ML061740580

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RAI Related to Alternate Source Term Amendment Request
ML061740580
Person / Time
Site: Byron, Braidwood  Constellation icon.png
Issue date: 06/28/2006
From: Robert Kuntz
Plant Licensing Branch III-2
To: Crane C
Exelon Generation Co
Kuntz, Robert , NRR/DLPM, 415-3733
References
TAC MC6221, TAC MC6222, TAC MC6223, TAC MC6224
Download: ML061740580 (6)


Text

June 28, 2006 Mr. Christopher M. Crane, President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNIT 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO ALTERNATE SOURCE TERM AMENDMENT REQUEST (TAC NOS. MC6221, MC6222, MC6223, AND MC6224)

Dear Mr. Crane:

By letter to the Nuclear Regulatory Commission (NRC) dated February 15, 2005, Exelon Generation Company, LLC submitted a license amendment request related to application of alternate source term, for the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on June 5, 2006, it was agreed that you would provide a response 60 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-3733.

Sincerely,

/RA/

Robert F. Kuntz, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-454, STN 50-455, STN 50-456 and STN 50-457

Enclosure:

Request for Additional Information cc w/encl: See next page

Mr. Christopher M. Crane, President June 28, 2006 and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNIT 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO ALTERNATE SOURCE TERM AMENDMENT REQUEST (TAC NOS. MC6221, MC6222, MC6223, AND MC6224)

Dear Mr. Crane:

By letter to the Nuclear Regulatory Commission (NRC) dated February 15, 2005, Exelon Generation Company, LLC submitted a license amendment request related to application of alternate source term, for the Byron Station, Units 1 and 2, and Braidwood Station, Units 1 and 2.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on June 5, 2006, it was agreed that you would provide a response 60 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-3733.

Sincerely,

/RA/

Robert F. Kuntz, Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-454, STN 50-455, STN 50-456 and STN 50-457

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION:

PUBLIC LPL3-2 R/F RidsNrrDorlLpl3-2 RidsNrrPMRKuntz RidsNrrLADClarke RidsAcrsAcnwMailCenter RidsOgcRp RidsRgn3MailCenter RidsNrrDorlDpr ADAMS Accession Number: ML061740580 OFFICE LPL3-2/PM LPL3-2/LA SCVB/BC LPL3-2/BC NAME RKuntz:mw DClarke (EWhitt for)

RDennig DCollins DATE 6/26/06 6/26/06 6/28/06 6/28/06 OFFICIAL RECORD COPY

Byron/Braidwood Stations cc:

Dwain W. Alexander, Project Manager Westinghouse Electric Corporation Energy Systems Business Unit Post Office Box 355 Pittsburgh, PA 15230-0355 Joseph Gallo Gallo & Ross 1025 Connecticut Ave., NW, Suite 1014 Washington, DC 20036 Howard A. Learner Environmental Law and Policy Center of the Midwest 35 East Wacker Dr., Suite 1300 Chicago, IL 60601-2110 U.S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 N. German Church Road Byron, IL 61010-9750 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Ms. Lorraine Creek RR 1, Box 182 Manteno, IL 60950 Chairman, Ogle County Board Post Office Box 357 Oregon, IL 61061 Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, IL 61107 George L. Edgar Morgan, Lewis and Bockius 1800 M Street, NW Washington, DC 20036-5869 Attorney General 500 S. Second Street Springfield, IL 62701 Illinois Emergency Management Agency Division of Disaster Assistance &

Preparedness 110 East Adams Street Springfield, IL 62701-1109 Byron Station Plant Manager Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 Site Vice President - Byron Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 U.S. Nuclear Regulatory Commission Braidwood Resident Inspectors Office 35100 S. Rt. 53, Suite 79 Braceville, IL 60407 County Executive Will County Office Building 302 N. Chicago Street Joliet, IL 60432 Braidwood Station Plant Manager Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Ms. Bridget Little Rorem Appleseed Coordinator 117 N. Linden Street Essex, IL 60935

Byron/Braidwood Stations Document Control Desk - Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Site Vice President - Braidwood Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Senior Vice President of Operations Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Regulatory Assurance Manager - Braidwood Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Regulatory Assurance Manager - Byron Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 Assistant General Counsel Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348 Vice President - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Licensing - Braidwood, Byron and LaSalle Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

Enclosure REQUEST FOR ADDITIONAL INFORMATION BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2 DOCKET NOS. STN 50-454, STN 50-455, STN 50-456 AND STN 50-457 In reviewing the Exelon Generation Companys (Exelons) submittal dated February 15, 2005, related to a license amendment request related to application of alternate source term, for the Byron Station, Units 1 and 2 (Byron) and Braidwood Station, Units 1 and 2, the NRC staff has determined that the following information is needed in order to complete its review:

1.

Your submittal requested a change to the note on Technical Specification (TS) page 3.9.4-1 from LCO 3.7.13 to TS 3.7.13. Clarify how changing the wording from LCO to TS changes the applicability of the note, or alternatively, reword the note so that it explicitly defines when the note is applicable. (RAI category 4, unclear TS requirement).

2.

In the program manual section 5.5.11 the requested change is from 0.05% bypass to 1.0% bypass. The 0.05% bypass is a system integrity test specified in ANSI N510, and stated in section C.5.d of Regulatory Guide (RG) 1.52 to insure leak tightness. Please explain how system integrity will be ensured given this proposed deviation from the RG 1.52 guidance. (RAI category 2.d).

RAI CATEGORIES (Select only one, most dominant category for each RAI question) 1.

More information is needed because of:

a. complexity of request
b. first-of-a-kind nature of request
c. NRC change in regulatory significance or focus
d. NRC questions on previously used methodology or guidance
e. licensee change to previously used methodology
f. licensee reduction in current safety margin 2.

The review can not be completed without additional explanation or clarification of:

a. input variables or analytical assumptions
b. methodology used or results obtained
c. applicability or bounding nature of third party analyses or data correlations
d. differences from NRC guidance documents (SRP, RG, etc.)
e. no significant hazards consideration discussion
f. environmental considerations discussion
g. applicable regulatory requirements discussion
h. information that appears to be incorrect and needs to be corrected
i. response to previous RAI appears inadequate 3.

Reviewer requesting information even though the question is, or the question asks for:

a. not directly related to the request
b. inconsistent with applicable codes, standards, RGs, or SRP sections
c. information accessible from readily available sources and was explicitly referenced
d. information does not appear needed given the precedent cases discussed in the request
e. information that is not safety significant or pertinent to the regulatory finding
f. information that is known to engineers who work in the general technical area
g. going beyond the current licensing basis and doesnt need to be asked
h. a formal commitment 4.

Other (please specify)