ML072710170

License Amendment, Revise Technical Specifications, Section 5.5.7, Inservice Testing Program.

ML072710170
Person / Time
Site:	LaSalle
Issue date:	10/17/2007
From:	Sands S NRC/NRR/ADRO/DORL/LPLIII-2
To:	Crane C Exelon Generation Co
Sands, S, NRR/DLPM/PD3-2, 415-3154
Shared Package
ML072710127	List: ML072710170
References
TAC MD3604, TAC MD3605
Download: ML072710170 (14)

Text

October 17, 2007 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, ISSUANCE OF AMENDMENTS RE: AMENDMENT TO TECHNICAL SPECIFICATION SECTION 5.5.7, INSERVICE TESTING PROGRAM (TAC NOS. MD3604 AND MD3605)

Dear Mr. Crane:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 185 to Facility Operating License No. NPF-11 and Amendment No. 172 to Facility Operating License No. NPF-18 for the LaSalle County Station, Units 1 and 2, respectively. The amendments are in response to your application dated November 17, 2006.

The amendments will replace reference to Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), with reference to the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) in Technical Specification (TS) 5.5.7, Inservice Testing Program. The proposed changes are based on TS Task Force (TSTF) 479-A, Revision 0, Changes to Reflect Revision of 10 CFR 50.55a, [Title 10 of the Code of Federal Regulations (10 CFR)], and TSTF-497, Revision 0, Limit Inservice Testing Program SR [surveillance requirement] 3.0.2 Application to Frequencies of 2 Years or Less, approved by the NRC on December 6, 2005.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission=s biweekly Federal Register notice.

Sincerely,

/RA/

Stephen P. Sands, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-373 and 50-374

Enclosures:

1. Amendment No. 185 to NPF-11

2. Amendment No. 172 to NPF-18

3. Safety Evaluation cc w/encls: See next page

October 17, 2007 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, ISSUANCE OF AMENDMENTS RE: AMENDMENT TO TECHNICAL SPECIFICATION SECTION 5.5.7, INSERVICE TESTING PROGRAM (TAC NOS. MD3604 AND MD3605)

Dear Mr. Crane:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 185 to Facility Operating License No. NPF-11 and Amendment No. 172 to Facility Operating License No. NPF-18 for the LaSalle County Station, Units 1 and 2, respectively. The amendments are in response to your application dated November 17, 2006.

The amendments will replace reference to Section XI of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code), with reference to the ASME Code for Operation and Maintenance of Nuclear Power Plants (OM Code) in Technical Specification (TS) 5.5.7, Inservice Testing Program. The proposed changes are based on TS Task Force (TSTF) 479-A, Revision 0, Changes to Reflect Revision of 10 CFR 50.55a, [Title 10 of the Code of Federal Regulations (10 CFR)], and TSTF-497, Revision 0, Limit Inservice Testing Program SR [surveillance requirement] 3.0.2 Application to Frequencies of 2 Years or Less, approved by the NRC on December 6, 2005.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission=s biweekly Federal Register notice.

Sincerely,

/RA/

Stephen P. Sands, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-373 and 50-374

Enclosures:

1. Amendment No. 185 to NPF-11

2. Amendment No. 172 to NPF-18

3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

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EXELON GENERATION COMPANY, LLC DOCKET NO. 50-373 LASALLE COUNTY STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 185 License No. NPF-11

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by the Exelon Generation Company, LLC (the licensee), dated November 17, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission=s regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission=s regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission=s regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-11 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 185, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 30 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Russell Gibbs, Chief Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance: October 12, 2007

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-374 LASALLE COUNTY STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 172 License No. NPF-18

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment filed by the Exelon Generation Company, LLC (the licensee), dated November 17, 2006, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission=s regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission=s regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission=s regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the enclosure to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-18 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 172, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of the date of its issuance and shall be implemented within 30 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Russell Gibbs, Chief Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating License Date of Issuance: October 12, 2007

ATTACHMENT TO LICENSE AMENDMENT NOS. 185 AND 172 FACILITY OPERATING LICENSE NOS. NPF-11 AND NPF-18 DOCKET NOS. 50-373 AND 50-374 Replace the following pages of the Facility Operating Licenses and Appendix "A" Technical Specifications with the enclosed pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Insert License NPF-11 License NPF-11 Page 3 Page 3 License NPF-18 License NPF-18 Page 3 Page 3 TSs TSs 5.5-5 5.5-5 5.5-6 5.5-6

(4) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5) Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of LaSalle County Station, Units 1 and 2.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission=s regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of full power (3489 megawatts thermal).

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 185, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Conduct of Work Activities During Fuel Load and Initial Startup The licensee shall review by committee all Unit 1 Preoperational Testing and System Demonstration activities performed concurrently with Unit 1 initial fuel loading or with the Unit 1 Startup Test Program to assure that the activity will not affect the safe performance of the Unit 1 fuel loading or the portion of the Unit 1 Startup Program being performed. The review shall address, as a minimum, system interaction, span of control, staffing, security and health physics, with respect to performance of the activity concurrently with the Unit 1 fuel loading or the portion of the Unit 1 Startup Program being performed. The committee for the review shall be composed of at least three members, knowledgeable in the above areas, and who meet the qualifications for professional-technical personnel specified by

(5) Pursuant to the Act and 10 CFR Parts 30, 40, and 70 possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of LaSalle County Station Units 1 and 2.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission=s regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1) Maximum Power Level The licensee is authorized to operate the facility at reactor core power levels not in excess of full power (3489 megawatts thermal). Items in Attachment 1 shall be completed as specified. Attachment 1 is hereby incorporated into this license.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 172, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Conduct of Work Activities During Fuel Load and Initial Startup The licensee shall review by committee all Unit 2 Preoperational Testing and System Demonstration activities performed concurrently with Unit 2 initial fuel loading or with the Unit 2 Startup Test Program to assure that the activity will not affect the safe performance of the Unit 2 fuel loading or the portion of the Unit 2 Startup Program being performed. The review shall address, as a minimum, system interaction, span of control, staffing, security and health physics, with respect to performance of the activity concurrently with the Unit 2 fuel loading or the portion of the Unit 2 Startup Program being performed. The committee for the review shall be composed of at least three members, knowledgeable in the above areas, and who meet the qualifications for professional-technical personnel specified by section 4.4 of ANSI N18.7-1971. At least one of these three shall be a senior member of the Assistant Superintendent of Operation=s staff.

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 185 TO FACILITY OPERATING LICENSE NO. NPF-11 AND AMENDMENT NO. 172 TO FACILITY OPERATING LICENSE NO. NPF-18 EXELON GENERATION COMPANY, LLC LASALLE COUNTY STATION, UNITS 1 AND 2 DOCKET NOS. 50-373 AND 50-374

1.0 INTRODUCTION

By letter to the Nuclear Regulatory Commission (NRC, the Commission) dated November 17, 2006, Exelon Generation Company (EGC, the licensee), requested changes to the technical specifications (TSs) for its LaSalle County Station (LSCS), Units 1 and 2. The proposed TS amendments would replace inservice testing (IST) program reference from the American Society of Mechanical Engineers Boiler and Pressure Vessel Code (ASME Code),Section XI to a reference to the Operation and Maintenance of Nuclear Power Plants (OM Code) and applicable addenda. This change would eliminate the ASME Code inconsistency between the revised IST program and the current TS, as required by Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.55a(f)(5)(ii). Additionally, the amendment would extend the applicability of Surveillance Requirement (SR) 3.0.2 provisions to other normal and accelerated frequencies specified as two years or less in the IST program.

2.0 REGULATORY EVALUATION

Section 182a of the Atomic Energy Act (Act) requires applicants for nuclear power operating licenses to include TSs as part of the license. These TSs are derived from the plant safety analyses.

The NRC staff reviewed the proposed changes for compliance with 10 CFR 50.36 and agreement with NUREG-1433 and 1434, General Electric Plants, Rev. 3.1. In general, licensees cannot justify TS changes solely on the basis of adopting the model standard technical specifications (STS). The NRC staff makes a determination that proposed changes maintain adequate safety. Changes that result in relaxation (less restrictive condition) of current TS requirements require detailed justification.

Section 50.55a(f)(5)(ii) of 10 CFR, requires that, if a revised IST program for a facility conflicts with the TS for that facility, the licensee shall apply to the NRC for amendment of the TS to conform the TS to the revised program. The licensee is required to submit the application, as specified in 10 CFR 50.4, at least 6 months before the start of the period during which the provisions become applicable, (as determined by 10 CFR 50.55a(f)(4)).

In 1990, the ASME published the initial edition of the ASME OM Code, which provides requirements for IST of pumps and valves. The ASME OM Code was developed and is maintained by the ASME Committee on Operation and Maintenance of Nuclear Power Plants.

The ASME OM Code was developed in response to the ASME Board on Nuclear Codes and Standards directive that transferred responsibility for the development and maintenance of requirements for the IST of pumps and valves from the ASME,Section XI, Subcommittee on Nuclear Inservice Inspection to the ASME OM Committee. The ASME intended the ASME OM Code to replace Section XI rules for IST of pumps and valves. The Section XI requirements for IST of pumps and valves that had been incorporated by reference into NRC regulations were deleted from Section XI in the 2000 Addenda.

The LSCS third 10-year interval IST programs were developed to meet the requirements of the 2001 Edition through 2003 Addenda of the ASME OM Code pursuant to 10 CFR 50.55a(f)(4)(ii) as required by 10 CFR 50.55a(f)(4). The TS 5.5.7 reference to Section XI of the ASME Code for IST requirements results in a reference to a deleted portion of the Section IX ASME Code. EGC submitted this TS amendment to revise the TS to reference the current ASME OM Code requirements. The licensee stated that the third 10-year IST interval for LSCS will begin on October 12, 2007.

Additionally, this TS amendment addresses TS Task Force (TSTF) Change Travelers TSTF-479 and TSTF-497. NUREG-1433, Standard Technical Specifications General Electric Plants, BWR/4, Revision 3.1, and NUREG-1434, Standard Technical Specifications General Electric Plants, BWR/6, Revision 3.1, incorporated TSTF traveler TSTF-479 in December 2005. This traveler addressed changes to Section 5.5.7, IST Program, in Revision 3.1 of the standard TS, to reflect the revisions to 10 CFR 50.55a referencing the ASME OM Code and the application of SR 3.0.2 to test frequencies specified in the IST program. NUREG-1433 and NUREG-1434 were again modified via TSTF traveler TSTF-497 in October 2006. This traveler updated Section 5.5.7.b to specify that the 25 percent extension applies only to IST frequencies of two years or less.

The NRCs findings with respect to authorizing or denying the TS amendment are given below.

3.0 TECHNICAL EVALUATION

3.1 Specific Changes Requested The licensee has proposed the following changes to the LSCS TS:

For TS Section 5.5.7, IST Program, the reference to Section XI of the ASME Code for IST requirements would be replaced with ASME OM Code in TS Sections: 5.5.7.a and 5.5.7.d.

For TS Section 5.5.7, IST Program, Section 5.5.7.b would be revised to apply SR 3.0.2 to other normal and accelerated frequencies specified as two years or less in the IST Program.

The associated TS SRs Bases Sections B 3.4.4, B 3.4.6, B 3.5.1, B 3.6.2.3, B 3.6.2.4, and B 3.8.1 would be revised to replace references to the ASME Code,Section XI with references to the ASME OM Code for consistency with the TS changes.

3.2 Basis for Changes TS 5.5.7, IST Program, establishes the SRs for IST of ASME Class 1, 2, and 3 components for LSCS. TS Section 5.5.7 currently referencesSection XI of the ASME Code as the source of requirements for the IST of ASME Code Class 1, 2, and 3, pumps and valves.

The regulations in 10 CFR 50.55a(f)(4) establish the effective Code edition and addenda to be used by licensees for performing IST of pumps and valves. The regulations in 10 CFR 50.55a(f)(4)(ii) require licensees to update their IST program to the latest approved edition and addenda of the ASME OM Code incorporated by reference into 10 CFR 50.55a(b).

The licensee states that the IST Program for the LSCS third interval was updated to comply with the appropriate revisions of the ASME OM Code and included the 2001 Edition through 2003 Addenda as the new Code of Record for performing IST at LSCS. Consequently, the current TS 5.5.7 reference to Section XI of the ASME Code is inconsistent with the revised IST program.

According to 10 CFR 50.55a(f)(5)(ii), if a revised IST program for a facility conflicts with the TS for the facility, the licensee is required to apply to the NRC for amendment of the TS to conform the TS to the revised IST program. The licensee must submit the application, as specified in 10 CFR 50.4, at least 6 months before the start of the period during which the provisions become applicable as determined by 10 CFR 50.55a(f)(4). Accordingly, EGC submitted an amendment application to conform TS 5.5.7 with the revised IST program for LSCS, Units 1 and 2.

TSTF-497, approved October 2006, updates standard TS 5.5.7.b to allow the 25 percent extension only for surveillance intervals of two years or less. Application of SR 3.0.2 to frequencies of two years or less is consistent with the NRC staff position contained in NUREG-1482, Guidelines for IST at Nuclear Power Plants.

3.3 Evaluation In 1990, ASME published the initial edition of the ASME OM Code, which provides the requirements for IST of pumps and valves. The OM Code was developed and is maintained by the ASME Committee on Operation and Maintenance of Nuclear Power Plants. The ASME OM Code was developed in response to the ASME Board on Nuclear Codes and Standards directive that transferred responsibility for development and maintenance of rules for the IST of pumps and valves from the ASME,Section XI, Subcommittee on Nuclear Inservice Inspection to the ASME OM Committee. The ASME intended the ASME OM Code to replace Section XI rules for IST of pumps and valves. The ASME publishes a new edition of the ASME OM Code every 3 years, and a new addendum every year. The LSCS third interval IST program was updated to comply with the 2001 Edition through 2003 Addenda of the ASME OM Code as required by 10 CFR 50.55a(f)(4)(ii).

Consequently, the TS 5.5.7 reference to Section XI of the ASME Code for IST requirements results in a reference to a deleted portion of the ASME Code. The TS changes though, do not eliminate any tests and do not relieve the licensee of its responsibility to seek relief from Code test requirements when they are impractical. The changes will eliminate the ASME Code inconsistency between the IST program and the TSs as required by 10 CFR 50.55a(f)(5)(ii). The

proposed change of the ASME Code from ASME Section XI to ASME OM Code will maintain consistency with the Code requirements; therefore, the NRC staff finds these proposed changes to be acceptable. Additionally, the proposed changes are consistent with the comparable Section 5.5.7 of the standard TS, contained in NUREG-1433, Revision 3.1, and NUREG-1434, Revision 3.1.

The licensees proposed change to TS 5.5.7.b applies SR 3.0.2 to the frequencies specified in TS 5.5.7.a and other normal and accelerated frequencies specified as two years or less in the IST program. This change recognizes that the IST program may direct that additional tests be performed in accordance with the ASME OM Code that are not at the standard intervals listed in TS 5.5.7.a. This is consistent with the intent of the 25 percent extension, in that the extension would provide operational flexibility, but would not significantly degrade the reliability that results from performing the surveillance at the specified frequency. Further, the licensees proposal to limit application of SR 3.0.2 to frequencies specified as two years or less limits the maximum incremental time period between surveillances that could be added by the 25 percent extension.

Without this limitation, some components, such as safety and relief valves which may be tested at surveillance intervals significantly greater than two years, could have extensions applied which would be greater than needed for operational flexibility. The proposed change is consistent with guidance contained in NUREG-1482 regarding maximum allowable extensions of test intervals. In light of the foregoing, the NRC staff finds this proposed change to be acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission=s regulations, the Illinois State official was notified of the proposed issuance of the amendments. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of the facilities components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (72FR 17948; April 10, 2007). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission=s regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public. LSCS is authorized to complete the proposed changes.

7.0 REFERENCES

1. Title 10 of the Code of Federal Regulations, Domestic Licensing of Production and Utilization Facilities, Part 50, Section 50.55a, Codes and Standards.

2. U.S. Nuclear Regulatory Commission, Guidance for Inservice Testing at Nuclear Power Plants, NUREG-1482, Revision 1, January 2005.

3. U.S. Nuclear Regulatory Commission, Standard Technical Specifications General Electric Plants BWR/4, NUREG-1433, Volume 1, Revision 3.1, December 1, 2005.

4. U.S. Nuclear Regulatory Commission, Standard Technical Specifications General Electric Plants, BWR/6, NUREG-1434, Volume 1, Revision 3.1, December 1, 2005.

Principal Contributors: M. Orenak, NRR G. Waig, NRR Date: October 12, 2007