ML16216A076
| ML16216A076 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 08/02/2016 |
| From: | Jim Barstow Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| Download: ML16216A076 (5) | |
Text
200 Exelon Way Exelon Generation Kennett Square. PA 19348 www.exeloncorp.com August2,2016 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 10 CFR 50.90
Subject:
Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request concerning Emergency Diesel Generator Fuel Oil Transfer Surveillance Requirements for Peach Bottom Atomic Power Station, Units 2 and 3
References:
- 1) Letter from J. Barstow (Exelon Generation Company, LLC) to the U.S.
Nuclear Regulatory Commission,.. License Amendment Request to Revise Surveillance Requirement 3.8.1.6 Involving EDG Fuel Oil Transfer (ML15337A413),.. dated December 3, 2015.
- 2) E-mail correspondence from R. Ennis (U.S. Nuclear Regulatory Commission) to S. J. Hanson (Exelon Generation Company, LLC),
.. Peach Bottom Atomic Power Station-Request for Additional Information Regarding Proposed License Amendment Request to Revise Surveillance Requirement 3.8.1.6 Involving EDG Fuel Oil Transfer (ML16134A474),.. dated April 20, 2016.
- 3) Letter from J. Barstow (Exelon Generation Company, LLC) to the U.S.
Nuclear Regulatory Commission,.. Peach Bottom Atomic Power Station
- Response to Request for Additional Information Regarding the Proposed License Amendment Request to Revise Surveillance Requirement 3.8.1.6 Involving EDG Fuel Oil Transfer (ML16162A101 ),..
dated June 9, 2016.
- 4) E-mail correspondence from R. Ennis (U.S. Nuclear Regulatory Commission) to S. J. Hanson (Exelon Generation Company, LLC),
.. Peach Bottom Atomic Power Station - Request for Additional Information Regarding the Proposed License Amendment Request to Revise Surveillance Requirement 3.8.1.6 Involving EDG Fuel Oil Transfer (ML16209A204),.. dated July 27, 2016.
U.S. Nuclear Regulatory Commission Response to Request for Additional Information SR 3.8.1.6-EDG Fuel Oil Transfer August 2, 2016 Page 2 By application dated December 3, 2015, as supplemented by letter dated June 9, 2016, Exelon Generation Company, LLC (Exelon) submitted a license amendment request (LAR) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 (Reference 1 ). The proposed amendment would revise the technical specification (TS) surveillance requirements (SRs) associated with the emergency diesel generator (EDG) fuel oil transfer system. Specifically, the amendment would allow for the crediting of manual actions, in lieu of automatic actions, without having to declare the EDGs inoperable.
In the Reference 2 e-mail correspondence, the U.S. NRC requested additional information.
Reference 3 provided Exelon's response.
In the Reference 4 e-mail correspondence, the U.S. NRC requested additional information.
Attached is our response.
Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the U.S. 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 regulatory commitments in this response.
If you have any questions concerning this response, 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 2nd day of August 2016.
Respectfully, a~~
James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC
Attachment:
Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request to Revise Surveillance Requirement 3.8.1.6 Involving EDG Fuel Oil Transfer for Peach Bottom Atomic Power Station, Units 2 and 3 cc:
USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS R. R. Janati, Pennsylvania Bureau of Radiation Protection S. T. Gray, State of Maryland
ATTACHMENT Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Docket Nos. 50-2n and 50-278 Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request to Revise Surveillance Requirement 3.8.1.6 Involving EDG Fuel Oil Transfer for Peach Bottom Atomic Power Station, Units 2 and 3
Response to Request for Additional Information SR 3.8.1.6-EDG Fuel Oil Transfer Docket Nos. 50-277 and 50-278 Attachment Page 1 of 2 By application dated December 3, 2015, as supplemented by letter dated June 9, 2016, Exelon Generation Company, LLC (Exelon) submitted a license amendment request (LAR) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The proposed amendment would revise the technical specification (TS) surveillance requirements (SRs) associated with the emergency diesel generator (EDG) fuel oil transfer system. Specifically, the amendment would allow for the crediting of manual actions, in lieu of automatic actions, without having to declare the EDGs inoperable.
The NRC staff has determined that additional information is needed to complete its review. The specific request for additional information (RAI) question is restated below along with Exelon's response.
Question 1 CAPHB-RAI-8):
In APHB-RAI-7 (ADAMS Accession No. ML16134A474), the NRC staff requested the licensee to address the following:
Describe the process used to monitor manual actions to ensure that they remain feasible and reliable over the long term, and are not degraded because of design changes, inadequate training, or other mechanisms.
In the June 9, 2016, response to this request for additional information (RAI), the licensee indicated that there is no specific training required to support this LAR. The licensee also referenced procedure CC-AA-1 02, Revision 29, "Design Input and Configuration Change Impact Screening," and stated that, in accordance with the procedure, impacts on operator manual actions need to be assessed as part of the design change process. The licensee's response does not fully address the staff's concern as discussed below.
Section 3.11, "Human Performance Monitoring Strategy" of NUREG-1764 (ADAMS Accession No. ML07260413), contains review criteria intended to ensure that operators remain capable of performing manual actions throughout the lifetime of the plant. Subsequent changes to plant systems or procedures, operators becoming unfamiliar with rarely used procedures, or other factors may influence operators in a way that impedes future task performance. Licensees typically track and trend credited operator manual actions to ensure that these actions remain feasible.
The procedure referenced in the RAI response dated June 9, 2016 (i.e., CC-AA-1 02) was not docketed so it's not clear to the NRC staff if it provides for tracking and trending of operator manual actions. Additional information is necessary to clarify how the review criteria in Section 3.11 of NUREG-1764 are met. One potential method for submitting this material is to provide a brief summary of the tracking/trending program that will track this action accompanied by indication that the credited manual actions described in this LAR will be included in this program. Alternatively, you may choose to provide the procedure, or portion of the procedure that indicates how this particular manual action is tracked and maintained over time.
Response to Request for Additional Information SR 3.8.1.6-EDG Fuel Oil Transfer Docket Nos. 50-277 and 50-278
Response
Attachment Page 2 of 2 The new operator manual action would be screened for consideration to be placed in the operator response time program. This program requires periodic validation of operator manual actions that are credited in the design I licensing basis. In accordance with procedure OP-PB-1 02-1 06, the Operations Department, with the assistance of Operations Training and Engineering as necessary, periodically re-validate the ability to perform these credited actions that are placed into the program by verifying the expected performance time is within the time required by the design I licensing basis. This is accomplished by verifying the source documents I programs, review of plant procedure changes, crew human performance methodology changes, and plant modifications that would affect time completion. Acceptable methods (or combination of methods) for re-validation can include:
- 1. Simulator Scenario (e.g., Training, Out of the Box Evaluations (OBEs), other)
- 2. Plant Walkthrough (e.g., Job Performance Measure (JPM), Training, other)
- 3. Estimated Times (When simulator and plant walkthrough are not practical or to account for other time to improve the accuracy of the Expected Performance Time (ET).)