|
---|
Category:Letter type:CCN:
MONTHYEARCCN:23-09, Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information2023-11-10010 November 2023 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information CCN:23-63, Registration of Use of Independent Spent Fuel Storage Installation (ISFSI) Casks2023-08-11011 August 2023 Registration of Use of Independent Spent Fuel Storage Installation (ISFSI) Casks CCN:22-15, (Pbaps), Units 1, 2, and 3 - Annual Commitment Revision Report for the Period 01/01/21 Through 12/31/212022-01-31031 January 2022 (Pbaps), Units 1, 2, and 3 - Annual Commitment Revision Report for the Period 01/01/21 Through 12/31/21 CCN:22-14, Submittal of the Inservice Inspection (ISI) Owner'S Activity Report (OAR) for the 23rd Refueling Outage for Unit 32022-01-31031 January 2022 Submittal of the Inservice Inspection (ISI) Owner'S Activity Report (OAR) for the 23rd Refueling Outage for Unit 3 CCN:21-65, Registration of Use of Independent Spent Fuel Storage Installation (ISFSI) Casks2021-07-23023 July 2021 Registration of Use of Independent Spent Fuel Storage Installation (ISFSI) Casks 2023-08-11
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARCCN:23-09, Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information2023-11-10010 November 2023 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information ML22312A3642022-11-0808 November 2022 Response to NRC Inspection Report and Preliminary White Finding ML22145A0852022-05-25025 May 2022 Response to Request for Additional Information - Proposed Relief Request Associated with Reactor Pressure Vessel N-16A Nozzle Repair RS-22-027, Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated2022-02-23023 February 2022 Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated P NMP1L3447, Constellation Energy Generation, LLC - Response to Request for Additional Information - Proposed Relief Request Associated with Reactor Pressure Vessel Water Level Instrumentation Partial Penetration Nozzle Repairs2022-02-0202 February 2022 Constellation Energy Generation, LLC - Response to Request for Additional Information - Proposed Relief Request Associated with Reactor Pressure Vessel Water Level Instrumentation Partial Penetration Nozzle Repairs JAFP-21-0087, Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments2021-09-16016 September 2021 Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments JAFP-21-0044, Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments2021-06-11011 June 2021 Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments JAFP-21-0032, Response to Request for Additional Information - Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting2021-04-20020 April 2021 Response to Request for Additional Information - Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting ML21035A0332021-02-0404 February 2021 Response to Request for Additional Information - License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative ML21029A1662021-01-29029 January 2021 Response to Request for Additional Information - License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative RS-20-112, Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-5682020-09-0303 September 2020 Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-568 ML20224A5302020-08-11011 August 2020 Response to the Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Wolf Creek Operating Corporation Independent Spent Fuel Storage Installation ML20188A2642020-07-0606 July 2020 Clinton Power Station, R.E. Ginna Station, Limerick Station, Nine Mile Point Station & Peach Bottom Station - Proposed Alternative to Utilize Code Case OMN-26 - Response to Request for Additional Information ML19276F2812019-10-0303 October 2019 Supplemental Response to Request for Additional Information (RAl-1) License Amendment Request to Revise Technical Specifications 3.8.4, DC Sources-Operating ML19241A4652019-08-29029 August 2019 Response to Request for Additional Information (RAl-1) License Amendment Request to Revise Technical Specifications 3.8.4, DC Sources-Operating ML19225B9762019-08-13013 August 2019 Response to NRC Request for Clarification of Information, Dated August 1, 2019 Related to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application ML19206A0562019-07-24024 July 2019 Stations, Units 2 and 3 - Response to Request for Additional Information - License Amendment Request to Revise Technical Specifications 3.8.1, Required Action A.3, for Temporary One-Time Extension of Completion Time ML19163A2232019-06-12012 June 2019 Revised Response to NRC Request for Additional Information, Core Shroud Support Fatigue Analysis Reevaluation, Related to the Subsequent License Renewal Application ML19157A0092019-06-0606 June 2019 Response to NRC Request for Additional Information, Dated May 15, 2019 Related to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application JAFP-19-0057, Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-8802019-06-0404 June 2019 Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880 ML19150A2972019-05-30030 May 2019 Revised Responses to NRC Requests for Additional Information, Fire Water System, Related to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application ML19122A2892019-05-0202 May 2019 Response to NRC Requests for Additional Information, Set 1, Dated April 10, 2019 Related to Plant Subsequent License Renewal Application NMP1L3279, Response to Request for Additional Information - Proposed Alternatives to Utilize Code Cases N-878 and N-880 for Plants2019-05-0101 May 2019 Response to Request for Additional Information - Proposed Alternatives to Utilize Code Cases N-878 and N-880 for Plants ML19085A3852019-03-26026 March 2019 Response to Second Request for Additional Information - License Amendment Request to Reduce High Pressure Service Water System Design Pressure and Revise Technical Specifications ... ML19065A0082019-03-0505 March 2019 Response to Nrg Audit Review Information Request - Application for Subsequent Renewed Operating Licenses Section 4.6 Primary Containment Fatigue Analyses ML19046A1292019-02-15015 February 2019 Response to RAI - License Amendment Request to Reduce High Pressure Service Water System Design Pressure and Revise Technical Specifications 3.6.2.3, 3.6.2.4, 3.6.2.5, and 3.7.1 for Temporary Extension of Completion Times ML19028A2802019-01-28028 January 2019 Response to NRC Request for Additional Information, Dated December 13, 2018, Regarding Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Severe Accident Mitigation Alternatives Requests for Additional Information JAFP-19-0006, Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-8802019-01-0808 January 2019 Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880 ML19007A3262019-01-0707 January 2019 Response to Request Dated December 7, 2018 for Docketing of Additional Documents to Support Nrc'S Environmental Review of the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application ML18354B0612018-12-20020 December 2018 Response to NRC Request for Additional Information, Dated November 23, 2018, Regarding the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application, Environmental Requests for Additional Information ML18340A1852018-12-0606 December 2018 Response to Request for Additional Information License Amendment Request - Revise Technical Specifications to Allow Two Safety Relief Valves/Safety Valves to Be Out-of-Service with Increased Reactor Pressure Safety Limit RS-18-143, Supplemental Information Supporting License Amendment Requests for Approval of Changes to Emergency Plan Staffing Requirements2018-11-29029 November 2018 Supplemental Information Supporting License Amendment Requests for Approval of Changes to Emergency Plan Staffing Requirements ML18337A2402018-11-28028 November 2018 Response to Request for Additional Information - Relief Requests Associated with the Fifth Inservice Inspection Interval ML18305B2702018-11-0101 November 2018 Response to Request for Additional Information - License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements ML18257A0172018-09-14014 September 2018 Response to Request for Additional Information Application to Revise Technical Specifications to Adopt Technical Specification Task Force (TSTF)-500, Revision 2, DC Electrical Rewrite Update to ... ML18222A3872018-08-10010 August 2018 Response to Request for Additional Information and Supplemental Information - Application to Adopt 1 O CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems, and Components ... ML18128A0092018-05-0707 May 2018 Response to Request for Additional Information Application to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Plants. RS-18-061, Response to Request for Additional Information Regarding Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (Isfsis)2018-05-0202 May 2018 Response to Request for Additional Information Regarding Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (Isfsis) ML17354A3812017-12-20020 December 2017 Supplemental Response Concerning License Amendment Request to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2 RS-17-149, Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from The.2017-12-15015 December 2017 Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from The. ML17241A1942017-08-29029 August 2017 License Amendment Request - Revise Technical Specifications Section 3.4.3 (Srvs/Svs) for the Remainder of the Current Operating Cycle for Unit 2 - Supplement 1 Response to Request for Additional Information ML17223A6262017-08-11011 August 2017 Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2 ML17220A2142017-08-0808 August 2017 Measurement Uncertainty Recapture License Amendment Request - Supplement 3 Response to Request for Additional Information ML17195A2852017-07-13013 July 2017 Measurement Uncertainty Recapture License Amendment Request - Supplement 2 Response to Request for Additional Information RS-17-044, Response to Request for Additional Information Regarding Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography2017-03-13013 March 2017 Response to Request for Additional Information Regarding Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography ML16224A3422016-08-11011 August 2016 Response to Request for Additional Information Regarding Proposed License Amendment Concerning Diesel Generator Lube Oil Inventory (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3 ML16216A0762016-08-0202 August 2016 Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request Concerning Emergency Diesel Generator Fuel Oil Transfer Surveillance Requirements ML16162A1012016-06-0909 June 2016 Response to Request for Additional Information Regarding Proposed License Amendment Concerning Emergency Diesel Generator Fuel Oil Transfer Surveillance Requirements RA-16-049, Response to Request for Additional Information Regarding Requests to Withhold Emergency Preparedness Documents from Public Disclosure2016-05-26026 May 2016 Response to Request for Additional Information Regarding Requests to Withhold Emergency Preparedness Documents from Public Disclosure ML16083A3942016-03-23023 March 2016 Changes to High Pressure Coolant Injection and Reactor Core Isolation Cooling Surveillance Requirements - Supplement 1, Response to Request for Additional Information 2023-11-10
[Table view] |
Text
200 Exelon Way Kennett Square, PA 19348 www.constellation.com 10 CFR 73.5 CCN: 23-093 November 10, 2023 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent Renewed Facility Operating Licensee Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278
Subject:
Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information
References:
- 1. Letter from D. Gudger (Constellation Energy Generation, LLC) to U.S.
Nuclear Regulatory Commission, "Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation," dated October 16, 2023 (ML23289A121)
- 2. Email from Scott Wall (NRC Senior Project Manager) to Ron Reynolds (Constellation Energy Generation, LLC), "Final RCI - Constellation Energy Generation, LLC - Peach Bottom 2 & 3 - Exemption from Security Rule,"
dated October 30, 2023 (ML23304A018)
By letter dated October 16, 2023 (Reference 1), Constellation Energy Generation, LLC (CEG) requested an exemption for Peach Bottom Atomic Power Station (Peach Bottom), Units 2 and 3, from the compliance date of January 8, 2024, for the new security Rule, "Enhanced Weapons, Firearms Background Checks, and Security Event Notifications." The requested exemption was based on the NRC's projected timeline for completion of revision to the applicable Regulatory Guides associated with the new rule, and the time necessary for Peach Bottom to process change management adequately to include the number of training weeks that will be required to implement the Rule. Peach Bottom requested a new compliance date of December 31, 2024, or 180 days after publication of final Regulatory Guides, whichever is later.
On October 24, 2023, the NRC issued, via email, a draft Request for Confirmatory Information (RCI) for the Byron Station. A clarification call with the NRC and CEG was held on October 25, 2023, resulting in a formal RCI request for Byron and the NRC also issuing a formal RCI on October 30, 2023, for Peach Bottom (Reference 2).
U.S. Nuclear Regulatory Commission Supplemental Information Letter Responses to Request for Confirmatory Information NRC Docket Nos. 50-277 and 50-278 November 10, 2023 Page 2 The Attachment to this supplemental information letter provides responses to the RCI provided in Reference 2.
There are no regulatory commitments contained in this supplement.
If you should have any questions concerning this submittal, please contact Richard Gropp at (267) 533-5642.
Respectfully, David P. Helker Sr. Manager, Licensing Constellation Energy Generation, LLC
Attachment:
Supplemental Information Letter cc: w/ Attachment NRC Region I Administrator Senior Resident Inspector - PBAPS NRC Project Manager - PBAPS Scott Wall, NRC Fleet Project Manager Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources W. DeHass - Commonwealth of Pennsylvania Bureau of Radiation Protection S. Seaman - State of Maryland
Supplemental Information Letter Attachment Responses to Request for Confirmatory Information Page 1 of 3 NRC Docket Nos. 50-277 and 50-278 SUPPLEMENTAL INFORMATION This Supplemental Information provides responses to the Request for Confirmatory Information (RCI) provided by the NRC in Reference 2. Each confirmatory request is provided below followed by CEG's response.
- 1. Regarding CEGs request for exemption from the January 8, 2024, compliance date, please confirm the following:
o CEG is requesting an exemption for Peach Bottom from specific requirements, as described below, associated with the final rule for Enhanced Weapons, Firearms Background Checks, and Security Event Notifications, as identified in your submission; that would defer compliance with those provisions until December 31, 2024, or 180 days after publication of final Regulatory Guides, whichever is later.
CEG Response:
Yes, CEG is requesting an exemption for Peach Bottom from specific requirements, as described below, associated with the final rule for Enhanced Weapons, Firearms Background Checks, and Security Event Notifications, as identified in Peach Bottom's submittal dated October 16, 2023 (ML23289A121), that would defer compliance with those provisions until December 31, 2024, or 180 days after publication of final Regulatory Guides, whichever is later.
o CEG is not requesting an extension to the compliance date for Peach Bottom for specific requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 73, Subpart B, "Enhanced Weapons, Preemption, and Firearms Background Checks," described in 10 CFR 73.15, "Authorization for Use of Enhanced Weapons and Preemption of Firearms Laws," and 10 CFR 73.17, "Firearms Background Checks for Armed Security Personnel."
CEG Response:
Correct, CEG is not requesting an extension to the compliance date for Peach Bottom for specific requirements in Title 10 of the Code of Federal Regulations (10 CFR) Part 73, Subpart B, "Enhanced Weapons, Preemption, and Firearms Background Checks,"
described in 10 CFR 73.15, "Authorization for Use of Enhanced Weapons and Preemption of Firearms Laws," and 10 CFR 73.17, "Firearms Background Checks for Armed Security Personnel."
o CEG is requesting an exemption for Peach Bottom from specific requirements in 10 CFR Part 73, Subpart T, "Security Notifications, Reports, and Recordkeeping," 10 CFR 73.1200(a) through 10 CFR 73.1200(t), "Notification of Physical Security Events," 10 CFR 73.1205(a)(1) through 10 CFR 73.1205(e), "Written Follow-up Reports of Physical Security Events," 10 CFR 73.1210(a)(1) through10 CFR 73.1210(h), "Recordkeeping of Physical Security Events," and "Suspicious Activity Reports," 10 CFR 73.1215(a) through 10 CFR 73.1215(f) until the later of December 31, 2024, or 180 days after publication of the final Regulatory Guides.
CEG Response:
Yes, CEG is requesting an exemption for Peach Bottom from specific requirements in 10 CFR Part 73, Subpart T, "Security Notifications, Reports, and Recordkeeping," 10 CFR
Supplemental Information Letter Attachment Responses to Request for Confirmatory Information Page 2 of 3 NRC Docket Nos. 50-277 and 50-278 73.1200(a) through 10 CFR 73.1200(t), "Notification of Physical Security Events," 10 CFR 73.1205(a)(1) through 10 CFR 73.1205(e), "Written Follow-up Reports of Physical Security Events," 10 CFR 73.1210(a)(1) through10 CFR 73.1210(h), "Recordkeeping of Physical Security Events," and 10 CFR 73.1215(a) through 10 CFR 73.1215(f), "Suspicious Activity Reports," until the later of December 31, 2024, or 180 days after publication of the final Regulatory Guides.
o CEG is requesting an exemption for Peach Bottom from using the definitions for the terms "Contraband," and "Time of Discovery" as recently revised in 10 CFR 73.2, "Definitions," until the later of December 31, 2024, or 180 days after publication of the final Regulatory Guides. The exemption would not apply to the definitions of those terms that were in effect prior to the issuance of the 2023 revisions.
CEG Response:
Yes, CEG is requesting an exemption for Peach Bottom from using the definitions for the terms "Contraband," and "Time of Discovery" as recently revised in 10 CFR 73.2, "Definitions," until the later of December 31, 2024, or 180 days after publication of the final Regulatory Guides. The exemption would not apply to the definitions of those terms that were in effect prior to the issuance of the 2023 revisions.
- 2. Confirm that the current Peach Bottom site security plan implements the requirements of 10 CFR 73.71, "Reporting of Safeguards Events" for reporting the suspension of security measures.
CEG Response:
CEG confirms that the current Peach Bottom site security plan implements the requirements of 10 CFR 73.71, "Reporting of Safeguards Events" for reporting the suspension of security measures.
o Confirm that Peach Bottom will continue to comply with security event reporting, as previously required in 10 CFR 73.71, "Reporting of Safeguards Events," and Appendix G to Part 73, "Reportable Safeguards Events."
CEG Response:
CEG confirms that Peach Bottom will continue to comply with security event reporting, as previously required in 10 CFR 73.71, "Reporting of Safeguards Events," and Appendix G to Part 73, "Reportable Safeguards Events."
o Confirm that Peach Bottom will use the definitions for the terms "Contraband" and "Discovery (time of)" in its site security plan consistent with how these terms are currently defined in Regulatory Guide 5.76, Revision 1, "Physical Protection Programs at Nuclear Power Reactors."
CEG Response:
CEG confirms that Peach Bottom will use the definitions for the terms "Contraband" and "Discovery (time of)" in its site security plan consistent with how these terms are currently defined in Regulatory Guide 5.76, Revision 1, "Physical Protection Programs at Nuclear Power Reactors."
Supplemental Information Letter Attachment Responses to Request for Confirmatory Information Page 3 of 3 NRC Docket Nos. 50-277 and 50-278
- 3. Confirm that when Peach Bottom states that it is implementing the new Access Authorization Rule it actually means that it is implementing the new 2022 10 CFR Part 26 Fitness for Duty Rule (87 FR 71422, November 22, 2022)?
CEG Response:
CEG confirms that the statement in its exemption request that "CEG is in the process of implementing the new Access Authorization Rule" was made in error. What the statement intended to say is that CEG is in the process of implementing the new 2022 10 CFR Part 26 Fitness for Duty Rule (87 FR 71422, November 22, 2022).