|
|
Line 21: |
Line 21: |
|
| |
|
| ==Subject:== | | ==Subject:== |
|
| |
| Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRG Docket Nos. 50-277 and 50-278 Peach Bottom Atomic Power Station, Units 2 and 3 Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 | | Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRG Docket Nos. 50-277 and 50-278 Peach Bottom Atomic Power Station, Units 2 and 3 Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 |
|
| |
|
| ==References:== | | ==References:== |
|
| |
|
| (1) Letter from D. P. Helker (Exelon Generation | | (1) Letter from D. P. Helker (Exelon Generation Company, LLC) to U.S. NRG, "Application to Revise Technical Specifications to Adopt TSTF-523, 'Generic Letter 2008-01, Managing Gas Accumulation,' |
| : Company, LLC) to U.S. NRG, "Application to Revise Technical Specifications to Adopt TSTF-523,
| | Revision 2, using the Consolidated Line Item Improvement Process," dated July 10, 2014 (ML14191B190) |
| 'Generic Letter 2008-01, Managing Gas Accumulation,' | | (2) Memorandum from A. B. Ennis (U.S. Nuclear Regulatory Commission) to D. A. Broaddus (U.S. Nuclear Regulatory Commission), "Peach Bottom Atomic Power Station, Units 2 and 3, Draft Request for Additional Information (TAC NOS. MF4410 AND MF4411 )" dated February 24, 2015 (ML 15056A046) |
| Revision 2, using the Consolidated Line Item Improvement Process," | | By letter dated July 10, 2014 (Reference 1), Exelon Generation Company, LLC (Exelon), requested an amendment to the Technical Specifications (TS) for Peach Bottom Atomic Power Station, Units 2 and 3 (PBAPS) to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," as described in TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation." The U.S. Nuclear Regulatory Commission (USNRC) staff has been reviewing the Reference 1 submittal and has determined that additional information is needed to complete the review. The USNRC staff requested additional information on February 24, 2015 (Reference 2). Exelon's response to the USNRC request is provided in the Attachment to this letter. Exelon has determined that the information provided in response to this request for additional information does not impact the conclusions of the No Significant Hazards Consideration or Environmental Consideration as stated in Reference |
| dated July 10, 2014 (ML14191B190) | |
| (2) Memorandum from A. B. Ennis (U.S. Nuclear Regulatory Commission) to D. A. Broaddus (U.S. Nuclear Regulatory Commission), | |
| "Peach Bottom Atomic Power Station, Units 2 and 3, Draft Request for Additional Information (TAC NOS. MF4410 AND MF4411 )" dated February 24, 2015 (ML 15056A046) | |
| By letter dated July 10, 2014 (Reference 1), Exelon Generation | |
| : Company, LLC (Exelon),
| |
| requested an amendment to the Technical Specifications (TS) for Peach Bottom Atomic Power Station, Units 2 and 3 (PBAPS) to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," | |
| as described in TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation." | |
| The U.S. Nuclear Regulatory Commission (USNRC) staff has been reviewing the Reference 1 submittal and has determined that additional information is needed to complete the review. The USNRC staff requested additional information on February 24, 2015 (Reference 2). Exelon's response to the USNRC request is provided in the Attachment to this letter. Exelon has determined that the information provided in response to this request for additional information does not impact the conclusions of the No Significant Hazards Consideration or Environmental Consideration as stated in Reference | |
| : 1. There are no regulatory commitments contained in this submittal. | | : 1. There are no regulatory commitments contained in this submittal. |
| U.S. Nuclear Regulatory Commission March 23, 2015 Page2 In accordance with 1 O CFR 50.91, "Notice for public comment; State consultation," | | U.S. Nuclear Regulatory Commission March 23, 2015 Page2 In accordance with 1 O CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the Commonwealth of Pennsylvania of this response by transmitting a copy of this letter and its attachment to the designated State Official. |
| paragraph (b), Exelon is notifying the Commonwealth of Pennsylvania of this response by transmitting a copy of this letter and its attachment to the designated State Official. | |
| Should you have any questions concerning this letter, please contact Ms. Wendy E. Croft at (610) 765-5726. | | Should you have any questions concerning this letter, please contact Ms. Wendy E. Croft at (610) 765-5726. |
| I declare under penalty of perjury that the foregoing is true and correct. | | I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd day of March, 2015. Respectfully, David P. Helker Manager -Licensing and Regulatory Affairs Exelon Generation Company, LLC |
| Executed on the 23rd day of March, 2015. Respectfully, David P. Helker Manager -Licensing and Regulatory Affairs Exelon Generation | |
| : Company, LLC
| |
|
| |
|
| ==Attachment:== | | ==Attachment:== |
|
| |
|
| Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 cc: USNRC Region I, Regional Administrator USNRC Project Manager, PBAPS USNRC Senior Resident Inspector, PBAPS Director, Bureau of Radiation Protection, PA Department of Environmental Resources R.R. Janati, Commonwealth of Pennsylvania S. T. Gray, State of Maryland ATTACHMENT Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Attachment March 23, 2015 Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 By letter dated July 10, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14191B190), | | Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 cc: USNRC Region I, Regional Administrator USNRC Project Manager, PBAPS USNRC Senior Resident Inspector, PBAPS Director, Bureau of Radiation Protection, PA Department of Environmental Resources R.R. Janati, Commonwealth of Pennsylvania S. T. Gray, State of Maryland ATTACHMENT Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Attachment March 23, 2015 Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 By letter dated July 10, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14191B190), Exelon Generation Company, LLC (Exelon, the licensee) submitted a license amendment request for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The proposed amendment would revise Technical Specification (TS) requirements to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," in accordance with TS Task Force (TSTF) Traveler TSTF-523, Revision 2. USNRC Question 1. As discussed on page 2 of Attachment 1 to the application dated July 10, 2014, the licensee stated that the high pressure service water (HPSW) system components have been determined to not be required to be in the scope of a number of the surveillance requirements (SRs) due to operating experience and the design of the system. a) Please describe the operating experience that justifies excluding the HPSW system from the scope of the SRs. b) Please provide a descripti<;m of the HPSW design in sufficient detail such that the NRC staff can independently assess the potential that gas accumulation could affect operability. |
| Exelon Generation | |
| : Company, LLC (Exelon, the licensee) submitted a license amendment request for Peach Bottom Atomic Power Station (PBAPS),
| |
| Units 2 and 3. The proposed amendment would revise Technical Specification (TS) requirements to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," | |
| in accordance with TS Task Force (TSTF) Traveler TSTF-523, Revision | |
| : 2. USNRC Question
| |
| : 1. As discussed on page 2 of Attachment 1 to the application dated July 10, 2014, the licensee stated that the high pressure service water (HPSW) system components have been determined to not be required to be in the scope of a number of the surveillance requirements (SRs) due to operating experience and the design of the system. a) Please describe the operating experience that justifies excluding the HPSW system from the scope of the SRs. b) Please provide a descripti<;m of the HPSW design in sufficient detail such that the NRC staff can independently assess the potential that gas accumulation could affect operability.
| |
| PBAPS Response to 1.a PBAPS, Units 2 and 3 has been in operation in excess of 40 years. The HPSW pumps are functionally tested in accordance with the In-Service Testing and Surveillance Testing Programs. | | PBAPS Response to 1.a PBAPS, Units 2 and 3 has been in operation in excess of 40 years. The HPSW pumps are functionally tested in accordance with the In-Service Testing and Surveillance Testing Programs. |
| The HPSW System provides cooling water to the Residual Heat Removal (AHR) heat exchangers. | | The HPSW System provides cooling water to the Residual Heat Removal (AHR) heat exchangers. |
| The thermal performance of the AHR heat exchangers is periodically verified in accordance with the Station Generic Letter 89-13 Program with no abnormal performance observed indicative of air voiding. | | The thermal performance of the AHR heat exchangers is periodically verified in accordance with the Station Generic Letter 89-13 Program with no abnormal performance observed indicative of air voiding. PBAPS performed a Technical Evaluation that concluded that testing for voided areas in the HPSW System is not warranted due to the system design, as described below in the response to USNRC Question 1.b. Additionally, the scope of both Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," and TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation" do not include HPSW, or any other service water systems. For example, the TSTF-523, Section 2.3 list of affected TS Sections for NUREG-1433 (BWR/4) does not include TS Section 3.7.1, "Residual Heat Removal Service Water," which is the equivalent of PBAPS's TS Section 3.7.1 for the HPSW System. Page 1 of 2 Attachment March 23, 2015 Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 PBAPS Response to 1.b The HPSW System is used during power operations to supply cooling water to the AHR System for torus cooling, and to provide a reliable supply of cooling water for the AHR System under shutdown and post-accident conditions. |
| PBAPS performed a Technical Evaluation that concluded that testing for voided areas in the HPSW System is not warranted due to the system design, as described below in the response to USNRC Question 1.b. Additionally, the scope of both Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," | |
| and TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation" do not include HPSW, or any other service water systems. | |
| For example, the TSTF-523, Section 2.3 list of affected TS Sections for NUREG-1433 (BWR/4) does not include TS Section 3.7.1, "Residual Heat Removal Service Water," which is the equivalent of PBAPS's TS Section 3.7.1 for the HPSW System. Page 1 of 2 Attachment March 23, 2015 Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 PBAPS Response to 1.b The HPSW System is used during power operations to supply cooling water to the AHR System for torus cooling, and to provide a reliable supply of cooling water for the AHR System under shutdown and post-accident conditions. | |
| The HPSW System is a safety-related, open-loop, cooling water system. A separate HPSW System serves each of PBAPS's two Units. Each Unit has four HPSW pumps separated into two subsystems with two pumps each. The HPSW pumps take suction from the Conowingo Pond through the Service Water Pump Bay, provide cooling water flow to the AHR heat exchangers, and discharge through a common pipe for each Unit to the Discharge Pond. The majority of HPSW piping is located below the ground elevation of the site. The RHR heat exchanger HPSW motor operated discharge valves are normally in the closed position. | | The HPSW System is a safety-related, open-loop, cooling water system. A separate HPSW System serves each of PBAPS's two Units. Each Unit has four HPSW pumps separated into two subsystems with two pumps each. The HPSW pumps take suction from the Conowingo Pond through the Service Water Pump Bay, provide cooling water flow to the AHR heat exchangers, and discharge through a common pipe for each Unit to the Discharge Pond. The majority of HPSW piping is located below the ground elevation of the site. The RHR heat exchanger HPSW motor operated discharge valves are normally in the closed position. |
| The first pump of the HPSW system is placed into service by opening the selected AHR heat exchanger HPSW motor operated discharge valve and then starting the HPSW pump. The system is secured and restored to standby by shutting down the HPSW pump and then closing the discharge valve. The HPSW System is an open-loop cooling water system and it is not designed to be water solid. Page 2 of 2}} | | The first pump of the HPSW system is placed into service by opening the selected AHR heat exchanger HPSW motor operated discharge valve and then starting the HPSW pump. The system is secured and restored to standby by shutting down the HPSW pump and then closing the discharge valve. The HPSW System is an open-loop cooling water system and it is not designed to be water solid. Page 2 of 2}} |
Letter Sequence Response to RAI |
---|
TAC:MF4410, Implement 10 CFR 50, Appendix J, Option B, Generic Letter 2008-01, Managing Gas Accumulation, TSTF-5 (Approved, Closed) |
|
MONTHYEARML14191B1902014-07-10010 July 2014 Application to Revise Technical Specifications to Adopt TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation, Revision 2, Using the Consolidated Line Item Improvement Process Project stage: Request ML14219A6622014-08-0707 August 2014 Acceptance Review for TACs MF4410 & MF4411 - Peach Bottom, Units 2 and 3 - TSTF-523, Generic Letter 2008-01 - Managing Gas Accumulation Project stage: Acceptance Review ML15056A0462015-02-24024 February 2015 Draft Request for Additional Information Project stage: Draft RAI ML15082A2552015-03-23023 March 2015 Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 Project stage: Response to RAI ML15154A6142015-06-30030 June 2015 Issuance of Amendments Adoption of Technical Specification Task Force (TSTF) Traveler TSTF-523, Generic Letter 2008-01, Managing Gas Accumulation Project stage: Approval 2015-02-24
[Table View] |
|
---|
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: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:Amendment
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 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 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 ML18172A2832018-06-21021 June 2018 Emergency License Amendment Request - One-Time Change Suspending Emergency Diesel Generator Surveillance Test Completion Requirements 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 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 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 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 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 ML0719701642007-07-12012 July 2007 Tech Spec Pages for Amendment 265 Risk-Informed Modification to Selected Required End States RS-06-181, Byron, Dresden, LaSalle, Peach Bottom, and Quad Cities Nuclear Plants, Request for Technical Specification Change to Provide Consistency with EGC Quality Assurance Topical Report2006-12-15015 December 2006 Byron, Dresden, LaSalle, Peach Bottom, and Quad Cities Nuclear Plants, Request for Technical Specification Change to Provide Consistency with EGC Quality Assurance Topical Report ML0634102932006-11-17017 November 2006 License Amendment Request Revise Local Power Range Monitor Calibration Frequency ML0535601852005-12-21021 December 2005 License Amendment Request, Incorporation of Previously NRC-Approved Generic Technical Specification Changes - Submittal of Camera Ready Technical Specification Pages RS-04-125, Exelon/Amergen Request for Amendment to Technical Specifications Administrative Controls to Incorporate Requirement for Control Room Envelope Integrity Program2004-11-29029 November 2004 Exelon/Amergen Request for Amendment to Technical Specifications Administrative Controls to Incorporate Requirement for Control Room Envelope Integrity Program RS-04-067, Amergen, Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process2004-04-30030 April 2004 Amergen, Request for Amendment to Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process ML0320304722003-07-14014 July 2003 Request for License Amendments Related to Application of Alternative Source Term ML0234505702002-11-27027 November 2002 Request for Technical Specifications Change to Eliminate Requirements for Post Accident Sampling System Using the Consolidated Line Item Improvement Process ML0214801832002-05-23023 May 2002 Revised TS Pages Extending Delay Period, Before Entering Limiting Condition for Operation, Following Missed Surveillance 2023-05-25
[Table view] |
Text
10 CFR 50.90 March 23, 2015 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001
Subject:
Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRG Docket Nos. 50-277 and 50-278 Peach Bottom Atomic Power Station, Units 2 and 3 Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523
References:
(1) Letter from D. P. Helker (Exelon Generation Company, LLC) to U.S. NRG, "Application to Revise Technical Specifications to Adopt TSTF-523, 'Generic Letter 2008-01, Managing Gas Accumulation,'
Revision 2, using the Consolidated Line Item Improvement Process," dated July 10, 2014 (ML14191B190)
(2) Memorandum from A. B. Ennis (U.S. Nuclear Regulatory Commission) to D. A. Broaddus (U.S. Nuclear Regulatory Commission), "Peach Bottom Atomic Power Station, Units 2 and 3, Draft Request for Additional Information (TAC NOS. MF4410 AND MF4411 )" dated February 24, 2015 (ML 15056A046)
By letter dated July 10, 2014 (Reference 1), Exelon Generation Company, LLC (Exelon), requested an amendment to the Technical Specifications (TS) for Peach Bottom Atomic Power Station, Units 2 and 3 (PBAPS) to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," as described in TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation." The U.S. Nuclear Regulatory Commission (USNRC) staff has been reviewing the Reference 1 submittal and has determined that additional information is needed to complete the review. The USNRC staff requested additional information on February 24, 2015 (Reference 2). Exelon's response to the USNRC request is provided in the Attachment to this letter. Exelon has determined that the information provided in response to this request for additional information does not impact the conclusions of the No Significant Hazards Consideration or Environmental Consideration as stated in Reference
- 1. There are no regulatory commitments contained in this submittal.
U.S. Nuclear Regulatory Commission March 23, 2015 Page2 In accordance with 1 O CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the Commonwealth of Pennsylvania of this response by transmitting a copy of this letter and its attachment to the designated State Official.
Should you have any questions concerning this letter, please contact Ms. Wendy E. Croft at (610) 765-5726.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd day of March, 2015. Respectfully, David P. Helker Manager -Licensing and Regulatory Affairs Exelon Generation Company, LLC
Attachment:
Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 cc: USNRC Region I, Regional Administrator USNRC Project Manager, PBAPS USNRC Senior Resident Inspector, PBAPS Director, Bureau of Radiation Protection, PA Department of Environmental Resources R.R. Janati, Commonwealth of Pennsylvania S. T. Gray, State of Maryland ATTACHMENT Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 Attachment March 23, 2015 Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 By letter dated July 10, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14191B190), Exelon Generation Company, LLC (Exelon, the licensee) submitted a license amendment request for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The proposed amendment would revise Technical Specification (TS) requirements to address Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," in accordance with TS Task Force (TSTF) Traveler TSTF-523, Revision 2. USNRC Question 1. As discussed on page 2 of Attachment 1 to the application dated July 10, 2014, the licensee stated that the high pressure service water (HPSW) system components have been determined to not be required to be in the scope of a number of the surveillance requirements (SRs) due to operating experience and the design of the system. a) Please describe the operating experience that justifies excluding the HPSW system from the scope of the SRs. b) Please provide a descripti<;m of the HPSW design in sufficient detail such that the NRC staff can independently assess the potential that gas accumulation could affect operability.
PBAPS Response to 1.a PBAPS, Units 2 and 3 has been in operation in excess of 40 years. The HPSW pumps are functionally tested in accordance with the In-Service Testing and Surveillance Testing Programs.
The HPSW System provides cooling water to the Residual Heat Removal (AHR) heat exchangers.
The thermal performance of the AHR heat exchangers is periodically verified in accordance with the Station Generic Letter 89-13 Program with no abnormal performance observed indicative of air voiding. PBAPS performed a Technical Evaluation that concluded that testing for voided areas in the HPSW System is not warranted due to the system design, as described below in the response to USNRC Question 1.b. Additionally, the scope of both Generic Letter 2008-01, "Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems," and TSTF-523, Revision 2, "Generic Letter 2008-01, Managing Gas Accumulation" do not include HPSW, or any other service water systems. For example, the TSTF-523, Section 2.3 list of affected TS Sections for NUREG-1433 (BWR/4) does not include TS Section 3.7.1, "Residual Heat Removal Service Water," which is the equivalent of PBAPS's TS Section 3.7.1 for the HPSW System. Page 1 of 2 Attachment March 23, 2015 Response to Request for Additional Information Regarding Proposed License Amendment to Revise Technical Specifications to Adopt TSTF-523 PBAPS Response to 1.b The HPSW System is used during power operations to supply cooling water to the AHR System for torus cooling, and to provide a reliable supply of cooling water for the AHR System under shutdown and post-accident conditions.
The HPSW System is a safety-related, open-loop, cooling water system. A separate HPSW System serves each of PBAPS's two Units. Each Unit has four HPSW pumps separated into two subsystems with two pumps each. The HPSW pumps take suction from the Conowingo Pond through the Service Water Pump Bay, provide cooling water flow to the AHR heat exchangers, and discharge through a common pipe for each Unit to the Discharge Pond. The majority of HPSW piping is located below the ground elevation of the site. The RHR heat exchanger HPSW motor operated discharge valves are normally in the closed position.
The first pump of the HPSW system is placed into service by opening the selected AHR heat exchanger HPSW motor operated discharge valve and then starting the HPSW pump. The system is secured and restored to standby by shutting down the HPSW pump and then closing the discharge valve. The HPSW System is an open-loop cooling water system and it is not designed to be water solid. Page 2 of 2