ML20073E229

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R. E. Ginna Nuclear Power Plant - Supplemental Information Associated with the License Amendment Request to Add a One-Time Note for Use of Alternate Residual Heat Removal Methods
ML20073E229
Person / Time
Site: Ginna Constellation icon.png
Issue date: 03/12/2020
From: David Gudger
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
Download: ML20073E229 (2)


Text

Exelon Generation© 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50.90 March 12, 2020 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001

Subject:

Reference R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244 Supplemental Information Associated with the License Amendment Request to Add a One-Time Note for Use of Alternate Residual Heat Removal Methods

1. Letter from S. Rafferty-Czincila (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "License Amendment Request to Add a One-Time Note for Use of Alternate Residual Heat Removal Methods," dated February 25, 2020
2. Letter from S. Rafferty-Czincila (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission, "Supplemental Information Associated with the License Amendment Request to Add a One-Time Note for Use of Alternate Residual Heat Removal Methods," dated March 5, 2020 In the Reference 1 letter, Exelon Generation Company, LLC (EGC) requested changes to the Technical Specifications (TS) of the R. E. Ginna Nuclear Power Plant (Ginna). EGC proposed to revise TS 3.4. 7 ("RCS Loops - MODE 5, Loops Filled"), TS 3.4.8 ("RCS Loops

- MODE 5, Loops Not Filled"), TS 3.9.4 ("Residual Heat Removal (RHR) and Coolant Circulation - Water Level~ 23 Ft"), and TS 3.9.5 ("Residual Heat Removal (RHR) and Coolant Circulation - Water Level < 23 Ft") to add an asterisk to allow the use of alternate means for residual heat removal. Detailed descriptions of the alternatives were provided in the Technical Evaluation. This one-time change was requested to support the station in the shutdown of the reactor during the upcoming refueling outage scheduled to start in April 2020.

As a result of a detailed evaluation of the actions required to attain refueling conditions in the event that MOV 700 is unable to be opened, EGC has determined that a change in cooldown strategy is warranted. In Reference 1, EGC requested that water-solid steam generator cool down would be the Residual Heat Removal method to transition to Mode 5. EGC considers that the water-solid steam generator cooldown is still viable, but adds unnecessary operational complexity, for example, switching from the condensate pumps to auxiliary pumps during a loss-of-offsite power, to the cooldown methodology without a corresponding benefit to cooldown duration. Instead, EGC proposes to make use of our current normal cooldown strategy that employs auxiliary feedwater and the condenser dump valves and

Supplemental Information Associated with the License Amendment Request to Add a One-Time Note for Use of Alternate Residual Heat Removal Methods March 12, 2020 Page2 atmospheric relief valves for cooldown while in Mode 4 at Ginna. This method would be employed until Mode 4 conditions are attained which corresponds to reaching between 350°F and 330°F. At that point, normal RHR cooling will be attempted to be put into service. If MOV 700 cannot be opened, then work would begin to install the alternate RHR cooling components. Once installed, alternate RHR cooling as depicted in the Reference 1 letter would be initiated for entry into Mode 5. References to water-solid steam generator cooldown methods in the Reference 1 and Reference 2 letters should be considered superseded by this letter.

EGC has reviewed the information supporting a finding of no significant hazards consideration, and the environmental consideration, that were previously provided to the NRC in the Reference 1 letter. The supplemental information provided in this response does not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92. In addition, EGC has concluded that the information provided in this supplemental response does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

There are no regulatory commitments contained in this submittal. Should you have any questions concerning this submittal, please contact Tom Loomis at (610) 765-5510.

I declare under penalty of perjury that the foregoing is true and correct. This statement was executed on the 12th day of March 2020.

Respectfully, Jc.__ *J-r,.&_ J vv--

David T. Gudger Senior Manager - Licensing Exelon Generation Company, LLC cc:

NRC Regional Administrator, Region I NRC Senior Resident Inspector, Ginna NRC Project Manager, Ginna A. L. Peterson, NYSERDA