IR 05000461/2018090
| ML18039A728 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 02/08/2018 |
| From: | Khadijah West Region 3 Administrator |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| References | |
| EA-17-098 IR 2018090 | |
| Download: ML18039A728 (6) | |
Text
February 8, 2018
SUBJECT:
NRC DENIAL OF EXELON GENERATION COMPANY, LLC, APPEAL OF CLINTON POWER STATIONFINAL SIGNIFICANCE DETERMINATION OF A WHITE FINDING; NRC INSPECTION REPORT 05000461/2018090
Dear Mr. Hanson:
On November 27, 2017, the U.S. Nuclear Regulatory Commission (NRC) provided Exelon Generation Company, LLC, (EGC), the final significance determination for a finding of low-to-moderate significance (White) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17331B161). This finding involved the failure to evaluate the change in the actual drop out voltages for replacement relays associated with the Division 1 Emergency Diesel Generator (EDG) room ventilation fan, which was a component subject to the requirements of Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B.
The change in drop out voltages prevented the fan from operating during an undervoltage condition, resulting in the Division 1 EDG being unable to perform its intended safety function and becoming inoperable for a time longer than its Technical Specification allowed outage time.
In that same letter, the NRC stated that Exelon had 30 calendar days to appeal the NRCs final significance determination. The letter also stated that such an appeal would be considered to have merit only if it met the criteria given in Inspection Manual Chapter (IMC) 0609, Attachment 2, Process for Appealing NRC Characterization of Inspection Findings (SDP Appeal Process) (ADAMS Accession No. ML101400502).
By letter dated December 21, 2017, Exelon reiterated that a performance deficiency had occurred and did not dispute the violation or the assigned cross-cutting aspect (ADAMS Accession No. ML17355A562). However, Exelon appealed the NRC's characterization of the final significance determination of the White finding. Exelon asserted that the basis documented in the final significance determination letter appeared to be qualitative in nature, subjective, and based on an undefined alternative process. As a result, the NRC's final significance determination deviated from established NRC regulations and guidance currently used for safety-related equipment qualification. Therefore, Exelon stated that its appeal met the lacked justification merit standard provided in NRC IMC 0609, Attachment 2.
This letter provides you the NRCs response to your December 21, 2017, appeal. The NRC concluded that Exelons appeal did not have sufficient merit for review by the appeal process specified in IMC 0609 Attachment 2. Our evaluation of the appeal submitted by Exelon is provided in the enclosure to this letter. Accordingly, the NRC concluded that the final significance determination documented in NRC Inspection Report 05000461/2017010, is unchanged and, based on your previous response to the Notice of Violation, no further response is required. If you have any questions on our conclusions on the merit of your appeal, please contact Mr. Patrick Louden, Director, Division of Reactor Projects, at 630-829-9600, or Ms. Karla Stoedter, Chief, Reactor Projects Branch 1, at 630-829-9731.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room and in ADAMS, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.
Sincerely,
/RA/
K. Steven West Regional Administrator
Docket No. 50-461 License No. NPF-62
Enclosure:
NRC Response to Final Significance Determination Appeal