202A518
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 07/21/2014
From: Richard Ennis
Plant Licensing Branch 1
To: Robert Schaaf
Plant Licensing Branch 1
Ennis R
References
TAC MF3085, TAC MF3086
Download: ML14202A518 (4)
v • d • e


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 21, 2014 MEMORANDUM TO: Robert G. Schaaf, Acting Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Richard B. Ennis, Senior Project Manager /RA/

Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MF3085 AND MF3086)

The enclosed draft request for additional information (RAI) was transmitted on July 21, 2014, to Mr. Frank Mascitelli of Exelon Generation Company, LLC (Exelon, the licensee). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensees amendment request for Limerick Generating Station (LGS), Units 1 and 2 dated November 15, 2013. The proposed amendment would revise the Technical Specification requirements related to the response time for the main steam line flow-high isolation function.

The draft RAI was sent to Exelon to ensure that the questions are understandable, the regulatory basis for the questions is clear, and to determine if the information was previously docketed. This memorandum and the enclosure do not convey or represent an NRC staff position regarding the licensee's request.

Docket Nos. 50-352 and 50-353

Enclosure:

Draft RAI

July 21, 2014 MEMORANDUM TO: Robert G. Schaaf, Acting Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Richard B. Ennis, Senior Project Manager /RA/

Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

LIMERICK GENERATING STATION, UNITS 1 AND 2, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MF3085 AND MF3086)

The enclosed draft request for additional information (RAI) was transmitted on July 21, 2014, to Mr. Frank Mascitelli of Exelon Generation Company, LLC (Exelon, the licensee). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensees amendment request for Limerick Generating Station (LGS), Units 1 and 2 dated November 15, 2013. The proposed amendment would revise the Technical Specification requirements related to the response time for the main steam line flow-high isolation function.

The draft RAI was sent to Exelon to ensure that the questions are understandable, the regulatory basis for the questions is clear, and to determine if the information was previously docketed. This memorandum and the enclosure do not convey or represent an NRC staff position regarding the licensee's request.

Docket Nos. 50-352 and 50-353

Enclosure:

Draft RAI DISTRIBUTION PUBLIC GThomas, NRR/DSS/SRXB LPL1-2 R/F RidsNrrDorlLpl1-2 Resource RidsNrrDorlDpr Resource RidsNrrPMLimerick Resource ACCESSION NO.: ML14202A518 OFFICE LPL1-2/PM NAME REnnis DATE 7/21/14 OFFICIAL RECORD COPY

DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT MAIN STEAM LINE FLOW-HIGH ISOLATION RESPONSE TIME EXELON GENERATION COMPANY, LLC LIMERICK GENERATING STATION, UNITS 1 AND 2 DOCKET NOS. 50-352 AND 50-353 By application dated November 15, 2013, as supplemented by letter dated April 16, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession Nos.

ML13322A448 and ML14106A642, respectively), Exelon Generation Company, LLC (Exelon, the licensee), submitted a license amendment request for Limerick Generating Station (LGS),

Units 1 and 2. The proposed amendment would revise the Technical Specification (TS) requirements related to the response time for the main steam line flow-high isolation function.

The Nuclear Regulatory Commission (NRC) staff has reviewed the information the licensee provided that supports the proposed amendment and would like to discuss the following issues to clarify the submittal.

1. Section 3.0 of Attachment 1 to the application dated November 15, 2013, states that the current analysis of record for the LGS main steam line break (MSLB) loss-of-coolant accident peak cladding temperature response is documented in General Electric topical report NEDC-32170P, Revision 2, day May 1995. If this topical report has already been submitted to the NRC, please identify the document which submitted the report, otherwise submit the report.
2. Section 4.1 of Attachment 1 to the application lists 10 CFR Part 50, Appendix A, General Design Criterion (GDC) 46 as Acceptance criteria for emergency core cooling systems for light-water nuclear power reactors. That title pertains to 10 CFR 50.46, not GDC 46.

Please clarify the applicable regulatory requirements/criteria that pertain to this amendment request.

3. As discussed in Section 3.0 of Attachment 1 to the application, GE Hitachi Nuclear Energy (GEH) performed a MSLB outside of containment (STMO) analysis using the evaluation model SAFER04A. The licensee stated that the SAFER simulation of the analysis provides fuel heat-up and long-term cooling system response. The NRC staff requests that the licensee provide additional information to support the following statement in the submittal:

This methodology is more accurate than the current method which is based on simplifying assumptions as described in UFSAR [Updated Final Safety Analysis Report] Section 15.6.4. In addition, Attachment 4 to the application, GEH document 0000-0158-9651-NP, states on page 3 that:

Enclosure

LGS UFSAR 15.6.4.4.f: Level rise time is conservatively assumed to be 1 second. Mixture quality is conservatively taken to be a constant 7% (steam weight percentage) during mixture flow. This assumption is not necessary.

SAFER is a systems code and can calculate the time varying two phase break flow during the STMO event.

The original and the newly submitted analysis are based on SAFER evaluation model. Why is the above assumption not necessary now? Describe the SAFER code changes, if any, to justify the deletion of this key assumption.

Confirm whether or not the following assumptions currently listed in UFSAR Section 15.6.4.4, and discussed in Attachment 1 to the application, will be revised as part of the implementation of the proposed amendment:

d. Isolation valves start to close at 0.5 seconds on high flow signal and are fully closed at 5.5 seconds.
f. Level rise time is conservatively assumed to be 1 second. Mixture quality is conservatively taken to be a constant 7% (steam weight percentage) during mixture flow.
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