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| | issue date = 01/25/2019 | | | issue date = 01/25/2019 |
| | title = Secondary Containment LAR Requests for Additional Information | | | title = Secondary Containment LAR Requests for Additional Information |
| | author name = Tobin J C | | | author name = Tobin J |
| | author affiliation = NRC/NRR/DORL/LPLI | | | author affiliation = NRC/NRR/DORL/LPLI |
| | addressee name = Helker D P | | | addressee name = Helker D |
| | addressee affiliation = Exelon Nuclear | | | addressee affiliation = Exelon Nuclear |
| | docket = 05000277, 05000278 | | | docket = 05000277, 05000278 |
| | license number = DPR-044, DPR-056 | | | license number = DPR-044, DPR-056 |
| | contact person = Tobin J C, NRR/DORL/LPLI, 415-2328 | | | contact person = Tobin J, NRR/DORL/LPLI, 415-2328 |
| | case reference number = EPID L-2018-LLA-0284 | | | case reference number = EPID L-2018-LLA-0284 |
| | document type = E-Mail, Request for Additional Information (RAI) | | | document type = E-Mail, Request for Additional Information (RAI) |
Letter Sequence RAI |
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EPID:L-2018-LLA-0284, Package: Summary of October 29, 2018, Public Meeting with Tn Americas LLC to Discuss Pre-Application of Amendment No. 2 to Nuhoms Eos Spent Fuel Storage Systems (Open) |
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MONTHYEARML18309A0552018-10-29029 October 2018, 1 November 2018 Package: Summary of October 29, 2018, Public Meeting with Tn Americas LLC to Discuss Pre-Application of Amendment No. 2 to Nuhoms Eos Spent Fuel Storage Systems Project stage: Request ML18309A0562018-11-0101 November 2018 October 29, 2018, Summary of Public Meeting with Tn Americas LLC to Discuss Pre-Application of Amendment No. 2 to Nuhoms Eos Spent Fuel Storage Systems (W/Enclosure) Project stage: Meeting ML19028A0062019-01-25025 January 2019 Secondary Containment LAR Requests for Additional Information Project stage: RAI 2018-11-01
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Category:E-Mail
MONTHYEARML24002A7132023-12-29029 December 2023 Supplement - Peach Bottom Security Rule Exemption Request ISFSI Docket No. Reference (EPID L-2023-LLE-0032) (Updated) (Email) ML23352A3242023-12-18018 December 2023 Acceptance of Requested Licensing Action Request for Alternative Schedule to Complete Decommissioning Beyond 60 Years of Permanent Cessation of Operations (EPID L- 2023-LLN-0004) ML23331A9112023-11-22022 November 2023 Supplement - Peach Bottom Security Rule Exemption Request ISFSI Docket No. Reference ML23304A0182023-10-30030 October 2023 NRR E-mail Capture - Final RCI - Constellation Energy Generation, LLC - Peach Bottom 2 & 3 - Exemption from Security Rule (L-2023-LLE-0032) ML23264A7992023-09-21021 September 2023 NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC Fleet Request License Amendment Request to Adopt TSTF-580, Revision 1 ML23237B3972023-08-24024 August 2023 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of Alternative Request to Use Updated BWRVIP Guidelines ML23163A2292023-06-12012 June 2023 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of License Amendment Request to Adopt TSTF-580, Revision 1 ML22354A2622022-12-20020 December 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of Request to Use Certain Provisions of the 2019 Edition of the ASME BPV Code, Section XI ML22325A0052022-11-18018 November 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request - Acceptance of License Amendment Request to Adopt TSTF-273-A, Revision 2 ML22200A0782022-07-19019 July 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Fleet Request to Use Honeywell Mururoa V4F1 R Supplied Air Suits ML22118A3312022-04-28028 April 2022 NRR E-mail Capture - Peach Bottom - Formal RAI for Proposed Alternative I5R-14, Revision 1 ML22041B5362022-02-10010 February 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Request for Additional Information Regarding Fleet License Amendment Request to Adopt TSTF-541 ML22024A1852022-01-24024 January 2022 Acceptance for Review of Relief Request Associated with Reactor Pressure Vessel N-16A Nozzle Repair ML22020A0642022-01-13013 January 2022 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative for Repair of Water Level Instrumentation Partial Penetration Nozzles ML21301A0672021-10-28028 October 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of License Amendment Request to Adopt TSTF-541 ML21256A1902021-09-10010 September 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21252A0482021-09-0707 September 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Fleet Alternative Request for Repair of Water Level Instrumentation Partial Penetration Nozzles ML21215A3502021-08-0303 August 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of License Amendment Request to Adopt TSTF-554 ML21154A0142021-05-28028 May 2021 NRR E-mail Capture - Extension of Comment Period for the Exelon Generation Company, LLC License Transfer Application ML21154A0132021-05-28028 May 2021 NRR E-mail Capture - Extension of Comment Period for the Exelon Generation Company, LLC License Transfer Application ML21154A0112021-05-28028 May 2021 NRR E-mail Capture - Extension of Comment Period for the Exelon Generation Company, LLC License Transfer Application ML21144A2132021-05-24024 May 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21134A0152021-05-14014 May 2021 Acceptance Ventilation Filter Testing LAR ML21117A0442021-04-26026 April 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting ML21084A2532021-03-24024 March 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of License Transfer Application ML21062A0652021-03-0101 March 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting ML21049A2572021-02-18018 February 2021 Request for Additional Information Byron/Dresden Proposed Changes to Site Emergency Plans to Support Post-Shutdown and Permanently Defueled Conditions (EPID-2020-LLA-0240 & EPID-2020-LLA-0237) ML21091A1782021-02-0202 February 2021 Ti 2515/194 Inspection Documentation Request ML21033A8552021-02-0202 February 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Fleet Alternative Request to Expand the Use ASME Codes Cases N-878 and N-880 ML21012A1302021-01-12012 January 2021 Request for Additional Information - TSTF-505 ML20357A0972020-12-21021 December 2020 Request for Additional Information - TSTF-505 ML20350B5582020-12-14014 December 2020 NRR E-mail Capture - Exelon Generation Company, LLC -Alternative Request for Documentation of Replacement of Pressure Retaining Bolting ML20343A3492020-12-0707 December 2020 Acceptance of Requested Licensing Action: Peach Bottom Relief Request for N-16 Nozzle ML20324A6472020-11-19019 November 2020 Acceptance of Requested Licensing Action: Peach Bottom One-time Exemption App. B Sect. VI.C.3.(I)(1) Force on Force (COVID-19) ML20314A0282020-11-0606 November 2020 Verbal Relief for Penetration Nozzle ML20283A7722020-10-0909 October 2020 Submittal of Pennsylvania Letter Requesting Exemption from Biennial Exercise Requirements for Pennsylvania Nuclear Power Plants in Calendar Year 2020 ML20276A0762020-10-0202 October 2020 Acceptance of Requested Licensing Action, One-Time Acceptance for Review - Peach Bottom of Exemption from 10 CFR 50, Appendix E, Biennial Emergency Preparedness Exercise Requirements Due to COVID-19 Pandemic ML20266G3032020-09-22022 September 2020 NRR E-mail Capture - Exelon Generation Company, LLC - Fleet Request to Use Paragraph IWA-5120 of the 2017 Edition of the ASME B&PV Code, Section XI ML20239A7982020-08-25025 August 2020 NRR E-mail Capture - Exelon Generation Company, LLC - Fleet License Amendment Request to Adopt TSTF-568, Revision 2 ML20217L3462020-08-0404 August 2020 Audit Plan Regarding License Amendment Request to Implement Riskinformed Extended Completion Times (L-2020-LLA-0120) ML20191A0182020-07-0101 July 2020 NRR E-mail Capture - Exelon Fleet RR for SPI for Appendix J Valves ML20178A1392020-06-26026 June 2020 Acceptance Review for Peach Bottom - License Amendment Request for TSTF-505 ML20153A7042020-06-0101 June 2020 NRR E-mail Capture - Preliminary RAI for Fleet Request to Use Alternative OMN-26 ML20149K4312020-05-22022 May 2020 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of License Amendment Request to Adopt TSTF-566 ML20135H1972020-05-14014 May 2020 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Request to Extend Safety Relief Valve Test Interval ML20122A2302020-05-0101 May 2020 NRR E-mail Capture - Exelon Generation Company, LLC - Acceptance of Fleet License Amendment Request to Adopt TSTF-566 ML20077F6112020-03-16016 March 2020 E-mail: the U.S. Nuclear Regulatory Commission'S Record of Decision Regarding Exelon'S Subsequent License Renewal Application for Peach Bottom Atomic Power Station Units 2 and 3 ML20070R2282020-03-10010 March 2020 Request for Additional Information - RR ML20063G1362020-02-27027 February 2020 NRR E-mail Capture - Exelon Generation Company, LLC -Acceptance of Proposed Alternative to Extend Safety Relief Valve Test Frequency (EPIDs L-2020-LLR-0014 Through L-2020-LLR-0018) ML20057E5562020-02-26026 February 2020 Availability of the Final Supplemental Environmental Impact Statement for Subsequent License Renewal of Peach Bottom Atomic Power Station, Units 2 and 3 2023-09-21
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARIR 05000277/20244012023-10-0505 October 2023 Information Request for the Cybersecurity Baseline Inspection, Notification to Perform Inspection 05000277/2024401 and 05000278/2024401 ML23264A7992023-09-21021 September 2023 NRR E-mail Capture - Final RAI - Constellation Energy Generation, LLC Fleet Request License Amendment Request to Adopt TSTF-580, Revision 1 ML22118A3312022-04-28028 April 2022 NRR E-mail Capture - Peach Bottom - Formal RAI for Proposed Alternative I5R-14, Revision 1 ML22041B5362022-02-10010 February 2022 NRR E-mail Capture - Constellation Energy Generation, LLC - Request for Additional Information Regarding Fleet License Amendment Request to Adopt TSTF-541 ML22021A5692022-01-21021 January 2022 Information Request for the Cyber Security Baseline Inspection, Notification to Perform Inspection 05000277/2022403 and 05000278/2022403 ML22020A0642022-01-13013 January 2022 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative for Repair of Water Level Instrumentation Partial Penetration Nozzles ML21256A1902021-09-10010 September 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21144A2132021-05-24024 May 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21062A0652021-03-0101 March 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Proposed Fleet Alternative to Documentation Requirements for Pressure Retaining Bolting ML21049A2572021-02-18018 February 2021 Request for Additional Information Byron/Dresden Proposed Changes to Site Emergency Plans to Support Post-Shutdown and Permanently Defueled Conditions (EPID-2020-LLA-0240 & EPID-2020-LLA-0237) ML21035A2222021-02-0404 February 2021 Notification of Conduct of a Fire Protection Team Inspection ML21091A1782021-02-0202 February 2021 Ti 2515/194 Inspection Documentation Request ML21012A1302021-01-12012 January 2021 Request for Additional Information - TSTF-505 ML20357A0972020-12-21021 December 2020 Request for Additional Information - TSTF-505 ML20296A3342020-10-21021 October 2020 ISI Remote Inspection - Supplemental Request for Information ML20239A7982020-08-25025 August 2020 NRR E-mail Capture - Exelon Generation Company, LLC - Fleet License Amendment Request to Adopt TSTF-568, Revision 2 ML20153A7042020-06-0101 June 2020 NRR E-mail Capture - Preliminary RAI for Fleet Request to Use Alternative OMN-26 ML20135H1972020-05-14014 May 2020 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding Request to Extend Safety Relief Valve Test Interval ML20070R2282020-03-10010 March 2020 Request for Additional Information - RR ML19303D1662019-10-31031 October 2019 Requests for Additional Information for the Environmental Review of the Peach Bottom Subsequent License Renewal Application - Set 2 (EPID No. L-2018-RNW-0013)- RAIs ML19232A1752019-08-20020 August 2019 Request for Additional Information - TSTF-500 Implementation LAR ML19140A2832019-05-15015 May 2019 Email - Peach Bottom Atomic Power Station, Units 2 and 3 Second Round RAI Request - Set 1 ML19140A2822019-05-15015 May 2019 027 Pb FU RAI Subsequent to Clarification Call - Cu Greater than 15 Zn Holston (Jg) ML19253D2932019-05-0707 May 2019 002 Attachment 4D Confirmation Water Chemistry Chereskin Revised (002) ML19249C7252019-05-0303 May 2019 SLRA Requests for Additional Information - Set 2 May 3, 2019 ML19108A4282019-04-10010 April 2019 RAIs SLRA Set 1_ERO(Rev 1) ML19079A0232019-03-19019 March 2019 Licensed Operator Positive Fitness-For-Duty Test ML19058A2902019-02-27027 February 2019 Request for Additional Information - High Pressure Service Water One Time TS Change ML19037A4832019-02-0606 February 2019 NRR E-mail Capture - Clarification Questions Associated with Staff Assessment of Peach Bottom Seismic Probabilistic Risk Assessment Report Dated August 28, 2018 ML19028A0062019-01-25025 January 2019 Secondary Containment LAR Requests for Additional Information ML19017A0472019-01-16016 January 2019 Request for Additional Information - High Pressure Service Water One Time TS Change ML18348B0292018-12-13013 December 2018 Subsequent License Renewal Severe Accident Mitigation Alternatives Requests for Additional Information ML19010A3832018-12-0707 December 2018 Additional Documents Needed for Peach Bottom SLR Environmental Review ML18324A6742018-11-15015 November 2018 Request for Additional Information (FINAL)- LAR to Allow 2SRV/SVs OOS at High Pressure ML18312A4072018-11-0808 November 2018 Request for Additional Information (Public) - LAR to Allow 2SRV/SVs OOS at High Pressure ML18276A0202018-10-0202 October 2018 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Amendment Request to Revise Emergency Plan for Limerick and Peach Bottom ML18240A1742018-08-28028 August 2018 Request for Additional Information (Final) - Adopt TSTF-500 Battery TS Changes LAR ML18239A1322018-08-27027 August 2018 Request for Additional Information Final - Relief Request I5R-04 ML18228A6762018-08-14014 August 2018 Request for Additional Information - Adopt TSTF-500 Battery TS Changes LAR ML18226A2012018-08-14014 August 2018 Request for Additional Information - Relief Request I5R-05 ML18214A2812018-08-0202 August 2018 Request for Additional Information Draft - Relief Request I5R-02 ML18200A2742018-07-17017 July 2018 Request for Additional Information 2nd Round (Final) - Adopt 50.69 License Amendment ML18192A1192018-07-10010 July 2018 Request for Additional Information 2nd Round (Final) - Adopt 50.69 License Amendment ML18178A4772018-06-27027 June 2018 Request for Additional Information 2nd Round - Adopt 50.69 License Amendment ML18096B5062018-04-0606 April 2018 Request for Additional Information Exelon Generation Company, LLC Requested Amendment to Adopt 10 CFR 50.69 for Risk-informed Categorization and Treatment of Structures, Systems and Components ML18094B0832018-04-0505 April 2018 Enclosurequest for Additional Information (Letter to P. Duke RAI Regarding Entergy Operations, Inc.'S Decommissioning Funding Plan Update for Salem and Hope Creek, and Peach Bottom ISFSIs Docket Nos. 72-48 and 72-29) ML18067A1482018-03-0808 March 2018 Enclosurequest for Additional Information (Letter to P. R. Simpson Request for Additional Information Regarding Exelon Generating Company, Llc'S Decommissioning Funding Plan Update for Independent Spent Fuel Storage Installation) ML17317B5502017-11-0909 November 2017 Licensed Operator Positive Fitness-For-Duty Test ML17240A0062017-08-24024 August 2017 Request for Additional Information Regarding License Amendment Request for Measurement Uncertainty Recapture Power Uprate ML17222A0962017-08-10010 August 2017 Request for Additional Information - Amendment Request Regarding Safety Relief Valve and Safety Valce Operability for Cycle 22 2023-09-21
[Table view] |
Text
From: Tobin, Jennifer To: "Helker, David P:(GenCo-Nuc)" Cc: "Gropp Jr, Richard W:(GenCo-Nuc)"
Subject:
Peach Bottom Units 2 and 3 - Request for Additional Information - Secondary Containment LAR (EPID L-2018-LLA-0264)Date: Friday, January 25, 2019 4:58:00 PM
Dear Mr. Helker,
By letter dated September 27, 2018 (Accession No. ML18271A009), Exelon Generation Company, LLC requested to change technical specifications for Peach Bottom Atomic Power Station Units 2 and 3.
The proposed change would modify TSs to help alleviate scheduling difficulties associated with reactor building and refueling floor ventilation system. The Nuclear Regulatory Commission's (NRC) staff is reviewing your submittal and has determined that additional information is needed to complete its review.
The specific request for additional information (RAI) questions are provided below.
These questions are being sent to ensure that the questions are understandable, the regulatory basis for the questions is clear, and to determine if the information was previously docketed.
A clarification phone call to discuss the draft RAIs was held January 24, 2019, and both RAIs were clarified as a result of the call.
A 30-day response time was agreed upon so please provide your response to the RAIs by February 25, 2019.
If you have any questions, please contact me at (301) 415-2328.
A copy of this email will be made publicly available in ADAMS.
Thanks, Jenny Jenny Tobin Project Manager NRR/DORL/LPL-1 Office O9-C12 Phone 301-415-2328 REQUEST FOR ADDITIONAL INFORMATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION FOR A LICENSE AMENDMENT REQUEST TO REVISE THE APPLICABILITY OF FUNCTIONS 3 AND 4 IN TECHNICAL SPECIFICATIONS 3.3.6.2 EXELON GENERATION COMPANY LLC PEACH BOTTOM ATOMIC POWER STATION UNITS 2 AND 3 DOCKET NUMBERS 50-277 AND 50-278 ENTERPRISE PROJECT IDENTIFIER L-2018-LLA-0264 By letter dated September 27, 2018, Exelon Generation Company LLC, the licensee, proposes to change technical specifications for Peach Bottom Atomic Power Station Units 2 and 3 (Peach Bottom).
The proposed change would modify the applicability for technical specifications 3.3.6.2, functions 3 and 4.
Specifically, function 3 (reactor building ventilation exhaust radiation - high) would be revised to only be required when function 4 (refueling floor ventilation exhaust radiation - high) is not maintained, and function 4 would be revised to only be required when function 3 is not maintained.
Additionally, this change clarifies which standby gas treatment (SGT) subsystems are required to be put into operation or declared inoperable as described in TS 3.3.6.2 condition C for required actions C.2.1 and C.2.2. During the Nuclear Regulatory Commission (NRC) staff's review of the license amendment request, the NRC staff determined that more information was needed to complete the review. Title 10 of the Code of Federal Regulations (10 CFR) Part 50.67, "Accident Source Term,"
allows licensees seeking to revise their current accident source term in design basis radiological consequence analyses to apply for a license amendment under § 50.90.
The application shall contain an evaluation of the consequences of applicable design basis accidents previously analyzed in the safety analysis report.
Section 50.67(b)(2) requires that the licensee's analysis demonstrates with reasonable assurance that: (i)
An individual located at any point on the boundary of the exclusion area for any 2-hour period following the onset of the postulated fission product release, would not receive a radiation dose in excess of 0.25 Sv (25 rem) total effective dose equivalent (TEDE).(ii)
An individual located at any point on the outer boundary of the low population zone, who is exposed to the radioactive cloud resulting from the postulated fission product release (during the entire period of its passage), would not receive a radiation dose in excess of 0.25 Sv (25 rem) TEDE.(iii)
Adequate radiation protection is provided to permit access to and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 0.05 Sv (5 rem)
TEDE for the duration of the accident.
10 CFR 50.36, "Technical Specifications," in part, requires that the technical specifications be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto and includes items in following categories: (1) safety limits, limiting safety systems settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; (5) administrative controls; (6) decommissioning; (7) initial notifications; and (8) written reports.
In the license amendment request the licensee determined that it is acceptable to revise TS 3.3.6.2 functions 3 and 4 applicability as described above in section 2.0 as long as the refuel floor hatch plug remains removed and no other physical obstruction seals the air flow path between the refuel floor and the reactor building.
The licensee stated that the absence of the refuel floor hatch cover allows air flow in the spaces between the reactor building and the refuel floor and that for a design basis accident where excessive radioactive material is released into secondary containment, airborne radioactivity will be drawn down and detected at either the refuel floor exhaust radiation monitors or the reactor building exhaust radiation monitors (whichever set is not isolated) to provide a valid secondary containment isolation signal.
The NRC staff agrees that the reactor building and refuel floor air spaces allow air flow when the refuel floor hatch plug is removed.
While in this condition, both the refuel floor ventilation exhaust radiation monitor and reactor building ventilation exhaust radiation monitor are able to generate a high radiation secondary containment isolation signal if there is a mechanism to ensure mixing between the reactor building and refuel floor.
However, the license amendment request did not discuss if there is a mechanism available in all conditions i.e., normal operations and during a loss of offsite power, to ensure mixing between the reactor building and refuel floor air spaces.
The licensee proposed the addition of footnote (c) to the applicability for TS 3.3.6.2 function 3, Reactor Building Ventilation Exhaust Radiation - High , and footnote (d) to the applicability for TS 3.3.6.2 function 4, Refueling Floor Ventilation Exhaust Radiation - High
. Footnote (c) would state:
Function is only applicable if Function 4 isolation capability is not maintained.
Footnote (d) would state:
Function is only applicable if Function 3 isolation capability is not maintained.
The NRC staff reviewed the proposed TS wording to ensure that the allowance of reducing the required functions to either the reactor building ventilation exhaust radiation function or the refuel floor ventilation exhaust radiation function is only allowed when the refuel floor plug is removed.
The proposed TS wording doesn't appear to be limited to when the refuel floor plug is removed and seems to allow reducing the required functions even if the refuel floor plug is installed.
Additionally, the proposed footnotes are worded such that neither function is required by TS 3.3.6.2 during their applicable modes or other specified conditions if isolation capability is maintained.
The proposed footnotes seem to essentially negate the requirements for the functions in modes 1, 2, 3 and during movement of recently irradiated fuel assemblies in secondary containment when isolation capability is maintained for both functions.
Because the proposed change to TS 3.3.6.2 is not limited to when the refuel floor plug is removed and essentially seems to negate the function 3 and 4 requirements when isolation capability is maintained for both functions, a revision to the proposed TS change is necessary or a technical evaluation discussing these aspects is needed.
RAI-1 Provide a discussion that explains if there is a mixing mechanism available during all conditions assumed in the licensing basis (i.e., normal operations, during a loss of offsite power, etc.), to ensure mixing between the reactor building and refuel floor air spaces.
In addition, discuss any impacts on the current licensing basis that may result from the mixing and transporting mechanisms with respect to the detector response times for the refuel floor ventilation exhaust and reactor building ventilation exhaust radiation detectors.
This clarification applies to response time delay when the radiation monitor in that affected area is not available and the radiation monitor in the other area is in operation.
RAI-2 Provide a revision to the proposed TS 3.3.6.2 footnotes such that the footnote is: (1) dependent on the refuel floor hatch plug being removed, and (2) identifies that at least one function must be operable during their applicable modes or other specified conditions, either the reactor building ventilation exhaust radiation instrumentation or the refueling floor ventilation exhaust radiation instrumentation, or, Provide a technical basis for removing these functions from TS 3.3.6.2.