OFFICIAL USE ONLY – SENSITIVE INTERNAL …2017/05/25 · OFFICIAL USE ONLY – SENSITIVE INTERNAL...

OFFICIAL USE ONLY – SENSITIVE INTERNAL INFORMATION


May 25, 2017 MEMORANDUM TO: Theresa Clark

Executive Technical Assistant Office of Executive Director for Operations

FROM: David J. Wrona, Chief /RA/ Plant Licensing Branch III Division of Operating Reactor Licensing

Office of Nuclear Reactor Regulation SUBJECT: OEDO-17-00280 - BRIEFING PACKAGE FOR DROP-IN VISIT ON

JUNE 9, 2017, BY SENIOR MANAGEMENT OF EXELON GENERATION COMPANY, LLC WITH CHAIRMAN SVINICKI, COMMISSIONER BARAN, AND COMMISSIONER BURNS

Enclosed is the briefing package in support of the June 9, 2017, drop-in visit by senior

management of Exelon Generation Company, LLC (Exelon) with Chairman Svinicki,

Commissioner Baran, and Commissioner Burns. Please contact Blake Purnell at 301-415-1380

if you need any additional information.

Docket Nos. STN 50-456, STN 50-457, STN 50-454, STN 50-455, 50-317, 50-318, 50-461, 50-237, 50-249, 50-244, 50-373, 50-374, 50-352, 50-353, 50-220, 50-410, 50-219, 50-277, 50-278, 50-254, 50-265, 50-289, and 50-333

Enclosure: Briefing Package cc w/encl: W. Dean, NRR M. Evans, NRR B. McDermott, NRR M. J. Ross-Lee, NRR E. Benner, NRR K. Brock, NRR D. Wrona, NRR D. Broaddus, NRR J. Danna, NRR S. Anderson, NRR G. Casto, NRR D. Huyck, NSIR A. Dimitriadis, RGN I D. Schroeder, RGN I A. Burritt, RGN I S. Kennedy, RGN I K. Stoedter, RGN III E. Duncan, RGN III J. Cameron, RGN III B. Dickson, RGN III C. Scott, OGC

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OEDO-17-00280 - BRIEFING PACKAGE FOR DROP-IN VISIT ON JUNE 9, 2017, BY SENIOR MANAGEMENT OF EXELON GENERATION COMPANY, LLC WITH CHAIRMAN SVINICKI, COMMISSIONER BARAN, AND COMMISSIONER BURNS DATED May 25, 2017 DISTRIBUTION: OEDO-17-00280 NON-PUBLIC LPL1 r/f LPL3 r/f LSPB r/f RidsEdoMailCenter Resource RidsNrrDorl Resource RidsNrrDorlLpl1 Resource RidsNrrDorlLpl3 Resource RidsNrrDorlLspd Resource RidsNrrDpr Resource RidsNrrDprPrmb Resource RidsNrrDprPrlb Resource RidsNrrDra Resource RidsNrrDraAphb Resource RidsNrrDirsIpab Resource RidsNrrDss Resource RidsNrrDssSrxb Resource RidsNrrLASRohrer Resource RidsNrrMailCenter Resource

RidsNrrOd Resource RidsNrrPMExelon Resource RidsNrrPMBraidwood Resource RidsNrrPMByron Resource RidsNrrPMCalvertCliffs Resource RidsNrrPMClinton Resource RidsNrrPMDresden Resource RidsNrrPMREGinna Resource RidsNrrPMLaSalle Resource RidsNrrPMLimerick Resource RidsNrrPMNineMilePoint Resource RidsNrrPMOysterCreek Resource RidsNrrPMPeachBottom Resource RidsNrrPMQuadCities Resource RidsNrrPMThreeMileIsland Resource RidsNrrPMFitzPatrick Resource RidsRgn1MailCenter Resource RidsRgn3MailCenter Resource

ADAMS Accession Nos.: Package: ML17121A423 Briefing Package: ML17142A238 OFFICE NRR/DORL/LPL3 NRR/DORL/LPL3/LA NRR/DORL/LPL3/BC NAME BPurnell SRohrer DWrona DATE 05/22/17 05/22/17 05/25/17

OFFICIAL RECORD COPY

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DROP-IN VISIT BY EXELON GENERATION COMPANY, LLC

WITH

CHAIRMAN SVINICKI

COMMISSIONER BARAN COMMISSIONER BURNS

June 9, 2017

CONTACT: Blake Purnell, NRR ADAMS Accession No. ML17142A238 Theresa Clark, OEDO

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CONTENTS

Page AGENDA ................................................................................................................1 LICENSEE SUMMARY ..........................................................................................2 SIGNIFICANT ISSUES/TALKING POINTS ...........................................................3

Plant Status in Current Electric Market ........................................................3 Physical Security ..........................................................................................4 Risk and Reactor Oversight Process ...........................................................5

MANAGEMENT INFORMATION

Licensee Organization ..................................................................................8 Biographical Information ............................................................................ 11

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- 1 - OFFICIAL USE ONLY – SENSITIVE INTERNAL INFORMATION

Agenda

June 9, 2017

ITINERARY

TIME PERSON VISITED CONTACT PERSON EXTENSION

1:30 pm – 2:00 pm Commissioner Baran Stacey Schumann 301-415-1839

2:00 pm – 2:30 pm Commissioner Burns Kathleen Blake 301-415-1820

3:00 pm – 3:30 pm Chairman Svinicki Janet Lepre 301-415-1750

VISITORS REPRESENTING EXELON GENERATION COMPANY, LLC

• Bryan Hanson, Senior Vice President Exelon Generation, President and Chief Nuclear

Officer, Exelon Nuclear

• Scot Greenlee, Senior Vice President, Engineering and Technical Services • Bradley Fewell, Senior Vice President, Regulatory Affairs, and General Counsel

• Chris Mudrick, Senior Vice President, Northeast Operations, and Chief Operating

Officer, CENG

TOPICS OF DISCUSSION

• Plant Status in Current Electric Market • Physical Security • Risk and Reactor Oversight Process

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LICENSEE SUMMARY

Exelon Generation Company, LLC (EGC) is one of the largest competitive power generators in the United States, with generating capacity of more than 33,300 megawatts. With strong positions in the Midwest, Mid-Atlantic, Texas, and California, EGC is the largest owner and operator of nuclear plants in the United States and maintains a growing renewable energy development business headquartered in Baltimore, Maryland. Exelon Nuclear, a division of EGC, operates 23 reactors at 14 facilities located in Illinois, Maryland, New Jersey, New York, and Pennsylvania. The fleet has the capacity to generate more than 20,200 megawatts of electricity. Exelon Nuclear operates the following nuclear facilities: Illinois: Braidwood Station, Units 1 and 2 Byron Station, Unit Nos. 1 and 2 Clinton Power Station, Unit No. 1 Dresden Nuclear Power Station, Units 2 and 3 LaSalle County Station, Units 1 and 2 Quad Cities Nuclear Power Station, Units 1 and 2 Maryland: Calvert Cliffs Nuclear Power Plant, Units 1 and 2 New Jersey: Oyster Creek Nuclear Generating Station New York: James A. FitzPatrick Nuclear Power Plant

Nine Mile Point Nuclear Station, Units 1 and 2 R.E. Ginna Nuclear Power Plant Pennsylvania: Limerick Generating Station, Units 1 and 2 Peach Bottom Atomic Power Station, Units 2 and 3 Three Mile Island Nuclear Station (TMI), Unit 1

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SIGNIFICANT ISSUES/TALKING POINTS Plant Status in Current Electric Market Illinois • On June 20, 2016, Exelon submitted separate letters certifying permanent cessation of

power operations at Clinton Power Station (Clinton) by June 1, 2017, and Quad Cities Nuclear Power Station (Quad Cities) by June 1, 2018, per 10 CFR 50.82, “Termination of license.”

• On December 1, 2016, the Illinois General Assembly passed the Future Energy Jobs Bill and the Illinois Governor signed the Bill on December 7, 2016. The Bill established a zero emission standard that will provide a subsidy to Clinton and Quad Cities. Because of this, Exelon reversed its decision to permanently cease power operations at Clinton and Quad Cities.

• Federal lawsuits have been filed against the Illinois zero emission standard.

New York • On March 16, 2016, Entergy provided its letter certifying permanent cessation of power

operations at the FitzPatrick Nuclear Power Plant. The decision to shutdown the plant was based on economic factors.

• In July 2016, the New York Public Service Commission (PSC) announced a proposal to aid upstate New York nuclear plants (Ginna, Nine Mile Point, and FitzPatrick) with a zero-emissions credit (ZEC) program. After the PSC announcement, Exelon and Entergy announced that they were working on a deal for Exelon to purchase Fitzpatrick from Entergy.

• On August 1, 2016, the New York PSC adopted a clean energy standard, which included the ZEC program.

• On August 18, 2016, Entergy and Exelon submitted a joint license transfer application, requesting approval of the transfer of the FitzPatrick license to Exelon. The NRC order approving the license transfer was issued on March 1, 2017, and Exelon assumed ownership of FitzPatrick on March 31, 2017.

• Since April 1, 2017, all New York state customers are assessed ZEC charges on their electric bills.

• Federal lawsuits have been filed against the New York PSC ZEC program.

Pennsylvania • On May 24, 2017, Exelon announced the results of the 2020-2021 PJM capacity auction.

TMI did not clear in this auction or the past three.

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• On May 30, 2017, Exelon announced its intention to shut down TMI, Unit 1, by September 30, 2019, “absent needed policy reforms.” The NRC has not yet received formal correspondence related to a cessation of operations.

• Exelon and other nuclear plant owners have lobbied the Pennsylvania state legislature to provide support similar to what has been provided by Illinois and New York.

Physical Security Key Messages • NRC staff’s assessment of the security baseline inspection program is ongoing. • NRC staff is developing the response to SRM-SECY-16-0073, “Options and

Recommendations for the Force-on-Force [FOF] Inspection Program in Response to SRM-SECY-14-0088.”

• The staff is meeting with internal and external stakeholders to solicit input on the FOF

and baseline security inspection programs. • By October 2017, the staff will provide recommendations in a vote paper to the

Commission on how to make the programs more efficient.

Facts • The staff held public meetings on March 2 and April 20, 2017, to discuss the status of its

assessment and to solicit feedback. Proposed Commission paper topics were discussed and stakeholder feedback was requested. Industry stakeholders are not proposing NRC observation of licensee-conducted FOF exercises in lieu of NRC-conducted exercises as part of this assessment.

• Staff met with the Nuclear Energy Institute (NEI) to discuss industry’s outline of a

proposed security event mitigation assessment (SEMA) that would credit operator actions and FLEX equipment in conjunction with tactical law enforcement response. The SEMA was submitted to the NRC on May 3, 2017, and the staff is reviewing the assessment for potential endorsement.

• Staff from the Office of Nuclear Security and Incident Response solicited internal

stakeholder input through a series of working group sessions with headquarters and regional managers and staff.

• The staff completed a comprehensive review of the security baseline inspection program

inspection manual chapter and inspection procedures (IP) in March 2017. The review identified multiple opportunities for efficiencies and improved inspection schedule coordination and identified redundant inspection items to be consolidated.

• Staff is revising the FOF IP to focus on performance-based inspection activities and

eliminate compliance-based activities that are redundant to other security inspections under the baseline inspection program.

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• Staff is developing a proposal to improve exercise effectiveness by reducing artificialities.

• The staff plans to start a comprehensive review of the security significant determination

processes (SDP) by the end of June 2017. The review will help ensure that the SDPs are effective and efficient, and reflect a reasonable level of assurance.

• Staff is coordinating with industry to evaluate timeframes for risk-informed compensatory

measures, consistent with Commission direction regarding the concept of “high assurance” and “reasonable assurance.”

Risk and Reactor Oversight Process (ROP) RASP Handbook and SPAR Modeling • In a letter dated January 12, 2017 (ADAMS Accession No. ML17013A161), Exelon

provided four recommendations (see below) to improve the NRC’s use of the Standardized Plant Analysis Risk (SPAR) Model and Risk Assessment of Operational Events (RASP) Handbook. The letter cited examples of findings and potential findings at Exelon plants to support its recommendations.

• In a letter dated March 21, 2017 (ADAMS Accession No. ML17066A245), the NRC informed Exelon that it will continue to engage industry on the specific recommendations in Exelon’s letter. Several key points related to this subject are: o It is the responsibility of the NRC staff to develop the basis for enforcement

decisions, including preparation of the risk assessment. o In some cases, NRC SPAR models are more conservative than licensees’

models. To address this, the basis for differences in modeling needs to be understood.

o The NRC staff has evaluated the costs and benefits associated with using

licensees’ probabilistic risk assessment (PRA) models in lieu of the SPAR models and concluded that a lack of a strong business case and the lack of universal licensee interest in sharing their PRA models make this proposal unfeasible.

o The staff will continue to engage with a broad range of stakeholders through the

Risk Informed Steering Committee and other venues to address the Exelon’s recommendations.

• On May 2, 2017, the NRC staff held a public meeting to discuss industry concerns

regarding the RASP Handbook and Significance Determination Process. At that meeting, the NRC and industry agreed that the Risk Informed Steering Committee would be best suited for vetting the path forward on the issues discussed.

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Exelon Recommendation 1: Use the best available model • Differences in the model results are mostly due to differing assumptions in areas outside

the base model configuration (e.g., common cause failure and human reliability analysis).

• The NRC staff will continue to meet with stakeholders to revisit the means of addressing

model differences. Exelon Recommendation 2: Realistically treat failure events • Current PRA methods primarily model at the system and component level because of

limited reliability data. • Where detailed data is available, the NRC staff is open to refining the data resolution. Exelon Recommendation 3: Rely on a fact-based common cause failure (CCF) treatment • In the SPAR models, the treatment of CCF is consistent with the level of detail in PRA

models, including data collection methods. • The NRC staff may deviate from the CCF methods in the RASP handbook if the staff

concludes that the RASP methodology leads to overly conservative results. Exelon Recommendation 4: Eliminate the minimum joint human error probability (HEP) • The minimum joint HEP of 1E-6 is based on a number of research activities; therefore, it

is not arbitrary. • The minimum joint HEP is a valuable screening tool to identify over-reliance on operator

manual actions. • NRC staff will continue to engage industry and other stakeholder to determine

circumstances which may justify using joint HEPs lower than 1E-6. Holistic Engineering Inspection Review This is a comprehensive NRC review of the suite of NRC baseline engineering inspections, which include: • Fire Protection (triennial team inspection) • Heat Sink (annual/triennial inspections) • Inservice Inspection Activities (inspection every refueling outage) • Design Bases Assurance (triennial team inspection) • Design Bases Assurance Programs (triennial inspection) • Evaluations of Changes, Tests, and Experiments (triennial inspection)

The purpose of this review is to identify and implement short-term program changes that will make our engineering inspection program more effective and efficient:

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• Consider eliminating inspection overlap areas • Consider increased focus on current engineering performance • Discuss other efficiency or effectiveness program changes that could be implemented on

a longer timeline The industry is also performing a similar review, which is expected to be completed in 2017. Lessons learned from the recent changes made to the component design bases inspection program indicated that a more holistic review of all engineering inspections may ensure that we are performing inspections of licensee engineering areas in the most effective and efficient way. The NRR Division of Inspection and Regional Support is leading a working group, with representatives from all four regions, to accomplish the holistic review. A charter for the working group is in development. Public outreach has begun using the ROP monthly public meetings. Future communications with interested stakeholders are planned, and the Commission will be engaged consistent with the staff requirements memorandum on COMSECY-16-0022.

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LICENSEE ORGANIZATION

CEO: Chief Executive Officer CFO: Chief Financial Officer CNO: Chief Nuclear Officer COO: Chief Operating Officer EVP: Executive Vice President SVP: Senior Vice President VP: Vice President

President and CEO ExelonChristopher M. Crane

Senior VP & Chief HR Officer ExelonAmy Best

EVP & Chief Enterprise Risk Officer

Paymon Aliabadi

VP and Chief of StaffSue Wallace

Senior EVP ExelonCEO Exelon Utilities

Denis P. O’Brien

Senior EVP and CFOJonathan W. Thayer

Senior EVP Chief Strategy Officer

William A. Von Hoene

Sr. EVP & Chief Commercial OfficerPresident & CEO Exelon Generation

Kenneth W. Cornew

EVP& Chief Administrative Officer & President BSC

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Licensee Organization – Exelon Generation

Sr. EVP & Chief Commercial Officer

President & CEO Exelon Generation

Kenneth Cornew

VP & Managing DirectorGeneration Development

Corey Hessen

EVP & Chief Operating Officer

Exelon Generation

Michael Pacilio

SVP Exelon Generation, President &

Chief Nuclear Officer Exelon Nuclear

Bryan Hanson

SVP Exelon Generation,President Exelon Power

Ronald DeGregorio

EVP Exelon &CEO Constellation

Joseph Nigro

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Licensee Organization – Exelon Nuclear

SVP Exelon Generation &CNO Exelon Nuclear

Bryan Hanson

COO FleetOperations

David Rhoades

SVP Engineering & Technical Services

Scot Greenlee

SVP Strategy & Planning

Carol Peterson

COO CENGSVP NE Operations

Chris Mudrick

VP Nuclear Oversight

David Hoots

SVP Organizational Effectiveness and Performance Assessment

Susan Landahl

SVP Regulatory Affairs &

General Counsel

Bradley Fewell

VP Licensing & Regulatory

Affairs

Keith Jury

Director Licensing –

West

Glen Kaegi

Director Licensing –

East

Jim Barstow

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BIOGRAPHICAL INFORMATION

Bryan Hanson Senior Vice President, Exelon Generation

President and Chief Nuclear Officer, Exelon Nuclear

Bryan Hanson is responsible for ensuring that Exelon Generation maintains high levels of performance and safety across its nuclear fleet. Exelon Generation operates the largest nuclear fleet in the nation, which includes 23 reactors at 14 facilities located in Illinois, Maryland, Nebraska, New Jersey, New York, and Pennsylvania. Hanson has more than 25 years of progressive experience in the nuclear power industry. Prior to his current role, Hanson was chief operating officer of Exelon Generation’s nuclear fleet with oversight for the daily operation of Braidwood, Byron, Calvert Cliffs, Clinton, Dresden, Fort Calhoun, Ginna, LaSalle, Limerick, Nine Mile Point, Oyster Creek, Peach Bottom, Quad Cities, and TMI nuclear stations. During his tenure with Exelon, Hanson served as the senior vice president of Midwest operations, site vice president for Exelon’s Braidwood Generating Station and the site vice president for Clinton Power Station. He also has been vice president of nuclear oversight, Limerick Generating Station plant manager and director of operations and work control. Hanson earned a bachelor’s degree in nuclear engineering from the University of Wisconsin at Madison and a Master of Business Administration from St. Ambrose University in Davenport, Iowa. Hanson is a graduate of the Institute of Nuclear Power Operations Senior Nuclear Plant Management Program and the Exelon Leadership Institute at the Kellogg Graduate School of Management at Northwestern University.

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Scot Greenlee

Senior Vice President, Engineering and Technical Services Mr. Greenlee is responsible for governance and oversight of engineering functions for Exelon’s 22 nuclear reactors and the Fort Calhoun Nuclear Station in Omaha, Neb. Prior to this role, Mr. Greenlee was Exelon’s vice president of engineering and served as the engineering director at Byron station. Mr. Greenlee began his nuclear career as an officer in the United States Nuclear Navy. Following a successful Navy career, Mr. Greenlee was a Nuclear Regulatory Commission resident inspector at the Beaver Valley Nuclear Station in Pennsylvania. He has held numerous leadership positions in engineering and operations, having worked at four other nuclear facilities prior to joining Exelon. Mr. Greenlee obtained his bachelor’s degree in electrical engineering from the Georgia Institute of Technology. He completed the Navy Nuclear Power School and Prototype Training, NRC Inspector Training and the Institute of Nuclear Power Operations Senior Nuclear Plant Management Course.

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J. Bradley Fewell Senior Vice President, Regulatory Affairs, and General Counsel

Fewell oversees the licensing and regulatory affairs functions, as well as the coordination of issues that involve legal, communication and governmental affairs activities, for Exelon Generation’s nuclear fleet. The fleet consists of 23 reactors at 14 locations in Illinois, Maryland, Nebraska, New Jersey, New York and Pennsylvania. He also manages legal matters involving all of Exelon’s generation assets. Fewell joined Exelon in 2003 as an Assistant General Counsel and has held several key leadership positions within Exelon’s Legal department during his tenure with the company. Previously, Fewell served as Regional Counsel for the Nuclear Regulatory Commission. Fewell earned a bachelor’s degree from Wabash College in Indiana, with a double major in English and Psychology. He earned his law degree at Rutgers University Law School. Fewell serves as chairman with both the Nuclear Energy Institute and Nuclear Electric Insurance Limited lawyer advisory committees. He also serves as vice chair of the nuclear division of the American Bar Association’s Section of Public Utility, Communications and Transportation Law. He is a member of the technical advisory board for the National Museum of Nuclear Science and History.

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Chris Mudrick

Senior Vice President, Northeast Operations Chief Operating Officer, CENG

Mudrick is responsible for the oversight of Exelon’s Northeast sites: Calvert Cliffs, Nine Mile Point, Oyster Creek, and R.E. Ginna. Mudrick has more than 29 years of progressive experience in plant operations in support of nuclear power stations, including his current responsibilities in Exelon Nuclear. Prior to his current position, Chris was the Senior Vice President Mid-Atlantic Operations for the Exelon Nuclear Sites: Limerick, Peach Bottom, Oyster Creek, and Three Mile Island. Previous positions include the Sr. Vice President Operations Support, Site Vice President and Plant Manager Limerick Generating Station, Director of Operations, and Director of Engineering at Limerick. Prior to that, he served in various management positions at Limerick, Peach Bottom, and Millstone. Mudrick holds a Bachelor of Science degree in Electrical Engineering from Lehigh University. He was licensed by the NRC as a Senior Reactor Operator at Limerick. In 2008, he completed the Exelon Leadership Institute at Northwestern University. Chris completed the Harvard Business School Advanced Management Program 189 in October 2015. He has completed several leadership programs throughout his career, and is a licensed professional engineer in the state of Pennsylvania. He is a member of the American Nuclear Society.

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OFFICIAL USE ONLY – SENSITIVE INTERNAL …2017/05/25 · OFFICIAL USE ONLY – SENSITIVE INTERNAL...

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Transcript of OFFICIAL USE ONLY – SENSITIVE INTERNAL …2017/05/25 · OFFICIAL USE ONLY – SENSITIVE INTERNAL...