ML080770409
| ML080770409 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 04/17/2008 |
| From: | John Hughey NRC/NRR/ADRO/DORL/LPLI-2 |
| To: | Pardee C Exelon Generation Co |
| Hughey J, NRR/DORL, 301-415-3204 | |
| References | |
| TAC MD7029, TAC MD7030 | |
| Download: ML080770409 (6) | |
Text
April 17, 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 - REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR EXEMPTION FROM 10 CFR 50, APPENDIX R, SECTION III.G, FIRE PROTECTION OF SAFE SHUTDOWN CAPABILITY (TAC NOS. MD7029 AND MD7030)
Dear Mr. Pardee:
By letter to the Nuclear Regulatory Commission (NRC) dated October 5, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072820129), Exelon Generation Company, LLC (the licensee), submitted a Request for Exemption from Title 10 of the Code of Federal Regulations, Part 50,Section III.G, Fire Protection of Safe Shutdown Capability, 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 Glen Stewart, 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 March 31, 2008, Mr. Stewart indicated that the licensee will submit a response by May 2, 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
Enclosure:
Request for Additional Information cc: See next page
April 17,2008 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 - REQUEST FOR ADDITIONAL INFORMATION REGARDING REQUEST FOR EXEMPTION FROM 10 CFR 50, APPENDIX R, SECTION III.G, FIRE PROTECTION OF SAFE SHUTDOWN CAPABILITY (TAC NOS. MD7029 AND MD7030)
Dear Mr. Pardee:
By letter to the Nuclear Regulatory Commission (NRC) dated October 5, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072820129), Exelon Generation Company, LLC (the licensee), submitted a Request for Exemption from Title 10 of the Code of Federal Regulations, Part 50,Section III.G, Fire Protection of Safe Shutdown Capability, 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 Glen Stewart, 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 March 31, 2008, Mr. Stewart indicated that the licensee will submit a response by May 2, 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
Enclosure:
Request for Additional Information cc: See next page DISTRIBUTION:
PUBLIC LPLI-2 R/F RidsNrrPMJHughey RidsNrrLAABaxter RidsNrrDcicptb RidsRgn1MailCenter RidsNrrDorlLpl1-2 DFrumkin RVettori RidsOgcRp RidsAcrsAcnw&mMailCenter ADAMS Accession Number: ML080770409
- by memo dated OFFICE LPL1-2/PM LPL1-2/LA CPTB/BC LPL1-2/BC NAME JHughey ABaxter AKlein*
HChernoff DATE 4/08/2008 4/08/2008 02/27/2008 4/17/2008 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 REQUEST FOR EXEMPTION FROM 10 CFR 50 APPENDIX R, SECTION III.G PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-277 AND 50-278 By letter to the Nuclear Regulatory Commission (NRC) dated October 5, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072820129), Exelon Generation Company, LLC (the licensee), submitted a Request for Exemption from Title 10 of the Code of Federal Regulations (10 CFR), Part 50,Section III.G, Fire Protection of Safe Shutdown Capability, for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The NRC staff has reviewed the requests for relief the licensee provided in the October 5, 2007, submittal.
The licensee is requesting that the NRC approve an exemption request for manual actions previously approved in an NRC Fire Protection Safety Evaluation Report (SER). As described in Regulatory Issue Summary 2006-10, Regulatory Expectations with Appendix R Paragraph lll.G.2 Operator Manual Actions, an approved exemption is required for all operator manual actions for compliance with 10 CFR Part 50, Appendix R Section III.G.2, even those that were accepted in a previously-issued NRC SER for plants licensed before January 1, 1979. This exemption request is limited to those manual actions that were previously-accepted in an NRC SER for PBAPS.
of the exemption request lists the manual actions, in a table format, for which exemptions are being requested. The licensee has requested an exemption for a total of forty (40) manual actions. The previously-approved manual actions are listed in Table A-4, Revision 3, of the PBAPS Fire Protection Program document.
The NRC staff has identified that there is no clear connection between many of the submitted exemption requested manual actions in Attachment 2 and the approved manual actions listed in Table A-4, Revision 3, of the Fire Protection Program document.
For example, the first manual action listed in Attachment 2 of the Exemption Request has no corresponding or matching approved manual action in the Table A-4, Revision 3. The equipment listed for this manual action 20C32 is not listed in Table A-4, Revision 3. The action required for this manual action, Install U2 plug-in test switch 2-10A-J1A at 20C032, is not listed in any of the operations in Table A-4, Revision 3.
The second manual action listed in Attachment 2 has the item 2BS456 listed under the heading equipment. This item appears in the third manual action listed in Table A-4, Revision 3, under the heading component. The action or operations described in Attachment 2 and Table 4 are similar, however, in the exemption request there is an additional step that is not included in Table A-4, Revision 3.
Enclosure
Additionally, some of the approved manual actions listed in Table A-4, Revision 3, appear to have been divided into two separate manual actions, but there is no clear connection between the approved action and the submitted actions. For example, Attachment 2 provides equipment numbers for breakers that are not listed in Table A-4, Revision 3. The NRC staff needs to know which requested actions correspond to which approved actions.
In order for the NRC staff to complete its evaluation, response to the following requests for additional information (RAI) questions is requested.
RAI-01)
Provide a cross-reference for all actions submitted in Attachment 2 of the exemption request with those listed in Table A-4, Revision 3. This cross-reference should include, the fire affected component number, its system, its name, and the fire area it is located in. For the component that is to be operated, include its number, its system, its name, the fire area it is located in, and a brief description of the action required to be taken at the component. Also, include the original approved description of the action, and any differences between the approved action and the submitted action (number, name, system designation, fire area, description of action).
RAI-02),Section II, asserts that the basis for the exemption request per 10 CFR 50.12(a)(2)(ii) is that the referenced manual actions have already been found acceptable by the NRC in a prior SER. Describe the specific special circumstances that justify why application of the regulation does not meet the underlying purpose of the rule. Alternatively, provide other bases for the special circumstances.