Exelon Generation @ May 29, 2015 10 CFR 50.90 10 CFR 50.91 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001 Peach Bottom Atomic Power Station, Unit 3 Renewed Facility Operating License No. DPR-56 NRC Docket No. 50-278 Subject: Exigent License Amendment Request - Change to Unit 3 License Condition 2.C(15)(a)1 Reference: 1. NRC Letter to Exelon, "Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendments Re: Extended Power Uprate (TAC Nos. ME9631 and ME9632)", dated August 25, 2014 (ADAMS Accession No. ML 14133A046) 2. Exelon letter to the NRC, "Extended Power Uprate: Request for NRC Approval of Revision to Methodology for Establishing Replacement Steam Dryer Strain Limits", dated February 3, 2015 (ADAMS Accession No. ML 15034A573) 3. NRC letter to Exelon, "Peach Bottom Unit 2 - Approval of Revision to Methodology for Establishing Replacement Steam Dryer Strain Limits (TAC No. MF4792)", dated May 19, 2015 (ADAMS Accession No. ML 15127A208) In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," and 10 CFR 50.91 (a)(6) (exigent requests), Exelon Generation Company, LLC (Exelon) requests expedited approval for a license amendment to reduce the time before the Peach Bottom Atomic Power Station (PBAPS) Unit 3 Extended Power Uprate (EPU) outage for the submittal of the revised analysis of the replacement steam dryer (RSD). The NRC issued License Amendment Nos. 293 and 296 to the PBAPS Renewed Facility Operating Licenses (FOLs) to increase the authorized maximum power level from 3514 megawatts thermal (MWt) to 3951 MWt (Reference 1 ). The amendments included specific
Transcript
Exelon Generation@
May 29, 2015
10 CFR 50.90 10 CFR 50.91
U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001
Peach Bottom Atomic Power Station, Unit 3 Renewed Facility Operating License No. DPR-56 NRC Docket No. 50-278
Subject: Exigent License Amendment Request - Change to Unit 3 License Condition 2.C(15)(a)1
Reference: 1. NRC Letter to Exelon, "Peach Bottom Atomic Power Station, Units 2 and 3 - Issuance of Amendments Re: Extended Power Uprate (TAC Nos. ME9631 and ME9632)", dated August 25, 2014 (ADAMS Accession No. ML 14133A046)
2. Exelon letter to the NRC, "Extended Power Uprate: Request for NRC Approval of Revision to Methodology for Establishing Replacement Steam Dryer Strain Limits", dated February 3, 2015 (ADAMS Accession No. ML 15034A573)
3. NRC letter to Exelon, "Peach Bottom Unit 2 - Approval of Revision to Methodology for Establishing Replacement Steam Dryer Strain Limits (TAC No. MF4792)", dated May 19, 2015 (ADAMS Accession No. ML 15127 A208)
In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," and 10 CFR 50.91 (a)(6) (exigent requests), Exelon Generation Company, LLC (Exelon) requests expedited approval for a license amendment to reduce the time before the Peach Bottom Atomic Power Station (PBAPS) Unit 3 Extended Power Uprate (EPU) outage for the submittal of the revised analysis of the replacement steam dryer (RSD).
The NRC issued License Amendment Nos. 293 and 296 to the PBAPS Renewed Facility Operating Licenses (FOLs) to increase the authorized maximum power level from 3514 megawatts thermal (MWt) to 3951 MWt (Reference 1 ). The amendments included specific
U.S. Nuclear Regulatory Commission License Amendment Request - Change to Unit 3 License Condition 2.C(15)(a)1 Docket No. 50-278 May 29, 2015 Page 2
license conditions that required certain monitoring, evaluation, and response actions to potential adverse flow effects as a result of the EPU on plant structures, systems and components (including verifying the continued structural integrity of the RSD) during the initial EPU power ascension. One aspect of the License Condition 2.C(15)(a)1 for Unit 3 requires the submittal of a revised PBAPS Unit 3 RSD analysis utilizing the PBAPS Unit 2 on-dryer strain gauge based end-to-end bias errors and uncertainties (B/Us) at EPU conditions "at least 90 days prior to the start of the Peach Bottom Unit 3 EPU outage."
Evaluation of measured data taken during the PBAPS Unit 2 power ascension necessitated adjustments to the RSD analysis methodology. As described in Exelon letter dated February 3, 2015 (Reference 2), data collected at near the previously licensed thermal power level identified low frequency loads on the RSD that were not previously predicted in the analysis submitted with the original LAA.
On May 15, 2015, the NRG approved the revised methodology (Reference 3). The action to complete the final PBAPS Unit 2 RSD stress report within 90 days of completion of power ascension testing can now proceed in accordance with PBAPS Unit 2 License Condition 2.C(15)(e). The action to utilize the PBAPS Unit 2 on-dryer strain gauge based end-to-end B/Us at EPU conditions in the PBAPS Unit 3 RSD analysis can now also proceed in accordance with PBAPS Unit 3 License Condition 2.C(15)(a)1. However, based on the extended review of the PBAPS Unit 2 RSD analysis, Exelon is unable to submit the revised PBAPS Unit 3 RSD analysis 90 days prior to the planned September 14, 2015, start of the PBAPS Unit 3 EPU outage as required by the current PBAPS Unit 3 License Condition 2.C(15)(a)1. Exelon requests expedited review of the attached License Amendment Request to revise the PBAPS Unit 3 License Condition 2.C(15)(a)1 to reduce the required time prior to the EPU outage for submittal of the revised PBAPS Unit 3 RSD analysis. An evaluation of the proposed change is provided in Attachment 1 . A markup of the affected operating license page is provided in Attachment 2.
The need for the proposed change is based on the extended review required for Exelon to analyze and the NRG to review the PBAPS Unit 2 RSD structural integrity. As discussed with NRG staff, review of this exigent license amendment request is needed to ensure continued compliance with operating license requirements. This request is purely administrative in nature, in that it will only change the length of the required period prior to the EPU outage for the PBAPS Unit 3 submittal.
The proposed change has been reviewed by the PBAPS Plant Operations Review Committee and approved by the Nuclear Safety Review Board in accordance with the requirements of the Exelon Quality Assurance Program.
Exelon requests approval of the proposed amendment before the PBAPS Unit 3 refueling outage scheduled to begin September 14, 2015. Once approved, the amendment will be implemented within three weeks.
There are no regulatory commitments contained in this letter.
U.S. Nuclear Regulatory Commission License Amendment Request - Change to Unit 3 License Condition 2.C(15)(a)1 Docket No. 50-278 May 29, 2015 Page 3
Using the standards in 10 CFR 50.92, "Issuance of amendment," Exelon has concluded that the proposed change does not constitute a significant hazards consideration as described in the enclosed analysis performed in accordance with 1 O CFR 50.91 (a)(1 ).
In accordance with 1 O CFR 50.91, "Notice for public comment; State consultation," Exelon is notifying the Commonwealth of Pennsylvania and the state of Maryland of this application for change to the PBAPS Unit 3 Operating License by transmitting a copy of this letter and its attachments to the designated state officials.
Should you have any questions concerning this letter, please contact David Neff at (610) 765-5631.
Respectfully,
Kevin F. Borton Manager, Power Uprate Licensing Exelon Generation Company, LLC
Attachments: 1. Description and Evaluation of Proposed Change 2. Markup of Proposed Operating License Page
cc: USNRC Region I, Regional Administrator USNRC Senior Resident Inspector, PBAPS USNRC Project Manager, PBAPS R.R. Janati, Commonwealth of Pennsylvania S. T. Gray, State of Maryland
License Amendment Request - Change to Unit 3 License Condition 2.C(15)(a)1
DESCRIPTION and EVALUATION OF PROPOSED CHANGE
Attachment 1 Page 1of6
SUBJECT: Reduction of time prior to the outage required for submittal of the revised Unit 3 Replacement Steam Dryer analysis.
CONTENTS
1.0 SUMMARY DESCRIPTION
2.0 DETAILED DESCRIPTION
3.0 TECHNICAL EVALUATION
4.0 REGULATORY EVALUATION
4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA
4.2 PRECEDENT
4.3 NO SIGNIFICANT HAZARDS CONSIDERATION
4.4 CONCLUSIONS
5.0 ENVIRONMENTAL CONSIDERATION
6.0 REFERENCES
License Amendment Request - Change to Unit 3 License Condition 2.C(15)(a)1
1.0 SUMMARY DESCRIPTION
Attachment 1 Page 2 of 6
Exelon Generation Company, LLC (Exelon) requests an exigent license amendment request to reduce the time before the outage that the revised Peach Bottom Atomic Power Station (PBAPS) Unit 3 replacement steam dryer analysis must be submitted. Exelon proposes to reduce the period before the outage by which the analysis is to be submitted from 90 days to 30 days. This PBAPS Unit 3 EPU outage is scheduled to start on September 14, 2015.
By letter dated August 25, 2014, the NRC issued License Amendment Nos. 293 and 296 to the PBAPS Renewed Facility Operating Licenses (FOLs) to increase the authorized maximum power level from 3514 megawatts thermal (MWt) to 3951 MWt (Reference 1). The amendments included specific license conditions that required certain monitoring, evaluation, and response actions to potential adverse flow effects as a result of the EPU on plant structures, systems and components (including verifying the continued structural integrity of the replacement steam dryer (RSD)) during the initial EPU power ascension. One aspect of the new License Condition 2.C(15)(a)1 for PBAPS Unit 3 requires the submittal of a revised PBAPS Unit 3 RSD analysis utilizing the Unit 2 on-dryer strain gauge based end-to-end bias errors and uncertainties (B/Us) at EPU conditions "at least 90 days prior to the start of the Peach Bottom Unit 3 EPU outage."
Evaluation of measured data taken during the PBAPS Unit 2 power ascension necessitated adjustments to the RSD analysis methodology. As described in Exelon letter dated February 3, 2015 (Reference 2), data collected at near the previously licensed thermal power level identified low frequency loads on the RSD that were not predicted in the analyses submitted with the original LAA.
On May 19, 2015, the NRC approved the revised methodology (Reference 3). The action to complete the final Unit 2 RSD stress report within 90 days of completion of power ascension testing can now proceed in accordance with Unit 2 License Condition 2.C(15)(e). The action to utilize the PBAPS Unit 2 on-dryer strain gauge based end-to-end B/Us at EPU conditions in the PBAPS Unit 3 RSD analysis can now also proceed in accordance with PBAPS Unit 3 License Condition 2.C(15)(a) 1. However, based on the extended review of the PBAPS Unit 2 RSD analysis, Exelon is unable to submit the revised PBAPS Unit 3 RSD analysis 90 days prior to the start of the PBAPS Unit 3 EPU outage as required by the current PBAPS Unit 3 License Condition 2.C(15)(a)1.
As the revised analysis methodology was only recently approved, and because of the time required to complete the final Unit 2 stress report and develop the revised Unit 3 analysis, Exelon is unable to submit the revised analysis 90 days prior to the planned September 14, 2015, start of the Unit 3 EPU Outage. Exelon requests an administrative revision to PBAPS Unit 3 Operating License Condition 2.C(15)(a)1 to reduce the required time prior to the outage for submittal of the revised report from 90 days to 30 days.
License Amendment Request - Change to Unit 3 License Condition 2.C(15)(a) 1
Exigent Circumstances:
Attachment 1 Page 3 of 6
The Commission's regulations, 1 O CFR 50.91, contain provisions for issuance of amendments when the usual 30-day public notice period cannot be met. One type of special exception is an exigency. An exigency is a case where the staff and licensee need to act promptly. In this case, Exelon cannot submit the required revised analysis within the schedule required by the license condition. The need for, and NRG review of, a revised methodology was not recognized until after NRG approval of the EPU amendment and associated license condition, and data from the initial PBAPS Unit 2 power ascension test plateau had been evaluated. The non-Main Steam Line acoustic nature of the new loads observed during the PBAPS Unit 2 power ascension necessitated a revised methodology. The Exelon development and verification of the revised methodology has resulted in unforeseen delays affecting our ability to complete the PBAPS Unit 2 final analysis and develop the revised PBAPS Unit 3 analysis on a schedule that would comply with the current PBAPS Unit 3 license condition.
The proposed change relates to a revised analysis that will be based on the new NRCapproved methodology. Further, this revised analysis will provide an updated prediction of the expected performance of the PBAPS Unit 3 RSD for information; the power ascension test plan includes the test plateaus and hold points to support on-going NRG review of actual RSD performance during Unit 3 power ascension.
Without a license condition change or a significant delay in the outage start, PBAPS Unit 3 will be in non-compliance with the operating license. As such, pursuant to 10 CFR 50.91 (a)(6), Exelon is requesting the proposed amendment on an exigent basis. As demonstrated in Section 4.3, this proposed change involves no significant hazards consideration.
2.0 DETAILED DESCRIPTION
The PBAPS Unit 3 License Condition 2.C(15)(a)1 (Operating License page 7c) currently states:
At least 90 days prior to the start of the Peach Bottom Unit 3 EPU outage, Exelon Generation Company shall revise the Peach Bottom Unit 3 replacement steam dryer (RSD) analysis utilizing the Unit 2 on-dryer strain gauge based end-to-end Bias errors and Uncertainties (B/Us) at EPU conditions, and submit the information including the updated limit curves and a list of dominant frequencies for Unit 3, to the NRG as a report in accordance with 10 CFR 50.4.
The proposed change is to change the '90 days' to '30 days' and the revised statement of the license condition would read:
At least 30 days prior to the start of the Peach Bottom Unit 3 EPU outage, Exelon Generation Company shall revise the Peach Bottom Unit 3 replacement steam dryer (RSD) analysis utilizing the Unit 2 on-dryer strain gauge based end-to-end Bias errors and Uncertainties (B/Us) at EPU conditions, and submit the information including the updated limit curves and a list of dominant frequencies for Unit 3, to the NRG as a report in accordance with 10 CFR 50.4.
License Amendment Request - Change to Unit 3 License Condition 2.C(15)(a)1
3.0 TECHNICAL EVALUATION
Attachment 1 Page 4 of 6
The request for reducing the time before the outage at which the revised analysis must be submitted is not a technical or safety issue. The proposed change is purely an administrative change. When proposing the current license condition, Exelon had anticipated a more compact power ascension schedule, even considering time for the required NRC reviews of the interim stress data. With the recent approval of the revised methodology, a revised analysis of the PBAPS Unit 3 RSD using that methodology cannot be developed and submitted in the time currently required by the license condition.
The timing is a requirement of a license condition included in the Facility Operating License. As such, a change to the timing is a change to the operating license for the plant.
4.0 REGULATORY EVALUATION
4.1 APPLICABLE REGULATORY REQUIREMENTS/CRITERIA
The proposed change has been evaluated to determine whether applicable regulations and requirements continue to be met. Exelon has determined that the proposed change does not require any exemptions or relief from regulatory requirements other than the license. The following applicable regulations and regulatory requirements were reviewed in making this determination:
• 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit
• 10 CFR 50.91, Notice for public comment; State consultation • 10 CFR 50.92, Issuance of amendment
4.2 PRECEDENT
No relevant license amendments involving a reduction I relaxation of a required submittal schedule were identified.
4.3 NO SIGNIFICANT HAZARDS CONSIDERATION
Exelon Generation Company, LLC (Exelon) has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 1 O CFR 50.92, "Issuance of amendment," as discussed below:
1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No.
The proposed exigent license amendment reduces the length of time prior to the outage by which a predictive summary stress analysis of the Peach Bottom Atomic Power Station (PBAPS) Unit 3 replacement steam dryer (RSD), performed using an NRG-approved methodology benchmarked on the PBAPS Unit 2 RSD, must be
License Amendment Request - Change to Unit 3 License Condition 2.C(15)(a)1
Attachment 1 Page 5 of 6
submitted to the NRC for information. There is no required review or approval of the revised analysis needed to satisfy the license condition. The proposed change is an administrative change to the period before the outage and does not impact any system, structure or component in such a way as to affect the probability or consequences of an accident previously evaluated.
The proposed amendment is purely administrative and has no technical or safety aspects.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No.
The proposed exigent license amendment reduces the length of time prior to the outage by which a revised stress analysis of the PBAPS Unit 3 RSD must be submitted to the NRC for information. The proposed amendment is purely administrative and has no technical or safety aspects.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
3. Does the proposed amendment involve a significant reduction in a margin of safety?
Response: No.
The proposed exigent license amendment reduces the length of time prior to the outage by which a revised stress analysis of the PBAPS Unit 3 RSD must be submitted to the NRC for information. The proposed amendment is purely administrative and has no technical or safety aspects.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above, Exelon concludes that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c) and, accordingly, a finding of no significant hazards consideration is justified.
4.4 CONCLUSIONS
In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
License Amendment Request - Change to Unit 3 License Condition 2.C(15)(a)1
5.0 ENVIRONMENTAL CONSIDERATION
Attachment 1 Page 6 of 6
A review has determined that the proposed amendment does not change any technical requirement with respect to the installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, and does not change any inspection or surveillance requirement. The proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(10). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement
·or environmental assessment need be prepared in connection with the proposed amendment.
6.0 REFERENCES
1. NRC Letter to Exelon, "Peach Bottom Atomic Power Station, Units 2 and 3- Issuance of Amendments Re: Extended Power Uprate (TAC Nos. ME9631 and ME9632)", dated August 25, 2014 (ADAMS Accession No. ML 14133A046)
2. Exelon letter to the NRC, "Extended Power Uprate: Request for NRC Approval of Revision to Methodology for Establishing Replacement Steam Dryer Strain Limits", dated February 3, 2015 (ADAMS Accession No. ML 15034A573)
3. NRC letter to Exelon, "Peach Bottom Unit 2 - Approval of Revision to Methodology for Establishing Replacement Steam Dryer Strain Limits (TAC No. MF4792) 11
, dated May 19, 2015 (ADAMS Accession No. ML 15127A208)
Attachment 2
Peach Bottom Atomic Power Station Unit 3
NRC Docket No. 50-278
Markup of Proposed Operating License Page
~ 1. At least 9Q days prior to the start of the Peach Bottom Unit 3
EPU outage, Exelon Generation Company shall revise the Peach Bottom Unit 3 replacement steam dryer (RSD) analysis utilizing the Unit 2 on-dryer strain gauge based end-to-end Bias errors and Uncertainties (B/Us) at EPU conditions, and submit the information including the updated limit curves and a list of dominant frequencies for Unit 3, to the NRC as a report in accordance with 10 CFR 50.4.
2. Exelon Generation Company shall evaluate the Unit 3 limit curves prepared in {a)1 above based on new MSL strain gauge data collected following the Unit 3 EPU outage at or near 3514 MWt. If the limit curves change, the new post-EPU outage limit curves shall be provided by e-mail to the NRC Project Manager. Exelon Generation Company shall not increase power above 3514 MWt for at least 96 hours after the NRC Project Manager confirms receipt of the reports unless, prior to expiration of the 96 hour period, the NRC Project Manager advises that the NRC staff has no objections to the continuation of power ascension.
3. Exelon Generation Company shall provide a brief vibration summary report, for piping and valves vibration data collected at or near 3514 MWt, for NRC review before increasing power above 3514 MWt. The summary report shall be provided byemail to the NRC Project Manager. Exelon Generation Company shall not increase power above 3514 MWt for at least 96 hours after the NRC Project Manager confirms receipt of the report unless, prior to expiration of the 96 hour period, the NRC Project Manager advises that the NRC staff has no objections to the continuation of power ascension. The vibration summary report shall include the information in items a through c, as follows:
a. Vibration data for piping and valve locations deemed prone to vibration and vibration monitoring locations identified in Attachment 13 to the EPU application dated September 28 1 2012 1 and Supplement 16 dated December 20, 2013, including the following locations: MSLs (including those in the drywell, turbine building and in the steam tunnel), Feedwater Lines (including those in the drywell and turbine building), Safety Relief Valves (SRVs) and the Main Steam Isolation Valves in the drywell.
b. An evaluation of the measured vibration data collected in item 3.a above compared against acceptance limits.
c. Predicted vibration values and associated acceptance limits at approximately 104 percent, 108 percent and 112.4 percent of 3514 MWt using the data collected in item 3.a above.
