ML030730739

License Amendments, 198 and 191 Regarding Scram Discharge Volume Water Level Instruments

ML030730739
Person / Time
Site:	Dresden
Issue date:	04/03/2003
From:	Rossbach L NRC/NRR/DLPM/LPD3
To:	Skolds J Exelon Generation Co, Exelon Nuclear
Rossbach L, 415-2863, NRR/DLPM
References
TAC MB6067, TAC MB6068
Download: ML030730739 (13)

Text

April 3, 2003 Mr. John L. Skolds, President Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - ISSUANCE OF AMENDMENTS FOR SCRAM DISCHARGE VOLUME WATER LEVEL INSTRUMENTS (TAC NOS. MB6067 AND MB6068)

Dear Mr. Skolds:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 198 to Facility Operating License No. DPR-19 and Amendment No. 191 to Facility Operating License No. DPR-25 for Dresden Nuclear Power Station, Units 2 and 3. The amendments are in response to your application dated August 16, 2002.

The amendments change Technical Specification surveillance requirements and allowable values for reactor protection system Function 7, Scram Discharge Volume Water Level-High.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

/RA/

Lawrence W. Rossbach, Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-237 and 50-249

Enclosures:

1. Amendment No. 198 to DPR-19

2. Amendment No. 191 to DPR-25

3. Safety Evaluation cc w/encls: See next page

ML030730739 *Concurred by SE NRR-058 OFFICE PM:LPD3-2 LA:LPD3-2 SC:EEIB(A) OGC SC:LPD3-2 NAME LRossbach:sab PCoats EMarinos* RHoefling AMendiola DATE 03/17/03 03/17/03 01/ 27 /03 03/24/03 04/3/03 EXELON GENERATION COMPANY, LLC DOCKET NO. 50-237 DRESDEN NUCLEAR POWER STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 198 License No. DPR-19

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Exelon Generation Company, LLC (the licensee) dated August 16, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Facility Operating License No. DPR-19 is hereby amended to read as follows:

(2) Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 198, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Anthony J. Mendiola, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: April 3, 2003

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-249 DRESDEN NUCLEAR POWER STATION, UNIT 3 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 191 License No. DPR-25

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Exelon Generation Company, LLC (the licensee) dated August 16, 2002, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 3.B. of Facility Operating License No. DPR-25 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 191, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Anthony J. Mendiola, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: April 3, 2003

ATTACHMENT TO LICENSE AMENDMENT NOS. 198 AND 191 FACILITY OPERATING LICENSE NOS. DPR-19 AND DPR-25 DOCKET NOS. 50-237 AND 50-249 Replace the following page of the Appendix A Technical Specifications with the attached page. The revised page is identified by amendment number and contains lines in the margin indicating the area of change.

Remove Page Insert Page 3.3.1.1-10 3.3.1.1-10

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 198 TO FACILITY OPERATING LICENSE NO. DPR-19 AND AMENDMENT NO. 191 TO FACILITY OPERATING LICENSE NO. DPR-25 EXELON GENERATION COMPANY, LLC DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-237 AND 50-249

1.0 INTRODUCTION

By application to the U. S. Nuclear Regulatory Commission (Commission, Staff, NRC), dated August 16, 2002, Exelon Generation Company, LLC, (the licensee) requested changes to the Technical Specifications (TSs) for the Dresden Nuclear Power Station, Units 2 and 3.

The proposed changes would revise the specified function description, surveillance requirements (SRs) and allowable value (AV) that apply to Unit 3 in TS Table 3.3.1.1-1, Reactor Protection System Instrumentation, Function 7, Scram Discharge Volume Water Level-High. These proposed changes support the licensees plan to upgrade to the Unit 3 scram discharge volume (SDV) water level-high instrumentation with more reliable instrumentation. In addition, the proposed changes add an SR to the existing Unit 2 and 3 SDV water level differential pressure switches specified in Function 7.b of TS Table 3.3.1.1-1.

Specifically, the licensee has proposed changes that would revise TS Table 3.3.1.1-1, Function 7, as follows:

a. Function 7.a, change the term Float Switch to Level Indicating Switch.

b. Function 7.a, add SRs 3.3.1.1.1 and 3.3.1.1.12 to each SR listing (i.e., listing for Modes 1, 2, and the specified condition in Mode 5) followed by new table footnote designator d.

c. Add a new footnote (d), Specified SR performance only required for Unit 3.

d. Function 7.b, add SR 3.3.1.1.12 to each SR listing (i.e., listing for Modes 1, 2, and the specified condition in Mode 5).

e. Functions 7.a and 7.b, revise the AV for Unit 3 from # 39.1" to #38.7" gallons in four locations.

2.0 REGULATORY EVALUATION

The current instrumentation for the SDV high-level trip, Function 7.a of TS Table 3.3.1.1-1, Reactor Protection System Instrumentation, utilizes locally mounted, non-indicating Magnetrol level float switches for Unit 3 and non-indicating thermal probes for Unit 2 which initiate a reactor scram when the monitored parameter exceeds its specified limit. If the SDV were filled to a point where there was insufficient volume to accept the water from the control drives that are displaced during scram, control rod insertion would be hindered. This scram is required to be functional in Modes 1, 2, and 5 with any control rod withdrawn from a reactor core cell containing one or more fuel assemblies. The licensee has applied all requirements for the existing instruments to the new instruments and has proposed SRs based on the new instruments.

The staff finds that the licensee in Section F of Attachment A of its submittal identified the applicable regulatory requirements. The regulatory requirements on which the staff based its acceptance are in Section 50.55a(h)(2) of Title 10 of the Code of Federal Regulations (10 CFR), which encompasses the detailed requirements discussed by the licensee in its submittal.

3.0 TECHNICAL EVALUATION

The staff has reviewed the licensees regulatory and technical analyses in support of its proposed license amendment which are described in Sections A through F of the licensees submittal. Based on the review of the licensees submittal, the staff concludes that the proposed TS changes are acceptable. The detailed evaluation below will support the conclusion that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

3.1 Proposed Change: TS Table 3.3.1.1-1 Function 7.a - Change the term Float Switch to Level Indicating Switch.

Evaluation: This change is necessary to reflect the new SDV level-monitoring instrumentation and is administrative in nature; therefore, the staff finds it acceptable.

3.2 Proposed Change: TS Table 3.3.1.1-1 Function 7.a - Add SR 3.3.1.1.1 and SR 3.3.1.1.12 to each SR listing (i.e., listing for Mode 1, 2, and 5) followed by new table footnote designator d.

Evaluation: The licensee has added SR 3.3.1.1.1, channel check, and SR 3.3.1.1.12, trip unit calibration requirements, for the Unit 3 SDV water level instrumentation. Neither the existing instruments (thermal switches for Unit 2 and the float switches for Unit 3) nor the differential pressure instrumentation channel used for Function 7.b provide SDV water level indication. However, the new Unit 3 instruments provide indication and, therefore, allow for performance of the channel check. The thermal switches used in Unit 2 do not contain analog trip units and, therefore, do not require calibration.

The licensee has added calibration requirements for the trip units at the frequency of 92 days both for the Unit 3 replacement instrumentation and for the existing differential pressure instrumentation used for Function 7.b, which also has analog trip units. The licensee has based the 92-day calibration frequency on the General Electric Company and the Boiling Water Reactor Owners Group topical reports which were previously approved by NRC (NRC letter to O. D. Kingsley, Dresden Issuance of Amendments Changing Allowable Out-of-Service Times and Surveillance Test Intervals, dated August 2, 2000). The licensee has further stated that the 24-month channel calibration for the new instruments continues to be allowed provided that the analog trip units are calibrated every 92 days. The licensee has used drift values in accordance with the setpoint methodology described in Nuclear Standard NES-EIC-20.4, Analysis of Instrument Channel Setpoint Error and Instrument Loop Accuracy, which was approved by NRC in Dresden Amendments 185/180 dated March 30, 2001. Since the addition of SR 3.3.1.1.1 and SR 3.3.1.1.12 make the TSs more comprehensive and is consistent with a previously approved NRC methodology, the proposed change is acceptable.

3.3 Proposed Change: TS Table 3.3.1.1-1 Function 7.a - Add new footnote (d),

Specified SR performance only required for Unit 3.

Evaluation: Since the footnote clarifies that the particular SR is only required for Unit 3 equipment as discussed in item b above, this change is administrative in nature and, therefore, is acceptable to the staff.

3.4 Proposed Change: TS Table 3.3.1.1-1 Function 7.b - Add SR 3.3.1.1.12 to each SR listing (i.e., listing for Modes 1, 2, and the specified condition in Mode 5).

Evaluation: The addition of trip unit calibration provides appropriate SRs for the existing instrumentation for this function as discussed in item c earlier. Although SR 3.3.1.1.12 is not currently specified for this function, Dresden calibrates the trip units every 92 days. Since the addition of SR 3.3.1.1.12 for this function makes the TSs more comprehensive, the staff finds the proposed change acceptable.

3.5 Proposed Change: TS Table 3.3.1.1-1, Functions 7.a and 7.b - Revise the AV for Unit 3 from #39.1" to #38.7" gallons in the four printed locations.

Evaluation: The licensee had used the previously NRC-approved setpoint methodology to determine the AV for these instruments. There is no change to the analytical limit for these functions. On this basis, the staff finds the new AV acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Illinois State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (67 FR 68737). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: H. Garg, EEIB/DE Date: April 3, 2003

Dresden Nuclear Power Units 2 and 3 cc:

Site Vice President - Dresden Nuclear Power Station Vice President Exelon Generation Company, LLC Mid-West Regional Operating Group 6500 N. Dresden Road Exelon Generation Company, LLC Morris, IL 60450-9765 4300 Winfield Road Warrenville, IL 60555 Dresden Nuclear Power Station Plant Manager Exelon Generation Company, LLC Senior Vice President 6500 N. Dresden Road Mid-West Regional Operating Group Morris, IL 60450-9765 Exelon Generation Company, LLC 4300 Winfield Road Regulatory Assurance Manager - Dresden Warrenville, IL 60555 Exelon Generation Company, LLC 6500 N. Dresden Road Vice President - Licensing and Regulatory Morris, IL 60450-9765 Affairs Exelon Generation Company, LLC U.S. Nuclear Regulatory Commission 4300 Winfield Road Dresden Resident Inspectors Office Warrenville, IL 60555 6500 N. Dresden Road Morris, IL 60450-9766 Director - Licensing Mid-West Regional Operating Group Chairman Exelon Generation Company, LLC Grundy County Board 4300 Winfield Road Administration Building Warrenville, IL 60555 1320 Union Street Morris, IL 60450 Senior Counsel, Nuclear Mid-West Regional Operating Group Regional Administrator Exelon Generation Company, LLC U.S. NRC, Region III 4300 Winfield Road 801 Warrenville Road Warrenville, IL 60555 Lisle, IL 60532-4351 Manager Licensing - Dresden and Illinois Department of Nuclear Safety Quad Cities Office of Nuclear Facility Safety Exelon Generation Company, LLC 1035 Outer Park Drive 4300 Winfield Road Springfield, IL 62704 Warrenville, IL 60555 Document Control Desk-Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Senior Vice President, Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555