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| number = ML12086A014 | | number = ML12086A014 | ||
| issue date = 03/23/2012 | | issue date = 03/23/2012 | ||
| title = | | title = Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50, Appendix R, Section Iii.L | ||
| author name = Kaegi G | | author name = Kaegi G | ||
| author affiliation = Exelon Generation Co, LLC, Exelon Nuclear | | author affiliation = Exelon Generation Co, LLC, Exelon Nuclear | ||
| addressee name = | | addressee name = | ||
Line 13: | Line 13: | ||
| document type = Letter | | document type = Letter | ||
| page count = 7 | | page count = 7 | ||
| project = | |||
| stage = Response to RAI | |||
}} | }} | ||
=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:ExelonGeneration Exelon Generation Company, Company,LLCLLC www.exeloncorp.com www.exeloncorp.com 4300 Winfield 4300 Winfield Road Road Nuclear Nuclear Warrenville, ILIL60555 Warrenville, 60555 RS-12-045 RS-12-045 1010CFR CFR50.1250.12 10 10 CFR CFR 50,50, Appendix Appendix R R March23, March 23,2012 2012 U.S. Nuclear U.S. Nuclear Regulatory Commission AATTN: Document Control TIN: Document Control Desk Desk Washington,DC Washington, DC 20555-0001 20555-0001 Dresden Nuclear Dresden Nuclear Power Station,Station, Units Units 22 andand 3 Renewed Facility Operating Renewed Facility Operating License License Nos. Nos. DPR-19 DPR- 1 9and and DPR-25 DPR-25 NRC Docket NRC Docket Nos.Nos. 50-237 and and 50-249 | ||
-1 | |||
-237 and 50-249 | |||
==Subject:== | ==Subject:== | ||
Response to | Response to Response toRequest Requestfor forAdditional Additional Information Information Regarding Regarding the Request for the Request for Exemption from Exemption from 10 CFR 50, 50, Appendix Appendix R, R, Section SectionIII.L III.L | ||
==References:== | ==References:== | ||
(1) Letter from Letter from D. D. M. Gullott Gullott (EGC) | |||
(EGC) to NRC,NRC, "Request "Request forfor Exemption Exemption from 10 10 CFR 50,50, Appendix Appendix R, SectionSection III.L," dated February 13, 2012 2012 (2) Letter from Letter from J.J.Wiebe Wiebe (NRC) | |||
(NRC) to to M. J. Pacilio Pacilio (EGC), "Dresden "Dresden Nuclear Power Power Station, Units 22 and Station, Units and 33 -- Request Request for for Exemption Exemption From 10 CFR CFR 50, 50, Appendix Appendix R, Section III.L - Unacceptab Unacceptable with the le with theOpportunity Opportunity to to Supplement Supplement (TAC (TAC No. ME8008)," dated dated March March 19,19, 2012 2012 In Reference 1, In Reference 1, in in accordance accordance with with 1010 CFR CFR 50.12, 50.12,"Specific "Specific exemptions, exemptions," Exelon Generation | |||
" Exelon Generation Company, Company, LLC (EGC) requested LLC (EGC) requested a permanent permanent exemption exemption from from the requiremen requirements in 10 ts in 10CFRCFR 50 50 Appendix Appendix R, R, "Fire Protection Program for "Fire Protection for Nuclear Power FacilitiesFacilities Operating Operating PriorPrior to January January 1, 1, 1979," | |||
1979," Section SectionIII.L III.L "Alternative "Alternative and and dedicated dedicated shutdown shutdowncapability," | |||
capability," paragraph paragraph 4,4,for forDresden Dresden Nuclear Nuclear Power Station Station (DNPS) Units Units 22 and 3. The The requested requestedexemption exemptionwouldwouldeliminate eliminate the the requirement requirement for for the on-shift on-shift High Voltage Operator (HVO), | |||
(HVO), a membermember of of the the Safe SafeShutdown Shutdown (SSD) | |||
(SSD)staff, staff,totoremainremain"on "on site siteatatall alltimes" times" andandwould wouldallowallowthe theHVO HVOtotoconduct conductnormal normalshift shift duties, duties, including including those thoseatatremote remoteOwner OwnerControlled ControlledAreasAreas(OCAS), | |||
(OCAs),while whilefulfilling fulfillingaarequired required position position on on the the SSD SSDstaff. | |||
staff.InInaddition, addition,the theexemption exemptionwould wouldeliminate eliminatethetherequiremen requirement t totoremain remain "on "on site site at at all all times" times" for one one on -shift Operations Supervisor, also on-shift also aa member memberof ofthe theSSDSSDstaff,staff,and and allow allow that that individual individual to perform perform the the duties of of aa Safety /First-aid Monitor Safety/First-aid Monitor during during switching switching operations operations occurring occurring at at aa remote remoteOCA, OCA, i.e., | |||
i.e.,the the345kV 345kVswitchyard switchyardor orlake lakelift lift station. | |||
station. The The exemption was requested in accordance exemption was requested in accordance with the requiremen with the requirements of 10 ts of 10CFR CFR 50.12(a)(2)( | |||
50.12(a)(2)(ii) since ii) since the the application application of of the the regulation regulation in in this particular circumstance is not necessary particular circumstance necessary to toachieve achievethe the underlying underlying purpose purposeofofthe therule. | |||
rule. | |||
In In Reference Reference2,2,the theNRC NRCformally formallynotified notified EGCEGC that that additional additional information information was neededneededininorder order toto commence commenceaadetailed detailedreview reviewofofthe thesubmittal. | |||
submittal. PriorPrior toto issuance issuanceofofReference Reference2,2,ononMarch March7,7, 2012, 2012,aateleconferen teleconference ce waswasheldheldbetween betweenmembers membersofofthe theNRCNRCand andEGCEGCstaffs staffstotodiscuss discussand and clarify the additional information that would clarify the additional information that would be requested. A be requested. A subsequent subsequent telephone telephonecall callwaswas | |||
March 23, March 23, 2012 U.S. Nuclear Regulatory Commission U.S. | |||
Page 2 held between J. Wiebe (NRC) held (NRC) and and J. A. | |||
A. Bauer (EGG)(EGC)to toconfirm confirmthetheresponse responseduedue date. | |||
date. The The due date was was determined determined to to be be March March 26, 2012, i.e., | |||
26,2012, i.e., 13 13 working working days after thethe date of the clarification conference clarification conference call call in in accordance accordancewith withNRCNRCOffice Office Instruction Instruction LIC-1 09, Acceptance LlC-109, Acceptance Review Procedures." The Review Therequested requestedinformation informationisisprovided providedininAttachment Attachment11ofofthis thisletter. | |||
letter. | |||
This letter contains no newnew regulatory regulatory commitments. | |||
commitments. | |||
you have any questions concerning If you concerning this this letter, please please contact contact Joseph JosephA. A. Bauer Bauer atat (630) | |||
(630) 657-657-2804. | |||
Respectfully, Glen T. Kaegi Kaegi Director -- Licensing Licensing and and Regulatory RegulatoryAffairs Affairs Exelon Exelon Generation Company, LLC cc: NRC Regional Administrator, Region Region IIIIII NRC Senior Resident Inspector - Dresden NRC DresdenNuclearNuclearPower PowerStation Station IllinoisEmergency Illinois Emergency Management Management AgencyAgency - Division Division of of Nuclear Safety Safety | |||
ATTACHMENT ATTACHMENT11 Response to Request for Additional Information Information Regarding the the Request Requestfor forExemption Exemptionfrom from10 10CFRCFR50 50Appendix AppendixR,R,Section Section III.L lII.l "Alternative "Alternative and and dedicated dedicated shutdown shutdowncapability" capability" In In Reference 1, 1, in in accordance accordancewith with 1010 CFR CFR 50.12, 50.12, "Specific "Specific exemptions," | |||
Dresden | exemptions," Exelon Exelon Generation Generation Company, LLC (EGC) requested LLC (EGC) requested a permanent exemption exemption from the requirements requirements in 10 in 10 CFR CFR 50 50 Appendix R, "Fire Protection Program for Nuclear Facilities Operating Prior "Fire Protection Prior to January January1,1,1979," 1979," | ||
Section III.L "Alternativeand III.L "Alternative anddedicated dedicated shutdown shutdown capability," | |||
capability," paragraph paragraph 4, for for Dresden Dresden NuclearNuclear Power Station (DNPS) Units 22 and (DNPS) Units and 3.3. The The requested requestedexemption exemptionwould wouldeliminate eliminatethe the requirement for the on-shift High Voltage Operator (HVO), | |||
High Voltage (HVO), aa member of the Safe SafeShutdown Shutdown (SSD) staff, to remain remain "on"on site site atatall all times" times" andandwould wouldallow allow the theHVO HVO totoconduct conductnormal normalshift shift duties, including including those thoseatatremote remoteOwner OwnerControlled ControlledAreas Areas(OCAs), | |||
(OCAs),while whilefulfilling fulfilling aarequired required position on the SSD staff. staff. InIn addition, addition, the theexemption exemption wouldwould eliminate eliminate the therequirement requirementtotoremain remain | |||
`on "on site at all times" times" for foroneone on-shift on-shiftOperations Operations Supervisor, Supervisor, also also aa member of the SSD staff, and allow that individual individual to to perform perform the the duties of aa Safety/First-aid Safety/First-aid MonitorMonitor during switching switching operations operations occurring occurring at at aa remote remote OCA, OCA, i.e.,Le., the the 345kV 345kV switchyard switchyard or lake lake lift station. The lift station. The exemption is being requested requestedin in accordance accordancewith withthe therequirements requirementsofof10 10CFRCFR50.12(a)(2)(ii) 50.12(a)(2)(ii) since the application application of the regulation regulation in in this this particular particularcircumstance circumstance isis not not necessary necessary to achieve achieve the underlying underlying purposepurpose of of the the rule. | |||
rule. | |||
In Reference 2, In 2, the the NRC NRC formally formally notified notified EGC EGC thatthat additional additional information information was was needed needed in in order order to commence aa detailed detailed review review of the submittal. Prior Prior to to issuance issuanceof ofReference Reference2,2,on onMarch March7,7, 2012, aa teleconference was was held held between between members membersof of the the NRCNRC andand EGC EGC staffs staffs toto discuss discussand and clarifythe clarify the additional additionalinformation informationthat thatwould wouldbeberequested. | |||
requested. AA subsequent subsequent telephone telephone call call was was held between J. Wiebe (NRC) (NRC) and and J.J. A. | |||
A. Bauer Bauer (EGC) | |||
(EGC)totoconfirm confirmthe theresponse responsedue due date. | |||
date. TheThe due date date was was determined determined to to be beMarch March 26, 26, 2012, 2012, i.e., | |||
Le., 13 13working working days days after after thethe date dateof ofthe the clarification conference clarification conference call in accordance accordance with with NRC NRC Office Office Instruction Instruction LIC-1 LlC-109, 09, Acceptance Acceptance Review Procedures." | |||
Review Procedures." The The requested requestedinformation information is is provided provided below. | |||
below. | |||
Note that the below discussion focuses focuses primarily primarily on the HVO activities; however, HVO activities; however, the the remote OCA considered OCA considered (i.e., (Le., the the Goose GooseLake Lakepumping pumpingstation) station)isisthethemost mostlimiting limitingOCA OCAfrom from aatravel travel time standpoint; time standpoint; therefore, therefore, thethe conclusions conclusions are are also also applicable applicable to to scenarios scenarios where the Operations Supervisor Operations Supervisorisisperforming performingswitching switchingactivities activitiesatatthe the345 345kVkVswitchyard switchyardororlake lakelift lift station. | |||
RAI #1 Provide a summary of the analysis used to determine that adequate time is available to to ensure ensure in accordance reliability in accordance with Section 4.2.2 with Section 4.2.2 of NUREG 1852. | |||
of NUREG 1852. Include additional uncertainties and variability in the time required for manual actions that were considered. | |||
In Part 1/ ll of of the the submittal, "Bases"Bases for for Exemption Exemption Request" Request"section sectionNUREG-NUREG-1852 1852 Guidance, Guidance, the licensee cited cited NUREG-NUREG-1852 1852 as being germane to the subject exemption request request with with respect to feasibility and and reliability criteria criteria for competing manual actions similar to safe shutdown (SSD) (SSO) activities. | |||
NUREG-1852, Section 3.2.2, `Analysis NUREG-1852, "Analysis Showing Adequate Time Time Available to to Ensure Ensure Reliability" as as referenced by the licensee, licensee, addresses the reliability of the operator manual manual actions. ItIt states actions. states inin part part that that adequate adequate time time should be available to account for uncertainties that may be be encountered encountered by by the the operator operator manual manualactions. | |||
actions. In lieu of directly accounting for uncertainty, the sources of uncertainty, the extra time should be sufficient to make up for uncertainties in Page 11 of 5 | |||
ATTACHMENT 1 ATTACHMENT Response to Response to Request Request for for Additional Additional Information Information Regarding the Regarding the Request Request for for Exemption from from 10 CFR CFR 50 Appendix R, Section III.L lII.l "Alternative and "Alternative and dedicated shutdown capability" estimates of the estimates the time time available and the time it takes to diagnose and execute operator operator manual actions. | |||
manual actions. For For this this exemption, exemption, reliability reliability considerations for the travel to return to the plant are relevant. | |||
plant relevant. | |||
===Response=== | |||
Response Initial Justification Initial Justification Presented in Reference Reference 11 As noted in As in Reference 1, 1, the the limiting limiting scenario requiring Safe Shutdown Shutdown actions actions by by the the High High Voltage Operator Voltage Operator (HVO) (HVO)isisaddressed addressed in in Dresden Safe Shutdown Shutdown Procedure, Procedure, DSSP DSSP0100-CR, 0100-CR, "HotShutdown "Hot Shutdown Procedure Procedure -- Control Room Evacuation." Evacuation." In In this scenario, the the hydraulic hydraulic analysis of record of record (AOR) | |||
(AOR) showsshows that the IsolationIsolation Condenser Condenserand andControl ControlRod RodDriveDrive(CRD) | |||
(CRD) pump pump injection are injection are both both required required to to bebe restored in 32 minutes. In In January January2006, 2006,aatime timevalidation validation waswas conducted and all critical and all critical actions were completed in 25 minutes. Specifically, completed in 25 minutes. Specifically, the critical action the critical action assigned to assigned tothe theHVOHVO (i.e., | |||
(Le., locally locally starting the the 2A 2A (3A) | |||
(3A) CRD pump) was completed completed in in 14 14minutes. | |||
minutes. | |||
Reference 11 also also notes notesthatthatifif the theHVOHVO is is located located at atthethemost mostlimiting limiting remote Owner Owner Controlled Controlled Area (OCA) | |||
(OCA) (Le., (i.e., the the Goose Goose Lake pumping station) at the onset onsetof of the the above abovescenario, scenario,the theHVOHVO can be notified notified and return to the protected area areato to perform perform his/her his/her assigned assignedSSD SSDfunction function in in 15 15 minutes, as was minutes, was demonstrated demonstrated in in February February 2012.2012. Therefore, Therefore,adding addingthe the1515minutes minutestraveltraveltime time to the 14 14 minutes minutes SSD SSDaction actiontime time(i.e., | |||
(Le.,the thevalidated validatedtime timefor forthe theHVO HVOspecific specificaction actionof ofstarting starting the CRD pump) pump) yields yields 29 29 minutes to to complete the HVO HVO SSD SSD function. | |||
function. The 29 minutes remains within within the the hydraulic AOR AOR requirement of of 32 minutes. | |||
minutes. | |||
Additional HVO HVO Response Response Time Time Validation ValidationininSupport Supportofofthis thisRAIRAt#1 #1 It is important It is important to to note note that that the the actions in question pertain pertain to to fire areas areas addressed addressedbybyAppendixAppendixR,R, Section III.G, "Fire protection III.G, "Fire protection of of safe safe shutdown capability," paragraph 3, and capability," paragraph and as-such, as-such,NUREG-NUREG-1852 does does not notstrictly strictly apply. NUREG-1 NUREG-1852 852 specifically specifically addresses addresses exemption exemption requestsrequests associated associated with with Appendix Appendix R, R, Section Section III.G, III.G,paragraph paragraph22manual manualactions. | |||
actions. DNPS has used used thethe guidance guidance in in NUREG-1852 NUREG-1852 from from a philosophical standpoint in developing this exemption request. | |||
In In March 2012, subsequentsubsequentto toreceiving receivingthe theNRC's NRC'srequestrequestfor foradditional additionalinformation, information, DNPS DNPS conducted conducted an anadditional additional time time validation validation of the above above scenario. | |||
scenario.This Thisvalidation validationwas wasperformed performedinin two separate separatesteps:steps:1)1)the thetimetimefor forthe theHVO HVOtototravel travel fromfrom the the remote remote OCA OCA to the operator operator SSD SSD muster muster area;area; andand2) 2)the thetimetimefrom from the theHVO HVO to to travel travel from the SSD muster muster area areatotothetheCRDCRD pump location location and and simulate simulate aapump pumpstart. | |||
start. | |||
Individual Individual HVOs HVOs were were timed timed fromfrom the the Goose Lake Lake pumping station station through through the the Main Main Access Access Facility Facility to to the the operator SSD muster area. The TheHVOs, HVOs,positioned positionedatatthe theGoose GooseLake Lakepumping pumping | |||
: station, station, were were contacted contactedby bythetheControl ControlRoomRoom(simulated) | |||
(simulated) via via radio radio andanddirected directedto toreturn returntotothe the plant. | |||
plant. The The HVOs HVOs were wereinstructed instructedtotomove movebriskly brisklywithwith purpose, purpose,but butnotnotrun; run;and andtotodrive drivewithin within the the speed speedlimitlimit on on the the public public roads roads (as (asthe theHVOHVO utilizes utilizes a company vehicle to reach the the Goose Goose Lake Lake pump house housewhichwhich isis approximately approximately 1.5 1.5 miles miles fromfrom the DNPS DNPS security security entrance). | |||
entrance). The The three three individual individual HVOs times for for this this step step were 16, 13.5, 13.5, and and 16 16minutes, minutes,respectively. | |||
respectively. | |||
Page Page 2of52 of 5 | |||
ATTACHMENT ATTACHMENT 11 Response to Request for Additional Information Information Regarding the Request for Exemption from 10 10 CFR 50 50 Appendix Appendix R, R, Section Section III.L m.l | |||
.."Alternative Alternative and dedicated dedicated shutdown shutdown capability" capability" Separate from Separate from thethe above abovesimulation, simulation, three threedifferent different HVOs HVOs were were timed timed fromfrom thethe operator operatorSSD SSD muster area area to the CRD CRD pump location where they location where they simulated simulated the the CRDCRD pump pump start. | |||
start. The three three individuals completed individuals completed the the simulated simulated pump pump start start in in 12.5, 12.5, 10, and 19 19 minutes, respectively. | |||
respectively. Note Note that two minutes will also be will also be added to to these thesetimes timestotoaccount accountfor foraashort shortpre-job pre-jobbriefing briefingthat that would normallytake would normally takeplace placeininthetheSSDSSDmuster musterarea. area. Two Two minutes minutes was was selected selected based on engineering judgment. | |||
Therefore, the representative time for the entire evolution evolution is is taken taken as as the the sum sum of of the the longest longest recorded times (Le., | |||
recorded (i.e., most conservative) for the two steps; i.e., Le., | |||
16 + 19 + 2 (briefing) = 37 37 minutes minutes Note that Dresden Abnormal Abnormal Operating Procedure Procedure DOA DOA 0010-10, 0010-10, "Fire/Explosion," | |||
"Fire/Explosion," is is entered any time aa confirmed confirmed fire exists (e.g., by by multiple multiple corroborating indications indications of of aa fire, fire, or report of of aa fire by fire by personnel). To maximize the time margin available for performing To maximize the time margin available for performing time critical actions, time critical actions, DOA 0010-10 DOA 0010-10 has has been revised revised (in(in Revision Revision 14) 14) toto order order aarecall recall of of operators operatorsany anytimetimeaafire fireisis confirmed. If confirmed. fire is If the fire is located located inside inside the the protected area, area, then then instructions instructions are aregiven given to to "Recall "Recall Operations personnel outside outside the the protected protectedarea area(i.e., | |||
(Le.,switchyard, switchyard,lift lift station, etc.) | |||
etc.) to be be for assistance." | |||
available for assistance." | |||
Cable fire testing performed by the Industry is documented fire testing documented in in NEI NEI 00-01 00-01 Rev 2, "Guidance"Guidance for for Post-Fire Safe Shutdown Circuit Analysis,"(Le., | |||
Circuit Analysis," (i.e.,Reference Reference3). 3). This document notes notes thatthat cables cables do not fail fail immediately. | |||
immediately. Data indicated that that the the average averagetime timetotofailure failure forfor thermoset thermosetand and armored cables exceeded exceeded30 30minutes; minutes; and andthetheaverage averagetime timetotofailure failure forfor thermoplastic cables cables was 15 minutes. DNPS DNPS has hasaaboth boththermoset thermosetand andthermoplastic thermoplasticcable cable(with (withthe theexception exceptionof of aa few cables in the drywell drywell whichwhichare are stainless stainless steel). Therefore, Therefore, the theoperator operatorrecallrecalluponupon confirmation of confirmation ofaa fire firewould wouldbe beinitiated initiatedbefore beforeconditions conditionshave havedegraded degraded to the point where aa reactor shutdown is necessary necessary in in accordance accordancewith with the the DSSPs. | |||
DSSPs.Specifically, Specifically,ControlControlRoom Room(CR) (CR) personnel would would notify notify allall operators operators (including (including the HVO) HVO) to to return return to to the the plant, in accordance accordance with DOA0010-10, with DOA 0010-10, prior priorto tothe the growth growth of ofaa fire firethat that would wouldnecessitate necessitate entry into into DSSP DSSP 0100-CR. | |||
0100-CR. | |||
Therefore, at least least 1515 additional additional minutes minutes areareavailable availablefrom from thethetimetimethe therecall recall instruction instruction isis given to given to the the HVO HVOto tothe the time timethat that DSSP-0100-CR DSSP-01 00-CRisisentered enteredand andthe the associated associated start of of the AOR time requirement AOR time requirement for forSSD SSDaction actioncompletion. | |||
completion. Subsequently, 15 15 minutes minutes is is subtracted subtractedfrom from the total HVO response time (see HVO response (see column column 66 in in Table 1) since the the operator operator recallrecall would would begin approximately 15 minutes prior prior to the start start of of the the 3232minute minutetimetimerequirement requirementininthe theAOR. | |||
AOR. | |||
Page 33 of Page of 5 | |||
ATTACHMENT11 ATTACHMENT Response to Response to Request Request for for Additional Additional Information Information Regarding Regarding the theRequest Requestfor forExemption Exemptionfrom from1010 CFR CFR 5050 Appendix Appendix R, R, Section Section 111.1 lII.l "Alternative and and dedicated dedicated shutdown shutdown capability" capability" Table Table 11 Conservative HVO Most Conservative HVO Response Response Time Time and and Margin Margin to to AOR AOR Limit limit Column1-Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 7 Time to Pre-job Time to Total Growth Fire Growth Time to Margin Margin to Return Retumto to Briefing Leave leaveSSD SSD Response between Complete CRD Complete CRD 32 minute Station andand Muster Time DOA 0010-10 DOAOO1Q..10 Pump Start AOR Limitlimit Report to to Location location entry and from DSSP DSSP (32 - Cot 6): | |||
(32-CoI6) | |||
SSDMuster SSD Muster and Start DSSP entry DSSPentry Entry Area the theCRD CRD (Cot (Col 4 -- Cot Col 5) | |||
Pump PUMP 16 2 19 37 15 22 10 As can be seen, the margin margin to to thethe 32 32 minute minute AOR AOR limit, limit, using using thethe most most conservative conservative combination of the HVO HVO response response times times waswas 10 10 minutes. | |||
minutes. | |||
In addition In addition to to the the time time margin margin shownshown above, it should be noted noted that that additional additional time time margin margin is is embedded embedded in in the thehydraulic hydraulic analysis analysisof ofrecord record(AOR) (AOR) for thesethese scenarios, scenarios,although althoughnot notexplicitly explicitly credited. The The32 32minute minutetime timelimitlimit emanates emanatesfrom from assuming assuming that thatthetheIsolation Isolation Condenser Condenserisis placed in service and and CRD CRD pumppump injection injection is is initiated initiated to the reactor pressurepressurevessel vessel(RPV). | |||
(RPV). | |||
In | Untilthe Until the Isolation IsolationCondenser Condenser is is placed in in service, service, RPVRPV level level gradually graduallydecreases decreases due to to safety safety relief valve relief valve (SRV) | ||
(SRV)cycling cyclingtotorelieve relievereactor reactorpressure. | |||
pressure. Once Once the theIsolation Isolation Condenser Condenserisisinitiated, initiated, SRV cycling SRV cyclingceases ceases and RPV RPV inventory inventory loss loss due due toto SRV SRV cycling cyclingalso alsoceases. | |||
ceases. Thus, Thus, additional additional time is effectively available for the restoration restoration of of CRD CRD pumppump injection. | |||
injection. | |||
HVO Travel Time and Station Access AccessUncertainties Uncertainties Travel time Travel time and and station station access access uncertainties uncertaintieswere wereinitially addressed in initially addressed in Reference Reference 1, 1, on page page44of of1010ininthe the"HVO "HVO Travel Travel Time and and Station Station Access AccessImpediments" Impediments" Specifically,travel section. Specifically, traveltimetimeuncertainties uncertainties associated associated with with adverse weatherweather conditions conditions were were addressed; however, addressed; however, itit should should be benoted notedthat thatthere thereareareno noTechnical TechnicalSpecification Specification related related readings taken taken at at the theGoose GooseLake Lakepumping pumpingstation, station,and andlog logtaking takingactivities activitiesatatthis thislocation locationmay may be delayed in the event of severe severe weather weather until additional personnel until additional personnel are are available. | |||
available. ItIt is also noted that that NRC NRC guidance guidance in in NRC NRC BTP BTP APCSB APCSB 9.5-1, 9.5-1, "Guidelines "Guidelines for for Fire Fire Protection for Nuclear Power Plants," SectionSection III.A, III.A, "Defense in in Depth," | |||
Depth," doesdoes not require that fires fires be be postulated postulated concurrent with with other other plant plant accidents accidents or the the most severe severe natural natural phenomenon. | |||
phenomenon. | |||
Other various travel time uncertainties uncertainties such suchas asHVO HVOillness illnessor orinjury, injury, radio radio malfunction, malfunction, varying varying within the locations within the remote OCA,OCA, and varying physical capabilities of individual operators are individual operators specificallyaddressed not specifically addressed in in this evaluation but are are accommodated accommodatedininthe themargin marginto tothe theAORAOR limitshown time limit shown inin above above table. ItIt isis worthy worthy to note note that that none noneof ofthe theHVO's HVO'sactivities activities at atthe the Goose Lake Goose Lake pumping pumping station station would would prevent preventimmediate immediatereturn returntotothe theplant plantuponuponnotification notificationfrom from the Control Room. | |||
Page 4 of of 5 | |||
ATTACHMENT 1 ATTACHMENT Response to Response to Request Request for for Additional Additional Information Information Regarding the Regarding the Request Request for for Exemption Exemption from from 1010 CFR CFR 50 Appendix R, Section III. m.lL | |||
""Alternative Alternative and and dedicated dedicated shutdown capability" RAI #2 RAI#2 Provide information Provide information concerning concerning when, when, in in a fire fire event, event, the operators would be directed directed to to return return to the to the plant plant (e.g., | |||
(e.g., fire fire alarm alarm sounding sounding in in an an SSD-related fire area, area, verification of of actual fire in a fire area fire area containing containing SSD SSD equipment, equipment, when when a control room evacuation is required and and procedure procedure (and timeline) | |||
(and timeline) entry is required, required, or some other other time). | |||
time). | |||
===Response=== | |||
Response As noted As noted above, Dresden Dresden Abnormal Abnormal Operating Operating Procedure ProcedureDOA DOA 0010-10, 0010-10,"Fire/Explosion," | |||
"Fire/Explosion," is entered any any time time aa confirmed confirmed fire fire exists exists (e.g., | |||
(e.g.,by bymultiple multiple corroborating corroborating indications indicationsof of aafire, fire, or or report of report of aa fire fire by by personnel). | |||
personnel). To Tomaximize maximize the thetime timemargin marginavailable availablefor forperforming performingtime timecritical critical actions, DOA 0010-10 has DOA 0010-10 has been revised revised (in (in Revision Revision 14) to order an operator operator recall recall any any timetime aa confirmed fire confirmed fireexists. | |||
exists. If the fire If the fireisislocated located inside insidethe the protected protected area, area, then instructions instructions are are given given "Recall Operations to "Recall Operations personnel outside the protected protected areaarea(i.e., | |||
(Le.,switchyard, switchyard, lift lift station, etc.) to be available for for assistance." | |||
assistance." This Thisrecall recall isiswithin within the first step of the "Subsequent "Subsequent Operator Operator Actions" section Actions" section of the procedure; procedure; therefore, therefore,this thisrecall recallwould wouldoccur occurshortly shortlyfollowing following confirmation of aa fire. | |||
confirmation REFERENCES REFERENCES | |||
REFERENCES 1. | : 1. from D. M. Gullott (EGC) to NRC, "Request for Exemption Letter from Exemption fromfrom 1010 CFR CFR 50,50, Appendix R, Section III.L," III.L," dated dated February February 13, 13, 2012 2012 | ||
-Unacceptable with | : 2. Letter from from J.J. Wiebe (NRC)(NRC) to to M. | ||
M. J.J. Pacilio Pacilio (EGC), | |||
(EGC), "Dresden Nuclear Power Station, Station, Units Units 2 and and 33 -- Request Requestfor forExemption ExemptionFrom From10 10CFRCFR50,50,Appendix AppendixR,R,Section SectionIII.LIII.L-Unacceptable Unacceptablewith with thethe Opportunity Opportunity to to Supplement Supplement(TAC (TAC No. | |||
No. ME8008)," | |||
ME8008)," dated dated March March 19, 19, 2012 | |||
: 3. NEI 00-01 Rev NE100-01 Rev 2, "Guidance "Guidance for for Post-Fire Post-Fire Safe Safe Shutdown Shutdown Circuit Circuit Analysis," | |||
Analysis," June June5, 5, 2009 2009 Page Page55of of55}} |
Latest revision as of 18:04, 6 February 2020
ML12086A014 | |
Person / Time | |
---|---|
Site: | Dresden |
Issue date: | 03/23/2012 |
From: | Kaegi G Exelon Generation Co, Exelon Nuclear |
To: | Office of Nuclear Reactor Regulation, Document Control Desk |
References | |
RS-12 -045 | |
Download: ML12086A014 (7) | |
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ExelonGeneration Exelon Generation Company, Company,LLCLLC www.exeloncorp.com www.exeloncorp.com 4300 Winfield 4300 Winfield Road Road Nuclear Nuclear Warrenville, ILIL60555 Warrenville, 60555 RS-12-045 RS-12-045 1010CFR CFR50.1250.12 10 10 CFR CFR 50,50, Appendix Appendix R R March23, March 23,2012 2012 U.S. Nuclear U.S. Nuclear Regulatory Commission AATTN: Document Control TIN: Document Control Desk Desk Washington,DC Washington, DC 20555-0001 20555-0001 Dresden Nuclear Dresden Nuclear Power Station,Station, Units Units 22 andand 3 Renewed Facility Operating Renewed Facility Operating License License Nos. Nos. DPR-19 DPR- 1 9and and DPR-25 DPR-25 NRC Docket NRC Docket Nos.Nos. 50-237 and and 50-249
Subject:
Response to Response toRequest Requestfor forAdditional Additional Information Information Regarding Regarding the Request for the Request for Exemption from Exemption from 10 CFR 50, 50, Appendix Appendix R, R, Section SectionIII.L III.L
References:
(1) Letter from Letter from D. D. M. Gullott Gullott (EGC)
(EGC) to NRC,NRC, "Request "Request forfor Exemption Exemption from 10 10 CFR 50,50, Appendix Appendix R, SectionSection III.L," dated February 13, 2012 2012 (2) Letter from Letter from J.J.Wiebe Wiebe (NRC)
(NRC) to to M. J. Pacilio Pacilio (EGC), "Dresden "Dresden Nuclear Power Power Station, Units 22 and Station, Units and 33 -- Request Request for for Exemption Exemption From 10 CFR CFR 50, 50, Appendix Appendix R,Section III.L - Unacceptab Unacceptable with the le with theOpportunity Opportunity to to Supplement Supplement (TAC (TAC No. ME8008)," dated dated March March 19,19, 2012 2012 In Reference 1, In Reference 1, in in accordance accordance with with 1010 CFR CFR 50.12, 50.12,"Specific "Specific exemptions, exemptions," Exelon Generation
" Exelon Generation Company, Company, LLC (EGC) requested LLC (EGC) requested a permanent permanent exemption exemption from from the requiremen requirements in 10 ts in 10CFRCFR 50 50 Appendix Appendix R, R, "Fire Protection Program for "Fire Protection for Nuclear Power FacilitiesFacilities Operating Operating PriorPrior to January January 1, 1, 1979,"
1979," Section SectionIII.L III.L "Alternative "Alternative and and dedicated dedicated shutdown shutdowncapability,"
capability," paragraph paragraph 4,4,for forDresden Dresden Nuclear Nuclear Power Station Station (DNPS) Units Units 22 and 3. The The requested requestedexemption exemptionwouldwouldeliminate eliminate the the requirement requirement for for the on-shift on-shift High Voltage Operator (HVO),
(HVO), a membermember of of the the Safe SafeShutdown Shutdown (SSD)
(SSD)staff, staff,totoremainremain"on "on site siteatatall alltimes" times" andandwould wouldallowallowthe theHVO HVOtotoconduct conductnormal normalshift shift duties, duties, including including those thoseatatremote remoteOwner OwnerControlled ControlledAreasAreas(OCAS),
(OCAs),while whilefulfilling fulfillingaarequired required position position on on the the SSD SSDstaff.
staff.InInaddition, addition,the theexemption exemptionwould wouldeliminate eliminatethetherequiremen requirement t totoremain remain "on "on site site at at all all times" times" for one one on -shift Operations Supervisor, also on-shift also aa member memberof ofthe theSSDSSDstaff,staff,and and allow allow that that individual individual to perform perform the the duties of of aa Safety /First-aid Monitor Safety/First-aid Monitor during during switching switching operations operations occurring occurring at at aa remote remoteOCA, OCA, i.e.,
i.e.,the the345kV 345kVswitchyard switchyardor orlake lakelift lift station.
station. The The exemption was requested in accordance exemption was requested in accordance with the requiremen with the requirements of 10 ts of 10CFR CFR 50.12(a)(2)(
50.12(a)(2)(ii) since ii) since the the application application of of the the regulation regulation in in this particular circumstance is not necessary particular circumstance necessary to toachieve achievethe the underlying underlying purpose purposeofofthe therule.
rule.
In In Reference Reference2,2,the theNRC NRCformally formallynotified notified EGCEGC that that additional additional information information was neededneededininorder order toto commence commenceaadetailed detailedreview reviewofofthe thesubmittal.
submittal. PriorPrior toto issuance issuanceofofReference Reference2,2,ononMarch March7,7, 2012, 2012,aateleconferen teleconference ce waswasheldheldbetween betweenmembers membersofofthe theNRCNRCand andEGCEGCstaffs staffstotodiscuss discussand and clarify the additional information that would clarify the additional information that would be requested. A be requested. A subsequent subsequent telephone telephonecall callwaswas
March 23, March 23, 2012 U.S. Nuclear Regulatory Commission U.S.
Page 2 held between J. Wiebe (NRC) held (NRC) and and J. A.
A. Bauer (EGG)(EGC)to toconfirm confirmthetheresponse responseduedue date.
date. The The due date was was determined determined to to be be March March 26, 2012, i.e.,
26,2012, i.e., 13 13 working working days after thethe date of the clarification conference clarification conference call call in in accordance accordancewith withNRCNRCOffice Office Instruction Instruction LIC-1 09, Acceptance LlC-109, Acceptance Review Procedures." The Review Therequested requestedinformation informationisisprovided providedininAttachment Attachment11ofofthis thisletter.
letter.
This letter contains no newnew regulatory regulatory commitments.
commitments.
you have any questions concerning If you concerning this this letter, please please contact contact Joseph JosephA. A. Bauer Bauer atat (630)
(630) 657-657-2804.
Respectfully, Glen T. Kaegi Kaegi Director -- Licensing Licensing and and Regulatory RegulatoryAffairs Affairs Exelon Exelon Generation Company, LLC cc: NRC Regional Administrator, Region Region IIIIII NRC Senior Resident Inspector - Dresden NRC DresdenNuclearNuclearPower PowerStation Station IllinoisEmergency Illinois Emergency Management Management AgencyAgency - Division Division of of Nuclear Safety Safety
ATTACHMENT ATTACHMENT11 Response to Request for Additional Information Information Regarding the the Request Requestfor forExemption Exemptionfrom from10 10CFRCFR50 50Appendix AppendixR,R,Section Section III.L lII.l "Alternative "Alternative and and dedicated dedicated shutdown shutdowncapability" capability" In In Reference 1, 1, in in accordance accordancewith with 1010 CFR CFR 50.12, 50.12, "Specific "Specific exemptions,"
exemptions," Exelon Exelon Generation Generation Company, LLC (EGC) requested LLC (EGC) requested a permanent exemption exemption from the requirements requirements in 10 in 10 CFR CFR 50 50 Appendix R, "Fire Protection Program for Nuclear Facilities Operating Prior "Fire Protection Prior to January January1,1,1979," 1979,"
Section III.L "Alternativeand III.L "Alternative anddedicated dedicated shutdown shutdown capability,"
capability," paragraph paragraph 4, for for Dresden Dresden NuclearNuclear Power Station (DNPS) Units 22 and (DNPS) Units and 3.3. The The requested requestedexemption exemptionwould wouldeliminate eliminatethe the requirement for the on-shift High Voltage Operator (HVO),
High Voltage (HVO), aa member of the Safe SafeShutdown Shutdown (SSD) staff, to remain remain "on"on site site atatall all times" times" andandwould wouldallow allow the theHVO HVO totoconduct conductnormal normalshift shift duties, including including those thoseatatremote remoteOwner OwnerControlled ControlledAreas Areas(OCAs),
(OCAs),while whilefulfilling fulfilling aarequired required position on the SSD staff. staff. InIn addition, addition, the theexemption exemption wouldwould eliminate eliminate the therequirement requirementtotoremain remain
`on "on site at all times" times" for foroneone on-shift on-shiftOperations Operations Supervisor, Supervisor, also also aa member of the SSD staff, and allow that individual individual to to perform perform the the duties of aa Safety/First-aid Safety/First-aid MonitorMonitor during switching switching operations operations occurring occurring at at aa remote remote OCA, OCA, i.e.,Le., the the 345kV 345kV switchyard switchyard or lake lake lift station. The lift station. The exemption is being requested requestedin in accordance accordancewith withthe therequirements requirementsofof10 10CFRCFR50.12(a)(2)(ii) 50.12(a)(2)(ii) since the application application of the regulation regulation in in this this particular particularcircumstance circumstance isis not not necessary necessary to achieve achieve the underlying underlying purposepurpose of of the the rule.
rule.
In Reference 2, In 2, the the NRC NRC formally formally notified notified EGC EGC thatthat additional additional information information was was needed needed in in order order to commence aa detailed detailed review review of the submittal. Prior Prior to to issuance issuanceof ofReference Reference2,2,on onMarch March7,7, 2012, aa teleconference was was held held between between members membersof of the the NRCNRC andand EGC EGC staffs staffs toto discuss discussand and clarifythe clarify the additional additionalinformation informationthat thatwould wouldbeberequested.
requested. AA subsequent subsequent telephone telephone call call was was held between J. Wiebe (NRC) (NRC) and and J.J. A.
A. Bauer Bauer (EGC)
(EGC)totoconfirm confirmthe theresponse responsedue due date.
date. TheThe due date date was was determined determined to to be beMarch March 26, 26, 2012, 2012, i.e.,
Le., 13 13working working days days after after thethe date dateof ofthe the clarification conference clarification conference call in accordance accordance with with NRC NRC Office Office Instruction Instruction LIC-1 LlC-109, 09, Acceptance Acceptance Review Procedures."
Review Procedures." The The requested requestedinformation information is is provided provided below.
below.
Note that the below discussion focuses focuses primarily primarily on the HVO activities; however, HVO activities; however, the the remote OCA considered OCA considered (i.e., (Le., the the Goose GooseLake Lakepumping pumpingstation) station)isisthethemost mostlimiting limitingOCA OCAfrom from aatravel travel time standpoint; time standpoint; therefore, therefore, thethe conclusions conclusions are are also also applicable applicable to to scenarios scenarios where the Operations Supervisor Operations Supervisorisisperforming performingswitching switchingactivities activitiesatatthe the345 345kVkVswitchyard switchyardororlake lakelift lift station.
RAI #1 Provide a summary of the analysis used to determine that adequate time is available to to ensure ensure in accordance reliability in accordance with Section 4.2.2 with Section 4.2.2 of NUREG 1852.
of NUREG 1852. Include additional uncertainties and variability in the time required for manual actions that were considered.
In Part 1/ ll of of the the submittal, "Bases"Bases for for Exemption Exemption Request" Request"section sectionNUREG-NUREG-1852 1852 Guidance, Guidance, the licensee cited cited NUREG-NUREG-1852 1852 as being germane to the subject exemption request request with with respect to feasibility and and reliability criteria criteria for competing manual actions similar to safe shutdown (SSD) (SSO) activities.
NUREG-1852, Section 3.2.2, `Analysis NUREG-1852, "Analysis Showing Adequate Time Time Available to to Ensure Ensure Reliability" as as referenced by the licensee, licensee, addresses the reliability of the operator manual manual actions. ItIt states actions. states inin part part that that adequate adequate time time should be available to account for uncertainties that may be be encountered encountered by by the the operator operator manual manualactions.
actions. In lieu of directly accounting for uncertainty, the sources of uncertainty, the extra time should be sufficient to make up for uncertainties in Page 11 of 5
ATTACHMENT 1 ATTACHMENT Response to Response to Request Request for for Additional Additional Information Information Regarding the Regarding the Request Request for for Exemption from from 10 CFR CFR 50 Appendix R,Section III.L lII.l "Alternative and "Alternative and dedicated shutdown capability" estimates of the estimates the time time available and the time it takes to diagnose and execute operator operator manual actions.
manual actions. For For this this exemption, exemption, reliability reliability considerations for the travel to return to the plant are relevant.
plant relevant.
Response
Response Initial Justification Initial Justification Presented in Reference Reference 11 As noted in As in Reference 1, 1, the the limiting limiting scenario requiring Safe Shutdown Shutdown actions actions by by the the High High Voltage Operator Voltage Operator (HVO) (HVO)isisaddressed addressed in in Dresden Safe Shutdown Shutdown Procedure, Procedure, DSSP DSSP0100-CR, 0100-CR, "HotShutdown "Hot Shutdown Procedure Procedure -- Control Room Evacuation." Evacuation." In In this scenario, the the hydraulic hydraulic analysis of record of record (AOR)
(AOR) showsshows that the IsolationIsolation Condenser Condenserand andControl ControlRod RodDriveDrive(CRD)
(CRD) pump pump injection are injection are both both required required to to bebe restored in 32 minutes. In In January January2006, 2006,aatime timevalidation validation waswas conducted and all critical and all critical actions were completed in 25 minutes. Specifically, completed in 25 minutes. Specifically, the critical action the critical action assigned to assigned tothe theHVOHVO (i.e.,
(Le., locally locally starting the the 2A 2A (3A)
(3A) CRD pump) was completed completed in in 14 14minutes.
minutes.
Reference 11 also also notes notesthatthatifif the theHVOHVO is is located located at atthethemost mostlimiting limiting remote Owner Owner Controlled Controlled Area (OCA)
(OCA) (Le., (i.e., the the Goose Goose Lake pumping station) at the onset onsetof of the the above abovescenario, scenario,the theHVOHVO can be notified notified and return to the protected area areato to perform perform his/her his/her assigned assignedSSD SSDfunction function in in 15 15 minutes, as was minutes, was demonstrated demonstrated in in February February 2012.2012. Therefore, Therefore,adding addingthe the1515minutes minutestraveltraveltime time to the 14 14 minutes minutes SSD SSDaction actiontime time(i.e.,
(Le.,the thevalidated validatedtime timefor forthe theHVO HVOspecific specificaction actionof ofstarting starting the CRD pump) pump) yields yields 29 29 minutes to to complete the HVO HVO SSD SSD function.
function. The 29 minutes remains within within the the hydraulic AOR AOR requirement of of 32 minutes.
minutes.
Additional HVO HVO Response Response Time Time Validation ValidationininSupport Supportofofthis thisRAIRAt#1 #1 It is important It is important to to note note that that the the actions in question pertain pertain to to fire areas areas addressed addressedbybyAppendixAppendixR,R,Section III.G, "Fire protection III.G, "Fire protection of of safe safe shutdown capability," paragraph 3, and capability," paragraph and as-such, as-such,NUREG-NUREG-1852 does does not notstrictly strictly apply. NUREG-1 NUREG-1852 852 specifically specifically addresses addresses exemption exemption requestsrequests associated associated with with Appendix Appendix R, R, Section Section III.G, III.G,paragraph paragraph22manual manualactions.
actions. DNPS has used used thethe guidance guidance in in NUREG-1852 NUREG-1852 from from a philosophical standpoint in developing this exemption request.
In In March 2012, subsequentsubsequentto toreceiving receivingthe theNRC's NRC'srequestrequestfor foradditional additionalinformation, information, DNPS DNPS conducted conducted an anadditional additional time time validation validation of the above above scenario.
scenario.This Thisvalidation validationwas wasperformed performedinin two separate separatesteps:steps:1)1)the thetimetimefor forthe theHVO HVOtototravel travel fromfrom the the remote remote OCA OCA to the operator operator SSD SSD muster muster area;area; andand2) 2)the thetimetimefrom from the theHVO HVO to to travel travel from the SSD muster muster area areatotothetheCRDCRD pump location location and and simulate simulate aapump pumpstart.
start.
Individual Individual HVOs HVOs were were timed timed fromfrom the the Goose Lake Lake pumping station station through through the the Main Main Access Access Facility Facility to to the the operator SSD muster area. The TheHVOs, HVOs,positioned positionedatatthe theGoose GooseLake Lakepumping pumping
- station, station, were were contacted contactedby bythetheControl ControlRoomRoom(simulated)
(simulated) via via radio radio andanddirected directedto toreturn returntotothe the plant.
plant. The The HVOs HVOs were wereinstructed instructedtotomove movebriskly brisklywithwith purpose, purpose,but butnotnotrun; run;and andtotodrive drivewithin within the the speed speedlimitlimit on on the the public public roads roads (as (asthe theHVOHVO utilizes utilizes a company vehicle to reach the the Goose Goose Lake Lake pump house housewhichwhich isis approximately approximately 1.5 1.5 miles miles fromfrom the DNPS DNPS security security entrance).
entrance). The The three three individual individual HVOs times for for this this step step were 16, 13.5, 13.5, and and 16 16minutes, minutes,respectively.
respectively.
Page Page 2of52 of 5
ATTACHMENT ATTACHMENT 11 Response to Request for Additional Information Information Regarding the Request for Exemption from 10 10 CFR 50 50 Appendix Appendix R, R, Section Section III.L m.l
.."Alternative Alternative and dedicated dedicated shutdown shutdown capability" capability" Separate from Separate from thethe above abovesimulation, simulation, three threedifferent different HVOs HVOs were were timed timed fromfrom thethe operator operatorSSD SSD muster area area to the CRD CRD pump location where they location where they simulated simulated the the CRDCRD pump pump start.
start. The three three individuals completed individuals completed the the simulated simulated pump pump start start in in 12.5, 12.5, 10, and 19 19 minutes, respectively.
respectively. Note Note that two minutes will also be will also be added to to these thesetimes timestotoaccount accountfor foraashort shortpre-job pre-jobbriefing briefingthat that would normallytake would normally takeplace placeininthetheSSDSSDmuster musterarea. area. Two Two minutes minutes was was selected selected based on engineering judgment.
Therefore, the representative time for the entire evolution evolution is is taken taken as as the the sum sum of of the the longest longest recorded times (Le.,
recorded (i.e., most conservative) for the two steps; i.e., Le.,
16 + 19 + 2 (briefing) = 37 37 minutes minutes Note that Dresden Abnormal Abnormal Operating Procedure Procedure DOA DOA 0010-10, 0010-10, "Fire/Explosion,"
"Fire/Explosion," is is entered any time aa confirmed confirmed fire exists (e.g., by by multiple multiple corroborating indications indications of of aa fire, fire, or report of of aa fire by fire by personnel). To maximize the time margin available for performing To maximize the time margin available for performing time critical actions, time critical actions, DOA 0010-10 DOA 0010-10 has has been revised revised (in(in Revision Revision 14) 14) toto order order aarecall recall of of operators operatorsany anytimetimeaafire fireisis confirmed. If confirmed. fire is If the fire is located located inside inside the the protected area, area, then then instructions instructions are aregiven given to to "Recall "Recall Operations personnel outside outside the the protected protectedarea area(i.e.,
(Le.,switchyard, switchyard,lift lift station, etc.)
etc.) to be be for assistance."
available for assistance."
Cable fire testing performed by the Industry is documented fire testing documented in in NEI NEI 00-01 00-01 Rev 2, "Guidance"Guidance for for Post-Fire Safe Shutdown Circuit Analysis,"(Le.,
Circuit Analysis," (i.e.,Reference Reference3). 3). This document notes notes thatthat cables cables do not fail fail immediately.
immediately. Data indicated that that the the average averagetime timetotofailure failure forfor thermoset thermosetand and armored cables exceeded exceeded30 30minutes; minutes; and andthetheaverage averagetime timetotofailure failure forfor thermoplastic cables cables was 15 minutes. DNPS DNPS has hasaaboth boththermoset thermosetand andthermoplastic thermoplasticcable cable(with (withthe theexception exceptionof of aa few cables in the drywell drywell whichwhichare are stainless stainless steel). Therefore, Therefore, the theoperator operatorrecallrecalluponupon confirmation of confirmation ofaa fire firewould wouldbe beinitiated initiatedbefore beforeconditions conditionshave havedegraded degraded to the point where aa reactor shutdown is necessary necessary in in accordance accordancewith with the the DSSPs.
DSSPs.Specifically, Specifically,ControlControlRoom Room(CR) (CR) personnel would would notify notify allall operators operators (including (including the HVO) HVO) to to return return to to the the plant, in accordance accordance with DOA0010-10, with DOA 0010-10, prior priorto tothe the growth growth of ofaa fire firethat that would wouldnecessitate necessitate entry into into DSSP DSSP 0100-CR.
0100-CR.
Therefore, at least least 1515 additional additional minutes minutes areareavailable availablefrom from thethetimetimethe therecall recall instruction instruction isis given to given to the the HVO HVOto tothe the time timethat that DSSP-0100-CR DSSP-01 00-CRisisentered enteredand andthe the associated associated start of of the AOR time requirement AOR time requirement for forSSD SSDaction actioncompletion.
completion. Subsequently, 15 15 minutes minutes is is subtracted subtractedfrom from the total HVO response time (see HVO response (see column column 66 in in Table 1) since the the operator operator recallrecall would would begin approximately 15 minutes prior prior to the start start of of the the 3232minute minutetimetimerequirement requirementininthe theAOR.
AOR.
Page 33 of Page of 5
ATTACHMENT11 ATTACHMENT Response to Response to Request Request for for Additional Additional Information Information Regarding Regarding the theRequest Requestfor forExemption Exemptionfrom from1010 CFR CFR 5050 Appendix Appendix R, R, Section Section 111.1 lII.l "Alternative and and dedicated dedicated shutdown shutdown capability" capability" Table Table 11 Conservative HVO Most Conservative HVO Response Response Time Time and and Margin Margin to to AOR AOR Limit limit Column1-Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 7 Time to Pre-job Time to Total Growth Fire Growth Time to Margin Margin to Return Retumto to Briefing Leave leaveSSD SSD Response between Complete CRD Complete CRD 32 minute Station andand Muster Time DOA 0010-10 DOAOO1Q..10 Pump Start AOR Limitlimit Report to to Location location entry and from DSSP DSSP (32 - Cot 6):
(32-CoI6)
SSDMuster SSD Muster and Start DSSP entry DSSPentry Entry Area the theCRD CRD (Cot (Col 4 -- Cot Col 5)
Pump PUMP 16 2 19 37 15 22 10 As can be seen, the margin margin to to thethe 32 32 minute minute AOR AOR limit, limit, using using thethe most most conservative conservative combination of the HVO HVO response response times times waswas 10 10 minutes.
minutes.
In addition In addition to to the the time time margin margin shownshown above, it should be noted noted that that additional additional time time margin margin is is embedded embedded in in the thehydraulic hydraulic analysis analysisof ofrecord record(AOR) (AOR) for thesethese scenarios, scenarios,although althoughnot notexplicitly explicitly credited. The The32 32minute minutetime timelimitlimit emanates emanatesfrom from assuming assuming that thatthetheIsolation Isolation Condenser Condenserisis placed in service and and CRD CRD pumppump injection injection is is initiated initiated to the reactor pressurepressurevessel vessel(RPV).
(RPV).
Untilthe Until the Isolation IsolationCondenser Condenser is is placed in in service, service, RPVRPV level level gradually graduallydecreases decreases due to to safety safety relief valve relief valve (SRV)
(SRV)cycling cyclingtotorelieve relievereactor reactorpressure.
pressure. Once Once the theIsolation Isolation Condenser Condenserisisinitiated, initiated, SRV cycling SRV cyclingceases ceases and RPV RPV inventory inventory loss loss due due toto SRV SRV cycling cyclingalso alsoceases.
ceases. Thus, Thus, additional additional time is effectively available for the restoration restoration of of CRD CRD pumppump injection.
injection.
HVO Travel Time and Station Access AccessUncertainties Uncertainties Travel time Travel time and and station station access access uncertainties uncertaintieswere wereinitially addressed in initially addressed in Reference Reference 1, 1, on page page44of of1010ininthe the"HVO "HVO Travel Travel Time and and Station Station Access AccessImpediments" Impediments" Specifically,travel section. Specifically, traveltimetimeuncertainties uncertainties associated associated with with adverse weatherweather conditions conditions were were addressed; however, addressed; however, itit should should be benoted notedthat thatthere thereareareno noTechnical TechnicalSpecification Specification related related readings taken taken at at the theGoose GooseLake Lakepumping pumpingstation, station,and andlog logtaking takingactivities activitiesatatthis thislocation locationmay may be delayed in the event of severe severe weather weather until additional personnel until additional personnel are are available.
available. ItIt is also noted that that NRC NRC guidance guidance in in NRC NRC BTP BTP APCSB APCSB 9.5-1, 9.5-1, "Guidelines "Guidelines for for Fire Fire Protection for Nuclear Power Plants," SectionSection III.A, III.A, "Defense in in Depth,"
Depth," doesdoes not require that fires fires be be postulated postulated concurrent with with other other plant plant accidents accidents or the the most severe severe natural natural phenomenon.
phenomenon.
Other various travel time uncertainties uncertainties such suchas asHVO HVOillness illnessor orinjury, injury, radio radio malfunction, malfunction, varying varying within the locations within the remote OCA,OCA, and varying physical capabilities of individual operators are individual operators specificallyaddressed not specifically addressed in in this evaluation but are are accommodated accommodatedininthe themargin marginto tothe theAORAOR limitshown time limit shown inin above above table. ItIt isis worthy worthy to note note that that none noneof ofthe theHVO's HVO'sactivities activities at atthe the Goose Lake Goose Lake pumping pumping station station would would prevent preventimmediate immediatereturn returntotothe theplant plantuponuponnotification notificationfrom from the Control Room.
Page 4 of of 5
ATTACHMENT 1 ATTACHMENT Response to Response to Request Request for for Additional Additional Information Information Regarding the Regarding the Request Request for for Exemption Exemption from from 1010 CFR CFR 50 Appendix R,Section III. m.lL
""Alternative Alternative and and dedicated dedicated shutdown capability" RAI #2 RAI#2 Provide information Provide information concerning concerning when, when, in in a fire fire event, event, the operators would be directed directed to to return return to the to the plant plant (e.g.,
(e.g., fire fire alarm alarm sounding sounding in in an an SSD-related fire area, area, verification of of actual fire in a fire area fire area containing containing SSD SSD equipment, equipment, when when a control room evacuation is required and and procedure procedure (and timeline)
(and timeline) entry is required, required, or some other other time).
time).
Response
Response As noted As noted above, Dresden Dresden Abnormal Abnormal Operating Operating Procedure ProcedureDOA DOA 0010-10, 0010-10,"Fire/Explosion,"
"Fire/Explosion," is entered any any time time aa confirmed confirmed fire fire exists exists (e.g.,
(e.g.,by bymultiple multiple corroborating corroborating indications indicationsof of aafire, fire, or or report of report of aa fire fire by by personnel).
personnel). To Tomaximize maximize the thetime timemargin marginavailable availablefor forperforming performingtime timecritical critical actions, DOA 0010-10 has DOA 0010-10 has been revised revised (in (in Revision Revision 14) to order an operator operator recall recall any any timetime aa confirmed fire confirmed fireexists.
exists. If the fire If the fireisislocated located inside insidethe the protected protected area, area, then instructions instructions are are given given "Recall Operations to "Recall Operations personnel outside the protected protected areaarea(i.e.,
(Le.,switchyard, switchyard, lift lift station, etc.) to be available for for assistance."
assistance." This Thisrecall recall isiswithin within the first step of the "Subsequent "Subsequent Operator Operator Actions" section Actions" section of the procedure; procedure; therefore, therefore,this thisrecall recallwould wouldoccur occurshortly shortlyfollowing following confirmation of aa fire.
confirmation REFERENCES REFERENCES
- 1. from D. M. Gullott (EGC) to NRC, "Request for Exemption Letter from Exemption fromfrom 1010 CFR CFR 50,50, Appendix R,Section III.L," III.L," dated dated February February 13, 13, 2012 2012
- 2. Letter from from J.J. Wiebe (NRC)(NRC) to to M.
M. J.J. Pacilio Pacilio (EGC),
(EGC), "Dresden Nuclear Power Station, Station, Units Units 2 and and 33 -- Request Requestfor forExemption ExemptionFrom From10 10CFRCFR50,50,Appendix AppendixR,R,Section SectionIII.LIII.L-Unacceptable Unacceptablewith with thethe Opportunity Opportunity to to Supplement Supplement(TAC (TAC No.
No. ME8008),"
ME8008)," dated dated March March 19, 19, 2012
- 3. NEI 00-01 Rev NE100-01 Rev 2, "Guidance "Guidance for for Post-Fire Post-Fire Safe Safe Shutdown Shutdown Circuit Circuit Analysis,"
Analysis," June June5, 5, 2009 2009 Page Page55of of55