ML17181A197

Non-Acceptance with Supplemental Information Required Letter to Licensee - I4R-01 Request

ML17181A197
Person / Time
Site:	LaSalle
Issue date:	07/10/2017
From:	Bhalchandra Vaidya Plant Licensing Branch III
To:	Bryan Hanson Exelon Generation Co
VAIDYA/415-3308
References
CAC MF9758, CAC MF9759
Download: ML17181A197 (4)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 10, 2017 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)

Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2, SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE REVIEW OF REQUESTED LICENSING ACTION RE: RELIEF REQUEST RE: FOURTH 10-YEAR INSERVICE INSPECTION INTERVAL PROGRAM RELIEF REQUEST NO. 14R-01 (CAC NOS. MF9758 AND MF9759)

Dear Mr. Hanson:

By letter dated May 30, 2017, Exelon Generation Company, LLC (EGC, the licensee) submitted a request for the fourth 10-year inservice inspection (ISi) interval program regarding relief request (RR) for LaSalle County Station (LSCS), Units 1 and 2. The fourth interval of the LSCS ISi program is currently scheduled to begin on October 1, 2017, and end on September 30, 2027, and will comply with the American Society of Mechanical Engineers Boiler and Pressure Vessel (ASME Code) Code,Section XI, 2007 Edition with the 2008 Addenda. EGC requested the following:

• 14R-01 requests approval of alternative risk-informed ISi program and examination criteria for Examination Category 8-F, 8-J, C-F-1, and C-F-2, pressure retaining piping welds in accordance with ASME Code Case N-578-1, "Risk-Informed Requirements for Class 1, 2, or 3 Piping, Method B,Section XI, Division 1."

The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staff's acceptance review of this RR. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.

Pursuant to Sections 50.55a(z)(1) and 50.55a(z)(2) of Title 10 of the Code of Federal Regulations (10 CFR), the applicant shall demonstrate that the proposed alternatives would provide an acceptable level of quality and safety, or that compliance with the specified requirements of Section 50.55a would result in hardship or unusual difficulty without a compensating increase in the level of quality or safety.

B. Hanson The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the staff to make an independent assessment regarding the acceptability of the proposed amendment/relief request in terms of regulatory requirements and the protection of public health and safety and the environment.

ln order to make the application complete, the NRC staff requests that EGC supplement the application to address the information requested in the enclosure by July 27, 2017. This will enable the staff to begin its detailed technical review. If the information responsive to the staff's request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its review activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the staff's detailed technical review by separate correspondence.

The information requested and associated time frame in this letter were agreed upon during the telephone discussion with your staff on July 10, 2017.

If you have any questions, please contact me at (301) 415-3308.

Sincerely, Bhalchandra Vaidya, Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-373 and 50-374

Enclosure:

Request for supplemental Information cc: Distribution via ListServ

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 REQUEST FOR SUPPLEMENTAL INFORMATION NEEDED REGARDING RELIEF REQUEST NO. 14R-01 FOR LA SALLE COUNTY STATION {LSCS), UNITS 1 AND 2 DOCKET NOS. 50-373 AND 50-374

{CAC NOS. MF9758 AND MF9759)

Background-After reviewing relief request (RR) No. 14R-01, it is not clear if there have been any probabilistic risk assessment (PRA) upgrades, since 2008. The licensee has properly used their latest PRA model but the U.S. Nuclear Regulatory Commission (NRC) staff was not able to verify if the latest model has been peer reviewed based on the information provided in the RR. It appears that no peer review has been conducted since 2008. Additionally, the 2008 peer review used only Revision O of Regulatory Guide (RG) 1.200, rather than the current Revision 2. The RR states that Exelon Generation Company (EGG, the licensee) pertormed a self-assessment against Revision 1 of AG 1.200, but to date there does not appear to be any documentation verifying that a self-assessment against Revision 2 of AG 1.200 has been completed.

Supplemental Information Needed from Licensee-The licensee is using a risk-informed approach to support the inservice inspection interval program. Provide the documentation to demonstrate the technical adequacy of their PAA against Revision 2 of AG 1.200 as described below:

• In Enclosure LS-LAR-007 to Attachment 1 of the licensee submission (page 11 of 25), it is stated that "the most recent update of the LaSalle PAA model (designated the LS2014A model) was completed in November 2015 as a regularly scheduled update to the previous LS2011A model."

• Provide details of all changes to the PRA model since the version reviewed by the 2008 peer review (you may group changes such as "data refinements," but be specific as to other changes, e.g., changes in model structure or methods), justifying whether or not, the change constitutes PAA upgrade as defined in the ASME/ANS [American Society of Mechanical Engineers/American Nuclear Society) PAA standard - "new should be interpreted as new to the subject PRA even though the methodology in question has been applied in other PRAs" [Section 1-A. 1 of ASME/ANS RA-Sa-2009].

• If any changes constitute an upgrade, pertorm a focused scope peer review on the affected technical elements (including affected high level requirements as well as all supporting requirements) and provide the results of the review complete with the Facts and Observations/Findings and dispositions addressing any effect upon the application.

Enclosure

B. Hanson

SUBJECT:

LASALLE COUNTY STATION, UNITS 1AND2, SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE REVIEW OF REQUESTED LICENSING ACTION RE: RELIEF REQUEST RE FOURTH 10-YEAR NO. 14R-01 (CAC NOS. MF9758 AND MF9759) DATED JULY 10, 2017 DISTRIBUTION:

PUBLIC RidsNrrDraApla Resource LPL3 R/F RidsNrrlASRohrer Resource RidsNrrPMLaSalle Resource RidsAcrs_MailCTR Resource RidsRgn3MailCenter Resource LFields, NRR/DRNAPLA RidsOgcRp Resource RGalucci, NRR/DRNAPLA RidsNrrOorllp13 Resource ADAMS A ccess1on: ML17181A197 *N o su b stant '1al h c anoe 1n th eema1 I OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DRNAPLNBC NAME BVaidya SRohrer SRosenberg*

DATE 07/10/17 07/05/17 06/27/17 OFFICE NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME DWrona BVaidya DATE 07/10/17 07/10/17 OFFICIAL RECORD COPY