ML14064A403

Summary of Telephone Conference Call on February 27, 2014, Between U.S. Nuclear Regulatory Commission & Exelon Generation Company, LLC Concerning Draft Request for Additional Information Re Byron Station & Braidwood Station License Renewal

ML14064A403
Person / Time
Site:	Byron, Braidwood
Issue date:	03/11/2014
From:	Robinson L License Renewal Projects Branch 1
To:
Robinson L, 415-4115
References
TAC MF1879, TAC MF1880, TAC MF1881, TAC MF1882
Download: ML14064A403 (7)

Text

LICENSEE:

FACILITY:

SUBJECT UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 March 11,2014 Exelon Generation Company, LLC Byron Station, Units 1 and 2 Braidwood Station, Units 1 and 2

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON FEBRUARY 27, 2014, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND EXELON GENERATION COMPANY, LLC CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE BYRON STATION AND BRAIDWOOD STATION, LICENSE RENEWAL APPLICATION (TAG NOS.

MF1879, MF1880, MF1881, MF1882)

The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Exelon Generation Company, LLC (Exelon or the applicant), held a telephone conference call on February 27, 2014, to discuss and clarify the staff's draft request for additional information (ORAl), Set 15, concerning the Byron Station, Units 1 and 2, and the Braidwood Station, Units 1 and 2, license renewal application The telephone conference call was useful in clarifying the intent of the staff's ORAls. provides a listing of the participants, and Enclosure 2 contains a listing of the ORAls discussed with the applicant, including a brief description on the status of the items.

The applicant had an opportunity to comment on this summary.

Lindsay Robinson, Project Manager Projects Branch 1 Division of License Renewal Office of Nuclear Reactor Regulation Docket Nos. 50-454, 50-455, 50-456, and 50-457

Enclosures:

1. List of Participants 2 List of Draft Request for Additional Information cc w/encls* Listserv

• ML14064A403

• concurred via email OFFICE LA:DLR PM: RPB1 :DLR PM:RPB1 :DLR BC:RPB1:DLR PM:RPB1 :DLR NAME YEdmonds LRobinson JDaily YDiazSanabria LRobinson DATE 3/6/14 3/10/14 3/10/14 3/10/14 3/11/14

SUMMARY

OF TELEPHONE CONFERENCE CALL HELD ON FEBRUARY 27, 2014, BETWEEN THE U.S. NUCLEAR REGULATORY COMMISSION AND EXELON GENERATION COMPANY, LLC CONCERNING DRAFT REQUEST FOR ADDITIONAL INFORMATION PERTAINING TO THE BYRON STATION AND BRAIDWOOD STATION, LICENSE RENEWAL APPLICATION (TAG NOS.

MF1879, MF1880, MF1881, MF1882)

DISTRIBUTION EMAIL:

PUBLIC RidsNrrDir Resource RidsNrrDirRpb1 Resource RidsNrrDirRpb2 Resource RidsOgcMailCenter RidsNrrPMByron Resource RidsNrrPMBraidwood Resource LRobinson JDaily DMclntyre, OPA EDuncan, Rill JBenjamin, Rill AGarmoe, Rill JMcGhee, Rill JRobbins, Rill VMitlyng, Rill PChandrathil, Rill

TELEPHONE CONFERENCE CALL BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2 LICENSE RENEWAL APPLICATION PARTICIPANTS Lindsay Robinson Matthew Homiack Mark Yoo John Hufnagel Albert Piha AI Fulvio Don Warfel Chris Wilson Tom Quintenz Gary Becknell Don Brindle Ralph Walen LIST OF PARTICIPANTS February 27, 2014 AFFILIATIONS U.S. Nuclear Regulatory Commission (NRC)

NRC NRC Exelon Generating Company, LLC (Exelon)

Exelon Exelon Exelon Exelon Exelon Exelon Exelon Exelon ENCLOSURE 1

DRAFT REQUEST FOR ADDITIONAL INFORMATION BYRON STATION, UNITS 1 AND 2, AND BRAIDWOOD STATION, UNITS 1 AND 2, LICENSE RENEWAL APPLICATION February 27, 2014 The U.S. Nuclear Regulatory Commission (NRC or the staff) and representatives of Exelon Generation Company, LLC (Exelon or the applicant), held a telephone conference call on February 27, 2014, to discuss and clarify the following draft request for additional information (DRAI) concerning the Byron Station, Units 1 and 2, and the Braidwood Station, Units 1 and 2, license renewal application (LRA).

ORAl 4.2.6-1 Applicability:

Byron Station (Byron) and Braidwood Station (Braidwood), Units 1 and 2

Background:

License renewal application (LRA) Section 4.2.6 describes the time-limited aging analysis (TLAA) for calculation of the low temperature overpressure protection {L TOP) system setpoints.

The LRA states that, in accordance with 10 CFR 54.21 (c)(1 )(iii}, the applicant will use its Reactor Vessel Surveillance program to establish and report the L TOP system setpoints in order to manage the effects of aging for the period of extended operation (PEO) As described in LRA Section 8.2.1.19, the Reactor Vessel Surveillance program is a condition monitoring program that provides material and dosimetry data for monitoring irradiation embrittlement through the PEO.

Issue:

To satisfy the requirements of 10 CFR 54.21 (c)(1 )(iii), the applicant should describe the processes it will use to ensure that the L TOP system setpoints are updated and reported to the NRC prior to entering the PEO. LRA Section 4.2.6 states that the applicant will use its Reactor Vessel Surveillance program for this purpose. However, the current licensing bases (CLBs) already specify certain processes that the applicant must use to update the L TOP system setpoints. In particular, Technical Specification 5.6.6 identifies the analytical methods that the applicant must use for establishing the setpoints, and it also requires the applicant to document the setpoints in a Pressure and Temperature Limits Report and provide the report to the NRC for each reactor vessel fluence period and for any revision or supplement thereto. Since the primary purpose of the Reactor Vessel Surveillance program is for data collection only, the program does not include the specific analytical methods and processes that must be used to establish, document, and report the new LTOP system setpoints in accordance with Technical Specification 5.6.6. Because the Reactor Vessel Surveillance program does not fully implement the requirements of Technical Specification 5.6.6, it is not clear to the staff why the applicant credits this program for the demonstration required by 10 CFR 54.21 (c}(1 )(iii}.

Request:

Explain why the procedures that implement the requirements of Technical Specification 5.6.6 will not be used to establish, document, and report the new LTOP system setpoints prior to ENCLOSURE 2 entering the PEO, in order to satisfy the requirements of 10 CFR 54.21 (c)(1)(!ii). If any analytical methods or processes outside the requirements of Technical Specification 5.6.6 will be used to establish, document, and report the new LTOP system setpoints for the PEO, identify and explain the technical specification changes or additions that are needed per the requirements of 10 CFR 54.22. Based on this response, revise LRA Sections 4.2.6 and A4.2.6 accordingly.

Discussion: The applicant requested clarification on the request. After further discussion with the staff, it was noted that this request relates to information listed in LRA Section 4.2.5, on which the staff plans to request additional information. The staff agreed to remove the ORAl from this set and submit it to the applicant at a later date with the requests relating to LRA Section 4.2.5.

ORAl 6.1.4-1 Applicability:

Byron and Braidwood

Background:

LRA Section 8.1.4 describes the applicant's process for reviewing future operating experience for the aging management programs (AMPs). The LRA states that operating experience from plant-specific and industry sources will be captured and systematically reviewed on an ongoing basis in accordance with the Quality Assurance program and the Operating Experience program. In addition, the LRA describes several enhancements to the operating experience review process that the applicant will make in order to ensure the effective use of internal and external operating experience related to aging management.

Issue:

LRA Section 8.1.4 states that the Operating Experience program will be enhanced to require station personnel to periodically assess the performance of the AMPs, including insights obtained through operating experience. However, based on the description of this particular enhancement, it is unclear to the NRC staff under what circumstances the applicant will assess the performance of the AMPs. Specifically, it is unclear if the applicant will conduct these assessments regardless of whether the acceptance criteria of the AMPs have been met or not met.

LRA Section B.1.4 further states that the Operating Experience program will be enhanced to provide training to those personnel responsible for screening, evaluating, and communicating operating experience items related to aging management and age-related degradation.

However, the LRA does not demonstrate that this training will specifically include topics on age-related degradation and aging management.

Request:

1. Describe the circumstances under which the performance of the AMPs will be evaluated and describe how adverse performance results will be identified and processed. Provide justification if these evaluations will only be conducted when the AMP acceptance criteria are not met.

2. Demonstrate that the content of the training activities will include topics on age-related degradation and aging management Provide justification if the content of the training will not specifically include aging topics.

3. Based on these responses, revise the summary descriptions in LRA Sections A.1.6 and 8.1.4 accordingly.

Discussion: The applicant requested clarification on the first request, which the staff provided.

For the second request, the applicant requested clarification on the staff's request to "Demonstrate that the content" specifies additional details on the training activities. The applicant felt that the LRA contained sufficient information; however, the staff requested a greater level of detail in addition to the information listed in the LRA. Regarding the third request, the applicant and staff agreed that depending upon the information provided in items 1 and 2, revisions to LRA Section A.1.6 and 8.1.4 may not be required. This ORAl will be issued as a formal RAI titled "RAI 6.1.4-1."

ORAl 6.1.4-2 Applicability:

Byron and Braidwood

Background:

LRA Section A.1.6 provides the updated final safety analysis report (UFSAR) supplement description of the Operating Experience program and identifies enhancements that will be implemented to ensure that plant-specific and industry operating experience related to aging management will be used effectively.

Issue:

LRA Section B. 1 4 states that the ongoing evaluation of operating experience related to aging management will consider: (a) systems, structures, and components, (b) materials, (c) environments, (d) aging effects, (e) aging mechanisms, (f) AMPs, and (g) activities, criteria, and evaluations integral to the elements of the AMPs. However, LRA Section A.1.6 does not reflect that the evaluation will consider this information.

Request:

Revise LRA Section A.1.6 to reflect the specific information that is considered in the ongoing evaluation of operating experience related to aging management, as stated in LRA Section 8.1.4. Otherwise, provide a justification for not including this information in the UFSAR supplement.

Discussion: The applicant requested clarification on the staff's request. The applicant felt that based upon the guidance provided in LR-ISG-2011-05, "Ongoing Review or Operating Experience," sufficient information regarding this area of further review was provided in LRA Section B.1.4. The staff clarified their desire for the applicant to provide additional detail in LRA Section A 1.6. This ORAl will be issued as a formal RAI titled "RAI 6.1.4-2."