ML062080699

RAI Related to License Amendment Request to Revise Technical Specification (TS) Surveillance Requirement (SR) 3.4.3.1 and SR 3.1.7.10

ML062080699
Person / Time
Site:	Dresden
Issue date:	08/10/2006
From:	Banerjee M NRC/NRR/ADRO/DORL/LPLIII-2
To:	Crane C Exelon Generation Co
Banerjee M, NRR/ADPT, 415-2277
References
TAC MD2166, TAC MD2167
Download: ML062080699 (5)

Text

August 10, 2006 Mr. Christopher M. Crane, President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 3.4.3.1 AND 3.1.7.10 (TAC NOS. MD2166 AND MD2167)

Dear Mr. Crane:

By letter to the Nuclear Regulatory Commission (NRC) dated June 2, 2006, Exelon Generation Company, LLC submitted a request to revise Technical Specification (TS) Surveillance Requirement (SR) 3.4.3.1 and SR 3.1.7.10, for the Dresden Nuclear Power Station, Units 2 and 3. Specifically, the request proposes to change TS SR 3.4.3.1, to increase the allowable as-found main steam safety valve (MSSV) lift setpoint tolerance and TS SR 3.1.7.10, to increase the enrichment of sodium pentaborate used in the standby liquid control system.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on July 25, 2006, it was agreed that you would provide a response within 30 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-2277.

Sincerely,

/RA/

Maitri Banerjee, Senior Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237 and 50-249

Enclosure:

Request for Additional Information cc w/encl: See next page

August 10, 2006 Mr. Christopher M. Crane, President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION SURVEILLANCE REQUIREMENT 3.4.3.1 AND 3.1.7.10 (TAC NOS. MD2166 AND MD2167)

Dear Mr. Crane:

By letter to the Nuclear Regulatory Commission (NRC) dated June 2, 2006, Exelon Generation Company, LLC submitted a request to revise Technical Specification (TS) Surveillance Requirement (SR) 3.4.3.1 and SR 3.1.7.10, for the Dresden Nuclear Power Station, Units 2 and 3. Specifically, the request proposes to change TS SR 3.4.3.1, to increase the allowable as-found main steam safety valve (MSSV) lift setpoint tolerance and TS SR 3.1.7.10, to increase the enrichment of sodium pentaborate used in the standby liquid control system.

The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on July 25, 2006, it was agreed that you would provide a response within 30 days from the date of this letter.

The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-2277.

Sincerely,

/RA/

Maitri Banerjee, Senior Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237 and 50-249

Enclosure:

Request for Additional Information cc w/encl: See next page DISTRIBUTION:

PUBLIC LPL3-2 R/F RidsNrrDorlLpl3-2 RidsNrrPMMBanerjee RidsNrrLADClarke RidsAcrsAcnwMailCenter RidsOgcRp RidsRgn3MailCenter RidsNrrDorlDpr RidsNrrDssSbwb B. Parks, NRR ADAMS Accession Number ML062080699 *By e-mail dated July 26, 2006 OFFICE LPL3-2/PM LPL3-2/LA SBWB/BC LPL3-2/BC NAME MBanerjee DClarke GCranston* DCollins DATE 8/10/2006 8/10/2006 7/26 /2006 8/10/2006 OFFICIAL RECORD COPY

Dresden Nuclear Power Units 2 and 3 cc:

Site Vice President - Dresden Senior Vice President - Midwest Operations Exelon Generation Company, LLC Exelon Generation Company, LLC 6500 N. Dresden Road 4300 Winfield Road Morris, IL 60450-9765 Warrenville, IL 60555 Plant Manager - Dresden Nuclear Power Station Director - Licensing & Regulatory Affairs Exelon Generation Company, LLC Exelon Generation Company, LLC 6500 N. Dresden Road 4300 Winfield Road Morris, IL 60450-9765 Warrenville, IL 60555 Manager Regulatory Assurance - Dresden Vice President - Regulatory & Legal Affairs Exelon Generation Company, LLC Exelon Generation Company, LLC 6500 N. Dresden Road 4300 Winfield Road Morris, IL 60450-9765 Warrenville, IL 60555 U.S. Nuclear Regulatory Commission Assistant General Counsel Dresden Resident Inspectors Office Exelon Generation Company, LLC 6500 N. Dresden Road 200 Exelon Way Morris, IL 60450-9766 Kennett Square, PA 19348 Chairman Manager Licensing - Dresden Grundy County Board Exelon Generation Company, LLC Administration Building 4300 Winfield Road 1320 Union Street Warrenville, IL 60555 Morris, IL 60450 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Illinois Emergency Management Agency Division of Disaster Assistance &

Preparedness 110 East Adams Street Springfield, IL 62701-1109 Document Control Desk - Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

REQUEST FOR ADDITIONAL INFORMATION DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-237 AND 50-249 In reviewing the Exelon Generation Company LLCs (Exelons) submittal dated June 2, 2006, related to a license amendment request to revise Technical Specification (TS) Surveillance Requirement (SR) 3.4.3.1 and SR 3.1.7.10, to increase the allowable as-found main steam safety valve (MSSV) lift setpoint tolerance and to increase the enrichment of sodium pentaborate used in the standby liquid control system (SLCS), for the Dresden Nuclear Power Station, Units 2 and 3, the NRC has determined that the following information is needed in order to complete its review:

1. The final paragraph of GE-NE-0000-0053-8435-R1P, page 6-5, states, ?Exelon will ensure that the 10CFR50.62 [sic] requirement to inject 86 GPM [gallons per minute] of 13% sodium pentaborate solution, or the equivalent, plus the ATWS [anticipated transient without scram] specific injection requirements stated in Section 3.0 of this report are met for injection against the maximum reactor vessel pressure of 1301 psig at the SLCS sparger occurring during an ATWS event when the SLCS is in operation without opening of the SLCS relief valve. However, TS SR 3.1.7.7 requires a discharge pressure of 1275 psig for each pump. Explain the disparity in discharge pressure between the General Electric (GE) maximum and the SR. Also explain why TS SR 3.1.7.7 should not be revised to reflect the higher discharge pressure.

(Category 2.a)

2. Figure 3-8 of same report provides the bounding pressure against which SLCS must inject. Please provide the figure with reactor vessel lower plenum pressure scaled in psig. (Category 2.c)

ENCLOSURE

RAI CATEGORIES (Select only one, most dominant category for each RAI question)

1. More information is needed because of:

a. complexity of request

b. first-of-a-kind nature of request

c. NRC change in regulatory significance or focus

d. NRC questions on previously used methodology or guidance

e. licensee change to previously used methodology

f. licensee reduction in current safety margin

2. The review can not be completed without additional explanation or clarification of:

a. input variables or analytical assumptions

b. methodology used or results obtained

c. applicability or bounding nature of third party analyses or data correlations

d. differences from NRC guidance documents (SRP, RG, etc.)

e. no significant hazards consideration discussion

f. environmental considerations discussion

g. applicable regulatory requirements discussion

h. information that appears to be incorrect and needs to be corrected

i. response to previous RAI appears inadequate

3. Reviewer requesting information even though the question is, or the question asks for:

a. not directly related to the request

b. inconsistent with applicable codes, standards, RGs, or SRP sections

c. information accessible from readily available sources and was explicitly referenced

d. information does not appear needed given the precedent cases discussed in the request

e. information that is not safety significant or pertinent to the regulatory finding

f. information that is known to engineers who work in the general technical area

g. going beyond the current licensing basis and doesnt need to be asked

h. a formal commitment

4. Other (please specify)