ML100200086
| ML100200086 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 01/19/2010 |
| From: | David Helker Exelon Generation Co, Exelon Nuclear |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML100200086 (3) | |
Text
Exelon Nuclear 200 Exelon Way Kennett Square, PA 19348 January 19, 2010 www.exeloncorp.com Nuclear 10 CFR 50.90 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:
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes
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 (ML090970796) 3)
Letter from P. B. Cowan (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information -
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes - TSTF-363-A," dated May 7,2009 4)
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 - Issuance of Amendments RE: Incorporation of Previously NRC-Approved TSTFs and Other Administrative Changes (TAC NOS. MD9434, MD9435, MD9447, MD9448, MD9449, MD9450, MD9451, MD9452, MD9454, MD9455, MD9456 and MD9457)," dated August 31, 2009 (ML092250339) 5)
Letter from S. L. Rosenberg (U.S. Nuclear Regulatory Commission) to Technical Specification Task Force, "Technical Specification Task Force (TSTF) Traveler 363, Revision 0, "Revise Topical Report References in ITS 5.6.5, COLR," dated November 2, 2009 (ML092151016)
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes January 19, 2010 Page 2 6)
Letter from S. L. Rosenberg (U.S. Nuclear Regulatory Commission) to Technical Specification Task Force, "Technical Specifications Task Force Traveler TSTF-363, Revision 0, "Revise Topical Report References in ITS 5.6.5, COLR," dated December 11, 2009 (ML093100498)
In the Reference 1 letter, Exelon Generation Company, LLC (Exelon) requested proposed changes to incorporate various NRC-approved Technical Specification Task Force travelers (TSTFs) and other administrative changes. Reference 2 contained a request for additional information concerning TSTF-363-A, and Reference 3 provided our response. Reference 4 contained partial approval of the Reference 1 request.
Included in the Reference 1 submittal is a request for NRC approval to adopt TSTF-363-A, Revision 0, "Revise Topical Report References in ITS 5.6.5, COLR." As discussed in References 5 and 6, the NRC has revised its position with respect to the generic acceptability of TSTF-363-A. As a result of this change in position, Exelon is no longer requesting approval of TSTF-363-A, and hereby withdraws this request.
Also included in the Reference 1 submittal are requests for NRC approval to adopt TSTF-400-A, Revision 1, "Clarify SR on Bypass of DG Automatic Trips," and TSTF-439-A, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCO."
The following information is being submitted regarding TSTF-400-A and TSTF-439-A:
TSTF-400-A. Revision 1. "Clarify SR on Bypass of DG Automatic Trips":
With regards to TSTF-400-A, Revision 1, the following discussion will be added to the Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3, Updated Final Safety Analysis Report (UFSAR):
- 1) A listing of the critical diesel generator trips. Also, a list of non-critical trips will be added to the PBAPS, Units 2 and 3, UFSAR. This will ensure that revisions to these trips will be evaluated per the criteria of 10 CFR 50.59 to determine if a license amendment request is required.
- 2) A description of the testing of the diesel generator critical trips similar to that below will be placed in the PBAPS, Units 2 and 3, UFSAR. This will ensure that application of the 10 CFR 50.59 screening criteria will result in an evaluation under 10 CFR 50.59:
Critical diesel generator (DG) protective trip functions are tested periodically per station procedures. The critical DG protective trip functions are tested by inputting or simulating appropriate signals and demonstrating that the associated instrumentation logic will function to actuate a trip of the DG.
License Amendment Request to Incorporate Previously NRC-Approved TSTFs and Other Administrative Technical Specifications Changes January 19, 2010 Page 3 TSTF-439-A, Revision 2, "Eliminate Second Completion Times Limiting Time From Discovery of Failure to Meet an LCD":
With regards to TSTF-439-A, Revision 2, Exelon will revise OP-PB-1 08-1 04, Regulatory Compliance Action Logs, to implement the guidance contained in TSTF-439-A, Revision 2.
Specifically:
It is possible to alternate between Technical Specification Conditions in such a manner that operation could continue indefinitely without ever restoring systems to meet the LCD. However, doing so would be inconsistent with the basis of the Completion Times.
Therefore, the maximum time allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCD shall be limited. The Completion Times for those Conditions shall not be inappropriately extended.
OP-PB-1 08-1 04 provides guidance for documenting the entrance into Technical Specification Actions when an applicable Limiting Condition for Operation is not met. This document also provides supplemental guidance for interpreting and applying the requirements of the Technical Specifications.
Exelon is requesting an extension of the implementation period to 120 days for TSTF-400-A, Revision 1, and TSTF-439-A, Revision 2, to ensure the UFSAR and the procedure, respectively, are revised in a timely manner.
There are no regulatory commitments contained in this letter.
Should you have any questions concerning this letter, please contact Tom Loomis at (610) 765-5510.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19th of January 2010.
Respectfully, David P. Helker Manager, Licensing & Regulatory Affairs Exelon Generation Company, LLC 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