ML19322A009

U.S. Nuclear Regulatory Commission Acknowledgement of Disputed Cited Violation 05000244/2019010-02

ML19322A009
Person / Time
Site:	Ginna
Issue date:	11/14/2019
From:	Paul Krohn Division of Reactor Safety I
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Gray M
References
EA-19-122 IR 2019010
Download: ML19322A009 (3)

See also: IR 05000244/2019010

Text

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION I

2100 RENAISSANCE BOULEVARD, SUITE 100

KING OF PRUSSIA, PA 19406-2713

November 14, 2019

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: U.S. NUCLEAR REGULATORY COMMISSION ACKNOWLEDGEMENT OF

DISPUTED CITED VIOLATION 05000244/2019010-02

Dear Mr. Hanson:

I am writing to acknowledge receipt of Exelon Generation Company, LLCs (Exelons) letter

dated October 16, 2019, in response to U.S. Nuclear Regulatory Commission (NRC) Inspection

Report 05000244/2019010 issued on September 18, 2019 (ML19261A083)1.

In the letter (ML19291A173), Exelon contested a finding of very low safety significance (Green)

and associated Notice of Violation (NOV 05000244/2019010-02) issued to R. E. Ginna Nuclear

Power Plant (Ginna). The finding and violation involved a failure by Ginna 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 an electrical circuit fault

in the non-safety-related sump pump motors. Exelon stated that Ginna met the NRC's

standards in effect at the time of its construction as well as those in effect at the time of

Application for Full-Term Operating License (1972) and as such, Exelon views that the NOV is

unwarranted and should be rescinded. Additionally, Exelon believes that the position reflected

in the inspection report constitutes a backfit and asks that the NRC assess these concerns

consistent with agency backfitting processes. The NRC intends to review Exelons response

and provide a letter documenting the basis for any decision relative to the disputed NOV and

backfitting.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) 2.390 of the NRCs

Rules of Practice, a copy of this letter and your response (if any) will be available electronically

for public inspection in the NRCs Public Document Room or from the Publicly Available

1

Designation refers to an Agencywide 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 ADAMS, please contact the NRCs Public

Document Room (PDR) reference staff at 1-800-397-4209; 301-415-4737, or by e-mail to

pdr.resource@nrc.gov

B. Hanson 2

Records component of the NRCs Agencywide Documents Access and Management System

(ADAMS). ADAMS is accessible from the NRCs website at http://www.nrc.gov/reading-

rm/adams.html (the Public Electronic Reading Room).

Should you have any questions concerning this letter, please contact me at (610) 337-5081.

Sincerely,

/RA/

Paul G. Krohn, Deputy Director

Division of Reactor Safety

Docket No. 50-244

License No. DPR-18

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ML19322A009

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OFFICE RI/DRS RI/DRS RI/DRP RI/EAGL RI/RC

NAME KMangan via email MGray ECarfang RMcKinley BKlukan

DATE 11/13/19 11/13/19 11/13/19 11/14/19 11/14/19

OFFICE RI/DRS

NAME PKrohn

DATE 11/14/19