ML082701136
| ML082701136 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 09/26/2008 |
| From: | Satorius M Region 3 Administrator |
| To: | Pardee C Exelon Generation Co |
| References | |
| EA-08-065, IR-08-007 EA-08-065 | |
| Download: ML082701136 (4) | |
Text
September 26, 2008 EA-08-065 Mr. Charles G. Pardee Chief Nuclear Officer and Senior Vice President Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
WITHDRAWAL OF NON-CITED VIOLATION DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 INSPECTION REPORT 05000237/2008007; 05000249/20008007
Dear Mr. Pardee:
On February 29, 2008, Mr. D. Wozniak, Exelon Generation Company, LLC (Exelon), Dresden Nuclear Power Station (DNPS) provided a response to the NRCs Component Design Basis follow-up inspection report issued on January 17, 2008, concerning activities conducted at your DNPS facility. Specifically, the Exelon letter contested Non-Cited Violation 05000237(249)/
2008007-01, Failure To Perform a 10 CFR 50.59 Evaluation For Exceeding Continuous Rating On The EDG. In a response dated March 28, 2008, the NRC acknowledged your letter and informed you that the NRC continued to evaluate the information you provided and that we would inform you once we finished our evaluation.
In the February 29, 2008, letter your staff stated that the violation was being contested because it was contrary to the DNPS licensing basis that had been submitted to, and accepted by, the NRC on a number of occasions. In the attachment to the letter, your staff detailed the DNPS licensing basis that supported the above conclusion.
The NRC has completed its evaluation and we agree with your position that the change was not a violation of 10 CFR 50.59. Accordingly, the non-cited violation is hereby withdrawn and we will modify our records accordingly. This decision is based on the Dresden plant specific licensing basis and Technical Specifications that existed at the time of the subject calculation revision.
We note that Dresden Station has implemented Technical Specifications that require periodic 24-hour endurance tests. In a telephone conference call with the NRC staff on April 26, 2007, your staff stated that the emergency diesel generator (EDG) loading was recalculated again and was within the continuous rating of the EDGs as of April 4, 2007. Your staff provided the NRC staff with the EDG loading calculation (ADAMS Accession No. ML071570498) on May 3, 2007.
The calculation stated that if future calculation revision shows the loading to exceed the continuous rating, a 10 CFR 50.59 safety evaluation would be performed to assess the impact on the Dresden design and licensing basis.
C. Pardee It is the NRCs position that emergency diesel generator endurance and margin testing should envelope the worst case loading for the emergency diesel generators. Upon determining that its endurance and margin testing does not envelope the worst case loading, the NRC expects a licensee to evaluate the condition and to implement appropriate actions in accordance with the regulatory requirements of 10 CFR 50.59 and the guidance of NRC Administrative Letter 98-10.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Mark A. Satorius Deputy Regional Administrator Docket Nos. 50-237; 50-249;72-037 License Nos. DPR-19; DPR-25 cc:
Site Vice President - Dresden Nuclear Power Station Plant Manager - Dresden Nuclear Power Station Regulatory Assurance Manager - Dresden Nuclear Power Station Chief Operating Officer and Senior Vice President Senior Vice President - Midwest Operations Senior Vice President - Operations Support Vice President - Licensing and Regulatory Affairs Director - Licensing and Regulatory Affairs Manager Licensing - Clinton, Dresden, and Quad Cities Associate General Counsel Document Control Desk - Licensing Assistant Attorney General Illinois Emergency Management Agency State Liaison Officer Chairman, Illinois Commerce Commission
C. Pardee It is the NRCs position that emergency diesel generator endurance and margin testing should envelope the worst case loading for the emergency diesel generators. Upon determining that its endurance and margin testing does not envelope the worst case loading, the NRC expects a licensee to evaluate the condition and to implement appropriate actions in accordance with the regulatory requirements of 10 CFR 50.59 and the guidance of NRC Administrative Letter 98-10.
In accordance with 10 CFR 2.390 of the NRC's "Rules of Practice," a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records System (PARS) component of NRC's Agencywide Documents Access and Management System (ADAMS), accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Mark A. Satorius Deputy Regional Administrator Docket Nos. 50-237; 50-249;72-037 License Nos. DPR-19; DPR-25 cc:
Site Vice President - Dresden Nuclear Power Station Plant Manager - Dresden Nuclear Power Station Regulatory Assurance Manager - Dresden Nuclear Power Station Chief Operating Officer and Senior Vice President Senior Vice President - Midwest Operations Senior Vice President - Operations Support Vice President - Licensing and Regulatory Affairs Director - Licensing and Regulatory Affairs Manager Licensing - Clinton, Dresden, and Quad Cities Associate General Counsel Document Control Desk - Licensing Assistant Attorney General Illinois Emergency Management Agency State Liaison Officer Chairman, Illinois Commerce Commission DISTRIBUTION See next page
- See previous concurrence DOCUMENT NAME:G:\\EICS\\ENFORCEMENT\\Enforcement Cases 2008\\EA-08-065 Dresden EDG Disputed\\DRAFT Dresden Disputed Violation Response EA-08-065 Rev 5 (2).doc Publicly Available Non-Publicly Available Sensitive Non-Sensitive To receive a copy of this document, indicate in the concurrence box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE RIII E RIII N
RIII E RIII D:OE NAME Lougheed*
West for Hills*
West*
Heck*
Hilton for Magruder1 DATE 9/24/08 9/25/08 9/25/08 9/25/08 9/24/08 OFFICE RIII RIII NAME OBrien*
Satorius DATE 9/25/08 9/26/08 OFFICIAL RECORD COPY 1 OE verbal concurrence received from N. Hilton on September 24, 2008.
Letter to Mr. Charles G. Pardee from Mark A. Satorius dated September 26, 2008
SUBJECT:
WITHDRAWAL OF NON-CITED VIOLATION DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 INSPECTION REPORT 05000237/2008007; 05000249/20008007 DISTRIBUTION:
RidsSecyMailCenter OCADistribution B. Mallett, DEDR C. Carpenter, OE D. Starkey, OE E. Leeds, NRR M. Ashley, NRR F. Brown, NRR J. Caldwell, RIII C. Marco, OGC R. Romine, OGC E. Brenner, OPA H. Bell, OIG G. Caputo, OI D. Holody, RI C. Evans, RII W. Jones, RIV V. Mitlyng, RIII P. Chandrathil, RIII A. Barker, RIII J. Lynch, RIII P. Lougheed, RIII P. R. Pelke, RIII M. Gryglak, RIII OEMAIL OEWEB TEB RAG1 CXG1 RidsNrrDirsIrib MAS KGO JKH3 CJP3 CAA1 DRPIII DRSIII CAC NDH DRS ROPreports@nrc.gov