PLA-6143, Supplement to Proposed License Amendment Nos. 279 and 248, Arts/Mellla Implementation - Response to NRC Request for Additional Information

Supplement to Proposed License Amendment Nos. 279 and 248, Arts/Mellla Implementation - Response to NRC Request for Additional Information

ML063610192
Person / Time
Site:	Susquehanna
Issue date:	12/15/2006
From:	Mckinney B Susquehanna
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
PLA-6143
Download: ML063610192 (8)

Text

Brltt T. McKInney PPL Susquehanna, LLC Sr. Vice President & Chief Nuclear Officer 769 Salem Boulevard Berwick, PA 18603 Tel. 570.542.3149 Fax 570.542.1504 40 PPI btmckinney@pplweb.com I T.

U. S- Nuclear Regulatory Commission Attn: Document Control Desk Mail Stop OP 1-17 Washington, DC 20555-0001 SUSQUEHANNA STEAM ELECTRIC STATION SUPPLEMENT TO PROPOSED LICENSE AMENDMENT NO. 279 FOR UNIT 1 OPERATING LICENSE NO. NPF-14 AND NO. 248 FOR UNIT 2 OPERATING LICENSE NO. NPF-22 ARTS/MELLLA IMPLEMENTATION - RESPONSE TO NRC REQUEST FOR ADDITIONAL INFORMATION Docket Nos. 50-387 PLA-6143 and 50-388 Reference 1: PLA-5931, B. T McKinney (PPL)to Document ControlDesk (USNRC),

"SusquehannaSteam Electric Station ProposedLicense Amendment No. 2 79for Unit 1 OperatingLicense No. NPF-14 and 248for Unit 2 OperatingLicense No. NPF-22 ARTS/MELLLA Implementation, "dated November 18, 2005.

In accordance with 10 CFR 50.90, PPL Susquehanna, LLC (PPL) submitted a request for a license amendment to the Susquehanna Steam Electric Station (SSES) Unit 1 and Unit 2 Technical Specifications to implement an expanded operating domain resulting from the implementation of Average Power Range Monitor/Rod Block Monitor/

Technical Specifications/Maximum Extended Load Line Limit Analysis (ARTS/MELLLA) (Reference 1).

The purpose of this letter is to supplement the Reference 1 submittal to delete the requirement to perform SR 3.3.2.1.4 on the Rod Block Monitor Inop FUNCTION.

The Attachment to this letter provides the basis for this supplemental request.

PPL has reviewed the "No Significant Hazards Consideration" and the "Environmental Consideration" submitted with Reference 1 relative to this supplemental information.

We have determined that there are no changes required to either of these documents.

PPL respectfully requests that NRC expeditiously complete the review and approval of the proposed ARTS/MELLLA License Amendment Request proposed in Reference 1.

PPL continues to plan to implement ARTS/MELLLA for Unit 2 during the startup from the Spring 2007 Outage.

AcwD

Document Control Desk PLA-6143 If you have any questions or require additional information, please contact Mr. Michael Crowthers at (610) 774-7766.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on: Oecepe.6 /&, 2-ZC4, B. [cKinney Attachments:

Attachment - Supplement to PLA-5931 cc: NRC Region I Mr. A. J. Blarney, NRC Sr. Resident Inspector Mr. R. V. Guzman, NRC Project Manager Mr. R. R. Janati, DEP/BRP

Attachment to PLA-6143 Supplement to PLA-5931

Attachment to PLA-6143 Page 1 of 2 Supplement to PLA-5931 In the Reference 1 submittal, PPL inadvertently failed to delete the applicability of SR 3.3.2.1.4 from the Rod Block Monitor (RBM) Inop FUNCTION in Table 3.3.2.1-1.

The SR 3.3.2.1.4 shown in the SSES Unit 1 and Unit 2 Technical Specifications (TS) markups for the RBM Inop FUNCTION in Table 3.3.2.1-1 should have been crossed out.

This oversight was recently identified during implementation preparation activities for ARTS/MELLLA, scheduled to be implemented in the Spring of 2007 on SSES Unit 2.

The RBM Inop FUNCTION inserts a rod block when too few LPRM detectors are available. The RBM Inop FUNCTION is not affected by the proposed implementation of ARTS/MELLLA, as described on page 4-5 of Reference 1, Attachment 3.

The current SSES TS, Table 3.3.2.1-1 note "(a)" requires the RBM Inop FUNCTION L.b to be applicable in MODE 1 at > 30% RTP. The SR 3.3.2.1.4 requires verification that the RBM Inop FUNCTION is not bypassed at > 30% RTP. This SR is duplicative to the LCO applicability for the RBM Inop FUNCTION. If the RBM Inop FUNCTION is bypassed, it is not capable of performing its function as described in the TS and thus is not OPERABLE. This SR and the LCO Applicability requirement are verified by SSES startup procedures by verifying that the bypass for all RBM functions is cleared at

<30% power.

The SSES ARTS/MELLLA application proposes a revised SR 3.3.2.1.4 and revised Table 3.3.2.1-1 function applicability notes. The revised SR is worded such that the SR excludes the RBM Inop FUNCTION, unlike the current SSES SR. The revised SR is presented in "INSERT ARTS-I" of Reference 1. The revised Table 3.3.2.1-1 function applicability notes are presented in "INSERT ARTS-3" of Reference 1. The new notes that apply to the RBM Inop FUNCTION collectively require the RBM Inop FUNCTION to be applicable at > 28% RTP with MCPR less than the limits specified in the COLR.

The revised SR 3.3.2.1.4 wording and revised Table 3.3.2.1-1 notes are consistent with NUREG 1433 Revision 3. The SSES proposed revised SR and Table 3.3.2.1-1 notes are also consistent with the SR wording in the NRC-approved NEDC-32410P-A, Volume 2, "Nuclear Measurement Analysis and Control, Power Range Neutron Monitor (NUMAC PRNM) Retrofit Plus Option III Stability Trip Function," Class III, October 1995.

Attachment to PLA-6143 Page 2 of 2 The SR 3.3.2.1.4 is not required to be applied to the RBM Inop FUNCTION by the NUREG or the NRC-approved NEDC since the RBM Inop FUNCTION is required by the LCO Applicability (Table 3.3.2.1-1 function applicability notes) to be OPERABLE at the power levels required by the RBM to perform its protective safety functions.

Inclusion of an SR in TS to verify that an LCO Applicability requirement is met is not required nor is it part of the NUREG format, and thus inclusion of an SR of this type provides no added assurance of safety.

The revised TS markups showing the deletion of SR 3.3.2.1.4 for the RBM Inop FUNCTION in Table 3.3.2.1-1 are attached.

Reference:

PLA-5931, B. T. McKinney (PPL) to Document Control Desk (USNRC),

"Susquehanna Steam Electric Station Proposed License Amendment No. 279 for Unit 1 Operating License No. NPF-14 and 248 for Unit 2 Operating License No. NPF-22 ARTS/MELLLA Implementation," dated November 18, 2005.

Units I & 2 Revised Technical Specification Table 3.3.2.1-1 Markups (Deletion of SR 3.3.2.1.4 from Function 1.b)

PPLRev. 0 Control Rod Block Instrumentation 3.3.2.1 Table 3.32.1-1 (page 1 of 1)

Control Rod BWoi Instrmentatinon APPLICABLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS CHANNELS REQUIREMENTS VALUE 1, Rod Blok **// """

a. LOW Power 2 SR 3.32,1.1 < 0.58W÷55%4')

Range- / . "SR 3.3.2.1 A "

c. Downscale 1 2 SR 3.3.2.1.1 a 3/125 division of SR 3.32.1. full scale SR 3.32.1.7

2. Rod WOMt 14 1. SR 3.32.1.2 NA Mnmizrnk SR 33.32.1.3 SR 3.3.2.1.5 SR3.3.2.1.8

3. Reactor Mode (d) 2 SR 3.3.2.1.6 NA IhSwod--Sh*d . *II position Reactor mode switch In the shutdown position.

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