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TAC:ME3376, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Open) TAC:ME3377, Relocate Surveillance Frequencies to Licensee Control - RITSTF Initiative 5B (Open) |
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Category:Letter type:RS
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Application to Revise Primary Containment Isolation Instrumentation Technical Specifications in Accordance with TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration2022-10-0303 October 2022 Nine and Quad Cities - Application to Revise Primary Containment Isolation Instrumentation Technical Specifications in Accordance with TSTF-306, Revision 2, Add Action to LCO 3.3.6.1 to Give Option to Isolate the Penetration RS-22-066, License Amendment Request to Revise Technical Specification 3.1.4, Control Rod Scram Times2022-08-25025 August 2022 License Amendment Request to Revise Technical Specification 3.1.4, Control Rod Scram Times RS-22-065, License Amendment Request Regarding Transition to GNF3 Fuel2022-08-18018 August 2022 License Amendment Request Regarding Transition to GNF3 Fuel RS-22-093, Advisement of Leadership Changes for Constellation Energy Generation, LLC and Submittal of Updated Standard Practice Procedures Plans2022-08-18018 August 2022 Advisement of Leadership Changes for Constellation Energy Generation, LLC and Submittal of Updated Standard Practice Procedures Plans RS-22-101, Response to Request for Additional Information Related to Relief Request I6R-01 Associated with the Sixth Inservice Inspection Interval2022-08-10010 August 2022 Response to Request for Additional Information Related to Relief Request I6R-01 Associated with the Sixth Inservice Inspection Interval RS-22-099, Submittal of Upcoming Sixth Inservice Inspection Interval Relief Requests I6R-09 and I6R-102022-07-19019 July 2022 Submittal of Upcoming Sixth Inservice Inspection Interval Relief Requests I6R-09 and I6R-10 RS-22-082, Defueled Safety Analysis Report Update, Revision 112022-06-22022 June 2022 Defueled Safety Analysis Report Update, Revision 11 RS-22-080, Withdrawal and Proposed Alternative I6R-08 Associated with Code Case N-921 for Sixth Inservice Inspection Intervals2022-06-0909 June 2022 Withdrawal and Proposed Alternative I6R-08 Associated with Code Case N-921 for Sixth Inservice Inspection Intervals RS-22-064, License Amendment Request Regarding New Fuel Storage Vault and Spent Fuel Storage Pool Criticality Methodologies with Proposed Change to Technical Specifications Section 4.3.12022-06-0808 June 2022 License Amendment Request Regarding New Fuel Storage Vault and Spent Fuel Storage Pool Criticality Methodologies with Proposed Change to Technical Specifications Section 4.3.1 RS-22-051, Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists2022-04-12012 April 2022 Constellation Energy Generation, LLC - Update to Correspondence Addressees and Service Lists RS-22-049, Constellation Energy Generation, LLC, Supplemental Information to Correct Typographical Errors in Constellation'S Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for2022-04-0404 April 2022 Constellation Energy Generation, LLC, Supplemental Information to Correct Typographical Errors in Constellation'S Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for V RS-22-046, Relief Requests Associated with the Sixth Inservice Inspection Interval2022-03-25025 March 2022 Relief Requests Associated with the Sixth Inservice Inspection Interval RS-22-045, Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations2022-03-25025 March 2022 Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2022-01, Preparation and Scheduling of Operator Licensing Examinations RS-22-042, Report on Status of Decommissioning Funding for Shutdown Reactors2022-03-23023 March 2022 Report on Status of Decommissioning Funding for Shutdown Reactors RS-22-027, Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated2022-02-23023 February 2022 Constellation, Response to Request for Additional Information Regarding Application to Revise Technical Specifications to Adopt TSTF-541 Revision 2, Add Exceptions to Surveillance Requirements for Valves and Dampers Locked in the Actuated P RS-22-023, Constellation Energy Generation, LLC, Executed Trust Fund Agreement Amendment and Subordinate Trust Agreement2022-02-23023 February 2022 Constellation Energy Generation, LLC, Executed Trust Fund Agreement Amendment and Subordinate Trust Agreement RS-22-019, Constellation Energy Generation, LLC - 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ExeJon Generation Company, LLC 4300 Winfield Road www.exelonc:orp.com Nuclear Warrenville, IL 60555 10 CFR 50.90 RS-10-107 June 22, 2010 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C. 20555-0001 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating Ucense Nos. DPR-19 and DPR-25 NRC Docket Nos. 50-237 and 50-249
Subject:
Additional Information Supporting Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency Requirements to a Licensee Controlled Program
Reference:
- 1. Letter from J. L. Hansen (Exelon Generation Company, LLC) to U. S.
NRC, "Application for Technical Specification Change Regarding Risk-Informed Justification for the Relocation of Specific Surveillance Frequency ReqUirements to a Licensee Controlled Program (Adoption of TSTF-425, Revision 3)" dated February 16, 2010
- 2. Letter from C. Gratton (U. S. NRC) to C. G. Pardee (Exelon Generation Company, LLC), "Dresden Nuclear Power Station, Units 2 and 3-Request for Additional Information Regarding an Amendment Request to Relocate Specific Surveillance Frequency Requirements to a Licensee-Controlled Program (TAC Nos. ME3376 thru ME33n)," dated May 17, 2010.
- 3. May 20, 2010 Teleconference between U. S. NRC (C. Gratton) and Exelon Generation Company, LLC (J. Schrage, et al)
In Reference 1, Exelon Generation Company, LLC (EGG) submitted a request to amend Appendix A, "Technical Specifications," (TS) of Renewed Facility Operating License Nos.
DPR-19, and DPR-25 Dresden Nuclear Power Station (DNPS), Units 2 and 3, respectively.
The proposed amendment revises the DNPS TS by relocating specific surveillance frequencies to a licensee-controlled program.
June 22, 2010 U. S. Nuclear Regulatory Commission Page 2 In Reference 2, the NRC forwarded a request for additional information concerning the Reference 1 license amendment request. In the Reference 3 teleconference, representatives from the NRC and EGC clarified the information that was requested by the NRC. The attachment to this letter provides the additional information requested by the NRC.
There are no regulatory commitments in this letter or the attachment.
Should you have any questions or require additional information, please contact Mr. John L.
Schrage at (630) 657-2821.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 22nd day of June 2010.
Jeff ey . ansen Manage - Licensing
Attachment:
Response to NRC Request for Additional Information, License Amendment Request to Relocate Specific Surveillance Frequency Requirements to a Licensee-Controlled Prog ram
ATTACHMENT Response to NRC Request for Additional Information License Amendment Request to Relocate Specific Surveillance Frequency Requirements to a Licensee-Controlled Program By letter dated February 16, 2010, Exelon Generation Company, LLC (EGC) submitted a request to amend Appendix A, "Technical Specifications," (TS) of Renewed Facility Operating License Nos. DPR-19, and DPR-25 Dresden Nuclear Power Station (DNPS), Units 2 and 3, respectively. The proposed amendment revises the DNPS TS by relocating specific surveillance frequencies to a licensee-controlled program.
The NRC forwarded a request for additional information concerning the proposed license amendment request by letter dated May 17, 2010. On May 20,2010, representatives from the NRC and EGC clarified the information that was requested by the NRC. The EGC response to the NRC request is provided below.
NRC Request for Additional Information "In Table 2-1 of Attachment 2 of the submittal, Gap #2 identified against supporting requirement DA-C8 states that plant-specific operational records were not used to quantify system or train standby times. The disposition of this item states that the existing model is "...judged to appropriately estimate the time that components were in standby..." There is no basis identified for how the licensee reached this jUdgment. State how standby times were estimated and why these estimates are jUdged to be appropriate for the calculation of standby failure rates instead of using plant-specific, operational data."
EGC Response For standby systems, nearly all of the demands are surveillance tests. As such, the system or train standby time estimates are based on the surveillance test interval for the system or train.
Basing the standby time on the interval between successive surveillance tests, using the established frequencies, is therefore consistent with actual demand experience.
However, this demand estimate does not account for operational demands or unplanned surveillances. The exclusion of these additional demands in the estimation of standby times is conservative in that the estimated standby time would be greater than or equal than actual.
This difference does not significantly impact the risk profile.
Additionally, NEI 04-10, Step 8, requires that an appropriate time-related failure contribution be utilized in the surveillance frequency change assessment, and Step 14, "Perform Sensitivity Studies," requires the performance of sensitivity studies regarding the choice of that value.
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