NUREG-2171 Supp 1, 'Safety Evaluation Report Related To .
NUREG-2171Supplement 1Safety Evaluation ReportRelated to the LicenseRenewal of LimerickGenerating Station,Units 1 and 2Office of Nuclear Reactor Regulation
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NUREG-2171Supplement 1Safety Evaluation ReportRelated to the LicenseRenewal of LimerickGenerating Station,Units 1 and 2Supplement 1Docket Nos. 50-352 and 50-353Manuscript Completed: September 2014Date Published: September 2014Office of Nuclear Reactor Regulation
ABSTRACTThis document is a supplemental safety evaluation report (SSER) for the license renewalapplication (LRA) for Limerick Generating Station (LGS), Units 1 and 2, as submitted by ExelonGeneration Company, LLC (Exelon or the applicant). By letter dated June 22, 2011, Exelonsubmitted its LRA to the U.S. Nuclear Regulatory Commission (NRC) for renewal of the LGSoperating licenses for an additional 20 years. The NRC staff (the staff) issued a safetyevaluation report (SER) related to the license renewal of Limerick Generating Station, Units 1and 2, dated January 10, 2013, (Agencywide Documents Access and Management SystemAccession No. ML13015A191), which summarizes the results of its review of the LRA forcompliance with the requirements of Title 10, Part 54, of the Code of Federal Regulations,(10 CFR Part 54), “Requirements for Renewal of Operating Licenses for Nuclear Power Plants.”This SSER documents the staff’s review of supplemental information provided by the applicantsince the issuance of the SER. This information includes annual updates required by10 CFR 54.21(b) and updated information and commitments in response to the recent industryoperating experience.iii
TABLE OF CONTENTSABSTRACT . iiiABBREVIATIONS . viiSECTION 1 INTRODUCTION AND GENERAL DISCUSSION . 1-11.1 Introduction. 1-11.4 Interim Staff Guidance . 1-1SECTION 2 STRUCTURES AND COMPONENTS SUBJECT TO AGINGMANAGEMENT REVIEW . 2-1SECTION 3 AGING MANAGEMENT REVIEW RESULTS . 3-13.0 Applicant’s Use of the Generic Aging Lessons Learned (GALL) Report . 3-13.0.3 Aging Management Programs (AMPs) . 3-13.0.3.1 AMPs Consistent with the GALL Report . 3-13.0.3.2 AMPs Consistent with the GALL Report with Exceptionsor Enhancements. 3-13.0.3.3 Staff Evaluation of LRA Changes to IncorporateLR-ISG-2012-02, “Aging Management of InternalSurfaces, Fire Water Systems, Atmospheric StorageTanks, and Corrosion Under Insulation” . 3-103.0.3.4 Aging Management Related to Loss of Coating Integrityfor Internal Coatings on In-Scope Mechanical SSCs . 3-303.1 Aging Management of Reactor Coolant System . 3-483.2 Aging Management of Engineered Safety Features Section . 3-483.3 Aging Management of Auxiliary Systems . 3-483.4 Aging Management of Steam and Power Conversion Systems . 3-513.5 Aging Management of Containments, Structures, and ComponentSupports . 3-523.6 Aging Management of Electrical and Instrumentation and ControlSystems . 3-53SECTION 4 TIME LIMITED AGING ANALYSES . 4-1SECTION 5 REVIEW BY THE ADVISORY COMMITTEE ON REACTOR SAFEGUARDS . 5-1SECTION 6 CONCLUSION . 6-1APPENDIX A LIMERICK GENERATING STATION, UNITS 1 AND 2 LICENSERENEWAL COMMITMENTS.A-1APPENDIX B CHRONOLOGY .B-1APPENDIX C PRINCIPAL CONTRIBUTORS.C-1APPENDIX D REFERENCES .D-1v
ABBREVIATIONSACRSAdvisory Committee on Reactor SafeguardsADAMSAgencywide Documents Access and Management SystemAERMaging effect requiring managementAMPaging management programAMRaging management reviewANSIAmerican National Standards InstituteASMEAmerican Society of Mechanical EngineersASTMAmerican Society for Testing and MaterialsCAPcorrective action programCFRCode of Federal RegulationsCLBcurrent licensing basisCLSMcontrolled low strength materialCUIcorrosion under insulationEDGemergency diesel generatorEPRIElectric Power Research InstituteExelonExelon Generation Company, LLCGALLGeneric Aging Lessons LearnedGLgeneric letterHDPEhigh-density polyethyleneHPCIhigh-pressure coolant injectionLGSLimerick Generating StationLRAlicense renewal applicationLR-ISGlicense renewal interim staff guidancevii
MCRmain control roommVmillivolt(s)NACENational Association of Corrosion EngineersNFPANational Fire Protection AssociationNRCU.S. Nuclear Regulatory CommissionOEoperating experienceohm-cmohm-centimeter(s)PIVpost indicating valvesppmpart(s) per millionpsidpound(s) per square inch differentialRAIrequest for additional informationRCICreactor core isolation coolingRECWreactor enclosure cooling waterRGregulatory guideSCCstress-corrosion crackingSERsafety evaluation reportSRP-LR“Standard Review Plan for Review of License Renewal Applications forNuclear Power Plants, Rev.2”SSCsystem, structure, and componentSSERsupplemental safety evaluation reportSWservice waterUFSARupdated final safety analysis reportUTultrasonic testingVT-3visual examinationviii
SECTION 1INTRODUCTION AND GENERAL DISCUSSION1.1 IntroductionThis document is a supplemental safety evaluation report (SSER) for the license renewalapplication (LRA) for Limerick Generating Station (LGS), Units 1 and 2, as submitted by ExelonGeneration Company, LLC (Exelon or the applicant). By letter dated June 22, 2011, Exelonsubmitted its LRA to the U.S. Nuclear Regulatory Commission (NRC) for renewal of the LGSoperating licenses for an additional 20 years. The NRC staff (the staff) issued a safetyevaluation report (SER) related to the license renewal of LGS, Units 1 and 2, datedJanuary 10, 2013 (Agencywide Documents Access and Management System (ADAMS)Accession No. ML13015A191), which summarizes the results of its review of the LRA forcompliance with the requirements of Title 10, Part 54, of the Code of Federal Regulations(10 CFR Part 54), “Requirements for Renewal of Operating Licenses for Nuclear Power Plants.”This SSER documents the staff’s review of additional information provided by the applicantsince the staff’s issuance of the SER in January 2013. This information includes annualupdates required by 10 CFR 54.21(b) and updated information and commitments in response tothe recent industry operating experience. This SSER supplements portions of SERSections 1, 3, Appendix A, and Appendix B.1.4 Interim Staff GuidanceLicense renewal is a living program. The staff, industry, and other interested stakeholders gainexperience and develop lessons learned with each renewed license. The lessons learnedaddress the staff’s performance goals of maintaining safety, improving effectiveness andefficiency, reducing regulatory burden, and increasing public confidence. License renewalinterim staff guidance (LR-ISG) is documented for use by the staff, industry, and otherinterested stakeholders until incorporated into such license renewal guidance documents as theNUREG–1800 “Standard Review Plan for Review of License Renewal Applications for NuclearPower Plants,” Revision 2, December 2010 (SRP-LR) and the NUREG–1801, “Generic AgingLessons Learned Report,” Revision 2, December 2010 (GALL Report).Table 1.4-1 shows the current set of LR-ISGs addressed in this SSER, as well as the SSERsections in which the staff addresses them. This SSER also discusses operating experienceconcerning loss of coating integrity of internal coatings of piping, piping components, heatexchangers, and tanks.1-1
Table 1.4-1 Current License Renewal Interim Staff GuidanceISG Issue(Approved ISG Number)“Changes to the Generic AgingLessons Learned (GALL) ReportRevision 2, Aging ManagementProgram (AMP) XI.M41, Buriedand Underground Piping andTanks”(LR-ISG-2011-03)PurposeThis LR-ISG provides changes toGALL Report AMP XI.M41 as anacceptable approach formanaging the effects of aging ofburied and underground pipingand tanks.SER SectionSSER Section 3.0.3.2.12“Wall Thinning Due to ErosionMechanisms”(LR-ISG-2012-01)This LR-ISG provides an alternateapproach to manage the effects ofaging for wall thinning due tovarious erosion mechanisms forpiping and components throughAMP XI.M17, “Flow-AcceleratedCorrosion.”SSER Section 3.0.3.1.8“Aging Management of InternalSurfaces, Fire Water Systems,Atmospheric Storage Tanks, andCorrosion under Insulation”(LR-ISG-2012-02)This LR-ISG revises the guidancerelated to aging managementactivities associated with AMPsXI.M38, “Inspection of InternalSurfaces in Miscellaneous Pipingand Ducting Components,” XI.M27,“Fire Water System,” XI.M29,“Aboveground Metallic Tanks,”XI.M41, “Buried and UndergroundPiping and Tanks,” RecurringInternal Corrosion, and CorrosionUnder Insulation (CUI).SSER Section 3.0.3.31-2
SECTION 2STRUCTURES AND COMPONENTS SUBJECT TO AGINGMANAGEMENT REVIEWThe staff does not have any changes or updates to this section of the safety evaluation report.2-1
SECTION 3AGING MANAGEMENT REVIEW RESULTS3.0 Applicant’s Use of the Generic Aging Lessons Learned (GALL) Report3.0.3 Aging Management Programs (AMPs)3.0.3.1 AMPs Consistent with the GALL Report3.0.3.1.8 Flow-Accelerated CorrosionSummary of Changes. By letter dated September 25, 2013, the applicant stated that ExelonGeneration Company, LLC (Exelon or the applicant), had performed a review of LicenseRenewal Interim Staff Guidance (LR-ISG) -2012-01, “Wall Thinning Due to ErosionMechanisms.” The applicant also stated that Limerick Generating Station (LGS) recentlyimplemented the guidance contained in this LR-ISG through its Flow-Accelerated Corrosionprogram. Based on its review, the applicant provided changes to license renewal application(LRA) Sections A.2.1.10 and B.2.1.10, to reflect the changes allowed by this LR-ISG, byincluding wall thinning mechanisms other than flow-accelerated corrosion to be managed by theFlow-Acceleration Corrosion program.Staff Evaluation. The U.S. Nuclear Regulatory Commission (NRC) staff (the staff) notes that, asdescribed in the safety evaluation report (SER), LGS’s Flow-Accelerated Corrosion program isbased on Electric Power Research Institute (EPRI) guidelines in NSAC-202L-R3, whichprovides guidance for susceptible-not-modeled piping. The staff also notes that, as described inLR-ISG-2012-01, piping or locations that are being monitored for wall thinning due to erosionmechanisms may be included with these susceptible-not-modeled lines and treated in acomparable fashion. The staff finds the applicant’s proposal acceptable because it hasimplemented the guidance contained in LR-ISG-2012-01 for managing wall thinning due toerosion mechanisms.Conclusion. The staff has concluded that no changes are required to the Flow-AcceleratedCorrosion program. The program is adequate to manage the applicable aging effects.3.0.3.2 AMPs Consistent with the GALL Report with Exceptions or Enhancements3.0.3.2.12 Buried and Underground Piping and TanksSummary of Technical Information in the Application. LRA Section B.2.1.29 describes theexisting Buried and Underground Piping and Tanks program as consistent, with enhancements,with GALL Report AMP XI.M41 “Buried and Underground Piping and Tanks.” The LRA statesthat the AMP addresses the external surfaces of metallic buried and underground piping andtanks exposed to soil and the outdoor air environments to manage the effects of loss ofmaterial. The LRA also states that the AMP proposes to manage this aging effect throughelectrochemical verification of cathodic protection, nondestructive evaluation of pipe wallthickness of underground piping, visual inspections of the pipe during opportunistic excavations,3-1
external coatings, cathodic protection, and the quality of backfill used. This program augmentsother programs that manage the aging of internal surfaces of buried and underground pipingand tanks. By letters dated June 17, 2013, and August 16, 2013, the applicant amended itsBuried and Underground Piping and Tanks program to address LR-ISG-2011-03, “Changes tothe Generic Aging Lessons Learned (GALL) Report Revision 2 Aging Management Program(AMP) XI.M41, ‘Buried and Underground Piping and Tanks,’” which was issued in its finalversion on August 2, 2012.Staff Evaluation. During the staff audit (Agencywide Documents Access and ManagementSystem (ADAMS) Accession No. ML12018A332), the staff reviewed the applicant’s claim ofconsistency with the GALL Report. The staff compared program elements 1-6 of the applicant’sprogram to the corresponding program elements of GALL Report AMP XI.M41.For the “preventive actions,” “detection of aging effects,” and “acceptance criteria” programelements, the staff determined the need for additional information, which resulted in theissuance of RAIs, as discussed below.The “preventive actions” program element in GALL Report AMP XI.M41 states that oneacceptable way to mitigate loss of material for buried steel piping is to provide external coatingsand cathodic protection. During its audit, the staff found that the Buried and UndergroundPiping and Tanks program states that the plant drainage system piping is neither coated norcathodically protected, and the circulating water system piping is not coated. By letter datedJanuary 17, 2012, the staff issued request for additional information (RAI) B.2.1.29-1 requestingthe applicant to state the basis for how the aging of buried components in the plant drainageand circulating water systems will be adequately managed such that their intended functions willbe maintained consistent with the current licensing basis (CLB) if cathodic protection andexternal coatings are not provided for the plant drainage system and external coatings are notprovided for the circulating water system.In its response, dated February 15, 2012, the applicant stated that, based on further review, theplant drainage system is coated with a somastic coating, the circulating water system is coatedwith coal tar epoxy, both coatings are recommended by National Association of CorrosionEngineers (NACE) SP0169-2007, and the plant drainage system piping is not cathodicallyprotected because it is constructed from cast iron, a corrosion-resistant material.The staff found the applicant’s response acceptable because both piping systems are coatedwith coatings recommended by NACE SP0169-2007, which is referenced by GALL ReportAMP XI.M41 as an acceptable standard for coatings. The staff does not agree with theapplicant’s stated basis for not installing cathodic protection (i.e., cast iron is acorrosion-resistant material). However, buried cast iron piping will not experience sufficientcorrosion to result in a loss of piping function because cast iron components are designed with athicker wall that allows much longer buried service. The staff’s concern described inRAI B.2.1.29-1 is resolved.The “detection of aging effects” program element in GALL Report AMP
Supplement 1 ! NRC Reference Material As of November 1999, you may electronically access . New York, NY 10036–8002 www.ansi.org 212–642–4900 ! AVAILABILITY OF REFERENCE MATERIALS . and 2, dated January 10, 2013, (Agencywide Documents Access and Management System Accession No. ML13015A191), which summarizes the results of its review of .
NUREG/CR-5230 SECY 88-260 (No requirements) NUREG-1030 NUREG-1211/ GL 87-02, GL 87-03 NUREG-1217, NUREG-1218 GL 89-19 All (All All All All (A-48 Hydrogen Control Measures and Effects of Hydrogen Burns on Safety Equipment 10 CFR 50.44 SECY 89-122 All, except PWRs with large dry containments A-49 Pressurized Thermal Shock RGs 1.154, 1.99 SECY 82 .
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