View source for JAFP-20-0020, Response to Request for Additional Information to Support Review of a License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation

{{Adams
| number = ML20052E056
| issue date = 02/21/2020
| title = Response to Request for Additional Information to Support Review of a License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (RWCU) System Primary Containment Isolation
| author name = Gudger D
| author affiliation = Exelon Generation Co, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000333
| license number = DPR-059
| contact person = 
| case reference number = EPID L-2019-LLA-0190, JAFP-20-0020
| document type = Letter type:JAFP, Response to Request for Additional Information (RAI)
| page count = 7
| project = EPID:L-2019-LLA-0190
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Exelon Generation ~                                               200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 JAFP-20-0020 February 21, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-059 NRC Docket No. 50-333

==Subject:==
Response to Request for Additional Information to Support Review of a License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (RWCU} System Primary Containment Isolation

==References:==
: 1. Letter from J. Barstow (Exelon Generation Company, LLC} to U.S. Nuclear Regulatory Commission (NRC}, License Amendment Request - Proposed Change to Technical Specifications to Revise the Allowable Value for Reactor Water Cleanup (RWCU} System Primary Containment Isolation, (ML192488085} dated September 5, 2019.
: 2. Email from NRC S. Lee, FitzPatrick Supplemental Information Needed for Acceptance: Revise Allowable Value for Reactor Water Cleanup System Primary Containment Isolation (EPID L-2019- LLA-0190), ML19291A035, dated October 18, 2019.
: 3. Letter from Exelon D. Gudger, Response to Request for Supplemental Information by the Office of Nuclear Reactor Regulation to support Review of a License Amendment Request to Revise the Allowable Value for Reactor Water Cleanup (RWCU} System Primary Containment Isolation. Letter dated November 6, 2019.
: 4. Email from NRC S. Lee, "FitzPatrick request for additional information:
License Amendment request for Change to the Technical Specifications to Revise the Allowable Value for Reactor water Cleanup (RWCU}
System Primary Containment Isolation" (EPID: L2019-LLA-0190}. Email dated January 23, 2020.
By letter dated September 5, 2019, (Reference 1} and supplemented by letter dated November 6, 2019, (Reference 3) Exelon Generation Company, LLC (Exelon) requested a change to the James A. FitzPatrick Nuclear Power Plant (JAF) Technical Specifications (TS) in accordance with 10 CFR 50.90. The proposed amendment

Response to RAI to Support Review of LAR to Revise RWCU Setpoint February 21, 2020 Page 2 request would revise the TS Allowable Value for Reactor Water Clean Up (RWCU) isolation on low Reactor Pressure Vessel (RPV) water level from Level 3 (<::177 inches) to Level 2 (~107 inches).
By electronic mail dated January 23, 2020 (Reference 4), the NRC identified areas where additional information was necessary. These additional RAls were discussed with the NRC Staff in a clarification call held on January 21, 2020, and it was agreed to a response by February 24, 2020.
Attachment to this letter contains the NRC's request for additional information immediately followed by Exelon's response.
Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference 1.
The information attached to this letter does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration.
Furthermore, the information attached to this letter does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.
There are no new regulatory commitments contained in this response.
If you should have any questions regarding this submittal, please contact Enrique Villar at 610-765-5736.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 21st day of February 2020.
Respectfully,
   ~'JI ..,t{_J<I-'
David T. Gudger Senior Manager, Licensing Exelon Generation Company, LLC Attachments: Response to Request for Additional Information cc: Regional Administrator - NRC Region I NRC Senior Resident Inspector- JAF NRC Project Manager, NRR - JAF A. L. Peterson, NYSERDA

ATTACHMENT Response to Request for Additional Information By letter dated September 5, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML19248B085), as supplemented by letter dated November 6, 2019 (ADAMS Accession No. ML19310D579), Exelon Generation Company, LLC (Exelon, the licensee), submitted a license amendment request (LAR) proposing changes to the technical specifications (TS) for the James A. FitzPatrick Nuclear Power Plant (JAF). The proposed changes revise the JAF TS Allowable Value for Reactor Water Cleanup (RWCU) System isolation on low Reactor Pressure Vessel (RPV) water level from Level 3 ( 177 inches) to Level 2 ( 107 inches) in Tables 3.3.6.1-1 and 3.3.5.2-1. The NRC staff has reviewed the LAR and determined that additional information is required to complete the review. The NRC staffs requests for additional information (RAIs) are listed below. These RAIs are in the human factors engineering areas. The staff may have additional RAIs in other review areas. A clarification call was held on January 21, 2020. The Exelon staff indicated that there was no proprietary or sensitive information. The Exelon staff requested, and NRC agreed, to a RAI response by February 24, 2020.
Human Factors Engineering RAI-IOLB-1 Title 10 of the Code of Federal Regulations (10 CFR), Section 50.34(f)(2)(iii) requires, in part, that the licensee or applicant provide, for Commission review, a control room design that reflects state-of-the-art human factor principles.
Chapter 18, "Human Factors Engineering," Revision 3, of NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," provides guidance for the review of Human Factors Engineering (HFE) considerations of plant modifications and important human actions (HAs). Specifically, Section I, "Areas of Review,"
Subsection 5, "Important Human Actions," states, in part, that this document is used to review changes or modification to licenses for nuclear power plants that include or result in changes to human actions. An HFE review is also conducted if such a modification affects the role of personnel or the tasks they perform, the sequence of actions, the timing, or the overall workload, and is potentially significant to plant safety.
Provide additional information regarding whether the proposed change would result in any changes to the existing manual operator actions or introduce any new manual operator actions associated with the action to isolate Primary Containment. If there are any changes to the existing manual operator actions, describe the extent to which the changes affect personnel tasks, the sequence of actions, the amount of time required and/or available to perform such actions, and/or any impact on the operator workload.
Exelons Response to RAI-IOLB-1 The proposed change to revise the James A. FitzPatrick Nuclear Power Plant (JAF) Technical Specification (TS) Allowable Value for Reactor Water Cleanup (RWCU) system isolation on low Reactor Pressure Vessel (RPV) water level does not result in any changes to the existing manual operator actions and does not introduce any new manual operator actions associated with the action to isolate Primary Containment.

Attachment Response to Request for Additional Information                                         Page 2 of 5 Existing Emergency Operating Procedures (EOP) require a Licensed Operator to verify system isolations occur as designed.
Specifically, for Reactor Water Clean Up (RWCU), a Licensed Operator will verify proper isolation of the system utilizing available control room instrumentation. If the RWCU system fails to isolate (on low RPV water level), the licensed operator will manually close, by switch from the Control Room, any RWCU isolation valve(s) that failed to close.
Furthermore, procedure for Operator Response Time Program at JAF does not include any time critical or time sensitive actions for verifying or manually isolating RWCU.
All other RWCU isolations setpoints remain the same.
RAI-IOLB-2 Section 50.34(f)(3)(i) of 10 CFR 50 requires that the licensee or applicant provide administrative procedures for evaluating operating, design, and construction experience and for ensuring that applicable important industry experiences will be provided in a timely manner to those designing and constructing the plant. NUREG-0711, "Human Factors Engineering," Revision 3, provides guidance for the staffs review of HFE programs, to ensure that HFE practices and guidelines were appropriately considered and incorporated in the plant design and modifications. NUREG-0711, Review Element 3, "Operating Experience Review," provides guidance for the NRC staffs evaluation of the operating experience review (OER) that would be performed by a licensee, as part of the HFE program, to identify HFE-related safety issues. Section 3.4, "Review Criteria," states, in part, that the applicants OER should include information about relevant human factors issues in the predecessor plant(s) or highly similar plants, systems, and human-system interfaces (HSIs), recognized industry HFE issues, related HSI technology, issues identified by plant personnel, and important HAs. Further, Section 3.4.3, "Plant Modifications," states that, in addition to other considerations, the applicants OER should provide information on the plants systems, HSIs, procedures, or training that are being modified, and account for the operating experience of the plant that will be modified, including experiences with the systems that will be changed.
Provide additional information regarding the OER that was performed by Exelon, as it relates to the proposed change revising the JAF TS Allowable Value for RWCU System isolation on low RPV water level from Level 3 to Level 2. In your response, describe whether the review identified any human performance issues associated with the existing procedural guidance, training, and any human performance issues associated with the operator actions required for RWCU System isolation, by reviewing operating experience at JAF and applicable industry experience, as appropriate.
Exelons Response to RAI-IOLB-2 A JAF and industry operating experience review was conducted on RWCU isolations to identify any lessons learned for human performance issues associated with existing procedural guidance, training, and any human performance issues associated with operator actions required for RWCU system isolation.

Attachment Response to Request for Additional Information                                           Page 3 of 5 Operating experience review at JAF identified three (3) events, which resulted in either a manual or automatic RWCU system isolation. In December 2012, operators manually isolated RWCU due to rising temperatures and local report of a steam leak in the RWCU Heat Exchanger Room. In December 2011, operators removed RWCU system from service in order to repair a cracked pipe upstream of 12MOV-68. And finally, in March 2007, the RWCU system automatically isolated due to a seal failure on "B" RWCU pump. No procedural, training, equipment or human performance issues were noted with the review of these events.
Several industry operating experience events reviewed included inadvertent RWCU isolations caused by human performance errors or equipment challenges. For example, on May 27, 2018, at Fermi Unit 2, an inadvertent RWCU isolation occurred when a RWCU system flow differential flow indicator failed downscale. At JAF, RWCU does not have a differential flow isolation signal.
On June 29, 2019, at Cooper Nuclear Power Station, an inadvertent RWCU isolation occurred due to the failure of a temperature switch. On April 11, 2014, at Brunswick Unit 2, a RWCU isolation occurred when a jumper was inadvertently removed during surveillance testing.
The operating experience did not identify any instances of a failure of RWCU to isolate either manually or automatically at JAF or other nuclear power plants.
The operating experience review did not identify any further lessons learned on human performance issues associated with existing procedural guidance, training, and any human performance issues associated with operator actions required for RWCU system isolation.
RAI-IOLB-3 Title 10 of the Code of Federal Regulations (10 CFR), Section 50.34(f)(2)(iii) requires, in part, that the licensee or applicant provide, for Commission review, a control room design that reflects state-of-the-art human factor principles. NUREG-0711, "Human Factors Engineering,"
Revision 3, provides guidance for the staffs review of HFE programs, to ensure that HFE practices and guidelines were appropriately considered and incorporated in the plant design and modifications.
a) NUREG-0711, Review Element 9, Procedure Development, provides guidance for the staffs evaluation of the licensees procedure development program. Section 9.4, Review Criteria, states, in part, that the licensee should have a plan for maintaining procedures and controlling updates. It further states that procedure modifications should be integrated across the full set of procedures and that changes in particular parts of the procedures should not conflict with other parts nor be inconsistent with them.
Provide additional information describing the impact, if any, that the proposed change will have on plant procedures, including any affected emergency operating procedures, plant and system operations, abnormal and emergency operations, and alarm response.
In your response, identify the affected procedures and describe the scope of changes those documents.
Exelons Response to RAI-IOLB-3 a)
As stated in response to RAI-IOLB-1, the proposed change to revise the JAF TS Allowable Value for RWCU System isolation on low RPV water level does not result in any changes to the existing manual operator actions and does not introduce any new manual operator actions associated with the action to isolate Primary Containment.

Attachment Response to Request for Additional Information                                            Page 4 of 5 The only changes required by this License amendment involve changes that are necessary to update those procedure with the new TS Allowable Value for RWCU System isolation on low RPV level.
However, since the RWCU system will now isolate at a lower setpoint, the AOP-15 Follow Up actions for Group 2 system restoration will require minor changes to remove the RWCU isolation reset and system restoration and make it a standalone procedure section.
Additionally, Operating Procedure for RWCU, OP-28, requires minor changes to update the system description section and a procedure section for Recovery from Manual or Automatic Isolation with the new RPV water level isolation setpoint. However, the specific operator actions for manual and automatic isolation and recovery remain unchanged.
The Annunciator Response Procedures (ARP) do not require any changes.
b) NUREG-0711, Review Element 10, "Training Program Development," provides guidance for the staffs evaluation of the licensees training program. Section 10.4.6, "Evaluation and Modification of Training," states, in part, that the licensee should define the methods for verifying the accuracy and completeness of the training course materials. It further states that the licensee should establish procedures for refining and updating the content and conduct of training, including procedures for tracking modifications in the training courses.
c)
Provide additional information describing the impact, if any, that the proposed change will have on Exelons training program for licensed and non-licensed personnel.
Exelons Response to RAI-IOLB-3 b)
The overall learning objectives for licensed and non-licensed personnel, purpose, function, and operation of RWCU System components remain unchanged as a result of the proposed change to revise the JAF TS Allowable Value for RWCU system isolation on low RPV water level.
Non-Licensed Operators are currently trained on the RWCU isolation function on low RPV water level. The specific level setpoint is not an enabling objective in the Non-Licensed Operators training.
Licensed Operators are also trained on the RWCU isolation function, including the specific setpoint at which it occurs. The new low RPV water level setpoint is an enabling objective in the License Operator training; and therefore, the RWCU lesson plan will require a minor update to incorporate the new RWCU isolation setpoint.
d) NUREG-0711, Review Element 11, "Human Factors Verification and Validation,"
provides guidance for the staffs evaluation of the verification and validation (V&V) activities, which comprehensively determine that the HFE design conforms to HFE design principles and that it enables plant personnel to successfully perform their tasks to assure plant safety and operational goals. Section 11.4.3, "Integrated System Validation," states, in part, that the objective of the Integrated System Validation (ISV) review is to verify that the applicant validated, using performance-based tests, that the integrated system design supports the safe operation of the plant.

Attachment Response to Request for Additional Information                                         Page 5 of 5 Provide additional information regarding the V&V activities that have been, or will be conducted to provide reasonable assurance that following the implementation of the proposed changes, operator actions required for RWCU System isolation can continue to be performed safely and reliably within the established time and performance criteria, with effective situational awareness, and acceptable workload levels. In your response, provide information that addresses the applicable criteria described in Section 11.4.3 of NUREG-0711.
Exelons Response to RAI-IOLB-3 c)
The specific minor procedure revisions for AOP-15 and OP-28 have not been drafted to date.
Once the procedures are drafted, they will be evaluated in accordance with Exelon established process, which includes an evaluation of the Consequence Risk Factors.
If High or Medium Risk Factors exist, then procedure validation is required, and the methods of validation may include Mockup / Simulator, Field Walkdown, and Benchtop Review.}}