RS-22-027, Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated

Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated P

ML22054A107
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle
Issue date:	02/23/2022
From:	David Gudger Constellation Energy Generation
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-22-027
Download: ML22054A107 (16)

Text

200 Exelon Way Kennett Square, PA 19348 www.constellation.com 10 CFR 50.90 RS-22-027 February 23, 2022 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. 50-456 and 50-457 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. 50-454 and 50-455 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. DPR-69 NRC Docket No. 50-410

Response to Request for Additional Information Application to Adopt TSTF-541, Revision 2 February 23, 2022 Page 2 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 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 R.E. Ginna Nuclear Power Plant Facility Operating License No. DPR-18 NRC Docket No. 50-244

SUBJECT:

Response to Request for Additional Information regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, "Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position"

REFERENCES:

1. Letter from David T. Gudger (Exelon Generation Company, LLC now Constellation Energy Generation) to U.S. Nuclear Regulatory Commission, Application to Revise Technical Specifications to Adopt TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position. Dated September 27, 2021

2. Electronic Mail from Blake Purnell (Nuclear Regulatory Commission) to Christian Williams (Exelon Generation Company, LLC) Request for Additional Information Regarding Fleet License Amendment Request to Adopt TSTF-541 dated February 10, 2022 By letter dated September 27, 2021 (Reference 1), Exelon Generation Company, LLC (Exelon), now Constellation Energy Generation (CEG), submitted a license amendment request for Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; James A. FitzPatrick Nuclear Power Plant; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Unit 2; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; and R. E. Ginna Nuclear Power Plant.

The proposed amendments would revise the technical specifications (TSs) for each facility based on Technical Specification Task Force (TSTF) traveler TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position (ADAMS Accession No. ML19240A315). The proposed amendments would also make similar changes to surveillance requirements not included in TSTF-541, Revision 2, and additional editorial changes to the TSs.

Response to Request for Additional Information Application to Adopt TSTF-541, Revision 2 February 23, 2022 Page 3 By electronic mail dated February 10, 2022 (Reference 2), the NRC requested additional information that was necessary to complete its review. to this letter contains the NRC's requests for additional information (RAIs) followed by the CEG response.

CEG 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 regulatory commitments made in this submittal.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated State Officials.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd day of February 2022.

If you should have any questions regarding this submittal, please contact Christian Williams at (732) 281-9104.

Sincerely, David T. Gudger Senior Manager, Licensing Constellation Energy Generation, LLC

Attachment:

1) NRC Request for Additional Information and Detailed Response

Enclosure:

1) Corrected Technical Specification Changes (Mark-Up)

Response to Request for Additional Information Application to Adopt TSTF-541, Revision 2 February 23, 2022 Page 4 cc: NRC Regional Administrator - Region I NRC Regional Administrator - Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - R.E. Ginna Nuclear Power Plant Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection A. L. Peterson, NYSERDA Bridget Frymire, NYSPSC S. Seaman, MD-DNR W. DeHaas, Pennsylvania Bureau of Radiation Protection

Attachment 1 Request for Additional Information and Detailed Response Request for Additional Information And Detailed Response Page 1 of 3 Request For Additional Information and Detailed Response

Background

By letter dated September 27, 2021 (Reference 1) , Exelon Generation Company, LLC (Exelon),

now Constellation Energy Generation (CEG), submitted a license amendment request for Braidwood Station, Units 1 and 2; Byron Station, Unit Nos. 1 and 2; Calvert Cliffs Nuclear Power Plant, Units 1 and 2; Clinton Power Station, Unit No. 1; Dresden Nuclear Power Station, Units 2 and 3; James A. FitzPatrick Nuclear Power Plant; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Unit 2; Peach Bottom Atomic Power Station, Units 2 and 3; Quad Cities Nuclear Power Station, Units 1 and 2; and R. E. Ginna Nuclear Power Plant.

The proposed amendments would revise the technical specifications (TSs) for each facility based on Technical Specification Task Force (TSTF) traveler TSTF-541, Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated Position (ADAMS Accession No. ML19240A315). The proposed amendments would also make similar changes to surveillance requirements not included in TSTF-541, Revision 2, and additional editorial changes to the TSs.

The NRC made requests for additional information (RAI) in an email dated February 10, 2022 (Reference 2). The additional information requests and the CEG responses are provided below.

RAI-1

The TS markups provided in the application include several changes that are not consistent with TSTF-541, Revision 2, and are not identified as variations in the application. The differences between the markup and the changes in TSTF-541, Revision 2, are as follows:

Dresden In its TS markup for SR 3.6.4.3.3, the licensee added except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The TSTF-541 markup does not include valves.

Fitzpatrick In its TS markup for SR 3.6.4.3.3, the licensee added except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The TSTF-541 markup does not include valves.

Limerick In its TS markup for SR 4.6.5.3.d.2, the licensee added except for valves that are locked, sealed, or otherwise secured in the actuated position. The TSTF-541 markup includes only dampers, not valves for this SR.

NMP-2 In its TS markup for SR 3.6.4.3.3, the licensee added except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The TSTF-541 markup does not include valves.

Request for Additional Information And Detailed Response Page 2 of 3 Peach Bottom In its TS markup for SR 3.6.4.3.3, the licensee added except for valves that are locked, sealed, or otherwise secured in the actuated position. The TSTF-541 markup only includes dampers, not valves.

Quad Cities In its TS markup for SR 3.6.4.3.3, the licensee added except for dampers and valves that are locked, sealed, or otherwise secured in the actuated position. The TSTF-541 markup does not include valves.

In its TS markup for SR 3.7.4.3, the licensee added except for dampers that are locked, sealed, or otherwise secured in the actuated position. The TSTF-541 markup includes dampers and valves.

Confirm that these differences are variations from TSTF-541, Revision 2, that are necessary to reflect plant-specific configurations. Otherwise, provide an explanation for these variations from the TSTF traveler.

Response to RAI-1 Except for Limerick SR 4.6.5.3.d.2 and Quad Cities SR 3.7.4.3, the above referenced SRs do not require variances due to plant specific configurations. The inclusion of dampers and valves or valves instead of dampers in the referenced Standby Gas Treatment System (SGT) SRs was an oversight during the development of the amendment request. Corrected pages for the above referenced SRs consistent with the TSTF, except for Limerick SR 4.6.5.3.d.2 and Quad Cities SR 3.7.4.3, are provided as an enclosure to this response and shall replace the corresponding pages from Reference 1.

Regarding Limerick SR 4.6.5.3.d.2, this SR specifically refers to the tested components as valves and not dampers. This is a function of Limerick maintaining custom Technical Specifications. Although the affected components are ventilation system isolation devices, the nomenclature used in the Limerick SR varies from the nomenclature of the TSTF. This is an administrative variance from the TSTF based on the naming of the components.

Regarding Quad Cities SR 3.7.4.3, this SR exercises only the Control Room Emergency Ventilation (CREV) systems dampers and is not a full system actuation. This is a variance from the approved TSTF that is necessary based on the difference between the Quad Cities SR 3.7.4.3 and the Standard Tech Spec (STS) 3.7.4.3 on which the TSTF is based. STS SR 3.7.4.3 requires actuation of the Main Control Room Environmental Control (MCREC) system which might include both valves and dampers whereas the Quad Cities SR only exercises dampers. The justification for applying the note to the STS SR 3.7.4.3 also applies to the Quad Cities SR 3.7.4.3 as the intent of the Quad Cities SR is consistent with the intent of the STS SR.

Request for Additional Information And Detailed Response Page 3 of 3

RAI-2

The TS markup for Limerick, Unit 2, proposes to add the following footnote to SR 4.7.3.c.1:

Except for valves that [are] locked, sealed, or otherwise secured in the actuated position.

However, the word are is missing as indicated by the bracketed text. Provide the correct wording for this proposed footnote.

Response to RAI-2 A corrected markup of Limerick Unit 2 SR 4.7.3.c.1 is provided with the enclosure to this response and shall replace the associate page from Reference 1.

Enclosure 1 Corrected Technical Specification Changes (Mark-Up)

Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 REVISED TECHNICAL SPECIFICATION PAGE 3.6.4.3-3 James A. FitzPatrick Nuclear Power Plant, Unit 1 Renewed Facility Operating License No. DPR-59 REVISED TECHNICAL SPECIFICATION PAGE 3.6.4.3-3 Limerick Generating Station, Unit 2 Facility Operating License Nos. NPF-39 and NPF-85 REVISED TECHNICAL SPECIFICATION PAGE 3/4 7-10 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 REVISED TECHNICAL SPECIFICATION PAGE 3.6.4.3-3 Peach Bottom Atomic Power Station, Unit 2 Renewed Facility Operating License Nos. DPR-44 and DPR-56 REVISED TECHNICAL SPECIFICATION PAGE 3.6-42 Peach Bottom Atomic Power Station, Unit 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 REVISED TECHNICAL SPECIFICATION PAGE 3.6-42 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 REVISED TECHNICAL SPECIFICATION PAGE 3.6.4.3-3

SGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for In accordance

~ 15 continuous minutes with heaters with the operating. Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required SGT filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program CVFTP).

SR 3.6.4.3.3 Verify each SGT subsystem actuates on an In accordance actual or simulated initiation signal. with the Surveillance Frequency Control Program INSERT , except for dampers that are locked, sealed, or otherwise secured in the actuated position.

Dresden 2 and 3 3.6.4.3-3 Amendment t~o. 241/234

SGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for ~ 15 continuous In accordance minutes with heaters operating. with the Surveillance Frequency Control Program SR 3.6.4.3.2 Perform required SGT filter testing in accordance In accordance with the Ventilation Filter Testing Program (VFTP). with the VFTP SR 3.6.4.3.3 Verify each SGT subsystem actuates on an actual In accordance or simulated initiation signal. with the Surveillance Frequency Control Program SR 3.6.4.3.4 Manually cycle each SGT subsystem filter cooling In accordance cross-tie valve. with the Surveillance Frequency Control Program INSERT , except for dampers that are locked, sealed, or otherwise secured in the actuated position.

JAFNPP 3.6.4.3-3 Amendment 326

PLANT SYSTEMS SURVEILLANCE REOUIREMENTS (Continued)

c. In accordance with the Surveillance Frequency Control Program by:

1. Performing a system functional test which includes simulated automatic actuation and restart and verifying that each automatic valve in the flow path actuates to its correct position. Actual injection of coolant into the reactor vessel may be excluded.

2. Verifying that the system will develop a flow of greater than or equal to 600 gpm in the test flow path when steam is supplied to the turbine at a pressure of 150 + 15, - 0 psig.*

3. Verifying that the suction 'for the RCIC system is automatically transferred from the condensate storage tank to the suppression pool on a condensate storage tank water level-low signal.

4. Performing a CHANNEL CALIBRATION of the RCIC system discharge line "keep filled" level alarm instrumentation.

INSERT **"

• The provisions of Specification 4.0.4 are not applicable provided the surveillance is performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after reactor steam pressure i s adequate to perform the tests. If OPERABILITY is not successfully demonstrated within the 12-hour period, reduce reactor steam dome pressure to less than 150 psig within the following 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

INSERT "** Except for valves that are locked, sealed, or otherwise secured in the actuated position."

LIMERICK - UNIT 2 3/4 7-10 Amendment No. 34,147

SGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem for In accordance with 2'. 15 continuous minutes with heaters the Surveillance operating. Frequency Control Program SR 3.6.4.3.2 Perform required SGT filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.6.4.3.3 Verify each SGT subsystem actuates on an In accordance with actual or simulated initiation signal. the Surveillance Frequency Control Program SR 3.6.4.3.4 Verify each SGT decay heat removal air In accordance with inlet valve can be opened. the Surveillance Frequency Control Program INSERT , except for dampers that are locked, sealed, or otherwise secured in the actuated position.

NMP2 3.6.4.3-3 Amendment 91, 1Q1, 162, 166, 168

SGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.1 Operate each SGT subsystem r n accordance

~ 15 minutes with heaters operating. with the Surveillance F uency Contro-Program.

SR 3.6.4.3.2 Perform uired SGT filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.6.4.3.3 Verify each subsystem actuates on an In accordance actual or simulated initiation signal. with the Surveillance Frequency Cont ro 1 Program.

INSERT , except for dampers that are locked, sealed, or otherwise secured in the actuated position PBAPS UNIT 2 3.6-42 Amendment No.273

SGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FR ENCY SR 3.6.4.3.1 Operate each SGT subsystem for In accordance

~ 15 minutes with heaters operating. with the Surveillance Frequency Control Program.

SR 3.6.4.3.2 Perform required SGT filter testing in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.6.4.3.3 Verify each SGT subsystem actuates on an In accordance actual or simulated initiation signal. with the Surveillance Frequency Control Program.

INSERT , except for dampers that are locked, sealed, or otherwise secured in the actuated position PBAPS UN IT 3 3.6-42 Amendment No .281

SGT System 3.6.4.3 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.3.l Operate each SGT subsystem for In accordance

~ 15 continuous minutes with heaters with the operating. Surveillance Frequertcy Control Program SR 3.6.4.3.2 Perform required SGT filter testtng in In accordance accordance with the Ventilation Filter with the VFTP Testing Program (VFTP).

SR 3.6.4.3.3 Verify each SGT subsystem actuates on an In accordance actual or simulated initiation signal. with the Surveillance Frequency Control Program INSERT , except for dampers that are locked, sealed, or otherwise secured in the actuated position.

Quad Cities 1 and 2 3.6.4.3-3 Amendment No. 252/247