RS-18-078, Supplemental Information Related to Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control

Supplemental Information Related to Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control

ML18169A401
Person / Time
Site:	LaSalle
Issue date:	06/18/2018
From:	Simpson P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2017-LLA-0415, RS-18-078
Download: ML18169A401 (11)

Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-18-07810 CFR 50.90 June 18, 2018U.S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D.C. 20555-0001LaSalle CountyStation, Units1and 2Renewed Facility Operating License Nos. NPF-11 and NPF-18NRC Docket Nos. 50-373 and 50-374

Subject:

Supplemental Information Related to Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control"

References:

1.Letter from P. R. Simpson (Exelon Generation Company, LLC (EGC)) to NRC, "Application to Revise Technical Specifications to Adopt TSTF-542, 'Reactor Pressure Vessel Water Inventory Control,'" dated December 13, 20172.Email from B. K. Vaidya(NRC) to D. M. Gullott (EGC), "LaSalle Units 1 and 2, EPID-L-2017-LLA-0415 --Request for Additional Information (RAIs) -License Amendment Request (LAR) to Adopt TSTF-542," dated June 12, 2018InReference 1, EGCsubmitteda request for amendmentsto the Technical Specifications (TS) for LaSalle CountyStation(LSCS), Units1and2.In Reference 2, the NRC determined that additional information was required to complete itsevaluation of the Reference1 request. The requested informationis provided in Attachment 1.Additionally,in Reference 2, the NRC identified two typographical issues associated with the Technical Specifications(TS)changes provided in Reference 1. The identified issues are addressed through the resubmission of the affectedTS markups and revised pages in Attachments 2 and 3, respectively.EGC has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Reference 1.The additional information provided in this submittal does not affect the bases for concluding that the proposed license amendmentsdo not involve a significant hazards consideration. In addition, the information provided in this submittal 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 amendments.

LaSalle County Station, Units 1 and 2Renewed Facility Operating License Nos. NPF-11 and NPF-18NRC Docket Nos.50-373 and 50-374ATTACHMENT1SUPPLEMENTAL INFORMATION RELATED TO APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-542, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" ATTACHMENT 1 -SUPPLEMENTAL INFORMATION RELATED TO APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-542, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL"Page 1of 2REQUEST FOR ADDITIONAL INFORMATIONAPPLICATION TO REVISE TECHNICAL SPECIFICATION TO ADOPT TSTF-542REVISION 2, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL"EXELON GENERATION COMPANY (LLC)LASALLE COUNTY STATION (DOCKET NOS. 50-373 and 50-374) (EPID: L-2017-LLA-0415)By application dated December 13, 2017 (Agencywide Documents Access and Management System Accession No. ML ML17360A159), Exelon Generation Company, LLC (EGC), requests an amendment to Renewed Facility Operating License Nos. NPF-11 and NPF-18 for LaSalle County Station (LSCS), Units 1 and 2, respectively.

The proposed changes modify Technical Specifications (TSs) to adopt TSTF-542.The NRC staff has determined that a request for additional information (RAI) is necessary to complete its review regarding the requested amendment.EICB-RAI-1

Background:

In Attachment 2 of the LAR, on page 3.3.5.2-3, proposed LSCS TS Table 3.3.5.2-1, Function1.a, "Low Pressure Coolant Injection-A (LPCI) and Low PressureCore Spray (LPCS) Subsystems, and Function 2.a, "LPCI-B and LPCI-C Subsystem,"Reactor Steam Dome Pressure -Low (Injection Permissive)," are not consistent with TSTF-542.For Modes 4 and 5, the equivalent function in TSTF-542 standard technical specifications (STS) Table 3.3.5.2-1 retains the same requirement for channels per function (three) as found in STS Table 3.3.5.1-1.However, LSCS proposed to reduce the channels per function from two in current LSCS TS table 3.3.5.1-1 (Functions 1.d and 2.d) to one in proposed Table 3.3.5.2-1.This difference was not identified as a variation in Section 2.2 of Attachment 1 of the LAR.Question: Please provide technical justification for the proposed required channels per function for Functions 1.a and 2.a in LSCS TS Table 3.3.5.2-1.Exelon Generation Company, LLC (EGC)ResponseIn Attachment 2 of EGC's December 13, 2017, request to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-542, EGC indicated in the proposed LaSalle County Station (LSCS),Units 1 and 2 Technical Specifications (TS), that for Table 3.3.5.2-1 Functions 1.a and 2.a, "Reactor Steam Dome Pressure Low (Injection Permissive)," only one channelis needed. This applied to the required Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core Spray (LPCS) Subsystems, andrequiredLPCI B and LPCI C Subsystems, respectively. This proposal is related to bracketed values in the markup of the Standard Technical Specifications pages provided in TSTF-542; therefore, EGC did not initially consider this a variation. However, ATTACHMENT 1 -SUPPLEMENTAL INFORMATION RELATED TO APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-542, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL"Page 2of 2the following explanation provides additional clarity to aid the NRC in its review of the EGC proposal. Specifically, the instruments associated with TS Table 3.3.5.2-1, Functions 1.a and 2.a are installed in a parallel configuration, so only one of the two channels for these functions is required to satisfy the logic and provide the permissive for the associated subsystem. Moreover, if the required channel is found to be inoperable, Limiting Condition for Operation 3.3.5.2, "RPV Water Inventory Control Instrumentation," Condition C applies. Required Action C.1, requires the channel to be placed in trip within one hour, which will allow manual operation of the associated subsystem.Therefore, for manual operation of a required subsystems in Modes 4 and 5 as proposed, only one instrument channel is needed for Table 3.3.5.2-1, Functions 1.a and 2.a.Additional Corrections:The NRC staff noted that the following corrections are needed to the TS Mark-up Pages submitted in the Application:1.Attachment 2 of the License Amendment Request (LAR), markup page 3.5.2-1, Required Action B.1As proposed: B.1 Initiate action to establish a method of water injection capable of operating without offsite power.'Electrical'is missing between offsite and power2.Attachment 2 of the LAR, markup page 3.5.2-2, Condition C is missing period.EGC ResponseUpdated TS Page Changes (i.e., markups) and the corresponding revised TS Pages (i.e., clean pages) that address the identified issues have been included as Attachments 2 and 3, respectively.

LaSalle County Station, Units 1 and 2Supplemental Information Related to Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water InventoryControl"ATTACHMENT 2REVISED TECHNICAL SPECIFICATIONS PAGECHANGES(MARK-UPS)3.5.2-13.5.2-2 RPV Water Inventory ControlECCS-Shutdown 3.5.2 LaSalle 1 and 2 3.5.2-1 Amendment No.

147/133 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)

WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC)

SYSTEM 3.5.2 RPV Water Inventory ControlECCS-Shutdown

LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active

fuel (TAF) shall be hours AND One Two ECCS injection/spray subsystem s shall be OPERABLE.

---

NOTE----------------------------

One A L l ow P p ressure C c oolant I i njection (LPCI) subsystem may be considered OPERABLE during alignment and operation

for decay heat removal, if capable of being manually

realigned and not otherwise inoperable.

---

APPLICABILITY: MODE S 4 and , MODE 5 except with the spent fuel storage pool gates removed and water level 22 ft over the top of the reactor pressure vessel flange

.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One r R equired ECCS injection/spray subsystem inoperable.

A.1 Restore required ECCS injection/spray subsystem to OPERABLE

status. 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B. Required Action and associated Completion Time of Condition A

not met. B.1 Initiate action to suspend operations with a potential for draining the reactor vessel (OPDRVs)establish a method of water injection capable of

operating without offsite electrical power. Immediately (continued)

RPV Water Inventory ControlECCS-Shutdown 3.5.2 LaSalle 1 and 2 3.5.2-2 Amendment No.

147/133 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two required ECCS injection/spray subsystems inoperable.

C.1 Initiate action to suspend OPDRVs.

AND C.2 Restore one required ECCS injection/spray subsystem to OPERABLE status.

Immediately

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> C DRAIN TIME hours and hours C Verify secondary containment boundary is capable of being

established in less than the DRAIN TIME AND C Verify each secondary containment

penetration flow path

is capable of being

isolated in less than

the DRAIN TIME AND C Verify one standby gas treatment

subsystem is capable of being placed in operation in less

than the DRAIN TIME 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (continued)

LaSalle County Station, Units 1 and 2Supplemental Information Related to Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control"ATTACHMENT 3REVISED TECHNICAL SPECIFICATIONS PAGES3.5.2-13.5.2-2 RPV Water Inventory Control 3.5.2 LaSalle 1 and 2 3.5.2-1 Amendment No.

147/133 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV) WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC)

SYSTEM 3.5.2 RPV Water Inventory Control

LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be AND One ECCS injection/spray subsystem shall be OPERABLE.

---

NOTE----------------------------

A Low Pressure Coolant Injection (LPCI) subsystem may be considered OPERABLE during alignment and operation for decay heat removal, if capable of being manually realigned and not

otherwise inoperable.

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APPLICABILITY: MODES 4 and 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS injection/spray subsystem inoperable.

A.1 Restore required ECCS injection/spray subsystem to OPERABLE status.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> B. Required Action and associated Completion Time of Condition A

not met.

B.1 Initiate action to establish a method of

water injection

capable of operating without offsite

electrical power.

Immediately (continued)

RPV Water Inventory Control 3.5.2 LaSalle 1 and 2 3.5.2-2 Amendment No.

147/133 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME .

C.1 Verify secondary containment boundary

is capable of being

established in less

than the DRAIN TIME.

AND C.2 Verify each secondary containment

penetration flow path is capable of being isolated in less than

the DRAIN TIME.

AND C.3 Verify one standby gas treatment

subsystem is capable

of being placed in

operation in less

than the DRAIN TIME.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> (continued)