RS-15-305, Corrections to the License Renewal Application Dated December 9, 2014

Corrections to the License Renewal Application Dated December 9, 2014

ML15336A220
Person / Time
Site:	LaSalle
Issue date:	12/02/2015
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-15-305, TAC MF5346, TAC MF5347
Download: ML15336A220 (13)

Text

Michael P. Gallagher Vice President. License Renewal Exelon Generation Exelon Nuclear 200 Exelon Way Kennett Square. PA 19348 610 765 5958 Office 610 765 5956 Fax www.exeloncorp.com michaelp.gallagher@exeloncorp.com 10 CFR 50 10 CFR 51 10 CFR 54 RS-15-305 December 2, 2015 U.S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Corrections to the LaSalle County Station, Units 1 and 2, License Renewal Application (TAC Nos. MF5347 and MF5346)

Reference:

Letter from Michael P. Gallagher, Exelon Generation Company LLC (Exelon) to NRC Document Control Desk, dated December 9, 2014, "Application for Renewed Operating Licenses" In the Reference letter, Exelon Generation Company, LLC (Exelon) submitted the License Renewal Application (LRA) for the LaSalle County Station (LSCS), Units 1 and 2. Exelon has identified a number of corrections that need to be made to the LRA.

The Enclosure to this letter provides a description of each correction, and corresponding mark-ups to affected portions of the LRA, thereby supplementing the LSCS LRA.

Change #3 addresses License Renewal Change Request (LRCR) REGION-10, involving an operating experience example provided in the LRA for the BWR Feedwater Nozzle aging management program. This item was identified during the NRC Region Ill IP-71002 Inspection in October 2015.

This submittal has been discussed with the NRC License Renewal Project Manager for the LSCS License Renewal project.

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

December 2, 2015 U.S. Nuclear Regulatory Commission Page 2 If you have any questions, please contact Mr. John Hufnagel, Licensing Lead, LaSalle License Renewal Project, at 610-765-5829.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on

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Respectfully, M~~~--*

Vice President - License Renewal Projects Exelon Generation Company, LLC

Enclosure:

Corrections to the LSCS LRA cc: Regional Administrator - NRC Region Ill NRC Project Manager (Safety Review), NRR-DLR NRC Project Manager (Environmental Review), NRR-DLR NRC Project Manager, NRR-DORL- LaSalle County Station NRC Senior Resident Inspector, LaSalle County Station Illinois Emergency Management Agency - Division of Nuclear Safety

RS-15-305 Enclosure Page 1 of 11 Enclosure Corrections to the LSCS LRA Introduction This enclosure contains five (5) License Renewal Application (LRA) corrections that were identified subsequent to the submittal of the LRA. In addition, a discrepancy in the response to RAI B.2.1.13-3, provided in Exelon Letter RS-15-193, is addressed. For each correction, the change is described and the affected page number(s) and portion of the LRA is provided. For clarity, entire sentences or paragraphs from the LRA, as modified by previous RAI responses, are provided with deleted text highlighted by strikethroughs and inserted text highlighted by bolded italics. Revisions to LRA tables are shown by providing excerpts from the affected tables.

RS-15-305 Enclosure Page 2 of 11 Change #1: Condenser and Air Removal System Affected LRA Section: 2.3.4.2 LRA Page Number: 2.3-146 Description of Change: An inconsistency has been identified in the Reason for Scope Determination paragraph provided in LRA Section 2.3.4.2 for the Condenser and Air Removal System. It is stated in this paragraph that the Condenser and Air Removal System is not in scope under 10 CFR 54.4(a)(2) because failure of nonsafety-related portions of the system would not prevent satisfactory accomplishment of function(s) identified for 10 CFR 54.4(a)(1).

This is contrary to the list of system intended functions for the Condenser and Air Removal System which includes 10 CFR 54.4(a)(2) intended functions for post-accident containment holdup and plate out of MSIV bypass leakage and to minimize the release of radioactive material to the environment. The Reason for Scope Determination paragraph is revised to correct this inconsistency, as shown below.

Reason for Scope Determination The Condenser and Air Removal System meets 10 CFR 54.4(a)(1) because it is a safety-related system that is relied upon to remain functional during and following design basis events.

The Condenser and Air Removal System is not in scope under 10 CFR 54.4(a)(2) because failure of nonsafety-related portions of the system would not prevent satisfactory accomplishment of function(s) identified for 10 CFR 54.4(a)(1). The Condenser and Air Removal System meets 10 CFR 54.4(a)(2) because failure of nonsafety-related portions of the system could prevent satisfactory accomplishment of function(s) identified for 10 CFR 54.4(a)(1). The Condenser and Air Removal System also meets 10 CFR 54.4(a)(3) because it is relied upon in the safety analyses and plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for Environmental Qualification (10 CFR 50.49). The Condenser and Air Removal System is not relied upon in any safety analyses or plant evaluations to perform a function that demonstrates compliance with the Commission's regulations for Fire Protection (10 CFR 50.48), Anticipated Transient Without Scram (10 CFR 50.62), and Station Blackout (10 CFR 50.63).

RS-15-305 Enclosure Page 3 of 11 Change #2: Nonessential Cooling Water System Affected LRA Sections: Table 2.3.3-14 and Table 3.3.2-14 LRA Page Numbers: 2.3-94 and 3.3-183 Description of Change: Nonessential Cooling Water System Service Water Strainers 0WS01F, 1WS01F, and 2WS01F shown on license renewal boundary drawing LR-LAS-M-68, sheet 1 (dwg coordinates C, D, and E-4) are in the water supply to the Fire Water System and are in scope for 10 CFR 54.4(a)(3). The strainer bodies are included in LRA Table 2.3.3-14, Nonessential Cooling Water System Components Subject to Aging Management Review, and Table 3.3.2-14, Nonessential Cooling Water System Summary of Aging Management Evaluation, under the component type of piping, piping components, and piping elements with a component intended function of pressure boundary. However, the strainers also have an intended function to filter which was not identified as a component function in the LRA. LRA Table 2.3.3-14 is revised to add the component type of strainer element with a component intended function of filter. LRA Table 3.3.2-14 is revised to add the component type of strainer element with an intended function of filter with the corresponding material, environment, and aging management line item. These changes are shown below.

RS-15-305 Enclosure Page 4 of 11 Table 2.3.3-14 Nonessential Cooling Water System Components Subject to Aging Management Review Component Type Intended Function Bolting Mechanical Closure Structural Integrity Heat Exchanger - (Aux Bldg HVAC Leakage Boundary Condenser Unit) Tube Side Components Heat Exchanger - (Aux Bldg HVAC Leakage Boundary Condenser Unit) Tubes Heat Exchanger - (Counting Room HVAC Leakage Boundary Condenser Unit) Tube Side Components Heat Exchanger - (Counting Room HVAC Leakage Boundary Condenser Unit) Tubes Heat Exchanger - (Fuel Pool Cooling) Leakage Boundary Tube Side Components Heat Exchanger - (Primary Containment Leakage Boundary Ventilation Chiller Service Water Condenser) Tube Side Components Heat Exchanger - (Primary Containment Leakage Boundary Ventilation Chiller Service Water Condenser) Tubes Heat Exchanger - (Process Computer Leakage Boundary Room A/C Unit) Tube Side Components Heat Exchanger - (Process Computer Leakage Boundary Room A/C Unit) Tubes Heat Exchanger - (Reactor Building Leakage Boundary Closed Cooling Water Heat Exchanger)

Tube Side Components Piping, piping components, and piping Leakage Boundary elements Pressure Boundary Pump Casing (Service Water) Pressure Boundary Strainer Element Filter Tanks (Clean Gland Water) Leakage Boundary Traveling Water Screen Framework Structural Integrity Valve Body Leakage Boundary Pressure Boundary

RS-15-305 Enclosure Page 5 of 11 Table 3.3.2-14 Nonessential Cooling Water System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Programs Item Management Piping, piping Pressure Boundary Carbon Steel Raw Water (Internal) Loss of Material Open-Cycle Cooling Water VII.C1.AP-183 3.3.1-38 C components, and System (B.2.1.12)

VII.C1.A-400 3.3.1-127 E, 4 piping elements Soil (External) Loss of Material Buried and Underground VII.C3.AP-198 3.3.1-106 A Piping (B.2.1.28)

Stainless Steel Air - Indoor None None VII.J.AP-17 3.3.1-120 A Uncontrolled (External)

Raw Water (Internal) Loss of Material Open-Cycle Cooling Water VII.C1.A-54 3.3.1-40 A System (B.2.1.12)

Pump Casing Pressure Boundary Gray Cast Iron Air - Indoor Loss of Material External Surfaces VII.I.A-77 3.3.1-78 A (Service Water) Uncontrolled (External) Monitoring of Mechanical Components (B.2.1.24)

Condensation Loss of Material External Surfaces VII.C1.A-405 3.3.1-132 A, 7 (External) Monitoring of Mechanical Components (B.2.1.24)

Raw Water (Internal) Loss of Material Open-Cycle Cooling Water VII.C1.AP-183 3.3.1-38 C System (B.2.1.12)

Selective Leaching VII.C1.A-51 3.3.1-72 A (B.2.1.22)

Strainer Element Filter Stainless Steel Raw Water (External) Loss of Material Open-Cycle Cooling VII.C1.A-54 3.3.1-40 A Water System (B.2.1.12)

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

Condensation Loss of Material External Surfaces VII.C1.A-405 3.3.1-132 A, 7 (External) Monitoring of Mechanical Components (B.2.1.24)

Raw Water (Internal) Loss of Material Open-Cycle Cooling Water VII.C1.AP-183 3.3.1-38 C System (B.2.1.12)

RS-15-305 Enclosure Page 6 of 11 Change #3: BWR Feedwater Nozzle Affected LRA Section: B.2.1.5 LRA Page Number: B-33 Description of Change: An inconsistency has been identified in the Operating Experience discussion provided in LRA Appendix B, Section B.2.1.5 for the BWR Feedwater Nozzle aging management program. In Operating Experience item 3, it is stated that minor recordable indications were noted and evaluated as acceptable within the software used by the automated UT inspection equipment, consistent with ASME Code, Section XI Article IWB-3000 criteria.

The software used by the automated UT inspection equipment only provided the input data from the ultrasonic examination that was evaluated by the analyst that is trained and qualified to perform the examination and evaluate the data. Operating Experience item 3 is revised to correct this inconsistency, as shown below.

Operating Experience

3. The feedwater nozzles have been inspected for cracking as part of the existing augmented ISI program in accordance with the guidance in GE-NE-523-A71-0594-A, Revision 1. Each nozzle has been inspected at least twice using UT techniques recommended within GE-NE-523-A71-0594-A, Revision 1. Minor recordable indications were noted and evaluated as acceptable within the software used by the automated UT inspection equipment, consistent with ASME Code, Section XI Article IWB-3000 criteria, during the following inspections of feedwater nozzles:

The Unit 1 N4A, C, D, E, F feedwater nozzle-to-vessel welds in 2012, during refueling outage L1R14.

The Unit 2 N4A, D, E feedwater nozzle-to-vessel welds in 2011, during refueling outage L2R13.

In addition, as part of the ISI program, a reactor vessel pressure test is performed during each refueling outage to verify no unacceptable reactor coolant pressure boundary leakage. These pressure tests have not identified any leakage from the feedwater nozzles.

RS-15-305 Enclosure Page 7 of 11 Change #4: BWR Vessel Internals Affected LRA Section: B.2.1.9 LRA Page Number: B-44 Description of Change: An inconsistency has been identified in the Program Description provided in LRA Appendix B, Section B.2.1.9 for the BWR Vessel Internals aging management program. In the section for Core Spray inspections, it is stated that The repair design criteria in BWRVIP-16-A and BWRVIP-19-A would be utilized in preparing a repair plan for the core plate.

BWRVIP-16-A and BWRVIP-19-A provide guidance for preparing a repair plan for core spray piping and sparger components that are internal to the reactor vessel. The Core Spray portion of the Program Description is revised to correct this inconsistency, as shown below.

Program Description Core Spray: Inspections and evaluations are performed in accordance with BWRVIP-18-R1-A. The repair design criteria in BWRVIP-16-A and BWRVIP-19-A would be utilized in preparing a repair plan for the core plate spray components that are internal to the reactor vessel.

RS-15-305 Enclosure Page 8 of 11 Change #5: Plant Drainage System Affected LRA Sections: Table 3.3.2-16 LRA Page Numbers: 3.3-195 Description of Change: Modifications have been done to upgrade the current carbon steel sump pumps with more corrosion resistant stainless steel sump pumps in the Plant Drainage System. Stainless steel was not included in the LRA for sump pumps in the Plant Drainage System. LRA Table 3.3.2-16, Plant Drainage System Summary of Aging Management Evaluation, is revised to add the material type of Stainless Steel to the component type of Pump Casing (Sump Pumps) with the corresponding environments and aging management line items, as shown below.

RS-15-305 Enclosure Page 9 of 11 Table 3.3.2-16 Plant Drainage System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Programs Item Management Pump Casing Leakage Boundary Ductile Cast Iron Waste Water (Internal) Loss of Material Inspection of Internal VII.E5.AP-281 3.3.1-91 A (Drywell Floor and Surfaces in Miscellaneous Drywell Equipment Piping and Ducting Drain Pumps) Components (B.2.1.25)

Pump Casing Leakage Boundary Ductile Cast Iron Air - Indoor Loss of Material External Surfaces VII.I.A-77 3.3.1-78 A (Reactor Building Uncontrolled (External) Monitoring of Mechanical Equipment Drain Components (B.2.1.24)

Pump) Waste Water (Internal) Loss of Material Inspection of Internal VII.E5.AP-281 3.3.1-91 A Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

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

Waste Water (Internal) Loss of Material Inspection of Internal VII.E5.AP-281 3.3.1-91 A Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

Stainless Steel Air - Indoor None None VII.J.AP-17 3.3.1-120 A Uncontrolled (External)

Waste Water (Internal) Loss of Material Inspection of Internal VII.E5.AP-278 3.3.1-95 A Surfaces in Miscellaneous Piping and Ducting Components (B.2.1.25)

RS-15-305 Enclosure Page 10 of 11 Change #6: Fire Protection System Affected LRA Sections: Table 3.3.2-12 LRA Page Numbers: 3.3-167 and 3.3-171 Description of Change: In the response to RAI B.2.1.13-3 under Exelon Letter RS-15-193, dated August 6, 2015, Table 3.3.2-12, Fire Protection System, line item Tanks (Retard Chambers) was updated to include Aging Effect Requiring Management - Cracking, Aging Management Programs - Closed Treated Water Systems (B.2.1.13), and Notes - H,11. On further review it was determined that these items were added in error and do not apply to the Tanks (Retard Chambers) which have a raw water internal environment. LRA Table 3.3.2-12 is revised to remove the erroneous line items and note added in the response to RAI B.2.1.13-3 under Exelon Letter RS-15-193, dated August 6, 2015, as shown below.

RS-15-305 Enclosure Page 11 of 11 Table 3.3.2-12 Fire Protection System (Continued)

Component Intended Material Environment Aging Effect Aging Management NUREG-1801 Table 1 Item Notes Type Function Requiring Programs Item Management Tanks (Retard Pressure Boundary Copper Alloy Air - Indoor None None VII.J.AP-144 3.3.1-114 C Chamber) with 15% Zinc or Uncontrolled (External)

More Raw Water (Internal) Cracking Closed Treated Water H, 11 Systems (B.2.1.13)

Loss of Material Fire Water System VII.G.AP-197 3.3.1-64 D (B.2.1.17)

Selective Leaching VII.C2.AP-43 3.3.1-72 C (B.2.1.22)

Ductile Cast Iron Air - Indoor Loss of Material External Surfaces VII.I.A-77 3.3.1-78 A Uncontrolled (External) Monitoring of Mechanical Components (B.2.1.24)

Raw Water (Internal) Loss of Material Fire Water System VII.G.A-33 3.3.1-64 D (B.2.1.17)

Table 3.3.2-12 Fire Protection System (Continued)

Plant Specific Notes: (continued)

11. The aging effects for copper alloy with 15% zinc or more in a closed cycle cooling water environment include cracking. The Closed Treated Water Systems (B.2.1.13) program is used to manage cracking for this component, material, and environment combination.