RS-20-112, Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-568

Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-568

ML20247J525
Person / Time
Site:	Dresden, Peach Bottom, Nine Mile Point, Limerick, Quad Cities, LaSalle
Issue date:	09/03/2020
From:	Simpson P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
RS-20-112
Download: ML20247J525 (6)

Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-20-112 10 CFR 50.90 September 3, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Nine Mile Point Nuclear Station, Unit 2 Renewed Facility Operating License No. NPF-69 NRC Docket No. 50-410 Peach Bottom Atomic Power Station, Units 2 and 3 Subsequent Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-277 and 50-278 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265

Subject:

Response to Request for Additional Information Related to License Amendment Request to Adopt TSTF-568

References:

1. Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "License Amendment Request - Application to Adopt Technical Specification Task Force (TSTF) Traveler TSTF-568, Revision 2, 'Revise Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.2', Using the Consolidated Line Item Improvement Process," dated April 30, 2020

September 3, 2020 U.S. Nuclear Regulatory Commission Page 2

2. Email from B. Purnell (U.S. NRC) to P. A. Henderson (Exelon Generation Company, LLC), "Exelon Generation Company, LLC - Fleet License Amendment Request to Adopt TSTF-568, Revision 2 (EPID L-2020-LLA-0096," dated August 25, 2020 By application dated April 30, 2020 (Reference 1), Exelon Generation Company, LLC (EGC) requested adoption of TSTF-568, "Revise Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.2."

TSTF-568 revises the Applicability and Actions of Technical Specification (TS) 3.6.2.5, "Drywell-to-Suppression Chamber Differential Pressure," and TS 3.6.3.2, "Primary Containment Oxygen Concentration," and presents the requirements in a manner more consistent with the Standard Technical Specifications (STS) format and content.

In an NRC email dated August 25, 2020 (Reference 2), the NRC determined that additional information is needed to complete its review. Attachment 1 to this letter provides the requested information.

In the license amendment request it was determined that the Environmental Consideration contained two errors. Attachment 2 contains the revised Environmental Consideration which supersedes the previous submittal. The revision does not alter the conclusion of the previous Environmental Consideration.

EGC has reviewed the information supporting the No Significant Hazards Consideration and the Environmental Consideration that was previously provided to the NRC in Attachment 1 of the Reference 1 letter. The additional information provided in this submittal does not affect the conclusion that the proposed license amendment does not involve a significant hazards consideration. This additional information also does not affect the conclusion that there is no need for an environmental assessment to be prepared in support of the proposed amendment.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b),

EGC is providing a copy of this letter and its attachment to the State of Illinois.

There are no regulatory commitments contained within this letter. Should you have any questions concerning this letter, please contact Mr. Phillip A. Henderson at (630) 657-4727.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 3rd day of September 2020.

Respectfully, Patrick R. Simpson Sr. Manager Licensing Exelon Generation Company, LLC

September 3, 2020 U.S. Nuclear Regulatory Commission Page 3 Attachments:

1. Response to Request for Additional Information

2. Revised Environmental Consideration cc: NRC Regional Administrators, Regions I and III NRC Senior Resident Inspector - DNPS, LSCS, LGS, NMP2, PBAPS, QCNPS Illinois Emergency Management Agency - Division of Nuclear Safet

ATTACHMENT 1 Response to Request for Additional Information By application dated April 30, 2020 (Reference 1) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20121A274), Exelon Generation Company, LLC (Exelon) submitted a license amendment request for Dresden Nuclear Power Station (Dresden), Units 2 and 3; LaSalle County Station, Units 1 and 2; Limerick Generating Station, Units 1 and 2; Nine Mile Point Nuclear Station, Unit 2; Peach Bottom Atomic Power Station, Units 2 and 3; and Quad Cities Nuclear Power Station (Quad Cities), Units 1 and 2. The proposed amendments would revise the Technical Specifications (TSs) for each facility based on Technical Specification Task Force (TSTF) traveler TSTF-568, Revision 2, Revise Applicability of BWR/4 [Boiling-Water Reactor/Type 4] TS 3.6.2.5 and TS 3.6.3.2 (ADAMS Accession No. ML19141A122).

By email dated August 25, 2020 (Reference 2), the NRC determined that additional information is needed to complete its review. This attachment provides the requested information.

References:

1) Letter from P. R. Simpson (Exelon Generation Company, LLC) to U.S. NRC, "License Amendment Request - Application to Adopt Technical Specification Task Force (TSTF)

Traveler TSTF-568, Revision 2, 'Revise Applicability of BWR/4 TS 3.6.2.5 and TS 3.6.3.2', Using the Consolidated Line Item Improvement Process," dated April 30, 2020

2) Email from B. Purnell (U.S. NRC) to P. A. Henderson (Exelon Generation Company, LLC), "Exelon Generation Company, LLC - Fleet License Amendment Request to Adopt TSTF-568, Revision 2 (EPID L-2020-LLA-0096," dated August 25, 2020

3) NUREG-1433, Revision 4, Volume 1, "General Electric Plants (BWR/4): Specifications"

4) NUREG-1433, Revision 4, Volume 2, "General Electric Plants (BWR/4): Bases" NRC RAI 1 The proposed changes to TS 3.6.2.5, Drywell-to-Suppression Chamber Differential Pressure, for Dresden and Quad Cities include increasing the completion time for required action B.1 from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. However, this change is not included in TSTF-568, Revision 2, and the application does not provide any justification for this change. In order for the U.S. Nuclear Regulatory Commission staff to complete its review of the application, the staff requests that Exelon provide justification for this change.

EGC Response to NRC RAI 1 In Reference 1 for Dresden and Quad Cities Technical Specification (TS) 3.6.2.5 "Drywell-to-Suppression Chamber Differential Pressure," a proposed change increases the Completion Time for the Required Action B.1 from 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This change is consistent with Reference 3 which allows a Completion Time for Required Action B.1 of 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. As documented in Reference 4 for TS 3.6.2.5, Required Action B.1, the 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Completion Time is reasonable, based on operating experience, to reduce reactor power from full power conditions in an orderly manner and without challenging plant systems. The change to TS 3.6.2.5 Page 1

ATTACHMENT 1 Response to Request for Additional Information "Drywell-to-Suppression Chamber Differential Pressure," aligns both the Dresden and Quad Cities Completion Time with the Standard Technical Specification that is approved for General Electric BWR/4 Plants and are applicable to Dresden and Quad Cities.

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ATTACHMENT 2 Revised Environmental Consideration

4.0 ENVIRONMENTAL CONSIDERATION

The proposed change would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. The proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

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