ML14337A294

Response to Request for Additional Information Regarding Request to Revise Facility Operating Licenses and the Technical Specifications to Incorporate Administrative Changes

ML14337A294
Person / Time
Site:	Peach Bottom
Issue date:	12/01/2014
From:	Jim Barstow Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
TAC MF4401, TAC MF4402
Download: ML14337A294 (10)

Text

10 CFR 50.90 December 1, 2014 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 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 Regarding Request to Revise Facility Operating Licenses and the Technical Specifications to Incorporate Administrative Changes

References:

1) Letter from D. Helker (Exelon Generation Company, LLC) to the U.S.

Nuclear Regulatory Commission, "License Amendment Request to Revise Facility Operating License and the Technical Specifications to Incorporate Administrative Changes," dated July 11, 2014

2) Two E-mails from R. Ennis (U.S. Nuclear Regulatory Commission) to S.

Hanson (Exelon Generation Company, LLC), "Peach Bottom Atomic Power Station, Units 2 and 3- Draft Request for Additional Information regarding Proposed License Amendment to revise the Facility Operating License and Technical Specifications to Incorporate Administrative Changes (TAC NOS. MF4401 and MF4402)," dated November 12, 2014, and November 14, 2014 By letter dated July 11, 2014, Exelon Generation Company, LLC (Exelon) submitted a license amendment request (LAA) for Peach Bottom Atomic Power Station, Units 2 and 3 (Reference 1). The LAA proposes to incorporate several miscellaneous administrative changes to the Facility Operating Licenses and the Technical Specifications.

In the Reference 2 e-mails, the U.S. Nuclear Regulatory Commission requested additional information. Enclosed is Exelon's response to the NRC request for additional information. contains our response and Attachment 2 contains the revised Facility Operating License page mark-ups.

Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the U.S. Nuclear Regulatory Commission in Reference 1. The additional information provided in this

U.S. Nuclear Regulatory Commission Response to Request for Additional Information LAR to Revise FOL and TS to Incorporate Administrative Changes December 1, 2014 Page2 response does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Furthermore, the additional information provided in this response does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments in this letter.

Should you have any questions concerning this letter, please contact Stephanie J. Hanson at 610-765-5143.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1st day of December 2014.

Respectfully, James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: 1. Response to Draft Request for Additional Information Regarding Request to Revise Facility Operating Licenses and the Technical Specifications to Incorporate Administrative Changes for Peach Bottom Atomic Power Station, Units 2 and 3

2. Revised Facility Operating License Page Mark-ups cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS, Units 2 and 3 USNRC Project Manager, PBAPS, Units 2 and 3 R. R. Janati, Bureau of Radiation Protection S. T. Gray, State of Maryland

ATTACHMENT 1 Response to Draft Request for Additional Information Regarding Request to Revise Facility Operating Licenses and the Technical Specifications to Incorporate Administrative Changes for Peach Bottom Atomic Power Station, Units 2 and 3

Response to Request for Additional Information LAA to Revise FOL and TS to Incorporate Administrative Changes Attachment 1 Docket Nos. 50-277 and 50-278 Page 1 of 1 By letter to the Nuclear Regulatory Commission (NRC) dated July 11, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14192B143), Exelon Generation Company, LLC (Exelon, the licensee), submitted a license amendment request for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The proposed amendment would incorporate several miscellaneous administrative changes to the Facility Operating Licenses and the Technical Specifications. The questions are restated below along with Exelon's response.

RAI 1

On the proposed revised Facility Operating License page 7, the License Condition C.2(13) is indicated as deleted with a strikethrough. In order to provide consistency (e.g., with deleted technical specifications) and for configuration control purposes, the NRC staff instead requests to have paragraph C.2(13) remain and to replace the text with 11 Deleted."

Response

The proposed revised Facility Operating License (FOL), page 7, License Condition C.2(13), to replace the text with 11 Deleted 11 has been updated as requested. The revised FOL page 7 mark-up (both units) is provided in Attachment 2.

RAI 2

For Unit 3, license page 3, Exelon has proposed to delete footnote 1, which reads:

1 Licensed power level was revised by Amendment No. 250, dated November 22, 2002, and will be implemented following the 14th refueling outage currently scheduled for Fall 2003.

The marked up license page should also show the deletion of the 11 1" at the end of license condition 2.C(2), 11Technical Specifications," (as shown below).

The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 296, are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications. 1 Please include that change in the supplement.

Response

For Unit 3 FOL, page 3, the marked up license page has been revised to show the deletion of 11 111 at the end of license condition 2.C(2). The revised FOL page 3 mark-up is provided in Attachment 2.

ATIACHMENT2 Revised Facility Operating License Page Mark-ups Peach Bottom Atomic Power Station Units 2 and 3 Renewed Facility Operating License Nos. DPR..44 and DPR-56 Docket Nos. 50-277 and 50.278 Unit 2 FOL and TS Pages FOL Page7 FOL Page7a Unit 3 FOL and TS Pages FOL Page3 FOL Page7 FOL Page7a

plant-specific program. Before July 2, 2014, the licensee will notify the NRC of its decision to implement the core shroud inspection and evaluation guidelines program or a plant-specific program, and provide the appropriate revisions to the Updated Final Safety Analysis Report Supplement summary descriptions of the core shroud inspection and evaluation guidelines program.

(11) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (12) The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.

(13) Upon implementation of Amendment No. 268 adopting TSTF 448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.4.4, in accordance \*:ith TS 5.5.13.c(i), the assessment of CRE habitability as required by Specification 5.5.13.c(ii),

and the measurement of CRE pressure as required by Specification 5.5.13.d, shall be considered met. Following implementation:

tat The first performance of SR 3.7.4 .4, in accordance >Nith Specification 5.5.13.c(i), shall be 'Nithin the specified Frequency of 6 years, plus the 18 month allowance of SR 3.0.2, as measured from October 25, 2004, the date of the most resent successful Renewed License No. DPR-56 Revised by letter dated August 9, 2007 Amendment No. 268 Page 7

tracer gas test, as stated in tho January 21, 2006 letter response to Generic Letter 2003 01, or within the next 18 months if the time period sinoe the most resent suooessfuf tracer gas test is greater than 6 years.

(&) The first performance of the periodio assessment of CRE habitability, Spooifioation 6.6.13.e(U). shall be within 3 years, plus the 9 month allaNanoo of SR 3.0.2, as measured from Ootober 26, 2004, the date of the most recent successful traeer gas test, as stated in the January 21, 2005 letter response to Generic Letter 2003 01, or within tho ne>d 9 months if tho time period since the most reoont successful tracer gas test is greater than 3 years.

f&} The first performance of the periodic measurement of CRE pressure, Specifioation 6.6.13.d, shall be within 24 months, plus the 180 days allaNed by SR 3.0.2, as measured from the date of the most recent successful presswre measwrement test, or within 180 days if not performed previously.

(14) Spent Fuel Pool Criticality Considerations (a) Use of spent fuel pool storage cells without NETCO-SNAP-IN rack inserts shall be restricted as follows:

1) Minimum panel Boron-1 O areal density of a storage cell shafl be greater than or equal to 0.014 grams per square centimeter to store fuel assemblies with the maximum in-core cold k-infinity of up to 1.235 (except as noted in a.3 below for restricted cells). The minimum panel Boron-10 areal density shall be evaluated by assuming that tho panel areal density was initially equal to a value of 0.0235 grams per square centimeter.

2) A storage cell shall not contain any fuet assembly if the minimum panel Boron-10 areal density of a storage cell is less than 0.014 grams per square centimeter (except as noted in a.3 below for restricted cells). The minimum panel Boron-10 areal density shall be evaluated by assuming that the panel areal density was initially equal to a value of 0.0235 grams per square centimeter.

Renewed License No. DPR-56 Revised by letter dated August 9, 2007 Amendment No. 290 Page 7a

(11) Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (12) The licensee shall implement and maintain all Actions required by Attachment 2 to NRC Order EA-06-137, issued June 20, 2006, except the last action that requires incorporation of the strategies into the site security plan, contingency plan, emergency plan and/or guard training and qualification plan, as appropriate.

(13) lJpon implementation of Amendment No. 264 adopting TSTF 448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by SR 3.7.4.4, in accordance *11ith TS 5.5.13.o(i), the assessment of CRE habitability as required by Specification 5.5.13.c(ii),

and the measurement of CRE pressure as required by Specification 5.5.13.d, shall be considered met. Following implementation:

ta} The first performance of SR 3.7.4.4, in accordance with Specification 5.5.13.c(i), shall be *11ithin the specified Frequency of 6 years, plus the 18 month allowance of SR 3.0.2, as .measured ffom October 25, 2004, the date of the most recent successful tracer gas test, as stated in the January 21, 2005 letter response to Generic Letter 2003 01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

Renewed License No. DPR-44 Revised by letter dated August 9, 2007 Amendment 264 Page?

IA&~~~HEMISFN:;e eJ 8K~~a9-f"9El&l::lt~#eF~tetelaeF~

2004, the date of the most reoent suooessful tracer gas test, as stated in the January 21, 2005 letter response to Generic letter 2003 01, or within the ne.a 9 months HI the time perioEI sinee the most recent successful tracer gas test is greater than a years.

tG) The first performance of the periodic measurement of GRE pressure. Speeifieation 6.fi.13.d, shall be *A*ithin 24 months. plus the 180 days allowed by SR 3. 0.2, as measured from the date ef the most recent successful pressure measurement test, or 1.-Jithin 180 days if not performeEI pre*.*iously.

(14) Spent Fuel Pool Criticality Considerations (a) Use of spent fuel pool storage cells without NETCO-SNAP-tN*

rack inserts shall be restricted as follows:

1) Minimum panel Boron-10 areal density of a storage cell shall be greater than or equal to 0.014 grams per square centimeter to store fuel assemblies with the maximum in-core cold k--infinity of up to 1.235. The minimum panel Boron-10 areal density shall be evaluated by assuming that the panel areal density was initially equal to a value of 0.0235 grams per square centimeter.

2) A storage cell shall not contain any fuel assembly if the minimum panel Boron-10 areal density of a storage cell is less than 0.014 grams per square centimeter. The minimum panel Boron-10 areal density shall be evaluated by assuming that the panel areal density was initially equal to a value of 0.0235 grams per square centimeter.

(b) Until the installation of NETCO-SNAP-IN" rack inserts are completed in the Peach Bottom Unit 2 spent fuel pool, Boraflex degradation shall be monitored analytically every 6 months.

(c) Boraflex degradation shall be monitored by in-situ testing in the Peach Bottom Unit 2 spent fuel pool no tater than December 31 .

2014. unless installation of the NETCO-SNAP-IN rack inserts for Unit 2 have been completed prior to this date.

(d) Installation of NETCO-SNAP-IN rack inserts shall be completed by December 31, 2016.

Renewed License No. DPR-44 Revised by letter dated August 9, 2007 Amendment No. 287 Page 7a

(5) Exelon Generation Company, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not to separate, such byproduct and special nuclear material as may be produced by operation of the facility, and such Class B and Class C low-level radioactive waste as may be produced by the operation of Limerick Generating Station, Units 1 and C. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified below:

( 1) Maximum Power Level Exelon Generation Company is authorized to operate the Peach Bottom Atomic Power Station, Unit No. 3, at steady state reactor core power levels not in excess of 3951 megawatts thermal.

(2) Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 296, are hereby incorporated in the license. Exelon Generation Company shall operate the facility in accordance with the Technical Specifications. i (3) Physical Protection Exelon Generation Company shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and r:tl 27822), and the auJ!lority of 10 CFR 50.90 and 10 CFR 50.54(p). The L1_J combined set of pl3fi~submitted by letter dated May 17, 2006, is entitled: "Peach Bottom Atomic Power Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan, and Independent Spent Fuel Storage Installation Security Program, Revision 3." The set contains Safeguards Information protected under 10 CFR 73.21.

Exelon Generation Company shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP),

including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Exelon Generation Company CSP was approved by License Amendment No. 283.

1 Usensed power fe*.<el was revised by Amendment No. 250, dated November 22, 2002, and will be implemented following the 44' refueling outage currently scheduled for Fall 2003.

ITJ ~he training and Qualification Plan and Safeguards Contingency Plan and Appendices to the Security Plan.

Renewed License No. DPR-56 Revised by letter dated October 28, 2004 Revised by letter dated November 5. 2004 Revised by letter dated May 29, 2007 Amendment No. 296 Page 3