ML20085L688
| ML20085L688 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 04/02/2020 |
| From: | V Sreenivas NRC/NRR/DORL/LPL1 |
| To: | Bryan Hanson Exelon Generation Co, Exelon Nuclear |
| Sreenivas, V. | |
| References | |
| EPID L-2020-LLA-0031 | |
| Download: ML20085L688 (6) | |
Text
April 2, 2020 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
R. E. GINNA NUCLEAR POWER PLANT - AUDIT
SUMMARY
IN SUPPORT OF LICENSE AMENDMENT REQUEST TO SUPPORT SHUT DOWN OF REACTOR DURING UPCOMING REFUELING OUTAGE (EPID L-2020-LLA-0031)
Dear Mr. Hanson:
By letter dated February 25, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20056E958), as supplemented by letters dated March 5, 2020 (ADAMS Accession No. ML20066E040); March 12, 2020 (ADAMS Accession No. ML20073E229); and March 20, 2020 (ADAMS Accession No. ML20080N889), Exelon Generation Company, LLC (the licensee) submitted a license amendment request to revise R. E. Ginna Nuclear Power Plant (Ginna) Technical Specifications 3.4.7, RCS [Reactor Coolant System] Loops - MODE 5, Loops Filled; 3.4.8, RCS Loops - MODE 5, Loops Not Filled; 3.9.4, Residual Heat Removal (RHR) and Coolant Circulation - Water Level 23 Ft; and 3.9.5, Residual Heat Removal (RHR) and Coolant Circulation - Water Level < 23 Ft, to add an asterisk to allow the use of alternative means for RHR.
The U.S. Nuclear Regulatory Commission (NRC) staff reviewed the licensees submittals and determined that a regulatory audit would assist in the timely completion of the licensing review process. The NRC staff issued the regulatory audit plan on March 10, 2020 (ADAMS Accession No. ML20070L025).
The regulatory audit was conducted remotely through the use of Skype meetings and an internet portal from March 17 to March 18, 2020. The results of the audit will be used by the NRC staff to finalize requests for additional information.
If you have any questions, please contact me at 301-415-2597 or V.Sreenivas@nrc.gov.
Sincerely,
/RA/
V. Sreenivas, Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosure:
Regulatory Audit Summary cc: Listserv
- by e-mail OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/SNSB/BC(A)* NRR/DORL/LPL1/BC NAME VSreenivas LRonewicz JBorromeo JDanna DATE 03/27/2020 03/27/2020 03/27/2020 04/02/2020 OFFICE NRR/DORL/LPL1/PM NAME VSreenivas DATE 04/02/2020
Enclosure REGULATORY AUDIT
SUMMARY
FOR AUDIT IN SUPPORT OF REVIEW OF LICENSE AMENDMENT REQUEST TO ADD A ONE-TIME NOTE FOR USE OF ALTERNATE RESIDUAL HEAT REMOVAL METHODS EXELON GENERATION COMPANY, LLC R. E. GINNA NUCLEAR POWER PLANT DOCKET NO. 50-244
1.0 BACKGROUND
By letter dated February 25, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20056E958), as supplemented by letters dated March 5, 2020 (ADAMS Accession No. ML20066E040); March 12, 2020 (ADAMS Accession No. ML20073E229); and March 20, 2020 (ADAMS Accession No. ML20080N889), Exelon Generation Company, LLC (Exelon or the licensee) submitted a license amendment request (LAR) to revise R. E. Ginna Nuclear Power Plant (Ginna) Technical Specifications 3.4.7, RCS
[Reactor Coolant System] Loops - MODE 5, Loops Filled; 3.4.8, RCS Loops - MODE 5, Loops Not Filled; 3.9.4, Residual Heat Removal (RHR) and Coolant Circulation - Water Level 23 Ft; and 3.9.5, Residual Heat Removal (RHR) and Coolant Circulation - Water Level
< 23 Ft, to add an asterisk to allow the use of alternative means for RHR.
An audit plan was issued by the U.S. Nuclear Regulatory Commission (NRC) staff by letter dated March 10, 2020 (ADAMS Accession No. ML20070L025). The purpose of the audit was for NRC staff to view supporting analysis, calculations, and documentation associated with use of alternate means of RHR due to the possibility of not being able to open the normal RHR suction valve Motor-Operated Valve (MOV) 700 and have technical discussions with the licensee.
2.0 AUDIT DATES AND LOCATION The regulatory audit was conducted remotely through the use of Skype meetings and an internet portal from March 17 to March 18, 2020.
3.0 AUDIT TEAM MEMBERS The NRC audit team members consisted of:
Robert Beaton, Nuclear Engineer, NRR/DSS/SNSB Joshua Borromeo, Acting Chief, NRR/DSS/SNSB (Audit Team Lead)
Victor Cusumano, Chief, NRR/DSS/STSB Ravi Grover, Safety and Plant Systems Engineer, NRR/DSS/STSB Jim Hickey, Senior Level Advisor, NRR/DSS Matt Leech, Risk and Reliability Analyst, NRR/DRA/APOB Kevin Mangan, Senior Reactor Inspector, R-I/DRS/EB1 Jason Schussler, Senior Resident Inspector, R-I/DRP/PB1/GRO Josh Wilson, Reactor Systems Engineer, NRR/DSS/SNSB 4.0 DOCUMENTS AUDITED The following documents were made available for NRC staff review:
Exelon calculation ESR-18-0277, Revision 000, January 2020 (no title)
Red Wolf Associates calculation RWA-1906-003, Ginna Water Solid Steam Generator Cooldown with Alternate RHR Configurations, Revision 0 (undated)
Westinghouse calculation CN-SEE-04-84, Ginna Uprate Cooldown Analysis, Revision 0 (undated) 5.0 AUDIT ACTIVITIES AND
SUMMARY
The majority of the staffs questions were focused on the proposed water solid steam generator cooldown method, which was subsequently withdrawn, making these questions moot. During the audit, the licensee provided presentations and responded to the staffs questions. This included presentations on the operating history of MOV 700 and walkthroughs of the flow paths for the proposed alternative RHR configurations.
The licensee discussed that it has not completed the design configuration of the alternate RHR and noted that it has changed since what was included in the LAR submittals. The NRC staff and licensee discussed the minimum requirements (e.g., flow rates) for the system once finalized.
Discussions were held on the details of the technical specifications change, and the NRC staff made comments on the proposed note. There were also discussions about the scope of the LAR related to what was being changed under Title 10 of the Code of Federal Regulations Section 50.59 versus what is being requested in the LAR. This gave the staff a better understanding of what specifically was being sought for approval.
The NRC staff reviewed the documents listed in Section 4.0 of this safety evaluation and provided several questions to the licensee. The licensee satisfactorily answered the NRC staffs questions. One item of note is that the NRC staff requested the calculations that demonstrate adequate flow would still be achieved through the proposed alternative RHR; however, the licensee noted that the design was not finalized yet and the calculations were not available.
This document review helped the staff validate the licensees design rationale.
Based on the technical discussions and review of the calculations made available in support of the proposed change, the NRC staff requested the licensee provide several items on the docket that were needed to make a regulatory determination. These items included revised wording on the proposed technical specification note, a general timeline of events in order to place the alternate RHR in service, information related to the partial opening of MOV 700, and discussion of the minimum required RHR flowrates needed. The licensee stated that it would provide a supplement to the LAR addressing these items.