ML17191A258

RAI Related to License Amendment Request to Revise Technical Specifications to Adopt Technical Specification Task Force Traveler-542, Revision 2 (CAC NOS.MF9295 and MF9296)

ML17191A258
Person / Time
Site:	Dresden
Issue date:	07/11/2017
From:	Haskell R Plant Licensing Branch III
To:	Bryan Hanson Exelon Nuclear
References
CAC MF9295, CAC MF9296
Download: ML17191A258 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 11, 2017 Mr. Bryan C. Hanson Senior Vice President Exelon Generation Company, LLC President and Chief Nuclear Officer (CNO)

Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATION TASK FORCE TRAVELER-542, REVISION 2, "REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" (CAC NOS. MF9295 AND MF9296)

Dear Mr. Hanson:

By application dated February 10, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17045A006), Exelon Generation Company, LLC (EGC, the licensee), requested to adopt Technical Specifications Task Force (TSTF) Traveler (TSTF-542),

"Reactor Pressure Vessel [RPV] Water Inventory Control [WIC]," Revision 2, which would change the technical specifications (TSs) for Dresden Nuclear Power Station, Units 2 and 3.

TSTF-542, Revision 2, was approved by the U.S. Nuclear Regulatory Commission (NRC) on December 20, 2016 (ADAMS Accession No. ML16343B008). The proposed cha~ges would replace the existing requirements in the TSs related to "operations with the potential to drain the reactor pressure vessel" with revised TSs providing an alternative for RPV WIC. These alternative requirements would protect Safety Limit 2.1.1.3, which requires RPV water level to be greater than the top of active fuel.

During the NRC staff review it was determined that additional information is required to complete the staff's safety evaluation. The specific request for additional information (RAI) is addressed in the enclosure to this letter. On June 28, 2017, a draft set of these R.Als was emailed to Mr. Mitch Mathews of your staff for review. In a follow-up phone conversation with NRC staff on July 7, 2017, Mr. Mathews stated that EGC did not require any clarifications to the RAls. He agreed to provide the NRC with EGC's responses no later than August 7, 2017.

The NRC staff considers that timely responses to the RAls ensures sufficient time is available for staff review and to contribute toward the NRC's goal of efficient and effective use of staff resources.

B. Hanson If circumstances result in the need to revise the requested response d-.=a~te,,._,_.~...-se contact me at (301) 415-1129, or by email at Russell.Haskell@nrc.gov.

Russell S. Haskell, Project Manager Plant Licensing Branch Ill Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237 and 50-249

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT APPLICATION TO REVISE TECHNICAL SPECIFICATIONS TO ADOPT TECHNICAL SPECIFICATION TASK FORCE TRAVELER-542. REVISION 2.

"REACTOR PRESSURE VESSEL WATER INVENTORY CONTROL" EXELON GENERATION COMPANY. LLC DRESDEN NUCLEAR POWER STATION - UNITS 2 AND 3 DOCKET NOS. 50-237 AND 50-249 By application dated February 10, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17045A006), Exelon Generation Company, LLC (EGC, the licensee), requested to adopt Technical Specifications Task Force (TSTF) Traveler (TSTF-542),

"Reactor Pressure Vessel [RPV] Water Inventory Control [WIC]," Revision 2, which would change the technical specifications (TSs) for Dresden Nuclear Power Station, Units 2 and 3.

TSTF-542, Revision 2, was approved by the U.S. Nuclear Regulatory Commission (NRC) on December 20, 2016 (ADAMS Accession No. ML16343B008). The proposed changes would replace the existing requirements in the TSs related to "operations with the potential to drain the reactor pressure vessel" with revised TSs providing an alternative for RPV WIC. These alternative requirements would protect Safety Limit 2.1.1.3, which requires RPV water level to be greater than the top of active fuel.

The NRC staff has reviewed the information the licensee provided that supports the proposed amendment. The staff requests the licensee to address the following issues:

DNPS-RAl-1:

Background:

In Attachment 2, pg. 3.5.2-1 (of the submittal), the staff identified a discrepancy in the limiting condition for operation (LCO) 3.5.2, Applicability proposed markup. The current TS LCO consists of text not shown in the proposed LCO markup as being deleted. Specifically, there is missing text associated with the MODE 5 exception (i.e., "except with the spent fuel storage pool gates removed and water level ~ 23 ft. over the top of the reactor pressure vessel flange").

Request:

Please correct the proposed TS markup as appropriate.

Enclosure

DNPS-RAl-2:

Background:

In Attachment 2, pg. 3.5.2-6 (of the submittal), the NRC staff identified a discrepancy. The current TS surveillance requirement (SR) consists of text not shown in the proposed SR markup as being deleted. Specifically, SR 3.5.2.4 is missing the operafing parameter data (i.e., System, Flow Rate, Pumps, Pressure), as per TSTF-542, Revision 2.

Request:

Please correct the proposed TS markup as appropriate.

DNPS-RAl-3:

Background:

In Attachment 2, pg. 3.5.2-6 (of the submittal), the NRC staff identified a discrepancy. The current TS SR consists of text not shown in the proposed SR markup as being deleted.

Specifically, SR 3.5.2.5 is missing from the proposed markup page.

Request:

Please correct the proposed TS markup as appropriate.

DNPS-RAl-4:

Background:

In Attachment 2 (of the submittal), the NRC staff identified a discrepancy. SR 3.8.2.1 (note 2) has not been revised to show the new title for LCO 3.5.2.

Request:

Please correct the proposed TS markup as appropriate.

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ML17191A258 OFFICE DORL/LPL3/PM DORL/LPL3/LA DORL/LPL3/BC , DORL/LPL3/PM NAME RHaskell SRohrer DWrona RHaskell DATE 7/10/2017 7/10/2017 7/11/2017 7/11/2017