ML080380530
| ML080380530 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 03/03/2008 |
| From: | John Hughey NRC/NRR/ADRO/DORL/LPLI-2 |
| To: | Pardee C Exelon Generation Co |
| Hughey J, NRR/DORL, 301-415-3204 | |
| References | |
| TAC MD7461, TAC MD7462 | |
| Download: ML080380530 (5) | |
Text
March 3, 2008 Mr. Charles G. Pardee Chief Nuclear Officer and Senior Vice President Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 RELIEF REQUESTS ASSOCIATED WITH THE FOURTH INSERVICE TESTING INTERVAL (TAC NOS. MD7461 AND MD7462)
Dear Mr. Pardee:
By letter to the Nuclear Regulatory Commission (NRC) dated November 28, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML073330605), Exelon Generation Company, LLC (the licensee), submitted Relief Requests associated with the fourth inservice testing interval for Peach Bottom Atomic Power Station, Units 2 and 3. The NRC staff has reviewed the request submitted by the licensee and has identified a need for additional information as set forth in the Enclosure.
The draft questions were sent to Tom Loomis, from your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. On February 13, 2008, Mr. Loomis indicated that the licensee will submit a response by March 19, 2008. Please note that if you do not respond to this letter by the agreed-upon date or provide an acceptable alternate date in writing, we may reject your application for amendment under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108. If you have any questions, please contact John Hughey at (301) 415-3204.
Sincerely,
/ra/
John D. Hughey, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278 cc: See next page
March 3, 2008 Mr. Charles G. Pardee Chief Nuclear Officer and Senior Vice President Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348
SUBJECT:
PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 RELIEF REQUESTS ASSOCIATED WITH THE FOURTH INSERVICE TESTING INTERVAL (TAC NOS. MD7461 AND MD7462)
Dear Mr. Pardee:
By letter to the Nuclear Regulatory Commission (NRC) dated November 28, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML073330605), Exelon Generation Company, LLC (the licensee), submitted Relief Requests associated with the fourth inservice testing interval for Peach Bottom Atomic Power Station, Units 2 and 3. The NRC staff has reviewed the request submitted by the licensee and has identified a need for additional information as set forth in the Enclosure.
The draft questions were sent to Tom Loomis, from your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. On February 13, 2008, Mr. Loomis indicated that the licensee will submit a response by March 19, 2008. Please note that if you do not respond to this letter by the agreed-upon date or provide an acceptable alternate date in writing, we may reject your application for amendment under the provisions of Title 10 of the Code of Federal Regulations, Section 2.108. If you have any questions, please contact John Hughey at (301) 415-3204.
Sincerely,
/ra/
John D. Hughey, Project Manager Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-277 and 50-278 cc: See next page DISTRIBUTION:
PUBLIC LPLI-2 R/F RidsNrrPMJHughey RidsNrrLAABaxter STingen RidsRgn1MailCenter RidsNrrDorlLpl1-2 JMcHale ADAMS Accession Number: ML080380530 OFFICE LPL1-2/PM LPL1-2/LA CPTB/BC LPL1-2/BC NAME JHughey ABaxter JMcHale HChernoff DATE 2/14/2008 2/27/2008 2/14/2008 3/3/2008 OFFICIAL RECORD COPY
Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 cc:
Site Vice President Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Plant Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Regulatory Assurance Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Chief Operating Officer (COO)
Exelon Nuclear Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Resident Inspector U.S. Nuclear Regulatory Commission Peach Bottom Atomic Power Station P.O. Box 399 Delta, PA 17314 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. Roland Fletcher Department of Environment Radiological Health Program 2400 Broening Highway Baltimore, MD 21224 Correspondence Control Desk Exelon Generation Company, LLC 200 Exelon Way, KSA 1N1 Kennett Square, PA 19348 Director, Bureau of Radiation Protection Pennsylvania Department of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Board of Supervisors Peach Bottom Township 545 Broad Street Ext.
Delta, PA 17314-9203 Mr. Richard McLean Power Plant and Environmental Review Division Department of Natural Resources B-3, Tawes State Office Building Annapolis, MD 21401 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Manager-Financial Control & Co-Owner Affairs Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038-0236 Manager Licensing-Peach Bottom Atomic Power Station Exelon Generation Company, LLC P.O. Box 160 Kennett Square, PA 19348 Vice President - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 cc:
Senior Vice President-Mid-Atlantic Operations Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Senior Vice President - Operations Support Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Director - Licensing and Regulatory Affairs Exelon Generation Company LLC Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Associate General Counsel Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUESTS FOR RELIEF ASSOCIATED WITH THE FOURTH INSERVICE TESTING INTERVAL PEACH BOTTOM ATOMIC POWER STATION, UNITS NO. 2 AND 3 DOCKET NOS. 50-277 AND 50-278 By letter dated November 28, 2007, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML073330605), Exelon Generation Company, LLC, submitted Relief Requests associated with the Fourth Inservice Testing Interval for Peach Bottom Atomic Power Station, Unit Nos. 2 and 3. The Nuclear Regulatory Commission (NRC) staff has reviewed the requests for relief the licensee provided in the November 28, 2007, submittal. In order for the NRC staff to complete its evaluation, response to the following requests for additional information (RAI) questions is requested.
RAIs Regarding Relief Request 01A-VRR-1:
RAI-01.1) Relief from an American Society of Mechanical Engineers Operation and Maintenance (ASME OM) Code relief valve 5-year setpoint test requirement is requested in accordance with Title 10 of the Code of Federal Regulations, Part 50, (10 CFR Part 50) Section 50.55a(a)(3)(ii). Explain why compliance with this requirement would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.
RAI-01.2) Explain why safety relief valve S/N 73 was not tested during the September 2007 Unit 3 refueling outage.
RAIs Regarding Relief Request 01A-VRR-2:
RAI-02)
Describe how proper installation of the electrical and air line connections to each pilot valve is verified following installation of the pilot and main valve assembly in the unit.
RAIs Regarding Relief Request GVRR-1:
RAI-03.1) Clarify the specific requirements in the ASME OM Code for which relief is requested.
RAI-03.2) Identify the differences between the version of OMN-1 in the 2006 Addenda of the ASME OM Code and the version of OMN-1 conditionally approved in Regulatory Guide (RG) 1.192, Operation and Maintenance Code Case Acceptability, ASME OM Code. Discuss if the conditions for use of OMN-1 listed in RG 1.192 are applicable to the version of OMN-1 in the 2006 Addenda of the ASME OM Code.
Enclosure
RAI-03.3) Relief Request GVRR-1 is requested pursuant to 10 CFR 50.55a(a)(3)(i) based on an alternative providing an acceptable level of quality and safety. However, GVRR-1 includes an exception to the ASME OMb Code-2006, OMN-1, Rev. 1, Section 3.6.1 which cites only hardship as a basis for relief. Describe how the proposed alternative provides an acceptable level of quality and safety. Include in this description an explanation of why the separation of oil and grease in a motor operated valve (MOV) actuator is not an issue for periods that exceed 24 months between cycling. Identify the approximately 20 MOVs to which this exception would apply and specifically explain why each MOV cannot be cycled every 24 months.
RAIs Regarding Relief Request GVRR-2:
RAI-04)
Clarify the specific requirements in ASME OM Code ISTC-3522, ISTC-5221, ISTC-5222, and ISTC-5223 that relief is being requested and why relief is needed for each requirement.