Text

Supplemental Information to Request for Additional Information - Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to A....
	ML16026A029
Person / Time
Site:	Nine Mile Point
Issue date:	01/25/2016
From:	David Gudger; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NMP1L3068
	Download: ML16026A029 (13)
	v • d • e

200 Exelon Way Kennett Square, PA 19348 Exelon Generation www.exeloncorp.com 10 CFR 50.90 NMP1L3068 January 25, 2016 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 NRG Docket No. 50-220

Subject:

Supplemental Information to Request for Additional Information - "Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)"

References:

1. Letter from J. Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Response to Request for Additional Information - Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)," dated December 3, 2015.

2. Letter from J. Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Supplemental Response to Request for Additional Information - Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)," dated December 22, 2015.

3. Letter from J. Barstow (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, "Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)," dated May 12, 2015.

By letter dated December 3 and December 22, 2015 (References 1 and 2), Exelon Generation Company, LLC (Exelon) responded to the U.S. Nuclear Regulatory Commission (NRG) Request for Additional Information (RAI). This letter supplements the response to Standard Technical Specifications Branch (STSB) RAI No. 6. Specifically, Exelon will revise

U.S. Nuclear Regulatory Commission Supplement to RAI -Adoption of TSTF-425, Rev. 3 January 25, 2016 Page 2 Note (I) as shown in Technical Specification (TS) page 203 of the December 22 submittal; however, because this Note appears in subsequent TS Pages, all appropriate revised TS pages are included in Attachment 1 to this letter.

Additionally, Attachment 6 of the May 12, 2015 letter (Reference 3) contained the proposed inserts to the License Amendment Request (LAR). INSERT 2 contained a typographical error in 6.5.9 band 6.5.9 c. Specifically, 6.5.9 b should read "Changes to the frequencies ... ,"

and 6.5.9 c should read "The provisions ...." to this letter contains the revised INSERT 2, which replaces and supersedes INSERT 2 of the original letter.

Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference 1. The additional information provided in this response does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration.

Furthermore, the additional information provided in this response does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no commitments contained in this response.

If you should have any questions regarding this submittal, please contact Enrique Villar at 610-765-5736.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 251h day of January 2016.

Respectfully, Du!~u~e;- L JY'="

Manager - Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

1. Revised Technical Specifications Pages

2. Revised Insert 2 cc: USNRC Regional Administrator, Region I w/attachments USNRC Senior Resident Inspector- NMP USNRC Project Manager, NRR - NMP A. L. Peterson, NYSERDA

ATTACHMENT 1 LICENSE AMENDMENT REQUEST RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION DOCKET NO. 50-220 REVISED TECHNICAL SPECIFICATIONS PAGES

NOTES FOR TABLES 3.6.2a and 4.6.2a (a) May be bypassed when necessary for containment inerting.

(b) May be bypassed in the refuel and shutdown positions of the reactor mode switch with a keylock switch.

(c) May be bypassed in the refuel and startup positions of the reactor mode switch when reactor pressure is less than 600 psi, or for the purpose of performing reactor coolant system pressure testing and/or control rod scram time testing with the reactor mode switch in the refuel position.

(d) No more than one of the four IRM inputs to each trip system shall be bypassed.

(e) No more than two C or D level LPRM inputs to an APRM shall be bypassed and only four LPRM inputs to an APRM shall be bypassed in order for the APRM to be considered operable. No more than one of the four APRM inputs to each trip system shall be bypassed provided that the APRM in the other instrument channel in the same core quadrant is not bypassed. A Traversing In-Core Probe (TIP) chamber may be used as a substitute APRM input if the TIP is positioned in close proximity to the failed LPRM it is replacing.

(f) Verify SRM/IRM channels overlap during startup after the mode switch has been placed in startup. Verify IRM/APRM channels overlap at least 1/2 decade during entry into startup from run (normal shutdown) if not performed within the previous 7 days.

(g) Within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months before startup, if not performed within the previous 7 days. Not required to be performed during shutdown until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after entering startup from run.

(h) Each of the four isolation valves has two limit switches. Each limit switch provides input to one of two instrument channels in a single trip system.

(i) May be bypassed when reactor power level is below 45%.

(j) Trip upon loss of oil pressure to the acceleration relay. in accordance with the Surveillance Frequency Control Program (k) May be bypassed when placing the reactor mode switch in the iHUTDOWN position and all control rods are fully inserted.

(I) ~the trip circuit will be calibrated and tested aHhe frequencies s~eified in Table 4-:6:2a, the primary sensor will be calibrated and tested enee-per operatffi§-eyeli.----__ I in accordance with the Surveillance Frequency Control Program (m) This calibration shall consist of the adjustment of the APRM channel to conform to the power values calculated by a heat balance during reactor operation when THERMAL POWER 2: 25% of RATED THERMAL POWER. Adjust the APRM channel if the difference is greater than +2.0/-1.9% of RATED THERMAL POWER. Any APRM channel gain adjustment made in compliance with Specification 2.1.2a shall not be included in determining the difference.

(n) Neutron detectors are excluded.

AMENDMENT NO. ~ +4J, ~+es,. 186 203

NOTES FOR TABLES 3.6.2b and 4.6.2b (a) May be bypassed in the refuel and startup positions of the reactor mode switch when reactor pressure is less than 600 psi.

(b) May be bypassed when necessary for containment inerting. in accordance with the Surveillance Frequency Control Program (c) May be bypassed in the shutdown mode whenever t!>e'reactor coolant system temperature is less than 215°F.

(d) GAly the trip circuit will be calibrated and tested at the frequencies specified in Table 4.6.2b, the primary sensor will be calibrated and tested nnr.r nrr nnrmtinn mmlr (e) Deleted. in accordance with the Surveillance Frequency Control Program (f) A channel may be placed in an inoperable status for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for required surveillances without placing the Trip System in the tripped condition provided at least one Operable Instrument Channel in the same Trip System is monitoring that Parameter.

With the number of Operable Channels one less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System requirement for one trip system, either

1. Place the inoperable channel(s) in the tripped condition within

a. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Parameters common to SCRAM Instrumentation, and

b. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Parameters not common to SCRAM Instrumentation.

or

2. Take the ACTION required by Specification 3.6.2a for that Parameter.

With the number of Operable Channels one less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System requirement for both trip systems,

1. Place the inoperable channel(s) in one trip system in the tripped condition within one hour.

and

2. a. Place the inoperable channel(s) in the remaining trip system in the tripped condition within (1) 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Parameters common to SCRAM Instrumentation, and (2) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Parameters not common to SCRAM Instrumentation.

or

b. take the ACTION required by Specification 3.6.2a for that Parameter.

A MENDMENT NO. 142 212

NOTES FOR TABLES 3.6.2c AND 4.6.2c (a) Each of two differential pressure switches provide inputs to one instrument channel in each trip system.

....-~~~~~~~~~~~~~~~~~~~~~~~~~

in accordance with the Surveillance Frequency Control Program (b) May be bypassed in the cold shutdown condition.

(c} 8ftly-the trip circuit will be calibrated and tested at-tt-te-frettuencies speeifled in Table 4.6.2e, the primary sensor will be calibrated and tested once peF

in accordance with the Surveillance Frequency Control Program (d) A channel may be placed in an inoperable status for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for required surveillances without placing the Trip System in the tripped condition provided at least one Operable Instrument Channel in the same Trip System is monitoring that parameter.

(e) With the number of Operable channels less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System requirement:

1. For one channel inoperable, place the inoperable channel in the tripped condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or take the action required by Specification 3.6.2a for that Parameter.

2. With more than one channel inoperable, take the ACTION required by Specification 3.6.2a for that Parameter.

(f) With the number of Operable channels one less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System requirement for one trip system, either

1. Place the inoperable channel(s) in the tripped condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

or

2. Take the ACTION required by Specification 3.6.2a for that Parameter.

With the number of Operable channels one less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System requirement for both trip systems,

1. Place the inoperable channel(s) in one trip system in the tripped condition within one hour and

2. a. Place the inoperable channel(s) in the remaining trip system in the tripped condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

or

b. Take the ACTION required by Specification 3.6.2a for that Parameter.

~Note 1: Surveillance intervals are specified in the Surveillance Frequency Control Program unless otherwise noted in Table 4.6.2c.

AMENDMENT NO. 142 216

NOTES FOR TABLES 3.6.2d AND 4.6.2d (a) May be bypassed when necessary for containment inerting.

in accordance with the Surveillance Frequency Control Program (b) May be bypassed when necessary for performing major mainte¢ance as specified in Specification 2.1.1.e.

(c) 8ftly the trip circuit will be calibrated and tested at the frequencies spcetfied in Table 4.6.2d, the primary sensor will be calibrated and tested once oer ooeratina cvcl&. I in accordance with the Surveillance Frequency Control Program (d) May be bypassed when necessary for integrated leak rate testing.

(e) The instrumentation that initiates the Core Spray System is not required to be operable, if there is no fuel in the reactor vessel.

(f) A channel may be placed in an inoperable status for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for required surveillances without placing the Trip System in the tripped condition provided at least one Operable Instrument Channel in the same Trip System is monitoring that parameter.

With the number of Operable channels less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System requirement:

1. With one channel inoperable, place the inoperable channel in the tripped condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or take the ACTION required by Specification 3.6.2a for that Parameter.

2. With more than one channel inoperable, take the ACTION required by Specification 3.6.2a for that Parameter.

Note 1: Surveillance intervals are specified in the Surveillance Frequency Control Program unless otherwise noted in Table 4.6.2d.

AMENDMENT NO. 142 219

in accordance with the Surveillance Frequency Control Program 3.6.2e AND 4.6.2e (a) May be bypassed in the shutdown mode whenever the reactor co¢1ant temperature is less than 215°F.

(b) eFtty the trip circuit will be calibrated and tested at-tfle-ffequencies s~ee-m--:Faele 4.6.2e, the primary sensor will be calibrated and tested onee per o~ng-eyele. I in accordance with the Surveillance Frequency Control Program I (c) A channel may be placed in an inoperable status for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for required suiveillances without placing the Trip system in the tripped condition provided at least one Operable Instrument Channel in the same Trip System is monitoring that parameter.

With the number of Operable channels less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System requirement:

1. With one channel inoperable, place the inoperable channel in the tripped condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or take the ACTION required by Specification 3.6.2a for that Parameter.

2. With more than one channel inoperable, take the ACTION required by Specification 3.6.2a for that Parameter.

Note 1: Surveillance intervals are specified in the Surveillance Frequency Control Program unless otherwise noted in Table 4.6.2e.

A MENDMENT NO. 142 222

NOTES FOR TABLES 3.6.2f AND 4.6.2f (a) Both instrument channels in either trip system are required to be energized to initiate auto depressurization. One trip system is powered from power board 102 and the other trip system from power board 103.

(b) May be bypassed when the reactor pressure is less than 11 O psig and the reactor coolant temperature is less than the corresponding saturation temperature. __J in accordance with the Surveillance Frequency Control Program (c) GAfy the trip circuit will be calibrated and tested aHRe freqtieneies-spceified in Table 4.6.2f, the primary sensor will be calibrated and tested once per operatin~. I in accordance with the Surveillance Frequency Control Program I (d) A channel may be placed in an inoperable status for up to 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months for required surveillances without placing the Trip System in the tripped condition provided at least one operable channel in the same Trip System is monitoring that parameter.

With the number of Operable channels less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System requirement:

1. With one channel inoperable, place the inoperable channel in the tripped condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or take the ACTION required by Specification 3.6.2a for that Parameter.

2. With more than one channel inoperable, take the ACTION required by Specification 3.6.2a for that Parameter.

.L.----1Note 1: Surveillance intervals are specified in the Surveillance Frequency Control Program unless otherwise noted in Table 4.6.2f.

AMENDMENT NO. 142 225

NOTES FOR TABLES 3.6.2k AND 4.6.2k (a) May be bypassed when the reactor pressure is less than 110 psig and the reactor coolant temperature is less than the corresponding saturation temperature. ..--J in accordance with the Surveillance Frequency Control Program I (b) 9A4y the trip circuit will be calibrated and tested at the frequencies specified in Table 4.6.21<, the primary sensor will be calibrated and tested eooe-~iA yefe. . d *h h S

F

--;;..._---l rn accor ance wit t e urve1llance requency antral Program c

(c) A channel may be placed in an inoperable s a us or up o ours or require surve1 ances w1 ou pacing e np System in the tripped condition provided at least one operable channel in the same Trip System is monitoring that parameter.

With the number of Operable channels less than required by the Minimum Number of Operable Instrument Channels per Operable Trip System requirement:

1. For one channel inoperable, place the inoperable channel in the tripped condition within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months or take the ACTION required by Specification 3.6.2a for that Parameter.

2. With more than one channel inoperable, take the ACTION required by Specification 3.6.2a for that Parameter.

.(; !Note 1: Surveillance intervals are specified in the Surveillance Frequency Control Program unless otherwise noted in Table 4.6.2k AMENDMENT NO. 142 245

NOTES FOR TABLES 3.6.21 AND 4.6.21 (a) May be bypassed when necessary for containment inerting. in accordance with the Surveillance Frequency Control Program (b) Gflly-the trip circuit will be calibrated and tested aHfle-fr-eqtteAeies specified; the primary sensor will be calibrated and tested eAee-J3ef--6Pefa ~ in accordance with the Surveillance Frequency Control Program (c) May be bypassed in the cod shutdown condition.

~Note 1: Surveillance intervals are specified in the Surveillance Frequency Control Program unlessothe-rWise noted in Table 4.6.21 I AMENDMENT NO. 464-, 194 247a

ATTACHMENT 2 LICENSE AMENDMENT REQUEST RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION DOCKET NO. 50-220 REVISED INSERT 2

INSERT2 6.5.9 Surveillance Frequency Control program This program provides controls for the Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a. The Surveillance Frequency Control Program shall contain a list of Frequencies of the Surveillance Requirements for which the Frequency is controlled by the program.

b. Changes to the Frequencies listed in the Surveillance Frequency Controlled Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequency," Revision 1.

c. The provisions of Surveillance Requirement 4.0.2 and 4.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.