ML051940641
| ML051940641 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/13/2005 |
| From: | Cowan P Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML051940641 (2) | |
Text
Exelon Nuclear www exeloncorp corn zoo Exelon Way Kennett Square, PA 19348 10 CFR 50.90 July 13, 2005 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353
Subject:
License Amendment Request - Supplement Activation of the Trip Outputs of the Oscillation Power Range Monitor Portion of the Power Range Neutron Monitoring System
Reference:
Letter from K. R. Jury, Exelon Generation Company, LLC, to U. S. Nuclear Regulatory Commission, dated May 20, 2004 In the Reference letter, Exelon Generation Company, LLC (Exelon), requested a change to the Technical Specifications (TS), Appendix A, of Facility Operating License Nos. NPF-39 and NPF-85 for Limerick Generating Station (LGS), Units 1 and 2, respectively. The proposed change supports the activation of the trip outputs of the previously installed Oscillation Power Range Monitor (OPRM) portion of the General Electric (GE) Nuclear Measurement Analysis and Control (NUMAC) Power Range Neutron Monitoring (PRNM) system.
In the Reference letter, Exelon requested a 60-day implementation period for activation of the OPRM trip once the NRC issues the approved amendments. Exelon hereby requests that the implementation period for activation of the OPRM trip be extended to 90 days following NRC issuance of the approved amendments for the reasons described below.
Plant fieldwork activities are scheduled and resource loaded 12 weeks ahead of the work execution window in accordance with the Exelon work control process. During the 12-week process scheduled work is assessed for system interfaces and interactions, plant risk, and production risk. Scheduling of additional work inside this 12 week period results in previously scheduled and assessed work being removed from the execution work weeks and rescheduled for other work windows. This causes additional impacts in the work scheduling process in subsequent work weeks. Assessments for system interfaces and interactions, plant risk, and production risk must be revalidated.
Limerick OPRM Trip Activation LAR Supplement July 13, 2005 Page 2 The fieldwork activities for activation of the OPRM trip functions were initially scheduled to be implemented in June 2005, based on an anticipated NRC issuance of the approved amendments by May 20, 2005. The work was scheduled for this time to comply with the original 60-day implementation period and to complete the work prior to July and August. During July and August, sustained summer related high temperature and high humidity weather conditions can result in emergency generation conditions due to extreme power demandsJloading on the regional power supply system. Generation is optimized to provide maximum generation capability to satisfy the extreme power demandsJloading and maintain regional power system stability. During emergency generation conditions, work activities like those required to activate the OPRM trip functions are curtailed to eliminate the probability of a plant trip due to those activities.
Exelon therefore requests that the implementation period for activation of the OPRM trip functions be extended to 90 days following NRC issuance of the approved amendments so that the field work can be scheduled, resource loaded, and assessed in accordance with the Exelon work control process, and to provide flexibility to respond to summer weather related extreme power demandJloading conditions during the summer months. Both Limerick Units 1 & 2 will be implemented within this 90-day window. Exelon will continue to implement the interim corrective actions currently in place and approved by the NRC until activation of the OPRM trip functions is complete.
Exelon has concluded that the information provided in this supplement does not impact the conclusions of the: (1) Technical Analysis, (2) No Significant Hazards Consideration under the standards set forth in 10 CFR 50.92(c), or (3) Environmental Consideration as provided in the original submittal (the Reference letter).
There are no regulatory commitments contained within this letter.
If you have any questions or require additional information, please contact Glenn Stewart at 61 0-765-5529.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 13th day of July, 2005.
Respectfully, Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC cc:
Regional Administrator - NRC Region I NRC Senior Resident Inspector - LGS NRC Project Manager, NRR - LGS Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection