RS-04-043, Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements

Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements

ML040790358
Person / Time
Site:	LaSalle
Issue date:	03/12/2004
From:	Ainger K Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-04-043
Download: ML040790358 (32)

Text

Exe ke I nW Exelon Generation www.exeloncorp.com 4300 Winfield Road Nuclear Warrenville, IL 60555 RS-04-043 10 CFR 50.90 March 12, 2004 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-1 1 and NPF-1 8 NRC Docket Nos. 50-373 and 50-374

Subject:

Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements

References:

(1) BWR Owners' Group Licensing Topical Report, "System Analyses for the Elimination of Selected Response Time Testing Requirements,"

NEDO-32291-A, Supplement 1, dated October 1999 (2) Letter from U. S. NRC to W. Glenn Warren (BWR Owners' Group),

"Review of Boiling Water Reactor Owners Group (BWROG) Licensing Topical Report NEDO-32291, Supplement 1, System Analyses for Elimination of Selected Response Time Testing Requirements," dated June11, 1999 (3) BWR Owners' Group Licensing Topical Report, "System Analyses for the Elimination of Selected Response Time Testing Requirements, NEDO-32291-A, dated October 1995 In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) proposes changes to Appendix A, Technical Specifications (TS), of Facility Operating License Nos. NPF-11 and NPF-18. The proposed changes would modify the TS to eliminate selected response time testing (RTT) requirements associated with Reactor Protection System instrumentation and Primary Containment Isolation instrumentation for Main Steam Line Isolation functions. The proposed changes are consistent with the BWR Owners' Group Licensing Topical Report (Reference 1) as approved by the NRC (Reference 2).

March 12, 2004 U. S. Nuclear regulatory Commission Page 2 Reference 3 established a generic basis for elimination of many RTTs for instrument loops that had good performance histories and longer response time requirements. The justification was based on the adequacy of surveillance tests other than RTTs to assure that response time requirements were met for sensors in those loops. Supplement I to Reference 3 (i.e., Reference 1) was prepared to document an analysis to extend the conclusions of the original study to cover the logic components in selected instrumentation loops that have intermediate length response time requirements. The intent was to demonstrate that elimination of the RTT requirements for the logic portions of those loops is of no safety significance. Reference I concludes, for instrument loops meeting the application criteria of the Licensing Topical Report, that performance of ongoing TS required surveillance tests other than RTTs (i.e., calibration tests, functional tests, and logic system functional tests) provides adequate assurance that those instrument loops will meet their respective response time requirements.

A table identifying a summary of regulatory commitments made in this submittal is provided in an attachment to this letter. Any other actions discussed in the submittal represent intended or planned actions by EGC. They are described to the NRC for the NRC's information and are not regulatory commitments.

This request is subdivided as follows:

1. Attachment 1 provides a description and safety analysis of the proposed changes for LaSalle County Station.

2. Attachment 2 includes the marked-up'LaSalle County Station TS pages for the proposed changes.

3. Attachment 3 includes the associated marked-up LaSalle County Station TS Bases pages for information only.

4. Attachment 4 provides a summary of regulatory commitments associated with this proposed amendment request.

These proposed changes have been reviewed by the Plant Operations Review Committee at LaSalle County Station and approved by the Nuclear Safety Review Board in accordance with the requirements of the Quality Assurance Program. We are requesting approval of the proposed changes by December 17, 2004. Approval by this date will prevent the need for removing safety related equipment from service for surveillances associated with these instruments, before or during the refueling outage scheduled at LaSalle County Station in February 2005. Once approved, the amendment shall be implemented within 60 days.

We are notifying the State of Illinois of this application for amendment by transmitting a copy of this letter and its attachments to the designated State Official.

March 12, 2004 U. S. Nuclear regulatory Commission Page 3 If you have any questions or require additional information, please contact Mr.

Timothy A. Byam at (630) 657-2804.

I declare under penalty of perjury that the foregoing is true and correct.

Respectfully, Executed on K. A. Ainger C/

Manager - Licensing Exelon Generation Company, LLC Attachments:

1. Evaluation of Proposed Changes for LaSalle County Station

2. Mark-up of Proposed LaSalle County Station Technical Specification Page Changes

3. Mark-up of Associated LaSalle County Station Bases Pages (For Information Only)

4. Summary of Exelon Nuclear Commitments

,cc: Regional Administrator - NRC Region IlIl NRC Senior Resident Inspector - LaSalle County Station Office of Nuclear Facility Safety - IEMA Division of Nuclear Safety

ATTACHMENT 1 Evaluation of Proposed Changes For LaSalle County Station Page 1 of 17

Subject:

Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements

2.0 PROPOSED CHANGE

S

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration 5.2 Applicable Regulatory Requirements/Criteria

7.0 REFERENCES

ATTACHMENT 1 Evaluation of Proposed Changes For LaSalle County Station Page 2 of 17

1.0 DESCRIPTION

In accordance with 10 CFR 50.90, Exelon Generation Company, LLC (EGC) requests the following amendment to Appendix A, Technical Specifications (TS), of Facility Operating License Nos. NPF-1 1 and NPF-1 8 for LaSalle County Station. The proposed change would modify the TS to eliminate the response time testing (RTT) requirements for TS Section 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," Reactor Vessel Steam Dome Pressure - High function and for TS Section 3.3.6.1, 'Primary Containment Isolation Instrumentation," Reactor Vessel Water Level - Low Low Low, Level 1 and Main Steam Line Pressure - Low functions. The proposed changes are consistent with the BWR Owners' Group Licensing Topical Report (Reference 1) as approved by the NRC (Reference 2).

Elimination of the response time testing requirements will result in significant improvement in plant safety by: (1) minimizing the time when safety systems are out of service or otherwise incapable of responding to a degraded plant condition; (2) reducing the potential for inadvertent RPS or essential safety function (ESF) actuations; (3) reducing the complexity of refuel outages and thus reducing shutdown risk; (4) reducing personnel radiation exposure; and, (5) allowing critical personnel to be used for more significant tasks.

2.0 PROPOSED CHANGE

2.1 TS Section 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," Table 3.3.1.1-1 Function 3, "Reactor Vessel Steam Dome Pressure - High," specifies Surveillance Requirement (SR) 3.3.1.1.17 as applicable to this function.

Function 3 is being revised to delete the applicability of SR 3.3.1.1.17.

2.2 TS Section 3.3.6.1, "Primary Containment Isolation Instrumentation," Table 3.3.6.1-1 Function 1.a, "Reactor Vessel Water Level - Low Low Low, Level 1,"

specifies SR 3.3.6.1.6 as applicable to this function. Function 1.a is being revised to delete the applicability of SR 3.3.6.1.6.

2.3 TS Section 3.3.6.1, Table 3.3.6.1-1 Function 1.b, "Main Steam Line Pressure -

Low," specifies SR 3.3.6.1.6 as applicable to this function. Function 1.b is being revised to delete the applicability of SR 3.3.6.1.6.

In addition, the TS Bases will be revised to reflect the above proposed changes.

In summary, EGC proposes to modify the TS to eliminate selected response time testing requirements. Specifically, the changes revise the response time testing requirements for TS Section 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," Reactor Vessel Steam Dome Pressure - High function and for TS Section 3.3.6.1, "Primary Containment Isolation Instrumentation," Reactor Vessel Water Level - Low Low Low, Level 1 and Main Steam Line Pressure - Low functions.

ATTACHMENT I Evaluation of Proposed Changes For LaSalle County Station Page 3 of 17

3.0 BACKGROUND

Current Standard TS require certain BWR plants to periodically perform response time tests for instrument channels in the Reactor Protection System (RPS), Isolation Actuation System (IAS) and Emergency Core Cooling Systems (ECCS). The purpose of these tests is to ensure that changes in response time beyond acceptable limits assumed in the safety analyses are detected. It is not necessary to demonstrate that the response time design value, which is typically more conservative than the value assumed in the safety analysis, is met. The instrumentation response time tests provide measurement of specific sensor, trip unit and/or loop response time. The information obtained from these tests is used to demonstrate that the loop response time is within the limits assumed in the safety analyses.

In January 1994, the Boiling Water Reactor Owners' Group (BWROG) issued Licensing Topical Report (LTR) NEDO-32291 (Reference 3). In Reference 3, the BWROG proposed eliminating the requirements for performance of RTT of selected instrumentation in the RPS, ECCS, and IAS. The NRC approved the LTR in an SER dated December 28, 1994 (Reference 4). Reference 3 established a generic basis for elimination of selected RTT requirements for instrument loops that had good performance histories and longer response time requirements. The result of this effort was a significant reduction of testing which was shown by the study to be unnecessary.

LaSalle County Station, as part of the conversion to Improved Technical Specifications (ITS), revised TS to eliminate selected response time testing requirements in accordance with the approved Reference 3. This was done by utilizing the Standard Technical Specification Change Traveler TSTF-332, Revision 0 which provided guidance on incorporating the allowances of Reference 3. Specifically, the definitions for ECCS response time, Isolation System response time, and RPS response time were modified, as well as the Bases for the associated Surveillance Requirements (SRs). The changes, approved as part of the ITS conversion, also eliminated the need for response time testing of sensors for selected parameters in the RPS and primary containment isolation systems.

The BWROG subsequently issued Supplement 1 to Reference 3 on November 4, 1997 (Reference 1). The LTR supplement documents the results of the second phase of the BWROG Response Time Testing Committee's study to identify ways to further eliminate RTT requirements. With only a few exceptions, the study results documented in Reference 1 cover all RPS and IAS instrumentation loops with response time requirements in the intermediate response time range (i.e., 300 to 5000 msec) that were not considered in the first phase of the study documented in Reference 3. This generic LTR Supplement documented an analysis to extend the conclusions of the original study to cover logic components in selected instrumentation loops to demonstrate that elimination of the RTT requirements for the logic portions of those loops is of no safety significance. In Reference 2, the NRC documented their review of Reference 1 and the determination that the LTR Supplement provided an acceptable basis for eliminating selected RTT from TS for the instruments/components identified in the supplement.

ATTACHMENT I Evaluation of Proposed Changes For LaSalle County Station Page 4 of 17

4.0 TECHNICAL ANALYSIS

Consistent with Reference 3, the supplement to NEDO-32291-A (Reference 1) utilized the requirements of Institute of Electrical and Electronics Engineers (IEEE) Standard 338-1977, "Criteria for Periodic Testing of Nuclear Power Generating Station Safety Systems," as endorsed by NRC Regulatory Guide 1.118, "Periodic Testing of Electric Power and Protection Systems," which states the following.

"Response time testing of all safety-related equipment, per se, is not required if, in lieu of response time testing, the response time of the safety equipment is verified by functional testing, calibration checks or other tests, or both. This is acceptable if it can be demonstrated that changes in response time beyond acceptable limits are accompanied by changes in performance characteristics which are detectable during routine periodic tests."

The analysis contained in Reference 1 provides the basis for eliminating selected response time testing requirements. The analysis was performed for BWRs, and its applicability to LaSalle County Station has been verified with regards to the proposed TS changes. LaSalle County Station participated in the development of Reference 1 as documented in Appendix A of the NEDO document.

The BWROG analysis includes the identification of potential failure modes of components in the affected instrumentation loops that could potentially impact the instrument loop response time. In addition, plant operating experiences were reviewed to identify response time failures and how they were detected. The failure modes identified were evaluated to determine if the effect on response time would be detected by other testing requirements contained in the TS.

The results of the BWROG analysis demonstrate that any credible failure of the instrument loop components would either be bounded by a bounding response time (BRT) or would be detected by other TS testing requirements, such as a channel calibration, channel check, channel functional test, or logic system functional test.

These other testing requirements are sufficient to identify failure modes or degradations in instrument response times and assure operation of the analyzed instrument loops are within acceptance limits. Furthermore, the BWROG has described various defense in depth issues (Reference 1) which clearly demonstrate that from a realistic basis, there is no safety significance even if instrumentation loop response times are significantly longer than the loop BRTs. Therefore, potential errors in the conclusions of the analysis and BRTs resulting from unanticipated failure modes of components do not affect the overall conclusion that elimination of the identified response time testing requirements has no substantial detrimental impact on plant safety.

4.1 Instrument Loop Logic Components A review of utility-supplied information for the loops included in the Reference 1 study was performed to identify the individual components comprising each of the instrument loops. Components with sufficiently similar design and

ATTACHMENT I Evaluation of Proposed Changes For LaSalle County Station Page 5 of 17 construction features were grouped together into a component set for which a common Failure Modes and Effects Analysis (FMEA) was performed.

The BWROG utilized the results of the FMEAs, in conjunction with industry failure experience and component specifications, requirements, and performance test results, to establish a BRT. The BRT is the maximum response time expected for any component in the set that could result from credible Undetected" component failures or degradation. Undetected component failures and degradations as used in Reference 1 are failures and degradations that are not expected to be detected either by immediate trip or by periodic surveillance actions other than response time testing. Response time increases up to the BRT may go undetected, but it is expected that any failure or degradation that results in a response time larger than the BRT will be detected by one or more surveillance actions other than response time testing. The BRT is established based on the assumption that specific RTT is not performed for the loop or component.

The BRT for each evaluated channel is determined by the summation of the individual component responses in the trip system actuation logic. In accordance with Reference 1 Section 8.5.1, the limiting BRT for the sensors is derived from the current RTT acceptance criteria. This value plus the sum of the channel relay BRTs is then compared to the current RTT limit required by the applicable RTT surveillance procedure.

4;2 Affected Instrument Channels LaSalle County Station evaluated the site-specific loop logic components against those that are covered in Reference 1. Those components that are applicable to the requested changes are listed below.

• GE 12HFA151A9 series relay

• Agastat EGPB series relay

• Rosemount 710DU series trip unit

• GE series CR105 scram contactor The instrument loops covered by References 1 and 2 are those whose required response times, as set by the safety analysis, are in the 300 to 5000 millisecond range. The loops applicable to LaSalle County Station for this TS change are as follows.

Reference 1 Table 6-2 Loop Type Reactor Protection System Reactor Vessel Steam Dome Pressure - High K

ATTACHMENT 1 Evaluation of Proposed Changes For LaSalle County Station Page 6 of 17 Reference 1 Table 6-2 Loon Type Primary Containment Isolation Instrumentation - Main Steam Line Isolation Reactor Vessel Water Level - Low Low Low, Level 1 E

Main Steam Line Pressure - Low J The following tables show the LaSalle BRT calculation using Reference 1, Table C.2-2, "Loop Component Combinations and Loop Logic BRT."

Loop Type K Reactor Vessel Steam Dome Pressure - High Sensor TripUnit TU Output Logic Output Loop Logic Required BRT JTU) Relay Relay Contactor BRT Response (msec) (msec) (msec) _(msec) (msec) (msec) Time (sec) 465 N/A N/A 40 45 85 0.55 Loop Type E Reactor Vessel Water Level - Low Low Low, Level 1 Sensor Trip Unit TU Output Logic Output Loop Logic Required BRT (TU) Relay Relay Contactor BRT Response (msec) (msec) (msec) (msec) (ec) ( m sec) Time (sec) 756 24 140 140 40 244 1.0 Loop Type J Main Steam Line Pressure - Low Sensor Trip Unit TU Output Logic Auxiliary Output Loop Logic Required BRT (TU) Relay Relay Relay Contactor BRT Response (msec) (msec) (msec) (msec) (msec) (msec) (msec) Time (sec) 1880 N/A N/A 40 40 40 120 2.0 As indicated above, the maximum allowable loop sensor response time for Loop Type K was determined to be 465 msec. The test data from the last sensor response time test were reviewed to determine the actual sensor response time for these loops. The actual sensor response time was found to range from 200 to 305 msec. Based on the response time test data reviewed, it was verified that the actual sensor response time is less than the maximum allowable loop sensor response time for these loop types. Therefore, this loop meets the criteria of Reference 1 indicating that eliminating the RTT requirements for this instrument loop (i.e., Reactor Vessel Steam Dome Pressure - High RPS actuation) is acceptable.

ATTACHMENT I Evaluation of Proposed Changes For LaSalle County Station Page 7 of 17 The maximum allowable loop sensor response time for Loop Type Ewas determined to be 756 msec. Based on test data from the last sensor response time test the actual sensor response times were found to range from 100 to 200 msec. Therefore, it was verified that the actual sensor response time is bounded by the maximum allowable loop sensor response time for this loop type. This loop, therefore, meets the criteria of Reference 1 indicating that eliminating the RTT requirements for this instrument loop (i.e., Reactor Vessel Water Level -

Low Low Low, Level 1 MSIV isolation) is acceptable.

As noted above, the maximum loop sensor response time for Loop Type J was determined to be 1880 msec. The test data from the last sensor response time test were reviewed to determine the actual sensor response time for these loops.

The actual sensor response time was found to range from 265 to 1643 msec.

Since the actual sensor response time is bounded by the maximum allowable loop sensor response time for this loop type, the criteria of Reference I have been met indicating that eliminating the RTT requirements for this instrument loop (i.e., Main Steam Line Pressure - Low MSIV isolation) is acceptable.

In accordance with the provisions of References 1 and 2, the elimination of response time testing for the channels analyzed is justified and does not degrade plant safety.

The results of the BWROG analysis demonstrate that any credible component failure of the instrument loop components would either be bounded by a bounding response time, or would be detected by other TS testing requirements, such as channel calibration, channel check, channel functional test, and logic system functional test. These other testing requirements are sufficient to identify failure modes or degradations in instrument response times and assure operation of the analyzed instrument loops are within acceptance limits. Furthermore, the BWROG has described various defense-in-depth issues (Reference 1, Addendum 1) that clearly demonstrate that from a realistic basis, there is no safety significance even if instrumentation loop response times are significantly longer than the loop bounding response times. Therefore, potential errors in the conclusions of the analysis and bounding response times resulting from unanticipated failure modes of components do not affect the overall conclusion that elimination of the identified response time testing requirements has no substantial detrimental impact on plant safety.

4.3 Compliance With Provisions of LTR and LTR Approval EGC will comply with the provisions of References 1 and 2 for the Agastat EGPB and GE HFA relays, Rosemount trip unit, and GE scram contactor. These provisions and EGC compliance are provided below.

ATTACHMENT I Evaluation of Proposed Changes For LaSalle County Station Page 8 of 17 A-iastat Relay Component Group As stated in Section 6.1.2.1 of Reference 1, provided the following conditions are met, no credible failure mode has been identified that will increase the response time to more than 140 msec and not also affect normal functioning of the relay, and thus be detected either by immediate trip or by tests other than the RTT.

1. Prior to installation or after any maintenance or repair of the relays, the normally open contacts of the relays are confirmed to open in 70 msec or less after power is removed from the coil.

The calibration procedures will be revised to include a step requiring a response time test of the relay to be performed before returning the relay to service after repair or maintenance. The normally open contacts will be confirmed to open in 70 msec or less after power is removed from the coil.

The testing as specified here would be required 'prior to return to service" rather than "prior to installation" as it is acceptable to perform this testing on the bench or installed.

2. The relays are within their qualified life.

The relays have been verified to be within their qualified life.

3. The relays are procured by the utility as "nuclear safety related," or are dedicated for nuclear safety related application under a utility dedicated program.

The relays are procured as nuclear safety related.

GE HFA Relay Component Group Section 6.1.2.2 of Reference 1 states that provided the following conditions are met, no credible failure mode has been identified that will increase the response time to more than 40 msec and not also affect normal functioning of the relay, and thus be detected either by immediate trip or by tests other than the RTT.

1. The HFA manufacturer's instructions are followed for setup and adjustment of the relay before initial operation and after any repair or maintenance.

The manufacturer's instructions for setup and adjustment of the relay will be proceduralized. These procedures will be performed before initial operation and after any repair or maintenance.

2. Before installation, or after any maintenance or repair of the relays, the normally open contacts of the relays are confirmed to open in 20 msec or less after power is removed from the coil.

ATTACHMENT 1 Evaluation of Proposed Changes For LaSalle County Station Page.9 of 17 The calibration procedure will be revised to include a requirement for verification that the normally open contacts of the relays open in 20 msec or less after the power is removed from the coil. The procedure will be revised to include this verification before installation or after maintenance or repair of the relays.

3. The relays are procured by the utility as "nuclear safety related," or are dedicated for nuclear safety related application under a utility dedication program.

The relays are procured as nuclear safety related.

4. These relays must be used as normally open energized in the untripped state, with power removed and contacts closed to trip.

These relays are used as normally open, energized in the untripped state, with power removed and contacts closed to trip.

Trip Unit Component Group The trip unit component considered in this evaluation for LaSalle County Station is the Rosemount Model 710DU. The FMEA performed for the trip unit component group as part of Reference 1 included this trip unit model and determined that the maximum value of undetected response time of the relays is 24 msec. Reference 1 states that if the following provision is met then no credible failure will increase response time to more than 24 msec without being detected by tests other than the RTT.

1. The trip units are procured by the utility as "nuclear safety related," or are dedicated for nuclear safety related application under a utility dedication program.

The trip units are procured as nuclear safety related.

RPS Scram Contactor Component Group The RPS contactor set evaluated in Reference 1 includes the GE CR105 magnetic contactors used at LaSalle County Station. As stated in Section 6.1.6.1 of Reference 1,the evaluation applies when the component controls a set of scram solenoid pilot valves (SSPV) in the following configuration.

1. One GE CR105, GE CR205, or GE CR305 Magnetic Contactor that directly operates a set of SSPVs.

These contactors have been verified to directly operate a set of SSPVs.

As stated in Section 6.1.6.2 of Reference 1, the maximum undetected response time of the RPS scram contactor is 65 msec, provided the plant performs the

ATTACHMENT 1 Evaluation of Proposed Changes For LaSalle County Station Page 10 of 17 average power range monitor (APRM) upscale scram trip RTT with a loop acceptance criteria of 90 msec maximum, and the APRM upscale scram trip RTT includes the APRM electronics and at least one interposing relay, not shared by other loops, between the APRM output and the RPS scram contactor. However, if the APRM RTT is performed in phases, the maximum undetected response time of the RPS scram contactor is 45 msec, provided the acceptance criteria is 50 msec maximum for the phase that includes the RPS scram contactor, and at least one interposing relay, not shared by other loops, is included in the phase.

Based on the Reference 1 analysis, it is reasonable to conclude that any undetected failure of the RPS scram contactor which has met the above conditions that could result in response time greater than .65 msec is not credible if the APRM RTT is a loop test, and an undetected failure that results in response times greater than 45 msec is not credible if the APRM RTT is a phased test.

1. RPS scram contactor components are tested as part of the APRM upscale trip RTT.

The APRM upscale trip RTT is currently performed in overlapping partial tests. The APRM section is tested separately from the scram contactors.

2. Determine that one of the two postulated test methods are used.

As noted above, the APRM upscale trip RTT is performed as a phased test with the APRM section tested separately from the scram contactors. The acceptance criteria for the scram contactor and one interposing relay, not shared by other loops, is less than or equal to 50 msec.

3. Use the appropriate Bounding Response Time for the test method used.

Based on the above a BRT of 45 msec is used.

RPS and MSIV Isolation Process Sensors The following sensors are used in the instrument loops evaluated for this amendment request.

SOR 9N6B45-NX-ClA-JJTTX6 pressure switch Rosemount 1153DB series differential pressure transmitter Reference 4 concurred with Reference 3 that the selected response time testing requirements could be eliminated for selected sensors in the RPS and MSIV actuation instrumentation. Intheir approval of Reference 3, the NRC required that licensees address specific requirements in order to eliminate response time testing from the selected applications. The following is a listing of the requirements and EGC's actions to satisfy the given requirement for the above identified sensors.

ATTACHMENT 1 Evaluation of Proposed Changes For LaSalle County Station Page 1I of 17

1. Prior to installation of a new transmitter/switch or following refurbishment of a transmitter/switch (e.g., sensor cell or variable damping components) a hydraulic RTT shall be performed to determine an initial sensor specific response time value.

Post-maintenance test procedures will be revised to reflect these requirements for the subject sensors. Design guidance documents will also be revised to reflect the above requirements. Maintenance personnel will be trained on the new procedural requirement for performance of a baseline RTT following refurbishment of an existing transmitter/switch performing the specified function. In addition, design engineers will be trained on the new procedural and design guidance requirement for performance of a baseline RTT prior to installation of a new transmitter/switch

2. For transmitters and switches that use capillary tubes, capillary tube testing shall be performed after initial installation and after any maintenance or modification activity that could damage the capillary tubes.

LaSalle County Station currently does not use any transmitters or switches that use capillary tubes in any application that requires response time testing. Therefore, this recommendation is not applicable to LaSalle County Station.

3. Calibration is being done with equipment designed to provide a step function or fast ramp in the process variable.

Applicable calibration procedures will be revised to include steps to input a fast ramp or step change to system components during calibrations.

4. Provisions have been made to ensure that operators and technicians, through an appropriate training program, are aware of the consequences of instrument response time degradation, and that applicable procedures have been reviewed and revised as necessary to assure that technicians monitor for response time degradation during the performance of calibrations and functional tests.

Training will be conducted for the operators and technicians that addresses the consequences of instrument response time degradation. The applicable procedures will be revised to assure that technicians monitor for response time degradation during the performance of calibrations and functional tests.

5. Surveillance testing procedures have been reviewed and revised if.

necessary to ensure calibrations and functional tests are being performed in a manner that allows simultaneous monitoring of both the input and output response of units under test.

ATTACHMENT I Evaluation of Proposed Changes For LaSalle County Station Page 12 of 17 Surveillance testing procedures will be revised to ensure that calibrations and functional tests are being performed in a manner that allows simultaneous monitoring of both the input and output response of units under test. This is done by either monitoring of the output at or near the input calibration source, or via the use of headsets to communicate between locations, if necessary.

6. For any request involving the elimination of RTT for Rosemount pressure transmitters, demonstrate compliance with the guidelines of Supplement I to Bulletin 90-01, "Loss of Fill-Oil in transmitters Manufactured by Rosemount."

EGC has conducted training for operators and technicians to ensure appropriate personnel are aware of the symptoms that a transmitter, both during operation and during calibration activities, may exhibit if it is experiencing a loss of fill-oil and the need for prompt identification of transmitters that may exhibit these symptoms.

7. For those instruments where the manufacturer recommends periodic RTT as well as calibration to ensure correct function, the licensee has ensured that elimination of RTT is nevertheless acceptable for the particular application involved.

LaSalle County Station has reviewed the vendor recommendations for these devices and confirmed that they do not contain recommendations for periodic response time testing.

Continued compliance with the Licensing Topical Report analyses is assured by the following.

• Comparison of plant procedures to requirements in accordance with Section 8.5.2 of Reference 1.

• Assurance that compliance with the provisions in References 1,2, 3 and 4 is documented.

• Restriction on the replacement of loop components to require the provisions of Sections 8.5.1 and 8.5.2 of Reference I are met, or that the RTT surveillance is reinstated.

• Design procedures will ensure that the provisions of References 1 and 3 are considered when design changes are made to the subject trip channels.

• Any design change or altered maintenance practice affecting these provisions will be subject to review in accordance with the requirements of 10 CFR 50.59, "Changes, tests and experiments."

ATTACHMENT 1 Evaluation of Proposed Changes For LaSalle County Station Page 13 of 17

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration In accordance with 10 CFR 50.90, Exelon Generation Company, LLC (EGC) requests a revision to Appendix A, Technical Specifications (TS), of Facility Operating License Nos. NPF-11 and NPF-18 for LaSalle County Station. The proposed change would modify the TS to eliminate the response time testing (RTT) requirements for TS Section 3.3.1.1, 'Reactor Protection System (RPS)

Instrumentation," Reactor Vessel Steam Dome Pressure - High function and for TS Section 3.3.6.1, "Primary Containment Isolation Instrumentation," Reactor Vessel Water Level - Low Low Low, Level 1 and Main Steam Line Pressure -

Low, functions. The proposed changes are consistent with the BWR Owners' Group (BWROG) Licensing Topical Report (LTR) NEDO-32291-A, "System Analyses for Elimination of Selected Response Time Testing requirements,"

dated October 1995, and its Supplement 1, dated October 1999.

Elimination of the response time testing requirements will result in significant improvement in plant safety by: (1)minimizing the time when safety systems are out of service or otherwise incapable of responding to a degraded plant condition; (2)reducing the potential for inadvertent RPS or essential safety function (ESF) actuations; (3)reducing the complexity of refuel outages and thus reducing shutdown risk; (4)reducing personnel radiation exposure; and, (5) allowing critical personnel to be used for more significant tasks.

EGC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below.

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed amendment to the TS eliminates selected RTT requirements in accordance with the NRC approved BWROG LTR. Elimination of RTT for selected instrumentation in the Reactor Protection System and Primary Containment Isolation Instrumentation does not result in the alteration of the design, material, or construction standards that were applicable prior to the proposed change. The response time assumptions used in the accident analyses remain unchanged. Only the methodology used for response time verification is changed. All component models used in the affected trip channels were analyzed for a bounding response time. As documented in the BWROG LTR and supplement, a degraded response time will be detected by other TS required tests. The bounding response time of the relays discussed in the supplement to the LTR can be used in place of actual measured response times to ensure that the instrumentation systems will meet the response time requirements of the accident analysis.

ATTACHMENT I Evaluation of Proposed Changes For LaSalle County Station Page 14 of 17 The proposed change will not result in the modification of any system interface that would increase the likelihood of an accident since these events are independent of the proposed change. In addition, the proposed amendment will not change, degrade, or prevent actions, or alter any assumptions previously made in evaluating the radiological consequences of an accident.

In summary, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed action does not involve physical alteration of the station. No new equipment is being introduced, and installed equipment is not being operated in a new or different manner. There is no change being made to the parameters within which LaSalle is operated. There are no setpoints at which protective or mitigative actions are initiated that are affected by this proposed action. All Reactor Protection System and Primary Containment Isolation Instrumentation channels affected by the proposed change will continue to have an initial response time verified by test before initially placing the channel in service and after any maintenance that could affect response time.

The proposed change does not alter assumptions made in the safety analysis. A review of the failure modes of the affected sensors and relays indicates that a sluggish response of the instruments can be detected by other TS surveillances.

Changing the method of periodically verifying instrument response for the' selected instrument channels will not create any new accident initiators or scenarios. Periodic surveillance of these instruments will detect significant degradation in the channel characteristic. This proposed action will not alter the manner in which equipment operation is initiated, nor will the function demands on credited equipment be changed. No change is being made to procedures relied upon to respond to an off-normal event. As such, no new failure modes are being introduced.

The sensors and relays in the affected channels will be able to meet the bounding response times as defined and presented in the LTR Supplement. It has been found acceptable to use component bounding response times in place of actual measured response times to ensure that instrumentation systems will meet response time requirements of the accident analyses. Inaddition, EGC's adherence to the conditions listed in the NRC Safety Evaluations for the LTR and Supplement provides additional assurance that the instrumentation systems will meet the response time requirements of the accident analyses.

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

ATTACHMENT 1 Evaluation of Proposed Changes For LaSalle County Station Page 15 of 17

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

Implementation of the BWROG LTR methodologies for eliminating selected response time testing requirements does not involve a significant reduction in the margin of safety. The current response time limits are based on the maximum values assumed in the plant safety analyses. The analyses conservatively establish the margin of safety. The elimination of the selected response time testing does not affect the capability of the associated systems to perform their intended function within the allowed response time used as the basis for plant safety analyses. Plant and system response to an initiating event will remain in compliance within the assumptions of the safety analyses, and therefore, the margin of safety is not affected. This is based on the ability to detect a degraded response time of an instrument or relay by the other required TS tests, component reliability, and redundancy and diversity of the affected functions, as justified in the reviewed and approved LTR and Supplement.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Conclusion Based on the above, EGC concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92, paragraph (c), and, accordingly, a finding of no significant hazards consideration is justified.

5.2 Applicable Regulatory Requirements/Criteria The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met. EGC has determined that the proposed change does not require any exemptions or relief from regulatory requirements, other than the Technical Specifications, and does not affect conformance with any General Design Criteria (GDC) differently than described in the LaSalle County Station Updated Final Safety Analysis Report (UFSAR).

Applicable regulatory requirements will continue to be met, adequate defense-in-depth will be maintained, and sufficient safety margins will be maintained. EGC's adherence to the conditions listed in the NRC Safety Evaluations for the LTR and Supplement provides additional assurance that the instrumentation systems will continue to meet the response time requirements of the accident analyses as defined in the UFSAR.

Inconclusion, based on the considerations discussed above, (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

ATTACHMENT I Evaluation of Proposed Changes For LaSalle County Station Page 16 of 17 conducted in compliance with the NRC'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.

The proposed changes are similar to license amendments issued for a number of other nuclear units. Specifically, the proposed amendment is similar to amendments issued for Fermi 2 (Reference 5), Edwin I. Hatch Nuclear Plant Unit 2 (Reference 6), and Susquehanna Steam Electric Station Units 1 and 2 (Reference 7).

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation," or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any.effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," Paragraph (c)(9). Therefore, pursuant to 10 CFR 51.22, paragraph (b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

7.0 REFERENCES

1. BWR Owners' Group Licensing Topical Report, "System Analyses for the Elimination of Selected Response Time Testing Requirements," NEDO-32291-A, Supplement 1, dated October 1999

2. Letter from U.S. NRC to W. Glenn Warren (BWR Owners' Group), "Review of Boiling Water Reactor Owners Group (BWROG) Licensing Topical Report NEDO-32291, Supplement 1, System Analyses for Elimination of Selected Response Time Testing Requirements," dated June 11, 1999

3. BWR Owners' Group Licensing Topical Report, "System Analyses for Elimination of Selected Response Time Testing Requirements," NEDO-32291, dated January 1994

4. Letter from U.S. NRC to R.A. Pinelli (BWROG), "BWR Owners Group, Licensing Topical Report NEDO-32291, System Analyses for Elimination of Selected Response Time Testing Requirements, January 1994," dated December 28, 1994

5. Letter from U.S. NRC to W. T. O'Connor, Jr. (Detroit Edison Company),

"Fermi 2 - Issuance of Amendment Re: Response Time Testing Requirements for the Reactor Protection System and Primary Containment Isolation Instrumentation (TAC No. MB5173)," dated October 2, 2002

ATTACHMENT I Evaluation of Proposed Changes For LaSalle County Station Page 17 of 17

6. Letter from U. S. NRC to H. L. Sumner, Jr. (Southern Nuclear Operating Company, Inc.), 'Edwin I. Hatch Nuclear Plant, Unit 2 Re: Issuance of Amendment (TAC No. MB2007)," dated May 17, 2002

7. Letter from U. S. NRC to R. G. Byram (PPL Susquehanna, LLC),

"Susquehanna Steam Electric Station, Units 1 and 2 - Issuance of Amendment Re: Elimination of Response Time Testing for Certain Reactor Protection System and Isolation Actuation System Instrumentation (TAC Nos.

MB0516 and MB0517)," dated March 12, 2001

ATTACHMENT 2 Markup of Proposed LaSalle County Station Technical Specification Page Changes Revised Technical Specification Pages 3.3.1.1-8 3.3.6.1-6

RPS Instrumentation 3.3.1.1 Table 3.3.1.1-1 (page 2 of 3)

Reactor Protection System Instrumentation APPLICABLE CONDITIONS MODES OR REOUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REOUIREMENTS VALUE

2. Average Power Range Monitors (continued)

d. Inop 1.2 2 G SR 3.3.1.1.8 NA SR 3.3.1.1.9 SR 3.3.1.1.15

3. Reactor Vessel Steam Dome 1.2 2 G SR 3.3.1.1.9 < 1059.0 psig Pressure - High SR 3.3.1.1.10

4. Reactor Vessel Water 1.2 2 G SR 3.3.1.1.1 > 11.0 inches Level - Low. Level 3 SR 3.3.1.1.9 SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.17 S. main Steam Isolation I

• 8 F SR 3.3.1.1.9 < 13.7Z closed Valve- Closure SR 3.3.1.1.13 SR 3.3.1.1.15 SR 3.3.1.1.17

6. Drywell Pressure - High 1.2 2 G SR 3.3.1.1.9 < 1.93 psig SR 3.3.1.1.13 SR 3.3.1.1.15

7. Scram Discharge Volume Water Level - High

a. Transmitter/Trip Unit 1.2 2 G SR 3.3.1.1.9 < 767 ft SR 3.3.1.1.13 B.55 inches SR 3.3.1.1.15 elevation 5 (a) 2 H SR 3.3.1.1.9 < 767 ft SR 3.3.1.1.13 8.55 inches SR 3.3.1.1.15 elevation (continued)

(a) With any-control rod withdrawn from a core cell containing one or more fuel assemblies.

LaSalle 1 and 2 3.3.1.1 -8 Amendment No. 147/133

Primary Containment Isolation Instrumentation 3.3.6.1 Table 3.3.6.1-1 (page 1 of 4)

Primary Containment Isolation Instrumentation APPLICABLE CONDITIONS MODES OR REOUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REOUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION C.] REOUIREMENTS VALUE

1. Main Steam Line Isolation

a. Reactor Vessel Water 1.2.3 2 D SR 3.3.6.1.1 > -137.0 inches Level - Low Low Low. SR 3.3.6.1.2 Level 1 SR 3.3.6.1.4

b. Main Steam Line 1 2 E SR 3.3.6.1.2 > 826.5 psig Pressure - Low SR 3.3.6.1.3

c. Main Steam Line 1.2.3 2 per MSL D SR 3.3.6.1.2 > 128.0 psid Flow - High SR 3.3.6.1.3 SR 3.3.6.1.5 SR 3.3.6.1.6

d. Condenser Vacuum - Low 2 D SR 3.3.6.1.2 > 3.8 inches SR 3.3.6.1.4 Hg vacuum 3 (a) SR 3.3. 6.1.5

e. Main Steam Line Tunnel 1.2.3 2 0 SR 3.3.6.1.2 ' 66.4-F Differential SR 3.3.6.1.4 Temperature - High SR 3.3.6.1.5

f. Manual Initiation 1.2.3 2 G SR 3.3.6.1.5 NA

2. Primary Containment Isolation

a. Reactor Vessel Water 1.2.3 2 H SR 3.3.6.1.2 > -58.0 Inches Level - Low Low. SR 3.3.6.1.4 Level 2 SR 3.3.6.1.5

b. Drywell Pressure - High 1.2.3 2 H SR 3.3.6. 1.2 1.93 psig SR 3.3.6.1.4 SR 3.3.6.1.5

c. Reactor Building 1.2.3 2 F SR 3.3.6.1.1 < 42.0 mR/hr Ventilation Exhaust SR 3.3.6.1.2 Plenum Radiation - High SR 3.3.6.1.4 SR 3.3.6.1.5

d. Fuel Pool Ventilation 1.2.3 2 F SR 3.3.6.1.1 ' 42.0 mR/hr Exhaust SR 3.3.6.1.2 Radiation - High SR 3.3.6.1.4 SR 3.3.6.1.5 (continued)

(a) With any turbine stop valve not closed.

LaSalle 1 and 2 3.3.6. 1-6 Amendment No. 147/133

ATTACHMENT 3 Markup of Associated LaSalle County Station Bases Changes (For Information Only)

Revised Bases Page (Provided For Information Only)

B 3.3.1.1-33 B 3.3.1.1-34 B 3.3.1.1-35 B 3.3.6.1-38 B 3.3.6.1-39

RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE SR 3.3.1.1.16 (continued)

REQUIREMENTS the instrument setpoint methodology are incorporated into the Allowable Value and the actual setpoint. Because main turbine bypass flow can affect this setpoint nonconservatively (THERMAL POWER is derived from turbine first stage pressure), the main turbine bypass valves must remain closed during in-service calibration at THERMAL POWER

> 25% RTP, if performing the calibration using actual turbine first stage pressure, to ensure that the calibration is valid.

If any bypass channel setpoint is nonconservative (i.e., the Functions are bypassed at > 25% RTP. either due to open main turbine bypass valve(s) or other reasons), then the affected Turbine Stop Valve- Closure and Turbine Control Valve Fast Closure, Trip Oil Pressure -Low Functions are considered inoperable. Alternatively, the bypass channel can be placed in the conservative condition (nonbypass). If placed in the nonbypass condition, this SR is met and the channel is considered OPERABLE.

The Frequency of 24 months is based on engineering judgment and reliability of the components.

SR 3.3.1.1.17 This SR ensures that the individual channel response times are less than or equal to the maximum values assumed in the accident analysis. The RPS RESPONSE TIME acceptance criteria are included in Reference 11.

RPS RESPONSE TIME may be verified by actual response time measurements in any series of sequential, overl ,pping, or total cjapn -rdents. However, the sensoX/r or Funct n 9 and 4 llowed to be excluded fr`Wspecific RPS R urement if the conditions of Reference 12 are satisfied. If these conditions are satisfied, sensor response time may be allocated based on either assumed design sensor response time or the manufacturer's stated design response time. When the (continued)

LaSalle 1 and 2 B 3.3.1.1-33 Revision 0

RPS Instrumentation B 3.3.1.1 BASES SURVEILLANCE SR 3.3.1.1.17 (continued)

REOUIREMENTS requirements of Reference 12 are not satisfied, sensor response time must be measured. Also, regardless of whether or not the sensor response time is measured, the response time for the remaining portion of the channel, including the trip unit and relay logic, is required to be measured. In addition, the response time of the limit switches for Function 8 may be assumed to be the design limit switch response time and therefore, are excluded from the RPS RESPONSE TIME testing. This is allowed, as documented in Reference 13, since the actual measurement of the limit switch response time is not practicable as this test is done during the refueling outage when the turbine stop valves are fully closed, and thus the limit switch in the RPS circuitry is open. The design limit switch response time is 10 ms.

As noted (Note 1), neutron detectors are excluded from RPS RESPONSE TIME testing. The principles of detector operation virtually ensure an instantaneous response time. Note 3 modifies the starting point of the RPS RESPONSE TIME test for Function 9, since this starting point (start of turbine control valve fast closure) corresponds to safety analysis assumptions.

RPS RESPONSE TIME tests are conducted on a 24 month STAGGERED TEST BASIS. Note 2 requires STAGGERED TEST BASIS Frequency to be determined based on 4 channels per trip system, in lieu of the 8 channels specified in Table 3.3.1.1-1 for the MSIV Closure Function. This Frequency is based on the logic interrelationships of the various channels required to produce an RPS scram signal.

Therefore, staggered testing results in response time verification of these devices every 24 months. The 24 month Frequency is consistent with the refueling cycle and is based upon plant operating experience, which shows that random failures of instrumentation components causing serious time degradation, but not channel failure, are infrequent.

(continued)

LaSalle 1 and 2 B 3.3.1.1-34 Revision 0

RPS Instrumentation B 3.3.1.1 BASES (continued)

REFERENCES 1. UFSAR, Section 7.2.

2. UFSAR, Section 5.2.2.

3. UFSAR, Section 6.3.3.

4. UFSAR, Chapter 15.

5. UFSAR, Section 15.4.1.

6. NEDO-23842, "Continuous Control Rod Withdrawal in the Startup Range," April 18, 1978.

7. UFSAR. Section 7.6.3.3.

8. UFSAR, Section 15.4.9.

9. Letter, P. Check (NRC) to G. Lainas (NRC), "BWR Scram Discharge System Safety Evaluation," December 1, 1980.

10. NEDC-30851-P-A, "Technical Specification Improvement Analyses for BWR Reactor Protection System,"

March 1988.

11. Technical Requirements Manual.

12. NEDO-32291-A, "System Analyses for the Elimination of Selected Response Time Testing Requirements," October 1995.

13. Letter, W. G. Guldemond (NRC) to C. Reed (ComEd).

dated January 28, 1987.

sjeon (&4?or1se7Tme, Tesri4 A+,wi~reiisJ O~cjoter (999.

as LaSalle 1 and 2 8 3.3.1.1-35 Revision 0

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES SURVEILLANCE SR 3.3.6.1.6 (continued)

REQUIREMENTS due to a MSIV closure time not within limits does not require the associated instrumentation to be declared inoperable; only the MSIV is required to be declared inoperable.

ISOLATION SYSTEM RESPONSE TIME acceptance criteria are included in Reference 11.

ISOLATION SYSTEM RESPONSE TIME may be verified by actual response time measurements in any series of sequential, overlap ing, or tota nel meureme However, the

• senso or Functio .{arllowed to be exclu~t from specific ISOLATION SYSTE ONSE TIME measurement if the conditions of Reference 12 are satisfied.

If these conditions are satisfied, sensor response time may be allocated based on either assumed design sensor response time or the manufacturer's stated design response time.

When the requirements of Reference 12 are not satisfied, sensor response time must be measured. Also, regardless of whether or not the sensor response time is measured, the response time of the remaining portion of the channel, including the trip unit and relay logic, is required to be measured.

ISOLATION SYSTEM RESPONSE TIME tests are conducted on a 24 month STAGGERED TEST BASIS. The 24 month test Frequency is consistent with the refueling cycle and is based upon plant operating experience that shows that random failures of instrumentation components causing serious response time degradation, but not channel failure, are infrequent.

REFERENCES 1. UFSAR. Table 6.2-21.

2. UFSAR. Section 6.2.1.1.

3. UFSAR, Chapter 15.

4. UFSAR, Section 15.1.3.

(continued)

LaSalle 1 and 2 B 3.3.6.1-38 Revision 0

Primary Containment Isolation Instrumentation B 3.3.6.1 BASES REFERENCES 5. UFSAR, Section 15.6.4.

(continued)

6. UFSAR, Section 15.2.5

7. UFSAR, Section 15.4.9.

8. UFSAR. Section 9.3.5.

9. NEDC-31677-P-A, "Technical Specification Improvement Analysis for BWR Isolation Actuation Instrumentation,"

July 1990.

10. NEDC-30851-P-A, Supplement 2, "Technical Specifications Improvement Analysis for BWR Isolation Instrumentation Common to RPS and ECCS Instrumentation." March 1989.

11. Technical Requirements Manual.

12. NEDO-32291-A, "System Analyses for the Elimination of Selected Response Time Testing Requirements," October 1995.

1~ZTos~xi~ Tve77-Tisi- , 6j,;,-ejnjJ en 4 Oc4 -O~ev~(9q7.-

LaSalle 1 and 2 B 3.3.6.1-39 Revision 0

INSERT #1 (Bases page B 3.3.1.1-34):

The sensor and relay/logic components for Function 3 are assumed to operate at the design response time and therefore, are excluded from specific RPS RESPONSE TIME measurement. This allowance is supported by References 12 and 14, which determined that significant degradation of the channel response time can be detected during performance of other Technical Specification surveillance requirements.

INSERT #2 (Bases page B 3.3.6.1-38):

The sensor and relay/logic components for Functions l.a and 1.b are assumed to operate at the design response time and therefore, are excluded from specific RPS RESPONSE TIME measurement. This allowance is supported by References 12 and 13, which determined that significant degradation of the channel response time can be detected during performance of other Technical Specification surveillance requirements.

ATTACHMENT 4 Summary of Exelon Nuclear Commitments Page 1 of 2 The following table identifies commitments made in this document by Exelon Generation Company, LLC (EGC). Any other actions discussed in the submittal represent intended or planned actions by EGC. They are described to the NRC for the NRC's information and are not regulatory commitments.

COMMITMENT COMMITTED DATE OR "OUTAGE" Revise appropriate calibration procedures to require that the normally Prior to implementation of open contacts of the Agastat relays addressed in this amendment approved amendment request are confirmed to open in 70 msec or less after power is removed from the coil. Testing will be required prior to return to ervice.

Proceduralize the manufacturer's instructions for setup and Prior to implementation of adjustment of the GE HFA relays and require performance of this approved amendment procedure before initial operation and after any repair or maintenance.

Revise appropriate calibration procedures to require that the normally Prior to implementation of open contacts of the HFA relays addressed in this amendment approved amendment request are confirmed to open in 20 msec or less after power is removed from the coil. Testing will be required before installation or after maintenance or repair of the relays.

Revise post-maintenance test procedures to require performance of a Prior to implementation of hydraulic response time test prior to installation of new approved amendment ransmitter/switch or following refurbishment of a transmitter/switch to etermine initial sensor specific response time value.

Revise design guidance documents to require performance of a Prior to implementation of hydraulic response time test prior to installation of new approved amendment transmitter/switch or following refurbishment of a transmitter/switch to determine initial sensor specific response time value.

As part of change management the following training will be provided: Prior to implementation of

1. Provide training to maintenance personnel on the new procedural approved amendment requirement for performance of a baseline response time test ollowing refurbishment of an existing transmitter/switch.

Provide training to design engineers on the new procedural and esign guidance requirement for performance of a baseline response ime test prior to installation of a new transmitter/switch.

Revise appropriate calibration procedures to include steps to input a Prior to implementation of ast ramp or step change to system components during calibrations. pproved amendment

ATTACHMENT 4 Summary of Exelon Nuclear Commitments Page 2 of 2 COMMITMENT COMMITTED DATE OR "OUTAGE" Provide training for operators and maintenance technicians that Prior to implementation of addresses consequences of instrument response time degradation. approved amendment Revise appropriate procedures to assure maintenance technicians Prior to implementation of monitor for response time degradation during performance of approved amendment calibrations and functional tests.

Revise applicable surveillance test procedures to ensure that Prior to implementation of alibrations and functional tests are being performed in a manner that approved amendment alows simultaneous monitoring of both input and output response of units under test.