ML043240126
| ML043240126 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 03/11/2005 |
| From: | Jabbour K NRC/NRR/DLPM/LPD3 |
| To: | Crane C AmerGen Energy Co |
| Jabbour K, NRR/DLPM, 415-1496 | |
| References | |
| TAC MC1323 | |
| Download: ML043240126 (5) | |
Text
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March 11, 2005 Mr. Christopher M. Crane, President and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, Illinois 60555
SUBJECT:
CLINTON POWER STATION, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATION RE: INSTRUMENT CHANNEL TRIP SETPOINT ALLOWABLE VALUES (TAC NO. MC1323)
Dear Mr. Crane:
By letter dated November 11, 2003 (RS-03-199), AmerGen submitted a license amendment for the Clinton Power Station, Unit 1, using instrumentation setpoints established by means of the Instrument Society of America (ISA) Standard, ISA-S67.04-1994, "Setpoints for Nuclear Safety-Related Instrumentation."
The Clinton Unit 1 Technical Specifications (TSs) define Limiting Safety System Settings (LSSSs) as allowable values (AVs). During reviews of proposed license amendments that contain changes to LSSS setpoints, the U.S. Nuclear Regulatory Commission (NRC) staff has identified concerns regarding the method used by some licensees to determine the AVs identified in the TSs. AVs are identified in the TSs as LSSSs to provide acceptance criteria for determination of instrument channel operability during periodic surveillance testing. The NRC staffs safety concern relates to one of the three methods for determining the AVs as described in the ISA recommended practice, ISA-RP67.04-1994, Part II, "Methodologies for Determination of Setpoints for Nuclear Safety-Related Instrumentation."
The staff has determined that, absent additional information related to determining the operability of the instrument channel, AVs associated with LSSSs established by means of ISA-RP67.04, Part II, Method 3, will not provide reasonable assurance that a plant will operate in accordance with the assumptions upon which the plant safety analyses have been based.
Details about the NRC staff's concerns are available on the NRC's public website under ADAMS Accession Numbers ML041690604 and ML0418103461.
In order for the NRC staff to assess the acceptability of your license amendment request related to this issue, the NRC staff requests the following additional information:
1.
Discuss the setpoint methodology used at Clinton Unit 1 to establish AVs associated with LSSS setpoints.
C. Crane 2.
Regardless of the methodology used, the NRC staff has the following questions regarding the use of the methodology at Clinton Unit 1:
- a. Discuss how the methodology and controls you have in place ensure that the analytical limit associated with an LSSS trip setpoint will not be exceeded (that the safety limit will not be exceeded). Include in your discussion information on the controls you employ to ensure the trip setpoint established after completing periodic surveillances satisfies your methodology. If the controls are located in a document other than the TSs, discuss how those controls satisfy the requirements of 10 CFR 50.36.
- b. Discuss how the TS surveillances ensure the operability of the instrument channel.
Specifically, relate the surveillance test results to the TS AVs and describe how these are used to determine the operability of the instrument channels. If the requirements for determining operability of the LSSS instrument being tested are in a document other than the TSs (e.g., plant test procedures), discuss how this meets the requirements of 10 CFR 50.36.
This request for additional information was previously forwarded to and discussed with Mr. Timothy Byam on March 8, 2005. Mr. Byam agreed that a response would be provided within 30 days of the date of this letter.
If you have any comments or questions, please contact the Clinton Project Manager, Kahtan Jabbour, at (301) 415-1496.
Sincerely,
/RA/
Kahtan N. Jabbour, Senior Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket No. 50-461 cc: See next page
- See previous concurrence OFFICE PM:PD3-2 LA:PD3-2 SC:EEIB*
SC:PD3-2 NAME KJabbour DClarke for PCoates EMarinos GSuh DATE 03/11/05 03/11/05 03/08/05 03/11/05
Clinton Power Station, Unit 1 cc:
Senior Vice President - Nuclear Services AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President of Operations - Mid-West Boiling Water Reactors AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President - Licensing and Regulatory Affairs AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Licensing - Dresden, Quad Cities, and Clinton AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Regulatory Assurance Manager - Clinton AmerGen Energy Company, LLC Clinton Power Station RR3, Box 228 Clinton, IL 61727-9351 Director - Licensing and Regulatory Affairs AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Document Control Desk-Licensing AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Site Vice President - Clinton Power Station AmerGen Energy Company, LLC Clinton Power Station RR 3, Box 228 Clinton, IL 61727-9351 Clinton Power Station Plant Manager AmerGen Energy Company, LLC Clinton Power Station RR 3, Box 228 Clinton, IL 61727-9351 Resident Inspector U.S. Nuclear Regulatory Commission RR #3, Box 229A Clinton, IL 61727 Chief Operating Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 801 Warrenville Road Lisle, IL 60532-4351 Associate General Counsel AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555 R. T. Hill Licensing Services Manager General Electric Company 175 Curtner Avenue, M/C 481 San Jose, CA 95125 Chairman of DeWitt County c/o County Clerks Office DeWitt County Courthouse Clinton, IL 61727
Clinton Power Station, Unit 1 J. W. Blattner Project Manager Sargent & Lundy Engineers 55 East Monroe Street Chicago, IL 60603 Illinois Emergency Management Agency Division of Disaster Assistance &
Preparedness 110 East Adams Street Springfield, IL 62701-1109