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Category:Enforcement Action
MONTHYEARML20107F8342020-04-16016 April 2020 (EA-19-122) Response to Contested Notice of Violation Documented in U.S. Nuclear Regulatory Commission R.E. Ginna Inspection Report 05000244/2019010 IR 05000244/20150072015-02-24024 February 2015 Notice of Violation - Severity Level III Problem - NRC Inspection Report 05000244/2015007 IR 05000244/20120092012-11-0505 November 2012 IR 05000244-12-009; 09/10/2012 - 09/28/2012; R.E. Ginna Nuclear Power Plant; Triennial Fire Protection Inspection IR 05000244/20090062009-12-28028 December 2009 IR 05000244-09-006; on 11/02/2009 - 11/20/209; R.E. Ginna Nuclear Power Plant; Triennial Fire Protection Team Inspection IR 05000244/20090082009-11-12012 November 2009 EA-09-249, R. E. Ginna Nuclear Power Plant, LLC, Notice of Violation - NRC Inspection Report No. 05000244-09-008 ML0931602002009-11-12012 November 2009 EA-09-249, R. E. Ginna Nuclear Power Plant, LLC, Notice of Violation - NRC Inspection Report No. 05000244-09-008 IR 05000244/20085022008-04-0707 April 2008 R. E. Ginna Nuclear Power Plant - Notice of Violation, NRC Supplemental Inspection Report No. 05000244/2008502 ML0233002832002-11-26026 November 2002 EA-02-121, EA-02-142, Peach Bottom, NOV & Green and White Findings 2020-04-16
[Table view] Category:Letter
MONTHYEARIR 05000244/20230042024-02-0505 February 2024 LLC - Integrated Inspection Report 05000244/2023004 ML24026A0112024-01-26026 January 2024 R. E. Ginna Nuclear Power Plant, Relief Request Associated with Inservice Testing of B Auxiliary Feedwater Pump IR 05000244/20230102023-12-19019 December 2023 LLC - Age-Related Degradation Inspection Report 05000244/2023010 ML23348A0992023-12-15015 December 2023 R. E. Ginna Nuclear Power Plant Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0029 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) ML23347A0092023-12-13013 December 2023 Annual Commitment Change Notification ML23346A0142023-12-12012 December 2023 LLC - Senior Reactor and Reactor Operator Initial License Examinations ML23341A1252023-12-0707 December 2023 Supplemental Response to Part 73 Exemption Request - Withdrawal of Request for Exemption from 10 CFR 73, Subpart B, Preemption Authority Requirements ML23321A1392023-11-17017 November 2023 Supplemental Information Letter for Part 73 Exemption Request - Responses to Request for Confirmatory Information and Request for Additional Information ML23317A1192023-11-10010 November 2023 Constellation Energy Generation, LLC - 2023 Annual Report - Guarantees of Payment of Deferred Premiums IR 05000244/20230032023-10-25025 October 2023 LLC - Integrated Inspection Report 05000244/2023003 ML23292A0282023-10-19019 October 2023 LLC - Notification of Conduct of a Fire Protection Team Inspection 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 ML23258A1382023-09-18018 September 2023 Request for Information and Notification of Conduct of IP 71111.21.N.04, Age-Related Degradation, Reference Inspection Report 05000244/2023010 IR 05000244/20230052023-08-31031 August 2023 Updated Inspection Plan for R.E. Ginna Nuclear Power Plant, LLC (Report 05000244/2023005) ML23158A1952023-08-30030 August 2023 R. E. Ginna - Issuance of Amendments to Adopt TSTF-273-A, Revision 2, Safety Function Determination Program Clarifications ML23235A1722023-08-23023 August 2023 Re. Ginna Nuclear Power Plant, Transmittal of 2023 Owner'S Activity Report IR 05000244/20234012023-08-15015 August 2023 LLC - Material Control and Accounting Program Inspection Report 05000244/2023401 (Cover Letter Only) IR 05000244/20230022023-08-0303 August 2023 LLC - Integrated Inspection Report 05000244/2023002 ML23191A0592023-07-21021 July 2023 R. E. Ginna Nuclear Power Plant - Issuance of Amendment No. 155 Adoption of TSTF-577, Revised Frequencies for Steam Generator Tube Inspections, Revision 1 IR 05000244/20234022023-07-19019 July 2023 R. E. Ginna Nuclear Power Plant - Security Baseline Inspection Report 05000244/2023402 (Cover Letter Only) 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 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. ML23135A0412023-05-15015 May 2023 2022 Annual Radioactive Effluent Release Report and 2022 Annual Radiological Environmental Operating Report ML23121A0482023-05-0101 May 2023 R. E. Ginna Nuclear Power Plant Core Operating Limits Report Cycle 44, Revision 0 ML23114A2522023-04-28028 April 2023 Request to Use a Provision of a Later Edition of the ASME Boiler & Pressure Vessel Code, Section XI IR 05000244/20230012023-04-26026 April 2023 LLC - Integrated Inspection Report 05000244/2023001 ML23100A0302023-04-10010 April 2023 2023 10 CFR 50.46 Annual Report ML23114A1152023-03-29029 March 2023 Electronic Reporting of Exposure Data for 2022 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 ML23075A0872023-03-15015 March 2023 R. E. Ginna Nuclear Power Plant - Project Manager Assignment ML23061A1632023-03-0303 March 2023 Reassignment of the U.S. Nuclear Regulatory Commission Branch Chief in the Division of Operating Reactor Licensing for Plant Licensing Branch 3 IR 05000244/20220062023-03-0101 March 2023 Annual Assessment Letter for R.E. Ginna Nuclear Power Plant, LLC (Report 05000244/2022006) ML22364A0242023-03-0101 March 2023 R. E. Ginna Nuclear Power Plant Issuance of Amendments Nos. 231, 231, 232, 232, and 154 Regarding Adoption of TSTF-246 ML23060A1622023-03-0101 March 2023 R. E. Ginna Nuclear Power Plant, Supplemental Information - Proposed Alternatives Related to the Steam Generators RS-23-045, Constellation Energy Generation, LLC Submittal of Fitness for Duty Performance Data Reports for 2022 Per 10 CFR 26.717(c) & 10 CFR 26.2032023-02-28028 February 2023 Constellation Energy Generation, LLC Submittal of Fitness for Duty Performance Data Reports for 2022 Per 10 CFR 26.717(c) & 10 CFR 26.203 ML23005A1762023-02-23023 February 2023 R. E. Ginna Nuclear Power Plant - Issuance of Amendment No. 153 Revise Technical Specifications (TS) for the Spent Fuel Pool Charcoal System and Two (2) TS Administrative Changes ML23005A1222023-02-22022 February 2023 R. E. Ginna Nuclear Power Plant - Issuance of Amendment No 152 Adopt TSTF-315-Revise Technical Specification 3.1.8, Physics Tests Exceptions - Mode 2 RS-23-040, Constellation Energy Generation, LLC, Supplemental Information - Proposed Alternatives Related to the Steam Generators2023-02-21021 February 2023 Constellation Energy Generation, LLC, Supplemental Information - Proposed Alternatives Related to the Steam Generators ML22287A0692023-02-0808 February 2023 R. E. Ginna Station - Forward Fit Analysis (Epids L-2022-LRR-0074, 0076, 0079, 0091, 0092, 0093 and 0094) ML23031A2992023-02-0707 February 2023 R. E. Ginna Nuclear Power Plant - Withdrawal of an Amendment Request ML23010A0112023-02-0101 February 2023 R. E. Ginna Nuclear Power Plant - Issuance of Relief Request Associated with Inservice Testing of Refueling Water Storage Tank Outlet Value RS-23-003, Constellation Energy Generation, LLC, Summary of Changes to Quality Assurance Topical Report, NO-AA-10, and Decommissioning Quality Assurance Program, NO-DC-102023-01-31031 January 2023 Constellation Energy Generation, LLC, Summary of Changes to Quality Assurance Topical Report, NO-AA-10, and Decommissioning Quality Assurance Program, NO-DC-10 IR 05000244/20223012023-01-20020 January 2023 Initial Operator Licensing Examination Report 05000244/2022301 IR 05000244/20220122023-01-12012 January 2023 LLC - Design Basis Assurance Inspection (Teams) Inspection Report 05000244/2022012 ML22362A0382022-12-28028 December 2022 R. E. Ginna Nuclear Power Plant - Letter to Withdraw Application to Revise Technical Specifications 5.6.5, Core Operating Limits Report (COLR) ML22348A2062022-12-14014 December 2022 Re. Ginna Nuclear Power Plant - Annual Commitment Change Notification RS-22-123, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator2022-12-0707 December 2022 Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-577, Revised Frequencies for Steam Generator 2024-02-05
[Table view] |
See also: IR 05000244/2019010
Text
UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION I
2100 RENAISSANCE BLVD.
KING OF PRUSSIA, PA 19406-2713
April 16, 2020
EA-19-122
Mr. Bryan C. Hanson
Senior Vice President, Exelon Generation Company, LLC
President and Chief Nuclear Officer, Exelon Nuclear
4300 Winfield Road
Warrenville, IL 60555
SUBJECT: RESPONSE TO CONTESTED NOTICE OF VIOLATION DOCUMENTED IN
U.S. NUCLEAR REGULATORY COMMISSION R. E. GINNA INSPECTION
REPORT 05000244/2019010
Dear Mr. Hanson:
In your letters dated October 16, 2019, (Agencywide Documents Access and Management
System (ADAMS)1 Accession No. ML19291A173) and November 27, 2019, (ML19337A431),
you contested a Green Notice of Violation (NOV)05000244/2019010-02 that was documented
in the R.E. Ginna Nuclear Power Plant (Ginna) NRC Inspection Report 05000244/2019010
dated September 18, 2019 (ML19261A083). The NOV was cited against Title 10 of the Code of
Federal Regulations (10 CFR) Part 50, Appendix B, Criterion III, Design Control, and involved
a failure to design or ensure that in the event of a design-basis earthquake, the safety-related
Emergency Diesel Generator (EDG) Motor Control Centers (MCCs) H and J would not be lost
due to a low impedance electrical circuit fault in the non-safety-related vault sump pump motors.
The NRC acknowledged receipt of your letters in our letters to you dated November 14, 2019,
(ML19322A009) and December 19, 2019, (ML19353B357) in which we stated our intent to
perform a review and provide a letter documenting our decision relative to the contested NOV.
As a consequence of our review, the NRC is withdrawing the NOV and will modify our records
accordingly. The basis for our decision to withdraw the NOV is described below and results
from a thorough review of the Ginna licensing basis documentation and deliberation within the
NRC.
The Ginna licensing basis relative to this issue involves Atomic Industrial Forum (AIF), General
Design Criteria (GDC) 2, AIF-GDC 2,2 which, in part, requires those systems and components of
1
Designation refers to an Agency-wide Documents Access and Management System (ADAMS) accession
number. Documents referenced in this letter are publicly-available using the accession number in ADAMS at
https://adams.nrc.gov/wba/ For problems with the ADAMS Public Document Room (PDR), contact staff at 1-
800-397-4209, 301-415-4737, or by e-mail to pdr.resource@nrc.gov.
2 The AEC published a proposed Appendix A, "General Design Criteria for Nuclear Power Plant Construction
Permits" to 10 CFR Part 50 on July 11, 1967 (32 Fed. Reg. 10213). The proposed rule explained Every applicant for
a construction permit is required by the provisions of [section] 50.34 to include the principal design criteria for the
proposed facility in the application. For Ginna licensing, consideration of the draft GDC occurred after the
construction permit was issued during the phase where the AECs review was focused on the issuance of an
operating license. The Ginna plant design incorporated the version of the criteria proposed by the Atomic Industrial
Forum (AIF) as they are described in the Ginna Updated Final Safety Analyses Report. This makes this aspect (i.e.,
how the design of Ginna reflects the draft GDC) unique to Ginna.
B. Hanson -2-
reactor facilities that are essential to the prevention or the mitigation of the consequences of
nuclear accidents to be designed, fabricated, and erected to performance standards that enable
such systems and components to withstand, without undue risk to the health and safety of the
public, the forces that might reasonably be imposed by the occurrence of an extraordinary
natural phenomenon such as an earthquake. The Ginna Updated Final Safety Analysis Report
(UFSAR), Section 8.1.4, states that AIF-GDC 2 applies to the design of the emergency diesel
generators and that, Such protection provides a high degree of confidence in the operability of
such components in the event their use is required.
The Ginna design relative to IEEE Std 308-1971, IEEE Standard Criteria for Class 1E Electric
Systems for Nuclear Power Generating Stations, is discussed in the Ginna UFSAR and was
discussed in the application for a full-term operating license.3 The application made conclusions
regarding the sufficiency of physical separation, electrical isolation, and redundancy to preclude
common mode failures in Class 1E electrical systems during postulated natural events and
accidents. Our subsequent Safety Evaluation Report accompanying the issuance of your full-
power license referenced your application and the construction of the Ginna Plant in conformity
with your application, as a basis for our issuance of the Ginna operating license.4 Therefore, the
EDGs are to be suitably protected against the effects of severe external environmental
phenomena, such as a design-basis earthquake, to ensure a high degree of confidence in their
operability.
Our review of the records5 revealed that prior to Ginna receiving its provisional operating
license, AEC inspections identified that the EDG vaults were not provided with drains or sumps
and were vulnerable to flooding from postulated pipe leaks. As a result, the applicant made
modifications to add EDG vault sumps and associated pumps and motors. These actions were
subsequently acknowledged in an AEC inspection report to address the flooding concern. From
a review of the record associated with the full-term operating license for Ginna, this aspect of
the Ginna licensing basis has not changed. Our review supports the determination made at the
time of licensing that the degree of electrical isolation provided in the MCC H and J design is
sufficient to meet the high confidence standard for the EDGs described in Ginnas current
licensing basis. In addition to the documents already referenced, we considered in our review
retrieved documentation dating from the time of initial licensing regarding NRC technical staff
questions and responses related to electrical system seismic design and an as-built electrical
drawing of the H and J MCCs. Considering this information, we concluded that the NRC found
the degree of electrical isolation for this particular application to be consistent with the licensing
basis at the time Ginna received a full-power license.
The violation was associated with whether the supply breakers to MCC H and J are sufficiently
coordinated to prevent a loss of power to EDG fuel transfer pumps in the wake of a seismic
event in accordance with AIF-GDC 2. This aspect of the Ginna licensing basis has remained
unchanged since the issuance of a full-term operating license. Because, as stated above, at the
3
See R.E. Ginna, Unit 1 - Technical Supplement Accompanying Application for a Full-Term Operating License,
August 1972 (ML18186A129), Pages III-104 through III-107
4
See NUREG-0944 (ML17255A483), Section 22, Conclusions
5
See R.E. Ginna - Drawing, "Elec.-480V Motor Control Center #1H, #1J, & #1K" (ML18143B176); R.E. Ginna -
Special Quality Control Inspection Report 244/69-1, On 04/21/1969, Inspections of Four Safety-Oriented Reactor
Systems, Three Mechanical and One Electrical (ML18143A065); R.E. Ginna, Unit 1 - 07/08/1969 Memo re:
Inspection Report 05000244/1969009 (ML18142B666); R.E. Ginna - Questions Relating to Instrumentation and
Emergency Power. Requests Additional Information in Area of Testing (ML18143A262); R.E Ginna Unit 1,
Amendment No. 2 to Technical Supplement Accompanying Application to Increase Power (ML18143A104) (question
6 Response).
B. Hanson -3-
time of licensing the staff found that the degree of electrical isolation provided in the MCC H and
J design met applicable requirements and this specific plant configuration has remained
unchanged from the time of licensing to the time of the violation, we are withdrawing the NOV.
Finally, with respect to the associated green finding, it is our understanding that Exelon staff at
Ginna modified the EDG vault sump pump motor supports to address this issue.
This letter will be made available for public inspection and copying at
http://www.nrc.gov/readingrm/adams.html and at the NRC Public Document Room in
accordance with 10 CFR 2.390, Public Inspections, Exemptions, Requests for Withholding.
Should you have any questions concerning this letter, please contact me at (610) 337-5128.
Sincerely,
X /RA/
Signed by: Jimi T. Yerokun
Jimi T. Yerokun, Director
Division of Reactor Safety
Docket No. 50-244
License No. DPR-18
cc: Distribution via ListServ
ML20107F834
Non-Sensitive Publicly Available
SUNSI Review
Sensitive Non-Publicly Available
OFFICE RI/ORA RI/RC * NLO via email NRR/DEX *via email
NAME RMcKinley BKlukan/*BK EBenner/*EB
DATE 03/03/2020 04/15/2020 02/18/2020
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NAME CErlanger/*CE JYerokun KGamin/*KG
DATE 02/20/2020 04/16/2020 04/15/2020
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NAME GWilson/*GW CMiller/*CM
DATE 02/202020 02/25/2020