ML19183A128

From kanterella
Jump to navigation Jump to search

Summary of June 20, 2019, Meeting with Exelon Generation Company, LLC, on a Planned License Amendment Request Regarding Main Steam Isolation Valve Leak Rate Increase Utilizing
ML19183A128
Person / Time
Site: FitzPatrick Constellation icon.png
Issue date: 07/15/2019
From: Carleen Parker
Plant Licensing Branch 1
To: Bryan Hanson
Exelon Generation Co
Parker C
References
EPID L-2019-LRM-0032
Download: ML19183A128 (5)


Text

July 15, 2019 LICENSEE: Exelon Generation Company, LLC FACILITY: James A. FitzPatrick Nuclear Power Plant

SUBJECT:

SUMMARY

OF JUNE 20, 2019, MEETING WITH EXELON GENERATION COMPANY, LLC, ON A PLANNED LICENSE AMENDMENT REQUEST REGARDING MAIN STEAM ISOLATION VALVE LEAK RATE INCREASE UTILIZING ALTERNATE SOURCE TERM ANALYSIS (EPID L-2019-LRM-0032)

On June 20, 2019, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Exelon Generation Company, LLC (Exelon, the licensee) at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of the meeting was to discuss the licensees plan to submit a license amendment request (LAR) regarding main steam isolation valve leak rate increase utilizing alternate source term (AST) analysis at the James A. FitzPatrick Nuclear Power Plant (FitzPatrick). The meeting notice and agenda, dated May 28, 2019, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML19156A264. A list of attendees is enclosed.

The licensee presented an overview of its plans to submit the license amendment request for FitzPatrick. The presentation closely followed Exelons slides provided for the meeting (ADAMS Accession No. ML19168A159).

The licensee stated that FitzPatrick currently has a partial AST approved for fuel handing accidents only. The planned LAR would request to expand the AST scope to full implementation and include an increase in main steam isolation valve local leak rate testing limits and addition of a secondary containment drawdown time. The licensee stated that the loss-of-coolant analysis and the Gothic computer code analysis will be provided as part of the LAR. The licensee stated that there are no planned physical equipment modifications for this request. The licensee is using the Quad Cities Nuclear Power Station, Units 1 and 2, application dated March 5, 2019, as precedent (ADAMS Accession No. ML19064B369). The Quad Cities Nuclear Power Station, Units 1 and 2, application is currently under NRC review.

The NRC staff provided some feedback to the licensee, including the following:

When referencing precedence, discuss how it is applicable to FitzPatrick.

The licensee should consider including a discussion of the meteorological data in the LAR.

When providing dose information, it is helpful to provide the dose value for each pathway in addition to the total dose.

Since the FitzPatrick licensing basis does not currently credit drywell sprays for aerosol removal, the licensee should consider including a detailed description of the proposed change to add credit for drywell sprays to the licensing basis.

Since the precedent cited for the proposed main steam line aerosol deposition did not include drywell sprays, the licensee should consider including a detailed discussion of how the use of sprays is accounted for in the subsequent steam line aerosol deposition.

The inclusion of a comparison of the dose with credit for sprays and steam line deposition to the dose without these aerosol deposition credits would be helpful for the NRC staffs review.

The licensee should consider including if the current environmental qualification of equipment is bounding or if testing/analysis was utilized or if the environment is mild.

The licensee should consider addressing control room access, specifically how Title 10 of the Code of Federal Regulations (10 CFR) Part 50.67, Accident source term, and General Design Criteria 19, Control Room, will continue to be met.

The licensee needs to address the requirements contained in 10 CFR 50.36, Technical specifications (TSs), when deleting TS limiting conditions for operation and adding surveillance requirements.

The licensee needs to clearly define dose equivalent iodine-131 in the FitzPatrick TSs so that the definition remains applicable to all design-basis accidents that utilize iodine dose conversion factors. The licensee should consider changing the dose conversion factor terminology from total effective dose equivalent to committed effective dose equivalent for the loss of coolant and fuel handling accidents, in addition to accounting for the different iodine dose conversation factors used in the different design-basis accidents.

In the licensees presentation, two items are shown to be inserted into primary containment leakage rate testing program in the TSs. These items state an exemption from a specific portion of 10 CFR Part 50, Appendix J, will be taken. It was not clear to the NRC staff if an exemption request was going to be part of the submittal. Therefore, the NRC staff provided feedback that the term exemption has specific regulatory meaning, and that if it is the licensees intention to request an exemption, the licensee should provide the exemption request with the necessary information and ensure the correct regulatory processes are used. In addition, if an exemption request is submitted, it should be accounted for in the licensees requested review time schedule.

The licensee needs to address the seismic adequacy of mechanical and electrical equipment as the basis for negating the seismic qualification requirements for systems, structures, and components (such as main steam isolation valves leakage bypass piping and other piping systems, electrical equipment, heating, ventilation, and air condition system components (including the control room and auxiliary electrical equipment room, etc.)), credited in an AST LAR.

The licensee is required to show that all systems, structures, and components credited for AST shall be structurally capable of remaining functional during and following a safe shutdown earthquake.

The schedule currently calls for the LAR to be submitted in July 2019. This is a change from the schedule noted in the licensees slides.

Members of the public were not in attendance. Public Meeting Feedback forms were not received.

Please direct any inquiries to me at 301-415-1603 or Carleen.Parker@nrc.gov.

/RA/

Carleen J. Parker, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-333

Enclosure:

List of Attendees cc: Listserv

LIST OF ATTENDEES JUNE 20, 2019, MEETING WITH EXELON GENERATION COMPANY, LLC PLANNED LICENSE AMENDMENT REQUEST REGARDING MAIN STEAM ISOLATION VALVE LEAK RATE INCREASE UTILIZING ALTERNATE SOURCE TERM ANALYSIS NRC Participants Carleen Parker John Parillo Kevin Hsueh Dan Hoang Gush Singh Carolyn Fairbanks Dan Barnhurst Jason White Matt Yoder Nageswara Karipineni Donna Williams Jorge Cintron-Rivera Sheila Ray Michael Breach Josh Borromeo Kevin Quinlan Kristy Bucholtz Muhammad Razzaque James Danna Exelon Participants Shane Gardner John Massari Ron Reynolds Bill Drews Katherine Leaveck Enclosure

ML19183A128 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME CParker LRonewicz JDanna CParker DATE 07/09/2019 07/08/2019 07/10/2019 07/15/2019