ML23052A065

NRR E-mail Capture - Dresden Units 2 and 3 - Request for Additional Information for Alternative Request RV-23H

ML23052A065
Person / Time
Site:	Dresden
Issue date:	02/21/2023
From:	Shilpa Arora NRC/NRR/DORL/LPL3
To:	Mathews M Exelon Generation Co
References
L-2022-LLR-0077
Download: ML23052A065 (4)

Text

From: Surinder Arora Sent: Tuesday, February 21, 2023 7:38 AM To: Surinder Arora

Subject:

Dresden Units 2 and 3 - Request for Additional Information for Alternative Request RV-23H (EPID: L-2022-LLR-0077)

From: Surinder Arora Sent: Friday, February 17, 2023 11:20 AM To: Mathews, Mitchel A:(Constellation Nuclear) <Mitchel.Mathews@constellation.com>

Cc: Nancy Salgado <Nancy.Salgado@nrc.gov>

Subject:

Dresden Units 2 and 3 - Request for Additional Information for Alternative Request RV-23H (EPID: L-2022-LLR-0077)

Mr. Mathews, The following is the Final version of the request for additional information (RAI) pertaining to the Alternative Request RV-23H submitted by Constellation for Dresden, Units 2 and 3. The draft of this RAI was sent to you on February 14, 2023 and in your response email dated February 17, 2023, you confirmed that Constellation did not need any clarification on this RAI. Based on the issuance date of the final RAI, we will expect to receive your response to the RAI question within 30 days (i.e., latest by March 20, 2023). Please note that any delay beyond that date may result in slippage of the scheduled response date previously communicated to you for your Alternative Request RV-23H.

Thanks, Surinder Arora, P. E.

Project Manager, Fermi 2 and Dresden 2 & 3 NRR/DORL/LPL3 surinder.arora@nrc.gov 301-415-1421 REQUEST FOR ADDITIONAL INFORMATION REGARDING ALTERNATIVE REQUEST RV-23H PROPOSED ALTERNATIVE TO HIGH PRESSURE COOLANT INJECTION DRAIN POT SOLENOID VALVE REQUIREMENTS IN ACCORDANCE WITH 10 CFR 50.55a(z)(1)

SIXTH 10-YEAR INSERVICE TESTING PROGRAM INTERVAL DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 DOCKET NOS. 50-237 AND 50-249 EPID L-2022-LLR-0077

Background:

By a letter dated November 1, 2022 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22305A578), Constellation (the licensee) submitted to the U.S.

Nuclear Regulatory Commission (NRC) Alternative Request RV-23H regarding certain inservice testing (IST) requirements of the 2017 Edition of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code) for the IST Program at Dresden Nuclear Power Station (Dresden),

Units 2 and 3 associated with the Sixth 10-Year IST Program interval.

Specifically, the licensee requested to conduct a functional verification test on the drain pot level limit switches and the associated control room annunciators at least once every 2 years as an alternative to the requirements in ASME OM Code, Subsection ISTC, paragraph ISTC-5151, Valve Stroke Testing, paragraph ISTC-5152, Stroke Test Acceptance Criteria, and paragraph ISTC-5153, Stroke Test Corrective Action, for the High Pressure Coolant Injection (HPCI)

Drain Pot Solenoid Valves at Dresden.

Regulatory Requirements:

The NRC regulations in Section 55a, Codes and standards, in Part 50, Domestic Licensing of Production and Utilization Facilities, in Title 10, Energy, of the Code of Federal Regulations (10 CFR 50.55a) in paragraph (z), Alternatives to codes and standards requirements, state the following:

Alternatives to the requirements of paragraphs (b) through (h) of this section or portions thereof may be used when authorized by the Director, Office of Nuclear Reactor Regulation.

A proposed alternative must be submitted and authorized prior to implementation. The applicant or licensee must demonstrate that:

(1) Acceptable level of quality and safety. The proposed alternative would provide an acceptable level of quality and safety; or (2) Hardship without a compensating increase in quality and safety. Compliance with the specified requirements of this section would result in hardship or unusual difficulty without a compensating increase in the level of quality and safety.

EMIB-RAI-1:

As an alternative to the ASME OM Code requirements for the HPCI drain pot solenoid valves at Dresden, the licensee proposes in Alternative Request RV-23H for the Sixth 10-Year IST Program interval that a functional verification test will be conducted on the drain pot level limit switches and the associated control room annunciators at least once every 2 years. In the Proposed Alternative and Basis for Use section, the licensee states, in part:

Using the provisions of this request (i.e., quarterly exercising and semi-annual functional testing combined with the enhanced maintenance activities) as an alternative to the specific requirements of ISTC-5150 identified above will provide adequate indication of valve performance and continue to provide an acceptable level of quality and safety

Upon review of Alternative Request RV-23H, the NRC staff requests the licensee to clarify the basis for the 2-year functional verification test schedule in Alternative Request RV-23H for the Sixth 10-Year IST Program interval in comparison to the statement, provisions of this request (i.e., quarterly exercising and semi-annual functional testing combined with the enhanced maintenance activities) as an alternative to the specific requirements of ISTC-5150.

Hearing Identifier: NRR_DRMA Email Number: 1950 Mail Envelope Properties (BY3PR09MB822548CA58A897E0AF5408B094A59)

Subject:

Dresden Units 2 and 3 - Request for Additional Information for Alternative Request RV-23H (EPID L-2022-LLR-0077)

Sent Date: 2/21/2023 7:37:43 AM Received Date: 2/21/2023 7:37:47 AM From: Surinder Arora Created By: Surinder.Arora@nrc.gov Recipients:

"Surinder Arora" <Surinder.Arora@nrc.gov>

Tracking Status: None Post Office: BY3PR09MB8225.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 5091 2/21/2023 7:37:47 AM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: