ML091280686

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Response to Request for Additional Information - License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes - TSTF-363-A
ML091280686
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 05/07/2009
From: Cowan P
Exelon Generation Co, Exelon Nuclear
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
TSTF-363-A
Download: ML091280686 (7)


Text

Exelon Nuclear www.exeloncorp.com 200 Exelon Way Nuclear Kennett Square, PA 19348 10 CFR 50.90 May 7,2009 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278

Subject:

Response to Request for Additional Information - License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes - TSTF-363-A

References:

1) Letter from P. B. Cowan (Exelon Generation Company, LLC) to U. S.

Nuclear Regulatory Commission, "License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes," dated August 7,2008

2) Letter from J. D. Hughey (U. S. Nuclear Regulatory Commission) to C. G. Pardee (Exelon Generation Company, LLC), "Peach Bottom Atomic Power Station, Units 2 and 3 - Request for Additional Information Regarding License Amendment Request to Implement TSTF-363-A, Revision 0," dated April 15, 2009 In the Reference 1 letter, Exelon Generation Company, LLC (EGC) requested proposed changes to incorporate various NRC-approved Technical Specification Task Force travelers (TSTFs) and other administrative changes. Reference 2 contains a request for additional information concerning TSTF-363-A. Attached is our response to this request.

Additionally, in order to coordinate the implementation of this License Amendment Request with the Peach Bottom Atomic Power Station, Unit 3 outage, particularly, implementation of the

Response to RAI - License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes - TSTF-363-A May 7,2009 Page 2 outage-related Core Operating Limits Report, we are requesting that the implementation occur within 90 days rather than the previously requested 60 days.

No regulatory commitments are contained in this letter.

Should you have any questions concerning this letter, please contact Tom Loomis at (610) 765-5510.

h I declare under penalty of perjury that the foregoing is true and correct. Executed on the i of May 2009.

Respectfully,

~cl p!.~at1 Director, Licensing & Regulatory Affairs Exelon Generation Company, LLC Attachments: 1) Response to the Request for Additional Information - TSTF-363-A

2) Updated Markup of Proposed Technical Specifications Page Changes cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS R. R. Janati, Commonwealth of Pennsylvania S. T. Gray, State of Maryland

Attachment 1 Response to the Request for Additional Information - TSTF-363.. A

Response to the Request for Additional Attachment 1 Information - TSTF-363-A May 7,2009 Page 1 Question:

RAI-01: Please provide an explanation for the apparent deviation from TSTF-363-A of not including a proposed note in Technical Specification 5.6.5 indicating that the COLR provides the complete citation for the reports used. Please include a technical basis for the deviation.

Response

The following note has been added to the attached Technical Specifications markups for page 5.0-22 of Units 2 and 3:

The COLR will contain the complete identification for each of the Technical Specifications (TS) referenced topical reports used to prepare the COLR (Le., report number, title, revision, date, and any supplements).

Attachment 2 Updated Markup of Proposed Technical Specifications Page Changes Peach Bottom Atomic Power Station, Units 2 and 3 5.0-22

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

7. PECo-FMS-0005-A, "Methods for Performing BWR Steady-State Reactor Physics Analysis";
8. PECo-FMS-0006-A, "Methods for Performing BWR Reload Safety Evaluations"; and
9. NEDO-32465-A, "Reactor Stability Detect and Suppress Solutions LicenSin===aS~i~. M.ethodo1o gy And Reload

..::::-, App1 i cati on~ I9~ '--~ .

.. .------/' 1.;(

c. The core operating limits shall be determined such that all applicable limits (e.g., fuel thermal mechanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident analysis limits) of the safety analysis are met.
d. The COLR, including any midcyc1e revisions or supplements, shall be provided upon issuance. for each reload cycle to the NRC.

5.6.6 Post Accident Monitoring (PAM) Instrumentation Report When a report is required by Condition B or F of LCO 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperabi1ity, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

The COLR will contain the complete identification for each of the Technical Specifications (TS) referenced topical reports used to prepare the COLR (i.e., report r

'number, title, revision, date, and any supplements). ~


..._---~ ....---------

y PBAPS UNIT 2 5.0-22 Alnendlilent No. 251 "-

Reporting Requirements 5.6 5.6 Reporting Requirements 5.6.5 CORE OPERATING LIMITS REPORT (COLR) (continued)

7. PECb-FMS-0005-A, "Methods for Performing BWR Steady-State Reactor Physics Analysis";
8. PECo-FMS-0006-A, "Methods for Performing BWR Reload Safety Evaluations"; and
9. NEOO-32465-A, "Reactor Stabilit~etect and Suppress Solutions Licen~~ ~ ~~e~Ol09Y And Reload Appl i cati on1JJ ~1Dl' st ~r
c. The core o~~rating limits shall be determined such that all applicable limits (e.g., fuel thermal m.echanical limits, core thermal hydraulic limits, Emergency Core Cooling Systems (ECCS) limits, nuclear limits such as SDM, transient analysis limits, and accident'analysis limits) of the safety analysis are met.
d. The COLR, including any midcycle revisions or supplements, shall be provided upon issuance for each reload cycle to the NRC. I 5.6.6 Post Accident Monitoring (PAM) Instrumentation Report When a report is required by Condition B or F of LCO 3.3.3.1, "Post Accident Monitoring (PAM) Instrumentation," a report shall be submitted within the following 14 days. The report shall outline the preplanned alternate method of monitoring, the cause of the inoperability, and the plans and schedule for restoring the instrumentation channels of the Function to OPERABLE status.

The COLA will contain the complete identification for each of the Technical Specifications (TS) referenced topical reports used to prepare the COLA (Le. report number, title, revision, date, and any supplements). ' )

PBAPS UNIT 3 5.0-22 Amendment No. 254