ML23264A799

NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC Fleet Request License Amendment Request to Adopt TSTF-580, Revision 1

ML23264A799
Person / Time
Site:	Dresden, Peach Bottom, Nine Mile Point, Clinton, Quad Cities, FitzPatrick, LaSalle
Issue date:	09/21/2023
From:	Scott Wall NRC/NRR/DORL/LPL3
To:	Mathews M Constellation Energy Generation
Wall S
References
L-2023-LLA-0077
Download: ML23264A799 (4)

Text

From: Scott Wall Sent: Thursday, September 21, 2023 2:39 PM To: Mathews, Mitchel A:(Constellation Nuclear)

Cc: Simpson, Patrick R.:(Exelon Nuclear); Steinman, Rebecca L:(Exelon Nuclear)

Subject:

FINAL RAI - Constellation Energy Generation, LLC - Fleet Request - License Amendment Request to Adopt TSTF-580, Revision 1 (EPID No. L-2023-LLA-0077)

Dear Mr. Mathews,

By letter dated May 25, 2023 (Agencywide Documents Access and Management System Accession No. ML23145A086), Constellation Energy Generation, LLC (CEG, the licensee) submitted license amendment requests for Clinton Power Station, Unit 1, Dresden Nuclear Power Station, Units 2 and 3, James A. FitzPatrick Nuclear Power Plant (FitzPatrick), LaSalle County Station, Units 1 and 2, Nine Mile Point Nuclear Station, Unit 2, Peach Bottom Atomic Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2.

The proposed amendments requested adoption of Technical Specifications Task Force (TSTF) Traveler, TSTF-580, Revision 1, Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling. The U.S. Nuclear Regulatory Commission (NRC) issued a final model safety evaluation approving TSTF 580, Revision 1, on July 11, 2021 (ML21188A227).

The NRC staff has reviewed the submittal and determined that additional information is needed to complete its review. The specific question is found in the enclosed request for additional information (RAI). On September 21, 2023, the CEG staff indicated that a response to the RAIs would be provided by October 23, 2023.

If you have questions, please contact me at 301-415-2855 or via e-mail at Scott.Wall@nrc.gov.

Scott P. Wall, LSS BB, BSP Senior Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation 301.415.2855 Scott.Wall@nrc.gov Docket Nos.: 50-461, 50-237, 50-249, 50-333, 50-373, 50-374, 50-410, 50-277, 50-278, 50-254, and 50-265

Enclosure:

Request for Additional Information cc: Listserv RAI (TSTF-580: STSB)

REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-580, REVISION 1 CONSTELLATION ENERGY GENERATION, LLC CLINTON POWER STATION, UNIT NO. 1 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 JAMES A. FITZPATRICK NUCLEAR POWER PLANT LASALLE COUNTY STATION, UNITS 1 AND 2

NINE MILE POINT NUCLEAR STATION, UNIT 2 PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-461, 50-237, 50-249, 50-333, 50-373, 50-374, 50-410, 50-277, 50-278, 50-254, AND 50-265 By letter dated May 25, 2023 (Agencywide Documents Access and Management System Accession No. ML23145A086), Constellation Energy Generation, LLC (CEG, the licensee) submitted license amendment requests for Clinton Power Station, Unit 1, Dresden Nuclear Power Station, Units 2 and 3, James A. FitzPatrick Nuclear Power Plant (FitzPatrick), LaSalle County Station, Units 1 and 2, Nine Mile Point Nuclear Station, Unit 2, Peach Bottom Atomic Power Station, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2.

The proposed amendments requested adoption of Technical Specifications Task Force (TSTF) Traveler, TSTF-580, Revision 1, Provide Exception from Entering Mode 4 With No Operable RHR Shutdown Cooling. The U.S. Nuclear Regulatory Commission (NRC) issued a final model safety evaluation approving TSTF 580, Revision 1, on July 11, 2021 (ML21188A227).

The NRC staff has reviewed the submittal and determined that additional information is needed to complete its review.

Technical Specifications Branch (STSB) Question

Background

TSTF-580 provides a technical specifications (TS) exception to entering Mode 4 if both required residual heat removal (RHR) shutdown cooling subsystems are inoperable. Any TS Required Action directing entry into Mode 4 would be suspended by this proposed change, regardless of whether it is related to RHR shutdown cooling, until at least one RHR shutdown cooling subsystem is restored to operable status. If there is a circumstance that rendered both required low pressure core injection subsystems, both required RHR suppression pool cooling subsystems, or both RHR service water subsystems inoperable but that did not render the RHR shutdown cooling function inoperable, the exception would not apply. The proposed change modifies standard technical specifications (STSs), NUREG-1433, Vol. 1, Rev. 5, Standard Technical Specifications General Electric [Boiling Water Reactor] BWR/4Plants: Specifications (ML21272A357), and NUREG-1434, Vol. 1, Rev. 5, Standard Technical Specifications, General Electric BWR/6 Plants: Specifications (ML21271A582).

Applicable Regulation and Guidance The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(a)(1) requires an applicant for an operating license to include in the application proposed TS in accordance with the requirements of 10 CFR 50.36.

The categories of items required to be in the TS are provided in 10 CFR 50.36(c). As required by 10 CFR 50.36(c)(2)(i), the TS will include limiting condition for operation (LCOs), which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Per 10 CFR 50.36(c)(2)(i), when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the condition can be met.

Request for Additional Information TSTF-580 modifies BWR/4 STS 3.4.8 and BWR/6 STS 3.4.9 as follows:

• Condition A is revised from, "One or two RHR shutdown cooling subsystems inoperable," to "One [required] RHR shutdown cooling subsystems inoperable."

• Condition B, "Required Action and associated Completion Time of Condition A not met," is revised to be applicable to a single inoperable RHR shutdown cooling subsystem.

• A new Condition C is added which is applicable when two [required] RHR shutdown cooling subsystems are inoperable.

• A new Condition D, "Required Action and associated Completion Time of Condition C not met," is added.

• Current Condition C and associated Required Actions C.1, C.2, and C.3 are renumbered as Condition E Required Actions E.1, E.2, and E.3 with no other changes as specified below:

CONDITION REQUIRED ACTION COMPLETION TIME E. No RHR shutdown cooling E.1 Initiate action to restore Immediately subsystem in operation. one RHR shutdown cooling subsystem or one AND recirculation pump to operation.

No recirculation pump in

operation. AND 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> from discovery of no E.2 Verify reactor coolant reactor coolant circulation circulation by an alternate method. AND AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter E.3 Monitor reactor coolant Once per hour temperature and pressure.

NUREG-1433, Vol. 2, Rev. 5, Standard Technical Specifications General Electric BWR/4 Plants: Bases (ML21272A358) explains the Condition E actions as below:

E.1, E.2, and E.3 With no RHR shutdown cooling subsystem and no recirculation pump in operation, except as permitted by LCO Note 1, reactor coolant circulation by the RHR shutdown cooling subsystem or recirculation pump must be restored without delay.

Until RHR or recirculation pump operation is re-established, an alternate method of reactor coolant circulation must be placed into service. This will provide the necessary circulation for monitoring coolant temperature. The 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Completion Time is based on the coolant circulation function and is modified such that the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> is applicable separately for each occurrence involving a loss of coolant circulation. Furthermore, verification of the functioning of the alternate method must be reconfirmed every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter. This will provide assurance of continued temperature monitoring capability.

During the period when the reactor coolant is being circulated by an alternate method (other than by the required RHR shutdown cooling subsystem or recirculation pump), the reactor coolant temperature and pressure must be periodically monitored to ensure proper function of the alternate method. The once per hour Completion Time is deemed appropriate.

RAI-STSB-01 FitzPatrick TS 3.4.7 does not currently include an equivalent requirement to NUREG-1433, STS 3.4.8 Condition C (re-numbered as Condition E), therefore Condition E is not proposed to be adopted. TSTF-580 allows suspension of LCO 3.0.3 and other LCO Required Actions when no RHR shutdown cooling subsystem is in operation. Part of the technical basis for the approval of TSTF-580 was the inclusion of Condition E which ensures that: 1) one RHR or recirculation pump is restored without delay, and 2) an alternate method of reactor coolant recirculation is established without delay so that coolant temperature can be adequately monitored. In the LAR, CEG stated that it had reviewed the information in TSTF-580 and the model SE and determined that it applied to FitzPatrick. However, FitzPatricks adoption of the TSTF without Condition E as proposed, would leave a deficiency that no requirement to establish heat removal and monitor reactor coolant temperature would be required when no RHR or recirculation pumps is operating.

• Please explain how FitzPatrick meets the technical basis for TSTF-580 without Condition E.

Hearing Identifier: NRR_DRMA Email Number: 2245 Mail Envelope Properties (SA1PR09MB9605991DA2F51B8B8377834D92F8A)

Subject:

FINAL RAI - Constellation Energy Generation, LLC - Fleet Request - License Amendment Request to Adopt TSTF-580, Revision 1 (EPID No. L-2023-LLA-0077)

Sent Date: 9/21/2023 2:38:48 PM Received Date: 9/21/2023 2:38:52 PM From: Scott Wall Created By: Scott.Wall@nrc.gov Recipients:

"Simpson, Patrick R.:(Exelon Nuclear)" <patrick.simpson@exeloncorp.com>

Tracking Status: None "Steinman, Rebecca L:(Exelon Nuclear)" <Rebecca.Steinman@exeloncorp.com>

Tracking Status: None "Mathews, Mitchel A:(Constellation Nuclear)" <Mitchel.Mathews@constellation.com>

Tracking Status: None Post Office: SA1PR09MB9605.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 9592 9/21/2023 2:38:52 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: