NMP1L3058, Supplemental Response to Request for Additional Information 1 - Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements.
| ML15321A253 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  (DPR-063) |
| Issue date: | 11/17/2015 |
| From: | Jim Barstow Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NMP1L3058 | |
| Download: ML15321A253 (4) | |
Text
Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 NMP1L3058 November 17, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington,, DC 20555-0001
Subject:
Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 NRC Docket No. 50-220 Supplemental Response to Request for Additional Information #1 -
"Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)"
References:
- 1.
Letter from J. Barstow (Exelon Generation Company, LLC) to U.S.
Nuclear Regulatory Commission, "Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)," dated May 12, 2015.
- 2. Email from Brenda Mozafari (Senior Project Manager, U.S. Nuclear Regulatory Commission) to Ronnie Reynolds and Enrique Villar (Exelon)
Request for Additional Information Related to an Amendment to Adopt Technical Specification Task Force Traveller (TSTF) -425 to Relocate Specific Surveillance Frequency Requirements to a Licensee Controlled Program Nine Mile Point Nuclear Station Unit 1 Docket No. 50-220, dated September 22, 2015.
- 3.
Letter from J. Barstow (Exelon Generation Company, LLC) to U.S.
Nuclear Regulatory Commission Response to Request for Additional Information #1 -"Application Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)," dated October 22, 2015.
By letter dated October 22, 2015, (Reference 3) Exelon Generation Company, LLC (Exelon) submitted its response to a Request for Additional Information (Reference 2) from the Nuclear Regulatory Commission (NRC).
Supplemental Response to Request for Additional Information #1 Adoption of TSTF-425, Revision 3 November 17, 2015 Page 2 On November 5, 2015, a telephone call was held between Exelon and NRC personnel to clarify Exelon's response to PAA RAI 2. This letter supplements the October 22 letter; specifically, Exelon's response to PAA RAI 2 is revised in its entirety as stated in. to this letter contains Exelon's supplemental response to PAA RAI 2.
Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference 1. The additional information provided in this 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 commitments contained in this response.
If you should have any questions regarding this submittal, please contact Enrique Villar at 610-765-5736.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 171h day of November 2015.
Respectfully, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC : Supplemental Response to Request for Additional Information #1 cc:
NRC Regional Administrator, Region I NRC Senior Resident Inspector-NMP NRC Project Manager, NRA - NMP A. L. Peterson, NYSERDA w/attachments
ATTACHMENT 1 Supplemental Response to Request for Additional Information #1 to Support Review of Nine Mile Point Nuclear Station, Unit 1 Adoption of Technical Specification Task Force-425 Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TAC No. MF6061)
Supplemental Response to Request for Additional Information #1 Adoption of TSTF-425, Revision 3 Page 1 PRA RAI 2 The LAR does not mention that a gap assessment was performed for the internal events PRA between RG 1.200, Revision 1 and RG 1.200, Revision 2. If this has not been done, perform a gap assessment. Provide the gap assessment findings and observations with their dispositions for the application.
Exelon Response to PRA RAI 2 A gap assessment was performed for the internal events PRA between RG 1.200, Revision 1 and AG 1.200, Revision 2 [5]. This gap assessment did not lead to the identification of any new "Not Mets," findings or observations to the original capability category ranking from the 2008 peer review. This is not unexpected.
Although the peer review was based on ASME RA-Sc-2007, the supporting requirements from the 2005 version were not changed. Furthermore, there were no significant changes in the supporting requirement when comparing the 2007 version to the PRA standard, ASME/ANS RA-Sa-2009 [6] endorsed in RG 1.200, Revision 2 [7]. The changes were mostly wording changes for some of the SRs, and many of these changes are only associated with reformatting and do not affect the SR's technical requirements compared to the PRA version of the standard used for the peer review.
Therefore, the only remaining internal events gaps were those identified in Table 2-1 of the TSTF-425 LAA submittal for Nine Mile Point Unit 1 where the impact for this application was already noted [8].
Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 NMP1L3058 November 17, 2015 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington,, DC 20555-0001
Subject:
Nine Mile Point Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-63 NRC Docket No. 50-220 Supplemental Response to Request for Additional Information #1 -
"Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)"
References:
- 1.
Letter from J. Barstow (Exelon Generation Company, LLC) to U.S.
Nuclear Regulatory Commission, "Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)," dated May 12, 2015.
- 2. Email from Brenda Mozafari (Senior Project Manager, U.S. Nuclear Regulatory Commission) to Ronnie Reynolds and Enrique Villar (Exelon)
Request for Additional Information Related to an Amendment to Adopt Technical Specification Task Force Traveller (TSTF) -425 to Relocate Specific Surveillance Frequency Requirements to a Licensee Controlled Program Nine Mile Point Nuclear Station Unit 1 Docket No. 50-220, dated September 22, 2015.
- 3.
Letter from J. Barstow (Exelon Generation Company, LLC) to U.S.
Nuclear Regulatory Commission Response to Request for Additional Information #1 -"Application Specific Surveillance Frequency Requirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)," dated October 22, 2015.
By letter dated October 22, 2015, (Reference 3) Exelon Generation Company, LLC (Exelon) submitted its response to a Request for Additional Information (Reference 2) from the Nuclear Regulatory Commission (NRC).
Supplemental Response to Request for Additional Information #1 Adoption of TSTF-425, Revision 3 November 17, 2015 Page 2 On November 5, 2015, a telephone call was held between Exelon and NRC personnel to clarify Exelon's response to PAA RAI 2. This letter supplements the October 22 letter; specifically, Exelon's response to PAA RAI 2 is revised in its entirety as stated in. to this letter contains Exelon's supplemental response to PAA RAI 2.
Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference 1. The additional information provided in this 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 commitments contained in this response.
If you should have any questions regarding this submittal, please contact Enrique Villar at 610-765-5736.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 171h day of November 2015.
Respectfully, James Barstow Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC : Supplemental Response to Request for Additional Information #1 cc:
NRC Regional Administrator, Region I NRC Senior Resident Inspector-NMP NRC Project Manager, NRA - NMP A. L. Peterson, NYSERDA w/attachments
ATTACHMENT 1 Supplemental Response to Request for Additional Information #1 to Support Review of Nine Mile Point Nuclear Station, Unit 1 Adoption of Technical Specification Task Force-425 Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program (TAC No. MF6061)
Supplemental Response to Request for Additional Information #1 Adoption of TSTF-425, Revision 3 Page 1 PRA RAI 2 The LAR does not mention that a gap assessment was performed for the internal events PRA between RG 1.200, Revision 1 and RG 1.200, Revision 2. If this has not been done, perform a gap assessment. Provide the gap assessment findings and observations with their dispositions for the application.
Exelon Response to PRA RAI 2 A gap assessment was performed for the internal events PRA between RG 1.200, Revision 1 and AG 1.200, Revision 2 [5]. This gap assessment did not lead to the identification of any new "Not Mets," findings or observations to the original capability category ranking from the 2008 peer review. This is not unexpected.
Although the peer review was based on ASME RA-Sc-2007, the supporting requirements from the 2005 version were not changed. Furthermore, there were no significant changes in the supporting requirement when comparing the 2007 version to the PRA standard, ASME/ANS RA-Sa-2009 [6] endorsed in RG 1.200, Revision 2 [7]. The changes were mostly wording changes for some of the SRs, and many of these changes are only associated with reformatting and do not affect the SR's technical requirements compared to the PRA version of the standard used for the peer review.
Therefore, the only remaining internal events gaps were those identified in Table 2-1 of the TSTF-425 LAA submittal for Nine Mile Point Unit 1 where the impact for this application was already noted [8].