Text

Summary of Meeting with Exelon Generation Company, LLC to Discuss the Request for Additional Information Related to License Amendment Regarding the Ultimate Heat Sink
	ML110620148
Person / Time
Site:	Byron
Issue date:	03/10/2011
From:	Nicholas Difrancesco; Plant Licensing Branch III
To:	;
	DiFrancesco N, NRR/DORL/LPL3-2, 415-1115
References
	TAC ME1670, TAC ME1669
	Download: ML110620148 (15)
	v • d • e

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555*0001 r~arch 10, 2011 LICENSEE:

Exelon Generation Company, LLC FACILITY:

Byron Station, Unit Nos. 1 and 2

SUBJECT:

SUMMARY

OF MARCH, 1,2011, MEETING WITH EXELON GENERATION COMPANY, LLC, TO DISCUSS THE REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REGARDING THE ULTIMATE HEAT SINK (TAC NOS. ME1669 AND ME1670)

On March 1, 2011, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Exelon Generation Company, LLC via teleconference with NRC staff. The purpose of the meeting was to discuss the development of Technical Specifications (TS) associated with the licensee response to request for additional information (RAI) dated February 14, 2011 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML110341352), related to licensee amendment request for Byron Station (Byron), Unit Nos. 1 and 2, to revise the TSs associated with the ultimate heat sink (UHS). A list of attendees is provided as Enclosure 1.

During the meeting, the licensee presented two different positions to the NRC staff:

1. Provided justification to retaining the TS as proposed in letter dated November 8, 2010 (ADAMS Accession No. ML103120556).

2. Proposed revised UHS TS (Enclosure 2) addressing the NRC staff RAI letter dated February 14, 2011.

For position 1, the licensee stated that they preferred to keep the proposed TS from the letter dated November 8,2010, containing Table 3.7.9-1 (which provides the number of operable UHS cooling tower fans required as a function of SX discharge temperature). The licensee provided the following justifications for why the TS with Table 3.7.9-1 were preferred:

1. Similar TSs were approved by the NRC for Vogtle Electric Generating Plant (Vogtle).

2. The operators would be more familiar with the approach using Table 3.7.9-1 as it was similar to the interim table that operators were trained on.

3. Use of Table 3.7.9-1 was more user friendly for a human factor prospective.

4. The TSs were drafted based on guidance from Nuclear Energy Institute (NEI) 01-03, Writer's Guide for the Improved Standard Technical Specifications (ADAMS Accession No. ML020450528)," and specifically referencing Section 4.1.4 (b) as a standard when developing the proposed TS Table 3.7.9-1.

The NRC staff noted that NEI 01-03 has not been endorsed by the NRC and that the Vogtle TS licensing basis is independent of the ongoing Byron review.

- 2 For position 2, the licensee presented a draft TS for the UHS. The TSs had been reformatted to address the NRC staff's RAI question dated February 14, 2011. The NRC staff noted that the draft TS would allow operation with one cooling tower fan inoperable with SX Pump Discharge temperature s 91°F in the Applicable Modes continuously. The NRC staff provided feedback to the licensee on its draft TS are contrary to Generic Letter (GL) 80-30, "Clarification of the Term

'Operable' as it Applies to Single Failure Criterion for Safety Systems Required by Technical Specifications." Specifically, GL 80-30 states, "that entry into action conditions are a temporary relaxation of the single failure criterion." As such, TS constructions that allow continuous operation within an Action Condition is not an acceptable method to write TSs.

The NRC staff asked the licensee if they had considered drafting the TSs in such a way as to not require continuous operation within an Action Condition. The NRC staff illustrated that the TSs could be written to avoid continuous operation within an Action Condition which were also consistent with the Byron's TS, Section 1.0, "Use and Application." This would involve constructing a Condition statement that contains a Note above the number of inoperable cooling tower fans. The number of inoperable cooling tower fans in the Condition would be one more than the maximum allowed number of inoperable cooling tower fans for a given SX Pump Discharge temperature region and the operational configuration of the SX trains. The Note would state "Only applicable when SX Pump Discharge temperature region is> X1 of and s X2 of AND SX Trains are Y." X1 and X2 represent temperatures and Y represents the operational configuration of the SX trains, either split or cross tied. Appropriate associated Required Actions for the given Condition would ensure that; 1) the operable cooling tower fans are capable of being powered by an operable emergency power source and 2) the number of operable cooling tower fans would be restored to at least the minimum number required for a given SX Pump Discharge temperature region and operational configuration of the SX trains.

Appropriate Completion Times for the given Condition would ensure that the Required Actions are completed in an acceptable time.

In summary, no regulatory decisions were made during this meeting. The NRC staff provided feedback to the licensee and illustrated that TSs could be drafted to be consistent with TS Section 1.0, avoid a relaxation of the single-failure criteria considering GL 80-30, and address the human factors concerns successfully.

Members of the public were not in attendance. Public Meeting Feedback forms were not received.

-3 Please direct any inquiries to me at 301-415-1115, or nicholas.difrancesco@nrc.gov.

Nicholas J. DiFrancesco, Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. STN 50-454 and STN 50-455

Enclosures:

1. List of Attendees

2. Licensee Handout - Proposed Draft Ultimate Heat Sink Technical Specifications cc w/encls: Distribution via Listserv

LIST OF ATTENDEES MARCH 1,2011, TELECONFERENCE WITH EXELON GENERATION COMPANY, LLC DISCUSSION OF TECHNICAL SPECIFICATIONS RELATED TO THE STAFF REVIEW OF AN ULTIMATE HEAT SINK AMENDMENT REQUEST G. Purciarello C. Schulten M. Hamm N. DiFrancesco Exelon L. Schofield D. Sargent J. Langan L. Rupert

3.7.9 UHS 3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS)

LCO 3.7.9 The UHS shall be OPERABLE.

APPLI CABI LITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQU IRED ACTI ON COMPLETION TIME A.

One or more OPERABLE cooling tower fanes) not running in high speed.

A.l Initiate actions to operate OPERABLE cooling tower fanes) in high speed.

Immediately AND SX pump discharge temperature> 82°F.

B.

One cooling tower fan inoperable.

B.1 Verify OPERABLE cooling tower fans are capable of being powered by an OPERABLE emergency power source.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND B.2 Restore cooling tower fan to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR BYRON - UNITS 1 & 2 3.7.9 1

Amendment.+/-Qi

3.7.9 UHS CONDITION REQUIRED ACTION

-NOTE--------

COMPLETION TIt-IE Required Action B.3 can not be utilized when SX trains are split on either Unit.

B.3 Verify SX pump discharge temperature i s ~ 91°F.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter C.

Two cooling tower fans inoperable.

C.1 Verify remalnlng OPERABLE cooling tower fans are capable of being powered by an OPERABLE emergency 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months power source.

AND C.2

-NOTE---

Required Action C.2 is only applicable when SX tra-j ns are split on either Unit.

Restore two cooling tower fans to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR C.3 Restore one cooling tower fan to OPERABLE status when SX pump discharge temperature is > 84°F and ~ 91°F.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR BYRON - UNITS 1 &2 3.7.9-2 limendment +/-Qi

3.7.9 UHS CONDITION REQUIRED ACTION C.4 Restore two cooling tower fan to OPERABLE status when SX pump discharge temperature is > 91°F.

OR

NOTE--------

Required Action C.5 can not be utilized when SX trains are split on either Unit.

C.5 Veri fy SX pump discharge temperature i s ~ 84°F.

AND C.6 Pl ace OPERABLE cooling tower fans in high speed when SX pump discharge temperature is > 77°F and ~ 8~F.

AND COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 4 hours AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter BYRON UNITS 1 &2 3.7.9 - 3 Amendment.we

3.7.9 UHS CONDITION REQUIRED ACTION

NOTE Required Actions C.7 and C.8 are not applicable when:

a. inoperable fans are powered by separate electrical.

AND

b. Outside wet bulb temperature is

< 76°F.

COMPLETION TIME C.7 C.8 Verify remaining OPERABLE cooling tower fans are capable of being powered by an OPERABLE emergency power source.

AND Restore cooling tower fan configuration such that two inoperable cooling fans are not powered by the same electrical division.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours D.

Three cooling tower fans inoperable.

D.1 AND Verify SX pump discharge temperature

< 9PF.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter BYRON - UNITS 1 &2 3.7.9 - 4 Amendment ~

3.7.9 UHS CONDITION REQU IRED ACTI ON COMPLETION TIME 0.2 AND D.3 D.4 D.5 Verify rema-jning OPERABLE cooling tower fans are capable of being powered by an OPERABLE emergency power source.

Restore one cooling tower fan to operable status when SX pump discharge temperature isS 84°F.

OR Restore two cooling tower fans to operable status when SX pump discharge temperature is > 84°F and S 91°F.

OR Restore three cool-j ng tower fan to operable status when SX pump discharge temperature is > 9PF.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 72 hours E.

SX pump discharge temperature> 96°F.

E.l AND E.2 Be in MODE 3.

Be in Mode 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours F.

One or more bas"j n level(s) < 60%.

F.l Restore both basin levels to ~ 60%.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (contlnued)

BYRON UNITS 1 &2 3.7.9 - 5 Amendment -+/-Ge

ACTIONS (continued)

CONDITION REQU IRED ACTI ON COtvlPLETION TIME G.

One Essential Service Water (SX) makeup pump inoperable.

G.1 AND G.2 AND G.3 Verify basin level for each tower is 2 90%.

Verify OPERABI LITY of associated makeup source.

Restore SX makeup pump to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 2 hours thereafter 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 7 days if both units are in MODE 1, 2, 3, or 4

AND 14 days if one unit is in MODE 5, 6 or defueled (continued)

BYRON - UNITS 1 &2 3.7.9 6

Amendment +/-4-+/-

ACTIONS (conti nued)

CONDITION REQUIRED ACTION COMPLETION TIME H.

Two SX makeup pumps inoperable.

H.l AND H.2 AND H.3 Verify basin level for each tower is

~ 90%.

Verify OPERABILITY of at least one makeup source.

Verify OPERABILITY of second makeup source.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours I. Rock River water level

~ 670.6 ft Mean Sea Leve1 (MSl).

I.l Verify Rock River water level is

> 664.7 ft MSL and flow ~ 700 cubic feet per second (cfs).

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Hill 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter (contlnued)

BYRON - UNITS 1 &2 3.7.9 - 7 Amendment -+/-4+/-

ACTIONS (continued)

CONDITION REQU IRED ACTI ON COMPLETION TIME J. Required Action I not met.

OR Rock River water level forecast to exceed 702.0 ft MSL by the National Weather Service (NWS).

OR Tornado Watch issued by the NWS that includes the Byron site.

J.l AND J.2 AND J.3 Verify basin level for each tower is

~ 90%.

Verify OPERABILITY of at least one deep well pump.

Verify OPERABILITY of both deep well pumps.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months thereafter 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours K.

Required Action and associated Completion Time of Condition A, B, C, D, F, G, H, or K not met.

OR UHS inoperable for reasons other than Condition A, B, C, D, F, G, H, or K.

K.l AND K.2 Be in MODE 3.

Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours BYRON UNITS 1 & 2 3.7.9 - 8 Amendment +/-4+/-

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.9.1 Verify water level basin is ;::: 60%.

-j n each cool i ng tower 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.7.9.2

NOTE - - -

OPERABLE cooling tower fans must be operating in high speed when SX pump discharge temperature is > 82°F.

Verify essential service water pump discharge water temperature is < 96°F with 8 OPERABLE cooling tower fans.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.7.9.3 Verify river water level and ~ 702.0 ft MSL.

is > 670.6 ft MSL 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.7.9.4 Operate each required cooling tower fan high speed for;::: 15 minutes.

on 31 days SR 3.7.9.5 Verify each SX makeup manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in the open position, is in the correct position.

31 days SR 3.7.9.6 Verify that each SX makeup pump starts on a simulated or actual low basin level signal and operates for;::: 30 minutes.

31 days (contlnued)

BYRON UNITS 1 &2 3.7.9 9

Amendment -+/-Ga

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.9.7 Verify each diesel driven SX makeup pump fuel oil day tank level ~ 47%.

31 days SR 3.7.9.8 Cycle each testable valve in the SX makeup pump flow path through at least one complete cycle of full travel.

18 months SR 3.7.9.9 Verify fuel oil properties are tested in accordance with and maintained within the limits of the Diesel Fuel on Testing Program.

In accordance with the Diesel Fuel Oi 1 Testing Program BYRON UN ITS 1 & 2 3.7.9 - 10 Amendment.we

PKG ML110620156 Meeting Notice ML 10450566 Meeting Summary and Handouts ML110620148 OFFICE LPL3-2/PM LPL3-2/LA LPL3-2/BC LPL3-2/PM NAME NDiFrancesco SRohrer RCarlson NDiFrancesco DATE 13/02/11 3/03111 3/10/11 3/10/11

v t e Letter Sequence RAI
TAC:ME1669, (Approved, Closed) TAC:ME1670, (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request Acceptance... Supplement Administration Meeting Questions 16 December 2010 11 December 2009 18 May 2010 18 August 2010 2 November 2010 28 December 2010 14 February 2011 10 March 2011 Answers 31 January 2011 Results Approval, Approval Other:
MONTHYEAR2010-05-18 [Table View]

ML110620148

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