JAFP-21-0041, Supplement to Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing
| ML21137A005 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick |
| Issue date: | 05/17/2021 |
| From: | David Gudger Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| JAFP-21-0041 | |
| Download: ML21137A005 (2) | |
Text
200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 JAFP-21-0041 May 17, 2021 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333
Subject:
Supplement to Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, "TS lnservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing"
References:
- 1.
Application To Revise Technical Specifications to Adopt TSTF-545, Revision 3, "TS lnservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing," letter dated December 11, 2020.
2.
E-mail from Justin Poole (NRC Project Manager) to Enrique Villar (Exelon) Staff Observations of the TSTF-545 submittal, dated May 5, 2021.
By letter dated December 11, 2020, Exelon Generation Company, LLC (Exelon) submitted a license amendment request to adopt TSTF-545, Revision 3, "TS lnservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing."
Via Reference 2, Justin Poole (NRC Project Manager) requested a teleconference to discuss observations from the Staff regarding the December 11, 2020 submittal. This teleconference took place on May 5, 2021. This letter documents the responses provided verbally during the call. The Staffs observations followed by Exelon responses are provided below.
There are several instances in the amendment request that refer to a specific TS Section (e.g., "TS Section 5.5") modified by use of the expression "or equivalent" (e.g., "TS Section 5.5, or equivalent,"). This expression is not used in the model application. Please clarify why this expression was used.
Response: The expression "or equivalent" can be removed. The intent in using this expression was to capture SRs which were not identified by the TSTF, but SRs that could be modified in accordance with the TSTF scope. These SRs are described in Table 2.
Supplement Application to Adopt TSTF-545, Revision 0 May 17, 2021 Page 2
- , page 2 of 6, (Section 2.2) states, "James A. FitzPatrick Nuclear Power Plant (JAF) was issued a construction permit on May 20, 1970, and the provisions of 10 CFR 50.55a(f)(3) are applicable." According to the regulations, 50.55a(f)(1) would be applicable to a 1970 CP plant. Please clarify.
Response: Exelon agrees that the correct reference is to 10 CFR 50.55a(f)(1) not 10 CFR 50.55a(f)(3).
- , page 3 of 6, has a sentence that precedes Table 2 that appears to be incomplete: "Table 2 below identifies JAF plant specific SRs that are not identify in the TSTF, but that clearly fall within the scope of the TSTF but are:" Please clarify.
Response: Exelon agrees that the sentence is incomplete. The sentence should read "Table 2 below identifies JAF plant specific SRs that are not identified in the TSTF but clearly fall within the scope of the TSTF." The words "but are" at the end of the sentence should have been deleted.
- , page 4 of 6, (Table 2), has an entry that appears to be incomplete (see SR 3.6.2.3.2 missing comments). Please clarify.
Response: The missing comment for SR 3.6.2.3.2 is similar to other comments in Table 2. The missing comment should read "The current SR Frequency is in accordance with Inservice Testing program, and it will be changed to in accordance with the INSERVICE TESTING PROGRAM."
There are no commitments contained in this response. If you should have any questions regarding this submittal, please contact Enrique Villar at 610-765-5736.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 17th day of May 2021.
Respectfully, David T. Gudger Senior Manager, Licensing Exelon Generation Company, LLC cc: Regional Administrator - NRC Region I NRC Senior Resident Inspector - JAF NRC Project Manager, NRR - JAF A. L. Peterson, NYSERDA