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MONTHYEARML20016A2282020-01-27027 January 2020 Summary of Teleconference Meeting with Exelon Generation Company, Lasalle County Station, Units 1 and 2 on Pre-Application Teleconference on License Amendment Requests on TSTF-505, 10 CFR 50.69 Project stage: Meeting 2020-01-27
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Category:Meeting Summary
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UNITED STATES WASHINGTON, D.C. 20555-0001 January 27, 2020 LICENSEE: Exelon Generation Company FACILITY: LaSalle County Station, Units 1 and 2
SUBJECT:
SUMMARY
OF JANUARY 9, 2020, TELECONFERENCE MEETING WITH EXELON GENERATION COMPANY, LASALLE COUNTY STATION, UNITS 1 AND 2, ON PRE-APPLICATION TELECONFERENCE ON LICENSE AMENDMENT REQUESTS ON TECHNICAL SPECIFICATION TASK FORCE (TSTF)-505 TITLE 10 CODE OF FEDERAL REGULATIONS (10 CFR) 50.69 (EPID L-2019-LRM-0095)
On January 9, 2020, a Category 1 public teleconference was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Exelon Generation Company (the licensee) at NRC Headquarters, One White Flint North, 11555 Rockville Pike, Rockville, Maryland. The purpose of this meeting was to discuss Exelon's plans and schedule related to the planned submittal of license amendment requests (LARs) for the LaSalle County Station, Units 1 and 2. The planned amendment would adopt TSTF-505, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b," and adopt a risk-informed 10 CFR 50.69 categorization program.
The meeting notice and agenda, dated December 23, 2019, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML19357A137. A list of attendees is provided as Enclosure 1.
The licensee presented information (see Enclosure 2) which included: license amendment development; timeline for submissions; probabilistic risk analysis (PRA) model technical adequacy; open findings and observations; PRA model uncertainties and assumptions; external hazards; and potential review efficiencies. Exelon also stated that the two applications are expected to be submitted by the end of January, 2020, and to request a 12-month completion.
The NRC staff queried the licensee about observations which included the following areas: identifying relevant differences in the boiling-water reactor (BWR)/5 design to the BWR/4 design, FLEX equipment credit in PRA, details on the Seismic Tier 2 approach, and the reviews completed for the screening analysis. The NRC staff indicated that based on its review of the LARs, it would determine whether it can support the requested completion timeline.
Exelon stated that the LARs would address the comments and concerns raised by the staff in this teleconference.
No regulatory decisions were made as a result of this teleconference.
Members of the public were in attendance. Public Meeting Feedback forms were not received.
/RA/
Bhalchandra K. Vaidya, Project Manager Plant Licensing Branch Ill Division Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-373 and 50-37 4
Enclosures:
- 1. List of Attendees
- 2. Exelon/Lasalle Presentation cc: Listserv
ENCLOSURE 1 EXELON/LASALLE PRESENTATION
LIST OF ATTENDEES FOR THE CATEGORY 1 PRE-APPLICATION PUBLIC TELEPHONE CONFERENCE WITH EXELON/LaSALLE REGARING TSTF-505 AND 10 CFR 50.69 LICENSE AMENDMENT APPLICATIONS JANUARY 9, 2020 NRC/NRR Dan Wildrevitz, NRR/DNRL/NVIB Khadijah West, NRR/DE/EICB Milton Valentin, Beyond Design Basis Bob Vettori, NRR/DRA/APLB Management (Fukushima), NRR/DORL/LPMB Todd Hilsmeier, NRR/DRA/APLA EXELON Dave Gullett Philip Tarpinian Dwi Murray Jason Taken Shannon Rafferty-Czincila Phillip Henderson Ryan Sprengel Ken Nicely Gene Kelly Patrick Johnson EPRI Patrick O'Regan John Richards JENSEN HUGHES Jeff Schappaugh Nick Sternowski Patrick Johnson David Passehl CJ Standridge AMERICAN MISSOURI, CALLAWAY ENERGY CENTER Andrew Burgess Bruce Huhmann Nathan Casey Enclosure 1
LIST OF ATTENDEES FOR THE CATEGORY 1 PRE-APPLICATION PUBLIC TELEPHONE CONFERENCE WITH LASALLE REGARING TSTF-505 AND 10 CFR 50.69 APPLICATIONS JANUARY 9, 2020 NAME TITLE ORGANIZATION
LIST OF ATTENDEES FOR THE CATEGORY 1 PRE-APPLICATION PUBLIC TELEPHONE CONFERENCE WITH LASALLE REGARING TSTF-505 AND 10 CFR 50.69 APPLICATIONS JANUARY 9, 2020 NAME TITLE ORGANIZATION
ENCLOSURE2 EXELON/LASALLE PRESENTATION
I I Rya Sprengel, Ion Ster ows i, J nsen Hughes J h Ri h rds, PRI Phil rpinian, Exelo Stan nd , J Hughes II lo Ja 1
- License Amendment Development
- PRA Model Technical Adequacy
- Open Findings and Observations
- PRA Model Uncertainties and Assumptions
- Potential Review Efficiencies 2
- No deviation from LAR template (except seismic)
- New TS Section 6.0
- BWR/5 reactor design; Mark II containment
- TS markups follow TSTF-505 for BWR/4
- LaSalle TS are ITS
- Variances from TSTF-505 in nomenclatur e/sequencin g
- TSTF-505 LCOs/Condit ions not in LaSalle TS 3
- Submittals will consist of two separate applications (RICT and 50.69)
- Submittal for both targeted by end of January 2020
- Changes to the schedule will be communicated to NRR Project Manager 4
- Gap analysis against Rev. 2 and current version of Standard performed as part of the 2014 FPIE PRA update
- Closure review performed
- 5 Open F&Os
- Closure review performed
- 3 Open F&Os
- Open findings will be addressed in 2020 update 5
Three open fire model F&Os
- 1-19 (Suggestion): Review of interlock & power supply notes in circuit analysis packages for potentially missed dependencies
- 4-17 (Finding): Plant-specific unavailability data for automatic FSD
- 6-11 (Finding): Cable data in Fire Safe Shutdown report (NEl-00-01)
Five open internal events model F&Os
- IE-D3-01 (Finding): Documentation of sources of uncertainty in LERF
- SY-A4-01 (Suggestion): Perform plant walkdowns with system engineers/ plant operators & document the walkdowns performed
- DA-C8-01 (Finding): Plant-specific data review for standby alignments
- DA-C6-01 (Suggestion): Enhance documentation of data collections
- IF-C3b-01 (Suggestion): Enhance documentation of the potential unavailability of flood barriers that may impact propagation 6
Both LaSalle submittals will follow the process defined in NUREG 1855 Rev. 1, EPRI 1016737 and EPRI 1026511
- Assessment of potential sources key to respective applications; disposition/treatment for application
- Identification of internal event/flooding plant-specific sources and generic sources per EPRI 1016737
- Identification of Fire PRA plant-specific sources and generic sources per Appendix B of EPRI 1026511
- Consideration of generic Level 2 sources per EPRI 1026511 Appendix E as applicable to LERF
- Consideration of parameter & completeness uncertainties 7
- Reviewed Current Hazard Information
- Updated Analysis Using Part 6 Screening Criteria of ASME/ANS PRA Standard RA-Sa-2009
- Performed conservative or bounding analyses
- Justify exclusion of external risk sources from models based on their insignificance to the calculation of configuration risk
- Figure 5-6, "Other External Hazards"
- Seismic Tier 2 - EPRI alternative approach (3002012988) 8
- LaSalle considered a Tier 2 site
- Moderate Seismic Hazard/Moderate Seismic Margin site
- GMRS comparison to SSE between 1-10 Hz> Tier 1 but not high enough to be treated as Tier 3
- GMRS is< SSE up through 6Hz; > SSE above 6 Hz.
- NRC screened LaSalle from performing an SPRA
- IDP informed of SSC-specific seismic insights for HSS/LSS
- Documented/presented to IDP for each system
- Risk-Informed graded approach for a Tier 2 plant
- RICT - Will Use Seismic Penalty Approach for RICT 9
- Section 7 of LaSalle IPEEE submittal contains a bounding analysis for high winds and tornado
- Median frequency of CDF due to tornadoes 3E-7/year
- Demonstrably conservative estimate< 1E-6/yr. based on
- plant design for wind pressure
- low frequency (< 1E-7/yr) of tornadoes
- Non-missile high wind hazards screened from consideration based on EXT-Ci Criterion C of ASME/ANS RA-Sa-2009 10
- External flooding hazard recently updated/submitted to NRC
- Flooding from all mechanisms except local intense precipitation (LIP) and probable maximum storm surge (PMSS) are bounded
- LIP maximum still water elevation levels (SWELs) exceed the CLB and cause ponding to occur at exterior doors
- Ingress is limited and available physical margin exists
- RICT: Plant able to mitigate flood-causing mechanisms with permanently installed passive flood protection (e.g. exterior doors and plant grade) that require no manual action
- 50.69: List of exterior doors credited to slow water intrusion
- Doors treated as HSS per NEI 00-04 Figure 5-6
Overlaps in level of PRA model acceptability Level of PRA Acceptability Depends on the Application I
I Acceptability Required scope, I ** Greater reliance on level of detailt I PRA technical I. More flexibility for licensee robustness, and I ., More complex staff plant representation .
I review I
I I
Reference:
ML190648049, NRR Presentation January 30-31, 2019 12
RICT - No deviation from model LAR 50.69 - No deviation from template (except seismic)
PRA Models
- PRA technical adequacy and sources of uncertainty similar for both applications
- Application-specific insights considered
- Common screening of hazards that can be screened
- Application-specific assessment of screening impact but related in terms of details to be considered
- Same PRA teams reviewing common information 13
- Incorporated lessons learned from previous submittals
- Sensitivity studies for key areas of uncertainty
- Loss of function TS LCO's evaluated closely
- Risk-informed graded approach Tier 2 seismic alternative 14
Meeting Notice- ML19357A137 ADAMS Accession No. Meeting Summary- ML20016A228 OFFICE NRR/D0RL/LPL3/PM NRR/D0RL/LPL3/LA NRR/D0RL/LPL3/BC NRR/D0RL/LPL3/PM NAME BVaidya SRohrer NSalgado BVaidya DATE 1/16/2020 1/16/2020 1/27/2020 1/27/2020