ML042870472

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Issuance of License Amendments 169 & 155 Response Time Testing Requirements
ML042870472
Person / Time
Site: LaSalle  Constellation icon.png
Issue date: 11/19/2004
From: Pickett D
NRC/NRR/DLPM/LPD3
To: Crane C
Exelon Generation Co
Pickett D, NRR/DLPM, 415-1364
References
TAC MC2354, TAC MC2355
Download: ML042870472 (21)
v • d • e


Text

November 19, 2004 Mr. Christopher M. Crane, President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2, ISSUANCE OF AMENDMENTS RE: RESPONSE TIME TESTING REQUIREMENTS (TAC NOS. MC2354 AND MC2355)

Dear Mr. Crane:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 169 to Facility Operating License No. NPF-11 and Amendment No. 155 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 12, 2004, and supplemented by letters dated June 16 and September 2, 2004.

The amendments modify the LaSalle Technical Specifications (TS) to eliminate selected response time testing requirements associated with Reactor Protection System instrumentation and Primary Containment Isolation instrumentation for Main Steam Line Isolation functions.

Specifically, the changes revise the response time testing requirements for TS Section 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," Reactor Vessel Steam Dome Pressure -

High function and TS Section 3.3.6.1, "Primary Containment Isolation Instrumentation," Reactor Vessel Water Level - Low Low Low, Level 1 and Main Steam Line Pressure - Low functions.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the NRC's biweekly Federal Register notice.

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos.: 50-373 and 50-374

Enclosures:

1. Amendment No. 169 to NPF-11
2. Amendment No. 155 to NPF-18
3. Safety Evaluation cc w/encls: See next page

November 19, 2004 Mr. Christopher M. Crane, President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

LASALLE COUNTY STATION, UNITS 1 AND 2, ISSUANCE OF AMENDMENTS RE: RESPONSE TIME TESTING REQUIREMENTS (TAC NOS. MC2354 AND MC2355)

Dear Mr. Crane:

The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 169 to Facility Operating License No. NPF-11 and Amendment No. 155 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 12, 2004, and supplemented by letters dated June 16 and September 2, 2004.

The amendments modify the LaSalle Technical Specifications (TS) to eliminate selected response time testing requirements associated with Reactor Protection System instrumentation and Primary Containment Isolation instrumentation for Main Steam Line Isolation functions.

Specifically, the changes revise the response time testing requirements for TS Section 3.3.1.1, "Reactor Protection System (RPS) Instrumentation," Reactor Vessel Steam Dome Pressure -

High function and TS Section 3.3.6.1, "Primary Containment Isolation Instrumentation," Reactor Vessel Water Level - Low Low Low, Level 1 and Main Steam Line Pressure - Low functions.

A copy of the Safety Evaluation is also enclosed. The Notice of Issuance will be included in the NRCs biweekly Federal Register notice.

Sincerely,

/RA/

Douglas V. Pickett, Senior Project Manager, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos.: 50-373 and 50-374

Enclosures:

1. Amendment No. 169 to NPF-11
2. Amendment No. 155 to NPF-18
3. Safety Evaluation cc w/encls: See next page DISTRIBUTION:

PUBLIC PDIII-2 R/F PCoates DPickett OGC, PLoeser GHill (4), T5C3 TBoyce, O-12H2 EMarinos ACRS, T2E26 SReynolds, RIII ADAMS Accession Number: ML042870472 (Letter) ML04(Tech Specs)

ML04(Package)

OFFICE PM:LPD3-2 LA:LPD3-2 SC:EEIB OGC SC:LPD3-2 NAME DPickett PCoates EMarinos* MHiggins GSuh DATE 11/15/04 11/16/04 09 / 09 /04 11/2/04 11/16/04 OFFICIAL RECORD COPY

  • See EMarinos to AMendiola memo dated September 9, 2004

LaSalle County Station Units 1 and 2 cc:

Site Vice President - LaSalle County Station Regional Administrator Exelon Generation Company, LLC U.S. NRC, Region III 2601 North 21st Road 801 Warrenville Road Marseilles, IL 61341-9757 Lisle, IL 60532-4351 LaSalle County Station Plant Manager Illinois Emergency Management Exelon Generation Company, LLC Agency 2601 North 21st Road Division of Disaster Assistance &

Marseilles, IL 61341-9757 Preparedness 110 East Adams Street Regulatory Assurance Manager - LaSalle Springfield, IL 62701-1109 Exelon Generation Company, LLC 2601 North 21st Road Document Control Desk - Licensing Marseilles, IL 61341-9757 Exelon Generation Company, LLC 4300 Winfield Road U.S. Nuclear Regulatory Commission Warrenville, IL 60555 LaSalle Resident Inspectors Office 2605 North 21st Road Senior Vice President - Nuclear Services Marseilles, IL 61341-9756 Exelon Generation Company, LLC 4300 Winfield Road Phillip P. Steptoe, Esquire Warrenville, IL 60555 Sidley and Austin One First National Plaza Vice President of Operations - Mid-West Chicago, IL 60603 Boiling Water Reactors Exelon Generation Company, LLC Assistant Attorney General 4300 Winfield Road 100 W. Randolph St. Suite 12 Warrenville, IL 60555 Chicago, IL 60601 Vice President - Licensing and Regulatory Chairman Affairs LaSalle County Board Exelon Generation Company, LLC 707 Etna Road 4300 Winfield Road Ottawa, IL 61350 Warrenville, IL 60555 Attorney General 500 S. Second Street Springfield, IL 62701 Chairman Illinois Commerce Commission 527 E. Capitol Avenue, Leland Building Springfield, IL 62706 Robert Cushing, Chief, Public Utilities Division Illinois Attorney General's Office 100 W. Randolph Street Chicago, IL 60601

LaSalle County Station Units 1 and 2 Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Associate General Counsel Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Licensing - Dresden, Quad Cities and Clinton Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-373 LASALLE COUNTY STATION, UNIT 1 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No.169 License No. NPF-11

1. 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 12, 2004, and supplemented by letters dated June 16 and September 2, 2004, 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 the Act, and the regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment 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 and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the enclosure to this license amendment and paragraph 2.C.(2) of the Facility Operating License No. NPF-11 is hereby amended to read as follows:

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment 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 be implemented within 30 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Gene Y. Suh, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: November 19, 2004

EXELON GENERATION COMPANY, LLC DOCKET NO. 50-374 LASALLE COUNTY STATION, UNIT 2 AMENDMENT TO FACILITY OPERATING LICENSE Amendment No. 155 License No. NPF-18

1. 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 12, 2004, and supplemented by letters dated June 16 and September 2, 2004, 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 the Act, and the regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment 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 and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2. Accordingly, the license is amended by changes to the Technical Specifications as indicated 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 Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 155, 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 be implemented within 30 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION

/RA/

Gene Y. Suh, Chief, Section 2 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation

Attachment:

Changes to the Technical Specifications Date of Issuance: November 19, 2004

ATTACHMENT TO LICENSE AMENDMENT NOS. 169 AND 155 FACILITY OPERATING LICENSE NOS. NPF-11 AND NPF-18 DOCKET NOS. 50-373 AND 50-374 Replace the following pages of the Appendix "A" Technical Specifications with the enclosed pages. The revised pages are identified by amendment number and contain marginal lines indicating the area of change.

Remove Pages Insert Pages 3.3.1.1-8 3.3.1.1-8 3.3.6.1-6 3.3.6.1-6

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 169 TO FACILITY OPERATING LICENSE NO. NPF-11 AND AMENDMENT NO. 155 TO FACILITY OPERATING LICENSE NO. NPF-18 EXELON GENERATION COMPANY, LLC LASALLE COUNTY STATION, UNITS 1 AND 2 DOCKET NOS. 50-373 AND 50-374

1.0 INTRODUCTION

By application dated March 12, 2004 (ADAMS Accession # ML040790358), Exelon Generation Company, LLC (the licensee) requested changes to the Technical Specifications (TS) for the LaSalle County Station, Units 1 & 2. Additional information was provided by letters dated June 16, 2004 (ADAMS Accession # ML041690155) and September 2, 2004 (ADAMS Accession # ML042460535). (Note: Public access to ADAMS has been temporarily suspended so that security reviews of publicly available documents may be performed and potentially sensitive information removed. Please check the NRC Web site for updates on the resumption of ADAMS access.)

The supplements dated June 16 and September 2, 2004, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on April 13, 2004 (69 FR 19569).

The proposed changes would modify the TS to eliminate selected response time testing (RTT) requirements associated with the Reactor Protection System and Primary Containment Isolation instrumentation. Specifically, the licensee proposes the following TS changes:

2.0 REGULATORY EVALUATION

Current standard technical specifications require nuclear power plants to periodically perform RTT for instrument channels in the RPS, the Emergency Core Cooling System (ECCS), and the Isolation Actuation System (IAS). The intent of these tests is to ensure that changes in response time of instrumentation beyond the limits assumed in safety analyses are detected and combined with instrument calibrations, to ensure that the instrumentation is operating correctly.

IEEE Standard 338-1977, which is endorsed in Regulatory Guide 1.1118, Rev. 2, defines a basis for eliminating selected RTT. Section 6.3.4 states, in part:

"Response time testing of all safety-related equipment, per se, is not required if, in lieu of response time testing, the response time of the safety system equipment is verified by functional testing, calibration check, or other tests, or both. This is acceptable if it can be demonstrated that changes in response time beyond acceptable limits are accompanied by changes in performance characteristics which are detectable during routine periodic tests."

In January 1994, the Boiling Water Reactor Owners Group (BWROG) under the auspices of the General Electric Company, issued licensing Topical Report NEDO-32291, "System Analyses for Elimination of Selected Response Time Testing Requirements." In NEDO-32291, the BWROG proposed eliminating the requirements for performance of RTT of selected instrumentation in the RPS, ECCS, and IAS. The staff approved the topical report in a safety evaluation dated December 28, 1994 (ADAMS Public Legacy Library Accession No. 9501060219).

On April 16, 1996, Commonwealth Edison Company, the licensee for LaSalle County Station, Units 1 & 2, submitted a license amendment request to take advantage of NEDO-32291. This change eliminated the requirement to perform response time testing for selected sensors and specified loop instrumentation for RPS, IAS, and ECCS. This amendment request was approved on August 14, 1996 (ADAMS Accession No. ML021130157).

On November 4, 1997, the BWROG submitted Supplement 1 to Topical Report NEDO-32291 to expand the scope of RTT elimination. In Supplement 1, the BWROG requested the elimination of RTT for six groups of components in instrument loops with shorter response time requirements. These loops have response time requirements between 300 and 5000 msec.

The requested elimination was based upon a failure modes and effects analysis (FMEA) performed on one selected component within each group and a similarity analysis showing the FMEA was bounding on all components within the group. The FMEA showed that any credible failure of any component would either be bounded by a bounding response time or would be detected by other surveillances. The U.S. Nuclear Regulatory Commission staff approved Supplement 1 in a safety evaluation dated June 11, 1999.

3.0 TECHNICAL EVALUATION

3.1 Technical Specification Changes The proposed TS changes would eliminate the requirement to perform response time testing for the RPS Instrumentation function Reactor Pressure Steam Dome Pressure-High and the Primary Containment Isolation Instrumentation functions Reactor Vessel Water Level - Low Low Low, Level 1 and Main Steam Line Pressure - Low. This elimination would include the logic and trip units and the output relays. The RTT functions and the components which will no longer be tested were addressed in NEDO 32291, Supplement 1, and were approved in the staffs safety evaluation for that topical report.

TS Section 3.3.1.1, Reactor Protection System (RPS) Instrumentation The application proposes to remove the reference to SR 3.3.1.1.17 from Table 3.3.1.1-1, Function 3, Reactor Vessel Steam Dome Pressure - High, and therefore eliminate the requirement to perform response time testing for this function.

TS Table 3.3.1.1-1 Function 3, Reactor Vessel Steam Dome Pressure - High, currently states:

APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE

3. Reactor Vessel Steam 1, 2 2 G SR 3.3.1.1.9 # 1059.0 psig Dome Pressure - High SR 3.3.1.1.10 SR 3.3.1.1.15 SR 3.3.1.1.17 The licensee proposes to revise this function to state:

APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE

3. Reactor Vessel Steam 1, 2 2 G SR 3.3.1.1.9 # 1059.0 psig Dome Pressure - High SR 3.3.1.1.10 SR 3.3.1.1.15 TS Section 3.3.6.1, Primary Containment Isolation Instrumentation, The application proposes to remove references to SR 3.3.6.1.6 from Table 3.3.6.1, Function 1.a, Reactor Vessel Water Level - Low Low Low, Level 1" and Function 1.b, Main Steam Line Pressure - Low, and therefore eliminate the requirement to perform response time testing for these functions.

TS Table 3.3.6.1-1 Function 1.a, Reactor Vessel Water Level - Low Low Low, Level 1, and Function 1.b, Main Steam Line Pressure - Low, currently state:

APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE 1 Main Steam Line Isolation A. Reactor Vessel Water 1, 2, 3 2 D SR 3.3.6.1.1 $-137.0 Inches Level - Low Low Low, SR 3.3.6.1.2 Level 1 SR 3.3.6.1.4 SR 3.3.6.1.5 SR 3.3.6.1.6 B. Main Steam Line 1 2 E SR 3.3.6.1.2 $ 826.5 psig Pressure - Low SR 3.3.6.1.3 SR 3.3.6.1.5 SR 3.3.6.1.6 The licensee proposes to revise these functions to state:

APPLICABLE CONDITIONS MODES OR REQUIRED REFERENCED OTHER CHANNELS FROM SPECIFIED PER TRIP REQUIRED SURVEILLANCE ALLOWABLE FUNCTION CONDITIONS SYSTEM ACTION D.1 REQUIREMENTS VALUE 1 Main Steam Line Isolation A. Reactor Vessel Water 1, 2, 3 2 D SR 3.3.6.1.1 $-137.0 Inches Level - Low Low Low, SR 3.3.6.1.2 Level 1 SR 3.3.6.1.4 SR 3.3.6.1.5 B. Main Steam Line 1 2 E SR 3.3.6.1.2 $ 826.5 psig Pressure - Low SR 3.3.6.1.3 SR 3.3.6.1.5 The TS Bases sections will also change. The second paragraph of TS Bases SR 3.3.1.1.17 will be modified to reflect this change. The second paragraph currently states:

RPS RESPONSE TIME may be verified by actual response time measurements in any series of sequential, overlapping, or total channel measurement. However, the sensors for Functions 3 and 4 are allowed to be excluded from specific RPS RESPONSE TIME measurement if the conditions of Reference 12 are satisfied. If these conditions are satisfied, sensor response time may be allocated based on either assumed design sensor response time or the manufacturers stated design response time. When the requirements of Reference 12 are not satisfied, sensor response time must be measured. Also, regardless of whether or not the sensor response time is measured, the response time for the remaining portion of the channel, including the trip unit and relay logic, is required to be measured. In addition, the response time of the limit switches for Function 8 may be assumed to be the design limit switch response time and therefore, are excluded from the RPS RESPONSE TIME testing. This is allowed, as documented in Reference 13, since the actual measurement of the limit switch

response time is not practicable as this test is done during the refueling outage when the turbine stop valves are fully closed, and thus the limit switch in the RPS circuitry is open. The design limit switch response time is 10 ms.

The licensee proposes to modify this paragraph to state:

RPS RESPONSE TIME may be verified by actual response time measurements in any series of sequential, overlapping, or total channel measurement. However, the sensor for Function 4 is allowed to be excluded from specific RPS RESPONSE TIME measurement if the conditions of Reference 12 are satisfied. If these conditions are satisfied, sensor response time may be allocated based on either assumed design sensor response time or the manufacturers stated design response time. When the requirements of Reference 12 are not satisfied, sensor response time must be measured. Also, regardless of whether or not the sensor response time is measured, the response time for the remaining portion of the channel, including the trip unit and relay logic, is required to be measured. The sensor and relay/logic components for Function 3 are assumed to operate at the design response time and therefore, are excluded from specific RPS RESPONSE TIME measurement. This allowance is supported by References 12 and 14, which determined that significant degradation of the channel response time can be detected during performance of other Technical Specification surveillance requirements. In addition, the response time of the limit switches for Function 8 may be assumed to be the design limit switch response time and therefore, are excluded from the RPS RESPONSE TIME testing. This is allowed, as documented in Reference 13, since the actual measurement of the limit switch response time is not practicable as this test is done during the refueling outage when the turbine stop valves are fully closed, and thus the limit switch in the RPS circuitry is open. The design limit switch response time is 10 ms.

The licensee proposes to modify TS Basis 3.3.1.1 References by adding reference 14, which will state:

14. NEDO-32291-A, Supplement 1, System Analyses for the Elimination of Selected Response Time Testing Requirements, October 1999.

The licensee proposes to revise the third paragraph of TS Bases SR 3.3.6.1.6. The paragraph currently states:

ISOLATION SYSTEM RESPONSE TIME may be verified by actual response time measurements in any series of sequential, overlapping, or total channel measurements.

However, the sensors for Functions 1.a, 1.b, and 1.c are allowed to be excluded from specific ISOLATION SYSTEM RESPONSE TIME measurement if the conditions of Reference 12 are satisfied. If these conditions are satisfied, sensor response time may be allocated based on either assumed design sensor response time or the manufacturer's stated design response time. When the requirements of Reference 12 are not satisfied, sensor response time must be measured. Also, regardless of whether or not the sensor response time is measured, the response time of the remaining portion of the channel, including the trip unit and relay logic, is required to be measured.

The licensee proposes to revise this paragraph to state:

ISOLATION SYSTEM RESPONSE TIME may be verified by actual response time measurements in any series of sequential, overlapping, or total channel measurements.

However, the sensor for Function 1.c is allowed to be excluded from specific ISOLATION SYSTEM RESPONSE TIME measurement if the conditions of Reference 12 are satisfied. If these conditions are satisfied, sensor response time may be allocated based on either assumed design sensor response time or the manufacturer's stated design response time. When the requirements of Reference 12 are not satisfied, sensor response time must be measured. Also, regardless of whether or not the sensor response time is measured, the response time of the remaining portion of the channel, including the trip unit and relay logic, is required to be measured. The sensor and relay/logic components for Functions 1.a and 1.b are assumed to operate at the design response time and therefore, are excluded from specific RPS RESPONSE TIME measurement. This allowance is supported by References 12 and 13, which determined that significant degradation of the channel response time can be detected during performance of other Technical Specification surveillance requirements.

The licensee proposes to revise TS Bases 3.3.6.1 References by adding reference 13, which will state:

13. NEDO-32291-A, Supplement 1, System Analyses for the Elimination of Selected Response Time Testing Requirements, October 1999.

The staff has reviewed these TS Bases changes, and concurs that these are the appropriate changes to the LaSalle Units 1 and 2 TS to eliminate the RTT requirement for the functions discussed.

3.2 Bounding Response Times In Supplement 1 to NEDO-32291, the BWROG requested elimination of RTT for six groups of components. The FMEA for these components has shown that the degree to which a component response time can degrade and still not be identified by other surveillance tests is limited. The limit to which response time of a component can degrade without detection by other routine surveillances or calibration was called the bounding response time (BRT) of that component. Response time degradation beyond the BRT will be detected by routine surveillances or calibration. The licensee, in their request, has four components, the GE 12HFA151A9 series relay, the Agastat EGPB series relay, the Rosemount 710DU.series trip unit, and the GE series CR105 scram contactor, for which they have requested RTT elimination. The instrument loops and the bounding response times for the four components are shown in the tables in Attachment 1 of the application, and are provided below:

Reactor Protection System, Reactor Vessel Steam Dome Pressure - High Loop type K Sensor Logic Relay Output Loop Logic BRT Total Loop Required BRT (msec) Contactor (msec) BRT (msec) Response Time (msec) (msec) (msec)

GE Relay GE CR305 465 40 45 85 550 550 Primary Containment Isolation Instrumentation Reactor Vessel Water Level - Low Low Low, Level 1 Loop type E Sensor Trip Unit TU Output Logic Output Loop Logic Total Loop Required BRT (TU) Relay Relay Contactor BRT BRT Response (msec) (msec) (msec) (msec) (msec) (msec) (msec) Time (msec)

Rosemount Agastat GE HFA GE HFA 710DU TU 756 24 140 40 40 244 1000 1000 Primary Containment Isolation Instrumentation Main Steam Line Pressure - Low Loop type J Sensor Logic Relay Auxiliary Output Loop Logic Total Loop Required BRT (msec) Relay Contactor BRT BRT (msec) Response (msec) (msec) (msec) (msec) Time (msec)

GE HFA GE HFA GE HFA 1880 40 40 40 120 2000 2000 3.2.1 Sensor Bounding Response Times The sensors for these trip functions have been previously approved in a staff safety evaluation dated August 14, 1996, approving Amendment No. 114 to Facility Operating License NPF-11 for the LaSalle County Station Unit 1, and Amendment No. 99 to Facility Operating License NPF-18 for the LaSalle County Station Unit 2. No BRT was approved in that license amendment and, therefore, the value for the BRT must be established. In their letter dated September 2, 2004, the licensee stated that they had collected and evaluated the available historical response time testing data for the sensor types used for the three loops. The BRT was calculated by adding the average response time to an amount of variation that would provide a 95% probability with a 95% confidence (i.e., 95/95 value) that future response time data would be less than this BRT. In all cases, the BRT value for the 95/95 condition was less than the BRT provided in the original license amendment application dated March 12, 2004.

When determining an allocated response time based upon historic test values, the staff requires licensees to use a 95/95 value, that is, a value chosen such that there is a 95%

confidence that 95% of all response time test values will be less than the allocated response time as defined in NUREG-1475. The staff verified that the BRT values are statistically valid by determination of the mean and 2 sigma standard deviation value of response time (value which represents 95% confidence level by definition). The staff then determined the one sided tolerance limit factor for a normal distribution for a 95/95% confidence level. This was done using guidance in Applying Statistics, NUREG-1475, Table T-11b: One sided tolerance limit factor for a normal distribution.

The results of these calculations are as shown below:

Sensor SOR 9N6-B45-NX-C1A-JJTTX6 used in Loop Type K Function Steam Dome Pressure - High Mean 0.139 seconds Standard Deviation 0.097 seconds Sample Size 14 One sided tolerance limit factor 3.614 (95/95 Multiplier IAW NUREG 1475)

One sided tolerance limit 0.392 seconds LaSalle BRT value 0.465 seconds Sensor Rosemount 1153 Range Code 5 used in Loop Type E Function Reactor Vessel Water Level - Low Low Low, Level 1 Mean 0.110 seconds Standard Deviation 0.063 seconds Sample Size 18 One sided tolerance limit factor 2.453 (95/95 Multiplier IAW NUREG 1475)

One sided tolerance limit 0.264 seconds LaSalle BRT value 0.756 seconds Sensor SOR 9N6-B45-NX-C1A-JJTTX6 used in Loop Type J Function Main Steam Line Pressure - Low Mean 0.559 seconds Standard Deviation 0.414 seconds Sample Size 19 One sided tolerance limit factor 2.425 (95/95 Multiplier IAW NUREG 1475)

One sided tolerance limit 1.563 seconds LaSalle BRT value 1.880 seconds In each case above, the one sided tolerance limit is lower than the BRT. Therefore, the BRT values are acceptable to the staff.

3.2.2 Component Bounding Response Times The specific components included in this request for which RTT elimination has been requested, and the associated BRT, is shown below:

Component BRT GE Model 12HFA 151A9 Relay 40 msec Agastat Model EGPB Relay 140 msec Rosemount 710DU series trip unit 24 msec GE Model CR105 Scram Contactor 45 msec These values were previously approved in the staff safety evaluation for NEDO-32291-A Supplement 1, and are therefore acceptable.

For each of the above instrumentation loop types, the total BRT is no greater than the accident analysis required response time, and is therefore acceptable.

3.3 Verification of Component Specific Conditions In approving NEDO-32291-A Supplement 1, the NRC staff stipulated that licensees must address specific conditions identified in the staffs safety evaluation for components for which RTT is no longer being required, to ensure that the bounding response time is valid. The four components for which the licensee has requested elimination of response time testing are: GE Model 12HFA 151A9 Relays, Agastat Model EGPB Relays, Rosemount 710DU Series Trip Units, and GE Model CR305 Magnetic Contactors.

3.3.1 GE Model 12HFA 151A9 Relay For the GE Model 12HFA 151A9 relays, the approved bounding response time was determined to be 40 ms, based on the following requirement:

1. The HFA manufacturer's instructions are followed for setup and adjustment of the relay before initial operation and after any repair or maintenance.
2. Before installation, or after any maintenance or repair of the relays, the normally open contacts of the relays are confirmed to open in 20 msec or less after power is removed from the coil.
3. The relays are procured by the utility as nuclear safety related, or are dedicated for nuclear-safety-related application under a utility dedication program.

In their amendment application, the licensee stated that:

1. The manufacturer's instructions for setup and adjustment of the relay will be proceduralized. These procedures will be performed before initial operation and after any repair or maintenance.
2. The calibration procedure will be revised to include a requirement for verification that the normally open contacts of the relays open in 20 msec or less after the power is removed from the coil. The procedure will be revised to include this verification before installation or after maintenance or repair of the relays.
3. The relays are procured as nuclear safety related.
4. These relays are used as normally open, energized in the untripped state, with power removed and contacts closed to trip.

The staff has reviewed the licensees response and has determined that it satisfies the component specific requirement as shown in the staffs safety evaluation for NEDO-32291-A Supplement 1, and is, therefore, acceptable.

3.3.2 Agastat Model EGPB Relay For the Agastat EGPB relays, the approved bounding response time was determined to be 140 ms, based on the following requirements:

1. Before installation, or after any maintenance or repair of the relays, the normally open contacts of the relays are confirmed to open in 70 msec or less after power is removed from the coil.
2. The relays are within their qualified life.
3. The relays are procured by the utility as nuclear safety related, or are dedicated for nuclear-safety-related application under a utility dedication program.

In their amendment application, the licensee stated that:

1. The calibration procedures will be revised to include a step requiring a response time test of the relay to be performed before returning the relay to service after repair or maintenance. The normally open contacts will be confirmed to open in 70 msec or less after power is removed from the coil. The testing as specified here would be required "prior to return to service" rather than "prior to installation" as it is acceptable to perform this testing on the bench or installed.
2. The relays have been verified to be within their qualified life.
3. The relays are procured as nuclear safety related.

The staff has reviewed the licensee response, and has determined that it satisfies the component specific requirement as shown in the staffs safety evaluation for NEDO-32291-A Supplement 1, and is, therefore, acceptable.

3.3.3 Rosemount 710DU Series Trip Unit For the Rosemount 710DU series, the approved bounding response time was determined to be 24 msec based on the trip units being procured by the utility as nuclear safety related or being dedicated for nuclear-safety-related application under a utility dedication program.

In their license amendment request, the licensee stated that the trip units are procured as nuclear safety related.

The staff has reviewed the licensee response and has determined that it satisfies the component specific requirement as shown in the staffs safety evaluation for NEDO-32291-A Supplement 1, and is, therefore, acceptable.

3.3.4 GE Model CR305 Magnetic Contactor The approved bounding response time for the GE Model CR305 magnetic contactors was determined to be either 65 msec if the APRM upscale trip test is performed as a total loop or 45 msec if the APRM upscale trip is tested in overlapping partial tests. In this case, the requirement was to determine which of the two postulated test methods are used and to use the appropriate BRT for the test method used.

In their license amendment request, the licensee stated that:

1. RPS scram contactor components are tested as part of the APRM upscale trip RTT, that the APRM upscale trip RTT is currently performed in overlapping partial tests, and that the APRM section is tested separately from the scram contactors.
2. The APRM upscale trip RTT is performed as a phased test with the APRM section tested separately from the scram contactors, and the acceptance criteria for the scram contactor and one interposing relay, not shared by other loops, is less than or equal to 50 msec.
3. Based upon the test method used, a BRT of 45 msec is appropriate.

The staff has reviewed the licensee response and has determined that it satisfies the component specific requirement as shown in the staffs safety evaluation for NEDO-32291-A Supplement 1, and, therefore, a BRT of 45 msec is acceptable.

Based upon the above review, the staff finds that the licensee has implemented the provisions of the staffs safety evaluation for RTT elimination and has satisfied the component specific requirements in accordance with the approved NEDO-32291-A Supplement 1. Therefore, the staff has concluded that the proposed Lasalle County Station, Units 1 & 2 TS modifications are acceptable.

4.0 STATE CONSULTATION

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

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of a facility component 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. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding (69 FR 19569). 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.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is 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: Paul Loeser, NRR/DE Date: November 19, 2004

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