ML18039A728

NRC Denial of Exelon Generation Company, Llc, Appeal of Clinton Power Station-Final Significance Determination of a White Finding; NRC Inspection Report 05000461/2018090

ML18039A728
Person / Time
Site:	Clinton
Issue date:	02/08/2018
From:	West K S Region 3 Administrator
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
References
EA-17-098 IR 2018090
Download: ML18039A728 (6)

See also: IR 05000461/2018090

Text

February 8, 2018

EA-17-098 Mr. Bryan Senior VP, Exelon Generation Company, LLC President and CNO, Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT: NRC DENIAL OF EXELON GENERATION COMPANY, LLC, APPEAL OF CLINTON POWER STATION-FINAL SIGNIFICANCE DETERMINATION OF A WHITE FINDING; NRC INSPECTION REPORT 05000461/2018090

Dear Mr. Hanson:

On November 27, 2017, the U.S. Nuclear Regulatory Commission (NRC) provided Exelon Generation Company, LLC, (EGC), the final significance determination for a finding of low-to-moderate significance (White) (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17331B161). This finding involved the failure to evaluate the change in the actual drop out voltages for replacement relays associated with the Division 1 Emergency Diesel Generator (EDG) room ventilation fan, which was a component subject to the requirements of Title 10 of the Code of Federal Regulations (CFR) Part 50, Appendix B.

The change in drop out voltages prevented the fan from operating during an undervoltage condition, resulting in the Division 1 EDG being unable to perform its intended safety function and becoming inoperable for a time longer than its Technical Specification allowed outage time.

In that same letter, the NRC stated that Exelon had 30 calendar days to appeal the NRC's final significance determination. The letter also stated that such an appeal would be considered to have merit only if it met the criteria given in Inspection Manual Chapter (IMC) 0609, Attachment 2, "Process for Appealing NRC Characterization of Inspection Findings (SDP Appeal Process)" (ADAMS Accession No. ML101400502).

By letter dated December 21, 2017, Exelon reiterated that a performance deficiency had occurred and did not dispute the violation or the assigned cross-cutting aspect (ADAMS Accession No. ML17355A562). However, Exelon appealed the NRC's characterization of the final significance determination of the White finding. Exelon asserted that the basis documented in the final significance determination letter appeared to be qualitative in nature, subjective, and based on an undefined alternative process. As a result, the NRC's final significance determination deviated from established NRC regulations and guidance currently used for safety-related equipment qualification. Therefore, Exelon stated that its appeal met the "lacked justification" merit standard provided in NRC IMC 0609, Attachment 2. This letter provides you the NRC's response to your December 21, 2017, appeal. The NRC concluded that Exelon's appeal did not have sufficient merit for review by the appeal process specified in IMC 0609 Attachment 2. Our evaluation of the appeal submitted by Exelon is provided in the enclosure to this letter. Accordingly, the NRC concluded that the final significance determination documented in NRC Inspection Report 05000461/2017010, is unchanged and, based on your previous response to the Notice of Violation, no further response is required. If you have any questions on our conclusions on the merit of your appeal, please contact Mr. Patrick Louden, Director, Division of Reactor Projects, at 630-829-9600, or Ms. Karla Stoedter, Chief, Reactor Projects Branch 1, at 630-829-9731. In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter and its enclosure will be made available electronically for public inspection in the NRC Public Document Room and in ADAMS, accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html.

Sincerely,/RA/ K. Steven West Regional Administrator Docket No. 50-461 License No. NPF-62

Enclosure:

NRC Response to Final Significance Determination Appeal