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| U.S. Nuclear Regulatory Commission Response to Request for Additional Information TSTF-501-A DG Lube Oil Inventory Requirements August 11, 2016 Page 2 In the Reference 2 e-mail correspondence, the U.S. Nuclear Regulatory Commission (NRC) requested additional information. | | U.S. Nuclear Regulatory Commission Response to Request for Additional Information TSTF-501-A DG Lube Oil Inventory Requirements August 11, 2016 Page 2 In the Reference 2 e-mail correspondence, the U.S. Nuclear Regulatory Commission (NRC) requested additional information. |
| Attachment 1 contains Exelon's response to the NRC request for additional information. | | Attachment 1 contains Exelon's response to the NRC request for additional information. |
| Attachment 2 provides a copy of the marked up TS Bases pages that reflect the proposed change (information only). Attachment 2 replaces the TS Bases markups submitted in Reference | | Attachment 2 provides a copy of the marked up TS Bases pages that reflect the proposed change (information only). Attachment 2 replaces the TS Bases markups submitted in Reference |
| : 1. The TS page markups submitted in Reference 1 are not affected by this response. | | : 1. The TS page markups submitted in Reference 1 are not affected by this 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 | | 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. | | : 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. | | 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. | | 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. | | 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 11 lh day of August 2016. Respectfully, James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: | | I declare under penalty of perjury that the foregoing is true and correct. Executed on the 11 lh day of August 2016. Respectfully, James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments: |
| : 1. Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request concerning Diesel Generator Lube Oil Inventory Requirements (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3 2. Markup of Proposed Technical Specifications Bases Pages (Information Only) 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 1 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Docket Nos. 5Q-277 and 50-278 Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request concerning Diesel Generator Lube Oil Inventory Requirements (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3 Response to Request for Additional Information TSTF-501-A DG Lube Oil Inventory Requirements Docket Nos. 50-277 and 50-278 Attachment 1 Page 1 of 3 By application dated June 20, 2016, Exelon Generation Company, LLC (Exelon) submitted a license amendment request (LAR) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The amendments would revise the Technical Specification (TS} 3.8.3, .. Diesel Fuel Oil, Lube Oil, and Starting Air, .. requirements associated with the stored inventory of lube oil for the diesel generators (DGs). Specifically, the TS inventory requirements for stored lube oil (currently specified in number of gallons) would be replaced with inventory requirements based on DG operating time (specified in number of days). The proposed changes are based on Revision 1 to Technical Specifications Task Force (TSTF} Improved Standard Technical Specifications Change Traveler TSTF-501, .. Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control .. (ADAMS Accession No. ML090510686). | | : 1. Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request concerning Diesel Generator Lube Oil Inventory Requirements (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3 2. Markup of Proposed Technical Specifications Bases Pages (Information Only) 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 1 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Docket Nos. 5Q-277 and 50-278 Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request concerning Diesel Generator Lube Oil Inventory Requirements (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3 Response to Request for Additional Information TSTF-501-A DG Lube Oil Inventory Requirements Docket Nos. 50-277 and 50-278 Attachment 1 Page 1 of 3 By application dated June 20, 2016, Exelon Generation Company, LLC (Exelon) submitted a license amendment request (LAR) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The amendments would revise the Technical Specification (TS} 3.8.3, .. Diesel Fuel Oil, Lube Oil, and Starting Air, .. requirements associated with the stored inventory of lube oil for the diesel generators (DGs). Specifically, the TS inventory requirements for stored lube oil (currently specified in number of gallons) would be replaced with inventory requirements based on DG operating time (specified in number of days). The proposed changes are based on Revision 1 to Technical Specifications Task Force (TSTF} Improved Standard Technical Specifications Change Traveler TSTF-501, .. Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control .. (ADAMS Accession No. ML090510686). |
| The NRC staff has determined that additional information is needed to complete its review. The specific requests for additional information (RAI) questions are restated below along with Exelon*s response. | | The NRC staff has determined that additional information is needed to complete its review. The specific requests for additional information (RAI) questions are restated below along with Exelon*s response. |
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| ): Attachment 3 to the licensee*s application dated June 20, 2016, provided marked up TS Bases pages (for information only) which would be implemented, in accordance with the TS Bases Control Program, as part of the proposed amendment. | | ): Attachment 3 to the licensee*s application dated June 20, 2016, provided marked up TS Bases pages (for information only) which would be implemented, in accordance with the TS Bases Control Program, as part of the proposed amendment. |
| The proposed markup for the Bases for TS 3.8.3, Limiting Condition for Operation (LCO), Action B.1 is not consistent with the BWR/4 STS Bases markup included in TSTF-501, Revision 1. Specifically, the licensee did not propose any changes to the first sentence in this section. In addition, TSTF-501, Revision 1, includes changes to the TS Bases for SR 3.8.3.2. The licensee did not propose any Bases changes for PBAPS SR 3.8.3.2. The licensee's application did not identify these differences as proposed deviations to the TSTF. Please provide justifications for these deviations or provide a supplement with proposed TS Bases changes consistent with TSTF-501, Revision 1. Response: | | The proposed markup for the Bases for TS 3.8.3, Limiting Condition for Operation (LCO), Action B.1 is not consistent with the BWR/4 STS Bases markup included in TSTF-501, Revision 1. Specifically, the licensee did not propose any changes to the first sentence in this section. In addition, TSTF-501, Revision 1, includes changes to the TS Bases for SR 3.8.3.2. The licensee did not propose any Bases changes for PBAPS SR 3.8.3.2. The licensee's application did not identify these differences as proposed deviations to the TSTF. Please provide justifications for these deviations or provide a supplement with proposed TS Bases changes consistent with TSTF-501, Revision 1. Response: |
| Exelon proposes to revise the TS Bases to be consistent with the BWR/4 STS Bases markup included in TSTF-501, Revision 1. For information, a copy of the revised marked up TS Bases pages that reflect the proposed change are provided in Attachment | | Exelon proposes to revise the TS Bases to be consistent with the BWR/4 STS Bases markup included in TSTF-501, Revision 1. For information, a copy of the revised marked up TS Bases pages that reflect the proposed change are provided in Attachment |
| : 2. Question 2 (DORL-RAI-2): | | : 2. Question 2 (DORL-RAI-2): |
| The NRC's model safety evaluation for TSTF-501, Revision 1, explains the reason why licensees would want to adopt this TSTF. Specifically, the DG fuel oil numerical volume inventory requirement (in gallons) may need to be modified in order to take into account changes to the energy content (BTU/gallon) of available fuels in the market. Replacing the TS inventory requirements for stored fuel oil in gallons with inventory requirements specified in number of days of DG operating time could allow the licensee to make changes to the required number of gallons under licensee control, and therefore, may not require NRC prior approval. | | The NRC's model safety evaluation for TSTF-501, Revision 1, explains the reason why licensees would want to adopt this TSTF. Specifically, the DG fuel oil numerical volume inventory requirement (in gallons) may need to be modified in order to take into account changes to the energy content (BTU/gallon) of available fuels in the market. Replacing the TS inventory requirements for stored fuel oil in gallons with inventory requirements specified in number of days of DG operating time could allow the licensee to make changes to the required number of gallons under licensee control, and therefore, may not require NRC prior approval. |
Letter Sequence Response to RAI |
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CAC:MF8010, Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control (Approved, Closed) |
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MONTHYEARML16175A3732016-06-23023 June 2016 Acceptance Review - Peach Bottom 2 & 3 - Emergency Diesel Generator Lube Oil Requirements (CACs MF8010 & MF8011) Project stage: Acceptance Review ML16221A6802016-08-0808 August 2016 Draft Request for Additional Information Project stage: Draft RAI ML16224A3422016-08-11011 August 2016 Response to Request for Additional Information Regarding Proposed License Amendment Concerning Diesel Generator Lube Oil Inventory (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3 Project stage: Response to RAI ML16235A4052016-10-14014 October 2016 Issuance of Amendments Diesel Generator Lube Oil Inventory Requirements Project stage: Approval 2016-06-23
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Category:Letter
MONTHYEARML24022A2262024-01-22022 January 2024 (PBAPS) Unit 3 - Submittal of the Inservice Inspection (ISI) Owner'S Activity Report (OAR) for the 24th Refueling Outage for Unit 3 ML23346A2412024-01-17017 January 2024 Staff Assessment of Updated Seismic Hazards Following the NRC Process for the Ongoing Assessment of Natural Hazards Information (EPID L-2019-PMP-0061) - Letter IR 05000277/20234022024-01-11011 January 2024 Security Baseline Inspection Report 05000277/2023402 and 05000278/2023402 and Independent Spent Fuel Storage Installation Security Inspection 07200029/2023401 ML23354A1922024-01-0505 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting) ML23355A0622023-12-18018 December 2023 Independent Spent Fuel Storage Installation (Isfsi), Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan ML23278A1292023-12-14014 December 2023 Units 1 & 2; Limerick, Units 1 & 2; Nine Mile Point, Units 1 & 2; and Peach Bottom, Units 2 & 3 -Revision to Approved Alternatives to Use Boiling Water Reactor Vessel and Internals Project Guidelines ML23305A1402023-12-13013 December 2023 Units 1 & 2; Nine Mile Point, Unit 2; Peach Bottom, Units 2 & 3; and Quad Cities, Units 1 and 2 - Issuance of Amendments to Adopt Traveler TSTF-580 ML23334A2502023-11-30030 November 2023 Request for Exemption from Enhanced Weapons, Firearms Background Checks, and Security Event Notifications Implementation ML23270C0072023-11-29029 November 2023 Notice of Proposed Amendment to Decommissioning Trust Agreement ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums ML23305A3472023-11-0101 November 2023 Revision of One Form That Implements the Radiological Emergency Response Plan (RERP) IR 05000277/20230032023-10-30030 October 2023 Integrated Inspection Report 05000277/2023003 and 05000278/2023003 and Exercise of Enforcement Discretion ML23286A0012023-10-13013 October 2023 Reply to a Notice of Violation (NOV) - NOV 05000277, 05000278/2023010-01 RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans ML23271A1342023-10-11011 October 2023 Dtf Analysis Letter IR 05000277/20244012023-10-0505 October 2023 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection 05000277/2024401 and 05000278/2024401 ML23265A1502023-09-22022 September 2023 License Amendment Request Revise a License Condition and Certain Technical Specifications to Remove Restrictions in Support of Decommissioning Activities ML23264A8682023-09-21021 September 2023 Independent Spent Fuel Storage Installation Registration of Dry Storage Canister WC-EOS-37PTH-008-B4L, WC-EOS-37PTH-007-B4L, and WC-EOS-37PTH-002-B4L IR 05000277/20230102023-09-15015 September 2023 Biennial Problem Identification and Resolution Inspection Report 05000277/2023010 and 05000278/2023010 and Notice of Violation ML23251A2022023-09-11011 September 2023 Cover Letter W/Report LR-N23-0045, and Peach Bottom Atomic Power Station, Units 2 and 3 - Notice of Proposed Amendment to Decommissioning Trust Agreement2023-09-0808 September 2023 and Peach Bottom Atomic Power Station, Units 2 and 3 - Notice of Proposed Amendment to Decommissioning Trust Agreement IR 05000277/20230052023-08-31031 August 2023 Updated Inspection Plan for Peach Bottom Atomic Power Station, Units 2 and 3 (Report 05000277/2023005 and 05000278/2023005) ML23158A1952023-08-30030 August 2023 R. E. Ginna - Issuance of Amendments to Adopt TSTF-273-A, Revision 2, Safety Function Determination Program Clarifications ML23232A0012023-08-19019 August 2023 Revision of One Procedure That Implements the Radiological Emergency Response Plan (Rerp). Includes EPP 06-009, Rev. 13 IR 05000277/20230112023-08-15015 August 2023 Comprehensive Engineering Team Inspection Report 05000277/2023011 and 05000278/2023011 ML23226A1112023-08-14014 August 2023 10 CFR 50.46 Annual Report IR 05000277/20230022023-08-0808 August 2023 Integrated Inspection Report 05000277/2023002 and 05000278/2023002 RS-23-087, Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor2023-08-0404 August 2023 Revision to Approved Alternatives Associated with the Use of the BWRVIP Guidelines in Lieu of Specific ASME Code Requirements on Reactor IR 05000277/20230402023-07-17017 July 2023 95001 Inspection Supplemental Report 05000277/2023040 and Follow-Up Assessment Letter ML23188A0532023-07-0707 July 2023 Registration of Use of Independent Spent Fuel Storage Installation (ISFSI) Casks ML23186A1272023-07-0606 July 2023 Response to Disputed Non-Cited Violation Documented in Peach Bottom Atomic Power Station, Units 2 and 3, Inspection Report 05000277/2022004 and 05000278/2022004 ML23178A0352023-06-27027 June 2023 Senior Reactor and Reactor Operator Initial License Examinations RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations ML23151A4162023-05-31031 May 2023 Revision of One Form That Implements the Radiological Emergency Response Plan (RERP) for Wolf Creek Generating Station (WCGS) ML23150A2052023-05-30030 May 2023 Independent Spent Fuel Storage Installation (Isfsi), Annual Radiological Environmental Operating Report 80 January 1, 2022 Through December 31, 2022 RS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling ML23142A1602023-05-23023 May 2023 Summary of April 11, 2023, Public Observation Meeting with Constellation Energy Generation, LLC Re Proposed Exemption Request from Work Hour Requirements ML23132A1582023-05-18018 May 2023 Correction to Technical Specification 3.4.7 (Page 3.4-16) Issued in Amendment No. 337 ML23132A1532023-05-12012 May 2023 Transmittal of 2022 Annual Financial Reports WM 23-0009, Financial Assurance Requirements for Decommissioning Nuclear Power Reactors 10 CFR 50.75(f)(1)2023-05-10010 May 2023 Financial Assurance Requirements for Decommissioning Nuclear Power Reactors 10 CFR 50.75(f)(1) IR 05000277/20230012023-05-0808 May 2023 Integrated Inspection Report 05000277/2023001 and 05000278/2023001 ML23114A2522023-04-28028 April 2023 Request to Use a Provision of a Later Edition of the ASME Boiler & Pressure Vessel Code, Section XI 2024-01-05
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARCCN:23-09, Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information2023-11-10010 November 2023 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information ML22312A3642022-11-0808 November 2022 Response to NRC Inspection Report and Preliminary White Finding ML22145A0852022-05-25025 May 2022 Response to Request for Additional Information - Proposed Relief Request Associated with Reactor Pressure Vessel N-16A Nozzle Repair 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 Actuated2022-02-23023 February 2022 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 NMP1L3447, Constellation Energy Generation, LLC - Response to Request for Additional Information - Proposed Relief Request Associated with Reactor Pressure Vessel Water Level Instrumentation Partial Penetration Nozzle Repairs2022-02-0202 February 2022 Constellation Energy Generation, LLC - Response to Request for Additional Information - Proposed Relief Request Associated with Reactor Pressure Vessel Water Level Instrumentation Partial Penetration Nozzle Repairs JAFP-21-0087, Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments2021-09-16016 September 2021 Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments JAFP-21-0044, Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments2021-06-11011 June 2021 Response to Request for Additional Information Regarding Request for Approval of Transfer of Licenses and Conforming Amendments JAFP-21-0032, Response to Request for Additional Information - Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting2021-04-20020 April 2021 Response to Request for Additional Information - Proposed Alternative Concerning ASME Section XI Repair/Replacement Documentation for Replacement of Pressure Retaining Bolting ML21035A0332021-02-0404 February 2021 Response to Request for Additional Information - License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative ML21029A1662021-01-29029 January 2021 Response to Request for Additional Information - License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative RS-20-112, Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-5682020-09-0303 September 2020 Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-568 ML20224A5302020-08-11011 August 2020 Response to the Order for Implementation of Additional Security Measures and Fingerprinting for Unescorted Access for Wolf Creek Operating Corporation Independent Spent Fuel Storage Installation ML20188A2642020-07-0606 July 2020 Clinton Power Station, R.E. Ginna Station, Limerick Station, Nine Mile Point Station & Peach Bottom Station - Proposed Alternative to Utilize Code Case OMN-26 - Response to Request for Additional Information ML19276F2812019-10-0303 October 2019 Supplemental Response to Request for Additional Information (RAl-1) License Amendment Request to Revise Technical Specifications 3.8.4, DC Sources-Operating ML19241A4652019-08-29029 August 2019 Response to Request for Additional Information (RAl-1) License Amendment Request to Revise Technical Specifications 3.8.4, DC Sources-Operating ML19225B9762019-08-13013 August 2019 Response to NRC Request for Clarification of Information, Dated August 1, 2019 Related to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application ML19206A0562019-07-24024 July 2019 Stations, Units 2 and 3 - Response to Request for Additional Information - License Amendment Request to Revise Technical Specifications 3.8.1, Required Action A.3, for Temporary One-Time Extension of Completion Time ML19163A2232019-06-12012 June 2019 Revised Response to NRC Request for Additional Information, Core Shroud Support Fatigue Analysis Reevaluation, Related to the Subsequent License Renewal Application ML19157A0092019-06-0606 June 2019 Response to NRC Request for Additional Information, Dated May 15, 2019 Related to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application JAFP-19-0057, Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-8802019-06-0404 June 2019 Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880 ML19150A2972019-05-30030 May 2019 Revised Responses to NRC Requests for Additional Information, Fire Water System, Related to the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application ML19122A2892019-05-0202 May 2019 Response to NRC Requests for Additional Information, Set 1, Dated April 10, 2019 Related to Plant Subsequent License Renewal Application NMP1L3279, Response to Request for Additional Information - Proposed Alternatives to Utilize Code Cases N-878 and N-880 for Plants2019-05-0101 May 2019 Response to Request for Additional Information - Proposed Alternatives to Utilize Code Cases N-878 and N-880 for Plants ML19085A3852019-03-26026 March 2019 Response to Second Request for Additional Information - License Amendment Request to Reduce High Pressure Service Water System Design Pressure and Revise Technical Specifications ... ML19065A0082019-03-0505 March 2019 Response to Nrg Audit Review Information Request - Application for Subsequent Renewed Operating Licenses Section 4.6 Primary Containment Fatigue Analyses ML19046A1292019-02-15015 February 2019 Response to RAI - License Amendment Request to Reduce High Pressure Service Water System Design Pressure and Revise Technical Specifications 3.6.2.3, 3.6.2.4, 3.6.2.5, and 3.7.1 for Temporary Extension of Completion Times ML19028A2802019-01-28028 January 2019 Response to NRC Request for Additional Information, Dated December 13, 2018, Regarding Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Severe Accident Mitigation Alternatives Requests for Additional Information JAFP-19-0006, Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-8802019-01-0808 January 2019 Response to Request for Additional Information - Proposed Alternative to Utilize Code Cases N-878 and N-880 ML19007A3262019-01-0707 January 2019 Response to Request Dated December 7, 2018 for Docketing of Additional Documents to Support Nrc'S Environmental Review of the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application ML18354B0612018-12-20020 December 2018 Response to NRC Request for Additional Information, Dated November 23, 2018, Regarding the Peach Bottom Atomic Power Station, Units 2 and 3, Subsequent License Renewal Application, Environmental Requests for Additional Information ML18340A1852018-12-0606 December 2018 Response to Request for Additional Information License Amendment Request - Revise Technical Specifications to Allow Two Safety Relief Valves/Safety Valves to Be Out-of-Service with Increased Reactor Pressure Safety Limit RS-18-143, Supplemental Information Supporting License Amendment Requests for Approval of Changes to Emergency Plan Staffing Requirements2018-11-29029 November 2018 Supplemental Information Supporting License Amendment Requests for Approval of Changes to Emergency Plan Staffing Requirements ML18337A2402018-11-28028 November 2018 Response to Request for Additional Information - Relief Requests Associated with the Fifth Inservice Inspection Interval ML18305B2702018-11-0101 November 2018 Response to Request for Additional Information - License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements ML18257A0172018-09-14014 September 2018 Response to Request for Additional Information Application to Revise Technical Specifications to Adopt Technical Specification Task Force (TSTF)-500, Revision 2, DC Electrical Rewrite Update to ... ML18222A3872018-08-10010 August 2018 Response to Request for Additional Information and Supplemental Information - Application to Adopt 1 O CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems, and Components ... ML18128A0092018-05-0707 May 2018 Response to Request for Additional Information Application to Adopt 10 CFR 50.69, Risk-informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Plants. RS-18-061, Response to Request for Additional Information Regarding Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (Isfsis)2018-05-0202 May 2018 Response to Request for Additional Information Regarding Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (Isfsis) ML17354A3812017-12-20020 December 2017 Supplemental Response Concerning License Amendment Request to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2 RS-17-149, Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from The.2017-12-15015 December 2017 Spent Fuel Pool Evaluation Supplemental Report, Response to NRC Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from The. ML17241A1942017-08-29029 August 2017 License Amendment Request - Revise Technical Specifications Section 3.4.3 (Srvs/Svs) for the Remainder of the Current Operating Cycle for Unit 2 - Supplement 1 Response to Request for Additional Information ML17223A6262017-08-11011 August 2017 Response to Request for Additional Information Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2 ML17220A2142017-08-0808 August 2017 Measurement Uncertainty Recapture License Amendment Request - Supplement 3 Response to Request for Additional Information ML17195A2852017-07-13013 July 2017 Measurement Uncertainty Recapture License Amendment Request - Supplement 2 Response to Request for Additional Information RS-17-044, Response to Request for Additional Information Regarding Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography2017-03-13013 March 2017 Response to Request for Additional Information Regarding Proposed Alternative for the Use of Encoded Phased Array Ultrasonic Examination Techniques in Lieu of Radiography ML16224A3422016-08-11011 August 2016 Response to Request for Additional Information Regarding Proposed License Amendment Concerning Diesel Generator Lube Oil Inventory (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3 ML16216A0762016-08-0202 August 2016 Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request Concerning Emergency Diesel Generator Fuel Oil Transfer Surveillance Requirements ML16162A1012016-06-0909 June 2016 Response to Request for Additional Information Regarding Proposed License Amendment Concerning Emergency Diesel Generator Fuel Oil Transfer Surveillance Requirements RA-16-049, Response to Request for Additional Information Regarding Requests to Withhold Emergency Preparedness Documents from Public Disclosure2016-05-26026 May 2016 Response to Request for Additional Information Regarding Requests to Withhold Emergency Preparedness Documents from Public Disclosure ML16083A3942016-03-23023 March 2016 Changes to High Pressure Coolant Injection and Reactor Core Isolation Cooling Surveillance Requirements - Supplement 1, Response to Request for Additional Information 2023-11-10
[Table view] Category:Technical Specification
MONTHYEARRS-23-042, Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling2023-05-25025 May 2023 Application to Revise Technical Specifications to Adopt TSTF-580, Provide Exception from Entering Mode 4 with No Operable RHR Shutdown Cooling ML23103A3302023-04-13013 April 2023 Submittal of Changes to Technical Specifications Bases JAFP-20-0049, Application to Adopt TSTF-427, Revision 2, Allowance for Non Technical Specification Barrier Degradation on Supported System Operability2020-06-22022 June 2020 Application to Adopt TSTF-427, Revision 2, Allowance for Non Technical Specification Barrier Degradation on Supported System Operability JAFP-19-0067, Application to Adopt TSTF-427, Revision 2, Allowance for Non Technical Specification Barrier Degradation on Supported System Operability2019-06-27027 June 2019 Application to Adopt TSTF-427, Revision 2, Allowance for Non Technical Specification Barrier Degradation on Supported System Operability RS-19-039, Fleet License Amendment Request - Common Language for Technical Specification High Radiation Area Administrative Controls2019-06-26026 June 2019 Fleet License Amendment Request - Common Language for Technical Specification High Radiation Area Administrative Controls ML19158A3122019-06-0707 June 2019 License Amendment Request to Revise Technical Specifications 3.8.4, DC Sources - Operating ML19141A1012019-05-21021 May 2019 Summary of Exelon'S Proposal for Implementation of TSTF-500-Technical Specification Changes ML18213A2712018-08-0101 August 2018 Application to Revise Technical Specifications to Adopt TSTF-500, Revision 2, DC Electrical Rewrite Update to TSTF-360, - Supplement 1, Revision of Implementation Dates. ML18172A2832018-06-21021 June 2018 Emergency License Amendment Request - One-Time Change Suspending Emergency Diesel Generator Surveillance Test Completion Requirements ML17030A3022017-01-30030 January 2017 Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2 ML16224A3422016-08-11011 August 2016 Response to Request for Additional Information Regarding Proposed License Amendment Concerning Diesel Generator Lube Oil Inventory (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3 ML16209A2182016-07-26026 July 2016 Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Lnservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing. ML15357A2502015-12-23023 December 2015 Application to Revise Technical Specifications to Adopt TSTF-484, Use of TS 3.10.1 for Scram Time Testing Activities, Revision 0, Using the Consolidated Line Item Improvement Process ML15349A8002015-12-15015 December 2015 License Amendment Request to Reduce Steam Dome Pressure Specified in the Reactor Core Safety Limits ML15337A4132015-12-0303 December 2015 License Amendment Request to Revise Surveillance Requirement 3.8.1.6 Involving EDG Fuel Oil Transfer ML15299A0842015-10-26026 October 2015 PBAPS MELLLA License Amendment Request - Supplement 7 Revision Regarding Proposed Technical Specifications ML15224B5722015-08-12012 August 2015 Submits Supplement to License Amendment Request Proposed Changes to the Technical Specifications to Address Administrative Control of Secondary Containment Access Openings ML15222B1712015-08-10010 August 2015 License Amendment Request to Revise Technical Specifications Section 5.5.12 for Permanent Extension of Type a and Type C Leak Rate Test Frequencies ML15133A5032015-04-14014 April 2015 Technical Specifications Bases ML15133A5002015-04-14014 April 2015 Technical Specifications Bases ML15082A2552015-03-23023 March 2015 Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 ML15041A3512015-02-0909 February 2015 Response to Request for Additional Information Revise Technical Specifications to Eliminate Main Steam Line Radiation Monitor Trip and Isolation Function ML14211A0192014-07-25025 July 2014 License Amendment Request Revise Technical Specifications Definition for Recently Irradiated Fuel ML14171A4092014-06-20020 June 2014 Extended Power Uprate License Amendment Request - Supplement 28 Supplemental Information ML14128A1322014-04-10010 April 2014 License No. DPR-56, Technical Specifications Bases, Page Revision Listing ML14128A1312014-04-10010 April 2014 License No. DPR-44, Technical Specifications Bases, Page Revision Listing ML13121A3782013-04-10010 April 2013 Technical Specifications Bases ML13121A3792013-04-10010 April 2013 Technical Specifications Bases ML12124A0922012-04-12012 April 2012 PBAPS Unit 3 - License No. DPR-56 Technical Specifications Bases ML12124A0912012-04-12012 April 2012 PBAPS Unit 2 - License No. DPR-44 Technical Specifications Bases ML1115401222011-06-0202 June 2011 License Amendment Request - Reactivity Anomalies Surveillance ML11126A3102011-04-15015 April 2011 Unit Unit 3 Technical Specifications Bases, Page B 3.3-66, Through Page B 3.10-36 ML11126A3092011-04-15015 April 2011 Technical Specifications Bases, Cover Page Through Unit 3 Technical Specifications Bases, Page B 3.3-65 ML1109700672011-04-0606 April 2011 License Amendment Request to Revise Operability Requirements and Actions for RCS Leakage Instrumentation ML1025004972010-04-22022 April 2010 Changes to Technical Specifications Bases ML1025004952010-04-22022 April 2010 Changes to Technical Specifications Bases ML1008407522010-03-24024 March 2010 Request for Amendment to Technical Specification 3.1.7, Standby Liquid Control (SLC) System. ML0924400532009-08-28028 August 2009 License Amendment Request - Type a Test Extension ML0922200452009-07-30030 July 2009 License Amendment Request for Adoption of TSTF-478-A, Revision 2, BWR Technical Specification Changes That Implement the Revised Rule for Combustible Gas Control, Using the Consolidated Line Item Improvement Process ML0912806092009-04-17017 April 2009 Changes to Technical Specifications Bases, Including Changes Through 04/08/2009 ML0912806082009-04-17017 April 2009 Changes to Technical Specifications Bases, Including Changes Through 04/08/2009 ML0824908352008-09-0505 September 2008 Amendment 273 Application of Alternative Source Term Methodology ML0823907072008-08-21021 August 2008 Revised T.S. Pages Oyster Creek Nuclear Generating Station and Peach Bottom Atomic Power Station, Unit 3-Correction to Facility Operating Licenses ML0819704612008-07-14014 July 2008 AST Response - Reconciliation of Technical Specifications Page Changes RA-08-047, Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency, Clarification of SRM Insert Control Rod Action and Clarification of a Frequency Example Using the Consolidation Line Item I2008-06-0909 June 2008 Application for Technical Specification Change Regarding Revision of Control Rod Notch Surveillance Test Frequency, Clarification of SRM Insert Control Rod Action and Clarification of a Frequency Example Using the Consolidation Line Item Im ML0813503632008-04-28028 April 2008 Changes to Technical Specifications Bases ML0813503662008-04-28028 April 2008 Changes to Technical Specifications Bases ML0735400492007-12-19019 December 2007 Letter to C. Pardee Correction of Administrative Error in Amendment - the Consistency of TSs to Exelon Generation Company Quality Assurance TR (Tac. MD3937 Thru MD3940 and MD3943 Thru MD3948). - Rplacement Pages RS-07-044, Amergen Energy Company, LLC, Request for Amendment to Technical Specifications Section for the Inservice Testing Program2007-08-0808 August 2007 Amergen Energy Company, LLC, Request for Amendment to Technical Specifications Section for the Inservice Testing Program ML0719701642007-07-12012 July 2007 Tech Spec Pages for Amendment 265 Risk-Informed Modification to Selected Required End States 2023-05-25
[Table view] Category:Bases Change
MONTHYEARML23103A3302023-04-13013 April 2023 Submittal of Changes to Technical Specifications Bases JAFP-19-0067, Application to Adopt TSTF-427, Revision 2, Allowance for Non Technical Specification Barrier Degradation on Supported System Operability2019-06-27027 June 2019 Application to Adopt TSTF-427, Revision 2, Allowance for Non Technical Specification Barrier Degradation on Supported System Operability ML19158A3122019-06-0707 June 2019 License Amendment Request to Revise Technical Specifications 3.8.4, DC Sources - Operating ML19141A1012019-05-21021 May 2019 Summary of Exelon'S Proposal for Implementation of TSTF-500-Technical Specification Changes ML18213A2712018-08-0101 August 2018 Application to Revise Technical Specifications to Adopt TSTF-500, Revision 2, DC Electrical Rewrite Update to TSTF-360, - Supplement 1, Revision of Implementation Dates. ML17030A3022017-01-30030 January 2017 Application to Revise Technical Specifications to Adopt TSTF-542, Reactor Pressure Vessel Water Inventory Control, Revision 2 ML16224A3422016-08-11011 August 2016 Response to Request for Additional Information Regarding Proposed License Amendment Concerning Diesel Generator Lube Oil Inventory (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3 ML16209A2182016-07-26026 July 2016 Application to Revise Technical Specifications to Adopt TSTF-545, Revision 3, TS Lnservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing. ML15357A2502015-12-23023 December 2015 Application to Revise Technical Specifications to Adopt TSTF-484, Use of TS 3.10.1 for Scram Time Testing Activities, Revision 0, Using the Consolidated Line Item Improvement Process ML15349A8002015-12-15015 December 2015 License Amendment Request to Reduce Steam Dome Pressure Specified in the Reactor Core Safety Limits ML15337A4132015-12-0303 December 2015 License Amendment Request to Revise Surveillance Requirement 3.8.1.6 Involving EDG Fuel Oil Transfer ML15299A0842015-10-26026 October 2015 PBAPS MELLLA License Amendment Request - Supplement 7 Revision Regarding Proposed Technical Specifications ML15133A5002015-04-14014 April 2015 Technical Specifications Bases ML15133A5032015-04-14014 April 2015 Technical Specifications Bases ML14211A0192014-07-25025 July 2014 License Amendment Request Revise Technical Specifications Definition for Recently Irradiated Fuel ML14171A4092014-06-20020 June 2014 Extended Power Uprate License Amendment Request - Supplement 28 Supplemental Information ML14128A1322014-04-10010 April 2014 License No. DPR-56, Technical Specifications Bases, Page Revision Listing ML14128A1312014-04-10010 April 2014 License No. DPR-44, Technical Specifications Bases, Page Revision Listing ML13121A3782013-04-10010 April 2013 Technical Specifications Bases ML13121A3792013-04-10010 April 2013 Technical Specifications Bases ML12124A0922012-04-12012 April 2012 PBAPS Unit 3 - License No. DPR-56 Technical Specifications Bases ML12124A0912012-04-12012 April 2012 PBAPS Unit 2 - License No. DPR-44 Technical Specifications Bases ML1115401222011-06-0202 June 2011 License Amendment Request - Reactivity Anomalies Surveillance ML11126A3092011-04-15015 April 2011 Technical Specifications Bases, Cover Page Through Unit 3 Technical Specifications Bases, Page B 3.3-65 ML11126A3102011-04-15015 April 2011 Unit Unit 3 Technical Specifications Bases, Page B 3.3-66, Through Page B 3.10-36 ML1109700672011-04-0606 April 2011 License Amendment Request to Revise Operability Requirements and Actions for RCS Leakage Instrumentation ML1025004972010-04-22022 April 2010 Changes to Technical Specifications Bases ML1025004952010-04-22022 April 2010 Changes to Technical Specifications Bases ML0912806082009-04-17017 April 2009 Changes to Technical Specifications Bases, Including Changes Through 04/08/2009 ML0912806092009-04-17017 April 2009 Changes to Technical Specifications Bases, Including Changes Through 04/08/2009 ML0813503662008-04-28028 April 2008 Changes to Technical Specifications Bases ML0813503632008-04-28028 April 2008 Changes to Technical Specifications Bases RS-07-044, Amergen Energy Company, LLC, Request for Amendment to Technical Specifications Section for the Inservice Testing Program2007-08-0808 August 2007 Amergen Energy Company, LLC, Request for Amendment to Technical Specifications Section for the Inservice Testing Program ML0713602352007-04-27027 April 2007 Technical Specifications Bases - License No. DPR-56 ML0713602242007-04-27027 April 2007 Technical Specifications Bases - License No DPR-44 RS-07-020, Exelon/Amergen Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process2007-04-12012 April 2007 Exelon/Amergen Application to Revise Technical Specifications Regarding Control Room Envelope Habitability in Accordance with TSTF-448, Revision 3, Using the Consolidated Line Item Improvement Process ML0612804782006-04-24024 April 2006 PBAPS Unit 3 - Technical Specifications Bases Page Revision Listing ML0612805382006-04-24024 April 2006 PBAPS Unit 2 - Technical Specifications Bases Page Revision Listing ML0514004382005-05-0202 May 2005 Improved Technical Specifications (Unit 3 Bases) ML0514004362005-05-0202 May 2005 Improved Technical Specifications (Unit 2 Bases) ML0504000832005-01-21021 January 2005 Supplement to the Request for License Amendments Related to Application of Alternative Source Term, Dated July 14, 2003 ML0413800892004-04-30030 April 2004 Submittal of Changes to Technical Specifications Gases ML0211902302002-04-19019 April 2002 Part H - Submittal of All Peach Bottom Atomic Power Station Unit 2 & Unit 3 Technical Specifications Bases Changes Through Unit 2 Bases Revision 39 & Unit 3 Bases Revision 40 ML0211901742002-04-19019 April 2002 Part G - Submittal of All Peach Bottom Atomic Power Station Unit 2 & Unit 3 Technical Specifications Bases Changes Through Unit 2 Bases Revision 39 & Unit 3 Bases Revision 40 ML0211901312002-04-19019 April 2002 Part F - Submittal of All Peach Bottom Atomic Power Station Unit 2 & Unit 3 Technical Specifications Bases Changes Through Unit 2 Bases Revision 39 & Unit 3 Bases Revision 40 ML0211901172002-04-19019 April 2002 Part E - Submittal of All Peach Bottom Atomic Power Station Unit 2 & Unit 3 Technical Specifications Bases Changes Through Unit 2 Bases Revision 39 & Unit 3 Bases Revision 40 ML0211901072002-04-19019 April 2002 Part D - Submittal of All Peach Bottom Atomic Power Station Unit 2 & Unit 3 Technical Specifications Bases Changes Through Unit 2 Bases Revision 39 & Unit 3 Bases Revision 40 ML0211900622002-04-19019 April 2002 Part C - Submittal of All Peach Bottom Atomic Power Station Unit 2 & Unit 3 Technical Specifications Bases Changes Through Unit 2 Bases Revision 39 & Unit 3 Bases Revision 40 ML0211900242002-04-19019 April 2002 Part B - Submittal of All Peach Bottom Atomic Power Station Unit 2 & Unit 3 Technical Specifications Bases Changes Through Unit 2 Bases Revision 39 & Unit 3 Bases Revision 40 ML0211900092002-04-19019 April 2002 Part a - Submittal of All Peach Bottom Atomic Power Station Unit 2 & Unit 3 Technical Specifications Bases Changes Through Unit 2 Bases Revision 39 & Unit 3 Bases Revision 40 2023-04-13
[Table view] |
Text
200 Exelon Way Exelon Generation Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 August 11, 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
Subject:
Response to Request for Additional Information Regarding Proposed License Amendment concerning Diesel Generator Lube Oil Inventory (TSTF-501-A) 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, .. Application to Revise Technical Specifications to Adopt TSTF-501-A, 'Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control,'
Revision 1, using the Consolidated Line Item Improvement Process (ML 16173A371
), .. dated June 20, 2016. 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 concerning Diesel Generator Lube Oil Inventory (TSTF-501-A) (ML16221A680)," dated July 26, 2016. By application dated June 20, 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 amendments would revise the Technical Specification (TS) 3.8.3, .. Diesel Fuel Oil, Lube Oil, and Starting Air, .. requirements associated with the stored inventory of lube oil for the diesel generators (DGs). Specifically, the TS inventory requirements for stored lube oil (currently specified in number of gallons) would be replaced with inventory requirements based on DG operating time (specified in number of days). The proposed changes are based on Revision 1 to Technical Specifications Task Force (TSTF) Improved Standard Technical Specifications Change Traveler TSTF-501, .. Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control .. (ADAMS Accession No. ML09051 0686).
U.S. Nuclear Regulatory Commission Response to Request for Additional Information TSTF-501-A DG Lube Oil Inventory Requirements August 11, 2016 Page 2 In the Reference 2 e-mail correspondence, the U.S. Nuclear Regulatory Commission (NRC) requested additional information.
Attachment 1 contains Exelon's response to the NRC request for additional information.
Attachment 2 provides a copy of the marked up TS Bases pages that reflect the proposed change (information only). Attachment 2 replaces the TS Bases markups submitted in Reference
- 1. The TS page markups submitted in Reference 1 are not affected by this 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 11 lh day of August 2016. Respectfully, James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Attachments:
- 1. Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request concerning Diesel Generator Lube Oil Inventory Requirements (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3 2. Markup of Proposed Technical Specifications Bases Pages (Information Only) 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 1 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Docket Nos. 5Q-277 and 50-278 Response to Draft Request for Additional Information Regarding the Proposed License Amendment Request concerning Diesel Generator Lube Oil Inventory Requirements (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3 Response to Request for Additional Information TSTF-501-A DG Lube Oil Inventory Requirements Docket Nos. 50-277 and 50-278 Attachment 1 Page 1 of 3 By application dated June 20, 2016, Exelon Generation Company, LLC (Exelon) submitted a license amendment request (LAR) for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The amendments would revise the Technical Specification (TS} 3.8.3, .. Diesel Fuel Oil, Lube Oil, and Starting Air, .. requirements associated with the stored inventory of lube oil for the diesel generators (DGs). Specifically, the TS inventory requirements for stored lube oil (currently specified in number of gallons) would be replaced with inventory requirements based on DG operating time (specified in number of days). The proposed changes are based on Revision 1 to Technical Specifications Task Force (TSTF} Improved Standard Technical Specifications Change Traveler TSTF-501, .. Relocate Stored Fuel Oil and Lube Oil Volume Values to Licensee Control .. (ADAMS Accession No. ML090510686).
The NRC staff has determined that additional information is needed to complete its review. The specific requests for additional information (RAI) questions are restated below along with Exelon*s response.
Question 1 (DORL-RAI-1
): Attachment 3 to the licensee*s application dated June 20, 2016, provided marked up TS Bases pages (for information only) which would be implemented, in accordance with the TS Bases Control Program, as part of the proposed amendment.
The proposed markup for the Bases for TS 3.8.3, Limiting Condition for Operation (LCO), Action B.1 is not consistent with the BWR/4 STS Bases markup included in TSTF-501, Revision 1. Specifically, the licensee did not propose any changes to the first sentence in this section. In addition, TSTF-501, Revision 1, includes changes to the TS Bases for SR 3.8.3.2. The licensee did not propose any Bases changes for PBAPS SR 3.8.3.2. The licensee's application did not identify these differences as proposed deviations to the TSTF. Please provide justifications for these deviations or provide a supplement with proposed TS Bases changes consistent with TSTF-501, Revision 1. Response:
Exelon proposes to revise the TS Bases to be consistent with the BWR/4 STS Bases markup included in TSTF-501, Revision 1. For information, a copy of the revised marked up TS Bases pages that reflect the proposed change are provided in Attachment
- 2. Question 2 (DORL-RAI-2):
The NRC's model safety evaluation for TSTF-501, Revision 1, explains the reason why licensees would want to adopt this TSTF. Specifically, the DG fuel oil numerical volume inventory requirement (in gallons) may need to be modified in order to take into account changes to the energy content (BTU/gallon) of available fuels in the market. Replacing the TS inventory requirements for stored fuel oil in gallons with inventory requirements specified in number of days of DG operating time could allow the licensee to make changes to the required number of gallons under licensee control, and therefore, may not require NRC prior approval.
Since the fuel oil inventory is based on 7 -days of DG operating time, the 7 -day inventory requirement also applies to the DG lube oil supply.
Response to Request for Additional Information TSTF-501-A DG Lube Oil Inventory Requirements Docket Nos. 50-277 and 50-278 Attachment 1 Page 2 of 3 As discussed in the licensee's application, Exelon is only proposing to adopt the TSTF-501 changes pertaining to lube oil (i.e., fuel oil changes are not proposed).
The licensee's application indicated that the technical justifications in the NRC staff's model SE are applicable to the proposed changes to the lube oil requirements for PBAPS. However, given that the model SE focuses on the reasons for potential changes in fuel oil volume requirements, the NRC staff concludes that the model SE is not sufficient to address the reason for changing only the lube oil requirements.
Since the nature of consumption of fuel oil and lube oil are different, it is not clear of the reason for the proposed amendment.
Please provide additional justification for the reasons for the proposed amendment request (e.g., reasons why the number of gallons of lube oil, currently required in the TSs for the 7-day DG operating period, may change). Response:
The diesel generator lubrication system is designed to provide sufficient lubrication to permit proper operation of its associated diesel generator under all loading conditions.
The system is required to circulate the lube oil to the diesel engine working surfaces and to remove excess heat generated by friction during operation.
Each diesel generator has a lube oil inventory capable of supporting a minimum of 7 days of operation.
The stored inventory ensures 7 days of operation with manual replenishment as needed. In order to meet a 7-day supply of stored lube oil for each diesel generator, TS 3.8.3, 11 Diesel Fuel Oil, Lube Oil, and Starting Air, 11 currently contains numerical volume requirements associated with a 7-day supply for each diesel generator.
PBAPS TS Bases currently discuss that the numerical volume requirements are based on meeting a 7-day supply. The proposed change revises TS 3.8.3 by relocating the current stored diesel lube oil numerical volume requirements from the TS to the TS Bases so that it may be modified under licensee control. The TS are modified so that the stored diesel lube oil inventory will require that a 7 -day supply be available for each diesel generator.
Additionally, NRC Information Notice 96-67, 11 Vulnerability of Emergency Diesel Generators to Fuel Oil/Lubricating Oil Incompatibility, II noted that the reduced amount of sulfur in Ultra Low Sulfur Diesel (ULSD) will result in more unreacted additive in the lubricating oil. This may result in the formation of deposits when some of the oil is burned, which may affect the volume of lube oil required to support 7-day operation.
Relocating the specific volume of lube oil equivalent to a 7-day supply to licensee control will allow licensees to adjust the required volume without submitting a license amendment request to the NRC. No changes to the current plant configuration, current numerical volume requirements, or current 7-day basis are proposed in the application; PBAPS proposes to relocate the current numerical volume requirements from the TS to the TS Bases and relocate the associated current 7 -day basis from the TS Bases to the TS. Currently, Condition B is entered when the stored diesel lube oil numerical volume requirements are not met. As discussed in the current TS Bases, the numerical volume requirements in Condition B are based on volumes less than a 7 -day supply, but greater than a 6-day supply. The proposed amendment will relocate the volumetric requirements from the TS and place them in the TS Bases. The TS are modified so that Condition B is entered when the stored diesel lube oil inventory is less than a 7-day supply, but greater than a 6-day supply for one or more diesel generators.
Response to Request for Additional Information TSTF*501-A DG Lube Oil Inventory Requirements Docket Nos. 50-277 and 50-278 Attachment 1 Page 3 of 3 No other parts of Condition B (i.e., Required Actions or Completion Times) are proposed to be modified in the application; PBAPS proposes to relocate the current numerical volume requirements that dictate Condition entry from the TS to the TS Bases and relocate the associated current less than 7 -day but greater than 6-day basis for Condition entry from the TS Bases to the TS. No other parts of the SRs (i.e., Frequencies) are proposed to be modified in the application; PBAPS proposes to relocate the current numerical volume requirement verification from the TS to the TS Bases and relocate the associated current 7-day basis for verification from the TS Bases to the TS. The lube oil inventory equivalent to a ?*day supply, as well as the 6-day supply associated with Condition B, is based on the diesel generator manufacturer's consumption values for the run time of the diesel generator.
The above method still provides assurance that the necessary quality of systems and components are maintained, that facility operation will be within safety limits, and that the LCOs will be met. Therefore, the proposed change to SR 3.8.3.2 is acceptable.
ATIACHMENT2 Markup of Technical Specifications Bases Pages (For Information Only) 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 concerning Diesel Generator Lube Oil Inventory Requirements (TSTF-501-A) for Peach Bottom Atomic Power Station, Units 2 and 3 Unit 2 TS Bases Pages B 3.8-51 B 3.8-53 Unit 3 TS Bases Pages B 3.8-51 B 3.8-53 BASES ACTIONS (continued)
Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 With fuel oil level < 33,000 gal in a storage tank (which includes margin for the unusable volume of oil), the 7 day fuel oil supply for a DG is not available.
However, the Condition is restricted to fuel oil level reductions that maintain at least a 6 day supply (with fuel oil transfer between storage tanks). These circumstances may be caused by events such as: a. Full load operation required for an inadvertent start while at minimum required level; or b. Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.
This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required level prior to declaring the DG inoperable.
This period is acceptable based on the remaining capacity (> 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period. In this condition, the 7 day inventory
< 350 gal , sufficient lube oil to The lube oil inventory equivalent to a 6 day supply is 300 gallons. PBAPS UNIT 2 support 7 day of continuous DG operation at full load not ee available.
However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day su This restriction allows sufficient o aining requisite replacement volume. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration of the required volume prior to declaring the DG inoperable.
This period is acceptable based on the remaining capacity (> 6 days), the low rate of usage, the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period. (continued)
B 3.8-51 Revision No. 114 BASES ACTIONS SURVEILLANCE REQUIREMENTS The lube oil inventory equivalent to a 7 day supply is 350 gallons and is based on PBAPS UNIT 2 .L1 (continued)
Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 the air receiver pressure is restored to the required limit. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration to the required pressure prior to declaring the DG inoperable.
This period is acceptable based on the remaining air start capacity, the fact that most DG starts are accomplished on the first attempt, and the low probability of an event during this brief period. With a Required Action and associated Completion Time of Condition A, B, C, D, or E not met, or the stored diesel fuel oil , 1 ube oil , or starting air subsystem not within limits for reasons other than addressed by Conditions A through E, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable.
SR 3.8.3.1 This SR provides verification that there is an adequate useable inventory of fuel oil in the storage tanks to support each DG's operation of all four DGs for 7 days at the worst case post accident time-dependent load profile. The 7 day period is sufficient time to place both Unit 2 and Unit 3 in a safe shutdown condition and to bring in replenishment fuel from an offsite location.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.8.3.2 This Surveillance ensures that sufficient lubricating oil inventory (combined inventory in the DG lube oil sump, lube oil storage tank, and in a seismically qualified structure) is available to support at least 7 days of full load operation for each DG. 350 §alloA exceeds the DG rna cturer's consumption values for the run time of the ,
inventory of lube oil required by Technical Specifi tions shall be stored in a location which is seismic Class I and is protected against other natural phenomena.
Implicit in this SR is the requirement to verify the B 3.8-53 Revision No. 122 BASES ACTIONS (continued)
Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 With fuel oil level < 33,000 gal in a storage tank (which includes margin for the unusable volume of oil), the 7 day fuel oil supply for a DG is not available.
However, the Condition is restricted to fuel oil level reductions that maintain at least a 6 day supply (with fuel oil transfer between storage tanks). These circumstances may be caused by events such as: a. Full load operation required for an inadvertent start while at minimum required level; or b. Feed and bleed operations that may be necessitated by increasing particulate levels or any number of other oil quality degradations.
This restriction allows sufficient time for obtaining the requisite replacement volume and performing the analyses required prior to addition of the fuel oil to the tank. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered suffic i ent to complete restoration of the required level prior to declaring the DG inoperable.
This period is acceptable based on the remaining capacity (> 6 days), the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period. ,...l_n_t_h.-ls_c_o_n_d-it-io_n_, 1 u oi 1 inventory sufficient 1 ube oi 1 to the7day support days of continuous DG operation at full load The lube oil inventory equivalent to a 6 day supply is 300 gallons. PBAPS UNIT 3 condition ffitt1 not fre available.
However, the Condition is restricted to lube oil volume reductions that maintain at least a 6 day suppl This restriction allows sufficient time for obt *
- g the requisite replacement volume. A perio hours is considered sufficient to complete storation of the required volume prior to declaring the DG inoperable.
This period is acceptable based on the remaining capacity (> 6 days), the low rate of usage, the fact that procedures will be initiated to obtain replenishment, and the low probability of an event during this brief period. (continued)
B 3.8-51 Revision No. 119 BASES ACTIONS SURVEILLANCE REQUIREMENTS The lube oil inventory equivalent to a 7 day supply is 350 gallons and is based on PBAPS UNIT 3 .Ll (continued)
Diesel Fuel Oil, Lube Oil, and Starting Air B 3.8.3 the air receiver pressure is restored to the required limit. A period of 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> is considered sufficient to complete restoration to the required pressure prior to declaring the DG inoperable.
This period is acceptable based on the remaining air start capacity, the fact that most DG starts are accomplished on the first attempt, and the low probability of an event during this brief period. With a Required Action and associated Completion Time of Condition A, B, C, D, or E not met, or the stored diesel fuel oil, lube oil, or starting air subsystem not within limits for reasons other than addressed by Conditions A through E, the associated DG may be incapable of performing its intended function and must be immediately declared inoperable.
SR 3.8.3.1 This SR provides verification that there is an adequate useable inventory of fuel oil in the storage tanks to support each DGis operation of all four DGs for 7 days at the worst case post accident time-dependent load profile. The 7 day period is sufficient time to place both Unit 2 and Unit 3 in a safe shutdown condition and to bring in replenishment fuel from an offsite location.
The Surveillance Frequency is controlled under the Surveillance Frequency Control Program. SR 3.8.3.2 This Surveillance ensures that sufficient lubricating oil inventory (combined inventory in the DG lube oil sump, lube oil storage tank, and in a seismically qualified structure) is available to support at least 7 days of full load operation for each D 350 §alloA requireffieAt exceeds the DG acturerls consumption values for the run time of the , tfie entire inventory of lube oil required by Technical Spe 'fications shall be stored in a location which is seismic Class I and is protected against other natural pheonomena.
Impl *cit in this SR is the requirement to verify the B 3.8-53 Revision No. 124