|
|
| (7 intermediate revisions by the same user not shown) |
| Line 2: |
Line 2: |
| | number = ML15194A068 | | | number = ML15194A068 |
| | issue date = 07/20/2015 | | | issue date = 07/20/2015 |
| | title = Limerick Generating Station, Unit 2 - 180-Day Relaxation of Certain Schedule Requirements for Order EA-12-049 Issuance of Order to Modify Licenses with Regard to Requirements for Mitigating Strategies for Beyond Design Basis External Events | | | title = 180-Day Relaxation of Certain Schedule Requirements for Order EA-12-049 Issuance of Order to Modify Licenses with Regard to Requirements for Mitigating Strategies for Beyond Design Basis External Events |
| | author name = Dean W M | | | author name = Dean W |
| | author affiliation = NRC/NRR | | | author affiliation = NRC/NRR |
| | addressee name = Hanson B C | | | addressee name = Hanson B |
| | addressee affiliation = Exelon Generation Co, LLC | | | addressee affiliation = Exelon Generation Co, LLC |
| | docket = 05000353 | | | docket = 05000353 |
| | license number = | | | license number = |
| | contact person = Hughy J D, NRR/JLD, 415-3204 | | | contact person = Hughy J, NRR/JLD, 415-3204 |
| | case reference number = EA-12-049, TAC MF0848 | | | case reference number = EA-12-049, TAC MF0848 |
| | document type = Letter | | | document type = Letter |
| | page count = 4 | | | page count = 4 |
| | project = TAC:MF0848 | | | project = TAC:MF0848 |
| | stage = Issuance | | | stage = Approval |
| }} | | }} |
|
| |
|
| =Text= | | =Text= |
| {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 July 20, 2015 SUBJECT: LIMERICK GENERATING STATION, UNIT 2 -180-DAY RELAXATION OF CERTAIN SCHEDULE REQUIREMENTS FOR ORDER EA-12-049, "ISSUANCE OF ORDER TO MODIFY LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND DESIGN BASIS EXTERNAL EVENTS" (TAC NO. MF0848) Dear Mr. Hanson: The purpose of this letter is to inform Exelon Generation Company, LLC (Exelon, the licensee) of the disposition of the licensee's request by letter dated July 9, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML 15190A332), to relax the schedule for compliance with Order EA-12-049 for Limerick Generating Station (LGS), Unit 2. By letter dated March 12, 2012 (ADAMS Accession No. ML 12054A735), the U.S. Nuclear Regulatory Commission (NRC) ordered Exelon to take certain actions at Limerick Generating Station (LGS), Unit 2, associated with the Fukushima Near-Term Task Force Recommendations. Order EA-12-049 directed that actions be taken by licensees to develop and implement strategies to maintain or restore core cooling, containment cooling, and spent fuel pool cooling capabilities during beyond-design-basis external events. Section IV of NRC Order EA-12-049 states that licensees proposing to deviate from requirements contained in the order may request that the Director of the Office of Nuclear Reactor Regulation relax or rescind certain requirements. Condition IV.A.2 of NRC Order EA-12-049 requires full implementation of the order requirements no later than two refueling cycles after submittal of the overall integrated plan, or by December 31, 2016, whichever comes first. By letter dated April 15, 2014 (ADAMS Accession No. ML 14065A528), the NRC granted relaxation of certain schedule requirements of Order EA-12-049 related to full containment wetwell venting capability until completion of the spring 2017 refueling outage for LGS, Unit 2, consistent with the requirements of NRC Order EA-13-109, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013 (ADAMS Accession No. ML 13143A334). The NRC relaxation approval dated April 15, 2014, identified that the equipment and modifications required to implement the mitigating strategies required by Order EA-12-049 were to be completed and available for use in accordance with the original implementation schedule requirements, except for the primary containment venting strategy. By letter dated April 2, 2015 (ADAMS Accession No. ML 15092A833), the licensee informed the NRC of its additional LGS, Unit 2, request for schedule relaxation from compliance with Order EA-12-049 for no more than 90 days following restart from the spring 2015 refueling outage. The additional schedule relaxation was requested to allow completion of two LGS Flexible B. Hanson -2 -Coping Strategies (FLEX) equipment storage robust buildings. The NRC staff concluded that Exelon demonstrated good cause for relaxation and that appropriate compensatory measures were identified for the period of relaxation. Therefore, by letter dated April 29, 2015 (ADAMS Accession No. ML 15106A013), the NRC staff approved the 90-day relaxation request. By letter dated July 9, 2015, the licensee requested that the schedule relaxation from compliance with Order EA-12-049 be extended to 180 days for LGS, Unit 2, following restart from the spring 2015 refueling outage. The licensee's submittal stated that the additional relaxation is required due to further delays encountered in constructing the two LGS FLEX storage robust buildings. Specifically, Exelon identified that foundation-to-wall and wall-to-roof dowels were not installed per design drawings resulting in significant engineering redesign and construction rework. The redesign required that prefabricated construction materials be reordered with different dimensions. However, the new construction materials delivered to the site were incorrect and multiple attempts were required to obtain correctly fabricated construction materials. Additionally, the schedule delays extended the building projects into the peak construction season, resulting in difficulties obtaining qualified and trained craft resources in a timely manner. The licensee's 180-day schedule relaxation request dated July 9, 2015, stated that corrective actions have been implemented to address the issues described above. The corrective actions include: additional resources to perform quality assurance verifications; additional engineering resources to ensure thorough review of design changes and shop drawings to mitigate errors; additional craft and supervision resources; and additional engineering hold points for the work activities to verify compliance with the design. The licensee stated that LGS has implemented the mitigation strategy requirements imposed by NRC Order EA-12-049, with the exception of the primary containment venting strategy and the two FLEX equipment storage robust buildings, as discussed above. Therefore, the LGS FLEX mitigating strategy equipment is onsite and available, and the design and programmatic changes required to implement the LGS, Unit 2, mitigating strategies are complete. In addition, the compensatory measures established during the current 90-day schedule relaxation period will remain in place for the entire 180-day extension request or until the FLEX buildings are completed. Specifically, in order to maintain post-deployment capability, key FLEX equipment, such as large portable generators and pumps, will be stored in locations that provide physical separation. These locations will not be susceptible to flooding events or building collapse, minimizing the likelihood of one event impacting both sets of equipment. If hurricane conditions are predicted, one set of portable FLEX equipment will be moved to a protected location. The NRC staff has concluded that the construction quality issues, out-of-tolerance material deliveries and resource limitations reasonably prevented completion of the two FLEX equipment storage buildings within the previously approved 90-day schedule relaxation period. The staff also recognizes that Exelon has established corrective actions to address the construction delays and will maintain appropriate compensatory measures to maintain post deployment capabilities for the FLEX equipment. In light of the facts presented in the licensee's July 9, 2015, letter, the NRC staff has determined that the licensee has demonstrated good cause to relax the NRC Order EA-12-049 B. Hanson -3 -implementation date for 180 days following restart from the spring 2015 refueling outage. The LGS, Unit 2 restarted from this outage on May 4, 2015. Therefore, the schedule relaxation will extend to October 31, 2015. The NRC staff also considered that, following the accident at Fukushima Dai-ichi, the NRC concluded that a sequence of events such as the Fukushima ichi accident is unlikely to occur in the United States based on the current regulatory requirements and existing plant capabilities. Given the plant-specific circumstances at LGS, and that implementation of the mitigating strategies relaxed by this letter will be completed before December 2016, the NRC staff approves the requested relaxation. Accordingly, based upon the authority granted to the Director, Office of Nuclear Reactor Regulation, the requirement of implementation of mitigating strategies for LGS, Unit 2, associated with Order EA-12-049 is relaxed until no later than October 31, 2015. Full compliance with Order EA-12-049 remains the spring of 2017 refueling outage for LGS, Unit 2, as granted in NRC letter dated April 15, 2014, to allow the licensee sufficient time to implement a severe accident capable hardened containment wetwell vent. If you have any questions, please contact John Hughey at 301-415-3204. Sincerely, Directo,.r ____ _ Office of Nuclear Reactor Regulation Docket No. 50-353 cc: Listserv B. Hanson -3-implementation date for 180 days following restart from the spring 2015 refueling outage. The LGS, Unit 2 restarted from this outage on May 4, 2015. Therefore, the schedule relaxation will extend to October 31, 2015. The NRC staff also considered that, following the accident at Fukushima Dai-ichi, the NRC concluded that a sequence of events such as the Fukushima ichi accident is unlikely to occur in the United States based on the current regulatory requirements and existing plant capabilities. Given the plant-specific circumstances at LGS, and that implementation of the mitigating strategies relaxed by this letter will be completed before December 2016, the NRC staff approves the requested relaxation. Accordingly, based upon the authority granted to the Director, Office of Nuclear Reactor Regulation, the requirement of implementation of mitigating strategies for LGS, Unit 2, associated with Order EA-12-049 is relaxed until no later than October 31, 2015. Full compliance with Order EA-12-049 remains the spring of 2017 refueling outage for LGS, Unit 2, as granted in NRC letter dated April 15, 2014, to allow the licensee sufficient time to implement a severe accident capable hardened containment wetwell vent. If you have any questions, please contact John Hughey at 301-415-3204. Docket No. 50-353 cc: Listserv DISTRIBUTION: PUBLIC JLD R/F RidsAcrsAcnw_MailCTR Resource RidsNrrLASLent Resource Sincerely, IRA/ William M. Dean, Director Office of Nuclear Reactor Regulation RidsNrrDorllpl1-2 Resource RidsNrrPMLimerick Resource RidsRgn1 MailCenter Resource MHalter, NRR RidsNrrOd ADAMS Accession No.: ML15194A068 OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA OE NRR/JLD/JOMB/BC(A) NAME JHughey Slent RFretz MHalter DATE 07/13/15 07/13/15 07/15/15 07/13/15 OFFICE OGC (NLO) NRR/JLD/D NRR/D NAME DCylkowski JDavis WDean DATE 07/16/15 07/16/15 07/20/15 OFFICIAL RECORD COPY | | {{#Wiki_filter:UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 20, 2015 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 |
| }} | | |
| | ==SUBJECT:== |
| | LIMERICK GENERATING STATION, UNIT 2 - 180-DAY RELAXATION OF CERTAIN SCHEDULE REQUIREMENTS FOR ORDER EA-12-049, "ISSUANCE OF ORDER TO MODIFY LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND DESIGN BASIS EXTERNAL EVENTS" (TAC NO. MF0848) |
| | |
| | ==Dear Mr. Hanson:== |
| | |
| | The purpose of this letter is to inform Exelon Generation Company, LLC (Exelon, the licensee) of the disposition of the licensee's request by letter dated July 9, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15190A332), to relax the schedule for compliance with Order EA-12-049 for Limerick Generating Station (LGS), Unit 2. |
| | By letter dated March 12, 2012 (ADAMS Accession No. ML12054A735), the U.S. Nuclear Regulatory Commission (NRC) ordered Exelon to take certain actions at Limerick Generating Station (LGS), Unit 2, associated with the Fukushima Near-Term Task Force Recommendations. Order EA-12-049 directed that actions be taken by licensees to develop and implement strategies to maintain or restore core cooling, containment cooling, and spent fuel pool cooling capabilities during beyond-design-basis external events. |
| | Section IV of NRC Order EA-12-049 states that licensees proposing to deviate from requirements contained in the order may request that the Director of the Office of Nuclear Reactor Regulation relax or rescind certain requirements. Condition IV.A.2 of NRC Order EA-12-049 requires full implementation of the order requirements no later than two refueling cycles after submittal of the overall integrated plan, or by December 31, 2016, whichever comes first. |
| | By letter dated April 15, 2014 (ADAMS Accession No. ML14065A528), the NRC granted relaxation of certain schedule requirements of Order EA-12-049 related to full containment wetwell venting capability until completion of the spring 2017 refueling outage for LGS, Unit 2, consistent with the requirements of NRC Order EA-13-109, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013 (ADAMS Accession No. ML13143A334). The NRC relaxation approval dated April 15, 2014, identified that the equipment and modifications required to implement the mitigating strategies required by Order EA-12-049 were to be completed and available for use in accordance with the original implementation schedule requirements, except for the primary containment venting strategy. |
| | By letter dated April 2, 2015 (ADAMS Accession No. ML15092A833), the licensee informed the NRC of its additional LGS, Unit 2, request for schedule relaxation from compliance with Order EA-12-049 for no more than 90 days following restart from the spring 2015 refueling outage. |
| | The additional schedule relaxation was requested to allow completion of two LGS Flexible |
| | |
| | B. Hanson Coping Strategies (FLEX) equipment storage robust buildings. The NRC staff concluded that Exelon demonstrated good cause for relaxation and that appropriate compensatory measures were identified for the period of relaxation. Therefore, by letter dated April 29, 2015 (ADAMS Accession No. ML15106A013), the NRC staff approved the 90-day relaxation request. |
| | By letter dated July 9, 2015, the licensee requested that the schedule relaxation from compliance with Order EA-12-049 be extended to 180 days for LGS, Unit 2, following restart from the spring 2015 refueling outage. The licensee's submittal stated that the additional relaxation is required due to further delays encountered in constructing the two LGS FLEX storage robust buildings. Specifically, Exelon identified that foundation-to-wall and wall-to-roof dowels were not installed per design drawings resulting in significant engineering redesign and construction rework. The redesign required that prefabricated construction materials be reordered with different dimensions. However, the new construction materials delivered to the site were incorrect and multiple attempts were required to obtain correctly fabricated construction materials. Additionally, the schedule delays extended the building projects into the peak construction season, resulting in difficulties obtaining qualified and trained craft resources in a timely manner. |
| | The licensee's 180-day schedule relaxation request dated July 9, 2015, stated that corrective actions have been implemented to address the issues described above. The corrective actions include: additional resources to perform quality assurance verifications; additional engineering resources to ensure thorough review of design changes and shop drawings to mitigate errors; additional craft and supervision resources; and additional engineering hold points for the work activities to verify compliance with the design. |
| | The licensee stated that LGS has implemented the mitigation strategy requirements imposed by NRC Order EA-12-049, with the exception of the primary containment venting strategy and the two FLEX equipment storage robust buildings, as discussed above. Therefore, the LGS FLEX mitigating strategy equipment is onsite and available, and the design and programmatic changes required to implement the LGS, Unit 2, mitigating strategies are complete. |
| | In addition, the compensatory measures established during the current 90-day schedule relaxation period will remain in place for the entire 180-day extension request or until the FLEX buildings are completed. Specifically, in order to maintain post-deployment capability, key FLEX equipment, such as large portable generators and pumps, will be stored in locations that provide physical separation. These locations will not be susceptible to flooding events or building collapse, minimizing the likelihood of one event impacting both sets of equipment. If hurricane conditions are predicted, one set of portable FLEX equipment will be moved to a protected location. |
| | The NRC staff has concluded that the construction quality issues, out-of-tolerance material deliveries and resource limitations reasonably prevented completion of the two FLEX equipment storage buildings within the previously approved 90-day schedule relaxation period. The staff also recognizes that Exelon has established corrective actions to address the construction delays and will maintain appropriate compensatory measures to maintain post deployment capabilities for the FLEX equipment. |
| | In light of the facts presented in the licensee's July 9, 2015, letter, the NRC staff has determined that the licensee has demonstrated good cause to relax the NRC Order EA-12-049 |
| | |
| | B. Hanson implementation date for 180 days following restart from the spring 2015 refueling outage. The LGS, Unit 2 restarted from this outage on May 4, 2015. Therefore, the schedule relaxation will extend to October 31, 2015. The NRC staff also considered that, following the accident at Fukushima Dai-ichi, the NRC concluded that a sequence of events such as the Fukushima Dai-ichi accident is unlikely to occur in the United States based on the current regulatory requirements and existing plant capabilities. Given the plant-specific circumstances at LGS, and that implementation of the mitigating strategies relaxed by this letter will be completed before December 2016, the NRC staff approves the requested relaxation. |
| | Accordingly, based upon the authority granted to the Director, Office of Nuclear Reactor Regulation, the requirement of implementation of mitigating strategies for LGS, Unit 2, associated with Order EA-12-049 is relaxed until no later than October 31, 2015. Full compliance with Order EA-12-049 remains the spring of 2017 refueling outage for LGS, Unit 2, as granted in NRC letter dated April 15, 2014, to allow the licensee sufficient time to implement a severe accident capable hardened containment wetwell vent. |
| | If you have any questions, please contact John Hughey at 301-415-3204. |
| | Sincerely, |
| | &.&~. Directo,.r_ _ _ __ |
| | Office of Nuclear Reactor Regulation Docket No. 50-353 cc: Listserv |
| | |
| | ML15194A068 OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA OE NRR/JLD/JOMB/BC(A) |
| | NAME JHughey Slent RFretz MHalter DATE 07/13/15 07/13/15 07/15/15 07/13/15 OFFICE OGC (NLO) NRR/JLD/D NRR/D NAME DCylkowski JDavis WDean DATE 07/16/15 07/16/15 07/20/15}} |
Letter Sequence Approval |
|---|
|
Results
Other: ML13357A331, ML15054A366, ML17059D129, RS-13-032, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), RS-13-122, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), RS-13-123, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), RS-14-200, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051), RS-14-210, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design- Basis External Events (Order Number EA-12-049), RS-16-024, Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), RS-17-062, Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
|
MONTHYEARRS-13-032, Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)2013-02-28028 February 2013
Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
Project stage: Other
ML13171A3152013-06-24024 June 2013
Request for Additional Information Overall Integrated Plan in Response to Order EA-12-051, Reliable Spent Fuel Pool Instrumentation
Project stage: RAI
RS-13-177, Response to Request for Additional Information - Overall Integrated Plan in Response to Commission Order Modifying License Requirements for Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)2013-07-18018 July 2013
Response to Request for Additional Information - Overall Integrated Plan in Response to Commission Order Modifying License Requirements for Reliable Spent Fuel Pool Instrumentation (Order No. EA-12-051)
Project stage: Response to RAI
RS-13-122, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)2013-08-28028 August 2013
First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
Project stage: Other
RS-13-123, First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)2013-08-28028 August 2013
First Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
Project stage: Other
ML13273A5382013-10-23023 October 2013
Interim Staff Evaluation and Request for Additional Information Regarding the Overall Integrated Plan for Implementation of Order EA-12-051, Reliable Spent Fuel Pool Instrumentation
Project stage: RAI
ML13357A3312014-01-0606 January 2014
Mega-Tech Services, LLC Technical Evaluation Report Regarding the Overall Integrated Plan for Limerick Generating Station, Units 1 and 2, TAC Nos.: MF0847 and MF0848
Project stage: Other
ML13337A6002014-01-10010 January 2014
Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigation Strategies)
Project stage: Acceptance Review
RS-14-200, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)2014-08-28028 August 2014
Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)
Project stage: Other
RS-14-210, Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design- Basis External Events (Order Number EA-12-049)2014-08-28028 August 2014
Third Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design- Basis External Events (Order Number EA-12-049)
Project stage: Other
ML15054A3662015-03-17017 March 2015
Report for the Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA-12-051
Project stage: Other
RS-15-101, Request for Schedule Relaxation from NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.2015-04-0202 April 2015
Request for Schedule Relaxation from NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events.
Project stage: Request
RS-15-183, Request for Second Schedule Relaxation from NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events2015-07-0909 July 2015
Request for Second Schedule Relaxation from NRC Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events
Project stage: Request
ML15194A0682015-07-20020 July 2015
180-Day Relaxation of Certain Schedule Requirements for Order EA-12-049 Issuance of Order to Modify Licenses with Regard to Requirements for Mitigating Strategies for Beyond Design Basis External Events
Project stage: Approval
RS-16-024, Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)2016-02-26026 February 2016
Sixth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
Project stage: Other
ML17059D1292017-02-28028 February 2017
Eighth Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond Design-Basis External Events
Project stage: Other
RS-17-062, Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)2017-07-20020 July 2017
Report of Full Compliance with March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
Project stage: Other
2014-08-28
[Table View] |
|
|---|
Category:Letter
MONTHYEARML24151A3842024-10-31031 October 2024
– Issuance of Amendment Nos. 264 and 226 Support to Digital Modernization Project Installation (EPID L-2023-LLA-0025) and Exemption from the Requirements of 10 CFR 50.62
ML24303A0902024-10-29029 October 2024
Operator Licensing Examination Approval
ML24303A2782024-10-29029 October 2024
10 CFR 50.46 Annual Report
ML24299A2642024-10-25025 October 2024
Response to Request for Supplemental Information Needed for Acceptance of Requested Licensing Action Regarding Primary Containment Leakage Technical Specifications
IR 05000352/20240122024-10-17017 October 2024
Commercial Grade Dedication Inspection Report 05000352/2024012 and 05000353/2024012
RS-24-093, Response to Request for Additional Information - Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests2024-10-10010 October 2024
Response to Request for Additional Information - Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests
ML24274A2372024-10-0707 October 2024
– Supplemental Information Needed for Acceptance of Requested Licensing Action Regarding Primary Containment Leakage Technical Specifications
ML24278A3022024-10-0404 October 2024
Supplement to License Amendment Request to Revise Technical Specifications and Exemption Request from Requirements of 10 CFR 50.62 ATWS Rule to Support the Digital Modernization Project Installation - Rev Unit 2 Technical Spec
ML24275A2442024-10-0303 October 2024
Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief, Division of Operating Reactor Licensing
ML24263A0032024-09-27027 September 2024
Generation Station, Units 1 and 2 – Regulatory Audit Plan Supporting Review of the Component Interface Module System of the Limerick Digital Instrumentation and Controls License Amendment Request (EPID L-2022-LLA-0140) (Redacted)
ML24243A0482024-09-19019 September 2024
Generation Station, Unit Nos. 1 and 2 - Schedule Update for License Amendment Request to Replace Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System
ML24215A4042024-09-18018 September 2024
Request for Withholding Information from Public Disclosure
IR 05000352/20244202024-09-16016 September 2024
– Security Baseline Inspection Report 05000352/2024420 and 05000353/2024420
RS-24-090, Response to Request for Additional Information - Relief Request Concerning Extension of Permanent Relief from Ultrasonic Examination of Reactor Pressure Vessel Circumferential Shell Welds2024-09-12012 September 2024
Response to Request for Additional Information - Relief Request Concerning Extension of Permanent Relief from Ultrasonic Examination of Reactor Pressure Vessel Circumferential Shell Welds
IR 05000352/20250102024-09-10010 September 2024
Information Request for Quadrennial Baseline Comprehensive Engineering Team Inspection; Notification to Perform Inspection 05000352/2025010 and 05000353/2025010
ML24255A8642024-09-0606 September 2024
Rscc Wire & Cable LLC Dba Marmon Industrial Energy & Infrastructure - Part 21 Retraction of Final Notification
IR 05000352/20240052024-08-29029 August 2024
Updated Inspection Plan for Limerick Generating Station, Units 1 and 2 (Report 05000352/2024005 and 05000353/2024005)
ML24241A1952024-08-28028 August 2024
License Amendment Request for Modification to Technical Specification 3.6.1.2 and Main Steam Isolation Valve Leakage Rate Requirements
ML24239A3972024-08-23023 August 2024
Rssc Wire & Cable LLC Dba Marmon - Part 21 Final Notification - 57243-EN 57243
ML24163A3902024-08-14014 August 2024
Request for Withholding Information from Public Disclosure
ML24220A2392024-08-12012 August 2024
Correction to Technical Specification Page 3/4 3-11 in Amendment No. 225
IR 05000352/20240022024-08-12012 August 2024
Integrated Inspection Report 05000352/2024002 and 05000353/2024002
ML24222A6772024-08-0909 August 2024
Response to Request for Additional Information for Application to Revise Technical Specifications to Adopt TSTF-591-A, Revise Risk Informed Completion Time (RICT) Program Revision 0 and Revise 10 CFR 50.69 License Condition
ML24204A0712024-07-29029 July 2024
Issuance of Amendment Nos. 263 and 225 Technical Specifications for Main Steam Line Tunnel Temperature
ML24208A0962024-07-25025 July 2024
57243-EN 57243 - Rssc Wire & Cable LLC, Dba Marmon - Part 21 Notification
ML24208A1592024-07-25025 July 2024
Regulatory Audit Plan Supporting Review of the System Development Portion of Limerick Digital Instrumentation and Controls License Amendment Request (EPID L-2022-LLA-0140) - Non-Proprietary
ML24201A1662024-07-19019 July 2024
Response to Request for Additional Information for License Amendment Request for Proposed Changes to the Technical Specification Isolation Actuation Instrumentation Tables and New Turbine Enclosure Main Steam L
ML24199A1842024-07-15015 July 2024
RAI-LAR for Limerick EPID: L-2024-LLA-0079- Use This Version
RS-24-070, Independent Spent Fuel Storage Installation, Nine Mile Point, Units 1 and 2, Quad Cities, Units 1 and 2, R. E. Ginna - Nuclear Radiological Emergency Plan Document Revisions2024-07-12012 July 2024
Independent Spent Fuel Storage Installation, Nine Mile Point, Units 1 and 2, Quad Cities, Units 1 and 2, R. E. Ginna - Nuclear Radiological Emergency Plan Document Revisions
ML24180A1572024-06-28028 June 2024
Request to Return and Replace WEC Documents (EQ-EV-386-GLIM, EQ-QR- 433-GLIM, and APP-GW-GLR-611), to Meet 10CFR2.390 Request to Withdraw from Public Disclosure Requirements
ML24170A7702024-06-20020 June 2024
Individual Notice of Consideration of Issuance of Amendments to Renewed Facility Operating Licenses, Proposed No Significant Hazards Consideration Determination, Opportunity for Hearing(Epid L-2024-LLA-0079) LTR
05000352/LER-2024-003, Core Operating Limits Report Thermal Limit Exceeded for Unit 1 Fuel Bundle GGK1232024-06-18018 June 2024
Core Operating Limits Report Thermal Limit Exceeded for Unit 1 Fuel Bundle GGK123
ML24166A1142024-06-14014 June 2024
Response to Requests for Additional Information (RAIs 15 Through 23) for License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems
RS-24-061, Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Examinations2024-06-14014 June 2024
Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Examinations
ML24165A2642024-06-13013 June 2024
License Amendment Request for Proposed Changes to the Technical Specification Isolation Actuation Instrumentation Tables and New Turbine Enclosure Main Steam Line Tunnel Temperature TS 3/4.7.9
05000352/LER-2024-002, Invalid Actuation Due to a Trip of 1B Reactor Protection System Circuit Breaker2024-06-10010 June 2024
Invalid Actuation Due to a Trip of 1B Reactor Protection System Circuit Breaker
ML24151A2882024-06-10010 June 2024
Request for Withholding Information from Public Disclosure
ML24151A2012024-06-10010 June 2024
Request for Withholding Information from Public Disclosure
05000352/LER-2024-001, Leakage for the Unit 1 `B Outboard Main Steam Isolation Valve Exceeded Technical Specification Limit2024-06-10010 June 2024
Leakage for the Unit 1 `B Outboard Main Steam Isolation Valve Exceeded Technical Specification Limit
ML24150A0242024-05-29029 May 2024
Notification of Commercial Grade Dedication Inspection (05000352/2024012 and 05000353/2024012) and Request for Information
ML24149A2112024-05-28028 May 2024
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
ML24079A0762024-05-23023 May 2024
Issuance of Amendments to Adopt TSTF 264
IR 05000352/20243022024-05-20020 May 2024
Revised Initial Operator Licensing Examination Report 05000352/2024302 and 05000353/2024302
RS-24-055, 2023 Corporate Regulatory Commitment Change Summary Report2024-05-17017 May 2024
2023 Corporate Regulatory Commitment Change Summary Report
IR 05000352/20240012024-05-0707 May 2024
Integrated Inspection Report 05000352/2024001 and 05000353/2024001
ML24124A0432024-05-0303 May 2024
Response to Requests for Additional Information (RAIs 9 Through 14) for License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with
RS-24-038, Relief Request Concerning Extension of Permanent Relief from Ultrasonic Examination of Reactor Pressure Vessel Circumferential Shell Welds2024-05-0202 May 2024
Relief Request Concerning Extension of Permanent Relief from Ultrasonic Examination of Reactor Pressure Vessel Circumferential Shell Welds
RS-24-041, Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests2024-04-30030 April 2024
Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests
ML24114A3222024-04-23023 April 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) - Pivot to Unit
ML24109A0702024-04-18018 April 2024
Supplement to License Amendment Request to Revise Technical Specifications and Exemption Request from Requirements of 10CFRC50.52 ATWS Rule to Support the Digital Modernization Project Installation .
2024-09-06
[Table view] |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 20, 2015 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
LIMERICK GENERATING STATION, UNIT 2 - 180-DAY RELAXATION OF CERTAIN SCHEDULE REQUIREMENTS FOR ORDER EA-12-049, "ISSUANCE OF ORDER TO MODIFY LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND DESIGN BASIS EXTERNAL EVENTS" (TAC NO. MF0848)
Dear Mr. Hanson:
The purpose of this letter is to inform Exelon Generation Company, LLC (Exelon, the licensee) of the disposition of the licensee's request by letter dated July 9, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15190A332), to relax the schedule for compliance with Order EA-12-049 for Limerick Generating Station (LGS), Unit 2.
By letter dated March 12, 2012 (ADAMS Accession No. ML12054A735), the U.S. Nuclear Regulatory Commission (NRC) ordered Exelon to take certain actions at Limerick Generating Station (LGS), Unit 2, associated with the Fukushima Near-Term Task Force Recommendations. Order EA-12-049 directed that actions be taken by licensees to develop and implement strategies to maintain or restore core cooling, containment cooling, and spent fuel pool cooling capabilities during beyond-design-basis external events.
Section IV of NRC Order EA-12-049 states that licensees proposing to deviate from requirements contained in the order may request that the Director of the Office of Nuclear Reactor Regulation relax or rescind certain requirements. Condition IV.A.2 of NRC Order EA-12-049 requires full implementation of the order requirements no later than two refueling cycles after submittal of the overall integrated plan, or by December 31, 2016, whichever comes first.
By letter dated April 15, 2014 (ADAMS Accession No. ML14065A528), the NRC granted relaxation of certain schedule requirements of Order EA-12-049 related to full containment wetwell venting capability until completion of the spring 2017 refueling outage for LGS, Unit 2, consistent with the requirements of NRC Order EA-13-109, "Issuance of Order to Modify Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions," dated June 6, 2013 (ADAMS Accession No. ML13143A334). The NRC relaxation approval dated April 15, 2014, identified that the equipment and modifications required to implement the mitigating strategies required by Order EA-12-049 were to be completed and available for use in accordance with the original implementation schedule requirements, except for the primary containment venting strategy.
By letter dated April 2, 2015 (ADAMS Accession No. ML15092A833), the licensee informed the NRC of its additional LGS, Unit 2, request for schedule relaxation from compliance with Order EA-12-049 for no more than 90 days following restart from the spring 2015 refueling outage.
The additional schedule relaxation was requested to allow completion of two LGS Flexible
B. Hanson Coping Strategies (FLEX) equipment storage robust buildings. The NRC staff concluded that Exelon demonstrated good cause for relaxation and that appropriate compensatory measures were identified for the period of relaxation. Therefore, by letter dated April 29, 2015 (ADAMS Accession No. ML15106A013), the NRC staff approved the 90-day relaxation request.
By letter dated July 9, 2015, the licensee requested that the schedule relaxation from compliance with Order EA-12-049 be extended to 180 days for LGS, Unit 2, following restart from the spring 2015 refueling outage. The licensee's submittal stated that the additional relaxation is required due to further delays encountered in constructing the two LGS FLEX storage robust buildings. Specifically, Exelon identified that foundation-to-wall and wall-to-roof dowels were not installed per design drawings resulting in significant engineering redesign and construction rework. The redesign required that prefabricated construction materials be reordered with different dimensions. However, the new construction materials delivered to the site were incorrect and multiple attempts were required to obtain correctly fabricated construction materials. Additionally, the schedule delays extended the building projects into the peak construction season, resulting in difficulties obtaining qualified and trained craft resources in a timely manner.
The licensee's 180-day schedule relaxation request dated July 9, 2015, stated that corrective actions have been implemented to address the issues described above. The corrective actions include: additional resources to perform quality assurance verifications; additional engineering resources to ensure thorough review of design changes and shop drawings to mitigate errors; additional craft and supervision resources; and additional engineering hold points for the work activities to verify compliance with the design.
The licensee stated that LGS has implemented the mitigation strategy requirements imposed by NRC Order EA-12-049, with the exception of the primary containment venting strategy and the two FLEX equipment storage robust buildings, as discussed above. Therefore, the LGS FLEX mitigating strategy equipment is onsite and available, and the design and programmatic changes required to implement the LGS, Unit 2, mitigating strategies are complete.
In addition, the compensatory measures established during the current 90-day schedule relaxation period will remain in place for the entire 180-day extension request or until the FLEX buildings are completed. Specifically, in order to maintain post-deployment capability, key FLEX equipment, such as large portable generators and pumps, will be stored in locations that provide physical separation. These locations will not be susceptible to flooding events or building collapse, minimizing the likelihood of one event impacting both sets of equipment. If hurricane conditions are predicted, one set of portable FLEX equipment will be moved to a protected location.
The NRC staff has concluded that the construction quality issues, out-of-tolerance material deliveries and resource limitations reasonably prevented completion of the two FLEX equipment storage buildings within the previously approved 90-day schedule relaxation period. The staff also recognizes that Exelon has established corrective actions to address the construction delays and will maintain appropriate compensatory measures to maintain post deployment capabilities for the FLEX equipment.
In light of the facts presented in the licensee's July 9, 2015, letter, the NRC staff has determined that the licensee has demonstrated good cause to relax the NRC Order EA-12-049
B. Hanson implementation date for 180 days following restart from the spring 2015 refueling outage. The LGS, Unit 2 restarted from this outage on May 4, 2015. Therefore, the schedule relaxation will extend to October 31, 2015. The NRC staff also considered that, following the accident at Fukushima Dai-ichi, the NRC concluded that a sequence of events such as the Fukushima Dai-ichi accident is unlikely to occur in the United States based on the current regulatory requirements and existing plant capabilities. Given the plant-specific circumstances at LGS, and that implementation of the mitigating strategies relaxed by this letter will be completed before December 2016, the NRC staff approves the requested relaxation.
Accordingly, based upon the authority granted to the Director, Office of Nuclear Reactor Regulation, the requirement of implementation of mitigating strategies for LGS, Unit 2, associated with Order EA-12-049 is relaxed until no later than October 31, 2015. Full compliance with Order EA-12-049 remains the spring of 2017 refueling outage for LGS, Unit 2, as granted in NRC letter dated April 15, 2014, to allow the licensee sufficient time to implement a severe accident capable hardened containment wetwell vent.
If you have any questions, please contact John Hughey at 301-415-3204.
Sincerely,
&.&~. Directo,.r_ _ _ __
Office of Nuclear Reactor Regulation Docket No. 50-353 cc: Listserv
ML15194A068 OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA OE NRR/JLD/JOMB/BC(A)
NAME JHughey Slent RFretz MHalter DATE 07/13/15 07/13/15 07/15/15 07/13/15 OFFICE OGC (NLO) NRR/JLD/D NRR/D NAME DCylkowski JDavis WDean DATE 07/16/15 07/16/15 07/20/15
