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MONTHYEARML15075A0782015-03-18018 March 2015 Request for Additional Information Regarding Phase 2 Staffing Assessment Provided Pursuant to Title 10 of the Code of Federal Regulations Part 50, Section 50.54(f) Request Regarding NTTF Recommendation 9.3 Project stage: RAI ML15156B2602015-06-11011 June 2015 Response Regarding Phase 2 Staffing Submittals Associated with Near-Term Task Force Recommendation 9.3 Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident Project stage: Other 2015-03-18
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Category:Letter
MONTHYEARIR 05000456/20230042024-02-0202 February 2024 Integrated Inspection Report 05000456/2023004 and 05000457/2023004 ML24025C7242024-01-29029 January 2024 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000456/2024002; 05000457/2024002 IR 05000457/20230112024-01-25025 January 2024 2B Auxiliary Feedwater Pump Diesel Fuel Oil Dilution Report 05000457/2023011 and Preliminary Greater than Green Finding and Apparent Violation ML24018A0362024-01-17017 January 2024 Paragon Energy Solutions, Defect with Detroit Diesel/Mtu Fuel Injectors P/N R5229660 Cat Id 0001390618 RS-24-004, Proposed Alternative to the Distribution Requirements of ASME Code Table IWC-2411-1 for the Steam Generators2024-01-11011 January 2024 Proposed Alternative to the Distribution Requirements of ASME Code Table IWC-2411-1 for the Steam Generators ML23348A2162023-12-15015 December 2023 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0030 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) IR 05000456/20200232023-12-15015 December 2023 Baseline Security Inspection Document; 05000456/2023/402; 05000457/2023/402 ML23277A0032023-12-11011 December 2023 Issuance of Amendments Regarding Adoption of TSTF-370 ML23339A0452023-12-0505 December 2023 Request for Information for an NRC Post-Approval Site Inspection for License Renewal Inspection Report 05000546/2024010 ML23313A1552023-12-0101 December 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report ML23331A8922023-11-22022 November 2023 Supplement - Braidwood Security Rule Exemption Request ISFSI Docket No. Reference 05000457/LER-2023-001, Submittal of LER 2023-001-00 for Braidwood Station, Unit 2, Train B Auxiliary Feedwater Pump Was Inoperable Due to Degraded Oil in the Crank Case2023-11-17017 November 2023 Submittal of LER 2023-001-00 for Braidwood Station, Unit 2, Train B Auxiliary Feedwater Pump Was Inoperable Due to Degraded Oil in the Crank Case ML23321A0442023-11-17017 November 2023 Notification of Deviation from Electric Power Research Institute (EPRI) Topical Report MRP-227, Revision 1-A, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guideline RS-23-118, 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 ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums RS-23-114, Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds2023-11-0101 November 2023 Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds IR 05000456/20234012023-10-18018 October 2023 Security Baseline Inspection Report 05000456/2023401 and 05000457/2023401 IR 05000456/20230102023-10-18018 October 2023 Functional Engineering Inspection Commercial Grade Dedication Report 05000456/2023010 and 05000457/2023010 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 RS-23-108, Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator Pressure Retaining Welds and Full Penetration Welded Nozzles2023-10-11011 October 2023 Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator Pressure Retaining Welds and Full Penetration Welded Nozzles RS-23-105, Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections2023-10-10010 October 2023 Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections RS-23-093, License Amendment to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, Technical Specifications 3.7.15, Spent Fuel Pool Boron Concentration, 3.7.16, Spent Fuel.2023-09-29029 September 2023 License Amendment to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, Technical Specifications 3.7.15, Spent Fuel Pool Boron Concentration, 3.7.16, Spent Fuel. ML23226A0062023-09-19019 September 2023 Review of License Renewal Commitment Number 10 Submittal ML23180A1692023-09-11011 September 2023 Calvert Cliff Units 1 & 2, and R.E. Ginna Plant - Withdrawal of Proposed Alternatives to American Society of Mechanical Engineers (ASME) Requirements (Epids L-2022-LRR-0074, 0076, 0079, 0091, 0092, 0093 and 0094) IR 05000456/20230052023-08-30030 August 2023 Updated Inspection Plan for Braidwood Station Report 05000456/2023005 and 05000457/2023005 ML23234A2462023-08-25025 August 2023 Confirmation of Initial License Examination IR 05000456/20230022023-08-0303 August 2023 Integrated Inspection Report 05000456/2023002 and 05000457/2023002 ML23188A1292023-07-26026 July 2023 Issuance of Amendment Nos. 233 and 233 Adoption of TSTF-577, Revised Frequencies for Steam Generator Tube Inspections, Revision 1 ML23087A0762023-07-13013 July 2023 Issuance of Amendment Nos. 232 and 232 Revision of Technical Specifications for the Ultimate Heat Sink ML23191A8442023-07-10010 July 2023 05000456; 05000457 Notification of an NRC Biennial Licensed Operator Requalification Program Inspection and Request for Information ML23178A2422023-06-28028 June 2023 Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch III RS-23-083, Withdrawal - Proposed Alternatives Related to the Steam Generators2023-06-27027 June 2023 Withdrawal - Proposed Alternatives Related to the Steam Generators 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 ML23110A1152023-06-12012 June 2023 Environmental Assessment and Finding of No Significant Impact Related to a Requested Increase in Ultimate Heat Sink Temperature (EPID L-2023-LLA-0042) (Letter) RS-23-074, Supplement to Application for License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2023-06-0909 June 2023 Supplement to Application for License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink RS-23-075, Application for Technical Specification Improvement to Extend the Completion Time for Condition B of Technical Specification 3.5.1, Accumulators, Using the Consolidated Line Item Improvement Process2023-06-0707 June 2023 Application for Technical Specification Improvement to Extend the Completion Time for Condition B of Technical Specification 3.5.1, Accumulators, Using the Consolidated Line Item Improvement Process RS-23-050, Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube.2023-05-22022 May 2023 Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube. ML23138A1342023-05-18018 May 2023 Information Meeting with a Question and Answer Session to Discuss NRC 2022 End-Of-Cycle Plant Performance Assessment of Braidwood Station and Byron Station ML23132A0472023-05-12012 May 2023 Submittal of 2022 Annual Radiological Environmental Operating Report ML23130A0072023-05-10010 May 2023 Submittal of Core Operating Limits Report Cycle 24, Rev. 16 IR 05000456/20230012023-05-0808 May 2023 Integrated Inspection Report 05000456/2023001 and 05000457/2023001 ML23114A2522023-04-28028 April 2023 Request to Use a Provision of a Later Edition of the ASME Boiler & Pressure Vessel Code, Section XI ML23118A0202023-04-28028 April 2023 Submittal of 2022 Annual Radioactive Effluent Release Report ML23110A3202023-04-21021 April 2023 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection RS-23-056, Response to Request for Additional Information to Braidwood Station, Unit 1, and Byron Station, Unit 1, for Steam Generator License Renewal Response to Commitment 102023-04-20020 April 2023 Response to Request for Additional Information to Braidwood Station, Unit 1, and Byron Station, Unit 1, for Steam Generator License Renewal Response to Commitment 10 RS-23-055, Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors2023-04-10010 April 2023 Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors ML23095A1292023-04-0505 April 2023 Steam Generator Tube Inspection Report for Refueling Outage 23 ML23094A1352023-04-0404 April 2023 Request for Information for Nrc Commercial Grade Dedication Inspection Inspection Report 05000456/2023010 05000457/2023010 RS-23-052, License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2023-03-24024 March 2023 License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink RS-23-049, Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-23023 March 2023 Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations 2024-02-02
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June 11, 2015 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)
Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
BRAIDWOOD STATION, UNITS 1 AND 2 - RESPONSE REGARDING PHASE 2 STAFFING SUBMITTALS ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION 9.3 RELATED TO THE FUKUSHIMA DAl-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NOS. MF5340 AND MF5341)
Dear Mr. Hanson:
By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340), the U.S. Nuclear Regulatory Commission (NRC) issued a request for information pursuant to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Section 50.54(f) (hereafter referred to as the 50.54(f) letter), regarding Recommendations 2.1 (seismic and flooding evaluations), 2.3 (seismic and flooding walkdowns), and 9.3 (emergency preparedness communication and staffing) of the Near-Term Task Force (NTTF) review of insights from the Fukushima Dai-ichi accident. With respect to Recommendation 9.3, Enclosure 5 to the NRC's letter requested licensees and holders of construction permits to assess their means to power communications equipment onsite and offsite during a prolonged station blackout (SBO) event and to perform a staffing assessment to determine the staff required to fill all necessary positions in response to a multi-unit event.
The 50.54(f) letter in part, required licensee responses pursuant to the provisions of 10 CFR 50.54(f) pertaining to onsite and augmented staff availability to implement the strategies discussed in the emergency plan and/or plant operating procedures including new staff or functions resulting from the assessment, any identified collateral duties, an implementation schedule to perform the assessments, any identified modifications, and any changes that have been made or will be made to the emergency plan regarding on-shift or augmented staffing. In addition, NTTF Recommendation 9.3 has a dependency on the implementation of NTTF Recommendation 4.2 (mitigating strategies). As a result of this dependency, licensees responded to the 50.54(f) letter in phases. The Phase 1 staffing assessment requested licensees to evaluate their ability to respond to a multi-unit extended loss of alternating current (ac) power (ELAP) event utilizing existing processes and procedures. The licensee responses to the 50.54(f) letter for Phase 1 staffing assessments for multi-unit sites were received and evaluated by the NRC staff by April 30, 2013. The NRC staff issued acknowledgement letters to all licensees with multi-unit sites, with the exception of San Onofre Nuclear Generating Station, by April 28, 2014.
B. Hanson Licensees were also requested to submit for NRC staff review a Phase 2 staffing assessment, which provides an assessment of the staffing necessary to perform the functions related to the strategies developed in response to NTTF Recommendation 4.2 and the resulting Order EA 049, "Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design~Basis External Events [BDBEE]" (ADAMS Accession No. ML12054A736).
Licensees were requested to provide their Phase 2 staffing assessments to the NRC no later than four months prior to the beginning of their second refueling outage (as used in the context of NRC Order EA-12-049).
By letter dated November 26, 2014 (ADAMS Accession No. ML14330A262), Exelon Generation Company, LLC (Exelon, the licensee) submitted its Phase 2 staffing assessment for Braidwood Station, Units 1 and 2 (Braidwood) to the NRC in response to the 50.54(f) letter. This submittal also references a non-public (Safeguards Information) attachment submitted by separate letter on the same date. By letter dated March 18, 2015 (ADAMS Accession No. ML15075A078, enclosure non-public Security Related Information), the NRC staff issued a request for additional information (RAI) regarding the 10 CFR 50.54(f) Phase 2 Staffing Assessment for Braidwood. The RAI requested clarification regarding the process, procedures, and training described in the Phase 2 submittal for the use of supplemental personnel in the response to a BDBEE. By letter dated April 13, 2015 (ADAMS Accession No. ML15103A499), Exelon provided a response to the RAI, which included the requested additional information and clarification on the process, procedures, and training for the response to a BDBEE, as described in the initial submittal.
The NRC staff reviewed your Phase 2 assessment and RAI response for staffing in accordance with the assumptions and guidelines of Sections 2.2, 2.3, and 3 of the Nuclear Energy Institute (NEI) guidance document NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," (ADAMS Accession No. ML12125A412),
which was endorsed by the NRC staff by letter dated May 15, 2012 (ADAMS Accession No. ML12131A043). The NRC staff noted that you assessed your current onsite minimum staffing levels to identify any enhancements needed to respond following a beyond-design-basis large-scale natural event, and to ensure that the strategies contained in the existing emergency plan and/or plant operating procedures, such as those used in response to a SBO, can be performed by the site staff. Your assessment assumed that a large-scale natural event causes: (1) an ELAP, (2) all units on the site to be affected, and (3) access to the site to be impeded for a minimum of six hours. You also assessed your capability to perform the site specific functions related to the strategies developed in response to NTTF Recommendation 4.2 and the resulting Order EA-12-049. You conducted independent reviews and concluded, based on your staffing assessment, that the existing on-shift minimum staff is sufficient to implement the existing loss of all ac power, multi-unit event response strategies, including those strategies developed to support the requirements of NRC Order EA-12-049, while supporting performance of the required emergency planning duties without unacceptable collateral duties.
The NRC staff reviewed your Phase 2 staffing submittal and your RAI response and confirmed that your existing emergency response resources, as described in your emergency plan, are sufficient to perform the required plant actions and emergency plan functions, and implement the multi-unit event response strategies that were developed in response to NRC Order EA 049 without the assignment of collateral duties that would impact the performance of assigned emergency plan functions.
B. Hanson As a result, the NRC staff concludes that your Phase 2 staffing submittal and RAI responses adequately address the response strategies needed to respond to a BDBEE using your procedures and guidelines. The NRC staff will verify the implementation of your staffing capabilities through the inspection program.
If you have any questions regarding this letter, please contact Stephen Philpott at (301) 415-2365 or via email at Stephen.Philpott@nrc.gov.
Sincerely,
!Jl~~
Mandy K. Halter, Acting Chief Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos. STN 50-456 and STN 50-457 cc: Distribution via Listserv
ML151568260 *via email OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NSIR/DPR/DDEP/NRLB/BC* NRR/JLD/JOMB/BC(A)
NAME SPhiloott Slent ARivera (KThomas for) MHalter DATE 06/10/15 06/08/15 06/10/15 06/11/15