JAFP-18-0038, Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2

Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2

ML18109A371
Person / Time
Site:	FitzPatrick
Issue date:	04/19/2018
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2017-LLA-0311, JAFP-18-0038
Download: ML18109A371 (14)

Text

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 JAFP-18-0038 April 19, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2 (EPID: L-2017-LLA-0311)

References:

1. Letter from James Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2," JAFP-19-0093, dated October 2, 2017 (ML17275A520)

2. Electronic mail from R. Haskell II, U.S. Nuclear Regulatory Commission, to Christian Williams, Exelon Generation Company, LLC, "James A.

FitzPatrick Nuclear Power Plant, Unit 1 - Request for Information to Adopt Traveler TSTF-542 RPV Water Inventory Control (EPID: L-2017-LLA-0311), dated March 26, 2018 (ML18085A692)

By letter dated October 2, 2017 (ADAMS Accession No. ML17275A520) (Reference 1),

Exelon Generation Company, LLC (Exelon), requested approval to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2, which changes the Technical Specifications (TSs) for James A. FitzPatrick Nuclear Power Plant (JAFNPP).

The NRC staff reviewed the information provided that supports the proposed amendment and identified the need for additional information in order to complete their evaluation of the amendment request. The request for additional information (RAI) was sent from the NRC to Exelon by electronic mail on March 26, 2018 (Reference 2). The NRC requested a response by April 23, 2018. to this letter provides a restatement of the RAI question followed by our response. Attachment 2 provides the revised TS markup as a result of the RAI. In addition to responding to this RAI Exelon is providing corrected marked up TS pages to address markup discrepancies identified during the review. A summary of the discrepancies is included in Attachment 3 and the corrected TS pages are included in Attachment 4.

U.S. Nuclear Regulatory Commission Response to Request for Additional Information Application to Revise TS to Adopt TSTF-542 Docket No. 50-333 April 19, 2018 Page2 Exelon has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Attachment 1 of the Reference 1 letter. Exelon has concluded that the information provided in this response does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92. In addition , Exelon has concluded that the information in this response does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no new regulatory commitments in this response.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation,"

paragraph (b), Exelon is notifying the State of New York of this RAI response by transmitting a copy of this letter and its attachments to the designated State Official.

If you have any questions or require additional information, please contact Christian Williams at 610-765-5729.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 191h day of April 2018.

Respectfully,

~*~ 'J T j_.. Jr--

David T. Gudger Manager, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:

1. Response to Request for Additional Information

2. Revised Markup of Proposed Technical Specification Page 3.3.5.2-2

3. Summary of Additional Markup Discrepancies and Corrections

4. Revised Markup of Technical Specifications Pages 3.5.2-1 thru 3.5.2-4 and 3.5.2-6 cc: Regional Administrator - NRC Region I NRC Senior Resident Inspector- JAFNPP NRC Project Manager, NRR - JAFNPP NYSPSC NYSE RDA

JAFP-18-0038 ATTACHMENT 1 Response to Request for Additional Information

Response to Request for Additional Information Attachment 1 Application to Revise TS to Adopt TSTF-542 Page 1 of 1 Docket No. 50-333 By letter dated October 2, 2017 (ADAMS Accession No. ML17275A520), Exelon Generation Company, LLC (Exelon), requested approval to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2, which changes the Technical Specifications (TSs) for James A. FitzPatrick Nuclear Power Plant (JAFNPP).

The NRC staff reviewed the information provided that supports the proposed amendment and identified the need for additional information in order to complete their evaluation of the amendment request. The request for additional information (RAI) was sent from the NRC to Exelon by electronic mail message on March 26, 2018. Below is a restatement of the question followed by our response.

Question 1 (JAFNPP-RAI-01):

Background:

In Attachment 1 (of the LAR), for Variation 2.2.6, the licensee states that Surveillance Requirement (SR) SR 3.3.5.2.3, Perform LOGIC SYSTEM FUNCTIONAL TEST, is not applicable because the manual initiation logic does not exist in the JAFNPP design. However, in Attachment 2 (of the LAR), on proposed TS markup page 3.3.5.2-2, SR 3.3.5.2.3 was included. Furthermore, proposed TS Table 3.3.5.2-1, Reactor Pressure Vessel (RPV) Water Inventory Control Instrumentation, has no reference to SR 3.3.5.2.3.

Request:

Since this appears to indicate the proposed markups for the SR (page 3.3.5.2-2) and TS Table 3.3.5.2-1 (page 3.3.5.2-3) do not align, either provide clarification or correct the proposed TS markup page(s) as appropriate.

Response

SR 3.3.5.2.3 was included in error on page 3.3.5.2-2. SR 3.3.5.2.3 has been removed from page 3.3.5.2-2. See revised TS markup (Attachment 2).

References:

1. Letter from James Barstow (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control," Revision 2," dated October 2, 2017 (ML17275A520).

2. Electronic mail from R. Haskell II, U.S. Nuclear Regulatory Commission, to Christian Williams, Exelon Generation Company, LLC, "James A. FitzPatrick Nuclear Power Plant, Unit 1 - Request for Information to Adopt Traveler TSTF-542 RPV Water Inventory Control (EPID: L-2017-LLA-0311) dated March 26, 2018 (ML18085A692)

JAFP-18-0038 ATTACHMENT 2 Revised Markup of Proposed Technical Specifications Page 3.3.5.2-2 TS Page 3.3.5.2-2

RPV Water Inventory Control Instrumentation 3.3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Declare associated low Immediately associated Completion pressure ECCS Time of Condition C or D injection/spray subsystem not met. inoperable.

SURVEILLANCE REQUIREMENTS

---

NOTE-----------------------------------------------------------

Refer to Table 3.3.5.2-1 to determine which SRs apply for each ECCS Function.

SURVEILLANCE FREQUENCY SR 3.3.5.2.1 Perform CHANNEL CHECK. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.2 Perform CHANNEL FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program SR 3.3.5.2.3 Perform LOGIC SYSTEM FUNCTIONAL TEST. In accordance with the Surveillance Frequency Control Program JAFNPP 3.3.5.2-2 Amendment XXX

JAFP-18-0038 ATTACHMENT 3 Summary of Additional Markup Discrepancies and Corrections

Response to Request for Additional Information Attachment 3 Application to Revise TS to Adopt TSTF-542 Page 1 of 1 Docket Nos. 50-333 The following discrepancies were identified during the review of the markup pages for TS 3.5.2:

DISCREPANCY 1 (pg 3.5.2-1): In Attachment 2 of Reference 1, in the LCO 3.5.2 statement, the greater than or equal to symbol (>) and the TS Logical Connector term AND both include strikeouts (crossed out).

CORRECTION 1: Neither the symbol nor the logical connector should have been crossed out.

The strikeouts have been removed.

DISCREPANCY 2 (pg 3.5.2-2): The proposed markup for CONDITION C does not conform with the Traveler TSTF-542, Rev. 2. CONDITION C states, DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and > 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> while the Traveler TSTF-542, Revision 2, states DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

CORRECTION 2: CONDITION C on the markup has been revised to be consistent with the TSTF-542 traveler as follows: DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> and 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> DISCREPANCY 3 (pg 3.5.2-2): The proposed markup for the TS Logical Connector term AND, located between REQUIRED ACTIONs C.2 and C.3, includes strikeout.

CORRECTION 3: This term should NOT have been crossed out. The strikeout has been removed.

DISCREPANCY 4 (pg 3.5.2-2): The proposed markup for REQUIRED ACTION C.3 states, Verify one standby gas treatment subsystem is capable of operation in less than the DRAIN TIME. Versus the Traveler TSTF-542, Revision 2, which states, Verify one standby gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

CORRECTION 4: REQUIRED ACTION C.3 on the markup has been revised to be consistent with the TSTF-542 traveler as follows: Verify one standby gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

DISCREPANCY 5 (pg 3.5.2-3): The proposed markup for REQUIRED ACTION D.1 includes a strikeout in the symbol for 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

CORRECTION 5: The symbol should NOT have been crossed out. The strikeout has been removed.

DISCREPANCY 6 (pg 3.5.2-4): The proposed markup for CONDITION E includes a strikeout in the TS Logical Connector term OR. Additionally, for REQUIRED ACTION E.1 the DRAIN TIME requirement includes the > symbol vs. > for the 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> parameter.

CORRECTION 6: The symbol should NOT have been crossed out. The strikeout has been removed.

DISCREPANCY 7 (pg 3.5.2-4): The proposed markup for SR 3.5.2.1 includes the > symbol vs.

> for the 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> parameter.

CORRECTION 7: SR 3.5.2.1 should be > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. This has been corrected in the attached markup.

DISCREPANCY 8 (pg 3.5.2-6): The proposed markup for SR 3.5.2.6 includes a strikeout for the symbol.

CORRECTION 8: The symbol should NOT have been crossed out. The strikeout has been removed.

JAFP-18-0038 ATTACHMENT 4 Revised Markup of Technical Specifications Pages 3.5.2-1 thru 3.5.2-4 and 3.5.2-6 TS Pages 3.5.2-1 3.5.2-2 3.5.2-3 3.5.2-4 3.5.2-6

ECCS - ShutdownRPV Water Inventory Control 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEM (ECCS), REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL AND REACTOR CORE ISOLATION COOLING (RCIC) SYSTEM 3.5.2 ECCS - ShutdownReactor Pressure Vessel (RPV) Water Inventory Control LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> AND One Two low pressure ECCS injection/spray subsystems shall be OPERABLE.

- - - - - - - - - - - - - - - - - - - - - -NOTE - - - - - - - - - - - - -

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal if capable of being manually realigned and not otherwise inoperable.

APPLICABILITY: MODES 4, and 5 MODE 5, except with the spent fuel storage pool gates removed and water level 22 ft 2 inches over the top of the reactor pressure vessel flange.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One rRequired low A.1 Restore required low 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> pressure ECCS pressure ECCS injection/spray injection/spray subsystem inoperable. subsystem to OPERABLE status.

B. Required Action and B.1 Initiate action to Immediately associated Completion establish a method of Time of Condition A water injection capable not met. of operating without offsite electrical power.suspend operations with a potential for draining the reactor vessel (OPDRVs).

JAFNPP 3.5.2-1 Amendment 274XXX

ECCS - ShutdownRPV Water Inventory Control 3.5.2 C. DRAIN TIME < 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> C.1 Verify secondary Immediately4 hours and > 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Two containment boundary is required low capable of being pressure ECCS established in less than injection/spray the DRAIN TIMEInitiate subsystems inoperable. action to suspend C. OPDRVs.

AND (continued)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.2 Verify each secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> containment penetration flow path is capable of being isolated in less than the DRAIN TIME.Restore one required low pressure ECCS injection/spray subsystem to OPERBLE status.

AND C.3 Verify one standby gas 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> treatment subsystem is capable of being placed in operation in less than the DRAIN TIME (continued)

JAFNPP 3.5.2-2 Amendment 274XXX

ECCS - ShutdownRPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Required Action C.2 and D.1 ---------NOTE------------ Immediately associated Completion Required ECCS Time not met.DRAIN TIME injection/spray subsystem

< 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or additional method of water injection shall be capable of operating without offsite electrical power.

Initiate action to restore secondary containment to OPERABLE status.establish an additional method of water injection with water sources capable of maintaining RPV water level

> TAF for > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

AND D.2 Initiate action to establish Immediately secondary containment boundary restore one standby gas treatment subsystem to OPERABLE status.

AND D.3 Initiate action to isolate Immediately each secondary containment penetration flow path or verify it can be manually isolated from the control room.restore Isolation capability in each required secondary containment penetration flow path not isolated.

AND D.4 Initiate action to verify one Immediately standby gas treatment JAFNPP 3.5.2-32 Amendment XXX

ECCS - ShutdownRPV Water Inventory Control 3.5.2 subsystem is capable of being placed in operation E. Required Action and E.1 Initiate action to restore Immediately associated Completion DRAIN TIME to > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> Time of Condition C or D not met.

OR DRAIN TIME < 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> SURVEILLANCE REQUIREMENTS SURVELLANCE FREQUENCY SR 3.5.2.1 Verify DRAIN TIME > 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> In accordance with the Surveillance Frequency Control Program SR 3.5.2.21 Verify, for each a required low pressure coolant injection In accordance with (LPCI) subsystem, the suppression pool water level is the Surveillance 10.33 ft. Frequency Control Program (continued)

JAFNPP 3.5.2-42 Amendment XXX

ECCS - ShutdownRPV Water Inventory Control 3.5.2 SURVEILLANCE REQUIREMENTS (continued)

SURVELLANCE FREQUENCY SR 3.5.2.65 Operate the required ECCS injection/spray subsystem In accordance with through the recirculation line for > 10 minutesVerify the Inservice Testing each required ECCS pump develops the ProgramSurveillance specified flow rate against a system head Frequency Control Program corresponding to the specified reactor pressure above primary containment pressure.

SYSTEM HEAD CORRESPONDING TO A REACTOR PRESSURE NO. ABOVE PRIMARY OF CONTAINMENT SYSTEM FLOW RATE PUMPS PRESSURE OF CS 4265 gpm 1 113 psi LPCI 7700 gpm 1 20 psi SR 3.5.2.7 Verify each valve credited for automatically In accordance with isolating a penetration flow path actuates to the the Surveillance isolation position on an actual or simulated isolation Frequency Control signal. Program SR 3.5.2.86 - - - - - - - - - - - - - - -NOTE - - - - - - - - - - - - - - - -

Vessel injection/spray may be excluded.

Verify each the required ECCS injection/spray subsystem In accordance with can be manually operated. actuates on an actual or the Surveillance simulated automatic Frequency Control initiation signal. Program JAFNPP 3.5.2-62 Amendment XXX