ML042800212
| ML042800212 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 10/08/2004 |
| From: | Travis Tate NRC/NRR/DLPM/LPD1 |
| To: | Crane C Exelon Generation Co, Exelon Nuclear |
| Tate T, NRR/DLPM, 415-8474 | |
| References | |
| TAC MC3847, TAC MC3848 | |
| Download: ML042800212 (4) | |
Text
October 8, 2004 Mr. Christopher M. Crane President and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 (LGS 1 and 2) -
REQUEST FOR ADDITIONAL INFORMATION RE: PROPOSED CHANGES TO CONTROL ROD REQUIREMENTS (TAC NOS. MC3847 AND MC3848)
Dear Mr. Crane:
By application dated July 22, 2004, Exelon Generation Company, LLC (Exelon), requested license amendments for LGS 1 and 2, related to control rod operability and surveillance requirements specified in Technical Specification 3/4.1.3, Control Rods.
The Nuclear Regulatory Commission (NRC) staff is reviewing the request and has determined that additional information is needed to complete the review. The specific information requested is addressed in the questions enclosed with this letter.
Per prior discussions with Mr. Dave Helker of your staff, it is requested that you provide the requested information within 30 days from the date of this letter. If circumstances result in the need to revise the response date, please contact me at (301) 415-8474.
Sincerely,
/RA/
Travis L. Tate, Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353
Enclosure:
Request for Additional Information cc w/encl: See next page
Mr. Christopher M. Crane President and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 (LGS 1 and 2) -
REQUEST FOR ADDITIONAL INFORMATION RE: PROPOSED CHANGES TO CONTROL ROD REQUIREMENTS (TAC NOS. MC3847 AND MC3848)
Dear Mr. Crane:
By application dated July 22, 2004, Exelon Generation Company, LLC (Exelon), requested license amendments for LGS 1 and 2, related to control rod operability and surveillance requirements specified in Technical Specification 3/4.1.3, Control Rods.
The Nuclear Regulatory Commission (NRC) staff is reviewing the request and has determined that additional information is needed to complete the review. The specific information requested is addressed in the questions enclosed with this letter.
Per prior discussions with Mr. Dave Helker of your staff, it is requested that you provide the requested information within 30 days from the date of this letter. If circumstances result in the need to revise the response date, please contact me at (301) 415-8474.
Sincerely,
/RA/
Travis L. Tate, Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353
Enclosure:
Request for Additional Information cc w/encl: See next page DISTRIBUTION:
PUBLIC PDI-2 R/F DCollins TTate JHardy GMatakas, RI OGC ACRS MOBrien AAttard DLPM DPR Accession Number: ML042800212 OFFICE PDI-2/PM PDI-2/LA PDI-2/SC(A)
NAME TTate MOBrien DCollins DATE 10/7/04 10/07/04 10/8/04 Official Record Copy
Limerick Generating Station, Unit Nos. 1 and 2 cc:
Site Vice President Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Plant Manager Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Regulatory Assurance Manager - Limerick Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Senior Vice President - Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Operations, Mid-Atlantic Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Vice President Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director Licensing and Regulatory Affairs Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Manager Licensing Limerick Generating Station Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Associate General Counsel Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Correspondence Control Desk Exelon Generation Company, LLC P.O. Box 160 Kennett Square, PA 19348 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector U.S. Nuclear Regulatory Commission Limerick Generating Station P.O. Box 596 Pottstown, PA 19464 Library U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Chief-Division of Nuclear Safety PA Dept. of Environmental Resources P.O. Box 8469 Harrisburg, PA 17105-8469 Chairman Board of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803
Enclosure REQUEST FOR ADDITIONAL INFORMATION LIMERICK GENERATING STATION, UNITS 1 AND 2 (LGS 1 and 2)
REQUEST FOR LICENSE AMENDMENTS RELATED TO PROPOSED CHANGES TO CONTROL ROD REQUIREMENTS 1.
In the July 22, 2004, submittal, it is indicated that the proposed changes are consistent with NUREG-1433, Rev. 2, Standard Technical Specifications - General Electric Plants, BWR/4." The proposed change to Technical Specification (TS) 3.1.3.1.b.1.b involves the removal of the statement, by drive water pressure within the normal operating range, from the Limiting Condition for Operation (LCO) statement. The NRC staffs review determined that the change to the proposed LCO is not consistent with the corresponding Standard Technical Specification (STS) 3.1.3.C of NUREG-1433, Rev. 2.
LGS 1 and 2 TS 3.1.3.1.b.1.b requires that the insertion capability of a trippable but inoperable control rod be demonstrated by inserting the control rod one notch. STS 3.1.3.C requires the an inoperable control rod be fully inserted within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and the control rod drive is to be disarmed within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />. The STS does not have a provision to allow an inoperable control rod to remain in a withdrawn position. The proposed change would remove the restriction on the drive water pressure. Please explain why the higher control rod drive pressure is not an indicator of a condition that inhibits the safety function of the control rod as indicated in Section 3.0, page 5, of the submittal. Provide a justification for why a required higher drive pressure, in addition to a condition that results in a rod being declared inoperable, is not the result of degradation that prohibits a rods insertion capability.
2.
TS 3.1.3.b.1.b uses the term trippable to distinguish the condition of an inoperable control rod. However, the associated TS Bases does not define the criteria used to declare an inoperable control rod as trippable. Please explain the criteria used to declare inoperable control rods as trippable. Explain the impact of the proposed change to remove the restriction on the drive water pressure on the trippable criteria.
3.
Please explain whether or not the associated TS Bases section will require modifications as a result of the proposed changes.