RS-16-033, Update to Commitment 47 Related to the License Renewal Application

Update to Commitment 47 Related to the License Renewal Application

ML16032A381
Person / Time
Site:	LaSalle
Issue date:	02/01/2016
From:	Gallagher M Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-16-033, TAC MF5346, TAC MF5347
Download: ML16032A381 (6)

Text

Michael P. Gallagher Exelon Generation Vice President. License Renewal Exelon Nuclear 200 Exelon Way RS-16-033 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 February 1, 2016 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 50-37 4

Subject:

Update to Commitment 47 related to the LaSalle County Station, Units 1 and 2, License Renewal Application (TAC Nos. MF5347 AND MF5346)

References:

1. Letter from Michael P. Gallagher, Exelon Generation Company LLC (Exelon) to NRC Document Control Desk, dated December 9, 2014, "Application for Renewed Operating Licenses"

2. Letter from Michael P. Gallagher, Exelon Generation Company LLC (Exelon) to NRC Document Control Desk, dated September 15, 2015, "Response to NRC Requests for Additional Information, Set 9, dated August 18, 2015 related to the LaSalle County Station, Units 1 and 2, License Renewal Application (TAC Nos.

MF5347 and MF5346)"

3. Letter from Michael P. Gallagher, Exelon Generation Company LLC (Exelon) to NRC Document Control Desk, dated January 7, 2016, "Responses to NRC Requests for Additional Information, Set 14, dated December 14, 2015, and Two Additional Commitment Implementation Schedule Clarifications, related to the LaSalle County Station, Units 1 and 2, License Renewal Application (TAC Nos.

MF5347 and MF5346)"

4. Teleconference Summary from Jeffrey S. Mitchell, USN RC, dated January 29, 2016, "Summary of Teleconference held on January 21, 2016, between the U.S.

Nuclear Regulatory Commission and Exelon Generation Co., LLC, concerning RAI 4.2.10-1 response pertaining to the LaSalle County Station, Units 1 and 2, License Renewal Application (TAC Nos. MF5347 and MF5346)"

In Reference 1, Exelon Generation Company, LLC (Exelon) submitted the License Renewal Application (LRA) for the LaSalle County Station (LSCS), Units 1 and 2, which included license

February 1, 2016 U.S. Nuclear Regulatory Commission Page 2 renewal Commitment 47, pertaining to aging management of the LSCS Unit 1 jet pump slip joint clamps. In Reference 2, Exelon responded to RAI 4.2.10-1, providing information to the NRC Staff regarding how Exelon will ensure that the limiting fluence value will not be exceeded. In that letter, Exelon noted that an action tracking assignment within the commitment management program will be established to ensure that appropriate corrective actions are taken to repair, replace, or reanalyze the clamps in advance of reaching the fluence limit.

In Reference 3, as part of an overall update to license renewal commitment implementation schedule, Exelon revised the Commitment 47 implementation schedule information to clarify that the procedure that tracks the cumulative effective full power years (EFPY), discussed in Reference 2, will be enhanced no later than six months prior to the period of extended operation.

As documented in Reference 4, a teleconference was held on January 21, 2016 to gain resolution on remaining NRC staff questions related to the LSCS Unit 1 jet pump slip joint clamp TLAA aging management and associated Commitment 47. As an outcome of the telecon, this LRA supplement is being submitted to document resolution, including a clarification regarding the action tracking item discussed in Reference 2, and an update to Commitment 47.

Enclosure A provides a description of this LRA Supplement.

Enclosure B provides an update to the License Renewal Commitment List (LRA Appendix A, Section A.5). There are no other LRA changes or new or revised regulatory commitments contained in this letter.

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

() ~ - 0 l - 2ot,,b Respectfully, Vice President - License Renewal Projects Exelon Generation Company, LLC

Enclosures:

A. Description of LSCS LRA Supplement B. LSCS License Renewal Commitment List Update

February 1, 2016 U.S. Nuclear Regulatory Commission Page 3 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-16-033 Enclosure A Page 1 of 1 Enclosure A Description of LSCS LRA Supplement Related to Unit 1 Jet Pump Slip Joint Clamps This enclosure provides a description of a revision to Commitment 47 that manages the TLAA for stress relaxation for the Unit 1 jet pump slip joint clamps due to neutron fluence as described in LRA Section 4.2.10 of the License Renewal Application (LRA).

As discussed in LRA Section 4.2.10, the allowable 30 percent stress relaxation for the Unit 1 jet pump slip joint clamps is projected to occur at a neutron fluence value that corresponds to 50.7 effective full power years (EFPY). Actions that can be taken to manage this TLAA through the end of the period of extended operation include replacement of the clamps, repair of the clamps to maintain acceptable clamp preload, or revision of the analysis to establish a higher allowable neutron fluence value. Because this TLAA is dispositioned as being managed for the period of extended operation pursuant to 10 CFR 54.24 (c)(1)(iii), if a revised analysis is performed to support the TLAA, it will be submitted to NRC for review prior to exceeding the time based limit.

Therefore, Commitment 47 is being revised to require that if a revised analysis is performed, the analysis must be submitted for NRC review at least 2 years prior to exceeding 50.7 EFPY.

The response to RAI 4.2.10-1, provided within the Exelon letter dated September 15, 2015, included a discussion of activities that will be used to ensure that the limiting fluence value for the Unit 1 jet pump slip joint clamps will not be exceeded. The response stated that a commitment tracking assignment for Commitment 47 will include an action tracking assignment with a due date approximately five years prior to the estimated calendar date that 50.7 EFPY will be reached for Unit 1. As discussed by Exelon in the January 21, 2016 telecon with NRC Staff (Reference 4), the purpose of that action tracking assignment is to prompt the initiation of corrective actions to ensure adequate time to implement the appropriate corrective action so that the Unit 1 jet pump slip joint clamps will be repaired, replaced, or reanalyzed prior to exceeding the limiting neutron fluence value.

LRA Appendix A, Section A.5, Commitment 47 is revised as shown in Enclosure B.

RS-16-033 Enclosure B Page 1 of 2 Enclosure B LSCS License Renewal Commitment List Update This Enclosure provides an update to the LRA Appendix A, Section A.5, License Renewal Commitment List. Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRCs information and are not regulatory commitments.

Changes to the LRA Appendix A, Section A.5, License Renewal Commitment List are as a result of this LRA Supplement, pertaining to Commitment 47 and the Unit 1 jet pump slip joint clamps.

To facilitate understanding, relevant portions of the previously submitted License Renewal Commitment List have been repeated in this Enclosure, with revisions indicated. Previously submitted information is shown in normal font. Changes are highlighted with bolded italics for inserted text and strikethroughs for deleted text.

RS-16-033 Enclosure B Page 2 of 2 LRA Appendix A, Section A.5, License Renewal Commitment List, Commitment 47 on LRA page A-80, is revised as shown below.

NO.

PROGRAM OR TOPIC COMMITMENT IMPLEMENTATION SCHEDULE*

SOURCE 47 TLAA - Slip Joint Clamp Prior to exceeding the limiting fluence value of 1.17E+20 n/cm2 at the Unit 1 jet pump slip joint clamp location, estimated to be at 50.7 EFPY, revise the analysis for the slip joint clamps for a higher acceptable fluence value or take other corrective action such as repair or replacement of the clamps to ensure acceptable clamp preload.

Procedure tracking the cumulative EFPY values to be enhanced no later than six months prior to the period of extended operation Additional schedule information identified in commitment.

For the analysis option, if selected, the revised analysis must be submitted to the NRC for review at least 2 years prior to exceeding 50.7 EFPY.

For the repair or replacement options, if selected, repair or replacement must be implemented prior to exceeding 50.7 EFPY.

Section A.4.2.10 Exelon Letter RS-15-232 09/15/2015 Exelon Letter RS-16-003 01/07/2016 Exelon Letter RS-16-033 02/01/2016