ML13182A048

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Audit Plan for Braidwood and Byron Licensee Action Taken to Resolve Turbine Building High Energy Line Break Non-Conformance
ML13182A048
Person / Time
Site: Byron, Braidwood  
Issue date: 07/10/2013
From: Joel Wiebe
Plant Licensing Branch III
To: Jeremy Bowen
Plant Licensing Branch III
Joel Wiebe, NRR/DORL 415-6606
References
Download: ML13182A048 (5)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20SSS"()001 July 10, 2013 MEMORANDUM TO: Jeremy S. Bowen, Chief Plant Licensing Branch 111-2 Division of Operating Reactor Licensing ice of ~uclear Reactor Regulation FROM:

J rt-..fi?eCd,~or Project Manager ant Licensing Branch 111-2 ivision of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

AUDIT PLAN FOR BRAIDWOOD AND BYRON LICENSEE ACTION TAKEN TO RESOLVE TURBINE BUILDING HIGH ENERGY LINE BREAK NON-CONFORMANCE By letter dated December 6,2012, to Exelon Generation Company, LLC, the NRC staff issued a request for additional information and suspended the review of the measurement uncertainty recapture power uprate amendment for the subject plants. The letter identified that a confirmatory audit may be needed to validate the resolution scope, including extent of condition, modifications, and analyses bound plant operation at the uprated power level. By letter dated July 5, 2013, the licensee confirmed that they are ready for the audit.

The audit plan for the audit is enclosed. Consistent with NRR Office Instruction LlC-111, "Regulatory Audits" the audit plan will be shared with the licensee to assist in their preparations for the audit.

Enclosure:

Audit Plan

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 BRAIDWOOD STATION. UNITS 1 AND 2 AND BYRON STATION. UNIT NOS. 1 AND 2.

DOCKET NOS. STN 50-456. STN 50-457, STN 50-454. AND STN 50-455 Audit Plan for Braidwood and Byron Turbine Building High Energy Line Break Resolution

Background

By letter dated December 6,2012, (Agency Document and Management System (ADAMS)

Accession No. ML12271A308) to Exelon Generation Company, LLC, the NRC staff issued a request for additional information and suspended the review of the measurement uncertainty recapture (MUR) power uprate amendment for the subject plants. The letter identified that a confirmatory audit may be needed to validate the resolution scope, including extent of condition, modifications, and analyses bound plant operation at the uprated power level. By letter dated July 5,2013, (ADAMS Accession No. ML13186A178) the licensee confirmed that they are ready for the audit.

Regulatory Audit Bases The guidance in NRC Regulatory Issue Summary (RIS) 2002-03, "Guidance on the Content of Measurement Uncertainty Recapture Power Uprate Applications," states that in areas for which the existing analyses of record do not bound the plant operation at the proposed uprated power level, the NRC staff will conduct a detailed review. In Attachment 1,Section III, of RIS 2002-03, analyses that are required by licensees to support licensing of the plant should be included in the scope of review. By the December 6, 2012, letter, the NRC documented its determination that the existing analyses of record that evaluates the performance of systems, structures, and components that mitigate a turbine building (TB) high-energy line break (HELB) did not bound plant operation at the proposed uprated power level.

The purpose of the audit is to confirm that the TB HELB non-conformance has been sufficiently resolved to continue the review of the MUR uprate amendment.

Regulatory Audit Scope The audit will review the licensee efforts to resolve the TB HELB non-conformance including the extent of condition, modifications, and analyses. Gothic Code analyses will be discussed and reviewed at the Exelon corporate offices, but Gothic Code files and input parameters will be obtained during the audit and taken back to the NRC offices to conduct independent confirmatory checks. Other analyses supporting the non-conformance resolution will be reviewed at the Exelon corporate offices. Modification packages will be reviewed at the Exelon

-2 corporate offices or the plant sites, as appropriate. Physical walkdowns of selected modifications will be performed at the plant sites.

Information and Other Material Necessary for the Regulatory Audit Plant configuration drawings to support Gothic Code analysis input and configuration parameters (piping and instrumentation diagrams and layout drawings that show break locations)

  • Calculation packages that provide input parameters to the Gothic Code analysis
  • Extent of condition review documentation related to the non-conformance resolution
  • Modification packages supporting the non-conformance resolution
  • Related analyses supporting the non-conformance resolution
  • Gothic Code analyses files and input/configuration parameters in a form that the auditors can take back to the NRC offices to conduct independent checks of the analyses.

Team Assignments Joel Wiebe Extent of condition review

  • Modification package review
  • Analyses review, except Gothic related analyses
  • Modification package and plant configuration information as necessary to support Gothic Code analysis review
  • Gothic Code analyses review
  • Independent checks of Gothic Code analyses, as appropriate
  • Confirmation that the Gothic Code is being used appropriately for this application, considering the Braidwood/Byron licensing basis and is consistent with NRC acceptance for other applications Logistics July 17, 2013 - Joel and Ahsan at Exelon Corporate offices July 18, 2013 - Joel at Byron Nuclear Station July 19, 2013 - Joel at Braidwood Nuclear Station Deliverables Audit Report - September 6, 2013

-3 References NRC letter dated December 6,2012 (ADAMS Accession No. ML12271A308)

Exelon letter dated July 5,2013 (ADAMS Accession No. ML13186A178)

ML13182A048 IIOFFICE

. NAME i DATE INRR/LPL3-2/PM JWiebe 7/8/13 INRR/LPL3-2/LA 1 SFigueroa If I SRohrer 1711/13 INRRISCVB/BC RDenning 718113 INRR/LPL3-2/BC JBowen 7/10/13 INRR/LPL3-2/PM JWiebe 7/10/13 I