RS-19-038, Supplement to the Application to Adopt TSTF-564, Safety Limit MCPR

Supplement to the Application to Adopt TSTF-564, Safety Limit MCPR

ML19066A162
Person / Time
Site:	FitzPatrick
Issue date:	03/07/2019
From:	Gullott D Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-19-038, TSTF-564
Download: ML19066A162 (7)

Text

4300 Winfield Road Warrenville, IL 60555 Exelon Generation 630 65 7 2000 Office RS-19-038 10 CFR 50 .90 March 7, 2019 U.S . Nuclear Regulatory Commission ATTN: Document Control Desk Washington , D.C. 20555-0001 James A. FitzPatrick Nuclear Power Plant, Unit 1 Renewed Facility Operating License No. DPR-59 Docket No. 50-333

Subject:

Supplement to the Application to Adopt TSTF-564, "Safety Limit MCPR" Reference : Application to Adopt TSTF-564, "Safety Limit MCPR" (RS-19-002), dated February 1, 2019 By letter dated February 1, 2019, (Reference 1), Exelon Generation Company, LLC, (EGC) submitted a License Amendment Request (LAR) for several Exelon sites including James A.

FitzPatrick Nuclear Power Plant (JAF), Unit 1. The submittal requesting changes to the Technical Specifications (TS) requirements related to Safety Limit Minimum Critical Power Ratio (SLMCRP) with new requirements which reduce the need for cycle specific changes to the value while still meeting the regulatory requirement of the SL. The requested TS changes were submitted based on Technical Specifications Task Force (TSTF) Traveler TSTF-564 Revision 2.

"Safety Limit MCPR."

Following the submittal , EGC identified that the referenced analysis methodologies used for determining the Safety Limits (including MCPR) required updating. This supplement is submitted to remove the analysis methodologies which are no longer required to be documented in TS 5.6.5.b. These methodologies were not referenced nor credited in the initial supplement and therefor do not change any of the conclusions or bases of the submittal. The revised TS Markup is provided in attachment 1 to this supplement. The revised (clean) TS page is provided in attachment 2.

The two references are being deleted as they do not provide additional methodologies beyond the remaining Topical Report, NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel (GESTAR II)" as updated and supplemented . Specifically, NEDC-3131 ?P, "James A. FitzPatrick Nuclear Power Plant SAFER/GESTAR-LOCA Loss of Coolant Accident Analysis" is a historical analysis and not a methodology as stated. Additionally, NED0-31960-A, "BWR Owners' Group Long Term Stability Solutions Licensing Methodology" has been incorporated into NEDE-24011-P-A, "General Electric Standard Application for Reactor Fuel (GESTAR II)" by the U.S. Supplement. The remaining document, NEDE-24011-P-A, as revised and supplemented, provides the complete methodology for determining JAF core operating limits as stated in TS 5.6.5. b. For clarity, the remaining methodology is being annotated to specifically identify the U.S. Supplement as part of the approved GESTAR methodology. JAF core

March 7, 2019 U.S. Nuclear Regulatory Commission Page2 operating limits are determined using the remaining NRC approved methodology and therefore this change is administrative only.

The proposed changes have been reviewed and recommended for approval by the affected Plant Operations Review Committees in accordance with the EGC Quality Assurance Program.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State Officials.

There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Christian Williams at (61 O) 765-5729.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 7th day of March 2019.

Respectfully, David M. Gullatt Director - Licensing Exelon Generation Company, LLC Attachments: 1. Proposed Technical Specifications Change

2. Revised Technical Specifications Page

cc: NRC Regional Administrator, Region I NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Project Managers - NRR (JAF and Fleet)

A. L. Peterson, NYSERDA

ATTACHMENT 1 Proposed Technical Specifications Change

Reporting Requirements 5.6 5.6 Reporting Requirements (continued)

5. 6.4 Not Used

5. 6.5 CORE OPERATING LIMITS REPORT (COLR)

a. Core operating limits shall be established prior to each reload cycle , or prior to any remaining portion of a reload cycle , and shall be documented in the COLR for the following :

1. The AVERAGE PLANAR LINEAR HEAT GENERATION RATE (APLHGR) of Specification 3 . 2 . 1 ;

2. The MINIMUM CRITICAL POWER RATIO (MCPR) , and MCPR (99.9%)

of Specification 3 . 2 . 2 ;

3. The LINEAR HEAT GENERATION RATE (LHGR ) of Specification 3.2 . 3 ;

4. The Reactor Protection System (RPS ) APRM Neutron Flux -

High (Flow Biased ) Function Allowable Value of Table 3.3.1.1 *1 ;

5. The Rod Block Monitor - Upscale Function Allowable Value of Table 3 . 3 . 2 . 1 - 1 ; and

6. The Power/Flow Exclusion Region of Specification 3 . 4 . 1 .

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC , specifically those described in the following document :

1. NEDE - 24011 - P~A , ~General Electric Standard Application for Reactor Fuel (GESTAR II) " and the US Supplement ,

NEDE - 24011 - P- A- US7

2. NEDC 3 1317P, James A. FitzPatriek Nuelear Power Plant SAFER/GESTR LOCA Loso of Coolant Aeeident Analysis: and

3. NEDO 31960 A, BWR Owners ' Group Long Term Stability Solutions Lieenoing Methodology.

(continued)

JAFNPP 5 . 6- 2 Amendment ~

ATTACHMENT 2 Revised Technical Specifications Page

Reporting Requirements 5.6 5.6 Reporting Requirements (cont i nued )

5. 6.4 Not Used

5. 6.5 CORE OPERATING LIMITS REPORT (COLR )

a. Core operating limits shall be established prior to each reload cycle , or prior to any remaining portion of a re l oad cyc l e , and shall be documented in the COLR for the fo ll owing :

1. The AVERAGE PLANAR LI NEAR HEAT GENERAT I ON RATE (APLHGR )

of Specification 3 . 2 . 1 ;

2. The MINIMUM CRITICAL POWER RATIO (MCPR ), and MCPR (99 . 9%)

of Specification 3 . 2 . 2 ;

3. The LINEAR HEAT GENERATION RATE (LHGR ) of Specification 3 . 2 . 3 ;

4. The Reactor Protection System (RPS ) APRM Neutron Flux -

High (Flow Biased ) Function Allowable Value of Table 3.3 . 1.1 *1 ;

5. The Rod Block Monitor - Upscale Function Allowable Va l ue of Table 3 . 3 . 2 . 1 - 1 ; and

6. The Power/Flow Exclusion Region of Specification 3 . 4 . 1 .

b. The analytical methods used to determine the core operating limits shall be those previously reviewed and approved by the NRC , specifica l ly those described in the following document :

1. NEDE - 24011 - P- A, "General Electric Standard Application for Reactor Fuel (GESTAR II )" and the US Supplement ,

NEDE - 24011 - P- A- US The COLR will contain the complete identification for each of the Technica l Specification referenced topical reports used to prepare the COLR (i . e ., report number , title ,

revision , date , and any supp l ements ) .

(continued )

JAFNPP 5 . 6- 2 Amendment