ML020240275
| ML020240275 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/22/2002 |
| From: | Anand R Division of Regulatory Improvement Programs |
| To: | Gallagher M Exelon Generation Co |
| References | |
| -nr | |
| Download: ML020240275 (10) | |
Text
January 23, 2002 Mr. Michael P. Gallagher Director-Licensing Exelon Corporation 200 Exelon Way Kennett Square, PA 19348
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) FOR THE REVIEW OF THE PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3
Dear Mr. Gallagher:
By letter dated July 2, 2001, Exelon Generation Company, LLC (Exelon), submitted for Nuclear Regulatory Commission (NRC) review an application, pursuant to 10 CFR Part 54, to renew the operating licenses for the Peach Bottom Atomic Power Station, Units 2 and 3. The NRC staff performed an audit on December 4 - 7, 2001, to review the scoping and screening methodology documentation that support the development of the application.
At the public exit meeting held on December 7, 2001, the NRC staff advised Exelon of its intent to issue several RAIs related to scoping and screening methodology of the application. A request for additional information is enclosed. We request that you provide your response to this RAI by February 28, 2002.
If you have any questions, please feel free to contact me at 301-415-1146.
Sincerely,
/RA/
Raj K. Anand, Project Manager License Renewal and Environmental Impacts Programs Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278
Enclosure:
As stated cc w/encl: See next page
Mr. Michael P. Gallagher Director-Licensing Exelon Corporation 200 Exelon Way Kennett Square, PA 19348
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION (RAI) FOR THE REVIEW OF THE PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3
Dear Mr. Gallagher:
By letter dated July 2, 2001, Exelon Generation Company, LLC (Exelon), submitted for Nuclear Regulatory Commission (NRC) review an application, pursuant to 10 CFR Part 54, to renew the operating licenses for the Peach Bottom Atomic Power Station, Units 2 and 3. The NRC staff performed an audit on December 4 - 7, 2001, to review the scoping and screening methodology documentation that support the development of the application.
At the public exit meeting held on December 7, 2001, the NRC staff advised Exelon of its intent to issue several RAIs related to scoping and screening methodology of the application. A request for additional information is enclosed. We request that you provide your response to this RAI by February 28, 2002.
If you have any questions, please feel free to contact me at 301-415-1146.
Sincerely,
/RA/
Raj K. Anand, Project Manager License Renewal and Environmental Impacts Programs Division of Regulatory Improvement Programs Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION:
See next page DOCUMENT NAME: C:\Program Files\Adobe\Acrobat 4.0\PDF Output\IQMB-Scoping and Screening
~.wpd OFFICE PM:RLEP LA SC: IEHB SC: RLEP PD:RLEP NAME RKAnand EGHylton DThatcher PTKuo CIGrimes DATE 01/17/02 01/18/02 01/18/02 01/23/02 01/23/02 OFFICIAL RECORD COPY DISTRIBUTION:
HARD COPY RLSB RF E. Hylton E-MAIL:
PUBLIC J. Johnson W. Borchardt D. Matthews C. Carpenter C. Grimes B. Zalcman J. Strosnider (RidsNrrDe)
E. Imbro G. Bagchi K. Manoly W. Bateman J. Calvo C. Holden P. Shemanski S. Rosenberg G. Holahan B. Boger D. Thatcher G. Galletti B. Thomas J. Moore R. Weisman M. Mayfield A. Murphy W. McDowell S. Droggitis N. Dudley RLEP Staff J. Boska L. Wheeler N. St. Amour D. McCain J. Yerokun, Region I
Peach Bottom Atomic Power Station, Units 2 and 3 cc:
Mr. Edward Cullen Correspondence Control Desk Vice President & General Counsel Exelon Generation Company, LLC Exelon Generation Company, LLC 200 Exelon Way, KSA 1-N-1 300 Exelon Way Kennett Square, PA 19348 Kennett Square, PA 19348 A. F. Kirby, III Mr. J. Doering External Operations - Nuclear Site Vice President Delmarva Power & Light Company Peach Bottom Atomic Power Station P.O. Box 231 1848 Lay Road Wilmington, DE 19899 Delta, PA 17314 Chief-Division of Nuclear Safety Mr. G. Johnston PA Dept. of Environmental Protection Plant Manager P.O. Box 8469 Peach Bottom Atomic Power Station Harrisburg, PA 17105-8469 1848 Lay Road Delta, PA 17314 Board of Supervisors Peach Bottom Township Mr. A. Winter R. D. #1 Regulatory Assurance Manager Delta, PA 17314 Peach Bottom Atomic Power Station 1848 Lay Road Public Service Commission of Maryland Delta, PA 17314 Engineering Division Chief Engineer Resident Inspector 6 St. Paul Center U.S. Nuclear Regulatory Commission Baltimore, MD 21202-6806 Peach Bottom Atomic Power Station P.O. Box 399 Mr. Richard McLean Delta, PA 17314 Power Plant and Environmental Review Division Regional Administrator, Region I Department of Natural Resources U.S. Nuclear Regulatory Commission B-3, Tawes State Office Building 475 Allendale Road Annapolis, MD 21401 King of Prussia, PA 19406 Dr. Judith Johnsrud Mr. Roland Fletcher National Energy Committee Department of Environment Sierra Club Radiological Health Program 433 Orlando Avenue 2400 Broening Highway State College, PA 16803 Baltimore, MD 21224 Manager-Financial Control & Co-Owner Affairs Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038-0236
Peach Bottom Atomic Power Station Units 2 and 3 cc:
Mr. Jeffrey A. Benjamin Vice President-Licensing Exelon Generation Company, LLC 1400 Opus Place, Suite 900 Downers Grove, IL 60515 Mr. Michael P. Gallagher Director - Licensing Mid-Atlantic Regional Operating Group Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Mr. Joseph Hagan Senior Vice President Mid-Atlantic Regional Operating Group Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Mr. John Skolds Chief Operating Officer Exelon Generation Company, LLC 1400 Opus Place, Suite 900 Downers Grove, IL 60515 Mr. William Bohlke Senior Vice President, Nuclear Services Exelon Generation Company, LLC 1400 Opus Place, Suite 900 Downers Grove, IL 60515 Mr. Jim Meister Senior Vice President, Operations Support Exelon Generation Company, LLC 1400 Opus Place, Suite 900 Downers Grove, IL 60515
Exelon Generation Company, LLC (Exelon)
License Renewal Application (LRA)
Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 Request for Additional Information
- 1. Section 2.1.2 of the PBAPS LRA, "Scoping Methodology" RAI 2.1.2-1 Scoping and Screening Methodology As discussed and understood during the scoping and screening methodology audit performed December 4-7, 2001, describe in detail the scoping and screening process, as shown in Figure 2.1-1 of the PBAPS LRA, with respect to mechanical, structural and electrical disciplines.
RAI 2.1.2-2 System Realignment As discussed and understood during the scoping and screening methodology audit performed December 4-7, 2001, describe the "system realignment" process and the rational for its use.
Ensure that the response includes a discussion of how the realignment of components is consistent with the criteria described in implementing plan PLI-001, the LRA, LRC-14, and the five cases discussed during the audit.
RAI 2.1.2-3 System and Structure Scoping Criteria (Seismic II/I)
An applicant needs to consider nonsafety-related (NSR) piping systems which are not connected to safety-related (SR) piping, but have a spatial relationship such that their failure could adversely impact on the performance of an intended safety function. For this piping system configuration, the applicant has two options when performing its scoping evaluation; a mitigative option or a preventive option. With respect to the mitigative approach, the applicant must demonstrate that plant mitigative features (e.g., pipe whip restraints, jet impingement shields, spray and drip shields, seismic supports, flood barriers, etc.) are provided which protect SR structures, systems and components (SSCs) from a failure of NSR piping segments. When evaluating the failure modes of NSR piping segments and the associated consequences, age-related degradation must be considered. The staff notes that pipe failure evaluations typically do not consider age-related degradation when determining pipe failure locations. Rather, pipe failure locations are normally postulated based on high stress. Industry operating experience has shown that age-related pipe failures can, and do, occur at locations other than the high-stress locations postulated in most pipe failure analyses. Therefore, to utilize the mitigative option, an applicant should demonstrate that the mitigating devices are adequate to protect SR SSCs from failures of NSR piping segments at any location where age-related degradation is plausible. If this level of protection can be demonstrated, then only the mitigative features need to be included within the scope of license renewal, and the piping segments need not be included within the scope.
However, if an applicant cannot demonstrate that the mitigative features are adequate to protect safety-related SSCs from the consequences of non-safety-related pipe failures, then the
applicant should utilize the preventive option, which requires that the entire non-safety-related piping system be brought into the scope of license renewal and an AMR be performed on the components within the piping system. Finally, an applicant may determine that in order to ensure adequate protection of the SR SSC, a combination of mitigative features and NSR SSCs must be brought within scope. Regardless, it is incumbent upon the applicant to provide adequate justification for the approach taken with respect to scoping of NSR SSCs in accordance with the Rule. Therefore the applicant is requested to identify which option is used for NSR piping systems which are not connected to SR piping, but have a spatial relationship such that their failure could adversely impact on the performance of an intended safety function.
For each NSR piping system which would normally be included within the scope of license renewal, but is excluded because mitigative features have been credited for protecting SR SSCs from the failure of the NSR piping system, please identify the following:
- a. the mitigative feature(s) that is credited for protection.
- b. the hazard (e.g., failure mechanisms and postulated failure locations) for which the mitigative feature(s) is providing protection.
- c. a summary discussion (including references, such as reports, analyses, calculations, etc.)
of the basis for the conclusion that the mitigative feature(s) is adequate to protect SR SSCs.
RAI 2.1.2-4 Given the methodology used to identify piping systems that meet the 54.4(a)(2) scoping criterion, there may be other non-safety-related systems, structures or components ( NSR SSCs) which should be included within the scope of license renewal. For these other NSR SSCs an applicant can exercise the mitigative option, the preventive option, or a combination, in order to address the scoping issue. For each NSR SSC identified as meeting the 54.4(a)(2) scoping criterion, list which option or combination of options is being credited. For those NSR SSCs which exercise the mitigative option further indicate:
- a. the mitigative feature(s) that is credited for protection,
- b. the hazard (e.g., failure mechanisms and postulated failure locations) for which the mitigative feature(s) is providing protection, and
- c. a summary discussion (including references, such as reports, analyses, calculations, etc.)
of the basis for the conclusion that the mitigative feature(s) is adequate to protect safety-related SSCs.
- 2. Appendix A of the PBAPS LRA - Updated Final Safety Analysis Report Supplement RAI A.2-1 Quality Assurance for Aging Management Programs Section A.2, "Quality Assurance for Aging Management Programs," of the NRCs Standard Review Plan for License Renewal (SRP-LR), states a license renewal applicant to demonstrate
that the effects of aging on structures and components subject to an aging management review will be adequately managed to ensure that their intended functions will be maintained consistent with the current licensing basis of the facility for the period of extended operation. Consistent with this approach, the applicants aging management programs should contain the attributes of corrective action, confirmation process, and administrative controls in order to ensure proper management of the aging programs.
However, Appendix A, "Updated Final Safety Analysis Report Supplement," of the PBAPS LRA, does not provide a description of how the Quality Assurance Program (QAP) specifically addresses these attributes. Therefore, the applicant is requested to provide a description of how the QAP specifically addresses these attributes for the aging management programs during the period of extended operation.
- 3. Appendix B of the PBAPS LRA RAI B.1-1 Aging Management Activities Appendix B to the LRA provides an aging management activity summary for each unique structure, component, or commodity group determined to require aging management during the period of extended operation. Section B.1 of the LRA includes a description of each attribute associated with the described Aging Management Activities. However, the LRA does not provide a description of each of these attributes necessary to ensure consistency between the SRP definitions and those applied by the applicant. Also, Appendix B does not provide a description of how the QAP specifically addresses corrective action, confirmation process, and administrative controls for which credit is being sought. Therefore, based on the staffs review of Appendix B, Section B.1, of the PBAPS LRA, the applicant is requested to provide:
- a. A general description of how the definitions established for each of the 10 attributes identified within Section B.1, "Existing Aging Management Activities," is consistent with the definitions described in Section A.1, "Aging Management Review - Generic," Table A.1-1, "Elements of an Aging Management Program for License Renewal," of the SRP-LR.
- b. A description of how the Exelon 10 CFR 50, Appendix B, QAP program specifically addresses corrective action, confirmation process, and administrative controls for the aging management programs at the PBAPS during the period of extended operation.
- c. A description of how the Exelon 10 CFR 50, Appendix B, QAP is consistent with the summary in Section A.2 of the SRP-LR and how it addresses the implementation of corrective action, confirmation process, and administrative controls for both safety-related and non-safety-related structures, systems, and components that are within the scope of license renewal.
Peach Bottom Atomic Power Station, Units 2 and 3 cc:
A. F. Kirby, III Mr. Edward Cullen External Operations - Nuclear Vice President & General Counsel Delmarva Power & Light Company Exelon Generation Company, LLC P.O. Box 231 300 Exelon Way Wilmington, DE 19899 Kennett Square, PA 19348 Chief-Division of Nuclear Safety Mr. J. Doering PA Dept. of Environmental Protection Site Vice President P.O. Box 8469 Peach Bottom Atomic Power Station Harrisburg, PA 17105-8469 1848 Lay Road Delta, PA 17314 Board of Supervisors Peach Bottom Township Mr. G. Johnston R. D. #1 Plant Manager Delta, PA 17314 Peach Bottom Atomic Power Station 1848 Lay Road Public Service Commission of Maryland Delta, PA 17314 Engineering Division 6 St. Paul Center Mr. A. Winter Baltimore, MD 21202-6806 Regulatory Assurance Manager Peach Bottom Atomic Power Station Mr. Richard McLean 1848 Lay Road Power Plant and Environmental Review Division Delta, PA 17314 Department of Natural Resources B-3, Tawes State Office Building Resident Inspector Annapolis, MD 21401 U.S. Nuclear Regulatory Commission Peach Bottom Atomic Power Station Dr. Judith Johnsrud P.O. Box 399 National Energy Committee, Sierra Club Delta, PA 17314 433 Orlando Avenue State College, PA 16803 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Manager-Financial Control & Co-Owner Affairs 475 Allendale Road Public Service Electric and Gas Company King of Prussia, PA 19406 P.O. Box 236 Hancocks Bridge, NJ 08038-0236 Mr. Roland Fletcher Department of Environment Mr. Frederick W. Polaski Radiological Health Program Manager License Renewal 2400 Broening Highway Exelon Corporation Baltimore, MD 21224 200 Exelon Way Kennett Square, PA 19348 Correspondence Control Desk Exelon Generation Company, LLC 200 Exelon Way, KSA 1-N-1 Kennett Square, PA 19348
Mr. Jeffrey A. Benjamin Vice President-Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Mr. Joseph Hagan Senior Vice President Mid-Atlantic Regional Operating Group Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Mr. John Skolds Chief Operating Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Mr. William Bohlke Senior Vice President, Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Mr. James Meister Senior Vice President, Operations Support Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Mr. Alan Nelson Nuclear Energy Institute 1776 I Street, Suite 400 Washington, DC 20006