ML19283A362

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Supplement No. 9 - Changes to Subsequent License Renewal Application
ML19283A362
Person / Time
Site: Peach Bottom  Constellation icon.png
Issue date: 10/09/2019
From: Gallagher M
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML19283A362 (11)
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Text

Exelon Generation ,. 200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50 10 CFR 51 10 CFR 54 October 9, 2019 U.S. Nuclear Regulatory Commission Attention: 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:

Supplement No. 9 - Changes to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application

References:

1. Letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon) to NRC Document Control Desk, dated July 10, 2018, "Application for Subsequent Renewed Operating Licenses"
2. Letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon) to NRC Document Control Desk, dated September 14, 2018, "Changes to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application" (Supplement No. 1)
3. Letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon) to NRC Document Control Desk, dated January 23, 2019, "Changes to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application" (Supplement No. 2)
4. Letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon) to NRC Document Control Desk, dated February 11, 2019, "Changes to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application" (Supplement No. 3)
5. Letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon) to NRC Document Control Desk, dated March 18, 2019, "Changes to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application" (Supplement No. 4)
6. Letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon) to NRC Document Control Desk, dated June 12, 2019, "Changes to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application" (Supplement No. 5)
7. Letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon) to NRC Document Control Desk, dated July 1, 2019, "First 10 CFR 54.21(b)

Annual Amendment to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application" (Supplement No. 6)

8. Letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon) to NRC Document Control Desk, dated July 12, 2019, "Changes to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application" (Supplement No. 7)

October 9, 2019 U.S. Nuclear Regulatory Commission Page2

9. Letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon) to NRC Document Control Desk, dated July 25, 2019, "Changes to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application" (Supplement No. 8)
10. Letter from Joseph E. Donoghue, USN RC to Michael P. Gallagher, Exelon Generation Company, LLC (Exelon), dated October 7, 2019, "Safety Evaluation Report Related to the Subsequent License Renewal of Peach Bottom Atomic Power Station, Units 2 and 3" In Reference 1, Exelon submitted the Subsequent License Renewal Application (SLRA) for the Peach Bottom Atomic Power Station, Units 2 and 3 (PBAPS). In References 2, 3, 4, 5, 6, 7, 8, and 9, Exelon submitted Supplement Nos. 1, 2, 3, 4, 5, 6, 7, and 8 to the SLRA for PBAPS. The purpose of this letter is to provide Supplement No. 9 to the SLRA for PBAPS. Supplement No. 9 includes one change to the SLRA which provides additional information in the SLRA to address the NRC Safety Evaluation Report Confirmatory Item No. 3.0.3.2.3-1 (Reference 10}

regarding the BWR Vessel Internals Program.

Enclosure A to this letter provides a description of the changes, and corresponding mark-ups to the affected portions of the SLRA, thereby supplementing the PBAPS SLRA.

Enclosure B to this letter provides an update to the License Renewal Commitment List (LRA Appendix A, Section A.5). There are no other new or revised regulatory commitments contained in this letter.

This submittal has been discussed with the NRC License Renewal Senior Project Manager for the PBAPS Subsequent License Renewal project.

If you have any questions, please contact Mr. David Distel, Licensing Lead, Exelon License Renewal Projects, at 610-765-5517.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 9th day of October 2019.

Respectfully submitted, Vice President - License Renewal and Decommissioning Exelon Generation Company, LLC

Enclosures:

A. Changes to the PBAPS Subsequent License Renewal Application B. PBAPS Subsequent License Renewal Commitment List Update

October 9, 2019 U.S. Nuclear Regulatory Commission Page 3 cc: Regional Administrator - NRC Region I NRG Senior Project Manager (Safety Review), NRR-DMLR NRC Project Manager (Environmental Review), NRR-DMLR NRG Project Manager, NRA-DORL- Peach Bottom Atomic Power Station NRC Senior Resident Inspector, Peach Bottom Atomic Power Station R.R. Janati, Pennsylvania Bureau of Radiation Protection D.A. Tancabel, State of Maryland

October 9, 2019 Enclosure A Page 1of6 Enclosure A Changes to the PBAPS Subsequent License Renewal Application Introduction This Enclosure contains one change that is being made to the Subsequent License Renewal Application {SLRA) that was identified after submittal of the SLRA. For this item, the change is described and the affected page number{s) and portion{s) of the SLRA is provided. For clarity, entire sentences or paragraphs from the SLRA are provided with deleted text highlighted by strikothroughs and inserted text highlighted by balded italics.

October 9, 2019 Enclosure A Page 2 of 6 Change #1 - Revision to BWR Vessel Internals Program Enhancement 1 Affected SLRA Sections: Section 3.1.2.2.14, Appendix A, Section A.2.1.7, Appendix A, Section A.5, Appendix B, Section B.2.1.7, Appendix C SLRA Page Numbers: 3.1-27, A-14, A-88, B-43, B-44, B-47, and C-5 Description of Change:

The BWR Vessel Internals (B.2.1.7) aging management program, Enhancement #1 is being revised to add specific actions to be taken for SLR with respect to the core plate rim hold-down bolts by using BWRVIP-25, Revision 1 guidance. The revised enhancement is, "In accordance with BWRVIP-25, Revision 1, install core plate wedges, or inspect core plate rim hold-down bolts for stress corrosion cracking, or demonstrate via analysis that the installation of wedges and inspections of the core plate rim hold-down bolts are not required, no later than six months prior to the second period of extended operation, or before the end of the last refueling outage prior to the second period of extended operation, whichever occurs later."

Accordingly, SLRA Section 3.1.2.2.14; Appendix A, Section A.2.1. 7; Appendix A, Section A.5; Appendix B, Section B.2.1. 7; and Appendix C are revised.

October 9, 2019 Enclosure A Page 3 of 6 SLRA Section 3.1.2.2.14, Loss of Preload Due to Thermal or Irradiation-Enhanced Stress Relaxation, 5th paragraph, page 3.1-27 is revised as shown below:

The BWR Vessel Internals (B.2.1.7) program is enhanced in accordance with BWRVIP-25, Revision 1 to install core plate wedges, for PBAPS Units 2 and 3 or inspect core plate rim hold-down bolts for stress corrosion cracking, or demonstrate via analysis that the installation of wedges and inspections of the core plate rim hold-down bolts are not required, no later than six months prior to the second period of extended operation, or before the end of the last refueling outage prior to the second period of extended operation, whichever occurs later.f-Gf; submit an inspection plan for tho core plate rim holddo*Nn bolts with a supporting analysis for NRG approval at least two years prior to entering tho second period of extended operation. An additional option for management of loss of preload in core plate holddO'Nn bolts is evaluation consistent with an NRG approved procedure documented in a ro 11ision to BlA'RVI P 25.

SLRA Appendix A, Section A.2.1.7, BWR Vessel Internals, Enhancement #1, page A-14 is revised as shown below:

1. In accordance with BWRVIP-25, Revision 1, install core plate wedges, or inspect core plate rim hold-down bolts for stress corrosion cracking, or demonstrate via analysis that the installation of wedges and inspections of the core plate rim hold-down bolts are not required, no later than six months prior to the second period of extended operation, or before the end of the last refueling outage prior to the second period of extended operation, whichever occurs later. ; or, submit an inspection plan for tho core plate rim hold dovm bolts with a supporting analysis for NRG approval at least two years prior to entering the second period of extended operation.

October 9, 2019 Enclosure A Page 4 of 6 SLRA Appendix B, Section B.2.1.7, BWR Vessel Internals, Program Description, 61h paragraph, page B-43 and B-44 are revised as shown below:

Core Plate: The BWRVIP recommendation to document deviation from BWRVIP-25 inspection guidelines of the core plate rim hold-down bolts is currently being implemented for PBAPS. The BWRVIP recognizes that it is not possible to implement meaningful inspections using the inspection methods recommended in BWRVIP-25. The BWRVIP is in the process of developing revised guidance. A BWRVIP deviation disposition is in place until revised BWRVIP guidance, or some other NRG-approved solution is implemented. The program is enhanced in accordance with BWRVIP-25, Revision 1 to require installation of core plate wedges, or inspect core plate rim hold-down bolts for stress corrosion cracking, or demonstrate via analysis that the installation of wedges and inspections of the core plate rim hold-down bolts are not required, no later than six months prior to the second period of extended operation, or before the end of the last refueling outage prior to the second period of extended operation, whichever occurs later.; prior to entering tho sosond period of ox-tended operation, or s1:1bmittal of an inspostion plan for tho sore plate rim hold do*Nn bolts with a s1:1pporting analysis for NRG appro>Jal at least two years prior to entering tho sosond period of ox-tended operation. Tho installation of sore plate wedges wo1:1ld eliminate tho need to inspost tho sore plate rim hold down bolts. The repair design criteria in BWRVIP-50-A would be utilized in preparing a repair plan for the core plate.

SLRA Appendix B, Section B.2.1.7, BWR Vessel Internals, Enhancement #1, page B-47 is revised as shown below:

1. In accordance with BWRVIP-25, Revision 1, install core plate wedges, or inspect core plate rim hold-down bolts for stress corrosion cracking, or demonstrate via analysis that the installation of wedges and inspections of the core plate rim hold-down bolts are not required, no later than six months prior to the second period of extended operation, or before the end of the last refueling outage prior to the second period of extended operation, whichever occurs later.; or, s1:1bmit an inspostion plan for tho sore plate rim hold down bolts with a s1:1pporting analysis for NRG appro>Jal at least t\Yo years prior to entering the sosond period of ex-tended operation. Program Elements Affected: Scope of Program (Element 1) and Parameters Monitored or Inspected (Element 3)

October 9, 2019 Enclosure A Page 5 of 6 SLRA Appendix C, BWRVIP-25 Core Plate Inspection and Flaw Evaluation Guidelines, BWRVIP-25 (5) Peach Bottom Response, applicable section of page C-5 is revised as shown below:

BWRVIP-25 Core Plate Inspection and Flaw Evaluation Guidelines The BWRVIP recognizes that it is not possible to BWRVIP-25 (5) implement meaningful inspections using the inspection methods recommended in BWRVIP-25. The BWRVIP is Until such time as an expanded addressing this issue and intends to develop revised technical basis for not guidance. The BWRVIP recommendation to document inspecting the rim hold-down deviation from BWRVIP-25 inspection guidelines of the bolts is approved by the staff, core plate hold down bolts is currently being applicants referencing the implemented. A BWRVIP Deviation Disposition is in BWRVIP-25 report for license place until revised guidance for core plate bolting renewal should continue to inspection within BWRVIP, or some other NRC-perform inspections of the rim approved solution is implemented.

hold-down bolts.

BWR Vessel Internals (B.2.1.7) aging management program Enhancement 1 requires, in accordance with BWRVIP-25, Revision 1, installation of core plate wedges, or inspection of core plate rim hold-down bolts for stress corrosion cracking, or analysis that demonstrates the installation of wedges and inspections of the core plate rim hold-down bolts are not required, no later than six months prior to the second period of extended operation, or before the end of the last refueling outage prior to the second period of extended operation, whichever occurs later. no later than six months prior to entering tho sosond period of extended operation, or s1::1bmittal of an inspection plan for tho sore plato rim hold down bolts with a s1::1pporting analysis for NRG approval at least two years prior to entering tho second period of oxtondod operation. Tho installation of sore plate *nodgos wo1::1ld eliminate tho need to inspect tho sore plate rim hold down bolts.

October 9, 2019 Enclosure A Page 6 of 6 SLRA Appendix A, Section A.5, Commitment 7, BWR Vessel Internals, Item #1, beginning on page A-88 is revised as shown below:

A.5 SECOND LICENSE RENEWAL COMMITMENT LIST PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

7 BWR Vessel BWR Vessel Internals is an existing program that will be enhanced to: Program will be Section A.2.1. 7 Internals 1. In accordance with BWRVIP-25, Revision 1, install core plate wedges, enhanced in accordance Exelon Letter or inspect core plate rim hold-down bolts for stress corrosion with the schedule described within the PBAPSSLRA cracking, or demonstrate via analysis that the installation of wedges Supplement and inspections of the core plate rim hold-down bolts are not commitments. Initial No. 9, dated required, no later than six months prior to the second period of extended steam dryer inspections will be completed no later October 9, 2019 operation, or before the end of the last refueling outage prior to the second period of extended operation, whichever occurs later. ; eF, Sll9mit than six months prior to aR iRspestieR plaR feF tl:ie seFe plate Fim l:iele eewR belts witl:i a SllppeFtiR§ the second period of aRalysis feF NRG appFeval at least twe yeaFS pFieF te eRteFiR§ tl:ie seseRB extended operation, or peFiee et exteReee epeFatieR. no later than the last refueling outage prior to

2. Perform a VT-3 inspection of the jet pump inlet mixer and beam regions the second period of every refuel cycle after a fluence value of 1.3E+20 n/cm2 (51 EFPY for extended operation.

Unit 2 and 63 EFPY for Unit 3) is reached at the jet pump holddown beam.

3. Perform periodic visual inspections of the PBAPS Westinghouse (Nordic style) stainless steel steam dryers for the aging effects of loss of material

October 9, 2019 Enclosure B Page 1 of 2 Enclosure B PBAPS Subsequent License Renewal Commitment List Update Introduction This Enclosure identifies commitments made in this document and is an update to the PBAPS SLRA Appendix A, Section A.5 License Renewal Commitment List. Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.

Changes to the PBAPS SLRA Appendix A, Section A.5 License Renewal Commitment List are as a result of this SLRA Supplement.

These Enclosure B pages are the same as the corresponding PBAPS SLRA Appendix A, Section A.5 pages included in Enclosure A.

To facilitate understanding, relevant portions of the previously submitted License Renewal Commitment List have been repeated in this Enclosure, with revisions indicated. Previously submitted information is shown in normal font. Additions due to this submittal are highlighted with bolded italics for inserted text, and strikothroughs for deleted text.

October 9, 2019 Enclosure B Page 2 of 2 SLRA Appendix A, Section A.5, Commitment 7, BWR Vessel Internals, Item #1, beginning on page A-88 is revised as shown below:

A.5 SECOND LICENSE RENEWAL COMMITMENT LIST PROGRAM OR IMPLEMENTATION NO. COMMITMENT SOURCE TOPIC SCHEDULE*

7 BWRVessel BWR Vessel Internals is an existing program that will be enhanced to: Program will be Section A.2.1. 7 Internals 1. In accordance with BWRVIP-25, Revision 1, install core plate wedges, enhanced in accordance Exelon Letter or inspect core plate rim hold-down bolts for stress corrosion with the schedule described within the PBAPSSLRA cracking, or demonstrate via analysis that the installation of wedges Supplement and inspections of the core plate rim hold-down bolts are not commitments. Initial steam dryer inspections No. 9, dated required, no later than six months prior to the second period of extended October 9, 2019 operation, or before the end of the last refueling outage prior to the will be completed no later second period of extended operation, whichever occurs later. ; eF, &ijl;}mit than six months prior to aR iRsi;ieslieR i;ilaR feF the seFe i;ilate Fim hale aewR l;}elts with a SijflfleRiR~ the second period of aRalysis feF Ni:;!G ai;ii;iFeval at least twe yeaFS flFieF ta eRteFiR~ the sesaREI extended operation, or i;ieFiaa et e>GeRaea ei;ieFatieR. no later than the last refueling outage prior to

2. Perform a VT-3 inspection of the jet pump inlet mixer and beam regions the second period of every refuel cycle after a fluence value of 1.3E+20 n/cm 2 (51 EFPY for extended operation.

Unit 2 and 63 EFPY for Unit 3) is reached at the jet pump holddown beam.

3. Perform periodic visual inspections of the PBAPS Westinghouse (Nordic style) stainless steel steam dryers for the aging effects of loss of material
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