ML071690299

License Amendments, Issuance of Amendments Primary Containment Isolation Instrumentation

ML071690299
Person / Time
Site:	LaSalle
Issue date:	06/29/2007
From:	Sands S NRC/NRR/ADRO/DORL/LPLIII-2
To:	Crane C Exelon Generation Co
Sands S,NRR/DORL, 415-3154
Shared Package
ML071690253	List: ML071690299 ML071830450
References
TAC MD0540, TAC MD0541
Download: ML071690299 (18)

Text

June 29, 2007Mr. Christopher M. CranePresident and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2, ISSUANCE OF AMENDMENTSRE: PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION (TAC NOS.

MD0540 AND MD0541)

Dear Mr. Crane:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosedAmendment No. 182 to Facility Operating License No. NPF-11 and Amendment No. 169 to Facility Operating License No. NPF-18 for the LaSalle County Station, Units 1 and 2, respectively. The amendments are in response to your application dated March 16, 2006, as supplemented by letter dated April 6, 2007.The amendments revise the allowable values for four reactor core isolation cooling leakdetection functions in Technical Specification Table 3.3.6.1-1, "Primary Containment Isolation Instrumentation."A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in theCommission's biweekly Federal Register notice. Sincerely,/RA/Stephen P. Sands, Project ManagerPlant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-373 and 50-374

Enclosures:

1. Amendment No. 182 to NPF-11

2. Amendment No. 169 to NPF-18

3. Safety Evaluationcc w/encls: See next page June 29, 2007Mr. Christopher M. CranePresident and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2, ISSUANCE OF AMENDMENTSRE: PRIMARY CONTAINMENT ISOLATION INSTRUMENTATION (TAC NOS.

MD0540 AND MD0541)

Dear Mr. Crane:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosedAmendment No. 182 to Facility Operating License No. NPF-11 and Amendment No. 169 to Facility Operating License No. NPF-18 for the LaSalle County Station, Units 1 and 2, respectively. The amendments are in response to your application dated March 16, 2006, as supplemented by letter dated April 6, 2007.The amendments revise the allowable values for four reactor core isolation cooling leakdetection functions in Technical Specification Table 3.3.6.1-1, "Primary Containment Isolation Instrumentation."A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in theCommission's biweekly Federal Register notice. Sincerely,/RA/Stephen P. Sands, Project ManagerPlant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket Nos. 50-373 and 50-374

Enclosures:

1. Amendment No.182 to NPF-11

2. Amendment No.169 to NPF-18

3. Safety Evaluationcc w/encls: See next pageDISTRIBUTION

PUBLICLPL3-2 R/FRidsNrrPMSSandsRidsOgcRp GHill (4)RidsNrrDirsItsbRidsAcrsAcnwMailCenterRidsRgn3MailCenter RidsNrrLAEWhittRidsNrrDorlDprRidsNrrDorlLpl3-2RidsNrrDeEicb Package: ML071690253 Amendment: ML071690299TS Pages: ML*See SE datedOFFICELPL3-2/PMLPL3-2/LADIRS/ITSBDE/EICBOGCLPL3-2/BCNAMESSandsEWhittTKobetzWKemperNiqbal signed for Kemper**RGibbsDATE06/26/0706/12/07 05/17/0705/17/0706/29/0706/29/07OFFICIAL RECORD COPY LaSalle County Station, Units 1 and 2 cc:

Site Vice President - LaSalle County StationExelon Generation Company, LLC 2601 North 21st Road Marseilles, IL 61341-9757Plant Manager - LaSalle County StationExelon Generation Company, LLC 2601 North 21st Road Marseilles, IL 61341-9757Manager Regulatory Assurance - LaSalleExelon Generation Company, LLC 2601 North 21st Road Marseilles, IL 61341-9757U.S. Nuclear Regulatory CommissionLaSalle Resident Inspectors Office 2605 North 21st Road Marseilles, IL 61341-9756Phillip P. Steptoe, EsquireSidley and Austin One First National Plaza Chicago, IL 60603Assistant Attorney General100 W. Randolph St. Suite 12 Chicago, IL 60601ChairmanLaSalle County Board 707 Etna Road Ottawa, IL 61350Attorney General500 S. Second Street Springfield, IL 62701ChairmanIllinois Commerce Commission 527 E. Capitol Avenue, Leland Building Springfield, IL 62706Robert Cushing, Chief, Public Utilities DivisionIllinois Attorney General's Office 100 W. Randolph Street Chicago, IL 60601Regional Administrator, Region IIIU.S. Nuclear Regulatory Commission2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352Illinois Emergency Management Agency Division of Disaster Assistance &

Preparedness 1035 Outer Park Dr Springfield, IL 62704Document Control Desk - LicensingExelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555Senior Vice President - Operations SupportExelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555Director - Licensing and Regulatory AffairsExelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555Vice President - Regulatory AffairsExelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555Associate General CounselExelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 LaSalle County Station, Units 1 and 2 cc:Manager Licensing - Braidwood, Byron, and LaSalle Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555Senior Vice President - Midwest OperationsExelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 EXELON GENERATION COMPANY, LLCDOCKET NO. 50-373LASALLE COUNTY STATION, UNIT 1AMENDMENT TO FACILITY OPERATING LICENSEAmendment No. 182License No. NPF-111.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment filed by the Exelon Generation Company, LLC(the licensee), dated March 16, 2006, as supplemented by letter dated April 6, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the attachment to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-11 is hereby amended to read as follows: June 29, 2007(2)Technical Specifications and Environmental Protection PlanThe Technical Specifications contained in Appendix A, as revised throughAmendment No. 182, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.3.This license amendment is effective as of the date of its issuance and shall beimplemented within 60 days of the date of issuance.FOR THE NUCLEAR REGULATORY COMMISSION/RA/Russell Gibbs, ChiefPlant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating LicenseDate of Issuance: June 29, 2007 EXELON GENERATION COMPANY, LLCDOCKET NO. 50-374LASALLE COUNTY STATION, UNIT 2AMENDMENT TO FACILITY OPERATING LICENSEAmendment No. 169License No. NPF-181.The Nuclear Regulatory Commission (the Commission) has found that:A.The application for amendment filed by the Exelon Generation Company, LLC(the licensee), dated March 16, 2006, as supplemented by letter dated April 6, 2007, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's regulations set forth in 10 CFR Chapter I;B.The facility will operate in conformity with the application, the provisions of theAct, and the regulations of the Commission;C.There is reasonable assurance (i) that the activities authorized by thisamendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I;D.The issuance of this amendment will not be inimical to the common defense andsecurity or to the health and safety of the public; andE.The issuance of this amendment is in accordance with 10 CFR Part 51 of theCommission's regulations and all applicable requirements have been satisfied.2.Accordingly, the license is amended by changes to the Technical Specifications asindicated in the enclosure to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-18 is hereby amended to read as follows: (2)Technical Specifications and Environmental Protection PlanThe Technical Specifications contained in Appendix A, as revised throughAmendment No. 169, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.3.This license amendment is effective as of the date of its issuance and shall beimplemented within 60 days of the date of issuance.FOR THE NUCLEAR REGULATORY COMMISSION/RA/Russell Gibbs, ChiefPlant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications and Facility Operating LicenseDate of Issuance: June 29, 2007 ATTACHMENT TO LICENSE AMENDMENT NOS. 182 AND 169 FACILITY OPERATING LICENSE NOS. NPF-11 AND NPF-18DOCKET NOS. 50-373 AND 50-374Replace the following pages of the Facility Operating Licenses and Appendix "A" TechnicalSpecifications with the enclosed pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.Remove InsertLicense NPF-11 License NPF-11Page 3Page 3 License NPF-18 License NPF-18Page 3Page 3

TS TSPage 3.3.6.1-7Page 3.3.6.1-7 (4)Exelon Generation Company, LLC, pursuant to the Act and 10 CFR Parts30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and(5)Exelon Generation Company, LLC, pursuant to the Act and 10 CFRParts 30, 40, and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of LaSalle County Station, Units 1 and 2.C.This license shall be deemed to contain and is subject to the conditions specifiedin the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:(1)Maximum Power LevelThe licensee is authorized to operate the facility at reactor core powerlevels not in excess of full power (3489 megawatts thermal).(2)Technical Specifications and Environmental Protection PlanThe Technical Specifications contained in Appendix A, as revised throughAmendment No. 182, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.(3)Conduct of Work Activities During Fuel Load and Initial StartupThe licensee shall review by committee all Unit 1 PreoperationalTesting and System Demonstration activities performed concurrently with Unit 1 initial fuel loading or with the Unit 1 Startup Test Program to assure that the activity will not affect the safe performance of the Unit 1 fuel loading or the portion of the Unit 1 Startup Program being performed. The review shall address, as a minimum, system interaction, span of control, staffing, security and health physics, with respect to performance of the activity concurrently with the Unit 1 fuel loading or the portion of the Unit 1 Startup Program being performed. The committee for the review shall be composed of at least three members, knowledgeable in the above areas, and who meet the qualifications for professional-technical personnel specified byAmendment No. 182 (5)Pursuant to the Act and 10 CFR Parts 30, 40, and 70 possess, but notseparate, such byproduct and special nuclear materials as may be produced by the operation of LaSalle County Station Units 1 and 2.C.This license shall be deemed to contain and is subject to the conditions specifiedin the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:(1)Maximum Power LevelThe licensee is authorized to operate the facility at reactor core powerlevels not in excess of full power (3489 megawatts thermal). Items in shall be completed as specified. Attachment 1 is hereby incorporated into this license.(2)Technical Specifications and Environmental Protection PlanThe Technical Specifications contained in Appendix A, as revised throughAmendment No. 169, and the Environmental Protection Plan contained in Appendix B, are hereby incorporated in the license. The licensee shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.(3)Conduct of Work Activities During Fuel Load and Initial StartupThe licensee shall review by committee all Unit 2 Preoperational Testingand System Demonstration activities performed concurrently with Unit 2 initial fuel loading or with the Unit 2 Startup Test Program to assure that the activity will not affect the safe performance of the Unit 2 fuel loading or the portion of the Unit 2 Startup Program being performed. The review shall address, as a minimum, system interaction, span of control, staffing, security and health physics, with respect to performance of the activity concurrently with the Unit 2 fuel loading or the portion of the Unit 2 Startup Program being performed. The committee for the review shall be composed of at least three members, knowledgeable in the above areas, and who meet the qualifications for professional-technical personnel specified by section 4.4 of ANSI N18.7-1971. At least one of these three shall be a senior member of the Assistant Superintendent of Operation's staff.Amendment No. 169 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATIONRELATED TO AMENDMENT NO. 182 TO FACILITY OPERATING LICENSE NO. NPF-11AND AMENDMENT NO. 169 TO FACILITY OPERATING LICENSE NO. NPF-18EXELON GENERATION COMPANY, LLCLASALLE COUNTY STATION, UNITS 1 AND 2DOCKET NOS. 50-373 AND 50-37

41.0 INTRODUCTION

By letter to the Nuclear Regulatory Commission (NRC, the Commission) dated March 16, 2006(Agencywide Documents Access and Management System (ADAMS) Accession No. ML060760585), as supplemented by letter dated April 6, 2007 (ADAMS Accession No. ML070990338), Exelon Generation Company, LLC (the licensee), requested changes to the technical specifications (TSs) and facility operating license for LaSalle County Station, Units 1 and 2. The proposed changes would revise the allowable values for four reactor coreisolation cooling leak detection functions in TS Table 3.3.6.1-1, "Primary Containment IsolationInstrumentation."The April 6, 2007, supplement, contained clarifying information and did not change the NRCstaff's initial proposed finding of no significant hazards consideration.

1.0BACKGROUND

By letter dated March 16, 2006, supplemented by letter dated April 6, 2007, the licenseeproposed a license amendment request (LAR) for LaSalle County Station, Units 1 and 2. The LAR proposes the following TS changes in TS Table 3.3.6.1-1, Primary Containment Isolation Instrumentation, Reactor Core Isolation Cooling (RCIC) leak detection functions:

• Increase the Allowable Value for Function 3.e., "RCIC Equipment Room Temperature -High," from < 291.0F to < 297.0F*Decrease the Allowable Value for Function 3.f., "RCIC Equipment Room DifferentialTemperature - High," from < 189.0F to < 188.0F*Decrease the Allowable Value for Function 3.g., "RCIC Steam Tunnel Temperature -High," from < 277.0F to < 267.0F*Increase the Allowable Value for Function 3.h., "RCIC Steam Tunnel DifferentialTemperature - High," from < 155.0F to < 163.0FThe licensee stated that while responding to a corrective action plan (CAP) action item, the existing reactor coolant leak detection calculation, L001324, Revision 5A, and the RCIC leakdetection setpoint calculation, NED-I-EIC-0213, Revision 1G, were reviewed in May 2005.

During this review, the licensee found that the current allowable values (AV) in Table 3.3.6.1-1 were derived from calculation L001324, Revision 0, rather than Revision 5A, and are therefore, no longer supported by the current calculation NED-I-EIC-0213, Revision 1G. The licensee's proposed TS changes are based on revised analytical limits for a leak rate equivalent to 25 gallons per minute determined by L001324, Revision 5A.

2.0REGULATORY EVALUATION

The NRC staff used the following regulatory bases and guidance documents in its evaluation ofthe LAR:2.110 CFR Part 50.36, Technical Specifications.

Section 50.36(a) states, "Each applicant for a license authorizing operation of a production orutilization facility shall include in his application proposed technical specification in accordancewith the requirements of this section." Section 50.36(c)(1)(i)(A) states, "Safety limits for nuclear reactors are limits upon importantprocess variables that are found to be necessary to reasonably protect the integrity of certain of physical barriers that guard against the uncontrolled release of radioactivity." Section 50.36(c)(1)(ii)(A) states, "Limiting safety system settings [LSSS] for nuclear reactor aresettings for automatic protective devices related to those variables having significant safety functions. Where a limiting safety system setting is specified for a variable on which a safety limit has been placed, the setting must be so chosen that automatic protective action will correct the abnormal situation before a safety limit is exceeded. If, during operation, it is determined that the automatic safety system does not function as required, the licensee shall take appropriate action, which may include shutting down the reactor."Section 50.36(c)(3) states, "Surveillance requirements are requirements relating to test,calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met."2.2NRC Regulatory Issue Summary (RIS) 2006-17, "NRC Staff Position on theRequirements of 10 CFR 50.36, Technical Specifications, Regarding Limiting Safety System Settings During Periodic Testing and Calibration of Instrument Channels,"

discusses the NRC's requirements on limiting safety system settings (LSSSs) assessed during periodic testing and calibration of instrumentation. This RIS discusses issues that could occur during testing of LSSSs and which, therefore, may have adverse effect on equipment operability and an acceptable approach for addressing these issues via licensing actions that require prior NRC staff approval. This document is available on the NRC public website at ADAMS Accession No. ML051810077.2.3Letter from Patrick L. Hiland, NRC, to the Nuclear Energy Institute Setpoint MethodsTask Force, "Technical Specification for Addressing Issues Related to Setpoint Allowable Values," dated September 7, 2005 (the Hiland letter), ADAMS Accession No. ML052500004. This letter addresses the TS Notes required for the TS setpointchanges involving safety limit-related instrumentations and corrective actions required when the as-found setpoints are beyond the acceptable as-found setpoints.2.4Regulatory Guide (RG) 1.105, Revision 3, "Setpoints for Safety-RelatedInstrumentation," describes a method acceptable to the NRC staff for complying with the NRC's regulations for ensuring that setpoints for safety-related instrumentation are initially within and remain within the TS limits. 2.5The International Society for Measurements and Control Standard, ISA-S67.04, Part I,"Setpoints for Nuclear Safety-Related Instrumentation,", defines a framework for ensuring that setpoints for nuclear safety limit-related instrumentation are established and maintained within specified limits. RG 1.105 endorses ISA-S67.04, Part I, subject to NRC staff clarifications.

3.0TECHNICAL EVALUATION

The RCIC system provides relatively cool water to the reactor vessel either from thecondensate storage tank or from the suppression pool and uses steam from the reactor to drive the RCIC turbine driven pump. The RCIC system is automatically initiated to ensure adequate core cooling in the event the reactor is isolated from the main condenser during power operation with a loss of main feedwater flow. Reactor vessel water level is maintained or supplemented by the RCIC system during the following conditions:a.reactor vessel isolated and maintained in the hot standby condition; b.reactor vessel isolated coincident with loss of normal coolant flow from the reactorfeedwater system; orc.plant shutdown where a loss of normal feedwater system is experienced before thereactor is depressurized to where the reactor shutdown cooling mode of the residual heat removal system can be placed in operation.The licensee stated that the RCIC leak detection isolation functions are not credited in anyUpdated Final Safety Analysis Report (UFSAR) transient or accident analysis, because thebounding analyses are performed for large breaks such as reactor recirculation line or main steam line breaks. The RCIC system is a safe shutdown system rather than an emergency core cooling system. Therefore, no safety limits are associated with the RCIC system as defined in 10 CFR 50.36(c)(1)(i)(A).The Hiland letter states that TS Notes should be added for setpoint verification surveillances forinstrument functions on which a safety limit has been placed. As stated previously, there are no safety limits associated with the RCIC system, therefore, the NRC staff concludes that there is no need to put the referenced TS Notes in the TS for the proposed AV changes in TS Table 3.3.6.1-1. The Hiland letter also states that operability and expected performance of instruments will beconfirmed during performance of surveillance tests. The surveillance should be conducted as outlined below: 1.If the as-found trip set point (TSP) is found to be non-conservative with respect to theAV specified in TSs, the channel is declared inoperable and the associated TS action statement must be followed.2.If the as-found TSP is found to be conservative with respect to the AV, and outside theas-found predefined acceptance criteria band, but the licensee is able to determine that the instrument channel is functioning as required and the licensee can reset the channel to within the setting tolerance of the limiting TSP, or a value more conservative than the limiting TSP, then the licensee may consider the channel operable. If the licensee cannot determine that the instrument channel is functioning as required, the channel is declared inoperable and the associated TS actions must be followed.3.If the as-found TSP is outside the as-found predefined acceptance criteria band, thecondition must be entered into the licensee's corrective action program for further evaluation.In response to the NRC staff request for additional information, by letter dated April 6, 2007, thelicensee provided copies of the following surveillance procedures:1.LIS-RI-1(2)03A, "Unit 1(2) RCIC Equipment Room/Steam Line Tunnel High Ambient andDifferential Temperature Outboard Isolation (DIV 1) Calibration."2.LIS-RI-1(2)03B, "Unit 1(2) RCIC Equipment Room/Steam Line Tunnel High Ambient andDifferential Temperature Outboard Isolation (DIV 2) Calibration." The licensee described the measures taken to ensure instrument channels are operatingproperly in the response to RAI Question No. 2. These procedures contain a statement to verify that the "as-found" data is within the required calibration limits. If the "as-found" data is not within the required calibration limits, the applicable procedure directs the instrument technician to identify the "as-found" data and contact the Instrument Maintenance Supervisor for further instructions and, if appropriate, calibrate the instrument and record the "as-left" data. The licensee, also, provided procedure ER-AA-520, "Instrument Performance Trending" whichdetails the plant procedures followed when the instruments are found outside the calibration limits. An Issue Report (IR) is initiated when any instrument is found out of calibration limits during periodic surveillances. An IR is the entry point into the plant CAP. If an instrument is found to be outside the "as-found" calibration limits (acceptable as-found) and outside the AV, the calibration information is documented in the IR. The CAP is also the tracking process to ensure the condition is evaluated, corrected, and the appropriate resolution documented.

ER-AA-520 also documents the requirements for reporting instruments that are found outside the "as-found" calibration limits but within AV. The calibration information is documented and entered into the CAP as a Condition Report for periodic trending evaluation. All instruments are required to be left within the "as-left" calibration limits by ER-AA-520, LIS-RI-1(2)03A and LIS-RI-1(2)03B. The NRC staff reviewed the information provided in the licensee's RAI response. The NRCstaff concludes that the licensee has adequate plant procedures to assure that surveillances are conducted in accordance with the three criteria detailed in the Hiland letter. Therefore, the NRC staff finds that the operability and expected performance of instruments will be confirmed during performance of surveillance tests.In response to staff request for additional information by letter dated April 6, 2007, the licenseeprovided:1.Engineering Calculation NED-I-EIC-0213, "RCIC Equipment Area/Pipe Tunnel HighAmbient and Differential Temperature Outboard and Inboard Isolation Error Analysis,"

Revision 00 2.Engineering Calculation NED-I-EIC-0213, "Derived Technical Specification AllowableValues for Instrument Loop Channels that detect RCIC Equipment Area/Pipe Tunnel High Ambient and Differential Temperature based on Corrected Values for Analytical Limits," Revision 1G3.Engineering Standard NES-EIC-20.04, "Analysis of Instrument Channel Setpoint Errorand Instrument Loop Accuracy." Revision 4. By letter dated March 16, 2006, the licensee, also, provided NES-EIC-20.04, "Equations forInstrument Channel Uncertainties, Setpoints and Allowable Values," Revision 4. From the above calculations, the licensee arrived at the following setpoint parameters:TABLE 1: SETPOINT PARAMETERSFunction No. in Table 3.3.6.1-13e3f3g3hAnalytical Limit (AL)299.6F195.6F270.5F170.5FTotal Error (TE)11.244F8.246F11.244F8.246FChannel Drift (DTI)8.739F1.298F8.739F1.298FAcceptable As-Found Tolerance (ET)+

7F+1.5F+7F+1.5FAcceptable As-Left Tolerance (ST)+

3F+1.5F+3F+1.5FTrip Setpoint (TS)192.0F108.5F192.0F108.5FLimiting Setpoint (SP)288.356F187.354F259.256F162.254FAllowable Value (AV)297.0F188.0F267.0F163.0FMargin (SP - TS)96.356F78.854F53.256F53.754FMargin (AV - TS - ET)98.0F78.0F98.0F53 As indicated in Calculation Standard NES-EIC-20.04, Revision 4, in calculating TE the licensee included:1.Instrumentation calibration uncertainties: Including calibration standards, calibrationmeasurement and test equipment error, and setting tolerances2.Calibration methods 3.Instrument uncertainties during normal operation: Including reference accuracy, powersupply voltage and frequency changes, ambient temperature changes, humidity changes, pressure changes, in service vibration allowances, radiation exposure, analog to digital and digital to analog conversion4.Instrument drift 5.Uncertainties caused by design basis events 6.Process dependent effects 7.Calculation effects 8.Dynamic effects 9.Installation biases The licensee provided calculations of the TE, DTI, ST, and ET in calculations NED-I-EIC-0213,Revision 00, and NED-I-EIC-0213, Revision 1G. The licensee's calculations demonstrated 95 percent/95 percent confidence level in uncertainty calculations. The NRC staff has reviewed the parameters used in calculating TE and find them acceptable, specifically considering the wide margins the licensee used, between 53 F and 96 F, for calculating TS from AL,compared to TE of 11.2 F and 8.2 F. Similarly, for calculating the AV the licensee usedmargin between 53 F and 98F, while the DTIs are 8.7 F and 1.3 F. The staff, specifically,checked the derivation of the acceptable as-left and acceptable as-found values and find acceptable as-left values of 3 F and 1.5 F and acceptable as-found values of 7 F and1.5 F, respectively, as reasonably low and, therefore, acceptable. Specifically, the channel as-found values are below the DTI values. Because the licensee used wide margins in calculating the trip setpoint and has usedreasonable parameters in calculating the acceptable as-left and acceptable as-found values, the NRC staff finds the calculations acceptable. In addition, the licensee described the plant procedures to set the channels within acceptable as-left values or declare the channel INOPERABLE, where required, and enter into adequate corrective actions. Based on the above considerations, the NRC staff finds that the revised TS values will ensure the RCIC system will perform its intended function. The NRC staff finds that the proposed TS changes are not related to any plant safety limits andaccordingly, there is no need to add the two TS Notes recommended in the NRC letter dated September 7, 2005, for safety limit-related setpoint TS changes. Furthermore, the NRC staff finds the acceptable as-left and acceptable as-found values the licensee selected arereasonable compared to the wide margin the licensee used in calculating the trip setpoints. The NRC staff, also, finds the licensee has satisfactory plant procedures to take adequatecorrective actions when the setpoints are found beyond the acceptable as-found values during the surveillance tests. In considerations of the above, the NRC staff concludes that the proposed TS changes are acceptable.

4.0STATE CONSULTATION

In accordance with the Commission's regulations, the Illinois State official was notified of theproposed issuance of the amendments. The State official had no comments.

5.0ENVIRONMENTAL CONSIDERATION

The amendments change surveillance requirements with respect to the installation or use of thefacilities components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. TheCommission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (71 FR 46929; August 15, 2006). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) thereis reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.Principal Contributor: S. Mazumdar Date: June 29, 2007