ML19084A078

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Response to Request for Additional Information Revised - Final to Generic Letter 2004-02
ML19084A078
Person / Time
Site: Calvert Cliffs  Constellation icon.png
Issue date: 03/25/2019
From: David Gudger
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
EPID L-2018-LLE-0013, GL-04-002
Download: ML19084A078 (3)


Text

Exelon Generation.~

March 25, 2019 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 200 Exelon Way Kennett Square, PA 19348 www.exeloncorp.com 10 CFR 50.90 Renewed Facility Operating License Nos. DPR-53 and DPR-69 Docket Nos. 50-317 and 50-318

Subject:

Response to Request for Additional Information Revised - Final Response to Generic Letter 2004-02

References:

1. Letter from Mr. J. Barstow (Exelon} to Document Control Desk (NRC},

dated August 13, 2018, Final Response to Generic Letter 2004-02.

2. Letter from Mr. D.T. Grudger (Exelon) to Document Control Desk (NRC}, dated October 10, 2018, Supplement to Final Response to Generic Letter 2004-02.
3. E-mail from Michael Marshall (NRC} to Enrique Villar (Exelon} Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Request for Additional Information Regarding Exemption Request From 1 OCFR50.46(A)(1} to Support Resolution of GSl-191 (EPID L-2018-LLE-0013), dated March 11, 2019.

By letters dated August 13, 2018 (Agencywide Documents Access and Management System (ADAMS} Accession No. ML18226A189) (Reference 1 }, as supplemented by letter dated October 10, 2018 (ADAMS Accession No. ML18283A034} (Reference 2), Exelon Generation Company, LLC (Exelon) submitted a license amendment request (LAA), exemption request, and updated response to Generic Letter 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors,"

dated September 13, 2004 (ADAMS Accession No. ML042360586}, for Calvert Cliffs Nuclear Power Plant, Units 1 and 2 (Calvert Cliffs).

A request for additional information (RAI) was transmitted via e-mail on March 11, 2019 (Reference 3).

This letter documents Exelon's response to the RAI. There is no regulatory commitment contained in this letter.

Response to Request for Additional Information Revised - Final Response to Generic Letter 2004-02 March 25, 2019 Page2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 251h day of March 2019.

If you should have any questions regarding this submittal, please contact Enrique Villar at 61 0-765-5736.

Respectfully, tA-f k,u-;) /. ~

cJyt>-

David T. Gudger Manager

  • Licensing & Regulatory Affairs Exelon Generation Company, LLC

Attachment:

Response to Request for Additional Information cc:

NRG Regional Administrator, Region I NRG Senior Resident Inspector, CCNPP NRG Project Manager, NRR, CCNPP D. A. Tancabel, State of Maryland w/attachments II

ATTACHMENT RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION -

FINAL RESPONSE TO GENERIC LETTER 2004-02 Page 1of1 NRC REQUEST By letter dated August 13, 2018 (Agencywide Document Access Management System (ADAMS) Accession No. ML18226A189) a supplemented by letter dated October 10, 2018 (ADAMS Accession No. ML18283A034), Exelon Generation Company, LLC (Exelon, the licensee) submitted an exemption request for Calvert Cliffs Nuclear Power Plant, Units 1 and

2. The proposed exemption request would allow use of the risk-informed method for assessing the impact of debris on long-term cooling.

The U.S. Nuclear Regulatory Commission (NRC) staff has reviewed the information provided in the LAR and has determined that additional information is needed to complete its review. Below is the NRC staff's request for additional information. The request for additional information was discussed with you on February 26, 2019, and it was agreed that your response would be provided within 30 days of the date of this email.

The request for additional information question listed below is not a complete listing of the additional information needed to complete the NRC staff's review. Additional RAI questions will be provided by separate emails.

REQUEST FOR ADDITIONAL INFORMATION Section 51.30(a) of Title 1 O of the Code of Federal Regulations requires, in part, that an environmental assessment include a brief discussion of the environmental impacts of the proposed action and alternatives, as appropriate. NRC staff has determined that environmental impacts (e.g., additional worker dose and radiologically contaminated waste) could occur in association with the No Action Alternative, should the subject exemption and license amendment request not be granted.

Section 2.2 of Attachment (2) of Exelon's letter dated August 13, 2018 identifies plant modifications and estimates the total dose to be expended for replacement of insulation under the No Action Alternative. But, no estimate is provided for the amount of fibrous insulation that would be replaced.

In order to support the evaluation of potential waste management impacts, NRC requests that Exelon provide the estimated volume of radiologically-contaminated waste that would be generated from the replacement of the existing insulation on the components discussed in Section 2.2 of Attachment (2).

EXELON'S RESPONSE Exelon estimates the volume of radiologically-contaminated waste generated from the replacement of the existing insulation on the components discussed in Section 2.2 of Attachment (2) for both units would be approximately 7,000 ft3 of insulation blankets, and 29,000 ft2 of insulation jacketing ranging in thickness from 0.01 O" to 0.030".