ML081630557

Request for Additional Information Regarding Proposed Local Power Range Monitor Calibration Frequency Revision

ML081630557
Person / Time
Site:	Limerick
Issue date:	06/20/2008
From:	Peter Bamford NRC/NRR/ADRO/DORL/LPLI-2
To:	Pardee C Exelon Generation Co
Bamford, Peter J., NRR/DORL 415-2833
References
TAC MD7048, TAC MD7049
Download: ML081630557 (4)

Text

June 20, 2008 Mr. Charles G. Pardee Chief Nuclear Officer and Senior Vice President Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

LIMERICK GENERATING STATION, UNIT NOS. 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LOCAL POWER RANGE MONITOR CALIBRATION FREQUENCY REVISION (TAC NOS.

MD7048 AND MD7049)

Dear Mr. Pardee:

By letter dated October 19, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072970339), Exelon Generation Company, LLC, submitted a license amendment request (LAR) regarding an extension of the local power range monitor calibration interval specified in the technical specifications for Limerick Generating Station, Units 1 and 2. The original LAR was supplemented by letters dated March 14, 2008 (ADAMS Accession No. ML080850565) and March 26, 2008 (ADAMS Accession No. ML080990667).

The U.S. Nuclear Regulatory Commission staff has been reviewing your LAR, and has determined that a response to the enclosed Request for Additional Information (RAI) is necessary in order for the staff to complete its review. The questions in the enclosure were sent to Mr. Richard Gropp of your staff via electronic transmission in draft form on June 3, 2008. The draft RAI was sent to ensure that the questions were understandable, the regulatory basis was clear and to determine if the information was previously docketed. These questions were discussed with your staff in a teleconference on June 9, 2008, and it was agreed that you would provide responses within 30 days of the date of this letter.

Please contact me at 301-415-2833 if you have any questions.

Sincerely,

/ra/

Peter J. Bamford, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosure:

As stated cc w/encl: See next page

Limerick Generating Station, Unit Nos. 1 and 2 cc:

Christopher Mudrick Site Vice President Limerick Generating Station Manager Licensing Exelon Generation Company, LLC Exelon Generation Company, LLC 3146 Sanatoga Road Correspondence Control Sanatoga, PA 19464 P.O. Box 160 Kennett Square, PA 19348 Ed Callan, Plant Manager Limerick Generating Station Correspondence Control Desk Exelon Generation Company, LLC Exelon Generation Company, LLC 3146 Santoga Road 200 Exelon Way, KSA 1-N-1 Sanatoga, PA 19464 Kennett Square, PA 19348 Manager Regulatory Assurance - Limerick Regional Administrator, Region I Generating Station U.S. Nuclear Regulatory Commission Exelon Generation Company, LLC 475 Allendale Road 3146 Sanatoga Road King of Prussia, PA 19406 Sanatoga, PA 19464 Senior Resident Inspector Senior Vice President - Mid-Atlantic U.S. Nuclear Regulatory Commission Operations Limerick Generating Station Exelon Generation Company, LLC P.O. Box 596 200 Exelon Way, KSA 3-N Pottstown, PA 19464 Kennett Square, PA 19348 Library Chief Operating Officer- Exelon Nuclear U.S. Nuclear Regulatory Commission Exelon Generation Company, LLC Region I 4300 Winfield Road 475 Allendale Road Warrenville, IL 60555 King of Prussia, PA 19406 Senior Vice President -Operations Support Director, Bureau of Radiation Protection Exelon Generation Company, LLC Pennsylvania Dept. of Environmental 4300 Winfield Road Protection Warrenville, IL 60555 Rachel Carson State Office Building P.O. Box 8469 Vice President Harrisburg, PA 17105-8469 Licensing and Regulatory Affairs Exelon Generation Company, LLC Chairman 4300 Winfield Road Board of Supervisors of Limerick Township Warrenville, IL 60555 646 West Ridge Pike Linfield, PA 19468 Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Dr. Judith Johnsrud Correspondence Control National Energy Committee P.O. Box 160 Sierra Club Kennett Square, PA 19348 433 Orlando Avenue State College, PA 16803

Limerick Generating Station, Unit Nos. 1 and 2 cc:

J. Bradley Fewell, Esquire Associate General Counsel Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Mr. Charles G. Pardee Chief Nuclear Officer and Senior Vice President Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

June 20, 2008 Mr. Charles G. Pardee Chief Nuclear Officer and Senior Vice President Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348

SUBJECT:

LIMERICK GENERATING STATION, UNIT NOS. 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LOCAL POWER RANGE MONITOR CALIBRATION FREQUENCY REVISION (TAC NOS.

MD7048 AND MD7049)

Dear Mr. Pardee:

By letter dated October 19, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072970339), Exelon Generation Company, LLC, submitted a license amendment request (LAR) regarding an extension of the local power range monitor calibration interval specified in the technical specifications for Limerick Generating Station, Units 1 and 2. The original LAR was supplemented by letters dated March 14, 2008 (ADAMS Accession No. ML080850565) and March 26, 2008 (ADAMS Accession No. ML080990667).

The U.S. Nuclear Regulatory Commission staff has been reviewing your LAR, and has determined that a response to the enclosed Request for Additional Information (RAI) is necessary in order for the staff to complete its review. The questions in the enclosure were sent to Mr.

Richard Gropp of your staff via electronic transmission in draft form on June 3, 2008. The draft RAI was sent to ensure that the questions were understandable, the regulatory basis was clear and to determine if the information was previously docketed. These questions were discussed with your staff in a teleconference on June 9, 2008, and it was agreed that you would provide responses within 30 days of the date of this letter.

Please contact me at 301-415-2833 if you have any questions.

Sincerely,

/ra/

Peter J. Bamford, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353

Enclosure:

As stated cc w/encl: See next page DISTRIBUTION:

PUBLIC LPL1-2 R/F RidsNrrPMPBamford RidsNrrLAABaxter RidsOgcRp RidsAcrsAcnw&mMailCenter RidsNrrDorlLpl1-2 RidsRgn1MailCenter RidsNrrDorlDpr Accession Number: ML081630557 OFFICE LPL1-2/PM LPL1-2/LA LPL1-2/BC NAME PBamford ABaxter HChernoff DATE 6/17/08 6/17/08 6/20/08 Official Record Copy

REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED CHANGES TO THE TECHNICAL SPECIFICATIONS LOCAL POWER RANGE MONITOR CALIBRATION FREQUENCY LIMERICK GENERATING STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-352 AND 50-353 By letter dated October 19, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072970339), Exelon Generation Company, LLC, submitted a license amendment request (LAR) regarding an extension of the local power range monitor (LPRM) calibration interval specified in the technical specifications for Limerick Generating Station, Units 1 and 2. The original LAR was supplemented by letters dated March 14, 2008 (ADAMS Accession No. ML080850565) and March 26, 2008 (ADAMS Accession No. ML080990667).

The Nuclear Regulatory Commission staff has been reviewing the submittal and has determined that additional information is needed to complete its review.

1.) In Enclosure 1 of the March 14, 2008, supplement, it is stated that 2,000 effective full-power hours (EFPH) is equivalent to ~ (approximately) 2,000 Megawatt Days per short ton (MWD/st). Provide a demonstration that 2,000 EFPH is conservative or equivalent to 2,000 MWD/st or provide a proposed surveillance interval that is bounding with respect to the analysis.

• 2.) In the March 14, 2008, supplement, it is stated that, Reference 9 also shows [emphasis added] that this has an (( )) on the calculated SLMCPR [Safety Limit Minimum Critical Power Ratio] value. Reference 9 was provided by the March 26, 2008, supplement, in which it is stated, For the Limerick plants, comparison between SLMCPR calculations using the original LPRM [local power range monitor] update uncertainty and the doubled LPRM update uncertainty shows an (( )) on the calculated SLMCPR. This is a statement or conclusion. Provide a demonstration or calculations with an explanation that shows this conclusion is valid.

3.) In the March 26, 2008, supplement, a demonstration was provided regarding doubling of the LPRM uncertainty on the SLMCPR. Is it your intent to apply this doubling to your SLMCPR calculations and reflect this methodology change in your licensing basis when operating with the longer surveillance interval? If so, how will the SLMCPR calculations and the licensing basis documentation be updated?

• Quotations in question (2), including the empty brackets, are taken from the non-proprietary versions of the supplements referenced.