ML18325A171

Summary of Meeting with Exelon Generation Company, LLC Regarding Planned Fleet License Amendment Request to Revise Technical Specifications for High Radiation Areas

ML18325A171
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Three Mile Island, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle
Issue date:	11/28/2018
From:	Blake Purnell Plant Licensing Branch III
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Purnell B, 415-1380
References
EPID L-2018-LRM-0068
Download: ML18325A171 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 November 28, 2018 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; R. E. GINNA NUCLEAR POWER PLANT; AND THREE MILE ISLAND NUCLEAR STATION, UNIT 1

SUMMARY

OF NOVEMBER 19, 2018, MEETING WITH EXELON GENERATION COMPANY, LLC REGARDING PLANNED FLEET LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS FOR HIGH RADIATION AREAS (EPID L-2018-LRM-0068)

On November 19, 2018, a Category 1 public meeting was held between the U.S. Nuclear Regulatory Commission (NRC) staff and representatives of Exelon Generation Company, LLC (Exelon, the licensee) via teleconference. The purpose of the meeting was to discuss a planned Exelon fleet license amendment request (LAR) to revise the technical specifications (TSs) for high radiation areas. The meeting notice and agenda, dated October 23, 2018, are available in Agencywide Documents Access and Management System (ADAMS) at Accession No. ML18296A146. The slides Exelon used for the discussion are available in ADAMS at Accession No. ML18319A127. A list of attendees is enclosed.

Exelon wants to establish common TS wording for the high radiation area requirements for its fleet of operating reactors. Exelon provided an overview of its planned changes including a comparison of the proposed wording to the standard TS wording. The proposed LAR will have a number of differences from the standard TSs. Exelon also provided a summary of the planned LAR content. Exelon stated tha*t it plans to submit the LAR at the end of January 2019, and will request a 1-year NRC review.

Exelon stated it is planning to include Three Mile Island Nuclear Station, Unit 1 (TMI), in the fleet request. On June 20, 2017 (ADAMS Accession No. ML17171A151), Exelon notified the NRC that it plans to permanently shutdown TMI no later than September 30, 2019. Exelon stated that the proposed TS changes would not impact the LAR for the proposed defueled TSs for TMI that is currently being reviewed by the NRC staff. The NRC staff noted that it would not consider the LARs for the defueled TSs and changes to the TS for high radiation areas to be linked; therefore, this would not be an acceptance review issue. However, the staff considers the actions for TMI to be complex from an administrative standpoint due to the need to consider

both operating and permanently shutdown conditions. The staff would prefer that the TMI LAR for the TS changes to high radiation areas be submitted separately from the fleet.

The NRC staff noted that it generally evaluates TS changes against the current TSs when reviewing LARs. The LAR should describe the plant-specific differences where they are significant. The staff also noted the following:

• The proposed TSs use thresholds for receiving a dose at 30 centimeters, but does not explain what this distance is measured from. The licensee should use language consistent with Title 10 of the Code of Federal Regulation Part 20.

• The standard TS for high radiation areas have several sections, and repeats some requirements in each section. Instead of repeating requirements in different sections, Exelon's proposed TS refer to "the proceeding requirements" in several sections. The proposed TSs should explicitly state what proceeding requirements are being referenced (e.g., provide TS numbers). In addition, some sections of the standard TSs provide multiple options to meet a requirements, whereas other sections provide multiple requirements. When referring to proceeding requirements, the licensee should be cognizant of where there are multiple requirements versus multiple options.

• The proposed TS includes requirements for a "Radiation Work Permit (RWP) or equivalent." The standard TSs explain what is considered equivalent to an RWP, whereas no explination was provided in the propsed TSs. The licensee should explain what is considered equivalent to an RWP.

• The proposed TSs describe the use of barricades, but does not provide an allowance for the opening of barricades.

• The standard TS 5.7.1.d refers to a continuously transmitting radiation monitoring device. The LAR should explain why the proposed TSs do not include the word "continuous" when referring to the radiation monitoring device.

Public meeting feedback forms were not received. Please direct any inquiries to me at 301-415-1380, or Blake.Purnell@nrc.gov.

Blake Purnell, Project Manager Plant Licensing Branch Ill 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, 50-37 4, 50-352, 50-353, 50-220, 50-410, 50-277, 50-278, 50-254, 50-265, 50-244, and 50-289

Enclosure:

List of Attendees cc: Listserv

LIST OF ATIEN DEES NOVEMBER 19, 2018, MEETING WITH EXELON GENERATION COMPANY, LLC Name Affiliation Blake Purnell NRC David Garmon-Candelaria NRC Justin Poole NRC Kevin Hsueh NRC Victoria Huckabay NRC Kristy Bucholtz NRC Frank Mascitelli Exelon Rebecca Steinman Exelon Mark Lvate Exelon Willie Harris Exelon David Lafleur Pennsylvania Department of Environmental Protection Bridget Frymire New York Department of Public Service David Tancabel Maryland Department of Natural Resources Enclosure

SUMMARY

OF NOVEMBER 19, 2018, MEETING WITH EXELON GENERATION COMPANY, LLC REGARDING PLANNED FLEET LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS FOR HIGH RADIATION AREAS (EPID L-2018-LRM-0068) DATED NOVEMBER 28, 2018 DISTRIBUTION:

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