RS-13-092, License Amendment Request to Revise Peak Calculated Primary Containment Internal Pressure

License Amendment Request to Revise Peak Calculated Primary Containment Internal Pressure

ML13249A231
Person / Time
Site:	LaSalle
Issue date:	09/05/2013
From:	Gullott D Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-13-092
Download: ML13249A231 (14)

Text

1

2000 RS-13-092 10 CFR 10 CFR 50.90 September 5, 2013 U. S. Nuclear Nuclear Regulatory Regulatory Commission Commission ATTN: Document Control Control Desk Washington, DC Washington, DC 20555-0001 LaSalle County Station, Units 1 and 22 Facility Operating License Nos. Nos. NPF-11 NPF-11 and and NPF-18 NPF-18 NRC Docket Nos. 50-373 and 50-374 50-374

Subject:

License Amendment Amendment Request to Revise Peak Peak Calculated Calculated Primary Primary Containment Containment Internal Pressure Internal Pressure In accordance In accordance withwith 10 CFR 50.90,50.90, "Application "Application forfor amendment amendment of license, constructionconstruction permit, permit, or or early site permit," Exelon Generation Company, permit," Exelon Company, LLC LLC (EGC) requests requests an anamendment amendmenttotoFacilityFacility Operating License License Nos.

Nos. NPF-1 NPF-111 and NPF-18 NPF-18 for LaSalle County Station (LSCS), (LSCS), UnitsUnits 11 and and 2.

2.

The proposed proposed change would revise the peak calculated primary containment internal pressurefor change would revise the peak calculated primary containment internal pressure for the design design basis basisloss-of-coolant loss-of-coolantaccident accident(LOCA)

(LOCA) described described in in TS TS 5.5.13, 5.5.13, "Primary "Primary Containment Containment Leakage Rate Testing Program."Program." The Thepeak peakcalculated calculatedprimary primarycontainment containmentinternal internal pressure, pressure,Pa, Pa ,

is increased from 39.9 psig to 42.6 psig. The Theproposed proposedincrease increaseininPa Paisisthe theresult resultofofaaLOCA-LOCA-DrywellTemperature Drywell Temperature sensitivity analysis performedperformed by by General GeneralElectric ElectricHitachi Hitachi(GEH).

(GEH).

Plant operations operations in in TS TS 5.5.13 5.5.13 arearecurrently currentlyadministratively administratively controlled controlled under underthe theprovisions provisionsof of NRC Administrative Administrative Letter (AL) (AL)98-10, 98-10, "Dispositioning "Dispositioning of ofTechnical Technical Specifications Specifications that are that are InsufficienttotoAssure Insufficient AssurePlant PlantSafety,"

Safety,"totoassure assure that that plant plant safety safety isis maintained.

maintained. This license amendment amendment request request isissubmitted submitted in in accordance accordancewith with the the guidance guidancein in AL AL 98-10. In In accordance accordance with the guidance with the guidance of of AL AL98-10, 98-10,EGCEGCsubmits submitsthe theproposed proposed change change as aa required required license license amendment amendment request request to to resolve resolve aa non-conservative non-conservative TS. TS. As Assuch, such,thisthisisisnot notaa"voluntary "voluntary request request from from a licensee licensee to to change changeits itslicensing licensing basis" basis"andandshould shouldnot notbe besubject subjecttoto"forward "forwardfit"fit" considerations.

The attached attached request requestisissubdivided subdivided as asfollows:

follows:

- Attachment 1 provides provides an an evaluation evaluation of of the the proposed proposed change.

change.

- Attachment 2 provides provides the the current current TSTS page with with thethe proposed changechange indicated.

indicated.

The proposed proposed amendment amendmenthas hasbeen beenreviewed reviewedby bythe theLSCS LSCSPlantPlantOperations OperationsReview ReviewCommittee Committee and approved approved byby the theNuclear NuclearSafety SafetyReview Review Board Board in in accordance accordancewith with the therequirements requirementsofofthe the EGC Quality Quality Assurance Assurance Program.

Program.

EGC requests approval of the proposed license amendment by September 5, 2014. Once Once approved, the amendment amendment will will be be implemented implementedwithin within60 60days.

days.

September 5, 2013 U. S. Nuclear Regulatory Commission U.

Page 2 In accordance In accordance withwith 10 CFR 50.91, 50.91, "Notice "Notice for public public comment; comment; State consultation," paragraph paragraph (b),

(b),

EGC is notifying the State of Illinois notifying the ofthis Illinois of thisapplication application forforlicense license amendment amendment by by transmitting aa copy ofof this this letter letter and and its its attachments attachments to the designated designatedStateStateOfficial.

Official.

There are no no regulatory regulatory commitments contained in this letter.

in this letter. Should Should you have anyany questions questions concerning this letter, please please contact contact Ms.

Ms. Lisa Lisa A.

A. Simpson at at (630)

(630) 657-2815.

657-2815.

II declare declare under penalty of perjury perjury that that the the foregoing foregoing isis true true and and correct.

correct. Executed Executedononthe the5th 5thday day of September of September 2013.2013.

Respectfully, Z?/41c:t:/

David M. Gullott Gullott Manager - Licensing licenSing Exelon Generation Company, LLC LLC Attachments:

1)) Evaluation of Proposed Change 1

2) Markup Markup of of Technical Technical Specifications Specifications PagePage cc: NRC Regional Administrator, Region Region III III NRC Senior Resident Inspector, LaSalle LaSalle County County Station Station IllinoisEmergency Illinois Emergency Management Management Agency Agency - Division Division ofof Nuclear Nuclear Safety Safety

ATTACHMENT ATTACHMENT11 Evaluation of Proposed Change

Subject:

License Amendment Request to Revise Revise Peak PeakCalculated Calculated Primary Containment Internal Pressure Internal Pressure 1.0

SUMMARY

DESCRIPTION 2.0 DETAILED DESCRIPTION DESCRIPTION

5.0 REGULATORY EVALUATION

EVALUATION 5.1 Applicable Regulatory Requirements/Criteria Applicable 5.2 No Significant No Significant Hazards Hazards Consideration 5.3 Conclusions

7.0 REFERENCES

11 of 10

ATTACHMENT 11 ATTACHMENT Evaluation of Proposed Evaluation Proposed Change 1.0 1.0

SUMMARY

DESCRIPTION This evaluation This evaluation supports aa request requestto to amend amendFacility Facility Operating Operating License License Nos.

Nos. NPF-1 NPF-111 and NPF-1 8for NPF-18 forLaSalle LaSalleCountyCounty Station, Station, Units Units 1 and 2.

Exelon Generation Company, LLC Exelon LLC (EGC) proposes to to revise revise the the peak peakcalculated calculatedprimary primary containment internal containment internalpressure pressure for forthe thedesign design basis basis loss-of-coolant loss-of-coolant accident accident (LOCA) described in in Technical Specifications (TS)

Technical (TS) 5.5.13, 5.5 .13, "Primary "Primary Containment Containment Leakage Rate Testing Leakage Rate Testing Program."

Program."

The proposed change changewould wouldrevise revisethe thepeak peakcalculated calculatedprimary primarycontainment containmentinternal internal pressure, pressure, Pa, P from39.9 a, from 39.9 psig psig to to 42.6 42.6 psig.

The proposed proposed increase increaseininPa is the Pais theresult resultofofaaLOCA-Drywell Temperature sensitivity LOCA-Drywell Temperature sensitivity analysis performed by GeneralGeneral Electric Hitachi (GEH). The GEH sensitivity analysis(2012 Electric Hitachi (GEH). The GEH sensitivity analysis (2012GEH GEHAnalysis, Analysis, Reference 1)

Reference 1) indicated indicated thatthatPa is higher Pais higherwhen whenusing usingan aninitial initiallower lowerdrywell drywell temperature temperature(98 (98°F)

OF) versus the maximum allowable drywell maximum allowable drywelltemperature temperature(135 (135OF).°F). The The proposed increase increase alsoalso various secondary issues incorporates various issues affecting affecting the analysis analysis of of record record (AOR) (Reference 2).

(AOR) (Reference 2). The The utilizingaa drywell result of utilizing drywelltemperature temperature inputinput ofof 98 98 of OFandandthe theeffect effectof ofthe thesecondary secondary issues issues isis aa Paa of P of 42.6 42.6 psig.

EGC requested EGC requested GEH GEH to to perform perform the the sensitivity sensitivity analysis analysis in in support support of of the the LSCS LSCS Extended ExtendedPowerPower Uprate (EPU)

Uprate (EPU) project.

project. On June June 11,11, 2013, 2013, EGC EGC announced announcedthe thecancellation cancellation of of its its LSCS LSCS EPUEPU project; however, project; however, the the cancellation cancellation of ofEPU EPUdoesdoes not not negate negate the need for the proposed change. change.

In accordance In accordance with with NRC NRC Administrative Administrative LetterLetter(AL)

(AL) 98-10, "Dispositioning "Dispositioning of of Technical Technical Specifications that are Insufficient to Assure Insufficient to Assure Plant Safety," (Reference (Reference 3), administrative controls 3), administrative implemented under EGC Operability EvaluationOE Operability Evaluation OE 11-002 11-002 (Reference (Reference 4) 4) assure assure that plant plant safety is maintained. In In accordance accordancewith with the theguidance guidanceofofAL AL 98-10, 98-10, EGC EGC submits submits the the proposed proposed change as as aa required required license license amendment amendment requestrequest to to resolve resolve aa non-conservative non-conservative TS. TS. AsAs such, such, this is not a "voluntary request from "voluntary request from aa licensee to changechange its its licensing licensing basis" basis" and and should should not notbebe subject to subject to "forward "forward fit" considerations.

fit" considerations.

Approval Approval of ofthis thisamendment amendment application applicationisisrequested requested by by September September 5, 5, 2014.

2014. OnceOnceapproved, approved, the amendment amendment will will be implemented implemented within within 60 days.

2.0 DETAILED DESCRIPTION TS 5.5.13.b currently currently states:

states:

"The "The peak calculated primary containment internal internal pressure pressure for the design basis basis loss lossofof coolant accident, Pa, Pa, is is 39.9 39.9 psig."

psig."

The proposed proposed changechangewould would revise reviseTS TS5.5.13.b 5.5.13.bby byreplacing replacingthe thePaPavalue valueof of39.9 39.9psig psigwith with aa value of of 42.6 42.6 psig.

psig.

2 of 10 10

ATTACHMENT 11 ATTACHMENT Evaluation of Proposed Evaluation Proposed Change The revised TS 5.5.13.b would state as follows:

The "The peak liThe peak calculated primary containment internal primary containment internal pressure pressure for the the design basis basis loss lossofof coolant accident, Pa, Pa , is is 42.6 42.6 psig."

psig."

Attachment 22 provides Attachment provides mark-ups mark-ups of ofthetheaffected affectedTS TSpages pages forforthethe proposed proposed change.

3.0 BACKGROUND

Peak containment internal pressure during internal pressure during a LOCA LOCA is calculated to to determine, determine, in in part, part, whether whether the design pressure pressure limit for the limit for the containment containment building buildingwouldwouldbe beexceeded exceeded during during aa design basis basis accident. LSCS TS 5.5.13, 5.5.13, "Primary Containment Leakage "Primary Containment Leakage Rate Rate Testing Program," describes Program," describes the peak peak calculated calculated primary containment internal primary containment internalpressure pressure during duringthe the design design basis basis LOCA, Pa- Pa .

A LOCA is initiated initiated by by the the rupture rupture of of the the primary primarycoolant coolant system system piping.

piping. The primary primary coolant flashes to steam and escapes escapesthrough through the the pipe pipe break.

break. As As the the steam steam isisreleased releasedto tocontainment, containment, containment atmosphere pressure pressureand andtemperature temperature quickly quickly increase.

increase. During a LOCA LOCA event, the initialblow initial blowdowndownofofthe theprimary primarycoolantcoolantsystem systemaddsadds mass mass and energyenergyto to the thecontainment.

containment.

The current LSCS AOR AOR peak peak calculated primary containment internal primary containment internal pressure, pressure, Pa, Pa , is 39.9 psig, as stated stated inin the the LSCSLSCS UFSARUFSAR and and TS TS (Reference TS TS 5.5.13 and UFSAR 6.2.1.1.3). Results UFSAR 6.2.1.1.3). Results of of the 2012 2012 GEHGEH Analysis Analysis concluded that that the the peak peakcalculated calculatedprimary primarycontainment containmentinternal internal pressure, Pa, pressure, Pa , is is 42.6 42.6 psig, psig, which which is 2.7 psig psig higher higher than the the value value determined determinedin in the theAOR AOR (i.e.,

(Le.,

42.6 psig - 39.9 39.9 psigpsig == 2.7 2.7 psig).

psig). ThisThisproposed proposedincrease increasetotoPaPaincludes includesboth boththetheeffects effectsofofusing using the lower drywelltemperature lower drywell temperature and and the secondary secondary issues issuesregarding regardingthe theAOR.

AOR.

The proposed proposed increase increasein in Pa Pa isis the the result result of a LOCA-Drywell LOCA-Drywell Temperature Temperature sensitivity sensitivity analysis analysis performed by performed by GEHGEH (2012 (2012 GEH GEH Analysis)

Analysis) in in support support of of the the LSCS LSCS EPU EPU project.

project. The The 20122012GEHGEH Analysis indicated indicated that Pa Pa is higher when using using anan initial initial lower drywell drywell temperature temperature (98 (98 °F)

OF) versus versus the maximum TS allowable drywell temperature (135 drywell temperature (135 OF).

°F). The The effect effectof ofusing usingthe thelower lowerdrywell drywell temperature increases Pa temperature increases Pa by 1.3 1.3 psig.

psig.

During During the the process process of of GEH conducting and EGC EGC reviewing reviewing the analysis, analysis, additional additional secondary secondary issues issues were were identified regarding the identified regarding the AOR AOR thatthat also also impact impact PPa. a . These issuesissuesinclude include the the Main Main Steam Steam Safety Safety Relief Relief Valve Valve (SRV)

(SRV) setpoints, the closure closure time time forfor the Main Main SteamSteam Isolation Isolation Valves Valves (MSIVs),

(MSIVs), the the core core flow flowconditions conditions permitted permitted by by the the Power/Flow Power/Flow Map, Map, and and the reactor reactor powerpower level.

level.

The new Analysis Analysiscorrects correctsthese these issues.

issues. GEHGEH has has addressed addressedeach eachissueissuethrough throughtheir theircorrective corrective action program.

program. The The cumulative cumulative effect of of these these secondary secondary issues increases increases Pa Pa by 1.4 psig.

Although Although EGC EGC canceled canceled the EPU project for for LSCS, LSCS, thisthis does does not negatenegate the the need needfor for the the proposed proposed change.

change. InInaccordance accordancewith withthe theguidance guidanceofofAL AL 98-10, 98-10, EGC EGC submits submits the the proposed proposed change as as aarequired required license license amendment amendmentrequest requestto toresolve resolvethe thenon-conservative non-conservative TS. TS.

4.0 TECHNICAL TECHNICAL EVALUATION EVALUATION The proposedTheincrease proposed to Pa incorporates increase an increase to Pa incorporates resulting an increase from from resulting usingusingthe the lower lowerdrywell drywell temperature and and anan increase increaseresulting resulting from from secondary secondary issues issuesregarding regardingthe theAOR.

AOA.

3 of 1010

ATTACHMENT 11 ATTACHMENT Evaluation of Proposed Change Evaluation DrywellTemperature Initial Drywell Temperature The current LSCS containmentcontainment AOR ADR (GE Project Task Task Report Report GE-NE-A1300384-02-01-R3, GE-NE-A1300384-02-01-R3, which is which is documented documented in in Design Design Analysis Analysis L-002874)

L-002874) used usedan aninitial initialdrywell drywell temperature temperatureofof135 135OF, of, which is which is the the maximum maximum value value allowed allowed by byTS TS (Reference (Reference TS TS 3.6.1.5).

3.6.1.5). The The 2012 2012GEH GEH Analysis Analysis indicated that indicated that the the peak calculated primary primary containment internal pressure pressure isis higher higher when when using using anan initiallower initial lowerdrywell drywelltemperature temperature (98 (98 OF)

°F)versus versus the maximum TS allowable drywell temperature drywell temperature (135 °F).

OF).

The 2012 GEH GEH Analysis Analysis uses usesan aninitial initial drywell drywell temperature temperatureof of9898OF of based based upon uponhistorical historicalbulkbulk average drywell average temperature data drywell temperature data forfor the time period of June June 1, 1, 2007, 2007, through through MarchMarch 22, 2011.

The evaluation examined the bulk bulk average average drywell drywell temperature in in one one hour hour increments increments to to ensure ensure that time time of of the the day day andand operating operating variations variations were were captured.

captured. The evaluation The evaluation includedincluded 2 sigma standard deviation standard deviation and andfoundfoundthat thatwhen whenthe theplant plantoperates operates at at

>_2:90%90%power powerlevel, level,the thedrywell drywell temperature will temperature will be be >_ 100of.

2: 100 OF.TheThe drywell drywelltemperature temperature of of 98 ofOFwaswas selected selected to add add conservatism.

The useuse ofof the the TSTS limiting drywelltemperature limiting drywell temperature as input input for the containment analysis analysis is is conservative in the determination of of the the peak drywell temperature; however, drywell temperature; however, the use of of the maximum TS maximum TS allowable allowable drywell drywelltemperature temperature is is not conservative in relation relation to to the peak calculated calculated primary containment primary containment internal pressure, pressure,Pa. Pa .TheTheeffect effectofofusing usingthe thelower lowerinitial initialdrywell drywell temperature increases increasesPa Pa by by 1.3 1.3 psig.

psig.

Secondary AOR Issues During the During the process of of GEH conducting and EGC EGC reviewing reviewing the analysis, analysis, additional additional secondary secondary issues were issues were identified identified regarding the AOR that also impacts Pa. Pa

• Exelon Exelon requested requestedthat thatGEHGEH evaluate the secondary secondary issues issuesused usedininthe thecontainment containmentanalysis analysistotodetermine determinehow howtheytheymaymay affect P affect Pa.

a . GEH has addressed addressed each each ofofthe the secondary secondary issues issues through through their their corrective corrective action action program. The program. The 2012 2012 GEHGEH Analysis corrects these Analysis corrects these issues. The Thecumulative cumulative effecteffect of these secondary issues issuesincreases increasesPa Paby by1.4 1.4psig.

psig.The Theissues issues identified identifiedduring duringthe thereview reviewof ofthe the 2012 GEH GEH Analysis Analysis include includethe thefollowing:

following:

• Main Main Steam Safety Safety Relief Relief Valve Valve (SRV) Setpoints Setpoints The Main Main Steam SRV setpoints used usedin in the the 2012 2012GEH GEH Analysis Analysis impact impact the Pa Pa results because because the theopening opening of of the the SRVs SRVs directs directs energy energy fromfrom the reactor reactor pressure pressurevesselvessel (RPV)

(RPV) to to the the suppression suppression pool pool instead insteadof ofreleasing releasingthe theenergy energytotothe thedrywell drywellthrough through the break.

break. HigherHigherSRVSRV setpoints setpoints result result inin the the SRVs SRVs remaining remaining closed longer, longer, thus directing directing more more energy to the drywell. drywell. The LSCS LSCS SRVs are are designed designedto toopen openininsafety safety mode (i.e.,

(Le., as as safety safetyvalves valveswith with spring spring mode modeof ofoperation) operation)or orrelief relief mode mode (i.e.,

(Le., aa pneumatic pneumatic piston/cylinder piston/cylinder actuator actuator providing providing the the mode modeof ofoperation).

operation). SRV operation in in the safety mode has has aa higher higher opening opening setpoint setpoint thanthan inin the relief relief mode. Therefore, Therefore, in in order to provide a bounding calculated calculated primary primary containment containment internal internal pressure, pressure,Pa, Pa ,

the 2012 2012 GEH GEH Analysis uses uses the the higher higherMainMain Steam Steam SRV SRV spring spring setpoints setpoints credited credited inin TS 3.4.4, 3.4.4, "Safety "Safety // Relief Relief Valves (S/RVs)."

(S/RVs)." This Thisdiffers differs from from the the AOR ADR which which usedused the the lower SRV relief relief mode mode setpoints.

setpoints.

4 of 10 10

ATTACHMENT 11 ATTACHMENT Evaluation of Proposed Change Evaluation

• • Main Steam Main Steam Isolation Isolation Valve Valve (MSIV) Closure Time (MSIV) Closure Time The MSIV closure time MSIV closure time assumed assumed in the 2012 GEH Analysis Analysis impacts impacts the Pa Pa results since the longer time it takes the MSIVs it takes MSIVs to to close, close, the longer RPV mass mass and and energy energyisis directed to to the turbine.

turbine. Conversely, Conversely, aashorter shorterMSIVMSIV closure closure timetime means meansthat thatmore more RPV mass RPV mass and energyenergy will be released will be released to to the the drywell drywell via via the break, resulting in a higher P higher Pa.

a . The AORAOR usesuses aaMSIVMSIV closure time of 5 seconds, seconds, which which is is the the maximum maximum MSIVclosure MSIV closuretimetimeallowed allowedininTS TSSurveillance SurveillanceRequirement Requirement (SR) (SR) 3.6.1.3.6.

3.6.1.3.6. In In order order toto provide aa bounding provide bounding peak calculated primary containment internal internal pressure, the 2012 2012 GEH Analysis GEH Analysisuses uses aa shorter MSIV closuretime MSIV closure timeofof3.5 3.5seconds, seconds, based based on the minimum TS SR 3.6.1.3.6 MSIV isolation minimum TS SR 3.6.1.3.6 MSIV isolation time with an assumed time with an assumed 0.5 second second from from break occurrence occurrenceto toinitiation initiation of of MSIV MSIV closure.

• Core Flow Conditions Permitted by the Power/Flow Power/Flow Map Map Core flowflowconditions conditionsassumedassumed in inthe the analysis analysis affect affectthe the mass mass and energy released released to to the drywell throughthe drywell through the break.

break. GEH GEH evaluated evaluated plantplant operation operation at atRated RatedCore CoreFlowFlow (RCF), Increased (RCF), Increased Core CoreFlow Flow(ICF),

(ICF), andandMaximum MaximumExtendedExtendedLoad LoadLimit LimitAnalysis Analysis (MELLA)conditions (MELLA) conditionstotoensureensurethat that the the condition condition which which maximizes maximizes the the energy being being released to to the the drywell drywell and provides provides aa bounding boundingPa Pa isis accounted accountedfor. for.Additionally, Additionally, feedwater temperature affects the energy released released through through the the break, break, therefore therefore bothboth the Final Feedwater Temperature Temperature ReductionReduction (FFWTR)

(FFWTR) and Normal Normal Feedwater Feedwater Temperature (NFWT) (NFWT) were wereconsidered.

considered. The The20122012GEH GEHAnalysis Analysis considered considered the the different core different core flow flowand andfeedwater feedwatertemperature temperature conditions, conditions, and and the the results are based based upon the conditions that yield the highest highest Pa. Pa.

• Reactor Power Level Level A lower reactor power level results in less energy being being released released to to the the drywell drywell viavia the the break, resulting resulting in in aalower lowerPa. Pa .

The AOR AOR states that the the analyses analyseswere wereperformed performedatataareactor reactorpower powerlevel levelofof 3559 MWt.MWt. However, itit was was subsequently subsequently determined determined that that the the AOR AOR analyses analyseswere were actually performed at 3789 MWt.

actually performed MWt. This discrepancy was addressed addressedby byGEH GEHthrough through their corrective action program.

The 20122012 GEH GEH Analysis Analysis used usedaamaximum maximumreactor reactorpower powerlevel levelofof3559 3559MWt, MWt,which whichisis 102% of of the the stretch power uprate licensed thermal power (3489 MWt). MWt). As a consequence consequence of of the the decrease decreaseininreactor reactorpower powerlevellevel used usedininthe the2012 2012GEH GEH Analysis Analysis compared to the AOR, AOR, the impact of this this specific specific change change was aa decrease decreaseininPa. Pa.

Summary of Changes Changes to to Peak PeakCalculated Calculated PrimaryPrimary Containment Containment InternalInternal Pressure Pressureand andEvaluation Evaluation The current LSCS LSCS AOR peak peak calculated calculated primary primary containment containment internal internal pressure, pressure,Pa, Pa ,isis39.9 39.9psig, psig, as as stated stated in in the the LSCS LSCS UFSARUFSAR and TS (Reference TS TS 5.5.13 5.5.13 andand UFSAR UFSAR 6.2.1.1.3). Results Resultsof of the 2012 2012 GEH GEH Analysis Analysis concluded that that the the peak peakcalculated calculatedprimary primarycontainment containmentinternal internal

pressure, pressure, Pa, Pa , is is 42.6 42.6 psig, psig, which which is is 2.7 2.7 psig psig higher higher thanthan the the value value determined determinedin in the theAOR AOR (i.e.,

(Le.,

42.6 psig - 39.9 39.9 psig psig = =2.7 psig). The The proposed proposedincreaseincreaseof of2.7 2.7psigpsigto to Pa Pa incorporates incorporates an an increase increase resulting resulting from from using the lower drywell drywelltemperature temperature (Le., (i.e., 1.3 1.3 psig) psig) andand anan increase increase resulting from from secondary secondary issuesissuesregarding regardingthe theAORAOR(i.e.,

(Le., 1.4 1.4psig).

psig).

5 of 1010

ATTACHMENT ATTACHMENT 11 Evaluation of Proposed Change Change As defined defined inin LSCS LSCS UFSARUFSARTable Table6.2-1, 6.2-1,thethecontainment containmentdesign design pressure pressure isis 45 45 psig.

psig. Since Since the the peak calculated peak calculated primary primary containment containment internal internal pressure pressureresulting resultingfrom fromthethenon-conforming non-conforming condition (42.6 condition (42.6 psig) psig) isis less less than than the containment design pressure pressure (45 (45 psig),

psig), the increased increasedPa Pa has no has no effect effect upon upon the the capability capability ofof the the primary primary containment containment to to accomplish accomplish its its safety-related safety-related functions.

Containment leakage rate testing is is addressed addressedininUFSAR UFSAR Section Section 6.2.6 6.2.6 and and LSCS LSCS TS TS 5.5.13.

5.5.13.

The LSCS containment leakage leakage rateratetesting testingprogram programimplements implementstesting testingrequirements requirementsinin accordance with accordance with 10 CFR 50 Appendix Appendix J, Option B, B, as modified modified by by any any approved exemptions, and criteria contained in in RG RG 1.163, 1.163, "Performance-

"Performance-Based Based Containment Leak Test Program." Program."

Tests that that measure measurecontainment containmentisolation isolation valve valve leak leak rates rates (Type (Type C C tests) tests) are are performed performed using using the the peak calculated primary primary containment internal pressure pressure value value of of 42.6 42.6 psig.

psig.

As described in TS 5.5.13 and LSCS LSCS UFSAR UFSAR TableTable 6.2-23, 6.2-23, thethe test test pressure usedusedfor for containment leakage testing testing is based upon upon the Pa Pa of 39.9 39.9 psig.

psig. TheThe higher higher calculated peak pressure Pa pressure Pa will affectthe will affect thecontainment containmentleakageleakage testing testing results.

results. Leak Leak rate testing based based upon uponthethe higher P Paa of of 42.6 42.6 psig psig would would havehave increased increased the measured measuredleakage.

leakage.EGC EGCOperability OperabilityEvaluation Evaluation OE 11-002 demonstrates that there is adequate adequate marginmargin to accommodate this increase.

As described described in in LSCS LSCS UFSARUFSAR 3.11.1.1.1, 3.11.1.1.1, the the environmental environmentalqualification qualification of safety-related electrical components electrical components and instrumentation instrumentation locatedlocated in in the primary primary containment are based baseduponupon the design pressure pressure (45 (45 psig),

psig), not not the calculated Pa Pa pressure (39.9 (39.9 psig). Hence, Hence, thethe revision revision ofof TS 5.5.13.b that increases increases the the PaPa value value toto 42.6 42.6 psig psig has hasno noeffect effect upon upon environmental environmental qualification.

The change change in in Pa Pa does does not not affect the LSCS analysis of radiological affect the consequences of a LOCA radiological consequences LOCA with respect to radiological with respect radiological dose dose at at the Exclusion Area Boundary (EAB), Low Population Zone the Exclusion (LPZ), Control Room (CR), or Technical Support Center (TSC). (TSC). Calculated doses during Calculated doses during a LOCA are dependent dependent on on the the maximum maximum allowable containmentcontainment atmosphere leakage leakage rate, rate, which is not affected byby Pa.

Pa .

5.0 REGULATORY EVALUATION

5.1 Applicable Regulatory Requirements/Criteria Requirements/Criteria The proposed change change has hasbeen beenevaluated evaluatedtotodetermine determinewhetherwhetherapplicable applicable regulations regulations and requirements continue to be met. met.

General Design Design Criterion Criterion 4, "Environmental "Environmental and Dynamic Effects Effects Design Design Bases," states states that structures, systems systems and andcomponents componentsimportant importantto to safety safety shall shall be be designed designedto to accommodate the accommodate theeffects effectsof,of, and andto tobebecompatible compatiblewith, with,thetheenvironmental environmentalconditions conditions associated associated with with normal operation, operation, maintenance, testing, and postulated accidents, postulated accidents, including LOCAs.

6of10 6 of 10

ATTACHMENT 11 ATTACHMENT Evaluation of Proposed Evaluation Proposed Change General Design Criterion Criterion 16, 16, "Containment "Containment Design,"Design,"states states that reactor containment and associated systems systems shall be provided to establish an essentiallyleak-tight shall be provided to establish an essentially leak-tight barrier barrier against against the uncontrolled release release of of radioactivity radioactivity to to the the environment environment and and toto assure assure that that the the containment design conditions containment conditions important importantto tosafety safetyare are not not exceeded exceeded for for as as long as postulated accident conditions require.

General Design Design Criterion Criterion 19, "Control Room,"states "Control Room," states that that a control control room room shall be provided provided from which actions from which actions can can be taken to operate the nuclear power unit taken to operate the nuclear power unit safely under normal safely under normal conditions and to maintainmaintain it in aa safe it in safe condition condition under under accident accidentconditions, conditions,including including LOCAs, and and that that adequate adequate radiation protectionshall radiation protection shallbe be provided.

provided. Adequate shielding is provided to provided to maintain maintain tolerable tolerable radiation radiationlevels levels inin the the control control roomroom underunder accident accident conditions for for the the duration duration of of the the accident.

General Design CriterionCriterion 38, 38, "Containment "Containment Heat Heat Removal,"

Removal,"states states that that aa system system to remove heat heat from from the reactor reactor containment containment shall shall bebeprovided provided that that rapidly rapidly reduces, reduces, consistent with the functioning with the functioningofofother otherassociated associated systems, systems, the containment pressure and temperature following any LOCA and maintain maintain them them at at acceptable acceptable low levels.

These General General Design Design Criteria continue to Criteria continue to be be met met byby the the change change in in Pa.

Pa . The The environmental qualification environmental qualification of of equipment equipment within withincontainment containmentisis not not affected affected by the change change in P in Paa following a LOCA.LOCA. The change change in in Pa Pa will will be reflected in in future future 10 CFR 50 Appendix J, Type A A containment integrated leak rate rate testing, so socontainment containmentintegrity integrity isis impacted by not impacted by the the change.

change. The Thechange changeininPa Padoes doesnot notimpact impactthe themaximum maximum allowable allowable containment leakage rate containment rate and therefore does does notnot impact impact control control room operator dose.

room operator dose. Pa Pa remains below containment design pressure. pressure.

Based on the considerations above, above, (1) there is (1) there is reasonable reasonable assurance assurance that that the the health health and and safety of thethe public public willwillnotnotbe beendangered endangered by by operation operation in in the the proposed manner; (2) (2) such such activities will activities willcontinue continuetotobe be conducted conducted in in accordance accordance with with the site licensing licensing basis; basis; and and(3)(3) the approval of the proposedproposed change changewill will not be inimical inimical to to the the common common defensedefense and and security or to the health and safety of the public. public.

In conclusion, In conclusion, EGC EGC has has determined that the proposed change change does doesnot notrequire requireanyany exemptions or relief from regulatory relief from regulatoryrequirements, requirements, other other than than the the TS, TS, and doesdoes not not affect affect conformance conformance with with any regulatory requirements or regulatory requirements or criteria. criteria.

5.2 No Significant Hazards Consideration In accordance In accordance with with 1010 CFRCFR 50.90, 50.90,"Application "Application for amendment amendment of of license, license,construction construction permit, permit, or or early early site site permit,"

permit," ExelonExelon Generation Generation Company, LLC LLC (EGG)(EGC) requests an an amendment to Facility Operating License Nos.

Facility Operating Nos. NPFNPF 1 1 and NPF-188 for and NPF-1 for LaSalle County County Station (LSCS), Units Units 1 and and 2. 2. The The proposed proposed change changewould would revise revisethe the peak peakcalculated calculated primary containmentinternal primary containment internalpressure pressurefor forthethedesign design basis basis loss-of-coolant loss-of-coolant accident accident (LOCA) described in in Technical Specifications (TS) 5.5 5.5.13, "Primary Containment

.13, "Primary Containment Leakage Leakage RateRate Testing TestingProgram."

Program." The Thepeak peakcalculated calculatedprimary primarycontainment containmentinternal internal pressure, Pa, Pa , is increased from from 39.9 psig to to 42.6 42.6 psig.

psig.

7 of 1010

ATTACHMENT 11 ATTACHMENT Evaluation of Proposed Change Change According According to to 10 10 CFR CFR 50.92, 50.92, "Issuance of amendment," paragraph paragraph (c), (c), aa proposed proposed amendment to an operating license involves no significant hazards considerationifif amendment to an operating license involves no significant hazards consideration operation of the facility inaccordance facility in accordance with with thethe proposed amendment amendmentwould would not:

not:

(1)

(1) Involve aa significant Involve significantincrease increase in in the the probability probabilityororconsequences consequences of of an accident previously evaluated; or previously (2)

(2) Create the Create the possibility possibility of of aa new new oror different different kind kind of accident accident from from anyany accident accident previously evaluated; or previously (3)

(3) Involve aa significant reduction in a margin Involve margin of of safety.

safety.

EGC has evaluated EGC evaluated the the proposed proposedchange changefor forLSCS, LSCS,usingusingthethecriteria criteriainin1010CFRCFR50.92, 50.92, and has has determined determined that the proposed proposed change change does doesnot notinvolve involve aa significant significant hazards consideration. The Thefollowing following information information is is provided provided to to support supportaafinding finding of of no nosignificant significant hazards consideration.

hazards consideration.

Criteria:

1. Does the proposed proposed change changeinvolveinvolve aasignificant significant increase increasein in the theprobability probability or consequences of an accident consequences of an accident previously previously evaluated?

Response: No.

Response: No.

The proposed change change to to PaP a does doesnotnotalter alter the the assumed assumedinitiators initiatorsto to any anyanalyzed analyzed event. The Theprobability probability of of an accident accident previously previously evaluated will not be will not be increased by this by this proposed change change since sincethis thischange changedoes doesnot notmodify modifythe theplant plantor orhow howititisis operated.

The change change in in Pa willnot P a will notaffect affectradiological radiologicaldose doseconsequence consequenceanalyses.

analyses. LSCS LSCS radiologicaldose radiological dose consequence consequence analysesanalysesare arebased basedon onthe themaximum maximumallowable allowable containment leakage rate. Even containment Even though though the the test testpressure pressureatatwhichwhich leak leak rate rate testing is performed is Pa, Pa , the maximum allowable containment maximum allowable containment leakage leakage rate is defined in in terms of a percentage percentageof ofweight weight of of the the original original content content of of containment containment air, which independent of which is independent of the peak peak calculated calculatedprimary primary containment containmentinternalinternal pressure. The pressure. TheAppendix AppendixJJcontainment containmentleak leakrate ratetesting testingprogram programwill will continue continue to to ensure that that containment containment leakageleakage remains remains within within the leakage assumedassumedin in the the offsitedose offsite dose consequence consequence analyses. The Theconsequences consequencesofofan anaccident accidentpreviously previously evaluated will not be will not be increased increased by this proposed change. change.

Therefore, operation of of the facility facility ininaccordance accordance with the proposed change with the changeto toPa Pa will notinvolve will not involveaasignificant significantincrease increase in in the the probability probability or or consequences consequences of ofanan accident previously evaluated.

evaluated.

8 of 10

ATTACHMENT ATTACHMENT 11 Evaluation of Proposed Change Does the proposed

2. changeDoes the create proposed the possibility change create theof a newofor possibility different a new or differentkind kindofof accident from from any accident previously evaluated?

previously evaluated?

Response: No.

Response: No.

The proposed change changeprovides providesaahigherhigherPaPathan thancurrently currently described described in in the the TS.

TS.

This change is This is the the result result of a LOCA-Drywell Temperature sensitivity analysis LOCA-Drywell Temperature analysis performed by performed by General Electric Hitachi (GEH).

Electric Hitachi (GEH). The peak peak calculated calculatedprimary primary containment internal containment internalpressure pressure remains remains below below the the containment containment design design pressure of of 45 psig. This Thischange changedoesdoes not involve not involve anyanyalteration alterationininthe theplant plantconfiguration configuration (no new or different type of different type of equipment equipment will willbebe installed) installed)or ormake make changes changes in in the methods governing normal plant governing normal plantoperation.

operation. The The change change does does notnot create create thethe possibility of possibility of a new oror different kind of different kind of accident accident fromfrom anyany accident previously evaluated.

Therefore, operation of of the facility facility ininaccordance accordance with the proposed change with the changeto to TS 5.5.13 wouldwould not create create the thepossibility possibility of of aa new newor ordifferent different kind kind ofof accident accident from evaluated.

from any previously evaluated.

3. Does the proposed proposed change changeinvolve involve aasignificant significant reduction reduction in in aa margin margin of safety?

Response: No.

Response: No.

The peak calculated calculated primary primary containment internal pressure pressure remains remains belowbelow thethe containment design containment design pressure of of 45 psig.

psig. LSCS LSCS radiological consequence radiological consequence analyses are based based onon the the maximum maximum allowable containment leakage allowable containment leakage rate.

rate. The change in in the peak peak calculated calculated primary primary containment internal internal pressure pressure does does not not represent aa significant represent significant change changein in the themargin marginof of safety.

safety.

Operation of the the facility facilityininaccordance accordance with with thethe proposed proposed change change to to TS 5.5.13 TS 5.5.13 does not does not involve involve aa significant significant reduction reduction in in the the margin margin of of safety.

safety.

Based on on the above above evaluation, evaluation, EGCEGC concludes that that the proposed amendment does does not involve a significant hazards hazards consideration consideration underunderthe thestandards standardsset setforth forthinin 10 CFR 50.92, 50.92, paragraph paragraph (c), (c), and and accordingly, accordingly, aafinding finding of of no no significant significant hazards hazards consideration is is justified.

justified.

5.3 Conclusions In conclusion, In conclusion, based based on on the considerations discussed above, above, (1) (1) there is is reasonable reasonable assurance that assurance that the thehealth healthand andsafety safetyofofthe thepublic public will not be will not be endangered endangered by by the operation operation Units 1 and 2 in the proposed of LSCS Units proposed manner, manner,(2) (2)such suchactivities activitieswill will be be conducted conductedinin compliance withwiththe the Commission's Commission's regulations, regulations, and and (3)(3)the the issuance issuance of the the amendment will not be will not be inimical inimicaltotothe thecommon commondefense defense and security or the health health andandsafety safetyof ofthe the public.

9 of 10

ATTACHMENT 1 ATTACHMENT Evaluation of Evaluation of Proposed Proposed Change 6.0

6.0 ENVIRONMENTAL CONSIDERATION

ENVIRONMENTAL EGC has EGC has evaluated the proposed amendment amendment for for environmental considerations. The review environmental considerations. review has resulted in resulted the determination in the determination that the proposed proposed amendment amendmentwould would change changerequirements requirementswith with respect to installation or use respect use of of aa facility component located within facility component the restricted area, within the area, as asdefined defined in 10 in 10 CFR CFR 20, 20, oror would wouldchange change an inspection or surveillance requirement. However, However, thethe proposed amendment proposed amendmentdoes doesnot notinvolve involve(i) (i) aasignificant significant hazards hazardsconsideration, consideration,(ii)

(ii)aasignificant significant change in in the types types or or significant significant increase increase in in the the amounts amountsof of any any effluent effluent that may may be be released released offsite, or offsite, or (iii)

(iii)aasignificant significantincrease increase in in individual individualor orcumulative cumulativeoccupational occupational radiation radiation exposure.

exposure.

Accordingly,the Accordingly, the proposed proposed amendment amendmentmeets meetsthe theeligibility eligibility criterion criterion for for categorical exclusion exclusion set set forth in forth in 10 10 CFR CFR 51.22(c)(9).

51.22(c)(9). Therefore, pursuant pursuant to 10 10 CFR CFR 51.22, 51.22, paragraph paragraph(b),

(b), no no environmental impact environmental impactstatement statementor orenvironmental environmentalassessment assessment needsneeds to be prepared in in connection with the proposed amendment.

with the proposed amendment.

7.0 REFERENCES

GEH Report1)1)0000-0149-2311-R0, GEH Report 0000-0149-2311-RO,Revision 0,Revision "LaSalle County 0, "LaSalle Generating County Generating Station Station Units 11 and Units and 2,2, Short Term Term Containment Bounding Bounding Pa Assessment,"

Assessment," dated dated August 2012 GE Project Task

2) Report GE Project GE-NE-A1300384-02-01-R3, Task Report GE-NE-A1300384-02-01-R3, Revision 3, "LaSalle Revision 3, "LaSalle County County Station Power Uprate Station Uprate Evaluation, Evaluation, Task Task400:

400: Containment Containment System System Response," dated dated May 2002 May 2002 (documented (documented in in Design Design Analysis Analysis L-002874, L-002874, Revision Revision 0)0) 3)

3) NRC Administrative NRC Administrative Letter Letter 98-10, 98-10, "Dispositioning "Dispositioning of of Technical Technical Specifications that that are are Insufficient to Assure Plant Safety,"

Insufficient to Assure Plant Safety," December December 29, 1998

4) Operability Evaluation OE 11-002, Revision Operability Evaluation Revision 5, 5, "Drywell Temp Used as "Drywell Temp as Input Input for for the Containment Containment Analysis,"

Analysis," April April 9,9, 2013 10 10 of of 10 10

ATTACHMENT 2 Markup MarkupofofTechnical TechnicalSpecifications Specifications Page Page LASALLE COUNTY STATION UNITS 1 AND 2 Docket Nos. 50-373 and 50-374 Facility Operating License Nos. NPF-11 and and NPF-18 NPF-18 REVISED TS PAGE PAGE 5.5-13

Programs Programs and and Manuals Manuals 5.5 5.5 5.5 5.5 Programs Programs andand Manuals Manuals 5.5.13 Primary Primary Containment Containment LeakageLeakage Rate Rate Testing Testing Program (continued)

Program (continued) 2.

2. NEI NEI 94-01 94-01 -- 1995, 1995, Section Section 9.2.3:

9.2.3: The first Unit The first Unit 22 Type Type A test performed A test performed after after December December 8, 8, 1993 1993 Type Type AA test test shall shall be performed prior be performed prior toto startup startup following following L2R12.

L2R12.

3. The The potential valve atmospheric potential valve atmospheric leakageleakage paths paths that that areare not not exposed exposed to reverse direction to reverse direction test test pressure pressure shall shall be be tested tested during during the the regularly regularly scheduled scheduled Type Type A A test.

test. The The program program shallshall contain contain the the list list of of the the potential potential valve valve atmospheric leakage paths, atmospheric leakage paths, leakage leakage raterate measurement measurement method, and method, and acceptance acceptance criteria. criteria. This This exception exception shall shall be be applicable applicable only only to to valves valves that that areare not not isolable isolable from from the the primary containment free primary containment free air air space.

space.

b. The peak calculated The peak calculated primary primary containment containment internal internal pressure pressure for for the design basis the design basis loss loss of of coolant coolant accident, accident, Pa, Pa, is is 3 9 - 4 p psig.

~ s i g .

42.6 c. The maximum allowable The maximum allowable primaryprimary containment containment leakage leakage rate, rate, La,La, at at Pa,Pa , is is 1.0%

1.0% of primary containment of primary containment air air weight weight perper day.

day.

d. Leakage Leakage rate rate acceptance acceptance criteria criteria are: are:

1. Primary containment Primary containment overalloverall leakage leakage raterate acceptance acceptance criterion isis <_~ 1.0 criterion 1.0 La. La. During During thethe first first unit unit startup startup following testing following testing in in accordance accordance with with this this program, program, the the leakage rate leakage rate acceptance acceptance criteria criteria areare s~ 0.60 0.60 L,La for for the the combined Type combined Type BB and and Type Type CCtests, tests, and and s~ 0.75 0.75 L,La for for Type AA tests.

Type tests.

2.

2. Air lock Air lock testing testing acceptance acceptance criteria criteria are:are:

a) a) Overall air Overall air lock lock leakage leakage rate rate is is <~ 0.05 0.05 L,La when when tested at tested at >;::: Pa.

Pa.

b) b) For each For each door, door, the the seal seal leakage leakage raterate isis<_~ 55 scf scf per hour per hour when when the the gap gap between between the the door door seals seals is is pressurized to pressurized to >;::: 10 10 psig.

psig.

e.

e. The provisions The provisions of of SR SR 3.0.33.0.3 are are applicable applicable to to the the Primary Primary Containment Leakage Containment Leakage RateRate Testing Testing Program.

Program.

(continued)

(continued)

LaSalle and 22 LaSalle 11 and 5.5-13 5.5-13 Amendment No.

Amendment No. 44-7' 197/184