RS-25-131, Correction of Technical Specification Typographical Error Regarding Unit 2 Amendment No. 286 and Unit 3 Amendment No. 279 for Risk Informed Completion Time Program
| ML25231A279 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 08/19/2025 |
| From: | Humphrey M Constellation Energy Generation, Exelon Generation Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| RS-25-131 | |
| Download: ML25231A279 (1) | |
Text
4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office 10 CFR 50.90 RS-25-131 August 19, 2025 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249
Subject:
Correction of Technical Specification Typographical Error Regarding Unit 2 Amendment No. 286 and Unit 3 Amendment No. 279 for Risk Informed Completion Time Program
References:
- 1. Letter from Mark D. Humphrey (Constellation Energy Generation, LLC) to U.S Nuclear Regulatory Commission, "Supplement to the Request for Additional Information Related to License Amendment Requests to Adopt TSTF-505, TSTF-591, and 10 CFR 50.69," dated June 2, 2025 (ADAMS Accession No. ML25153A051) 2.
Proposed Guidance for Correction of Technical Specification Typographical Errors, SECY-96-238, November 19, 1996 (ADAMS Accession No. ML20134M324) 3.
Letter from Mark D. Humphrey (Constellation Energy Generation, LLC) to U.S. Nuclear Regulatory Commission, "Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk Informed Completion Times TSTF-505, 'Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b,' TSTF-591, 'Revise Risk Informed Completion Time (RICT) Program,' and 10 CFR 50.69, 'Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors'," dated March 21, 2025 (ADAMS Accession No. ML25080A153) 4.
Letter from Surinder Arora (U.S. Nuclear Regulatory Commission) to David P.
Rhoades (Constellation Energy Generation, LLC), "Dresden Nuclear Power Station, Units 2 and 3 - Issuance of Amendment Nos. 286 and 279 Re:
Adoption of Risk Informed Completion Times TSTF-505, Revision 2, 'Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b' and TSTF-591, 'Revise Risk Informed Completion Time (RICT) Program'," dated July 30, 2025 (ADAMS Accession No. ML25196A299)
August 19, 2025 U.S. Nuclear Regulatory Commission Page 2 In Reference 4, Constellation Energy Generation, LLC (CEG) received an amendment to Renewed Facility Operating License Nos. DPR-19 and DPR-25 for Dresden Nuclear Power Station (DNPS) Units 2 and 3. The amendment in Reference 4 modified the Technical Specifications (TS) requirements to permit the use of Risk Informed Completion Times (RICTs) in accordance with TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times -
RITSTF Initiative 4b" and TSTF-591, Revision 0, "Revise Risk Informed Completion Time (RICT)
Program."
This letter requests NRC approval of a correction of an omission in the DNPS Units 2 and 3 TS.
This omission occurred during a response to a request for additional information for DNPS (Reference 1), where the High Wind/Tornado Missile Penalty Factor verbiage under TS 5.5.16 paragraph (e) was inadvertently omitted that was requested to be added in Question 11 CEG Response and approved by the NRC (Reference 3). The omission was neither addressed in the notice to the public nor reviewed by the NRC and thus falls within the scope of the guidance provided by SECY-96-238 (Reference 2). This correction does not change any of the conclusions in the safety evaluation or no significant hazards consideration determination associated with Amendment Nos. 286 or 279 as published in the Federal Register. Attachment 1 provides the page from Amendments 286/279 as issued, with the requested correction noted. contains the corrected page for Amendment 286/279.
There are no regulatory commitments contained in this letter. Should you have any questions concerning this letter, please contact Ms. Erin Whitsell at (309) 738-9650.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 19th day of August 2025.
Respectfully, Mark Humphrey Sr. Manager Licensing Constellation Energy Generation, LLC Humphrey, Mark D.
Digitally signed by Humphrey, Mark D.
Date: 2025.08.19 07:45:44 -05'00'
August 19, 2025 U.S. Nuclear Regulatory Commission Page 3 Attachments:
- 1. Markup of Technical Specification 5.5.16 Attached to Units 2 and 3 Amendment Nos.
286/279
- 2. Revised Technical Specification 5.5.16 cc:
Regional Administrator - NRC Region III NRC Senior Resident Inspector - DNPS NRC Project Manager, NRR - DNPS Illinois Emergency Management Agency and Office of Homeland Security - Division of Nuclear Safety
ATTACHMENT 1 Dresden Nuclear Power Station Docket Nos. 50-237 and 50-249 Renewed Facility Operating License Nos. DPR-19 and DPR-25 Correction of Technical Specification Typographical Error Regarding Unit 2 Amendment No. 286 and Unit 3 Amendment No. 279 for Risk Informed Completion Time Program Markup of Technical Specification 5.5.16 Attached to Units 2 and 3 Amendment Nos.
286/279
Programs and Manuals 5.5 Dresden 2 and 3 5.5-15 Amendment No. 286/279 5.5 Programs and Manuals 5.5.16 Risk Informed Completion Time Program (continued) 2.
For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.
3.
Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.
d.
For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:
1.
Numerically accounting for the increased possibility of CCF in the RICT calculation; or 2.
Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.
e.
A RICT calculation must include the following hazard groups:
internal flood and internal events PRA model, internal fire PRA model, and seismic penalty factor, and external flood penalty factor.
Changes to these means of assessing the hazard groups require prior NRC approval.
f.
The PRA models used to calculate a RICT shall be maintained and upgraded in accordance with the processes endorsed in the regulatory positions of Regulatory Guide 1.200, Revision 3, "Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities."
g.
A report shall be submitted in accordance with Specification 5.6.7 before a newly developed method is used to calculate a RICT.
high wind/tornado missile penalty factor,
ATTACHMENT 2 Dresden Nuclear Power Station Docket Nos. 50-237 and 50-249 Renewed Facility Operating License Nos. DPR-19 and DPR-25 Correction of Technical Specification Typographical Error Regarding Unit 2 Amendment No. 286 and Unit 3 Amendment No. 279 for Risk Informed Completion Time Program Revised Technical Specification 5.5.16
Programs and Manuals 5.5 Dresden 2 and 3 5.5-15 Amendment No. 286/279 5.5 Programs and Manuals 5.5.16 Risk Informed Completion Time Program (continued) 2.
For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> after the plant configuration change, whichever is less.
3.
Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.
d.
For emergent conditions, if the extent of condition evaluation for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:
1.
Numerically accounting for the increased possibility of CCF in the RICT calculation; or 2.
Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating events that challenge the function(s) performed by the inoperable SSCs.
e.
A RICT calculation must include the following hazard groups:
internal flood and internal events PRA model, internal fire PRA model, high wind/tornado missile penalty factor, seismic penalty factor, and external flood penalty factor.
Changes to these means of assessing the hazard groups require prior NRC approval.
f.
The PRA models used to calculate a RICT shall be maintained and upgraded in accordance with the processes endorsed in the regulatory positions of Regulatory Guide 1.200, Revision 3, "Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities."
g.
A report shall be submitted in accordance with Specification 5.6.7 before a newly developed method is used to calculate a RICT.