ML071700177
| ML071700177 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 07/11/2007 |
| From: | Bamford P J NRC/NRR/ADRO/DORL/LPLI-2 |
| To: | Crane C M AmerGen Energy Co |
| Bamford, Peter J., NRR/DORL 415-2833 | |
| References | |
| TAC MD4910 | |
| Download: ML071700177 (5) | |
Text
July 11, 2007Mr. Christopher M. CranePresident and Chief Executive Officer AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348
SUBJECT:
THREE MILE ISLAND, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATIONREGARDING THE HIGH THERMAL PERFORMANCE (HTP) FUEL REACTOR COOLANT SYSTEM PRESSURE-TEMPERATURE SAFETY LIMIT TECHNICAL SPECIFICATION AMENDMENT (TAC NO. MD4910)
Dear Mr. Crane:
By letter dated March 22, 2007 (Agencywide Documents Access and Management SystemAccession Number ML070860968), AmerGen Energy Company, LLC submitted a license amendment request (LAR) for a technical specification change regarding the Three Mile Island (TMI), Unit 1 Reactor Coolant System Pressure-Temperature Safety Limit. This change will support the introduction of AREVA NP's Mark-B-HTP fuel design during the TMI, Unit 1 Cycle 17 reload (Fall 2007). The proposed amendment would revise various technical specification figures and tables associated with the variable low pressure trip setpoint to reflect more restrictive Safety Limits and more restrictive Limiting Safety System Settings for the Reactor Protection System.The NRC staff has reviewed the information provided in the LAR and has identified theenclosed request for additional information (RAI). This RAI was also emailed to Mr. David Distel of your staff on June 7, 2007. The draft questions were sent to ensure that they were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. During a subsequent telephone discussion with members of your staff on June 18, 2007, it was agreed that your response would be provided within 30 days of the date of this letter.Please contact me at 301-415-2833, if you have any questions.Sincerely,/ra/Peter Bamford, Project ManagerPlant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-289
Enclosure:
As statedcc w/encl: See next page July 11, 2007Mr. Christopher M. CranePresident and Chief Executive Officer AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348
SUBJECT:
THREE MILE ISLAND, UNIT 1 - REQUEST FOR ADDITIONAL INFORMATIONREGARDING THE HIGH THERMAL PERFORMANCE (HTP) FUEL REACTOR COOLANT SYSTEM PRESSURE-TEMPERATURE SAFETY LIMIT TECHNICAL SPECIFICATION AMENDMENT (TAC NO. MD4910)
Dear Mr. Crane:
By letter dated March 22, 2007 (Agencywide Documents Access and Management SystemAccession Number ML070860968), AmerGen Energy Company, LLC submitted a license amendment request (LAR) for a technical specification change regarding the Three Mile Island (TMI), Unit 1 Reactor Coolant System Pressure-Temperature Safety Limit. This change will support the introduction of AREVA NP's Mark-B-HTP fuel design during the TMI, Unit 1 Cycle 17 reload (Fall 2007). The proposed amendment would revise various technical specification figures and tables associated with the variable low pressure trip setpoint to reflect more restrictive Safety Limits and more restrictive Limiting Safety System Settings for the Reactor Protection System.The NRC staff has reviewed the information provided in the LAR and has identified theenclosed request for additional information (RAI). This RAI was also emailed to Mr. David Distel of your staff on June 7, 2007. The draft questions were sent to ensure that they were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. During a subsequent telephone discussion with members of your staff on June 18, 2007, it was agreed that your response would be provided within 30 days of the date of this letter.Please contact me at 301-415-2833, if you have any questions.Sincerely,/ra/Peter Bamford, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor RegulationDocket No. 50-289
Enclosure:
As stated cc w/encl: See next pageDISTRIBUTION
- PUBLICRidsOgcRpLPLI-2 R/FRidsAcrsAcnwMailCenter RidsNrrPMPBamfordRidsNrrLACSolaRidsRgn1MailCenterRidsNrrDorlDpr RidsNrrDorlLpl1-2BMarcusSSunADAMS Accession Number: ML071700177
- by letter** by emailOFFICELPLI-2/PMLPLI-2/PMLPLI-2/LAEICB/BCSRXB/BCLPLI-2/BCNAMEPBamfordEMillerCSolaAHowe*GCranston**HChernoff DATE06/27/200706/27/200706/27/200705/21/200705/22/200707/11/2007OFFICIAL RECORD COPY Three Mile Island Nuclear Station, Unit 1 cc:
Site Vice President - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P. O. Box 480 Middletown, PA 17057Vice President - Operations, Mid-Atlantic AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348Vice President - Licensing and RegulatoryAffairs AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555Regional Administrator Region I U.S. Nuclear Regulatory Commission
475 Allendale Road King of Prussia, PA 19406ChairmanBoard of County Commissioners of Dauphin County Dauphin County Courthouse Harrisburg, PA 17120ChairmanBoard of Supervisors of Londonderry Township R.D. #1, Geyers Church Road Middletown, PA 17057Senior Resident Inspector (TMI-1)U.S. Nuclear Regulatory Commission P.O. Box 219 Middletown, PA 17057Director - Licensing and Regulatory AffairsAmerGen Energy Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348DirectorBureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469Plant Manager - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P. O. Box 480 Middletown, PA 17057Regulatory Assurance Manager - ThreeMile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P.O. Box 480 Middletown, PA 17057Ronald Bellamy, Region IU.S. Nuclear Regulatory Commission
475 Allendale Road King of Prussia, PA 19406Michael A. SchoppmanFramatome ANP Suite 705 1911 North Ft. Myer Drive Rosslyn, VA 22209Dr. Judith JohnsrudNational Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803Eric EpsteinTMI Alert 4100 Hillsdale Road Harrisburg, PA 17112Correspondence Control DeskAmerGen Energy Company, LLC P.O. Box 160 Kennett Square, PA 19348 Three Mile Island Nuclear Station, Unit 1 cc:
Manager Licensing - Three Mile Island Nuclear Station, Unit 1 Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348Mr. Christopher M. CranePresident and Chief Executive Officer AmerGen Energy Company, LLC 4300 Winfield Road Warrenville, IL 60555Assistant General CounselAmerGen Energy Company, LLC 200 Exelon Way Kennett Square, PA 19348
EnclosureREQUEST FOR ADDITIONAL INFORMATIONHTP FUEL REACTOR COOLANT SYSTEM PRESSURE-TEMPERATURE SAFETY LIMITTECHNICAL SPECIFICATION AMENDMENT REQUEST TAC NO. MD4910DOCKET NO. 50-289By letter dated March 22, 2007 (Agencywide Documents Access and Management SystemAccession Number ML070860968), AmerGen Energy Company, LLC (the licensee) submitted a license amendment request (LAR) regarding Three Mile Island, Unit 1 technical specifications (TSs). The proposed amendment would involve changes associated with instrument setpoints for the reactor coolant system (RCS) pressure-temperature safety limit associated with the use of AREVA NP's Mark-B-HP fuel design. Based on the review of the information provided by the licensee, the staff has the following additional questions. 1.The licensee indicated that the transient core penalty for a specific transient core modelwas calculated based on the largest departure from nucleate boiling (DNB) ratio difference between the limiting Mark-B-HTP fuel rod in a full core model of the Mark-B-HTP fuel and specific transient core model for all of the statepoints, condition I/IIDNB transients, and axial power shapes.Discuss the results of the transient core penalty analyses for condition I/II DNBtransients with associated axial power shapes, and demonstrate that (1) the analysis scope in terms of the applicable condition I/II DNB transients and the allowable axialpower shapes is adequate, and (2) the calculated value of the transient core penalty is a bounding value and acceptable for determining the thermal design limit that is used to calculate the reactor core safety limit. 2.Provide the basis for your determination that no setpoint changes to reactor tripfunctions, other than the variable low RCS pressure trip, are needed to assure that the analyses of record remain bounding, or new analyses meet the applicable acceptance criteria for design-basis events. 3.Identify the reactor coolant pressure and reactor outlet temperature at the end pointsand mid point of proposed TS Figure 2.1-1.4.Identify the low reactor coolant pressure and high reactor outlet temperature interceptpoints of proposed TS Figure 2.3-1.5.Demonstrate that, for operation with measured values at the limits of the "AcceptableOperation" region of proposed TS Figure 2.3-1, there would be adequate assurance that the actual operating point will be conservative relative to the indicated Safety Limit line, given measurement errors consistent with the instrument channel uncertainties.
6.Identify the normal operating point for the reactor coolant pressure and reactor outlettemperature.7.Identify the low reactor coolant pressure and high reactor outlet temperature interceptpoints for:(a)TS Variable Low Pressure Trip (VLPT) Limiting Safety System Setting Setpoint(b)Adjusted TS VLPT (c)VLPT Nominal Setpoint (NSP)
(d)VLPT As-Left Tolerance Band (e)VLPT Pre-Defined As-Found Tolerance Band8.Provide additional details concerning the methodology used to develop the VLPT10 pounds per square inch gauge additional margin. Confirm that this additional margin has not been used in determining the VLPT Pre-Defined As-Found Tolerance Band.9.The licensee has stated that the VLPT setpoint calculation is prepared in accordancewith American National Standards Institute (ANSI) / Instrument Society of America (ISA)
Standard 67.04.01-2000, "Setpoints for Nuclear Safety-Related Instrumentation," and Recommended Practice ISA-RP67.04.02-2000, "Methodologies for the Determination of Setpoints for Nuclear Safety-Related Instrumentation". In order to assess the adequacy of this methodology please provide a description of:(a)the criteria (not just the methods) used for combining uncertainties indetermining trip setpoints and allowable values.(b)the relationship of the allowable value to the setpoint methodology and testingrequirements. Also, describe the method of documentation of this relationship.Providing a description of how the regulatory positions of RG 1.105, Revision 3 areincorporated into the VLPT setpoint calculations would constitute an acceptable way to address questions 9(a) and 9(b) above.10.The Summary of AmerGen Commitments includes a commitment to determine thepredefined limits for the VLPT NSP As-Found Tolerance on a programmatic basis. The licensee should clarify this commitment. Aren't the predefined limits for the VLPT NSP As-Found Tolerance Band determined and included in March 22, 2007 submittal? Why would the limits of the VLPT NSP As-Found Tolerance Band need to be recalculated on a programmatic basis? What are the periodicity or events that would trigger a recalculation of the VLPT NSP As-Found Tolerance Band? Would a recalculation of the VLPT NSP As-Found Tolerance Band be the cause for a revision to any of the VLPT related items in question 7 (a) - (d) above?