ML21033A625
| ML21033A625 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/16/2021 |
| From: | Marshall M Plant Licensing Branch 1 |
| To: | Rhoades D Exelon Nuclear, Exelon Generation Co |
| Marshall M, NRR/DORL/LPL1, 415-2871 | |
| References | |
| EPID L-2020-LLA-0276 | |
| Download: ML21033A625 (6) | |
Text
February 16, 2021 LICENSEE:
Exelon Generation Company, LLC FACILITY:
Nine Mile Point Nuclear Station, Unit 1
SUBJECT:
SUMMARY
OF JANUARY 5, 2021, MEETING WITH EXELON GENERATION COMPANY, LLC REGARDING LICENSE AMENDMENT REQUEST TO ADOPT REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL ENHANCEMENTS AT NINE MILE POINT NUCLEAR STATION, UNIT 1 (EPID L-2020-LLA-0276)
On January 5, 2021, 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) using a video conferencing platform. The purpose of the meeting was to discuss the license amendment request (LAR) for Nine Mile Point Nuclear Station, Unit 1 (Nine Mile Point 1) to adopt Technical Specifications Task Force (TSTF) Traveler TSTF-582, RPV
[Reactor Pressure Vessel] WIC [Water Inventory Control] Enhancements (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19240A260).
Specifically, the meeting was held to discuss how closely the LAR submitted by the licensee aligns with the consolidated line item improvement process (CLIIP) and the licensees requested completion date for the review of the LAR. The meeting notice and agenda, dated December 21, 2020, are available in ADAMS at Accession No. ML20356A252. A list of attendees is provided as Enclosure 1. The handout used by the NRC staff is provided in.
By letter dated December 18, 2020 (ADAMS Accession No. ML20353A401), Exelon submitted a LAR to adopt TSTF-582 for Nine Mile Point 1. In its request, the licensee asked the NRC to process the request as a CLIIP and to complete the review by February 28, 2021 (i.e.,
approximately a 2-month review) to support a planned refueling outage. At the time of the meeting, the NRC staff had not started a detailed technical review. The LAR was undergoing an acceptance review to determine whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
During the meeting, the NRC staff described several challenges with the LAR that would be impediments to conducting the review as a CLIIP and completing the review within 2 months. In the handout shared with the representatives of Exelon, the NRC staff listed several observations from the LAR that were inconsistent with the criteria for being reviewed as a CLIIP. The staff identified variations from TSTF-582 related to the custom technical specifications used at Nine Mile Point 1, variations from TSTF-582 that needed plant-specific justification, and parts of the LAR that would require additional technical review beyond what would be expected for TSTF-582. The NRC staff shared with the licensee that LAR reviewed as a CLIIP did not typically need a request for additional information, and a possible need for a request for additional information would add at least 60 days to a review. The NRC staff informed the licensee that the observation shared was not a comprehensive list of parts of the LAR that would possibly lead to a request for additional information.
In response to the NRC staffs observation, the licensee provided clarification of parts of its LAR and described how TSTF-582 was adapted to the custom technical specifications of Nine Mile Point 1. In response to NRC staffs question about the impact of the review being completed after the planned refueling outage for Nine Mile Point 1, the licensee stated it was seeking dose savings, manpower reductions, and to avoid any impact on seismic support surveillance requirements.
No regulatory decisions were made during the meeting. The NRC staff informed the representatives of Exelon that the decision about whether to conduct the review as a CLIIP and the estimated date of completion of the review would be communicated to the licensee in acceptance correspondence.
No members of the public were in attendance. No public meeting feedback forms were received.
Please direct any inquiries to me at 301-415-2871 or Michael.Marshall@nrc.gov.
/RA/
Michael L. Marshall, Jr., Senior Project Manager Plant Licensing Branch I Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-220
Enclosures:
- 1. List of Attendees
- 2. NRC Staff Handout cc: Listserv LIST OF ATTENDEES JANUARY 5, 2021, MEETING WITH EXELON GENERATION COMPANY, LLC REGARDING LICENSE AMENDMENT REQUEST TO ADOPT REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL ENHANCEMENTS AT NINE MILE POINT, UNIT 1 Name Organization James Danna U.S. Nuclear Regulatory Commission (NRC)
Michael Marshall NRC Tarico Sweat NRC Khadijah West NRC Pasquale Bartolini Exelon Generation Company, LLC (Exelon)
Austin OConner Exelon Ronald Reynolds Exelon Brandon Shultz Exelon Denise Wolniak Exelon
1 of 2 Nine Mile Point Unit 1, Request to Adopt TSTF-582 (RPV WIC Enhancements)
Submittal Date: 12/18/20 ADAMS Accession No. ML20353A401 Potential Issues with Application to Share at 01/05/2021 Public Meeting Since a shortened review period was requested in this submittal, we are having a public meeting to discuss application questions. Some questions may become official requests for additional information (RAIs).
Criteria for review under the CLIIP process:
o LIC-101, Section 8.2.2: The level of conformity to the model application (including differences between the plant-specific [technical specifications] and the [standard technical specifications]) will determine whether the amendment will be reviewed as a CLIIP amendment (with an accelerated review schedule) or as a normal license amendment (with a review schedule consistent with the normal timeliness goals).
o LIC-600, Section 4.2.1: [] Theses travelers generally meet the following criteria:
not overly complex; few if any plant-specific variations expected; little plant-specific data/analysis required; and no technical branch input needed for the LAR review.
[]
Potential Issues with Application that May Warrant RAIs or Discussion*
Comment/Question TS LAR Page 1
A crosswalk between the NMP1 custom TS and STS NUREG-1433 (TSTF-582) would have been helpful.
NUREG-1433 has some design assumptions that are more than slightly different from NMP1. For proposed changes, differences in numbering, system name, design should be fully explained for a more efficient review. For instance, the low pressure emergency core cooling system described in TSTF-582 is comprised of Core Spray and Low Pressure Coolant Injection Systems.
N/A 2
The last optional change is a technical change and needs review or concurrence from an instrumentation and controls technical branch. Proposed change to number of required channels from 2 to 1 per trip system.
More detail describing why the change is proposed would be helpful.
TS Table 3.6.2m, Primary Coolant Isolation parameter,
Page 3 of 6 3
The list of TSTF-582 TS changes include Improvements 1 through 4 and Corrections 10 and 11. Assuming number 5 and 6 on page 3 correspond to 10 and 11 in TSTF-582 model application.
Number 5 (changes to NMP1 LCO 3.2.7) needs more explanation to clarify what is different from TSTF-582 (e.g.,
TS wording, formatting differences, design, etc.)
pages 2 and 3 of 6
2 of 2 Potential Issues with Application that May Warrant RAIs or Discussion*
Comment/Question TS LAR Page 4
Why is Manual a separate parameter from Primary Coolant Isolation? Which Table 3.6.2m notes apply when it is inoperable? There are no notes next to it like the other parameters.
NMP1 TS Table 3.6.2m NMP1 TS Page 247c 5
Proposed new Note (c)1 -
Missing completion time immediately Typo error: in the trip condition does not align with NMP1 instrumentation TSs which states, in the tripped condition in other LCO 3.6.2 tables.
NMP1 TS Table notes 3.6.2 m NMP1 TS Page 247f 6
Proposed new Note (c)2 states, Take the Action required by Specification 3.6.2 a for that parameter. Explain how this is equivalent to TSTF-582 STS 3.3.5.2 new Required Action A.2.1 (Declare associated penetration flow path(s) incapable of automatic isolation) and A.2.2 (Initiate action to calculate DRAIN TIME.)
NMP1 TS Table notes 3.6.2 m NMP1 TS Page 247f
- The potential issues listed in this table do not represent a complete set of potential issues with the application. The application is currently undergoing acceptance review, and the detailed technical review has not been started. Additional potential issues may be found during the detailed technical review.
Meeting Notice ML20356A252; Meeting Summary ML21033A625 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME MMarshall JBurkhardt JDanna MMarshall DATE 02/03/2021 02/03/2021 02/16/2021 02/16/2021