ML080700973

Request for Additional Information Related to License Amendment Request to Revise TS 3.3.1.1, Reactor Protection System (RPS) Instrumentation, Scram Discharge Volume Level Instrumentation Surveillance Requirements

ML080700973
Person / Time
Site:	Clinton
Issue date:	03/11/2008
From:	Sands S P NRC/NRR/ADRO/DORL/LPLIII-2
To:	Pardee C G AmerGen Energy Co
Sands S P,NRR/DORL, 415-3154
References
TAC MD4111
Download: ML080700973 (4)

Text

March 11, 2008

Mr. Charles G. Pardee Chief Nuclear Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

CLINTON POWER STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 3.3.1.1, "REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION," SCRAM DISCHARGE VOLUME LEVEL INSTRUMENTATION SURVEILLANCE REQUIREMENTS (TAC NO. MD4111)

Dear Mr. Pardee:

By letter to the Nuclear Regulatory Commission (NRC) dated January 26, 2007, AmerGen Energy Company, LLC submitted an amendment request to Appendix A, Technical Specifications of Facility Operating License No. NPF-62 for Clinton Power Station (CPS),

Unit No. 1. Specifically, the submittal requests changes which will revise surveillance requirement 3.

3.1.1.9, to increase the surveillance requirement frequency for the scram discharge volume level float switch from every 92 days to every 24 months.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on March 4, 2008, it was agreed that you would provide a response within 15 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC

=s goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-3154.

Sincerely, /RA/

Stephen P. Sands, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-461

Enclosure:

Request for Additional Information

cc w/encl: See next page March 11, 2008 Mr. Charles G. Pardee Chief Nuclear Officer and AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

CLINTON POWER STATION, UNIT NO. 1 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 3.3.1.1, "REACTOR PROTECTION SYSTEM (RPS) INSTRUMENTATION" SCRAM DISCHARGE VOLUME LEVEL INSTRUMENTATION SURVEILLANCE REQUIREMENTS (TAC NO. MD4111)

Dear Mr. Pardee:

By letter to the Nuclear Regulatory Commission (NRC) dated January 26, 2007, AmerGen Energy Company, LLC submitted an amendment request to Appendix A, Technical Specifications of Facility Operating License No. NPF-62 for Clinton Power Station (CPS),

Unit No. 1. Specifically, the submittal requests changes which will revise surveillance requirement 3.

3.1.1.9, to increase the surveillance requirement frequency for the scram discharge volume level float switch from every 92 days to every 24 months.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on March 4, 2008, it was agreed that you would provide a response within 15 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC

=s goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-3154.

Sincerely, /RA/ Stephen P. Sands, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-461

Enclosure:

Request for Additional Information

DISTRIBUTION:

PUBLIC LPL3-2 R/F RidsNrrDorlLpl3-2 RidsOgcRp RidsNrrPMSSands RidsNrrDeEicb RidsNrrLAEWhitt RidsNrrDorlDpr RidsRgn3MailCenter RidsAcrsAcnw&mMailCenter ADAMS Accession Number: ML080700973 NRR-088 *concurred via e-mail OFFICE LPL3-2/PM LPL3-2/LA*

LPL3-2/BC

NAME SSands EWhitt RGibbs DATE 03 / 11 /08 3/11/08 3/11/08 OFFICIAL RECORD COPY Clinton Power Station, Unit No. 1

cc: Corporate Distribution Exelon Generation Company, LLC Via e-mail

Clinton Distribution Exelon Generation Company, LLC Via e-mail

Clinton Senior Resident Inspector U.S. Nuclear Regulatory Commission Via e-mail

Clinton Resident Inspector U.S. Nuclear Regulatory Commission Via e-mail

Illinois Emergency Management Agency Division of Disaster Assistance &

Preparedness Via e-mail

J. W. Blattner, Project Manager Sargent & Lundy Engineers Via e-mail

Chairman of DeWitt County c/o County Clerk's Office Via e-mail

Enclosure REQUEST FOR ADDITIONAL INFORMATION

CLINTON POWER STATION, UNIT NO. 1

DOCKET NO. 50-461

In reviewing the January 26, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML070330254), AmerGen Energy Company, LLC submittal regarding an amendment to Appendix A, Technical Specifications for Clinton Power Station, Unit No. 1, the NRC staff has identified issues which will require resolution. Specifically, the submittal requests changes which will revise surveillance requi rements (SR) 3.3.1.1.9 for the scram discharge volume level float switch from every 92 days to every 24 months. Hence, additional information is required for the staff to complete its review.

In section 4.1, Attachment 1, of the letter dated January 26, 2007, it is stated, "These surveillances have routinely shown that the as-found condition of the instruments has not required readjustment. Surveillance test results from the past 12 quarters have been reviewed and it was determined that the as-found condition of the four float switches have been found to be within the acceptance criteria specified in the surveillance test procedures. In addition, the float switches are mechanical devices that are not subject to instrument setpoint drift and furthermore have not been subjected to failures requiring mechanical adjustment during this period."

The NRC staff needs following clarifications/information:

A. 12 quarters (48 months) is not adequate to justify extension of functional tests from quarterly to 24 months - please provide sufficient performance data to ensure 95 confidence level.

B. The float switches are subjected to calibration test SR 3.3.1.1.13 - how has it been concluded that the switches are not subject to instrument drift?

C. What is the make and the model number of the float switches and what is the industry experience with these switches? Does Title 10 of the Code of Federal Regulations (10 CFR) Part 21, "Reporting of Defects and Noncompliance" apply?

D. What are the nominal trip setpoints, acceptable as-left and as-found trip setpoints for float switches?

In the Attachment to the letter dated June 6, 2007 (ADAMS Accession No. ML071580953), the licensee quoted plant procedures 9431.22 and 9531.22. Do the plant procedures conform to clause B.4 of the NRC letter dated September 7, 2005 (ADAMS Accession No. ML052500004)?