Letter Sequence Response to RAI |
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EPID:L-2018-LLA-0265, 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 ... (Approved, Closed) |
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MONTHYEARML18275A0232018-09-28028 September 2018 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 ... Project stage: Request ML18295A2602018-10-22022 October 2018 Acceptance Review for Peach Bottom - License Amendment Request for TS Changes Related to HPSW System Project stage: Acceptance Review ML19017A0472019-01-16016 January 2019 Request for Additional Information - High Pressure Service Water One Time TS Change Project stage: RAI 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 Project stage: Response to RAI ML19058A2902019-02-27027 February 2019 Request for Additional Information - High Pressure Service Water One Time TS Change Project stage: RAI 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 ... Project stage: Request ML19232A1752019-08-20020 August 2019 Request for Additional Information - TSTF-500 Implementation LAR Project stage: RAI ML19182A0062019-08-28028 August 2019 Issuance of Amendment Nos. 327 and 330 Reduce High Pressure Service Water System Design Pressure and Temporarily Extend Completion Times Project stage: Approval 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 Project stage: Response to RAI 2019-02-27
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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
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200 Exelon Way Exelon Generation ~ Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 August 29, 2019 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 (RAl-1)
License Amendment Request to Revise Technical Specifications 3.8.4, DC Sources-Operating
References:
- 1. Exelon Letter to the NRC, "License Amendment Request to Revise Technical Specifications 3.8.4, DC Sources-Operating,"
dated June 7, 2019 (ADAMS Accession No. ML19158A312)
- 2. NRC Email to Exelon, "Peach Bottom Units 2 and 3 - Request for Additional Information - TSTF-500 Implementation LAR (EPID L-2018-LLA-0265)," dated August 20, 2019 (ADAMS Accession No.
ML19232A175)
In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) proposed a change to the Technical Specifications (TS), Appendix A of Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3 (Reference 1). The proposed change would revise TS 3.8.4, "DC Sources - Operating," to add a Condition for the opposite Unit consistent with Technical Specifications Task Force (TSTF)-500, Revision 2, "DC [direct current] Electrical Rewrite - Update to TSTF-360," as approved by the Nuclear Regulatory Commission (NRC). Specifically, the proposed Condition would allow a 72-hour Completion Time for an opposite Unit battery charger that is required for particular plant configurations.
During their technical review of the application, the NRC staff identified the need for additional information (Reference 2).
U.S. Nuclear Regulatory Commission Response to Request for Additional Information LAR to Revise TS 3.8.4, DC Sources-Operating Docket Nos. 50-277 and 50-278 August 29, 2019 Page 2 The Attachment to this letter provides a restatement of the question cited in Reference 2 followed by Exelon's response.
Exelon has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in Attachment 1 of the Reference 1 letter. Exelon has concluded that the information provided in this response does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92. In addition, Exelon has concluded that the information 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 contained in this response.
In accordance with 10 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 to the designated State Official.
Should you have any questions concerning this response, please contact Mr. Frank J. Mascitelli at (610) 765-5512.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 29th day of August 2019.
Respectfully, David P. Helker Sr. Manager, Licensing Exelon Generation Company, LLC
Attachment:
Response to Request for Additional Information (RAl-1 },
License Amendment Request to Revise Technical Specifications 3.8.4, DC Sources-Operating cc: Regional Administrator - NRC Region I w/ attachments II NRC Senior Resident Inspector- PBAPS II NRC Project Manager, NRR - PBAPS II R. R. Janati, Pennsylvania Bureau of Radiation Protection II D. A Tancabel , State of Maryland
ATTACHMENT License Amendment Request Peach Bottom Atomic Power Station, Units 2 and 3 Docket Nos. 50-277 and 50-278 Response to Request for Additional Information (RAl-1)
License Amendment Request to Revise Technical Specifications 3.8.4, DC Sources-Operating
Attachment Response to Request for Additional Information LAR to Revise TS 3.8.4, DC Sources-Operating Docket Nos. 50-277 and 50-278 Page 1 of 3 Response to NRC Staff's Request for Additional Information By application dated June 7, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19158A312), Exelon Generation Company, LLC (Exelon) requested an amendment to the Renewed Facility Operating License Nos. DPR-44 and DPR-56 for Peach Bottom Atomic Power Station (PBAPS), Units 2 and 3. The license amendment request (LAR) would revise the Technical Specifications (TS) 3.8.4, "DC Sources - Operating," to add a Condition for the opposite Unit consistent with Technical Specifications Task Force (TSTF)-500, Revision 2, "DC [direct current] Electrical Rewrite -
Update to TSTF-360," (ADAMS Accession No. ML092670242) as approved by the Nuclear Regulatory Commission (NRC).
Specifically, the proposed Condition would allow a 72-hour Completion Time (CT) for an opposite Unit battery charger that is required for particular plant configurations. Title 10 of the Code of Federal Regulations, Part 50 (10 CFR 50), Section 36, "Technical Specifications," requires, in part, that the operating license of a nuclear production facility include TS. 10 CFR 50.36 (c)(2) requires that the TS include limiting conditions for operation (LCOs) which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the condition can be met.
Below is a restatement of the question cited in Reference 2 of the cover letter followed by Exelon's response.
RAI -1 Question The licensee proposed a new TS 3.8.4 Condition B with associated Required Actions and Completion Times (CT) for the required opposite unit battery charger. The licensee stated that the word "required" denotes that only specific batteries from the opposite unit are required to support operation of the unit for particular plant configurations.
The proposed new Unit 2 TS 3.8.4 Condition B with associated Required Actions and CT would state:
Attachment Response to Request for Additional Information LAR to Revise TS 3.8.4, DC Sources-Operating Docket Nos. 50-277 and 50-278 Page 2 of 3
'I Resto'"'e ,_nit 3 patt~
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~ OPERAB: [ ru:.1<. I The proposed new Unit 3 TS 3.8.4 Condition B with associated Required Actions and CT would state:
fL_ Q"lf._f"PQt...1 rfd Lili:. 2 12 '1QU!"S 2d:t.e*'v ~-~ Qr Qr
~ v t:,, y s : '- m * ~ r 1P ..t rr-p r'n "'lUm "S~oQl 1snf.(L floar vc tag<:_
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The NRC staff has identified the following discrepancy:
Both the 12 hour-CT for Required Action 8.1 and the initial 12-hour CT for Required Action 8 .2 start when Condition 8 is entered. If the battery terminal voltage was restored to greater than or equal to the minimum established float voltage within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (Required Action
- 8. 1), the battery would be on the exponential charging current portion of its recharging cycle at the end of the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. It appears that there would be no time remaining for the battery charging current to decrease to less than or equal to 2 amperes (amps) within the same 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (i.e., initial 12-hour CT for Required Action 8.2) .
The staff requests the following information to address this discrepancy:
Provide a discussion to demonstrate that the required battery can be fully recharged with a charging current of less than 2 amps within the initial 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from entry into Condition B (Required Action 8.2) after the required battery terminal voltage is restored to greater than or equal to the minimum established float voltage at the end of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from entry into Condition B (Required Action 8. 1).
Attachment Response to Request for Additional Information LAR to Revise TS 3.8.4, DC Sources-Operating Docket Nos. 50-277 and 50-278 Page 3 of 3
Response
The required battery cannot be fully recharged with a charging current of less than 2 amps within the initial 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from entry into Condition B (Required Action B.2) after the required battery terminal voltage is restored to greater than or equal to the minimum established float voltage at the end of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from entry into Condition B (Required Action B.1 ). This condition had been recognized during development of the LAR. Exelon did not pursue additional calculations or analysis to provide a CT for Required Action B.2 that exceeded the analysis that had been provided in TSTF-500, Revision 2, "DC [direct current] Electrical Rewrite - Update to TSTF-360." For the above condition to occur, both the on-line and standby safety related battery chargers, as well as the permanently installed alternate non-safety related battery charger, would have had to fail. The alternate battery charger has been designed and will be operated in a manner to be available within approximately two hours to start charging the battery that may have experienced a discharging condition due to failure of the on-line and standby battery chargers. The condition of all three battery chargers failing concurrently was judged to be of such low probability that it did not justify the additional effort to support an extended CT beyond the 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> for the battery to be fully recharged with a charging current of less than 2 amps. Exelon acknowledges that if such a condition did occur and the proposed LCO 3.8.4.B Required Action B.2 could not be met, the proposed LCO 3.8.4 Condition F would be entered and the associated Unit would be required to be in Mode 3 within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and Mode 4 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.