ML18094A796

Enforcement Discretion Per Egm 15-002

ML18094A796
Person / Time
Site:	Dresden
Issue date:	04/12/2018
From:	Russell Felts NRC/NRR/DRA
To:	Bryan Hanson Exelon Generation Co, Exelon Nuclear
Wu A
References
EGM 15-002, EPID: L-2018-LLL-0006
Download: ML18094A796 (3)

Text

April 12, 2018 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Office (CNO)

Exelon Nuclear Dresden Nuclear Power Station 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

REQUEST TO EXTEND ENFORCEMENT DISCRETION PROVIDED IN ENFORCEMENT GUIDANCE MEMORANDUM 15-002 FOR TORNADO-GENERATED MISSILE PROTECTION NON CONFORMANCES IDENTIFIED IN RESPONSE TO REGULATORY ISSUE

SUMMARY

2015-06, TORNADO MISSILE PROTECTION (EPID: L-2018-LLL-0006)

Dear Mr. Hanson:

By letter dated March 13, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18082A081), Exelon Generating Company, LLC, requested the U.S. Nuclear Regulatory Commission (NRC, the Commission) to extend the expiration date for the period of enforcement for Dresden Nuclear Power Plant, Units 2 and 3, (DNPS), from June 10, 2018, to June 10, 2020, in accordance with information provided in Enforcement Guidance Memorandum (EGM) 15-002, Revision 1, Enforcement Discretion for Tornado Generated Missile Protection Non-Compliance, dated February 7, 2017 (ADAMS Accession No. ML16355A286).

Subsequently, the NRC staff has reviewed your letter in accordance with Commission direction as provided in EGM 15-002, Revision 1, and staff guidance provided in NRC Interim Staff Guidance, DSS-ISG-2016-01, Revision 1, Clarification of Licensee Actions in Receipt of Enforcement Discretion [per EGM 15-002]. dated November 2017 (ADAMS Accession No. ML17128A344).

The NRC staff reviewed the information that you have provided and finds that the compensatory measures taken are consistent with EGM 15-002, Revision 1, and with interim staff guidance found in DSS-ISG-2016-01, Revision 1. Specifically, the staff found that DNPS has sufficiently described and evaluated the following six items described in DSS-ISG-2016-01, Rev. 1, Appendix B: nonconformances applicable to the EGM, prompt compensatory actions, long-term compensatory actions, assessment of compensatory measures, need for additional enforcement discretion time, and timeline for restoring licensing basis compliance. The NRC staff has concluded that the actions taken by DNPS can be effectively implemented and justify extension of the enforcement discretion date to June 10, 2020, because DNPS has sufficiently described and documented compensatory measures for identified nonconforming structures, systems, and components (SSCs), provided assurance that compensatory measures will be effective and maintained through the extended period for enforcement discretion, and described

B. Hanson an implementable plan for restoring SSCs to compliance within the extended period for enforcement discretion. Therefore, the request to extend enforcement discretion is granted.

If you are unable to meet the extended EGM expiration date, you are requested to contact the NRC staff at least 90 days in advance. Please contact Greg Casto at (301) 415-0565.

Sincerely,

/RA/

Russell N. Felts, Deputy Director Division of Risk Assessment Office of Nuclear Reactor Regulation Docket Nos. 50-237, 50-249

ML18094A796 *Concurrence by e-mail OFFICE DRA/APLB DRA/APLB DSS/SCPB/BC DRA/APLB/BC DRA NAME AWu MPatterson* RDennig* GCasto RFelts DATE 04/04/2018 04/10/2018 03/28/2018 04/10/2018 04/ 12 /2018