ML042780222

RAI, Oscillation Power Range Monitors

ML042780222
Person / Time
Site:	LaSalle
Issue date:	10/22/2004
From:	Pickett D NRC/NRR/DLPM/LPD3
To:	Crane C Exelon Generation Co
Pickett D, NRR/DLPM, 415-1364
References
TAC MC3033, TAC MC3034
Download: ML042780222 (7)

Text

October 22, 2004 Mr. Christopher M. Crane, President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RE: OSCILLATION POWER RANGE MONITORS (TAC NOS. MC3033 AND MC3034)

Dear Mr. Crane:

By letter dated April 30, 2004 (RS-04-069), Exelon Generation Company, LLC, submitted a license amendment application to incorporate oscillation power range monitor instrumentation into the LaSalle County Stations Technical Specifications. As part of the Nuclear Regulatory Commission staffs ongoing review of this application, additional information will be needed in order to complete our review.

The enclosed request for additional information has previously been forwarded to your staff. If you have any questions concerning our review or the enclosure please contact me at (301) 415-1364.

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-373 and 50-374

Enclosure:

As stated cc w/encls: See next page

October 22, 2004 Mr. Christopher M. Crane, President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RE: OSCILLATION POWER RANGE MONITORS (TAC NOS. MC3033 AND MC3034)

Dear Mr. Crane:

By letter dated April 30, 2004 (RS-04-069), Exelon Generation Company, LLC, submitted a license amendment application to incorporate oscillation power range monitor instrumentation into the LaSalle County Stations Technical Specifications. As part of the Nuclear Regulatory Commission staffs ongoing review of this application, additional information will be needed in order to complete our review.

The enclosed request for additional information has previously been forwarded to your staff. If you have any questions concerning our review or the enclosure please contact me at (301) 415-1364.

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-373 and 50-374

Enclosure:

As stated cc w/encls: See next page DISTRIBUTION:

PUBLIC GSuh DLPM DPR PDIII-2 R/F OGC JHardy DPickett ACRS HGarg PCoates SReynolds CSchulten ADAMS Accession Number: ML04278022 OFFICE PM:LPD3-2 LA:LPD3-2 SC:LPD3-2 NAME DPickett PCoates GSuh DATE 10/07/04 10/07/04 10/22/04 OFFICIAL RECORD COPY

LaSalle County Station Units 1 and 2 cc:

Site Vice President - LaSalle County Station Robert Cushing, Chief, Public Utilities Division Exelon Generation Company, LLC Illinois Attorney General's Office 2601 North 21st Road 100 W. Randolph Street Marseilles, IL 61341-9757 Chicago, IL 60601 LaSalle County Station Plant Manager Regional Administrator Exelon Generation Company, LLC U.S. NRC, Region III 2601 North 21st Road 801 Warrenville Road Marseilles, IL 61341-9757 Lisle, IL 60532-4351 Regulatory Assurance Manager - LaSalle Illinois Emergency Management Exelon Generation Company, LLC Agency 2601 North 21st Road Division of Disaster Assistance &

Marseilles, IL 61341-9757 Preparedness 110 East Adams Street U.S. Nuclear Regulatory Commission Springfield, IL 62701-1109 LaSalle Resident Inspectors Office 2605 North 21st Road Document Control Desk - Licensing Marseilles, IL 61341-9756 Exelon Generation Company, LLC 4300 Winfield Road Phillip P. Steptoe, Esquire Warrenville, IL 60555 Sidley and Austin One First National Plaza Senior Vice President - Nuclear Services Chicago, IL 60603 Exelon Generation Company, LLC 4300 Winfield Road Assistant Attorney General Warrenville, IL 60555 100 W. Randolph St. Suite 12 Chicago, IL 60601 Vice President of Operations - Mid-West Boiling Water Reactors Chairman Exelon Generation Company, LLC LaSalle County Board 4300 Winfield Road 707 Etna Road Warrenville, IL 60555 Ottawa, IL 61350 Vice President - Licensing and Regulatory Attorney General Affairs 500 S. Second Street Exelon Generation Company, LLC Springfield, IL 62701 4300 Winfield Road Warrenville, IL 60555 Chairman Illinois Commerce Commission 527 E. Capitol Avenue, Leland Building Springfield, IL 62706

LaSalle County Station Units 1 and 2 cc:

Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Associate General Counsel Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Licensing - Dresden, Quad Cities and Clinton Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST FOR LASALLE COUNTY STATION UNITS 1 AND 2 PROPOSED CHANGES FOR THE ACTIVATION OF THE TRIP OUTPUTS OF THE OSCILLATION POWER RANGE MONITOR SYSTEM By letter dated April 30, 2004, Exelon Generation Company, LLC (EGC), submitted a proposed amendment to the Technical Specifications (TS) to Operating License Nos. NPF-11 and NPF-18 for LaSalle County Station, Units 1 and 2 respectively. The proposed amendment would revise TS 3.3.1.3, Oscillation Power Range Monitor (OPRM) Instrumentation, TS 3.4.1, Recirculating Loop Operating and TS 5.6.5, Core Operating Limits Report (COLR).

The staff has reviewed the application supporting the proposed license amendment. In order to complete our evaluation, the following information will be needed:

1. Describe in detail the current implementation status of the OPRM system including the detailed procedures to finalize system calibration and trip set-points based on the approach stated in NEDO-32465-A, Reactor Stability Detect and Suppress Solutions Licensing Basis Methodology for Reload Applications. Provide specific values for OPRM scram set points and the DIVOM correlation for the next cycle.

2. Identify any plant-specific differences from the generic values specified in NEDO-32465-A such as Period Based Detection Algorithm (PBDA) period confirmation set points in Table 3-1, PBDA trip set points in Table 3-2, and generic DIVOM curve slope.

3. Provide a detailed description of the procedure to generate the OPRM Period Based Algorithm Allowable Value and Confirmation Counts for future cycles, and the rationale to relocate the values to the COLR.

4. Provide a detailed description of the alternate method to detect and suppress thermal hydraulic instability oscillation stated in TS LCO 3.3.1.3, Actions A.3 and B.1.

5. TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation, states that with one or more functions with RPS trip capability not maintained, restore RPS trip capability within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or be in Mode 2 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. If an APRM deviates from calculated power by more than 2 percent, the flow biased simulated thermal power - upscale and fixed neutron flux high trip functions are inoperable, therefore, the actions of TS 3.3.1.1.C. are required. It is clear why Note 2 was included in TS 3.3.1.1. However, TS 3.3.1.3 has a completion time of 30 or 120 days and it is not clear why this same note is needed. Explain why Note 2 is required in TS 3.3.1.3 since the plant will be in Mode 2 in either 9 or 19 hours2.199074e-4 days <br />0.00528 hours <br />3.141534e-5 weeks <br />7.2295e-6 months <br /> if the inoperable APRM channel can not be returned to operable status.

6. In 2.0 Part A of the submittal stated that there are 4 exceptions from the ABB combustion engineering system installation. The reasons for these exceptions are explained in detail in Section 4.0 Part A. Two of the exceptions do not match. In 2.0 Part A, the second bullet on page 3 discusses the note that allows a 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> delay in the LCO required actions for maintenance. In Section 4.0 Part A, the fourth bullet on page 6 describes the change in the power set point for SR 3.3.1.3.4. The problem is the maintenance note is not referenced in Part 4.0 and the change to SR3.3.1.3.4 is not referenced in Part 2.0. Explain which of these is the exception to the ABB combustion engineering system installation.

7. ACTIONS Note 2 specifies either a 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> delay for entry into the associated Conditions and Required Actions if APRM indication is not within limits in accordance with Specification 3.3.1.1. This delay represents a deviation from the approved Topical Report (CENPD-400-NP-A, Rev 01). The justification for the time delay entries is based on the time required to perform gain adjustments on multiple APRM channels (Exelon Letter RS-04-069 dated April 30, 2004, Attachment 1).

Attachment 1 does not adequately justify the Note 2 delayed entry allowances within the context of the approved topical report Condition Completion Times (30 days to restore one or more inoperable channels). Attachment 1 does not discuss the Note 2 delayed entry within the context of APRM TS requirements which, like the OPRM TS, specify "Separate Condition Entry" is permitted for each APRM channel (LCO 3.3.1.1). For this item, additional information should include an evaluation of OPRM Note 2 for one and multiple inoperable APRM channels, including a discussion of likely scenarios for simultaneous multiple LCO (LCO 3.3.1.1 and 3.3.1.13) entry. Additionally, the staff requests an operability interpretation from the licensee for the Note 2 statement: not within limits in accordance with SR 3.3.1.1.2. This statement is unclear with regard to TS requirements for APRM channel operability.

8. On August 31, 2001, GE filed a Part 21 notification with respect to stability reload licensing calculations using generic DIVOM curve. Part 21 notification was issued because generic DIVOM curves specified in NEDO-32465 may not be conservative for current plant licensing conditions. Specifically, a non-conservative deficiency has been identified for use of the generic regional mode DIVOM curve for reload cycles which include high peak bundle power to flow ratios. The deficiency results in a non-conservative slope of the regional mode DIVOM curve so that the Option III trip setpoint is over predicted. On September 30, 2003, BWR owners group submitted the resolution to the concern identified by Part 21 notification. In accordance with the resolution each plant will generate plant-specific DIVOM curves in the reload licensing calculation. The submittal does not discuss how the concern identified in Part 21 has been addressed for LaSalle.

9. In order to ensure that the proposed OPRM trip will perform its intended design functions, the equipment should be qualified for all environmental conditions where it is installed as required by General Design Criteria (GDC) 4 of Appendix A to Part 50 of Title 10 of the Code of Federal Regulations, Part 50. Therefore, please confirm that the OPRM equipment at LaSalle has been qualified for electromagnetic interference (EMI) and radio frequency interference (RFI) based on either the worst-case EMI/RFI levels at its installed location or by using the generic levels identified by EPRI TR-102323 and Regulatory Guide 1.180.