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

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{{#Wiki_filter: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
{{#Wiki_filter:4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-18-078 10 CFR 50.90 June 18, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374


==Subject:==
==Subject:==
Line 24: Line 24:


==References:==
==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.  
: 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, 2017
: 2. 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, 2018 In Reference 1, EGC submitted a request for amendments to the Technical Specifications (TS) for LaSalle County Station (LSCS), Units 1 and 2. In Reference 2, the NRC determined that additional information was required to complete its evaluation of the Reference 1 request. The requested information is 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 affected TS 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 amendments do 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.
June 18, 2018 U.S. Nuclear Regulatory Commission Page 2 EGC is notifying the State of Illinois of this supplement to a previous application for a change to the TS by sending a copy of this letter and its attachment to the designated State Official in accordance with 10 CFR 50 .91 , "Notice for public comment; State consultation ," paragraph (b) .
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
Approval of the proposed amendments continues to be requested by December 13, 2018.
Once approved, the amendments will be implemented for LSCS, Units 1 and 2 prior to initial entry into Mode 4 during the LSCS, Unit 2 refuel outage in 2019 (i.e., L2R17), which is currently scheduled to occur in February 2019.
There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 18th day of June 2018.
Respectfully, Patrick R. Simpson Manager - Licensing Exelon Generation Company, LLC Attachments:      1. Supplemental Information Related to Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control"
: 2. Revised Technical Specifications Page Changes (Mark-Ups)
: 3. Revised Technical Specifications Pages cc:    NRC Regional Administrator, Region Ill NRC Senior Resident Inspector - LaSalle County Station Illinois Emergency Management Agency - Division of Nuclear Safety


==Background:==
LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 ATTACHMENT 1 SUPPLEMENTAL INFORMATION RELATED TO APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-542, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL"
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
ATTACHMENT 1 -
SUPPLEMENTAL INFORMATION RELATED TO APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-542, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" REQUEST FOR ADDITIONAL INFORMATION APPLICATION TO REVISE TECHNICAL SPECIFICATION TO ADOPT TSTF-542 REVISION 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


fuel (TAF) shall be  hours  AND  One Two ECCS injection/spray subsystem s shall be OPERABLE.
==Background:==
  ----------------------------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
In Attachment 2 of the LAR, on page 3.3.5.2-3, proposed LSCS TS Table 3.3.5.2-1, Function 1.a, "Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core 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) Response In 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 channel is needed.
This applied to the required Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core Spray (LPCS) Subsystems, and required LPCI 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, Page 1 of 2


realigned and not otherwise inoperable.
ATTACHMENT 1 -
------------------------------------------------------------
SUPPLEMENTAL INFORMATION RELATED TO APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-542, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" the 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.
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
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:
ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One r R equired ECCS injection/spray subsystem inoperable.
The NRC staff noted that the following corrections are needed to the TS Mark-up Pages submitted in the Application:
A.1 Restore required ECCS injection/spray subsystem to OPERABLE
: 1.      Attachment 2 of the License Amendment Request (LAR), markup page 3.5.2-1, Required Action B.1 As proposed: B.1 Initiate action to establish a method of water injection capable of operating without offsite power.
        'Electrical' is missing between offsite and power
: 2.      Attachment 2 of the LAR, markup page 3.5.2-2, Condition C is missing period.
EGC Response Updated 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.
Page 2 of 2


status. 4 hours B. Required Action and associated Completion Time of Condition A
LaSalle County Station, Units 1 and 2 Supplemental Information Related to Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 2 REVISED TECHNICAL SPECIFICATIONS PAGE CHANGES (MARK-UPS) 3.5.2-1 3.5.2-2


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  
RPV Water Inventory ControlECCSShutdown 3.5.2 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 ControlECCSShutdown LCO  3.5.2        DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be   hours
AND OneTwo ECCS injection/spray subsystems shall be OPERABLE.
                  ----------------------------NOTE----------------------------
One A Llow Ppressure Ccoolant Iinjection (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:    MODES 4 and, MODE 5 except with the spent fuel storage pool gates removed and water level t 22 ft over the top of the reactor pressure vessel flange.
ACTIONS CONDITION                  REQUIRED ACTION          COMPLETION TIME A. One rRequired ECCS      A.1    Restore required ECCS  4 hours injection/spray                  injection/spray subsystem inoperable.            subsystem to OPERABLE status.
B. Required Action and      B.1     Initiate action to     Immediately associated Completion            suspend operations Time of Condition A              with a potential for not met.                        draining the reactor vessel (OPDRVs)establish a method of water injection capable of operating without offsite electrical power.
(continued)
LaSalle 1 and 2                      3.5.2-1              Amendment No. 147/133


operating without offsite electrical power. Immediately (continued)
RPV Water Inventory ControlECCSShutdown 3.5.2 ACTIONS  (continued)
RPV Water Inventory ControlECCS-Shutdown 3.5.2 LaSalle 1 and 2 3.5.2-2 Amendment No.
CONDITION             REQUIRED ACTION           COMPLETION TIME C. Two required ECCS     C.1   Initiate action to     Immediately injection/spray              suspend OPDRVs.
147/133 ACTIONS  (continued)
subsystems inoperable.
CONDITION REQUIRED ACTION COMPLETION TIME C. Two required ECCS injection/spray subsystems inoperable.
AND C.2   Restore one required   4 hours ECCS injection/spray subsystem to OPERABLE status.
C.1 Initiate action to suspend OPDRVs.
C  DRAIN TIME   hours  C  Verify secondary        4 hours and   hours              containment boundary is capable of being established in less than the DRAIN TIME
AND C.2 Restore one required ECCS injection/spray subsystem to OPERABLE status.
AND C  Verify each secondary  4 hours containment penetration flow path is capable of being isolated in less than the DRAIN TIME
Immediately
AND C  Verify one standby      4 hours gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME
(continued)
LaSalle 1 and 2                3.5.2-2              Amendment No. 147/133


4 hours  C DRAIN TIME  hours and   hours C Verify secondary containment boundary is capable of being
LaSalle County Station, Units 1 and 2 Supplemental Information Related to Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 3 REVISED TECHNICAL SPECIFICATIONS PAGES 3.5.2-1 3.5.2-2


established in less than the DRAIN TIME  AND  C Verify each secondary containment
RPV Water Inventory Control 3.5.2 3.5   EMERGENCY CORE COOLING SYSTEMS (ECCS), REACTOR PRESSURE VESSEL (RPV)
 
WATER INVENTORY CONTROL, AND REACTOR CORE ISOLATION COOLING (RCIC)
penetration flow path
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 KRXUV
 
AND One ECCS injection/spray subsystem shall be OPERABLE.
is capable of being
                  ----------------------------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.
isolated in less than
APPLICABILITY:   MODES 4 and 5.
 
ACTIONS CONDITION                 REQUIRED ACTION           COMPLETION TIME A. Required ECCS           A.1     Restore required ECCS   4 hours injection/spray                  injection/spray subsystem inoperable.            subsystem to OPERABLE status.
the DRAIN TIME  AND  C Verify one standby gas treatment
B. Required Action and     B.1     Initiate action to     Immediately associated Completion            establish a method of Time of Condition A              water injection not met.                        capable of operating without offsite electrical power.
 
(continued)
subsystem is capable of being placed in operation in less
LaSalle 1 and 2                     3.5.2-1              Amendment No. 147/133
 
than the DRAIN TIME  4 hours 
 
4 hours
 
4 hours (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.  
 
------------------------------------------------------------
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 hours  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 hours
 
4 hours


4 hours (continued)}}
RPV Water Inventory Control 3.5.2 ACTIONS  (continued)
CONDITION              REQUIRED ACTION          COMPLETION TIME C. DRAIN TIME KRXUV C.1  Verify secondary        4 hours DQGKRXUV.              containment boundary is capable of being established in less than the DRAIN TIME.
AND C.2  Verify each secondary  4 hours containment penetration flow path is capable of being isolated in less than the DRAIN TIME.
AND C.3  Verify one standby      4 hours gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.
(continued)
LaSalle 1 and 2                3.5.2-2              Amendment No. 147/133}}

Latest revision as of 22:05, 2 February 2020

Supplemental Information Related to Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control
ML18169A401
Person / Time
Site: LaSalle  Constellation icon.png
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)
v • d • e


Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-18-078 10 CFR 50.90 June 18, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC 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, 2017

2. 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, 2018 In Reference 1, EGC submitted a request for amendments to the Technical Specifications (TS) for LaSalle County Station (LSCS), Units 1 and 2. In Reference 2, the NRC determined that additional information was required to complete its evaluation of the Reference 1 request. The requested information is 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 affected TS 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 amendments do 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.

June 18, 2018 U.S. Nuclear Regulatory Commission Page 2 EGC is notifying the State of Illinois of this supplement to a previous application for a change to the TS by sending a copy of this letter and its attachment to the designated State Official in accordance with 10 CFR 50 .91 , "Notice for public comment; State consultation ," paragraph (b) .

Approval of the proposed amendments continues to be requested by December 13, 2018.

Once approved, the amendments will be implemented for LSCS, Units 1 and 2 prior to initial entry into Mode 4 during the LSCS, Unit 2 refuel outage in 2019 (i.e., L2R17), which is currently scheduled to occur in February 2019.

There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Mr. Mitchel A. Mathews at (630) 657-2819.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 18th day of June 2018.

Respectfully, Patrick R. Simpson Manager - Licensing Exelon Generation Company, LLC Attachments: 1. Supplemental Information Related to Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control"

2. Revised Technical Specifications Page Changes (Mark-Ups)
3. Revised Technical Specifications Pages cc: NRC Regional Administrator, Region Ill NRC Senior Resident Inspector - LaSalle County Station Illinois Emergency Management Agency - Division of Nuclear Safety

LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 ATTACHMENT 1 SUPPLEMENTAL 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" REQUEST FOR ADDITIONAL INFORMATION APPLICATION TO REVISE TECHNICAL SPECIFICATION TO ADOPT TSTF-542 REVISION 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, Function 1.a, "Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core 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) Response In 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 channel is needed.

This applied to the required Low Pressure Coolant Injection-A (LPCI) and Low Pressure Core Spray (LPCS) Subsystems, and required LPCI 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, Page 1 of 2

ATTACHMENT 1 -

SUPPLEMENTAL INFORMATION RELATED TO APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TSTF-542, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" the 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.1 As proposed: B.1 Initiate action to establish a method of water injection capable of operating without offsite power.

'Electrical' is missing between offsite and power

2. Attachment 2 of the LAR, markup page 3.5.2-2, Condition C is missing period.

EGC Response Updated 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.

Page 2 of 2

LaSalle County Station, Units 1 and 2 Supplemental Information Related to Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 2 REVISED TECHNICAL SPECIFICATIONS PAGE CHANGES (MARK-UPS) 3.5.2-1 3.5.2-2

RPV Water Inventory ControlECCSShutdown 3.5.2 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 ControlECCSShutdown LCO 3.5.2 DRAIN TIME of RPV water inventory to the top of active fuel (TAF) shall be  hours

AND OneTwo ECCS injection/spray subsystems shall be OPERABLE.

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

One A Llow Ppressure Ccoolant Iinjection (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: MODES 4 and, MODE 5 except with the spent fuel storage pool gates removed and water level t 22 ft over the top of the reactor pressure vessel flange.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One rRequired ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> injection/spray injection/spray subsystem inoperable. subsystem to OPERABLE status.

B. Required Action and B.1 Initiate action to Immediately associated Completion suspend operations Time of Condition A with a potential for not met. draining the reactor vessel (OPDRVs)establish a method of water injection capable of operating without offsite electrical power.

(continued)

LaSalle 1 and 2 3.5.2-1 Amendment No. 147/133

RPV Water Inventory ControlECCSShutdown 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Two required ECCS C.1 Initiate action to Immediately injection/spray suspend OPDRVs.

subsystems inoperable.

AND C.2 Restore one required 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> ECCS injection/spray subsystem to OPERABLE status.

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

AND C Verify each secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> containment penetration flow path is capable of being isolated in less than the DRAIN TIME

AND C Verify one standby 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME

(continued)

LaSalle 1 and 2 3.5.2-2 Amendment No. 147/133

LaSalle County Station, Units 1 and 2 Supplemental Information Related to Application to Revise Technical Specifications to Adopt TSTF-542, "Reactor Pressure Vessel Water Inventory Control" ATTACHMENT 3 REVISED TECHNICAL SPECIFICATIONS PAGES 3.5.2-1 3.5.2-2

RPV Water Inventory Control 3.5.2 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 KRXUV

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.

APPLICABILITY: MODES 4 and 5.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS A.1 Restore required ECCS 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> injection/spray injection/spray subsystem inoperable. subsystem to OPERABLE status.

B. Required Action and B.1 Initiate action to Immediately associated Completion establish a method of Time of Condition A water injection not met. capable of operating without offsite electrical power.

(continued)

LaSalle 1 and 2 3.5.2-1 Amendment No. 147/133

RPV Water Inventory Control 3.5.2 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. DRAIN TIME KRXUV C.1 Verify secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> DQGKRXUV. containment boundary is capable of being established in less than the DRAIN TIME.

AND C.2 Verify each secondary 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> containment penetration flow path is capable of being isolated in less than the DRAIN TIME.

AND C.3 Verify one standby 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> gas treatment subsystem is capable of being placed in operation in less than the DRAIN TIME.

(continued)

LaSalle 1 and 2 3.5.2-2 Amendment No. 147/133

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