ML20315A245

Response to Request for Additional Information to Support Review of License Amendment Request - Application to Modify Technical Specifications 3.6.1.3 Primary Containment Isolation Valves

ML20315A245
Person / Time
Site:	FitzPatrick
Issue date:	11/10/2020
From:	David Gudger Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
JAFP-20-0080
Download: ML20315A245 (5)

Text

200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 JAFP-20-0080 November 10, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333

Subject:

Response to Request for Additional Information to support Review of License Amendment Request - Application to Modify Technical Specifications 3.6.1.3 Primary Containment Isolation Valves

References:

1. Letter from Dave T. Gudger (Exelon Generation Company, LLC) to U.S.

Nuclear Regulatory Commission, License Amendment Request -

Application to Modify Technical Specifications 3.6.1.3 Primary Containment Isolation Valves, dated June 30, 2020

2. Email from Justin Poole (Nuclear Regulatory Commission Project Manager for the James A. FitzPatrick Nuclear Power Plant) to Enrique Villar (Exelon Nuclear Senior Licensing Engineer) titled Request for Additional Information Regarding FitzPatrick Primary Containment Isolation Valve Amendment (L-2020-LLA-0145)," dated October 19, 2020 By letter dated June 30, 2020 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a license amendment request to modify Technical Specifications 3.6.1.3, Primary Containment Isolation Valves, for James A. FitzPatrick Nuclear Power Plant (FitzPatrick).

In this request, Exelon requested to modify the configuration requirements for the reactor building suction valves during inerting and de-inerting the containment atmosphere.

By electronic mail dated October 19, 2020 (Reference 2), the NRC identified areas where additional information was necessary to complete its review. These additional RAIs were discussed with the NRC Staff in a clarification call held on October 19, 2020, and it was agreed to a response by November 19, 2020. to this letter contains the NRC's request for additional information immediately followed by Exelon's response.

Response to RAI to Support Review of LAR -

Application to Modify Technical Specifications 3.6.1.3 November 10, 2020 Page 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 information attached to this letter does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Furthermore, the information attached to this letter 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 10th day of November 2020.

Respectfully, David T. Gudger Senior Manager, Licensing Exelon Generation Company, LLC

Attachment:

1. Request for Additional Information and Exelon Response cc: Regional Administrator - NRC Region I NRC Senior Resident Inspector - JAF NRC Project Manager, NRR - JAF A. L. Peterson, NYSERDA

ATTACHMENT 1 RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION REGARDING TECHNICAL SPECIFICATION 3.6.1.3 - PRIMARY CONTAINMENT ISOLATION VALVES EXELON GENERATION COMPANY, LLC JAMES A. FITZPATRICK NUCLEAR POWER PLANT DOCKET NO. 50- 333 Response to Request for Additional Information Regarding Technical Specification 3.6.1.3 Primary Containment Isolation Valves Page 1 of 2 By letter dated June 30, 2020, Exelon Generation Company, LLC (Exelon or the licensee) submitted a license amendment request to modify Technical Specifications 3.6.1.3, Primary Containment Isolation Valves, for James A. FitzPatrick Nuclear Power Plant (FitzPatrick). In this request, the licensee has requested to modify the configuration requirements for the reactor building suction valves (referred to as 01-125-MOV-12 in the submittal) during inerting and de-inerting the containment atmosphere. Specifically, the valves were previously required to be open, but may be closed if the request is approved. Title 10 of the Code of Federal Regulations (10 CFR) Section 50.55a(f)(4) states, in part, that valves that are within the scope of the American Society of Mechanical Engineer (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) must meet the inservice test requirements set forth in the ASME OM Code and that valves that are within the scope of the ASME OM Code but are not classified as ASME Boiler and Pressure Vessel Code (BPV Code) Class 1, Class 2, or Class 3 may be satisfied as an augmented IST program. The licensee states in its submittal that there is no impact to the design basis function of the valves to open upon receipt of a safety signal.

The U.S. Nuclear Regulatory Commission (NRC) staff requests confirmation of the following, to support a finding that the subject valves continue to be operationally ready to perform their required functions:

1. 01-125-MOV-12 is the only valve specifically named associated with this request.

However, the one-line diagram included in the submittal includes two valves that change configuration as part of this amendment request. Is the other valve 01-125-MOV-11?

Do statements made about 01-125-MOV-12 also apply to this MOV? Are there unique attributes of the other MOV that require additional consideration?

RESPONSE TO RAI #1 Exelon confirms that discussion in support of this amendment are also applicable to valve 01-125-MOV-11 SGT RX BLDG SUCT ABOVE 369 EL ISOL VALVE, and that there are no other unique attributes needing consideration.

2. Do the performance requirements of valve 01-125-MOV-12 (and the other suction valve, as noted above) remain bounded with regards to characteristics such as stroke time after the requested changes have been implemented?

RESPONSE TO RAI #2 The proposed amendment request only changes the valves position during primary containment inerting, de-inerting, pressure control evolutions.

No other physical changes are proposed beyond what is described above that would invalidate any other valve characteristic such as stroke time or flow. These valves are designed for a DP of 25 psi. Considering the pressures for these evolutions are very low (expressed in inches of H2O), Exelon concludes there are no adverse impact to performance of the valves.

Response to Request for Additional Information Regarding Technical Specification 3.6.1.3 Primary Containment Isolation Valves Page 2 of 2

3. 01-125-MOV-12 (and 01-125-MOV-11) are listed as augmented valves in the FitzPatrick IST Program. Do the requested changes in this LAR alter the importance such that their treatment should change within the IST Program? Are any additional changes expected to the IST Program as a result of this LAR?

RESPONSE TO RAI #3 These valves are listed as augmented valves in the FitzPatrick IST Program. The proposed amendment request does not alter the importance of these valves (01-125-MOV-12 and 01-125-MOV-11); and therefore, they will remain within the IST Program in order to maintain the active safety function in the open position. The active safety function is to allow air flow to the Standby Gas Treatment Filter Train and open automatically in the auto position under any of the following conditions:

• High refueling floor exhaust radiation

• Failure of both refueling floor radiation monitors.

• High Reactor Building vent exhaust radiation

• Failure of both Reactor Building vent exhaust radiation monitors.

• Low Reactor Water Level

• High Drywell Pressure

4. How will these closed valves be tested for operational readiness after implementation of the proposed LAR RESPONSE TO RAI #4 As noted above, these valves will remain in the IST program and continue to be stroke time tested as required by the IST program in order to maintain the active safety function in the open position.