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{{#Wiki_filter:Nuclear Exelon Generation Company, LLCwww.exeloncorp.com 4300 Winfield Road Warrenville, IL 60555 RS-12-04510 CFR 50.12 10 CFR 50, Appendix R March 23, 2012 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
{{#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 9 and DPR-25 NRC Docket Nos. 50
-237 and 50-249


==Subject:==
==Subject:==
Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50, Appendix R, Section III.L
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


(1)Letter from D. M. Gullott (EGC) to NRC, "Request for Exemption from 10 CFR 50, Appendix R, Section III.L," dated February 13, 2012 (2)Letter from J. Wiebe (NRC) to M. J. Pacilio (EGC), "Dresden Nuclear Power Station, Units 2 and 3 - Request for Exemption From 10 CFR 50, Appendix R, Section III.L - Unacceptable with the Opportunity to Supplement (TAC No. ME8008)," dated March 19, 2012 In Reference 1, in accordance with 10 CFR 50.12, "Specific exemptions," Exelon Generation Company, LLC (EGC) requested a permanent exemption from the requirements in 10 CFR 50 Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1, 1979," Section III.L "Alternative and dedicated shutdown capability," paragraph 4, for Dresden Nuclear Power Station (DNPS) Units 2 and 3. The requested exemption would eliminate the requirement for the on
March 23, March    23, 2012 U.S. Nuclear Regulatory Commission U.S.
-shift High Voltage Operator (HVO), a member of the Safe Shutdown (SSD) staff, to remain "on site at all times" and would allow the HVO to conduct normal shift duties, including those at remote Owner Controlled Areas (OCAS), while fulfilling a required position on the SSD staff. In addition, the exemption would eliminate the requirement to remain"on site at all times" for one on
Page 2 held between J. Wiebe (NRC) held                        (NRC) and and J. A.
-shift Operations Supervisor, also a member of the SSD staff, and allow that individual to perform the duties of a Safety
A. Bauer (EGG)(EGC)to  toconfirm confirmthetheresponse responseduedue date.
/First-aid Monitor during switching operations occurring at a remote OCA, i.e., the 345kV switchyard or lake lift station. The exemption was requested in accordance with the requirements of 10 CFR 50.12(a)(2)(ii) since the application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule.
date. The The due date was was determined determined to to be be March March 26,   2012, i.e.,
In Reference 2, the NRC formally notified EGC that additional information was needed in order to commence a detailed review of the submittal. Prior to issuance of Reference 2, on March 7, 2012, a teleconference was held between members of the NRC and EGC staffs to discuss and clarify the additional information that would be requested. A subsequent telephone call was Exelon Generation Company, LLC 4300 Winfield Road www.exeloncorp.com Nuclear Warrenville, IL 60555 RS-12-045 10 CFR 50.12 10 CFR 50, Appendix R March 23, 2012 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, DC 20555-0001
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


==Subject:==
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 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 Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50, Appendix R, Section III.L
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


==References:==
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.


(1) Letter from D. M. Gullott (EGC) to NRC, "Request for Exemption from 10 CFR 50, Appendix R, Section III.L," dated February 13, 2012 (2) Letter from J. Wiebe (NRC) to M. J. Pacilio (EGC), "Dresden Nuclear Power Station, Units 2 and 3 -Request for Exemption From 10 CFR 50, Appendix R, Section III.L -Unacceptable with the Opportunity to Supplement (TAC No. ME8008)," dated March 19, 2012 I n Reference 1, in accordance with 10 CFR 50.12, "Specific exemptions," Exelon Generation Company, LLC (EGC) requested a permanent exemption from the requirements in 10 CFR 50 Appendix R, "Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1 , 1979," Section III.L "Alternative and dedicated shutdown capability," paragraph 4, for Dresden Nuclear Power Station (DNPS) Units 2 and 3. The requested exemption would eliminate the requirement for the on-shift High Voltage Operator (HVO), a member of the Safe Shutdown (SSD) staff, to remain "on site at all times" and would allow the HVO to conduct normal shift duties, including those at remote Owner Controlled Areas (OCAs), while fulfilling a required position on the SSD staff. In addition, the exemption would eliminate the requirement to remain "on site at all times" for one on-shift Operations Supervisor, also a member of the SSD staff, and allow that individual to perform the duties of a Safety/First-aid Monitor during switching operations occurring at a remote OCA, i.e., the 345kV switchyard or lake lift station. The exemption was requested in accordance with the requirements of 10 CFR 50.12(a)(2)(ii) since the application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule. In Reference 2, the NRC formally notified EGC that additional information was needed in order to commence a detailed review of the submittal. Prior to issuance of Reference 2, on March 7, 2012, a teleconference was held between members of the NRC and EGC staffs to discuss and clarify the additional information that would be requested.
===Response===
A subsequent telephone call was March 23, 2012 U.S. Nuclear Regulatory Commission Page 2 held between J. Wiebe (NRC) and J. A. Bauer (EGC) to confirm the response due date. The due date was determined to be March 26, 2012, i.e., 13 working days after the date of the clarification conference call in accordance with NRC Office Instruction LIC-1 09, Acceptance Review Procedures." The requested information is provided in Attachment 1 of this letter.
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)
This letter contains no new regulatory commitments.
(AOR) showsshows that the IsolationIsolation Condenser Condenserand      andControl ControlRod  RodDriveDrive(CRD)
If you have any questions concerning this letter, please contact Joseph A. Bauer at (630) 657-2804.Respectfully, Glen T. Kaegi Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC cc:NRC Regional Administrator, Region III
(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


NRC Senior Resident Inspector - Dresden Nuclear Power Station Illinois Emergency Management Agency - Division of Nuclear Safety March 23, 2012 U.S. Nuclear Regulatory Commission Page 2 held between J. Wiebe (NRC) and J. A. Bauer (EGG) to confirm the response due date. The due date was determined to be March 26,2012, i.e., 13 working days after the date of the clarification conference call in accordance with NRC Office Instruction LlC-109, Acceptance Review Procedures." The requested information is provided in Attachment 1 of this letter. This letter contains no new regulatory commitments.
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
If you have any questions concerning this letter, please contact Joseph A. Bauer at (630) 657-2804. Respectfully, Glen T. Kaegi Director -Licensing and Regulatory Affairs Exelon Generation Company, LLC cc: NRC Regional Administrator, Region III NRC Senior Resident Inspector
                              .."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.
-Dresden Nuclear Power Station Illinois Emergency Management Agency -Division of Nuclear Safety ATTACHMENT 1 Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50 Appendix R, Section III.L"Alternative and dedicated shutdown capability" In Reference 1, in accordance with 10 CFR 50.12, "Specific exemptions," Exelon GenerationCompany, LLC (EGC) requested a permanent exemption from the requirements in 10 CFR 50 Appendix R, "Fire Protection Program for Nuclear Facilities Operating Prior to January 1, 1979," Section III.L "Alternative and dedicated shutdown capability," paragraph 4, for Dresden Nuclear Power Station (DNPS) Units 2 and 3. The requested exemption would eliminate the requirement for the on-shift High Voltage Operator (HVO), a member of the Safe Shutdown (SSD) staff, to remain "on site at all times" and would allow the HVO to conduct normal shift duties, including those at remote Owner Controlled Areas (OCAs), while fulfilling a required position on the SSD staff. In addition, the exemption would eliminate the requirement to remain
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.
`on site at all times" for one on-shift Operations Supervisor, also a member of the SSD staff, and allow that individual to perform the duties of a Safety/First-aid Monitor during switching
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


operations occurring at a remote OCA, i.e., the 345kV switchyard or lake lift station. The exemption is being requested in accordance with the requirements of 10 CFR 50.12(a)(2)(ii)
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


since the application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule.
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
In Reference 2, the NRC formally notified EGC that additional information was needed in order to commence a detailed review of the submittal. Prior to issuance of Reference 2, on March 7, 2012, a teleconference was held between members of the NRC and EGC staffs to discuss and clarify the additional information that would be requested. A subsequent telephone call was held between J. Wiebe (NRC) and J. A. Bauer (EGC) to confirm the response due date. The due date was determined to be March 26, 2012, i.e., 13 working days after the date of the clarification conference call in accordance with NRC Office Instruction LIC-1 09, Acceptance Review Procedures." The requested information is provided below.
                                ""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.,
Note that the below discussion focuses primarily on the HVO activities; however, the remoteOCA considered (i.e., the Goose Lake pumping station) is the most limiting OCA from a travel time standpoint; therefore, the conclusions are also applicable to scenarios where the Operations Supervisor is performing switching activities at the 345 kV switchyard or lake lift station.RAI #1 Provide a summary of the analysis used to determine that adequate time is available to ensure reliability in accordance with Section 4.2.2 of NUREG 1852. Include additional uncertainties and variability in the time required for manual actions that were considered.
(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)
In Part ll of the submittal, "Bases for Exemption Request" section NUREG- 1852 Guidance, the licensee cited NUREG- 1852 as being germane to the subject exemption request with respect to feasibility and reliability criteria for competing manual actions similar to safe shutdown (SSD) activities.
(and   timeline) entry is required, required, or some other    other time).
NUREG-1852, Section 3.2.2, `Analysis Showing Adequate Time Available to EnsureReliability" as referenced by the licensee, addresses the reliability of the operator manual actions. It states in part that adequate time should be available to account for uncertainties that may be encountered by the operator manual actions. In lieu of directly accounting for sources of uncertainty, the extra time should be sufficient to make up for uncertainties in Page 1 of 5 ATTACHMENT 1 Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50 Appendix R, Section lII.l "Alternative and dedicated shutdown capability" In Reference 1, in accordance with 10 CFR 50.12, "Specific exemptions," Exelon Generation Company, LLC (EGC) requested a permanent exemption from the requirements in 10 CFR 50 Appendix R, "Fire Protection Program for Nuclear Facilities Operating Prior to January 1, 1979," Section III.L "Alternative and dedicated shutdown capability," paragraph 4, for Dresden Nuclear Power Station (DNPS) Units 2 and 3. The requested exemption would eliminate the requirement for the on-shift High Voltage Operator (HVO), a member of the Safe Shutdown (SSD) staff, to remain "on site at all times" and would allow the HVO to conduct normal shift duties, including those at remote Owner Controlled Areas (OCAs), while fulfilling a required position on the SSD staff. In addition, the exemption would eliminate the requirement to remain "on site at all times" for one on-shift Operations Supervisor, also a member of the SSD staff, and allow that individual to perform the duties of a Safety/First-aid Monitor during switching operations occurring at a remote OCA, Le., the 345kV switchyard or lake lift station. The exemption is being requested in accordance with the requirements of 10 CFR 50.12(a)(2)(ii) since the application of the regulation in this particular circumstance is not necessary to achieve the underlying purpose of the rule. In Reference 2, the NRC formally notified EGC that additional information was needed in order to commence a detailed review of the submittal.
time).
Prior to issuance of Reference 2, on March 7, 2012, a teleconference was held between members of the NRC and EGC staffs to discuss and clarify the additional information that would be requested.
A subsequent telephone call was held between J. Wiebe (NRC) and J. A. Bauer (EGC) to confirm the response due date. The due date was determined to be March 26, 2012, Le., 13 working days after the date of the clarification conference call in accordance with NRC Office Instruction LlC-109, Acceptance Review Procedures." The requested information is provided below. Note that the below discussion focuses primarily on the HVO activities; however, the remote OCA considered (Le., the Goose Lake pumping station) is the most limiting OCA from a travel time standpoint; therefore, the conclusions are also applicable to scenarios where the Operations Supervisor is performing switching activities at the 345 kV switchyard or lake lift station. RAI #1 Provide a summary of the analysis used to determine that adequate time is available to ensure reliability in accordance with Section 4.2.2 of NUREG 1852. Include additional uncertainties and variability in the time required for manual actions that were considered.
In Part 1/ of the submittal, "Bases for Exemption Request" section NUREG-1852 Guidance, the licensee cited NUREG-1852 as being germane to the subject exemption request with respect to feasibility and reliability criteria for competing manual actions similar to safe shutdown (SSO) activities.
NUREG-1852, Section 3.2.2, "Analysis Showing Adequate Time Available to Ensure Reliability" as referenced by the licensee, addresses the reliability of the operator manual actions. It states in part that adequate time should be available to account for uncertainties that may be encountered by the operator manual actions. In lieu of directly accounting for sources of uncertainty, the extra time should be sufficient to make up for uncertainties in Page 1 of 5 ATTACHMENT 1 Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50 Appendix R, Section III.L"Alternative and dedicated shutdown capability" estimates of the time available and the time it takes to diagnose and execute operator manual actions. For this exemption, reliability considerations for the travel to return to the plant are relevant.
Response Initial Justification Presented in Reference 1 As noted in Reference 1, the limiting scenario requiring Safe Shutdown actions by the High Voltage Operator (HVO) is addressed in Dresden Safe Shutdown Procedure, DSSP 0100-CR,"Hot Shutdown Procedure - Control Room Evacuation." In this scenario, the hydraulic analysis of record (AOR) shows that the Isolation Condenser and Control Rod Drive (CRD) pump injection are both required to be restored in 32 minutes. In January 2006, a time validation was conducted and all critical actions were completed in 25 minutes. Specifically, the critical action assigned to the HVO (i.e., locally starting the 2A (3A) CRD pump) was completed in 14 minutes.
Reference 1 also notes that if the HVO is located at the most limiting remote Owner ControlledArea (OCA) (i.e., the Goose Lake pumping station) at the onset of the above scenario, the HVO can be notified and return to the protected area to perform his/her assigned SSD function in 15 minutes, as was demonstrated in February 2012. Therefore, adding the 15 minutes travel time to the 14 minutes SSD action time (i.e., the validated time for the HVO specific action of starting the CRD pump) yields 29 minutes to complete the HVO SSD function. The 29 minutes remains within the hydraulic AOR requirement of 32 minutes.
Additional HVO Response Time Validation in Support of this RAI #1 It is important to note that the actions in question pertain to fire areas addressed by Appendix R, Section III.G, "Fire protection of safe shutdown capability," paragraph 3, and as-such, NUREG-1852 does not strictly apply. NUREG-1 852 specifically addresses exemption requests associated with Appendix R, Section III.G, paragraph 2 manual actions. DNPS has used the guidance in NUREG-1852 from a philosophical standpoint in developing this exemption request.
In March 2012, subsequent to receiving the NRC's request for additional information, DNPS conducted an additional time validation of the above scenario. This validation was performed in two separate steps: 1) the time for the HVO to travel from the remote OCA to the operator SSD muster area; and 2) the time from the HVO to travel from the SSD muster area to the CRD pump location and simulate a pump start.
Individual HVOs were timed from the Goose Lake pumping station through the Main Access Facility to the operator SSD muster area. The HVOs, positioned at the Goose Lake pumping station, were contacted by the Control Room (simulated) via radio and directed to return to the plant.The HVOs were instructed to move briskly with purpose, but not run; and to drive within the speed limit on the public roads (as the HVO utilizes a company vehicle to reach the Goose Lake pump house which is approximately 1.5 miles from the DNPS security entrance). The three individual HVOs times for this step were 16, 13.5, and 16 minutes, respectively.
Page 2of5 ATTACHMENT 1 Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50 Appendix R, Section lII.l "Alternative and dedicated shutdown capability" estimates of the time available and the time it takes to diagnose and execute operator manual actions. For this exemption, reliability considerations for the travel to return to the plant are relevant.
Response Initial Justification Presented in Reference 1 As noted in Reference 1, the limiting scenario requiring Safe Shutdown actions by the High Voltage Operator (HVO) is addressed in Dresden Safe Shutdown Procedure, DSSP 0100-CR, "Hot Shutdown Procedure
-Control Room Evacuation." In this scenario, the hydraulic analysis of record (AOR) shows that the Isolation Condenser and Control Rod Drive (CRD) pump injection are both required to be restored in 32 minutes. In January 2006, a time validation was conducted and all critical actions were completed in 25 minutes. Specifically, the critical action assigned to the HVO (Le., locally starting the 2A (3A) CRD pump) was completed in 14 minutes. Reference 1 also notes that if the HVO is located at the most limiting remote Owner Controlled Area (OCA) (Le., the Goose Lake pumping station) at the onset of the above scenario, the HVO can be notified and return to the protected area to perform his/her assigned SSD function in 15 minutes, as was demonstrated in February 2012. Therefore, adding the 15 minutes travel time to the 14 minutes SSD action time (Le., the validated time for the HVO specific action of starting the CRD pump) yields 29 minutes to complete the HVO SSD function.
The 29 minutes remains within the hydraulic AOR requirement of 32 minutes. Additional HVO Response Time Validation in Support of this RAt #1 It is important to note that the actions in question pertain to fire areas addressed by Appendix R, Section III.G, "Fire protection of safe shutdown capability," paragraph 3, and as-such, NUREG-1852 does not strictly apply. NUREG-1852 specifically addresses exemption requests associated with Appendix R, Section III.G, paragraph 2 manual actions. DNPS has used the guidance in NUREG-1852 from a philosophical standpoint in developing this exemption request. In March 2012, subsequent to receiving the NRC's request for additional information, DNPS conducted an additional time validation of the above scenario.
This validation was performed in two separate steps: 1) the time for the HVO to travel from the remote OCA to the operator SSD muster area; and 2) the time from the HVO to travel from the SSD muster area to the CRD pump location and simulate a pump start. Individual HVOs were timed from the Goose Lake pumping station through the Main Access Facility to the operator SSD muster area. The HVOs, positioned at the Goose Lake pumping station, were contacted by the Control Room (simulated) via radio and directed to return to the plant. The HVOs were instructed to move briskly with purpose, but not run; and to drive within the speed limit on the public roads (as the HVO utilizes a company vehicle to reach the Goose Lake pump house which is approximately 1.5 miles from the DNPS security entrance).
The three individual HVOs times for this step were 16, 13.5, and 16 minutes, respectively.
Page 2 of 5 ATTACHMENT 1 Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50 Appendix R, Section III.L"Alternative and dedicated shutdown capability" Separate from the above simulation, three different HVOs were timed from the operator SSD muster area to the CRD pump location where they simulated the CRD pump start. The three individuals completed the simulated pump start in 12.5, 10, and 19 minutes, respectively. Note that two minutes will also be added to these times to account for a short pre-job briefing that would normally take place in the SSD muster area. Two minutes was selected based on engineering judgment.
Therefore, the representative time for the entire evolution is taken as the sum of the longest recorded times (i.e., most conservative) for the two steps; i.e., 16 + 19 + 2 (briefing) = 37 minutes Note that Dresden Abnormal Operating Procedure DOA 0010-10, "Fire/Explosion," is entered any time a confirmed fire exists (e.g., by multiple corroborating indications of a fire, or report of a fire by personnel). To maximize the time margin available for performing time critical actions, DOA 0010-10 has been revised (in Revision 14) to order a recall of operators any time a fire isconfirmed. If the fire is located inside the protected area, then instructions are given to "Recall Operations personnel outside the protected area (i.e., switchyard, lift station, etc.) to be available for assistance." Cable fire testing performed by the Industry is documented in NEI 00-01 Rev 2, "Guidance for Post-Fire Safe Shutdown Circuit Analysis," (i.e., Reference 3). This document notes that cables do not fail immediately. Data indicated that the average time to failure for thermoset and armored cables exceeded 30 minutes; and the average time to failure for thermoplastic cables was 15 minutes. DNPS has a both thermoset and thermoplastic cable (with the exception of a few cables in the drywell which are stainless steel). Therefore, the operator recall upon confirmation of a fire would be initiated before conditions have degraded to the point where a reactor shutdown is necessary in accordance with the DSSPs. Specifically, Control Room (CR) personnel would notify all operators (including the HVO) to return to the plant, in accordance with DOA 0010-10, prior to the growth of a fire that would necessitate entry into DSSP 0100-CR.
Therefore, at least 15 additional minutes are available from the time the recall instruction is given to the HVO to the time that DSSP-01 00-CR is entered and the associated start of the AOR time requirement for SSD action completion. Subsequently, 15 minutes is subtracted from the total HVO response time (see column 6 in Table 1) since the operator recall would begin approximately 15 minutes prior to the start of the 32 minute time requirement in the AOR.
Page 3 of 5 ATTACHMENT 1 Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50 Appendix R, Section m.l .. Alternative and dedicated shutdown capability" Separate from the above simulation, three different HVOs were timed from the operator SSD muster area to the CRD pump location where they simulated the CRD pump start. The three individuals completed the simulated pump start in 12.5, 10, and 19 minutes, respectively.
Note that two minutes will also be added to these times to account for a short pre-job briefing that would normally take place in the SSD muster area. Two minutes was selected based on engineering judgment.
Therefore, the representative time for the entire evolution is taken as the sum of the longest recorded times (Le., most conservative) for the two steps; Le., 16 + 19 + 2 (briefing)
= 37 minutes Note that Dresden Abnormal Operating Procedure DOA 0010-10, "Fire/Explosion," is entered any time a confirmed fire exists (e.g., by multiple corroborating indications of a fire, or report of a fire by personnel).
To maximize the time margin available for performing time critical actions, DOA 0010-10 has been revised (in Revision 14) to order a recall of operators any time a fire is confirmed.
If the fire is located inside the protected area, then instructions are given to "Recall Operations personnel outside the protected area (Le., switchyard, lift station, etc.) to be available for assistance." Cable fire testing performed by the Industry is documented in NEI 00-01 Rev 2, "Guidance for Post-Fire Safe Shutdown Circuit Analysis," (Le., Reference 3). This document notes that cables do not fail immediately.
Data indicated that the average time to failure for thermoset and armored cables exceeded 30 minutes; and the average time to failure for thermoplastic cables was 15 minutes. DNPS has a both thermoset and thermoplastic cable (with the exception of a few cables in the drywell which are stainless steel). Therefore, the operator recall upon confirmation of a fire would be initiated before conditions have degraded to the point where a reactor shutdown is necessary in accordance with the DSSPs. Specifically, Control Room (CR) personnel would notify all operators (including the HVO) to return to the plant, in accordance with DOA 0010-10, prior to the growth of a fire that would necessitate entry into DSSP 0100-CR. Therefore, at least 15 additional minutes are available from the time the recall instruction is given to the HVO to the time that DSSP-0100-CR is entered and the associated start of the AOR time requirement for SSD action completion.
Subsequently, 15 minutes is subtracted from the total HVO response time (see column 6 in Table 1) since the operator recall would begin approximately 15 minutes prior to the start of the 32 minute time requirement in the AOR. Page 3 of 5 ATTACHMENT 1 Response to Request for Additional InformationRegarding the Request for Exemption from 10 CFR 50 Appendix R, Section 111.1"Alternative and dedicated shutdown capability" Table 1 Most Conservative HVO Response Time and Margin to AOR Limit Column 1-Column 2 Column 3 Column 4 Column 5 Column 6 Column 7 Time to Pre-job Time to Total Fire Growth Time to Margin to Return to Briefing Leave SSD Response between Complete CRD 32 minute Station and Muster Time DOA 0010-10 Pump Start AOR Limit Report to Location entry and from DSSP (32 - Cot 6):
SSD Muster and Start DSSP entry Entry Area the CRD (Cot 4 - Cot 5)
PUMP 16 2 19 37 15 22 10 As can be seen, the margin to the 32 minute AOR limit, using the most conservative combination of the HVO response times was 10 minutes.
In addition to the time margin shown above, it should be noted that additional time margin is embedded in the hydraulic analysis of record (AOR) for these scenarios, although not explicitly credited. The 32 minute time limit emanates from assuming that the Isolation Condenser is placed in service and CRD pump injection is initiated to the reactor pressure vessel (RPV).
Until the Isolation Condenser is placed in service, RPV level gradually decreases due to safety relief valve (SRV) cycling to relieve reactor pressure. Once the Isolation Condenser is initiated,SRV cycling ceases and RPV inventory loss due to SRV cycling also ceases. Thus, additional time is effectively available for the restoration of CRD pump injection.
HVO Travel Time and Station Access Uncertainties Travel time and station access uncertainties were initially addressed in Reference 1, Attachment 1 on page 4 of 10 in the "HVO Travel Time and Station Access Impediments" section.Specifically, travel time uncertainties associated with adverse weather conditions were addressed; however, it should be noted that there are no Technical Specification related readings taken at the Goose Lake pumping station, and log taking activities at this location may be delayed in the event of severe weather until additional personnel are available. It is also noted that NRC guidance in NRC BTP APCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants," Section III.A, "Defense in Depth," does not require that fires be postulated concurrent with other plant accidents or the most severe natural phenomenon.
Other various travel time uncertainties such as HVO illness or injury, radio malfunction, varying locations within the remote OCA, and varying physical capabilities of individual operators are


not specifically addressed in this evaluation but are accommodated in the margin to the AOR time limit shown in above table. It is worthy to note that none of the HVO's activities at the Goose Lake pumping station would prevent immediate return to the plant upon notification from the Control Room.
===Response===
Page 4 of 5 ATTACHMENT 1 Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50 Appendix R, Section lII.l "Alternative and dedicated shutdown capability" Table 1 Most Conservative HVO Response Time and Margin to AOR limit Column 1 Column 2 Column 3 Column 4 Column 5 Column 6 Time to Pre-job Time to Total Fire Growth Time to Retumto Briefing leaveSSD Response between Complete CRD Station and Muster Time DOAOO1Q..10 Pump Start Report to location entry and from DSSP SSDMuster and Start DSSPentry Entry Area theCRD (Col 4 -Col 5) Pump 16 2 19 37 15 22 As can be seen, the margin to the 32 minute AOR limit, using the most conservative combination of the HVO response times was 10 minutes. Column 7 Margin to 32 minute AOR limit (32-CoI6) 10 In addition to the time margin shown above, it should be noted that additional time margin is embedded in the hydraulic analysis of record (AOR) for these scenarios, although not explicitly credited.
Response As noted As   noted above, Dresden Dresden Abnormal Abnormal Operating Operating Procedure ProcedureDOA  DOA 0010-10, 0010-10,"Fire/Explosion,"
The 32 minute time limit emanates from assuming that the Isolation Condenser is placed in service and CRD pump injection is initiated to the reactor pressure vessel (RPV). Until the Isolation Condenser is placed in service, RPV level gradually decreases due to safety relief valve (SRV) cycling to relieve reactor pressure.
                                                                                                      "Fire/Explosion," is entered any any time time aa confirmed confirmed fire  fire exists exists (e.g.,
Once the Isolation Condenser is initiated, SRV cycling ceases and RPV inventory loss due to SRV cycling also ceases. Thus, additional time is effectively available for the restoration of CRD pump injection.
(e.g.,by bymultiple multiple corroborating corroborating indications indicationsof  of aafire, fire, or or report of report    of aa fire fire by by personnel).
HVO Travel Time and Station Access Uncertainties Travel time and station access uncertainties were initially addressed in Reference 1, Attachment 1 on page 4 of 10 in the "HVO Travel Time and Station Access Impediments" section. Specifically, travel time uncertainties associated with adverse weather conditions were addressed; however, it should be noted that there are no Technical Specification related readings taken at the Goose Lake pumping station, and log taking activities at this location may be delayed in the event of severe weather until additional personnel are available.
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.
It is also noted that NRC guidance in NRC BTP APCSB 9.5-1, "Guidelines for Fire Protection for Nuclear Power Plants," Section III.A, "Defense in Depth," does not require that fires be postulated concurrent with other plant accidents or the most severe natural phenomenon.
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.,
Other various travel time uncertainties such as HVO illness or injury, radio malfunction, varying locations within the remote OCA, and varying physical capabilities of individual operators are not specifically addressed in this evaluation but are accommodated in the margin to the AOR time limit shown in above table. It is worthy to note that none of the HVO's activities at the Goose Lake pumping station would prevent immediate return to the plant upon notification from the Control Room. Page 4 of 5 ATTACHMENT 1 Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50 Appendix R, Section III.
(Le.,switchyard, switchyard, lift lift station, etc.) to be available for  for assistance."
L"Alternative and dedicated shutdown capability" RAI #2 Provide information concerning when, in a fire event, the operators would be directed to return to the plant (e.g., fire alarm sounding in an SSD-related fire area, verification of actual fire in a fire area containing SSD equipment, when a control room evacuation is required and procedure (and timeline) entry is required, or some other time).
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.
Response As noted above, Dresden Abnormal Operating Procedure DOA 0010-10, "Fire/Explosion," is entered any time a confirmed fire exists (e.g., by multiple corroborating indications of a fire, or report of a fire by personnel). To maximize the time margin available for performing time critical actions, DOA 0010-10 has been revised (in Revision 14) to order an operator recall any time a confirmed fire exists. If the fire is located inside the protected area, then instructions are given to "Recall Operations personnel outside the protected area (i.e., switchyard, lift station, etc.) to be available for assistance." This recall is within the first step of the "Subsequent Operator Actions" section of the procedure; therefore, this recall would occur shortly following confirmation of a fire.
confirmation REFERENCES REFERENCES
REFERENCES 1.Letter from D. M. Gullott (EGC) to NRC, "Request for Exemption from 10 CFR 50, Appendix R, Section III.L," dated February 13, 2012 2.Letter from J. Wiebe (NRC) to M. J. Pacilio (EGC), "Dresden Nuclear Power Station, Units 2 and 3 - Request for Exemption From 10 CFR 50, Appendix R, Section III.L
: 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 the Opportunity to Supplement (TAC No. ME8008)," dated March 19, 2012 3.NEI 00-01 Rev 2, "Guidance for Post-Fire Safe Shutdown Circuit Analysis," June 5, 2009 Page 5 of 5 ATTACHMENT 1 Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50 Appendix R, Section m.l " Alternative and dedicated shutdown capability" RAI#2 Provide information concerning when, in a fire event, the operators would be directed to return to the plant (e.g., fire alarm sounding in an SSD-related fire area, verification of actual fire in a fire area containing SSD equipment, when a control room evacuation is required and procedure (and timeline) entry is required, or some other time). Response As noted above, Dresden Abnormal Operating Procedure DOA 0010-10, "Fire/Explosion," is entered any time a confirmed fire exists (e.g., by multiple corroborating indications of a fire, or report of a fire by personnel).
: 2.     Letter from from J.J. Wiebe (NRC)(NRC) to  to M.
To maximize the time margin available for performing time critical actions, DOA 0010-10 has been revised (in Revision 14) to order an operator recall any time a confirmed fire exists. If the fire is located inside the protected area, then instructions are given to "Recall Operations personnel outside the protected area (Le., switchyard, lift station, etc.) to be available for assistance." This recall is within the first step of the "Subsequent Operator Actions" section of the procedure; therefore, this recall would occur shortly following confirmation of a fire. REFERENCES
M. J.J. Pacilio Pacilio (EGC),
: 1. Letter from D. M. Gullott (EGC) to NRC, "Request for Exemption from 10 CFR 50, Appendix R, Section III.L," dated February 13, 2012 2. Letter from J. Wiebe (NRC) to M. J. Pacilio (EGC), "Dresden Nuclear Power Station, Units 2 and 3 -Request for Exemption From 10 CFR 50, Appendix R, Section Unacceptable with the Opportunity to Supplement (TAC No. ME8008)," dated March 19, 2012 3. NE100-01 Rev 2, "Guidance for Post-Fire Safe Shutdown Circuit Analysis," June 5, 2009 Page 5 of 5}}
(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

Response to Request for Additional Information Regarding the Request for Exemption from 10 CFR 50, Appendix R, Section Iii.L
ML12086A014
Person / Time
Site: Dresden  Constellation icon.png
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)
v • d • e


Text

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

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