ML051040547
| ML051040547 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 06/14/2005 |
| From: | George Wunder NRC/NRR/DLPM/LPD1 |
| To: | Crane C Exelon Generation Co |
| Wunder G, NRR/DLPM, 415-1494 | |
| References | |
| TAC MC4947, TAC MC4948 | |
| Download: ML051040547 (16) | |
Text
June 14, 2005 Mr. Christopher M. Crane President and Chief Nuclear Officer Exelon Nuclear Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 - ISSUANCE OF AMENDMENT RE: MONTHLY OPERATING REPORTS AND ANNUAL OCCUPATIONAL RADIATION EXPOSURE REPORTS (TAC NOS. MC4947 AND MC4948)
Dear Mr. Crane:
The Commission has issued the enclosed Amendments Nos. 254 and 257 to Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station, Units 2 and 3, respectively. These amendments consist of changes to the Technical Specifications (TSs) in response to your application dated October 21, 2004.
These amendments delete the TS requirements to submit monthly operating reports and annual occupational radiation exposure reports. The change is consistent with Revision 1 of the Nuclear Regulatory Commission's approved Technical Specifications Task Force (TSTF)
Change Traveler, TSTF-369, "Elimination of Requirements for Monthly Operating Reports and Occupational Radiation Exposure Reports." This TS improvement was published in the Federal Register (69 FR 35067) on June 23, 2004, as part of the Consolidated Line Item Improvement Process.
A copy of our safety evaluation is also enclosed. Notice of Issuance will be included in the Commission's biweekly Federal Register notice.
Sincerely,
/RA/
George F. Wunder, Project Manager, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278
Enclosures:
- 1. Amendment No. 254 to Renewed DPR-44
- 2. Amendment No. 257 to Renewed DPR-56
- 3. Safety Evaluation cc w/encls: See next page
ML051040547 NRR-058 OFFICE PM/PD1-2 PD3-2:PM LA/PD1-2 Tech Branch SC/PD1-2 NAME GWunder SSands MOBrien WReckley REnnis for DRoberts DATE 06/09/05 4/28/05 4/28/05 4/18/05 06/10/05 Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 cc:
Site Vice President Rich Janati, Chief Peach Bottom Atomic Power Station Division of Nuclear Safety Exelon Generation Company, LLC Bureau of Radiation Protection 1848 Lay Road Department of Environmental Protection Delta, PA 17314 Rachel Carson State Office Building P.O. Box 8469 Associate General Counsel Harrisburg, PA 17105-8469 Exelon Generation Company, LLC 4300 Winfield Road Board of Supervisors Warrenville, IL 60555 Peach Bottom Township 545 Broad Street Ext.
Plant Manager Delta, PA 17314-9203 Peach Bottom Atomic Power Station Exelon Generation Company, LLC Mr. Richard McLean 1848 Lay Road Power Plant and Environmental Delta, PA 17314 Review Division Department of Natural Resources Regulatory Assurance Manager B-3, Tawes State Office Building Peach Bottom Atomic Power Station Annapolis, MD 21401 Exelon Generation Company, LLC 1848 Lay Road Dr. Judith Johnsrud Delta, PA 17314 National Energy Committee Sierra Club Resident Inspector 433 Orlando Avenue U.S. Nuclear Regulatory Commission State College, PA 16803 Peach Bottom Atomic Power Station P.O. Box 399 Manager-Financial Control & Co-Owner Delta, PA 17314 Affairs Public Service Electric and Gas Company Regional Administrator, Region I P.O. Box 236 U.S. Nuclear Regulatory Commission Hancocks Bridge, NJ 08038-0236 475 Allendale Road King of Prussia, PA 19406 Manager Licensing-Peach Bottom Atomic Power Station Mr. Roland Fletcher Exelon Generation Company, LLC Department of Environment 200 Exelon Way, KSA -3E Radiological Health Program Kennett Square, PA 19348 2400 Broening Highway Baltimore, MD 21224 Correspondence Control Desk Exelon Generation Company, LLC P. O. Box 160 Kennett Square, PA 19348
Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 cc:
Vice President - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Vice President-Operations Mid-Atlantic Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Senior Vice President, Nuclear Services Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director-Licensing and Regulatory Affairs Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348
EXELON GENERATION COMPANY, LLC PSEG NUCLEAR LLC DOCKET NO. 50-277 PEACH BOTTOM ATOMIC POWER STATION, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 254 Renewed License No. DPR-44
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Exelon Generation Company, LLC (Exelon Generation Company), and PSEG Nuclear LLC (the licensees), dated October 21, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I.
B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Renewed Facility Operating License No. DPR-44 is hereby amended to read as follows:
(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 254, are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications.
- 3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA by REnnis for/
Darrell J. Roberts, Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: June 14, 2005
ATTACHMENT TO LICENSE AMENDMENT NO. 254 RENEWED FACILITY OPERATING LICENSE NO. DPR-44 DOCKET NO. 50-277 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert 5.0-19 5.0-19 5.0-20 5.0-20
EXELON GENERATION COMPANY, LLC PSEG NUCLEAR LLC DOCKET NO. 50-278 PEACH BOTTOM ATOMIC POWER STATION, UNIT 3 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 257 Renewed License No. DPR-56
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Exelon Generation Company, LLC (Exelon Generation Company), and PSEG Nuclear LLC (the licensees), dated October 21, 2004, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I.
B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.
- 2. Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C(2) of Renewed Facility Operating License No. DPR-56 is hereby amended to read as follows:
(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 257, are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications.
- 3. This license amendment is effective as of its date of issuance and shall be implemented within 60 days.
FOR THE NUCLEAR REGULATORY COMMISSION
/RA by REnnis for/
Darrell J. Roberts, Chief, Section 2 Project Directorate I Division of Licensing Project Management Office of Nuclear Reactor Regulation
Attachment:
Changes to the Technical Specifications Date of Issuance: June 14, 2005
ATTACHMENT TO LICENSE AMENDMENT NO. 257 RENEWED FACILITY OPERATING LICENSE NO. DPR-56 DOCKET NO. 50-278 Replace the following pages of the Appendix A Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Insert 5.0-19 5.0-19 5.0-20 5.0-20
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 254 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-44 AND AMENDMENT NO. 257 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-56 EXELON GENERATION COMPANY, LLC PSEG NUCLEAR LLC PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278
1.0 INTRODUCTION
By application dated October 21, 2004, Exelon Generation Company, LLC (the licensee) requested changes to the Technical Specifications (TSs) for the Peach Bottom Atomic Power Station, Units 2 and 3 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML042990134). The Nuclear Regulatory Commission (NRC) proposed no significant hazards consideration determination was published in the Federal Register on April 12, 2005 (70 FR 19116).
The amendments will delete the TS requirements to submit monthly operating reports and annual occupational radiation exposure reports. The change is consistent with Revision 1 of NRC-approved Technical Specifications Task Force (TSTF) Change Traveler, TSTF-369, "Elimination of Requirements for Monthly Operating Reports and Occupational Radiation Exposure Reports." This TS improvement was published in the Federal Register (69 FR 35067) on June 23, 2004, as part of the Consolidated Line Item Improvement Process (CLIIP).
2.0 REGULATORY EVALUATION
Section 182a. of the Atomic Energy Act of 1954, as amended, (the Act) requires applicants for nuclear power plant operating licenses to state such TSs as the Commission may deem necessary. Such TSs shall be a part of the license issued. The Commission's regulatory requirements related to the content of TSs are set forth in Title 10 of the Code of Federal Regulations (10 CFR) 50.36, ?Technical specifications. The regulation requires that TSs include items in five specific categories, including (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCO); (3) surveillance requirements; (4) design features; and (5) administrative controls. However, the regulation does not specify the particular requirements to be included in a plant's TSs.
The Commission has provided guidance for the content of TSs in its "Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors," (58 FR 39132, published July 22, 1993) in which the Commission indicated that compliance with the Final Policy Statement satisfies Section 182a. of the Act. The Final Policy Statement identified four criteria to be used in determining whether a particular item should be addressed in the TSs as an LCO.
The criteria were subsequently incorporated into 10 CFR 50.36 (60 FR 36593, published July 19, 1995). While the criteria specifically apply to LCO, the Commission indicated that the intent of these criteria may be used to identify the optimum set of administrative controls in the TSs. Addressing administrative controls, 10 CFR Part 50.36 states that they are ?the provisions relating to organization and management, procedures, record keeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. The specific content of the administrative controls section of the TSs is, therefore, related to those programs and reports that the Commission deems essential for the safe operation of the facility, which are not adequately covered by regulations or other regulatory requirements. Accordingly, the NRC staff may determine that specific requirements, such as those associated with this change, may be removed from the administrative controls in the TSs if they are not explicitly required by 10 CFR 50.36(c)(5) and are not otherwise necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety.
The impetus for the monthly operating report (MOR) came from the 1973-1974 oil embargo.
Regulatory Guide 1.16, Revision 4, ?Reporting of Operating Information--Appendix A Technical Specifications, published for comment in August 1975, identifies operating statistics and shutdown experience information that was desired in the operating report at that time. In the mid-1990s, the NRC staff assessed the information that is submitted in the MOR and determined that while some of the information was no longer used by the NRC staff, the MOR was the only source of some data used in the NRC Performance Indicator (PI) Program of that time period (see NRC Generic Letter (GL) 97-02, ?Revised Contents of the Monthly Operating Report). Beginning in the late 1990s, the NRC developed and implemented a major revision to its assessment, inspection, and enforcement processes through its Reactor Oversight Process (ROP). The ROP uses both plant-level PI and inspections performed by NRC personnel. In conjunction with the development of the ROP, the NRC developed the Industry Trends Program (ITP). The ITP provides the NRC a means to assess overall industry performance using industry level indicators and to report on industry trends to various stakeholders (e.g., Congress). Information from the ITP is used to assess the NRC's performance related to its goal of having ?no statistically significant adverse industry trends in safety performance.
The ITP uses some of the same PI as the PI Program from the mid-1990s and, therefore, the NRC has a continuing use for the data provided in MOR. The NRC also uses some data from the MOR to support the evaluation of operating experience, licensee event reports, and other assessments performed by the NRC staff and its contractors.
The reporting requirements for the MOR include challenges to the safety/relief valves. The reporting of challenges to the safety/relief valves was included in TSs based on the guidance in NUREG-0694, "[Three Mile Island] TMI-Related Requirements for New Operating Licensees."
The industry proposed and the NRC accepted the elimination of the reporting requirements in TSs for challenges to safety/relief valves in Revision 4 to TSTF-258, "Changes to Section 5.0, Administrative Controls." The NRC staff's acceptance of TSTF-258 and subsequent approval of plant-specific adoptions of TSTF-258 is based on the fact that the information on challenges to relief and safety valves is not used in the evaluation of the MOR data, and that the
information needed by the NRC is adequately addressed by the reporting requirements in 10 CFR 50.73, "Licensee event reports."
Licensees are required by TSs to submit annual occupational radiation exposure reports (ORER) to the NRC. These reports, developed in the mid-1970s, supplement the reporting requirements currently defined in 10 CFR 20.2206, ?Reports of individual monitoring, by providing a tabulation of data by work areas and job functions. The NRC included data from the ORER in its annual publication of NUREG-0713, ?Occupational Radiation Exposure at Commercial Nuclear Power Reactors and Other Facilities, through the year 1997, but no longer includes the data in that or other reports.
3.0 TECHNICAL EVALUATION
3.1 MORs (Section 5.6.4 for Peach Bottom Atomic Power Station, Units 2 and 3)
As previously mentioned, the administrative requirements in the TSs are reserved for ?the provisions relating to organization and management, procedures, record keeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. The current use of the information from the MOR is not related to reporting on or confirming the safe operation of specific nuclear power plants. Instead, the data is used by the NRC to assess and communicate with stakeholders regarding the overall performance of the nuclear industry. Data related to PI for specific plants are reported to the NRC as part of the ROP. The NRC staff has determined that the MOR do not meet the criteria defined for requirements to be included in the administrative section of TSs and the reporting requirement may, therefore, be removed.
Although the MOR do not satisfy the criteria for inclusion in TSs, the NRC staff nevertheless has a continuing need to receive the data in order to compile its reports on industry trends and to support other evaluations of operating experience. In addition, information such as plant capacity factors that are reported in the MOR are useful to the NRC staff and are frequently asked for by agency stakeholders.
The NRC staff interacted with licensees, industry organizations, and other stakeholders during the development of the Consolidated Data Entry (CDE) program (currently being developed and maintained by the Institute of Nuclear Power Operations), regarding the use of an industry database like CDE to provide data currently obtained from the MOR. These discussions also involved the related Revision 1 to TSTF-369, ?Elimination of Requirements for Monthly Operating Reports and Occupational Radiation Exposure Reports. As described in Section 4.0 of this safety evaluation (SE), the licensee is making a regulatory commitment to continue to provide the data identified in GL 97-02, following the removal of the TS requirement to submit MOR, and will, therefore, continue to meet the needs of the NRC staff for the ITP and other evaluations. The use of an industry database such as CDE is more efficient and cost-effective for both the NRC and licensees than would be having the NRC staff obtain the needed information from other means currently available. Should a licensee fail to satisfy the regulatory commitment to voluntarily provide the information, the NRC could obtain the information through its inspection program (similar to the process described in NRC Inspection Procedure 71150, ?Discrepant or Unreported Performance Indicator Data) with the licensee being charged for the time spent by the NRC staff.
The only significant changes resulting from the adoption of TSTF-369 are that the information will be provided quarterly instead of monthly (although the operating data will still be divided by
month) and the form of the reporting will be from a consolidated database such as CDE instead of in correspondence from individual licensees. The change of reporting frequency to quarterly has some advantages for both the NRC staff and licensees, since it will coincide with the collection and submission of the ROP PI data. In terms of the specific method used to transmit the data to the NRC, the licensee has committed (see Section 4.0 below) to provide data identified in GL 97-02 on a quarterly basis. The NRC staff believes that the most efficient process for licensees and the NRC will be for all licensees to use a system such as CDE. Such systems have advantages in terms of improved data entry, data checking, and data verification and validation. The NRC will recognize efficiency gains by having the data from all plants reported using the same computer software and format. Although the data may be transmitted to the NRC from an industry organization maintaining a database such as CDE, the licensee provides the data for the system and remains responsible for the accuracy of the data submitted to the NRC for its plant(s). The public will continue to have access to the data through official agency records accessible in ADAMS.
The content requirements for the Peach Bottom Atomic Power Station, Units 2 and 3, MOR currently include information on challenges to the safety/relief valves. As discussed in the previous section, the NRC staff has documented in its approval of TSTF-258 and related plant-specific amendments that the reporting of challenges to safety/relief valves may be removed from TSs since the information needed by the NRC is adequately addressed by the reporting requirements in 10 CFR 50.73, ?Licensee event report. The NRC staff finds it acceptable to remove the requirement to report challenges to safety/relief valves along with the other reporting requirements associated with the MOR.
3.2 Occupational Radiation Exposure Reports (Section 5.6.1 Peach Bottom Atomic Power Station, Units 2 and 3)
The information that the NRC staff needs regarding occupational doses is provided by licensees in the reports required under 10 CFR Part 20. The data from the Part 20 reports are sufficient to support the NRC trending programs, radiation related studies, and preparation of reports such as NUREG-0713. Accordingly, the NRC's limited use of the ORER submitted pursuant to the existing TS requirements no longer warrants the regulatory burden imposed on licensees. Therefore, the NRC staff finds it acceptable that Section 5.6.1 for Peach Bottom Atomic Power Station, Units 2 and 3, is being deleted and the ORER will no longer be submitted by the licensee.
4.0 VERIFICATIONS AND COMMITMENTS In order to efficiently process incoming license amendment applications, the NRC staff requested each licensee requesting the changes addressed by TSTF-369 using the CLIIP to address the following plant-specific regulatory commitment.
Each licensee should make a regulatory commitment to provide to the NRC using an industry database the operating data (for each calender month) that is described in GL 97-02 ?Revised Contents of the Monthly Operating Report, by the last day of the month following the end of each calendar quarter. The regulatory commitment will be based on use of an industry database (e.g., the industry's CDE program, currently being developed and maintained by the Institute of Nuclear Power Operations).
The licensee has made a regulatory commitment to provide to the NRC using an industry database the operating data (for each calendar month) that is described in GL 97-02 "Revised Contents of the Monthly Operating Report," by the last day of the month following the end of each calendar quarter. The regulatory commitment will be based on use of an industry database (e.g., the industry's CDE program, currently being developed and maintained by INPO). This regulatory commitment will be implemented to prevent any gaps in the monthly operating statistics and shutdown experience provided to the NRC (i.e., data for all months will be provided using one or both systems (MOR and CDE)).
Each licensee (operating different reactor types at a single site) or (possessing both operating and shutdown reactors at a single site) will include in its application a regulatory commitment to provide information to the NRC annually (e.g., with its annual submittal in accordance with 10 CFR 20.2206) to support the apportionment of station doses (to each type of reactor) or (to differentiate between operating and shutdown units). The data will provide the summary distribution of annual whole-body doses as presented in Appendix B of NUREG-0713 for each reactor type and for operating and shutdown units.
The licensee has made a regulatory commitment to provide information to the NRC annually to support the apportionment of the station doses to each type of reactor and to differentiate between operating and shutdown units.
The NRC staff finds that reasonable controls for the implementation and for subsequent evaluation of proposed changes pertaining to the above regulatory commitments can be provided by the licensee's administrative processes, including its commitment management program. The NRC staff has agreed that Nuclear Energy Institute 99-04, Revision 0,
?Guidelines for Managing NRC Commitment Changes, provides reasonable guidance for the control of regulatory commitments made to the NRC staff (see Regulatory Issue Summary 2000-17, ?Managing Regulatory Commitments Made by Power Reactor Licensees to the NRC Staff, dated September 21, 2000). The NRC staff notes that this amendment establishes a voluntary reporting system for the operating data that is similar to the system established for the ROP Pl Program. Should the licensee choose to incorporate a regulatory commitment into the final safety analysis report or other document with established regulatory controls, the associated regulations would define the appropriate change-control and reporting requirements.
5.0 STATE CONSULTATION
In accordance with the Commission's regulations, the Pennsylvania State official was notified of the proposed issuance of the amendments. The State official had no comments.
6.0 ENVIRONMENTAL CONSIDERATION
The amendments relate to changes in record keeping, reporting, or administrative procedures or requirements. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
7.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: W. Reckley Date: June 14, 2005