RS-17-133, Additional Supplemental Information Regarding LaSalle County Station License Amendment Request for Extension of Type a and Type C Containment Leak Rate Test Intervals

Additional Supplemental Information Regarding LaSalle County Station License Amendment Request for Extension of Type a and Type C Containment Leak Rate Test Intervals

ML17277A219
Person / Time
Site:	LaSalle
Issue date:	10/03/2017
From:	Gullott D Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-17-133
Download: ML17277A219 (5)

Text

4300 Winfield Road AdENEW Warrenville, IL 60555 Exelon Generation... 630 657 2000 Office RS-17-133 10 C F R 50.90 October 3, 2017 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374

Subject:

Additional Supplemental Information Regarding LaSalle County Station License Amendment Request for Extension of Type A and Type C Containment Leak Rate Test Intervals

References:

1) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request to Revise Technical Specifications 5.5.13, 'Primary Containment Leakage Rate Testing Program,' for Permanent Extension of Type A and Type C Leak Rate Test Frequencies," dated October 26, 2016 (ADAMS Accession No. ML16300A200)

2) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Supplement to License Amendment Request for Permanent Extension of Type A and Type C Leak Rate Test Frequencies Regarding Hardened Containment Vent System (HCVS)

Modifications and Installation of Primary Containment Isolation Valves (PCIVs)," dated February 16, 2016 (ADAMS Accession No. ML17048A255)

3) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding LaSalle County Station License Amendment Request for Extension of Type A and Type C Containment Leak Rate Test Intervals (SBPB Branch)," dated July 17, 2017 (ADAMS Accession No. ML17200C944)

4) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding LaSalle County Station License Amendment Request for Extension of Type A and Type C Containment Leak Rate Test Intervals (PRA Branch)," dated August 8, 2017 (ADAMS Accession No. ML17220Al68)

October 3, 2017 U.S. Nuclear Regulatory Commission Page 2

5) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Supplemental Information Regarding LaSalle County Station License Amendment Request for Extension of Type A and Type C Containment Leak Rate Test Intervals," dated September 27, 2017 (ADAMS Accession No. ML17270A274)

By a letter to the U.S. Nuclear Regulatory Commission (NRC) dated October 26, 2016, (Reference 1), Exelon Generation Company, LLC (EGC) submitted an amendment request for LaSalle County Station (LSCS), Units 1 and 2. The proposed amendment would revise the Technical Specifications (TS) 5.5.13, "Primary Containment Leakage Rate Testing Program,"

to allow for the permanent extension of the Type A integrated leak rate testing (ILRT) and Type C leak rate testing frequencies. This request was supplemented by EGC letters dated February 16, July 17, August 8, and September 27, 2017 (References 2, 3, 4, and 5).

As discussed during a conference call with the NRC on September 28, 2017, additional supplemental information is being provided to support the NRC's review of the EGC request submitted on October 26, 2016 (Reference 1) and the supplement submitted September 27, 2017 (Reference 5). The Attachment to this letter provides the supplemental information.

EGC has reviewed the information supporting a finding of no significant hazards consideration that was previously provided to the NRC in Attachment 1 of Reference 1. The supplemental information provided in this submittal does not affect the bases for concluding that the proposed license amendment request does not involve a significant hazards consideration. In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), EGC is notifying the State of Illinois of this application for license amendment by transmitting a copy of this letter and its Attachment to the designated State Official.

There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Ms. Lisa A. Simpson at (630) 657-2815.

1 declare under penalty of perjury that the foregoing is true and correct. Executed on the 3rd day of October 2017.

Respectfully, s ~

David M. Gullott Manager Licensing Exelon Generation Company, LLC

Attachment:

Supplemental Information cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector, LaSalle County Station Illinois Emergency Management Agency Division of Nuclear Safety

ATTACHMENT Supplemental Information By a letter to the U.S. Nuclear Regulatory Commission (NRC) dated October 26, 2016, Exelon Generation Company, LLC (EGC) submitted an amendment request to revise the Technical Specifications (TS) 5.5.13, "Primary Containment Leakage Rate Testing Program," to allow for the permanent extension of the Type A integrated leak rate testing (ILRT) and Type C leak rate testing frequencies for LaSalle County Station (LSCS), Units 1 and 2. This request was supplemented by EGC letters dated February 16, July 17, August 8, and September 27, 2017 (References 2, 3, 4, and 5).

As discussed during a conference call with the NRC on September 28, 2017, supplemental information is being provided to support the NRC's review of the EGC request submitted on October 26, 2016 (Reference 1) and the supplement submitted September 27, 2017 (Reference 5). The information below provides a detailed explanation of Tables 3.4.5-1 and 3.4.5-2 in Reference 1.

References:

1) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request to Revise Technical Specifications 5.5.13, 'Primary Containment Leakage Rate Testing Program,' for Permanent Extension of Type A and Type C Leak Rate Test Frequencies," dated October 26, 2016 (ADAMS Accession No. ML16300A200)

2) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Supplement to License Amendment Request for Permanent Extension of Type A and Type C Leak Rate Test Frequencies Regarding Hardened Containment Vent System (HCVS)

Modifications and Installation of Primary Containment Isolation Valves (PCIVs)," dated February 16, 2016 (ADAMS Accession No. ML17048A255)

3) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding LaSalle County Station License Amendment Request for Extension of Type A and Type C Containment Leak Rate Test Intervals (SBPB Branch)," dated July 17, 2017 (ADAMS Accession No. ML17200C944)

4) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information Regarding LaSalle County Station License Amendment Request for Extension of Type A and Type C Containment Leak Rate Test Intervals (PRA Branch)," dated August 8, 2017 (ADAMS Accession No. ML17220A168)

5) Letter from D. M. Gullott (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Supplemental Information Regarding LaSalle County Station License Amendment Request for Extension of Type A and Type C Containment Leak Rate Test Intervals," dated September 27, 2017 (ADAMS Accession No. ML17270A274)

6) Letter from C. Gratton (U.S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Nuclear), "LaSalle County Station, Units 1 and 2 Issuance of Amendments Re: Application of Alternative Source Term JAC Nos. ME0068 and ME0069," dated September 6, 2010 (ADAMS Accession No. ML101750625)

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ATTACHMENT Supplemental I nformation The following information is provided for the purposes of correction and clarification.

The maximum allowable primary leakage containment leakage rate, La , changed from 0.635 percent to 1.0 percent with the approval of Alternative Source Term (AST) on September 6, 2010 (Reference 6).

Pn.t - AST

- The leakage acceptance value, La is equal to 1.0 % of containment air weight per day (Reference TS 5.5.13, "Primary Containment Leakage Rate Testing Program").

- La is currently equivalent to 640.4 standard cubic ft per hour (SCFH). This value was calculated using Attachment B of EGC program procedure LTS-300-4, Revision 29, "Unit 1(2) Primary Containment Integrated Leak Rate Test (ILRT)."

- 0.6 La is currently equal to 384.2 SCFH. This value was calculated based on the La value given in EGC program procedure LTS-300-4, Revision 29.

- An administrative limit for 0.6 La (i.e., less than 384.2 SCFH) is utilized by LSCS for the Type B and C tests. This administrative limit is used for the purpose of providing operating margin below the 0.6 La value of 384.2 SCFH.

Pra - ART

- Prior to the implementation of AST at LSCS, La was equal to 0.635 % of containment air weight per day (Reference 6).

- Prior to the implementation of AST at LSCS, La was equivalent to 387.8 SCFH. This value was calculated using Attachment B of EGC program procedure LTS-300-4, Revision 26, "Unit 1(2) Primary Containment Integrated Leak Rate Test (ILRT)."

- Prior to the implementation of AST at LSCS, 0.6 La was equal to 232.7 SCFH.

This value was calculated based on the La value given in EGC program procedure LTS-300-4, Revision 26.

- Prior to the implementation of AST at LSCS, an administrative limit for 0.6 La (i.e., less than 232.7 SCFH) was utilized by LSCS for the purpose of providing operating margin below the 0.6 La value of 232.7 SCFH.

The percentages shown in Tables 3.4.5-1 and 3.4.5-2 of Reference 1 were originally calculated using the administrative limits for 0.6 La that were applicable at the time of the tests. The administrative limits for 0.6 La have changed over time due to engineering judgement.

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ATTACHMENT Supplemental Information As shown below, Tables 3.4.5-1 and 3.4.5-2 of Reference 1 have been updated to present the data based on the actual 0.6 La values applicable at the time rather than the administrative limits. This summary demonstrates a history of satisfactory Type B and Type C tested components performance from 2005 through 2016 for LSCS, Units 1 and 2.

Table 3.4.5 LCSC Unit 1 Type B and C LLRT Combined As-Found/As-Left Trend Summary Pre-AST Post-AST 2 2006 2008 2010 2012 2014 2016 RFO L1 R11 L1 R12 L1 R13 L1 R14 L1 R15 L1 R16 AF Min Path 122.01 88.98 106.54 104.31 115.88 169.34 (SCFH)

Fraction of 52.43% 38.24% 45.78% 27.15% 30.16% 44.08%

0.6 La AL Max Path 145.81 160.06 187.49 206.39 192.03 221.08 SCFH Fraction of 62.66% 68.78% 80.57% 53.72% 49.98% 57.54%

0.6 La AL Min Path 80.79 78.21 72.25 101.23 115.55 112.97 SCFH Fraction of 34.72% 33.61% 31.05% 26.35% 30.08% 29.40%

0.6 La Note 1: Prior to the implementation of AST at LSCS, 0.6 La was equal to 232.7 SCFH.

Note 2: 0.6 La is currently equal to 384.2 SCFH.

Table 3.4.5 LCSC Unit 2 Type B and C LLRT Combined As-Found/As-Left Trend Summary Pre-AST' Post-AST 2 2005 2007 2009 2011 2013 2015 RFO L2R10 L2R11 L2R12 L2R13 L2R14 L2R15 AF Min Path 106.9 56.61 85.17 92.56 110.37 148.72 (SCFH)

Fraction of 45.94% 24.33% 36.60% 24.09% 28.73% 38.71%

0.6 La AL Max Path 173.17 125.11 136.35 150.35 160.93 214.14 SCFH Fraction of 74.42% 53.76% 58.59% 39.13% 41.89% 55.74%

0.6 La AL Min Path 73.99 55.8 62.25 77.14 73.38 117.98 SCFH Fraction of 31.80% 23.98% 26.75% 20.08% 19.10% 30.71%

0.6 La Note 1: Prior to the implementation of AST at LSCS, 0.6 La was equal to 232.7 SCFH.

Note 2: 0.6 La is currently equal to 384.2 SCFH.

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