ML25226A193
| ML25226A193 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 08/28/2025 |
| From: | V Sreenivas NRC/NRR/DORL/LPL1 |
| To: | Constellation Energy Generation |
| Sreenivas V, NRR/DORL/LPL1 | |
| Shared Package | |
| ML25226A194 | List: |
| References | |
| EPID L-2025-LLA-0087 | |
| Download: ML25226A193 (1) | |
Text
August 28, 2025 LICENSEE:
Constellation Energy Generation, LLC FACILITY:
R. E. Ginna Nuclear Power Plant
SUBJECT:
SUMMARY
OF AUGUST 11, 2025, MEETING WITH CONSTELLATION ENERGY GENERATION, LLC REGARDING A LICENSE AMENDMENT TO EXTEND THE COMPLETION TIME FOR SODIUM HYDROXIDE SYSTEM (EPID: L-2025-LLA-0087)
On August 11, 2025, a virtual observation public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Constellation Energy Generation, LLC (CEG, the licensee). The purpose of the meeting was for NRC to ask clarifying questions related to the license amendment request (LAR) submitted on May 20, 2025 (Agencywide Documents Access and Management System at Accession No. ML25140A128), to extend the Completion Time (CT) for Technical Specification (TS) 3.6.6 Containment Spray (CS),
Containment Recirculation Fan Cooler (CRFC), and NaOH Systems, Required Action B Sodium Hydroxide (NaOH) system inoperable. The meeting notice and agenda, dated August 7, 2025, are available in ADAMS (ML25219A198). A list of attendees is provided as Enclosure 1.
During the discussion, the NRC staff and CEG representatives discussed the following:
The NRC staff noted the application stated that the TS change request will allow for maintenance to be performed online and eliminate the potential need for Notice of Enforcement Discretion (NOED) in the future. Therefore, the NRC staff asked for clarification on how many times a NOED has been or may be needed, or the expected duration of online repairs for the NaOH system.
The NRC staff recalled that in a licensing submittals planning discussion with the licensee on January 31, 2025, the staff noted that extending a CT for a loss of function condition would require detailed justification.
The NRC staff clarified that that TS 3.6.6, Condition B, is essentially a loss of function (post loss -of -coolant accident containment pH control) condition. Standard Technical Specification (STS) CT for similar situations provide only 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or less time to continue plant operation in this condition. The NRC staff noted that the request did not include discussion on how the lack of pH control would impact the following:
o elemental iodine evolution after spray stops o corrosion prevention during recirculation o sump strainer clogging during recirculation The NRC staff clarified that for some loss of function conditions, like Control Room Envelope, STS use mitigating actions to justify extended operation in the condition.
However, for the pH control function at Ginna, the NRC staff noted that there does not appear to be a mitigating action for pH control that could be taken during the 14-day proposed CT.
The NRC staff stated that justifying the change from 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to 14 days by referring an expected dose might not be sufficient because the application did not clearly described whether the expected dose accounted for the evolution of elemental iodine, which could occur when pH is not controlled.
The licensee mentioned their senior technical expert was unable to attend the meeting but will take the questions and respond in a follow-up email.
The NRC staff did not make any regulatory decisions during the meeting. Members of the public were not in attendance. Public Meeting Feedback forms were available, but no comments were received.
Please direct any inquiries by email to V. Sreenivas@nrc.gov or 301-415-2597.
/RA/
V. Sreenivas, Project Manager Plant Licensing Branch 1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-244
Enclosure:
List of Attendees cc: Listserv
Enclosure LIST OF ATTENDEES AUGUST 11, 2025, OBSERVATION MEETING WITH CONSTELLATION ENERGY GENERATION, LLC REGARDING A LICENSE AMENDMENT TO EXTEND THE COMPLETION TIME FOR SODIUM HYDROXIDE SYSTEM ATTENDEE REPRESENTING V Sreenivas U.S. Nuclear Regulatory Commission (NRC)
Matt Hamm NRC John Parillo NRC Steven Bloom NRC Matt Yoder NRC Paul Klein NRC Reena Boruk NRC Michael Henry Constellation Energy Generation, LLC (CEG)
Abul Hasanat CEG Andrew Freedman CEG Damon Peters CEG Claire Schmittinger CEG Christopher Staum CEG Justin Knowles CEG
ML25226A194 (Package)
ML25219A198 (Meeting Notice)
ML25226A193 (Meeting Summary)
NRC-001 OFFICE NRR/DORL/LPL1/PM NRR/DORL/LPL1/LA NRR/DSS/STSB/BC NRR/DNRL/NCSG/BC NAME VSreenivas KEntz SMehta SBloom DATE 08/15/2025 08/18/2025 08/20/2025 08/20/2025 OFFICE NRR/DSS/ARCB/BC NRR/DORL/LPL1/BC NRR/DORL/LPL1/PM NAME KHsueh HGonzález VSreenivas DATE 08/28/2025 08/22/2025 08/28/2025