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{{#Wiki_filter:}} | {{#Wiki_filter:June 22, 2021 LICENSEE: EXELON GENERATION COMPANY, LLC FACILITIES: BRAIDWOOD STATION, UNITS 1 AND 2; BYRON STATION, UNIT NOS. 1 AND 2; CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2; CLINTON POWER STATION, UNIT NO. 1; DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; JAMES A. FITZPATRICK NUCLEAR POWER PLANT; LASALLE COUNTY STATION, UNITS 1 AND 2; LIMERICK GENERATING STATION, UNITS 1 AND 2; NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2; PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3; QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2; AND R. E. GINNA NUCLEAR POWER PLANT | ||
==SUBJECT:== | |||
==SUMMARY== | |||
OF MAY 18, 2021, MEETING WITH EXELON GENERATION COMPANY, LLC REGARDING ITS REQUESTED ALTERANTIVE TO ELIMINATE CERTAIN DOCUMENTATION REQUIREMENTS FOR THE REPLACEMENT OF PRESSURE RETAINING BOLTING (EPIDS L-2020-0153, L-2020-0154, L-2020-0155, L-2021-LLR-0029, AND L-2021-LLR-0030) | |||
By application dated December 1, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20336A008), Exelon Generation Company, LLC (Exelon, the licensee) submitted a request in accordance with paragraph 50.55a(z)(1) of Title 10 of the Code of Federal Regulations (10 CFR) for a proposed alternative to certain requirements of 10 CFR 50.55a, Codes and standards, for the subject facilities. The proposed alternative would allow the licensee to forgo preparation and completion of a repair and replacement plan and associated Form NIS-2 (or NIS-2A) for certain pressure retaining bolting at these facilities. These documentation requirements are provided in Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code, as incorporated by reference in 10 CFR 50.55a with conditions. By {{letter dated|date=April 20, 2021|text=letter dated April 20, 2021}} (ADAMS Accession No. ML21110A092), Exelon provided supplemental information in response to the U.S. Nuclear Regulatory Commission (NRC) staffs request for additional information (RAI) issued on March 1, 2021 (ADAMS Accession No. ML21062A065). | |||
On May 18, 2021, an observational public meeting was held between the NRC staff and Exelon representatives. The purpose of the meeting was to discuss Exelons proposed alternative. | |||
The meeting was primarily focused on Exelons response to RAIs 2 and 3. The meeting notice and agenda are available in ADAMS at Accession No. ML21118A701. A list of attendees is enclosed. | |||
According to the application, as supplemented, [t]he current Form NIS-2 (or NIS-2A) provides documented evidence of compliance with Section XI for repair/replacement activities by obtaining Owner and Authorized Inspection Agency [AIA] signatures. The application stated, in part, that the AIA reviews of completed work orders applying the proposed alternative would be documented in records associated with the work management process. In RAI 2, the NRC staff requested the licensee to describe how these processes will permit verification and certification | |||
by the AIA that the applicable Section XI requirements for repair/replacement activities have been met. In response to RAI 2, Exelon revised its application to state: Should the Authorized Inspection Agency choose to review certain completed work orders that fall under this relief request, the work management system will be used to document any agency comments during the work order records review. | |||
During the public meeting, the NRC staff asked for clarification regarding Exelons response to RAI 2. Exelon stated that review of the applicable work order records would be left to the discretion of the AIA. The process for documenting AIA reviews has not been determined and would be left to each site to develop on its own. If the AIA raised concerns, Exelon would add the concern to the corrective action program for the site. Exelon stated that AIA signature would no longer be required for the repair and replacement of applicable bolting under the proposed alternative. Exelon also stated that the AIA would sign off on the 90-day report (Owners Activity Report provided in ASME Code Case N-532) that is submitted to the NRC. However, Exelon clarified that this report would not cover the routine repair and replacement of bolting that is the focus of the requested alternative. | |||
The NRC staff stated that Exelon needs to provide supplemental information to explain why the AIA review and signature are not needed. In addition, the NRC staff stated that Exelon should describe how the AIA review will be documented if it chooses to review work order records under this alternative request. Exelon agreed to provide this information in a supplement to the application, but it would need time to determine the schedule for the supplement. | |||
Exelon also noted that the AIA review of pressure testing is also at the discretion of the AIA, and its proposed alternative would be similar in that regards. The NRC staff stated that it would be helpful to include this information in the supplement to the application. | |||
During the meeting, the NRC staff also discussed Exelons response to RAI 3, which expanded the scope of the original application to include the sixth 10-year inservice inspection (ISI) intervals at Dresden and Quad Cities. By email dated April 26, 2021 (ADAMS Accession No. ML21117A044), the NRC staff informed Exelon that it would review the additional request to use the proposed alternative for the sixth 10-year ISI intervals at Dresden and Quad Cities separately from the original application. During the meeting, the NRC staff stated that Exelon would also need to provide a supplement to support these additional reviews to identify the specific requirements within the 2017 Edition of the ASME BPV Code, Section XI, for which Exelon sought relief. Exelon stated it would provide this supplement by May 19, 2021. | |||
There were no public comments and no public meeting feedback forms were received. Please direct any inquiries to me at 301-415-1380 or Blake.Purnell@nrc.gov. | |||
/RA/ | |||
Blake Purnell, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-317, 50-318, 50-461, 50-237, 50-249, 50-333, 50-373, 50-374, 50-352, 50-353, 50-220, 50-410, 50-277, 50-278, 50-254, 50-265, and 50-244 | |||
==Enclosure:== | |||
List of Attendees Listserv | |||
LIST OF ATTENDEES MAY 18, 2021, MEETING WITH EXELON GENERATION COMPANY, LLC Name Affiliation Blake Purnell NRC Yamir Diaz-Castillo NRC John Tsao NRC John Honcharik NRC Keith Hoffman NRC Nancy Salgado NRC Russell Haskell NRC Booma Venkataraman NRC Kerri Kavanagh NRC Jackie Harvey NRC Thomas Loomis Exelon Brendan Casey Exelon Mark Weis Exelon Dan Lamond TruNorth Matt Ralstin Exelon Josh Sarrafian Exelon Ben Jordan Exelon Robert Hoke Exelon Brian Huling Exelon Michelle Karasek Exelon Rick Swart Exelon Enclosure | |||
ML21139A185 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME BPurnell SRohrer NSalgado BPurnell DATE 5/24/21 5/20/21 5/25/21 6/22/21}} | |||
Latest revision as of 13:27, 19 January 2022
| ML21139A185 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle  |
| Issue date: | 06/22/2021 |
| From: | Blake Purnell Plant Licensing Branch III |
| To: | Exelon Generation Co, Exelon Nuclear |
| Purnell B | |
| References | |
| EPID L-2020-0155, EPID L-2020-0153, EPID L-2020-0154, EPID L-2021-LLR-0029, EPID L-2021-LLR-0030 | |
| Download: ML21139A185 (5) | |
Text
June 22, 2021 LICENSEE: EXELON GENERATION COMPANY, LLC FACILITIES: BRAIDWOOD STATION, UNITS 1 AND 2; BYRON STATION, UNIT NOS. 1 AND 2; CALVERT CLIFFS NUCLEAR POWER PLANT, UNITS 1 AND 2; CLINTON POWER STATION, UNIT NO. 1; DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3; JAMES A. FITZPATRICK NUCLEAR POWER PLANT; LASALLE COUNTY STATION, UNITS 1 AND 2; LIMERICK GENERATING STATION, UNITS 1 AND 2; NINE MILE POINT NUCLEAR STATION, UNITS 1 AND 2; PEACH BOTTOM ATOMIC POWER STATION, UNITS 2 AND 3; QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2; AND R. E. GINNA NUCLEAR POWER PLANT
SUBJECT:
SUMMARY
OF MAY 18, 2021, MEETING WITH EXELON GENERATION COMPANY, LLC REGARDING ITS REQUESTED ALTERANTIVE TO ELIMINATE CERTAIN DOCUMENTATION REQUIREMENTS FOR THE REPLACEMENT OF PRESSURE RETAINING BOLTING (EPIDS L-2020-0153, L-2020-0154, L-2020-0155, L-2021-LLR-0029, AND L-2021-LLR-0030)
By application dated December 1, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20336A008), Exelon Generation Company, LLC (Exelon, the licensee) submitted a request in accordance with paragraph 50.55a(z)(1) of Title 10 of the Code of Federal Regulations (10 CFR) for a proposed alternative to certain requirements of 10 CFR 50.55a, Codes and standards, for the subject facilities. The proposed alternative would allow the licensee to forgo preparation and completion of a repair and replacement plan and associated Form NIS-2 (or NIS-2A) for certain pressure retaining bolting at these facilities. These documentation requirements are provided in Section XI of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (BPV) Code, as incorporated by reference in 10 CFR 50.55a with conditions. By letter dated April 20, 2021 (ADAMS Accession No. ML21110A092), Exelon provided supplemental information in response to the U.S. Nuclear Regulatory Commission (NRC) staffs request for additional information (RAI) issued on March 1, 2021 (ADAMS Accession No. ML21062A065).
On May 18, 2021, an observational public meeting was held between the NRC staff and Exelon representatives. The purpose of the meeting was to discuss Exelons proposed alternative.
The meeting was primarily focused on Exelons response to RAIs 2 and 3. The meeting notice and agenda are available in ADAMS at Accession No. ML21118A701. A list of attendees is enclosed.
According to the application, as supplemented, [t]he current Form NIS-2 (or NIS-2A) provides documented evidence of compliance with Section XI for repair/replacement activities by obtaining Owner and Authorized Inspection Agency [AIA] signatures. The application stated, in part, that the AIA reviews of completed work orders applying the proposed alternative would be documented in records associated with the work management process. In RAI 2, the NRC staff requested the licensee to describe how these processes will permit verification and certification
by the AIA that the applicable Section XI requirements for repair/replacement activities have been met. In response to RAI 2, Exelon revised its application to state: Should the Authorized Inspection Agency choose to review certain completed work orders that fall under this relief request, the work management system will be used to document any agency comments during the work order records review.
During the public meeting, the NRC staff asked for clarification regarding Exelons response to RAI 2. Exelon stated that review of the applicable work order records would be left to the discretion of the AIA. The process for documenting AIA reviews has not been determined and would be left to each site to develop on its own. If the AIA raised concerns, Exelon would add the concern to the corrective action program for the site. Exelon stated that AIA signature would no longer be required for the repair and replacement of applicable bolting under the proposed alternative. Exelon also stated that the AIA would sign off on the 90-day report (Owners Activity Report provided in ASME Code Case N-532) that is submitted to the NRC. However, Exelon clarified that this report would not cover the routine repair and replacement of bolting that is the focus of the requested alternative.
The NRC staff stated that Exelon needs to provide supplemental information to explain why the AIA review and signature are not needed. In addition, the NRC staff stated that Exelon should describe how the AIA review will be documented if it chooses to review work order records under this alternative request. Exelon agreed to provide this information in a supplement to the application, but it would need time to determine the schedule for the supplement.
Exelon also noted that the AIA review of pressure testing is also at the discretion of the AIA, and its proposed alternative would be similar in that regards. The NRC staff stated that it would be helpful to include this information in the supplement to the application.
During the meeting, the NRC staff also discussed Exelons response to RAI 3, which expanded the scope of the original application to include the sixth 10-year inservice inspection (ISI) intervals at Dresden and Quad Cities. By email dated April 26, 2021 (ADAMS Accession No. ML21117A044), the NRC staff informed Exelon that it would review the additional request to use the proposed alternative for the sixth 10-year ISI intervals at Dresden and Quad Cities separately from the original application. During the meeting, the NRC staff stated that Exelon would also need to provide a supplement to support these additional reviews to identify the specific requirements within the 2017 Edition of the ASME BPV Code,Section XI, for which Exelon sought relief. Exelon stated it would provide this supplement by May 19, 2021.
There were no public comments and no public meeting feedback forms were received. Please direct any inquiries to me at 301-415-1380 or Blake.Purnell@nrc.gov.
/RA/
Blake Purnell, Project Manager Plant Licensing Branch III Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-317, 50-318, 50-461, 50-237, 50-249, 50-333, 50-373, 50-374, 50-352, 50-353, 50-220, 50-410, 50-277, 50-278, 50-254, 50-265, and 50-244
Enclosure:
List of Attendees Listserv
LIST OF ATTENDEES MAY 18, 2021, MEETING WITH EXELON GENERATION COMPANY, LLC Name Affiliation Blake Purnell NRC Yamir Diaz-Castillo NRC John Tsao NRC John Honcharik NRC Keith Hoffman NRC Nancy Salgado NRC Russell Haskell NRC Booma Venkataraman NRC Kerri Kavanagh NRC Jackie Harvey NRC Thomas Loomis Exelon Brendan Casey Exelon Mark Weis Exelon Dan Lamond TruNorth Matt Ralstin Exelon Josh Sarrafian Exelon Ben Jordan Exelon Robert Hoke Exelon Brian Huling Exelon Michelle Karasek Exelon Rick Swart Exelon Enclosure
ML21139A185 OFFICE NRR/DORL/LPL3/PM NRR/DORL/LPL3/LA NRR/DORL/LPL3/BC NRR/DORL/LPL3/PM NAME BPurnell SRohrer NSalgado BPurnell DATE 5/24/21 5/20/21 5/25/21 6/22/21