RS-04-131, Transmittal of Supplemental Information Supporting the Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements

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Transmittal of Supplemental Information Supporting the Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements
ML042460535
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 09/02/2004
From: Simpson P
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-04-131
Download: ML042460535 (7)


Text

Exelon Generation www,exeloncorp.com 4300 Winfield Road Warrenville, IL 60555 RS-04-131 September 2, 2004 U . S . Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Subject : Supplemental Information Supporting the Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements References : Letter from K. A. Ainger (Exelon Generation Company, LLC) to U. S . NRC, "Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements," dated March 12, 2004 (2) Letter from K. A. Ainger (Exelon Generation Company, LLC) to U . S. NRC, "Additional Information Supporting the Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements,"

dated June 16, 2004 In Reference 1, Exelon Generation Company, LLC (EGC) submitted a request for change to Appendix A, Technical Specifications (TS), of Facility Operating License Nos . NPF-11 and NPF-18 for LaSalle County Station . Specifically, 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 approved BWR Owners' Group Licensing Topical Report .

The NRC subsequently provided a request for additional information in support of their review of the Reference 1 amendment request. EGC provided the requested information in Reference 2.

In a conference call between EGC and the NRC on June 21, 2004, the NRC requested additional information be provided to supplement the responses provided in Reference 2 . The attachment to this letter provides the requested information .

September 2, 2004 U. S . Nuclear regulatory Commission Page 2 Should you have any questions related to this information, please contact Mr. Timothy A.

Byarn at (630) 657-2804 .

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of September 2004 .

Respectfully, Patrick R. Simpson Manager - Licensing Exelon Generation Company, LLC Attachment : Supplemental Information Supporting the Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements

ATTACHMENT Supplemental Information Supporting the Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements Question 1 In Reference 1 to this attachment, the response to Question 1 did not provide the range code for each sensor type evaluated A Reference 2 to this attachment . Provide the range code for each sensor type evaluated .

Response 1 There were two sensor types evaluated as pat of the subject amendment request. The SOR 9N6-B45-NX-ClA-JJTTX6 sensor does not have a range code . The other sensor type, Rosemount 1153DB Series, has a range code of 5 .

Question 2 In Reference 1 to this attachment, Question 2 requested an explanation of how the bounding response time was determined for the recorded historical test data for each loop type . Question 3 requested the historical test data for each sensor in each loop type be provided . The NRC stated that the basis for the maximum bounding response time was provided in Reference 1 to this attachment however, the actual bounding response time was not provided . The NRC indicated that the amendment request assumes a representative response time but did not do a statistical analysis of the data.

The NRC requested that Exelon Generation Company, LLC (EGC) provide the historical test data and statistical analysis of the data for each loop type evaluated .

Response 2 EGC has collected and evaluated the available historical response time testing data for the sensor types used for the three loops evaluated in Reference 2 to this attachment .

The historical data was used to compute an average response time value and a standard deviation of that data for the B21-N015 and B21-N023 Series (i.e., SOR Model 9N6-B45-NX-ClA-JJTTX6) differential pressure switches and the B21-N402 Series (i .e .,

Rosemont 1153 Series Model 11 53DB5PB) differential pressure transmitters . Once the average and standard deviation values were computed for each sensor type, then a bounding response time value was computed . The bounding response time was calculated by adding the average response time to an amount of variation that would provide a 95% probability with a 95% confidence (i .e ., 95/95 value) that future response time data would be less than or equal to this bounding response time. To calculate the bounding response time value, the 9555 value 90M Table 18 .4 of Reference 3 to this attachment was used . The sensor with the fewest number of historical data points (i.e.,

fourteen data points) was the B21-N023 series of data. From the Reference 3 table, the 9195 value was 3 .01 standard deviations.

When the bounding response time value was computed it was compared to the maximum response time value allowed in the instrument loop's respective Reference evaluation in Reference 4 to this attachment . In all cases, the bounding response time

ATTACHMENT Supplemental Information Supporting the Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements value for the 95/95 condition was less than the previously evaluated value provided in Reference 2 to this attachment.

This evaluation has confirmed that the statistically averaged response time for the instrument sensors in each loop evaluated, is less than the maximum acceptable value defined in the BWR Owners' Group Licensing Topical Report (Reference 4 to this attachment) . The results of the evaluation, including the historical data used to determine the average response time and standard deviation for each loop type sensor, are provided in the attached tables . This evaluation supports the conclusions of Reference 2 to this attachment that the response time testing for the specified instrument loops can be eliminated in accordance with the guidance in Reference 4 to this attachment.

References

1. Letter from K. A. Ainger (Exelon Generation Company, LLC) to the U. S . NRC, "Additional Information Supporting the request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements," dated June 16, 2004
2. Letter from K. A. Ainger (Exelon Generation Company, LLC) to the U . S . NRC, "Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements," dated March 12, 2004
3. EPRI Report TR-103335, "Guidelines for Instrument Calibration Extension/Reduction Statistical Analysis of Instrument Calibration Data,"

Revision 1, dated October 1998

4. BWR Owners' group Licensing Topical Report, "System Analyses for the Elimination of Selected Response Time Testing Requirements," NEDO-32291-A, dated October 1995

ATTACHMENT Supplemental Information Supporting the Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements TABLE 1 Historical Data Evaluation for Loop Type E Differential Pressure Transmitters Rosemount Model 1153DB5PB 1 B21- 11321- 1 B21- 11321- 21321- 21321- 1-

[Date N402B N402D N402A N402B N402C N402D (msec) (msec) (msec) (msec) (msec) msec 05/27/1988 011OM991 04M6/1991 OV25/1992 --

10/27/1992 O 1 M8/1993 0911/1993 03/03/ 1995 02/09/ 1996 100 110 Average Maximum Response Bounding 109.72 756 Time Response Time

_Qrsec) ..... ... (msec)

Standard Bounding Deviation 62 .78 Response Time 298.70 (msec)

ATTACHMENT Supplemental Information Supporting the Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements TABLE 2 Historical Data Evaluation for Loop Type K Differential Pressure Switches SOR Model 9N6-B45-NX-ClA-JJTTX6 11321- B21- 1B21- B21- 213211 - 21321 -

Date N023AA N023BA N023C [N023D 1 N023AA N023BA N023C N023D (msec) (msec) (m msec) sec) (msec) (msec) msec msec 04/01/1991 1 1 0216/1992 11 /13/1992 ON21/1995 0309/1995 --

10/29/1996 Average Maximum Response Bounding 13&57 465 Time Response Time (msec) (msec)

Standard Bounding Deviation 96.87 Response Time 430 .14 (msec)

ATTACHMENT Supplemental Information Supporting the Request for Technical Specification Changes to Eliminate Selected Response Time Testing Requirements TABLE 3 Historical Data Evaluation for Loop Type J Differential Pressure Switches SOR Model 9N6-B45-NX-C1 A-JJTTX6 11321- 1 B21- 1 B21- 2B21- 21321- 21321- 2B21-Date N015A N015B N015C N015D N015A N015B N015C N015D (msec) (msec) (msec) msec) (mse msec msec )L L (msec) 1022/1988 0017/1990 02/19/1991 220 200 01/06/1 992 1120 560 1 V26M 992 435 240 0217M 995 --

03/15/1995 --

02/13/1996 295 680 10/04/1996 Average Maximum Response Bounding 558 .68 1880 Time Response Time Qnsec) Qnsec)

Bounding Standard 414.13 Response Time 1805 .22 Deviation Arnsec)