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| | document type = Letter | | | document type = Letter |
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| | | project = TAC:ME6555, TAC:ME6556 |
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| | =Text= |
| | {{#Wiki_filter:10CFR5010CFR5110CFR54February21,2013U.S.NuclearRegulatoryCommissionAttention:DocumentControlDeskWashington,DC20555-0001LimerickGeneratingStation,Units1and2FacilityOperatingLicenseNos.NPF-39andNPF-85NRCDocketNos.50-352and50-353Subject:ExelonGenerationCompany,LLCReviewoftheSafetyEvaluationReportrelatedtotheLimerickGeneratingStationLicenseRenewalApplicationReference:1.ExelonGenerationCompany,LLCletterfromMichaelP.GallaghertoNRCDocumentControlDesk,"ApplicationforRenewedOperatingLicenses",datedJune22,20112.LetterfromJohnW.Lubinski(NRC)toMichaelP.Gallagher(Exelon),"SafetyEvaluationReportRelatedtotheLicenseRenewalofLimerickGeneratingStation,Units1and2(TACNos.ME6555,ME6556)",datedJanuary10,2013IntheReference1letter,ExelonGenerationCompany,LLC(Exelon)submittedtheLicenseRenewalApplication(LRA)fortheLimerickGeneratingStation,Units1and2(LGS).IntheReference2letter,theU.S.NuclearRegulatoryCommissionissuedtheSafetyEvaluationReport(SER)relatedtotheLGSLicenseRenewalApplication.ExelonhascompleteditsreviewoftheSERandprovidescommentscontainedwithintheEnclosure.Therearenootherneworrevisedregulatorycommitmentscontainedinthisletter.Ifyouhaveanyquestions,pleasecontactMr.AIFulvio,Manager,ExelonLicenseRenewal,at610-765-5936. |
| | U.S.NuclearRegulatoryCommissionFebruary21,2013Page2Respectfully,VicePresident-LicenseRenewalProjectsExelonGenerationCompany,LLCEnclosure:CommentsregardingtheSafetyEvaluationReportrelatedtotheLimerickGeneratingStationLicenseRenewalApplication.cc:RegionalAdministrator-NRCRegionINRCProjectManager(SafetyReview),NRR-DLRNRCProjectManager(EnvironmentalReview),NRR-DLRNRCProjectManager,NRR-DORLLimerickGeneratingStationNRCSeniorResidentInspector,LimerickGeneratingStationR.R.Janati,CommonwealthofPennsylvania |
| | |
| | ==Enclosure== |
| | Page 1 of 3 Enclosure Comments regarding the Safety Evaluation Report related to the Limerick Generating Station License Renewal Application. The table on the following pages contains comments and suggestions for NRC staff consideration, based upon Exelon's review of the Limerick Generating Station, Units 1 and 2 Safety Evaluation (SER). An item number is provided in column 1, the SER Section number is given in column 2, the SER page number is listed in column 3 and the comment is provided in column 4. |
| | |
| | ==Enclosure== |
| | Page 2 of 3 Comments regarding the Safety Evaluation Report related to the Limerick Generating Station License Renewal Application. Where suggested changes to the SER are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text. # Section # Page # Comment 1. 3.0.3.1.18 3-58 Delete the following in the third paragraph: "For penetrations 238 and 239 associated with the RHR system relief valves, the staff noted that Table 6.2-25, Note 23 of the UFSAR, indicates that through modifications performed at the first refueling the relief valve discharge line isolation valves are also subject either to local testing or removal and bench testing for subsequent LLRTs. Penetrations 238 and 239 are comprised by a "Double O-Ring with Seal Assembly," where typically, the seals per Table 6.2-25, Note 23 of the UFSAR, will be leak rate tested by pressurizing between the O-Rings." Comment: |
| | As discussed in Exelon's response to RAI B.2.1.33-1, penetrations 238 and 239 include a suppression pool water seal, at least one isolation valve outside containment, and a closed system outside containment. Penetrations 238 and 239 are correctly discussed in the second paragraph. 2. 3.0.3.2.13 3-129 SER states that: "According to ASME Code Section XI, Subsection IWE, each "inspection period" and "inspection interval" are of 40 months and 120 months duration, respectively." Comment: Stating that each inspection period is 40 months in duration according to IWE Code is incorrect. ASME Code Section XI, Subsection IWE-2411 describes an Inspection Program B interval as 10 years. IWE-2412 and Table IWE-2412-1 indicate there are three periods in an Inspection Program B interval. Table IWE-2412-1 also indicates that periods of 4 years in duration are acceptable. LGS outages are conducted every 2 years and therefore some periods could be 4 years in duration. 3. 3.0.3.2.13 3-133 Delete the last part of the SER statement as shown in strikethrough below: "The staff reviewed the revised Commitment No. 30, as noted above, and found it acceptable because: (1) The applicant plans to recoat all local areas (less than 2.5 inches in diameter) of corrosion (pitting corrosion) that are greater than 50 mils plate thickness loss in the outage identified. in 2012 for Unit 1, and 2013 for Unit 2." Comment: |
| | As stated in Commitment No. 30, the coating maintenance plan will be initiated in the 2012 refueling outage for unit 1 and the 2013 refueling outage for unit 2. Our commitment was revised in our September 12, 2012 letter to the staff to require recoating local areas (less than 2.5 inches in diameter) of general corrosion that are greater than 50 mils plate thickness loss in the outage they are identified. The commitment revision occurred after the Unit 1 outage in 2012 and therefore not all local areas of general corrosion greater than 50 mils plate thickness loss were recoated in that outage. |
| | |
| | ==Enclosure== |
| | Page 3 of 3 Comments regarding the Safety Evaluation Report related to the Limerick Generating Station License Renewal Application. Where suggested changes to the SER are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text. # Section # Page # Comment 4. 3.7 3-412 Delete the part of the SER statement as shown in strikethrough below: "The staff reviewed the information in LRA Section 3, "Aging Management Review Results," and LRA Appendix B, "Aging Management Programs and Activities." On the basis of its review of the AMR results and AMPs, the staff concludes, with the exception of Open Items 3.0.3.2.13-1 and 3.0.5-1, that the applicant has demonstrated that the aging effects will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff also reviewed the applicable UFSAR supplement program summaries and concludes that the supplement adequately describes the AMPs credited for managing aging, as required by 10 CFR 54.21 (d). |
| | With regard to these matters, the staff concludes, with the exception of Open Item 3.0.3.2.13-1 that there is reasonable assurance that the applicant will continue to conduct the activities authorized by the renewed licenses in accordance with the CLB, and any changes made to the CLB, in order to comply with 10 CFR 54.21 (a)(3), are in accordance with the Atomic Energy Act of 1954, as amended, and NRC regulations.". |
| | Comment: Open items 3.0.3.2.13-1 and 3.0.5-1 are closed. 5. Appendix A, Item #38 A-24 Comment: Commitment #38 - Entry for the column entitled "Enhancements or Implementation Schedule." |
| | The program for commitment #38 does not have enhancements. |
| | The entry for this column should be revised to align with the LRA Appendix A, Table A.5. Delete: Program to be enhanced before the period of extended operation. Suggested reword: Program and initial inspections to be implemented before the period of extended operation. |
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Letter Sequence Other |
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Results
Other: ML11255A032, ML11258A109, ML11342A205, ML12018A332, ML12139A066, ML12139A071, ML12139A074, ML12164A800, ML12256A929, ML12286A325, ML13053A374, ML13171A064, ML14071A378, ML14073A117, RS-14-319, Cancellation of Parent Company Guarantee
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MONTHYEARML11209B7092011-07-22022 July 2011 Submittal of Summary Report for Inservice Inspections (2R11) Project stage: Request ML11255A0322011-09-15015 September 2011 Plan for the Scoping and Screening Regulatory Audit Regarding the Limerick Generating Station, Units 1 and 2 License Renewal Application Review (TAC Nos. ME6555, ME6556) Project stage: Other ML11258A1092011-09-20020 September 2011 Plan for the Aging Management Program Regulatory Audit Regarding the Limerick Generating Station, Units 1 and 2 License Renewal Application Review Project stage: Other ML1134101442011-12-0707 December 2011 Response to NRC Request for Additional Information, Dated November 18, 2011 Project stage: Response to RAI ML11342A2052011-12-0909 December 2011 Scoping and Screening Methodology Audit Report Regarding the Limerick Generating Station, Units 1 and 2 Project stage: Other ML1133402312011-12-12012 December 2011 Request for Additional Information for Limerick Generating Station, Units 1 and 2 License Renewal Application-Scoping and Screening (TAC Nos. ME6555 and ME6556) Project stage: RAI ML11343A4382011-12-15015 December 2011 Requests for Additional Information for the Review of the Limerick Generating Station License Renewal Application (TAC ME6555, ME6556) Project stage: RAI ML11335A3172012-01-0505 January 2012 RAI for the Review of the Limerick Generating Station License Renewal Application (TAC Nos. ME6555, ME6556) Project stage: RAI ML11347A3602012-01-17017 January 2012 Requests for Additional Information for the Review of the Limerick Generating Station License Renewal Application (TAC Nos. ME6555, ME6556) Project stage: RAI ML11361A0832012-01-18018 January 2012 Requests for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555, ME6556) Project stage: RAI ML11361A0792012-01-24024 January 2012 Requests for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555, ME6556) Project stage: RAI ML11364A0992012-01-30030 January 2012 Requests for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555, ME6556) Project stage: RAI ML12163A7532012-01-31031 January 2012 2012/01/31 Limerick Lr - FW: Request for Additional Information for the Review of the Limerick Generation Station, Units 1 and 2 License Renewal Application (TAC Nos. ME6555 and ME6556) Project stage: Request ML12005A2512012-01-31031 January 2012 Request for Additional Information for the Review of the Limerick Generating Station Units 1 and 2 License Renewal Application (TAC Nos. ME6555, ME6556) TLAA 43 and 468 RAIs Project stage: RAI ML12018A0332012-02-14014 February 2012 Request for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555, ME6556) Rapb AMR2 RAIs Project stage: RAI ML12017A1592012-02-16016 February 2012 Request for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555 and ME6556) Project stage: RAI ML12024A2312012-02-16016 February 2012 Requests for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555 and ME6556) OE and Other RAIs Project stage: RAI ML1204703722012-02-16016 February 2012 Response to NRC Request for Additional Information, Dated January 17, 2012 Project stage: Response to RAI ML12019A1562012-02-17017 February 2012 Requests for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC ME6555 and ME6556) Project stage: RAI ML12018A0352012-02-23023 February 2012 Requests for Addtional Information for the Review of the Limerick Generating Station, Units 1 & 2, License Renewal Application (TAC ME6555 and ME6556) Project stage: Approval ML12059A3452012-02-28028 February 2012 Response to NRC Request for Additional Information, Dated January 30, 2012, Related to License Renewal Application Project stage: Response to RAI ML12018A3322012-02-28028 February 2012 Letter Aging Management Programs Audit Report Regarding the Limerick Generating Station, Units 1 and 2 (TAC NO.ME6555 & ME6556) Project stage: Other ML12065A2062012-03-0505 March 2012 Response to NRC Requests for Additional Information, Dated February 16, 2012, and February 17, 2012, Related to Renewal Application Project stage: Response to RAI ML12046A8992012-03-0909 March 2012 Request for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555 and ME6556) Limerick App J RAIs Project stage: RAI ML12009A1352012-03-0909 March 2012 Summary of the Telephone Conference Call Held on December 14, 2011, Between the U.S. Nuclear Regulatory Commission and Exelon on Generation Company, LLC, Concerning Requests for Additional Information Pertaining to the Limerick 12-14-11 Tel Project stage: RAI ML1207303612012-03-13013 March 2012 Response to NRC Requests for Additional Information, Dated February 14 and February 16, 2012, Related to the Limerick Generating Station License Renewal Application Project stage: Response to RAI ML12080A1182012-03-20020 March 2012 Response to NRC Requests for Additional Information, Dated February 23 and March 9, 2012, Related to License Renewal Application Project stage: Response to RAI ML12074A0372012-03-22022 March 2012 Letter Request for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555, ME6556) Buried Piping and FP Follow Up Project stage: RAI ML12090A4892012-03-30030 March 2012 Response to NRC Request for Additional Information, Dated March 22, 2012 and Information Addressing Minor Errors or Omissions Related to License Renewal Application Project stage: Response to RAI ML12080A1902012-04-0505 April 2012 Request for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555 and ME6556) BWR SCC Smp and Ctws Follow Up Project stage: RAI ML12066A0262012-04-0909 April 2012 February 9, 2012, Summary of Telephone Conference Call Held Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, Llc. Concerning Request for Additional Information Pertaining to the Limerick Project stage: RAI ML12089A3772012-04-13013 April 2012 Request for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6556 and ME6555) Fluence and FP Followup RAIs Project stage: RAI ML12104A1182012-04-13013 April 2012 Response to NRC Requests for Additional Information, Dated April 5, 2012, Related to License Renewal Application Project stage: Response to RAI ML12082A1552012-04-16016 April 2012 Requests for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555 and ME6556) Project stage: RAI ML12095A3982012-04-17017 April 2012 Request for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos ME6555 and ME6556)TLAA Follow-up RAIs Project stage: RAI ML12025A0512012-04-20020 April 2012 Summary of Telephone Conference Call Held on January 18, 2012, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC, Concerning Request for Additional Information Pertaining to the Limerick Generation 1-18-12 Te Project stage: RAI ML12059A0802012-04-20020 April 2012 February 17, 2012, Summary of Telephone Conference Call Held Between U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC, Concerning Request for Additional Information Pertaining to the Limerick 2-17-12 Telecon Summary Project stage: RAI ML12018A0232012-04-26026 April 2012 1/12/2012 Telecon Summary Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC, Concerning Requests for Additional Information Pertaining to the Limerick Generating Station, License Renewal Application Project stage: RAI ML12111A0342012-04-30030 April 2012 Request for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555 and ME6556)SCC RAIs Project stage: RAI ML12125A3342012-05-0404 May 2012 Responses to NRC Requests for Additional Information, Dated April 17, 2012, Related to the License Renewal Application Project stage: Response to RAI ML12128A4382012-05-0707 May 2012 Responses to NRC Requests for Additional Information, Dated April 30, 2012, Related to the License Renewal Application Project stage: Response to RAI ML12152A3092012-05-31031 May 2012 Responses to NRC Requests for Additional Information, Dated May 18, 2012, Related to the License Renewal Application Project stage: Response to RAI ML12139A0662012-06-0707 June 2012 4-30-12 Telecon Summary Project stage: Other ML12157A2122012-06-12012 June 2012 Requests for Additional Information for the Review of the Limerick Generating Stations, Units 1 and 2, License Renewal Application (TAC Nos. ME6555 and ME6556) Ope Follow-up RAI Project stage: RAI ML12152A3052012-06-12012 June 2012 Request for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555, ME6556) Project stage: RAI ML12171A4872012-06-19019 June 2012 Responses to NRC Requests for Additional Information, Dated June 12, 2012, Related to the Limerick Generating Station License Renewal Application Project stage: Response to RAI ML12174A3292012-06-22022 June 2012 Response to NRC Request for Additional Information, Dated June 21, 2012, Related to License Renewal Application Project stage: Response to RAI ML12139A0612012-06-25025 June 2012 Summary of Telephone Conference Call Held on May 16, 2012, Between the U.S. Nuclear Regulatory Commission and Exelon Generation Company, LLC, Concerning Requests for Additional Information Pertaining to the Limerick Generating Station, Lice Project stage: RAI ML12193A1282012-07-10010 July 2012 2012/07/10 Limerick Lr - FW: Limerick: Request for Additional Information for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC Nos. ME6555 and ME6556) Project stage: Request ML12181A4412012-07-10010 July 2012 RAI for the Review of the Limerick Generating Station, Units 1 and 2, License Renewal Application (TAC No. ME6555 and ME6556) Project stage: RAI 2012-03-22
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Category:Letter
MONTHYEARIR 05000352/20243012024-02-0202 February 2024 Initial Operator Licensing Examination Report 05000352/2024301 and 05000353/2024301 IR 05000352/20230042024-01-31031 January 2024 Integrated Inspection Report 05000352/2023004 and 05000353/2023004 IR 05000352/20240112024-01-31031 January 2024 Information Request to Support Post-Approval Site Inspection for License Renewal; Inspection Report 05000352/2024011 ML24026A2962024-01-26026 January 2024 Supplement to License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System (PPS)- Syrs, . ML24004A0342024-01-17017 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0026 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) IR 05000352/20230102024-01-11011 January 2024 Age-Related Degradation Report 05000352/2023010 and 05000353/2023010 IR 05000352/20234012023-12-21021 December 2023 Cybersecurity Inspection Report 05000352/2023401 and 05000353/2023401 ML23321A2362023-12-14014 December 2023 Issuance of Amendment Nos. 262 and 224 Adoption of TSTF-477, Revision 3 and Associated Technical Specification Changes ML23278A1292023-12-14014 December 2023 Units 1 & 2; Limerick, Units 1 & 2; Nine Mile Point, Units 1 & 2; and Peach Bottom, Units 2 & 3 -Revision to Approved Alternatives to Use Boiling Water Reactor Vessel and Internals Project Guidelines ML23333A2182023-11-29029 November 2023 Operator Licensing Examination Approval ML23325A2062023-11-21021 November 2023 Supplement to License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System ML23313A0432023-11-13013 November 2023 Summary of Regulatory Audit in Support of Amendment Request for Control Room Air Conditioning Technical Specifications ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums IR 05000352/20230032023-10-27027 October 2023 Integrated Inspection Report 05000352/2023003 and 05000353/2023003 and Independent Spent Fuel Storage Installation Inspection 07200065/2023001 ML23297A1722023-10-24024 October 2023 Request for Information for a Biennial Problem Identification and Resolution Inspection; Inspection Report 05000352/2024010 and 05000353/2024010 IR 05000352/20235012023-10-17017 October 2023 Emergency Preparedness Biennial Exercise Inspection Report 05000352/2023501 and 05000353/2023501 RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans ML23279A0612023-10-0505 October 2023 Paragon Energy Solutions LLC, Part 21 Final Report Re Potential Defect with Eaton Jd and Hjd Series Molded Case Circuit Breakers (Mccbs) ML23276A5162023-10-0303 October 2023 Federal Emergency Management Agency Level 1 Finding from 2023 Evaluated Emergency Preparedness Exercise ML23275A1082023-09-29029 September 2023 FEMA Level 1 Findings Limerick NPP- Boyertown/Colebrookdale ML23241A9452023-09-27027 September 2023 Generation Station, Units 1 and 2 Regulatory Audit Plan Supporting Review of the Equipment Qualification Portion of Limerick Digital Instrumentation and Controls License Amendment Request ML23269A0522023-09-26026 September 2023 Request for Information and Notification of Conduct of IP 71111.21.N.04, Age-Related Degradation, Reference Inspection Report 05000352/2023010 and 05000353/2023010 ML23255A0952023-09-12012 September 2023 Resubmittal of License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System (PPS) to Address ML23254A0242023-09-0606 September 2023 Paragon Energy Solutions LLC, Potential Defect with Eaton Jd and Hjd Series Molded Case Circuit Breakers (Mccbs) ML23249A1002023-09-0606 September 2023 Requalification Program Inspection IR 05000352/20230052023-08-31031 August 2023 Updated Inspection Plan for Limerick Generating Station, Units 1 and 2 (Report 05000352/2023005 and 05000353/2023005) ML23248A2082023-08-31031 August 2023 UFSAR Cover Page ML23242A2172023-08-30030 August 2023 Response to Request for Additional Information for Application to Adopt TSTF-477, Revision 3, Add Action for Two Inoperable Control Room AC Subsystems and Associated Technical Specification Changes NMP2L2851, Relief Request Associated with Successive Inspections for Generic Letter 88-01 / BWRVIP-75-A Augmented Examinations2023-08-25025 August 2023 Relief Request Associated with Successive Inspections for Generic Letter 88-01 / BWRVIP-75-A Augmented Examinations ML23228A0942023-08-16016 August 2023 Response to Request for Additional Information for Supplemental License Amendment Request to Revise Technical Specifications and Exemption Request from Requirements of 10CFR50.62 ATWS Rule to Support the . IR 05000352/20230022023-08-14014 August 2023 Integrated Inspection Report 05000352/2023002 and 05000353/2023002 ML23220A0182023-08-0808 August 2023 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection 05000352/2023401 and 05000353/2023401 RS-23-087, Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor2023-08-0404 August 2023 Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor ML23212B2362023-07-31031 July 2023 Supplement to License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System - WEC Documents ML23212B1052023-07-31031 July 2023 Supplement to License Amendment Request to Revise Technical Specifications and Exemption Request from Requirements of 10CFR50.62 ATWS Rule to Support the Digital Modernization Project Installation - Revise ML23202A2192023-07-21021 July 2023 Response to Request for Additional Information for Supplemental License Amendment Request to Revise Technical Specifications and Exemption Request from Requirements of 10CFR50.62 ATWS Rule to Support the . ML23193B0122023-07-20020 July 2023 Audit Plan in Support of Review of License Amendment Request and Exemption Request for Digital Instrumentation and Controls Installation Support (Epids L-2023-LLA-0025 and L-2023-LLE-0005) ML23187A0962023-07-19019 July 2023 Generation Station, Unit Nos. 1 and 2 - Revised Estimated Review Completion Date Concerning License Amendment Request to Replace Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System ML23208A1522023-07-0606 July 2023 PEMA Letter Dated 7-6-23 Re Limerick Exercise 9-26-23 ML23177A2242023-06-26026 June 2023 Supplement to License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection . ML23145A1972023-06-23023 June 2023 Correction to the Renewed Facility Operating License Pages in Amendment Nos. 255, 256, 257, 258, 259, and 260 2024-02-02
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10CFR5010CFR5110CFR54February21,2013U.S.NuclearRegulatoryCommissionAttention:DocumentControlDeskWashington,DC20555-0001LimerickGeneratingStation,Units1and2FacilityOperatingLicenseNos.NPF-39andNPF-85NRCDocketNos.50-352and50-353Subject:ExelonGenerationCompany,LLCReviewoftheSafetyEvaluationReportrelatedtotheLimerickGeneratingStationLicenseRenewalApplicationReference:1.ExelonGenerationCompany,LLCletterfromMichaelP.GallaghertoNRCDocumentControlDesk,"ApplicationforRenewedOperatingLicenses",datedJune22,20112.LetterfromJohnW.Lubinski(NRC)toMichaelP.Gallagher(Exelon),"SafetyEvaluationReportRelatedtotheLicenseRenewalofLimerickGeneratingStation,Units1and2(TACNos.ME6555,ME6556)",datedJanuary10,2013IntheReference1letter,ExelonGenerationCompany,LLC(Exelon)submittedtheLicenseRenewalApplication(LRA)fortheLimerickGeneratingStation,Units1and2(LGS).IntheReference2letter,theU.S.NuclearRegulatoryCommissionissuedtheSafetyEvaluationReport(SER)relatedtotheLGSLicenseRenewalApplication.ExelonhascompleteditsreviewoftheSERandprovidescommentscontainedwithintheEnclosure.Therearenootherneworrevisedregulatorycommitmentscontainedinthisletter.Ifyouhaveanyquestions,pleasecontactMr.AIFulvio,Manager,ExelonLicenseRenewal,at610-765-5936.
U.S.NuclearRegulatoryCommissionFebruary21,2013Page2Respectfully,VicePresident-LicenseRenewalProjectsExelonGenerationCompany,LLCEnclosure:CommentsregardingtheSafetyEvaluationReportrelatedtotheLimerickGeneratingStationLicenseRenewalApplication.cc:RegionalAdministrator-NRCRegionINRCProjectManager(SafetyReview),NRR-DLRNRCProjectManager(EnvironmentalReview),NRR-DLRNRCProjectManager,NRR-DORLLimerickGeneratingStationNRCSeniorResidentInspector,LimerickGeneratingStationR.R.Janati,CommonwealthofPennsylvania
Enclosure
Page 1 of 3 Enclosure Comments regarding the Safety Evaluation Report related to the Limerick Generating Station License Renewal Application. The table on the following pages contains comments and suggestions for NRC staff consideration, based upon Exelon's review of the Limerick Generating Station, Units 1 and 2 Safety Evaluation (SER). An item number is provided in column 1, the SER Section number is given in column 2, the SER page number is listed in column 3 and the comment is provided in column 4.
Enclosure
Page 2 of 3 Comments regarding the Safety Evaluation Report related to the Limerick Generating Station License Renewal Application. Where suggested changes to the SER are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text. # Section # Page # Comment 1. 3.0.3.1.18 3-58 Delete the following in the third paragraph: "For penetrations 238 and 239 associated with the RHR system relief valves, the staff noted that Table 6.2-25, Note 23 of the UFSAR, indicates that through modifications performed at the first refueling the relief valve discharge line isolation valves are also subject either to local testing or removal and bench testing for subsequent LLRTs. Penetrations 238 and 239 are comprised by a "Double O-Ring with Seal Assembly," where typically, the seals per Table 6.2-25, Note 23 of the UFSAR, will be leak rate tested by pressurizing between the O-Rings." Comment:
As discussed in Exelon's response to RAI B.2.1.33-1, penetrations 238 and 239 include a suppression pool water seal, at least one isolation valve outside containment, and a closed system outside containment. Penetrations 238 and 239 are correctly discussed in the second paragraph. 2. 3.0.3.2.13 3-129 SER states that: "According to ASME Code Section XI, Subsection IWE, each "inspection period" and "inspection interval" are of 40 months and 120 months duration, respectively." Comment: Stating that each inspection period is 40 months in duration according to IWE Code is incorrect. ASME Code Section XI, Subsection IWE-2411 describes an Inspection Program B interval as 10 years. IWE-2412 and Table IWE-2412-1 indicate there are three periods in an Inspection Program B interval. Table IWE-2412-1 also indicates that periods of 4 years in duration are acceptable. LGS outages are conducted every 2 years and therefore some periods could be 4 years in duration. 3. 3.0.3.2.13 3-133 Delete the last part of the SER statement as shown in strikethrough below: "The staff reviewed the revised Commitment No. 30, as noted above, and found it acceptable because: (1) The applicant plans to recoat all local areas (less than 2.5 inches in diameter) of corrosion (pitting corrosion) that are greater than 50 mils plate thickness loss in the outage identified. in 2012 for Unit 1, and 2013 for Unit 2." Comment:
As stated in Commitment No. 30, the coating maintenance plan will be initiated in the 2012 refueling outage for unit 1 and the 2013 refueling outage for unit 2. Our commitment was revised in our September 12, 2012 letter to the staff to require recoating local areas (less than 2.5 inches in diameter) of general corrosion that are greater than 50 mils plate thickness loss in the outage they are identified. The commitment revision occurred after the Unit 1 outage in 2012 and therefore not all local areas of general corrosion greater than 50 mils plate thickness loss were recoated in that outage.
Enclosure
Page 3 of 3 Comments regarding the Safety Evaluation Report related to the Limerick Generating Station License Renewal Application. Where suggested changes to the SER are provided, they are highlighted with bolded italics for inserted text and strikethroughs for deleted text. # Section # Page # Comment 4. 3.7 3-412 Delete the part of the SER statement as shown in strikethrough below: "The staff reviewed the information in LRA Section 3, "Aging Management Review Results," and LRA Appendix B, "Aging Management Programs and Activities." On the basis of its review of the AMR results and AMPs, the staff concludes, with the exception of Open Items 3.0.3.2.13-1 and 3.0.5-1, that the applicant has demonstrated that the aging effects will be adequately managed so that the intended function(s) will be maintained consistent with the CLB for the period of extended operation, as required by 10 CFR 54.21 (a)(3). The staff also reviewed the applicable UFSAR supplement program summaries and concludes that the supplement adequately describes the AMPs credited for managing aging, as required by 10 CFR 54.21 (d).
With regard to these matters, the staff concludes, with the exception of Open Item 3.0.3.2.13-1 that there is reasonable assurance that the applicant will continue to conduct the activities authorized by the renewed licenses in accordance with the CLB, and any changes made to the CLB, in order to comply with 10 CFR 54.21 (a)(3), are in accordance with the Atomic Energy Act of 1954, as amended, and NRC regulations.".
Comment: Open items 3.0.3.2.13-1 and 3.0.5-1 are closed. 5. Appendix A, Item #38 A-24 Comment: Commitment #38 - Entry for the column entitled "Enhancements or Implementation Schedule."
The program for commitment #38 does not have enhancements.
The entry for this column should be revised to align with the LRA Appendix A, Table A.5. Delete: Program to be enhanced before the period of extended operation. Suggested reword: Program and initial inspections to be implemented before the period of extended operation.