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| | number = ML13350A342 | | | number = ML13350A342 |
| | issue date = 12/13/2013 | | | issue date = 12/13/2013 |
| | title = Braidwood Station, Unit 2, Reply to Notice of Violation, EA-13-209 | | | title = Reply to Notice of Violation, EA-13-209 |
| | author name = Kanavos M E | | | author name = Kanavos M E |
| | author affiliation = Exelon Generation Co, LLC | | | author affiliation = Exelon Generation Co, LLC |
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Category:Letter
MONTHYEARIR 05000456/20230042024-02-0202 February 2024 Integrated Inspection Report 05000456/2023004 and 05000457/2023004 ML24025C7242024-01-29029 January 2024 Notification of NRC Baseline Inspection and Request for Information; Inspection Report 05000456/2024002; 05000457/2024002 IR 05000457/20230112024-01-25025 January 2024 2B Auxiliary Feedwater Pump Diesel Fuel Oil Dilution Report 05000457/2023011 and Preliminary Greater than Green Finding and Apparent Violation ML24018A0362024-01-17017 January 2024 Paragon Energy Solutions, Defect with Detroit Diesel/Mtu Fuel Injectors P/N R5229660 Cat Id 0001390618 RS-24-004, Proposed Alternative to the Distribution Requirements of ASME Code Table IWC-2411-1 for the Steam Generators2024-01-11011 January 2024 Proposed Alternative to the Distribution Requirements of ASME Code Table IWC-2411-1 for the Steam Generators ML23348A2162023-12-15015 December 2023 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0030 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) IR 05000456/20200232023-12-15015 December 2023 Baseline Security Inspection Document; 05000456/2023/402; 05000457/2023/402 ML23277A0032023-12-11011 December 2023 Issuance of Amendments Regarding Adoption of TSTF-370 ML23339A0452023-12-0505 December 2023 Request for Information for an NRC Post-Approval Site Inspection for License Renewal Inspection Report 05000546/2024010 ML23313A1552023-12-0101 December 2023 Review of the Fall 2022 Steam Generator Tube Inspection Report ML23331A8922023-11-22022 November 2023 Supplement - Braidwood Security Rule Exemption Request ISFSI Docket No. Reference 05000457/LER-2023-001, Submittal of LER 2023-001-00 for Braidwood Station, Unit 2, Train B Auxiliary Feedwater Pump Was Inoperable Due to Degraded Oil in the Crank Case2023-11-17017 November 2023 Submittal of LER 2023-001-00 for Braidwood Station, Unit 2, Train B Auxiliary Feedwater Pump Was Inoperable Due to Degraded Oil in the Crank Case ML23321A0442023-11-17017 November 2023 Notification of Deviation from Electric Power Research Institute (EPRI) Topical Report MRP-227, Revision 1-A, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guideline RS-23-118, Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information2023-11-10010 November 2023 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums RS-23-114, Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds2023-11-0101 November 2023 Proposed Alternative for Examination of Pressurizer Circumferential and Longitudinal Shell-to-Head Welds and Nozzle-to-Vessel Welds IR 05000456/20234012023-10-18018 October 2023 Security Baseline Inspection Report 05000456/2023401 and 05000457/2023401 IR 05000456/20230102023-10-18018 October 2023 Functional Engineering Inspection Commercial Grade Dedication Report 05000456/2023010 and 05000457/2023010 RS-23-097, Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans2023-10-12012 October 2023 Constellation Energy Generation, LLC, Advisement of Leadership Changes and Submittal of Updated Standard Practice Procedures Plans RS-23-108, Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator Pressure Retaining Welds and Full Penetration Welded Nozzles2023-10-11011 October 2023 Proposed Alternative for Examinations of Examination Categories B-B, B-D, and C-A Steam Generator Pressure Retaining Welds and Full Penetration Welded Nozzles RS-23-105, Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections2023-10-10010 October 2023 Proposed Alternative for Examinations of Examination Category C-B Steam Generator Nozzle-to-Shell Welds and Nozzle Inside Radius Sections RS-23-093, License Amendment to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, Technical Specifications 3.7.15, Spent Fuel Pool Boron Concentration, 3.7.16, Spent Fuel.2023-09-29029 September 2023 License Amendment to Braidwood Station, Units 1 and 2, and Byron Station, Units 1 and 2, Technical Specifications 3.7.15, Spent Fuel Pool Boron Concentration, 3.7.16, Spent Fuel. ML23226A0062023-09-19019 September 2023 Review of License Renewal Commitment Number 10 Submittal ML23180A1692023-09-11011 September 2023 Calvert Cliff Units 1 & 2, and R.E. Ginna Plant - Withdrawal of Proposed Alternatives to American Society of Mechanical Engineers (ASME) Requirements (Epids L-2022-LRR-0074, 0076, 0079, 0091, 0092, 0093 and 0094) IR 05000456/20230052023-08-30030 August 2023 Updated Inspection Plan for Braidwood Station Report 05000456/2023005 and 05000457/2023005 ML23234A2462023-08-25025 August 2023 Confirmation of Initial License Examination IR 05000456/20230022023-08-0303 August 2023 Integrated Inspection Report 05000456/2023002 and 05000457/2023002 ML23188A1292023-07-26026 July 2023 Issuance of Amendment Nos. 233 and 233 Adoption of TSTF-577, Revised Frequencies for Steam Generator Tube Inspections, Revision 1 ML23087A0762023-07-13013 July 2023 Issuance of Amendment Nos. 232 and 232 Revision of Technical Specifications for the Ultimate Heat Sink ML23191A8442023-07-10010 July 2023 05000456; 05000457 Notification of an NRC Biennial Licensed Operator Requalification Program Inspection and Request for Information ML23178A2422023-06-28028 June 2023 Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch III RS-23-083, Withdrawal - Proposed Alternatives Related to the Steam Generators2023-06-27027 June 2023 Withdrawal - Proposed Alternatives Related to the Steam Generators RS-23-077, Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations2023-06-16016 June 2023 Response to NRC Regulatory Issue Summary 2023-01, Preparation and Scheduling of Operator Licensing Examinations ML23110A1152023-06-12012 June 2023 Environmental Assessment and Finding of No Significant Impact Related to a Requested Increase in Ultimate Heat Sink Temperature (EPID L-2023-LLA-0042) (Letter) RS-23-074, Supplement to Application for License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2023-06-0909 June 2023 Supplement to Application for License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink RS-23-075, Application for Technical Specification Improvement to Extend the Completion Time for Condition B of Technical Specification 3.5.1, Accumulators, Using the Consolidated Line Item Improvement Process2023-06-0707 June 2023 Application for Technical Specification Improvement to Extend the Completion Time for Condition B of Technical Specification 3.5.1, Accumulators, Using the Consolidated Line Item Improvement Process RS-23-050, Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube.2023-05-22022 May 2023 Supplement to Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator Tube. ML23138A1342023-05-18018 May 2023 Information Meeting with a Question and Answer Session to Discuss NRC 2022 End-Of-Cycle Plant Performance Assessment of Braidwood Station and Byron Station ML23132A0472023-05-12012 May 2023 Submittal of 2022 Annual Radiological Environmental Operating Report ML23130A0072023-05-10010 May 2023 Submittal of Core Operating Limits Report Cycle 24, Rev. 16 IR 05000456/20230012023-05-0808 May 2023 Integrated Inspection Report 05000456/2023001 and 05000457/2023001 ML23114A2522023-04-28028 April 2023 Request to Use a Provision of a Later Edition of the ASME Boiler & Pressure Vessel Code, Section XI ML23118A0202023-04-28028 April 2023 Submittal of 2022 Annual Radioactive Effluent Release Report ML23110A3202023-04-21021 April 2023 Information Request to Support the NRC Annual Baseline Emergency Action Level and Emergency Plan Changes Inspection RS-23-056, Response to Request for Additional Information to Braidwood Station, Unit 1, and Byron Station, Unit 1, for Steam Generator License Renewal Response to Commitment 102023-04-20020 April 2023 Response to Request for Additional Information to Braidwood Station, Unit 1, and Byron Station, Unit 1, for Steam Generator License Renewal Response to Commitment 10 RS-23-055, Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors2023-04-10010 April 2023 Annual 10 CFR 50.46 Report of Emergency Core Cooling System Evaluation Model Changes and Errors ML23095A1292023-04-0505 April 2023 Steam Generator Tube Inspection Report for Refueling Outage 23 ML23094A1352023-04-0404 April 2023 Request for Information for Nrc Commercial Grade Dedication Inspection Inspection Report 05000456/2023010 05000457/2023010 RS-23-052, License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink2023-03-24024 March 2023 License Amendment to Braidwood Station, Units 1 and 2, Technical Specification 3.7.9, Ultimate Heat Sink RS-23-049, Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations2023-03-23023 March 2023 Constellation Energy Generation, LLC, Report on Status of Decommissioning Funding for Reactors and Independent Spent Fuel Storage Installations 2024-02-02
[Table view] Category:Licensee Response to Notice of Violation
MONTHYEARML13350A3422013-12-13013 December 2013 Reply to Notice of Violation, EA-13-209 IR 05000456/20120042012-12-0707 December 2012 Reply to a Notice of Violation Regarding Inspection Reports 05000456/2012004-03; 05000457/2012004-03 ML12342A4122012-12-0707 December 2012 Reply to a Notice of Violation Regarding Inspection Reports 05000456/2012004-03; 05000457/2012004-03 ML12297A2972012-10-23023 October 2012 Reply to a Notice of Violation; 05000457/2012008-01 ML1108907372011-03-30030 March 2011 Reply to a Notice of Violation; EA-10-220 ML1106200892011-03-0202 March 2011 Response to NRC Verification Inspection Report; 05000456/2011009; 05000457/2011009 ML0620904022006-07-28028 July 2006 Reply to Notice of Violation: EA-06-081 ML0610704972006-02-0202 February 2006 Letter from Keith Poison, Braidwood Station to Beverly Booker, Illinois Environmental Protect Agency ML0617102232005-12-19019 December 2005 NRC Email from Steven Orth to Braidwood Communications Team, Bwd IEPA Violation ML0224603322002-08-22022 August 2002 Reply to a Notice of Violation ML0224000322002-08-19019 August 2002 Revised Response to a Notice of Violation ML0221204842002-07-24024 July 2002 Additional Information Regarding a Reply to a Notice of Violation ML0213502262002-05-0303 May 2002 Follow-up Reply to Notice of Violation ML0203505112002-01-11011 January 2002 Reply to a Notice of Violation 2013-12-13
[Table view] |
Text
December 13, 2013 BW130109 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, D.C. 20555-0001 Braidwood Station, Unit 2 Facility Operating License No. NPF-77 NRC Docket No. STN 50-457
Subject:
Reply to a Notice of Violation, EA-13-209
Reference:
Letter from David E. Hills (U.S. NRC) to Michael J. Pacilio (Exelon Generation Company, LLC), "Notice of Violation and Braidwood Station, Units 1 And 2, NRC Baseline Inservice Inspection Report 05000456/2013008; 05000457/2013008," dated November 14, 2013. In the referenced letter, based on the results of an inspection completed on October 29, 2013, the NRC concluded that Braidwood Station was in violation of 10 CFR 50.9(a), "Completeness and Accuracy of Information." Specifically, on October 3, 2005, in Letter RS-05-103, Exelon Generation Company, LLC (EGC) failed to provide complete and accurate information to the NRC in that the analysis demonstrating adequate Reactor Pressure Vessel (RPV) margin did not account for the actual Unit 2 configuration of one RPV head stud removed. The NRC requested EGC to respond to the Notice of Violation within 30 days of the date of the referenced letter. Attachment 1 to this letter contains EGG's response to the Notice of Violation.
EGC does not contest the violation.
This letter also contains a new regulatory commitment, which is identified in Attachment
- 2. If you have any questions regarding this reply, please contact Mr. Phil Raush, Regulatory Assurance Manager, at (815) 417-2800.
Respectfully, Mark E. Kanavos Site Vice President Braidwood Station Attachments:
- 1) Reply to Notice of Violation
- 2) Summary of Regulatory Commitment cc: Regional Administrator
-NRC Region III NRC Resident -Braidwood ATTACHMENT 1 Reply to Notice of Violation In a letter from David E. Hills (U.S. NRC) to Michael J. Pacilio (Exelon Generation Company, LLC), dated November 14, 2013, the NRC issued a Notice of Violation.
The violation of NRC requirements was identified during an NRC inspection completed on October 29,2013. The violation is stated below: Title 10 of the Code of Federal Regulations (10 CFR) 50.9(a), "Completeness and Accuracy of Information," requires that "Information provided to the Commission by an applicant for a license or by a licensee or information required by statute, or by the Commission's regulations, orders, or license conditions to be maintained by the applicant or the licensee shall be complete and accurate in all material respects." In Letter No. RS-05-103, "License Amendment Request Regarding Reactor Coolant System Pressure, and Temperature Limits Report and Request for Exemption from 10 CFR 50.60, Acceptance Criteria for Fracture Prevention Measures for Lightwater Nuclear Power Reactors for Normal Operation," Attachment 4, "Justification for Exemption from 10 CFR 50.60," the licensee [Exelon Generation Company, LLC] stated 'WCAP-16143 provides a valid basis for changing the RPV [Reactor Pressure Vessel] closure head flange limit and maintains the relative margin of safety commensurate with that which existed at the time the 10 CFR [Part] 50, Appendix G requirement was issued." Contrary to the above, on October 3, 2005, in Letter No. RS-05-103, the licensee [Exelon Generation Company, LLC] failed to provide information to the Commission that was complete and accurate in all material respects, in that, WCAP-16143, "Reactor Vessel Closure H[e]adNessel Flange Requirements Evaluation for Byron/Braidwood Units 1 and 2," did not provide a valid basis for changing the RPV closure head flange limit for Braidwood Unit 2. Specifically, WCAP-16143, Section 4, "Flange Integrity," demonstrated adequate vessel margins based upon the original closure head flange configuration and did not represent the modified closure head configuration (53 head studs applicable to the Unit 2 reactor vessel). Operation of the Braidwood Unit 2 vessel with 53 closure head studs was not within the bounds and limitations of what the NRC had reviewed in Letter No. RS-05-103 and found to be an acceptable basis to grant the exemption request. Therefore, this information was considered material to the NRC. This is a Severity Level IV Violation. 1 2 Response: 1 ) Reason for the violation Braidwood Station has performed a review of the circumstances related to the development of WCAP-16143-P, "Reactor Vessel Closure HeadNessel Flange Requirements Evaluation for Byron/Braidwood Units 1 and 2," and the submittal of incomplete and inaccurate information in Letter No. RS-05-103.
The reason for the violation is an inadequate technical human performance review associated with the acceptance review of WCAP-16143-P before the License Amendment Request/Exemption Request was submitted to the NRC. Technical details and inputs in WCAP-16143-P, specific to Braidwood and Byron, were not validated.
Exelon procedure, HU-AA-1212, Technical Task Risk/Rigor Assessment, Pre-Job Brief, Independent Third Party Review, and Post-Job Review," provides direction for the performance of a Technical Task Risk/Rigor assessment for technical work that produces a tangible product (usually a document).
As part of the HU-AA-1212 review, it was recognized that WCAP-16143-P was the technical basis for the License Amendment Request/Exemption Request. However, the procedural requirement to provide a compensating method to mitigate the risk of an error when an outside organization is providing significant inputs was not followed.
In this instance, the inputs to the document should have been provided to the outside organization in writing and verified first hand. Braidwood identified contributing reasons for the violation, including the details related to the information regarding 54 in lieu of 53 studs was not clearly listed as an input to the WCAP-16143-P analysiS.
Additionally, Braidwood identified that Design Engineering did not participate in the review process before the License Amendment Request/Exemption Request was sent to the NRC. 2) Corrective steps that have been taken and the results achieved Braidwood Station has performed Operability Evaluation 13-005, "Support Document for PTLR Analysis Not Revised for Rx Head Stud Configuration Change," to demonstrate immediate operability of the Braidwood Station Unit 2 Reactor Pressure Vessel. 3) Corrective steps that will be taken Braidwood Station has initiated revision to WCAP-16143-P to reflect the Braidwood Station Unit 2 configuration of 53 RPV head bolts. The revision is scheduled to be completed by August 15, 2014. The revised WCAP-16143-P will be submitted to the NRC for review by October 17, 2014. 4) Date when full compliance will be achieved Full compliance will be achieved following NRC review of the EGC submittal of the revised WCAP-16143-P.
Page 2 of 2
- 1. ATTACHMENT 2 Summary of Regulatory Commitments The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)
COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No) (Yes/No) Exelon Generation Company, LLC (EGG) will revise W CAP-16143-P, "Reactor Vessel Closure Head/Vessel Flange October 17, 2014 Yes No Requirements Evaluation for Byron/Braidwood Units 1 and 2 to reflect the Braidwood Unit 2 configuration of 53 reactor head studs and submit to the NRC for review. 1 1