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| author name = Gratton C | | author name = Gratton C | ||
| author affiliation = NRC/NRR/DORL/LPLIII-2 | | author affiliation = NRC/NRR/DORL/LPLIII-2 | ||
| addressee name = Pacilio M | | addressee name = Pacilio M | ||
| addressee affiliation = Exelon Nuclear | | addressee affiliation = Exelon Nuclear | ||
| docket = 05000237, 05000249, 05000254, 05000265 | | docket = 05000237, 05000249, 05000254, 05000265 | ||
Line 18: | Line 18: | ||
=Text= | =Text= | ||
{{#Wiki_filter:REGlI{ UNITED STATES ",,'-NUCLEAR REGULATORY COMMISSION P WASHINGTON, D.C. 20555-0001 | {{#Wiki_filter:~~R REGlI{ UNITED STATES | ||
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September 23, 2010 | |||
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****i' Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 SUB..IECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3, AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO EXELON GENERATION COMPANY'S REQUEST TO AMEND STANDBY LIQUID CONTROL TECHNICAL SPECIFICATIONS (TAC NOS. ME2567 THRU ME2670) | |||
==Dear Mr. Pacilio:== | ==Dear Mr. Pacilio:== | ||
By letter to the Nuclear Regulatory Commission (NRC) dated November 10, 2009, Exelon Generation Company, LLC submitted a request to amend the technical specifications (TSs) to extend the completion time for Condition B of TS 3.1.7 from 8 to 72 hours for the Dresden, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2. The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on September 21, 2010, it was agreed that you would provide a response by October 12,2010. The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. | |||
If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1055. | By letter to the Nuclear Regulatory Commission (NRC) dated November 10, 2009, Exelon Generation Company, LLC submitted a request to amend the technical specifications (TSs) to extend the completion time for Condition B of TS 3.1.7 from 8 to 72 hours for the Dresden, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2. | ||
Christopher Gratton, Senior Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237, 50-249, and Request for Additional cc w/encl: Distribution via Listserv REQUEST FOR ADDITIONAL INFORMATION DRESDEN NUCLEAR POWER STATION, UNITS 1 AND 2 AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-237, 50-249, 50-254, AND 50-265 In reviewing the Exelon Generation Company's (EGC's) submittal dated November 10, 2009 (Agencywide Documents Access and Management System Accession No. ML093140516), related to your request to amend Technical Specification (TS) 3.1.7, "Standby Liquid Control (SLC) System," for the Dresden Nuclear Power Station (DNPS), Units 1 and 2, and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, the NRC staff has determined that the following information is needed in order to complete its review: Question 1 Identify adequate defense-in-depth for mitigation of anticipated transient without scram (ATWS) events for the extended 72-hour completion time period. The SLC system mitigates an ATWS event by delivering a concentrated borated solution to the reactor pressure vessel to shutdown the reactor. The TS Required Action being modified addresses the condition where both SLC trains are inoperable. | The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on September 21, 2010, it was agreed that you would provide a response by October 12,2010. | ||
In the event of an ATWS during this condition, there is no system available to inject concentrated borated solution into the reactor pressure vessel in a timely manner to achieve shutdown. | The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1055. | ||
The licensee submittal addresses the low probability of an ATWS event due to the reliability and diversity of the control rods, and also discusses the recirculation pump trip feature which reduces reactor power. However, there is no mechanism identified to assure safe shutdown to subcritical conditions as normally ensured by the operation of one of the two SLC trains. Question 2 Clarify the intended reliance on emergency operating procedure (EOP) actions as an alternate means of boration and provide evaluations that justify any credited actions related to the requirements of Title 10 of the Code of Federal Regulations, Section 50.67, "Accident source term," as appropriate. | Christopher Gratton, Senior Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237, 50-249, 50-254, and 50-265 | ||
==Enclosure:== | |||
Request for Additional Information cc w/encl: Distribution via Listserv | |||
REQUEST FOR ADDITIONAL INFORMATION DRESDEN NUCLEAR POWER STATION, UNITS 1 AND 2 AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-237, 50-249, 50-254, AND 50-265 In reviewing the Exelon Generation Company's (EGC's) submittal dated November 10, 2009 (Agencywide Documents Access and Management System Accession No. ML093140516), | |||
related to your request to amend Technical Specification (TS) 3.1.7, "Standby Liquid Control (SLC) System," for the Dresden Nuclear Power Station (DNPS), Units 1 and 2, and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, the NRC staff has determined that the following information is needed in order to complete its review: | |||
Question 1 Identify adequate defense-in-depth for mitigation of anticipated transient without scram (ATWS) events for the extended 72-hour completion time period. | |||
The SLC system mitigates an ATWS event by delivering a concentrated borated solution to the reactor pressure vessel to shutdown the reactor. The TS Required Action being modified addresses the condition where both SLC trains are inoperable. In the event of an ATWS during this condition, there is no system available to inject concentrated borated solution into the reactor pressure vessel in a timely manner to achieve shutdown. The licensee submittal addresses the low probability of an ATWS event due to the reliability and diversity of the control rods, and also discusses the recirculation pump trip feature which reduces reactor power. | |||
However, there is no mechanism identified to assure safe shutdown to subcritical conditions as normally ensured by the operation of one of the two SLC trains. | |||
Question 2 Clarify the intended reliance on emergency operating procedure (EOP) actions as an alternate means of boration and provide evaluations that justify any credited actions related to the requirements of Title 10 of the Code of Federal Regulations, Section 50.67, "Accident source term," as appropriate. | |||
Page 17 of 19 of Attachment 1 states the following: | Page 17 of 19 of Attachment 1 states the following: | ||
By letter dated October 10, 2002, EGC requested an amendment to the DNPS and QCNPS TSs regarding the adoption of an alternate source term (AST) methodology. | By letter dated October 10, 2002, EGC requested an amendment to the DNPS and QCNPS TSs regarding the adoption of an alternate source term (AST) methodology. The [Nuclear Regulatory Commission] NRC approved the requested license amendment by letter and safety evaluation (SE) dated September 11, 2006. As part of the proposed [alternate source term] AST methodology, EGC proposed the use of the SLC system to inject sodium Enclosure | ||
The [Nuclear Regulatory Commission] | |||
NRC approved the requested license amendment by letter and safety evaluation (SE) dated September 11, 2006. As part of the proposed [alternate source term] AST methodology, EGC proposed the use of the SLC system to inject sodium Enclosure pentaborate into the [reactor pressure vessel] RPV following a | -2 pentaborate into the [reactor pressure vessel] RPV following a [Ioss-of-coolant accident] LOCA in order to maintain suppression pool pH above 7 (Le., In order to ensure against re-evolution of elemental iodine). As such, the SLC is required to be operable in Mode 3 to ensure that offsite doses remain within the limits of 10 CFR 50.67, "Accident source term" following a loss-of-coolant accident (LOCA) involving significant fission product releases. However, additional redundancy for the control of suppression pool pH control following a LOCA is established by the DNPS and QCNPS Emergency Operating Procedures (EOPs). | ||
accident] | The EOPs describe the actions and criteria for manual addition of boron into the condensate systems, should [reactor protection system] RPS, control rods, the control rod drive system, and the SLC be unable to perform the specifed [sic] | ||
LOCA in order to maintain suppression pool pH above 7 (Le., In order to ensure against re-evolution of elemental iodine). As such, the SLC is required to be operable in Mode 3 to ensure that offsite doses remain within the limits of 10 CFR 50.67, "Accident source term" following a loss-of-coolant accident (LOCA) involving significant fission product releases. | design functions. Therefore, the proposed SLC [completion time] CT extension will not impact the ability of DNPS and QCNPS to comply with the requirements of 10 CFR 50.67. | ||
However, additional redundancy for the control of suppression pool pH control following a LOCA is established by the DNPS and QCNPS Emergency Operating Procedures (EOPs). The EOPs describe the actions and criteria for manual addition of boron into the condensate systems, should [reactor protection system] RPS, control rods, the control rod drive system, and the SLC be unable to perform the specifed [sic] design functions. | The license amendment request (LAR) describes alternative means for boration as additional redundancy in support of defense-in-depth measures to justify the proposed extension of the TS 3.1.7 completion time. These alternative means of boration consist of actions in the EOPs. | ||
Therefore, the proposed SLC [completion time] CT extension will not impact the ability of DNPS and QCNPS to comply with the requirements of 10 CFR 50.67. The license amendment request (LAR) describes alternative means for boration as additional redundancy in support of defense-in-depth measures to justify the proposed extension of the TS 3.1.7 completion time. These alternative means of boration consist of actions in the EOPs. Page 4 of Attachment 1 of the LAR states that the SLC system is required to be operable to ensure that offsite doses remain within 10 CFR 50.67 limits following a LOCA. The SLC system is credited for maintaining pH balance in the suppression pool at or above 7 following a LOCA to ensure that iodine will be retained in the suppression pool. The NRC staff has identified that the proposed alternate means of boration are not currently included in the DNPS and QCNPS licensing basis. The LAR indicates that the licensees intend to credit the referenced EOP actions as an alternate boration pathway to meet the requirements of 10 CFR 50.67. If so, then additional justification is required to support reliance on these actions as a credited alternate boration pathway. The NRC document "Guidance on the Assessment of a BWR [boiling-water reactor] SLC System for pH Control," dated February 12, 2004 (ADAMS Accession No. ML040640364) provides an approach that is acceptable to the NRC staff for evaluating the alternative controls of the suppression pool pH against appropriate methodologies. | Page 4 of Attachment 1 of the LAR states that the SLC system is required to be operable to ensure that offsite doses remain within 10 CFR 50.67 limits following a LOCA. The SLC system is credited for maintaining pH balance in the suppression pool at or above 7 following a LOCA to ensure that iodine will be retained in the suppression pool. | ||
The NRC staff has identified that the proposed alternate means of boration are not currently included in the DNPS and QCNPS licensing basis. The LAR indicates that the licensees intend to credit the referenced EOP actions as an alternate boration pathway to meet the requirements of 10 CFR 50.67. If so, then additional justification is required to support reliance on these actions as a credited alternate boration pathway. The NRC document "Guidance on the Assessment of a BWR [boiling-water reactor] SLC System for pH Control," dated February 12, 2004 (ADAMS Accession No. ML040640364) provides an approach that is acceptable to the NRC staff for evaluating the alternative controls of the suppression pool pH against appropriate methodologies. | |||
If Exelon's intent is not to credit a new alternate boration pathway, then clarification is needed regarding the use of the EOP actions as an alternative means of boration with respect to defense-in-depth as related to 10 CFR 50.67. Please provide the following information: | If Exelon's intent is not to credit a new alternate boration pathway, then clarification is needed regarding the use of the EOP actions as an alternative means of boration with respect to defense-in-depth as related to 10 CFR 50.67. Please provide the following information: | ||
: 1) Does the alternate injection path require actions in areas outside the control room? 2) Confirm that these areas will be accessible during the design basis accidents in your licensing bases (LOCA, Main Steamline Break etc.)? 3) What additional personnel will be required? | : 1) Does the alternate injection path require actions in areas outside the control room? | ||
: 4) Confirm that these actions can be completed within a timeframe consistent the current licensing basis. | : 2) Confirm that these areas will be accessible during the design basis accidents in your licensing bases (LOCA, Main Steamline Break etc.)? | ||
-Question 3 Please demonstrate how General Design Criteria (GDC) 26, "Protection Systems Fail-Safe Design," and GDC 27, "Redundancy of Reactivity Control," regulatory requirements are met during the requested extended outage time for both trains of SLC inoperable. | : 3) What additional personnel will be required? | ||
Question 4 The Notices of Enforcement Discretion (NOEDs) referenced in the application provide lists of compensatory actions and additional committed actions. The NRC's basis for the NOEDs considered the compensatory measures to reduce the probability of a plant transient while ensuring the availability of other safety related equipment. | : 4) Confirm that these actions can be completed within a timeframe consistent the current licensing basis. | ||
Please describe how each compensatory action is addressed in the proposed change or demonstrate why it is not necessary. (Compensatory actions: 1) both ATWS recirculation pump trip systems would be protected, 2} the reactor protection system (RPS) would be protected, and 3) all production risk activities would be prohibited) | |||
September 23, 2010 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville,IL 60555 DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3, AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 -REQUEST FOR ADDITIONAL INFORMATION RELATED TO EXELON GENERATION COMPANY'S REQUEST TO AMEND STANDBY LIQUID CONTROL TECHNICAL SPECIFICATIONS ( | - 3 Question 3 Please demonstrate how General Design Criteria (GDC) 26, "Protection Systems Fail-Safe Design," and GDC 27, "Redundancy of Reactivity Control," regulatory requirements are met during the requested extended outage time for both trains of SLC inoperable. | ||
Question 4 The Notices of Enforcement Discretion (NOEDs) referenced in the application provide lists of compensatory actions and additional committed actions. The NRC's basis for the NOEDs considered the compensatory measures to reduce the probability of a plant transient while ensuring the availability of other safety related equipment. Please describe how each compensatory action is addressed in the proposed change or demonstrate why it is not necessary. (Compensatory actions: 1) both ATWS recirculation pump trip systems would be protected, 2} the reactor protection system (RPS) would be protected, and 3) all production risk activities would be prohibited) | |||
September 23, 2010 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville,IL 60555 SUB~IECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3, AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO EXELON GENERATION COMPANY'S REQUEST TO AMEND STANDBY LIQUID CONTROL TECHNICAL SPECIFICATIONS (TAC NOS. ME2567 THRU ME2670) | |||
==Dear Mr. Pacilio:== | ==Dear Mr. Pacilio:== | ||
By letter to the Nuclear Regulatory Commission (NRC) dated November 10, 2009, Exelon Generation Company, LLC submitted a request to amend the technical specifications (TSs) to extend the completion time for Condition B of TS 3.1.7 from 8 to 72 hours for the Dresden, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2. The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on September 21,2010, it was agreed that you would provide a response by October 12, 2010. The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. | |||
If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1055. | By letter to the Nuclear Regulatory Commission (NRC) dated November 10, 2009, Exelon Generation Company, LLC submitted a request to amend the technical specifications (TSs) to extend the completion time for Condition B of TS 3.1.7 from 8 to 72 hours for the Dresden, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2. | ||
Sincerely, IRA! Christopher Gratton, Senior Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237, 50-249, 50-254, and 50-265 Request for Additional cc w/encl: Distribution via Listserv DISTRIBUTION: | The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on September 21,2010, it was agreed that you would provide a response by October 12, 2010. | ||
PUBLIC LPL3-2 RlF RidsNrrDorlLpl3-2 Resource RidsNrrPMDresden Resource | The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1055. | ||
Sincerely, IRA! | |||
Christopher Gratton, Senior Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237, 50-249, 50-254, and 50-265 | |||
==Enclosure:== | |||
Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION: | |||
PUBLIC LPL3-2 RlF RidsNrrDorlLpl3-2 Resource RidsNrrPMDresden Resource RidsNrrLATHarris Resource RidsOgcRp Resource RidsAcrsAcnw_MailCTR Resource MBlumberg, NRR KDesai, NRR RidsRgn3MailCenter Resource RidsNrrDoriDpr Resource AHowe, NRR JGall, NRR ADAMS Accession No.: ML102660195 NRR-088 LPL3,-2/F)M I LPL3-2/LA -2/BC LPL3-2/PM NAME CGratton THarris/BTully fo Ison CGratton DATE 9/23/10 9/23/10 9/23/10 OFFICIAL RECORD COpy}} |
Latest revision as of 19:21, 11 March 2020
ML102660195 | |
Person / Time | |
---|---|
Site: | Dresden, Quad Cities ![]() |
Issue date: | 09/23/2010 |
From: | Gratton C Plant Licensing Branch III |
To: | Pacilio M Exelon Nuclear |
Gratton C, NRR/DORL/LPL3-2, 415-1055 | |
References | |
TAC ME2567, TAC ME2568, TAC ME2569, TAC ME2570 | |
Download: ML102660195 (5) | |
Text
~~R REGlI{ UNITED STATES
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~0 WASHINGTON, D.C. 20555-0001
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September 23, 2010
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- i' Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555 SUB..IECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3, AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO EXELON GENERATION COMPANY'S REQUEST TO AMEND STANDBY LIQUID CONTROL TECHNICAL SPECIFICATIONS (TAC NOS. ME2567 THRU ME2670)
Dear Mr. Pacilio:
By letter to the Nuclear Regulatory Commission (NRC) dated November 10, 2009, Exelon Generation Company, LLC submitted a request to amend the technical specifications (TSs) to extend the completion time for Condition B of TS 3.1.7 from 8 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the Dresden, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2.
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on September 21, 2010, it was agreed that you would provide a response by October 12,2010.
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1055.
Christopher Gratton, Senior Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237, 50-249, 50-254, and 50-265
Enclosure:
Request for Additional Information cc w/encl: Distribution via Listserv
REQUEST FOR ADDITIONAL INFORMATION DRESDEN NUCLEAR POWER STATION, UNITS 1 AND 2 AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. 50-237, 50-249, 50-254, AND 50-265 In reviewing the Exelon Generation Company's (EGC's) submittal dated November 10, 2009 (Agencywide Documents Access and Management System Accession No. ML093140516),
related to your request to amend Technical Specification (TS) 3.1.7, "Standby Liquid Control (SLC) System," for the Dresden Nuclear Power Station (DNPS), Units 1 and 2, and Quad Cities Nuclear Power Station (QCNPS), Units 1 and 2, the NRC staff has determined that the following information is needed in order to complete its review:
Question 1 Identify adequate defense-in-depth for mitigation of anticipated transient without scram (ATWS) events for the extended 72-hour completion time period.
The SLC system mitigates an ATWS event by delivering a concentrated borated solution to the reactor pressure vessel to shutdown the reactor. The TS Required Action being modified addresses the condition where both SLC trains are inoperable. In the event of an ATWS during this condition, there is no system available to inject concentrated borated solution into the reactor pressure vessel in a timely manner to achieve shutdown. The licensee submittal addresses the low probability of an ATWS event due to the reliability and diversity of the control rods, and also discusses the recirculation pump trip feature which reduces reactor power.
However, there is no mechanism identified to assure safe shutdown to subcritical conditions as normally ensured by the operation of one of the two SLC trains.
Question 2 Clarify the intended reliance on emergency operating procedure (EOP) actions as an alternate means of boration and provide evaluations that justify any credited actions related to the requirements of Title 10 of the Code of Federal Regulations, Section 50.67, "Accident source term," as appropriate.
Page 17 of 19 of Attachment 1 states the following:
By letter dated October 10, 2002, EGC requested an amendment to the DNPS and QCNPS TSs regarding the adoption of an alternate source term (AST) methodology. The [Nuclear Regulatory Commission] NRC approved the requested license amendment by letter and safety evaluation (SE) dated September 11, 2006. As part of the proposed [alternate source term] AST methodology, EGC proposed the use of the SLC system to inject sodium Enclosure
-2 pentaborate into the [reactor pressure vessel] RPV following a [Ioss-of-coolant accident] LOCA in order to maintain suppression pool pH above 7 (Le., In order to ensure against re-evolution of elemental iodine). As such, the SLC is required to be operable in Mode 3 to ensure that offsite doses remain within the limits of 10 CFR 50.67, "Accident source term" following a loss-of-coolant accident (LOCA) involving significant fission product releases. However, additional redundancy for the control of suppression pool pH control following a LOCA is established by the DNPS and QCNPS Emergency Operating Procedures (EOPs).
The EOPs describe the actions and criteria for manual addition of boron into the condensate systems, should [reactor protection system] RPS, control rods, the control rod drive system, and the SLC be unable to perform the specifed [sic]
design functions. Therefore, the proposed SLC [completion time] CT extension will not impact the ability of DNPS and QCNPS to comply with the requirements of 10 CFR 50.67.
The license amendment request (LAR) describes alternative means for boration as additional redundancy in support of defense-in-depth measures to justify the proposed extension of the TS 3.1.7 completion time. These alternative means of boration consist of actions in the EOPs.
Page 4 of Attachment 1 of the LAR states that the SLC system is required to be operable to ensure that offsite doses remain within 10 CFR 50.67 limits following a LOCA. The SLC system is credited for maintaining pH balance in the suppression pool at or above 7 following a LOCA to ensure that iodine will be retained in the suppression pool.
The NRC staff has identified that the proposed alternate means of boration are not currently included in the DNPS and QCNPS licensing basis. The LAR indicates that the licensees intend to credit the referenced EOP actions as an alternate boration pathway to meet the requirements of 10 CFR 50.67. If so, then additional justification is required to support reliance on these actions as a credited alternate boration pathway. The NRC document "Guidance on the Assessment of a BWR [boiling-water reactor] SLC System for pH Control," dated February 12, 2004 (ADAMS Accession No. ML040640364) provides an approach that is acceptable to the NRC staff for evaluating the alternative controls of the suppression pool pH against appropriate methodologies.
If Exelon's intent is not to credit a new alternate boration pathway, then clarification is needed regarding the use of the EOP actions as an alternative means of boration with respect to defense-in-depth as related to 10 CFR 50.67. Please provide the following information:
- 1) Does the alternate injection path require actions in areas outside the control room?
- 2) Confirm that these areas will be accessible during the design basis accidents in your licensing bases (LOCA, Main Steamline Break etc.)?
- 3) What additional personnel will be required?
- 4) Confirm that these actions can be completed within a timeframe consistent the current licensing basis.
- 3 Question 3 Please demonstrate how General Design Criteria (GDC) 26, "Protection Systems Fail-Safe Design," and GDC 27, "Redundancy of Reactivity Control," regulatory requirements are met during the requested extended outage time for both trains of SLC inoperable.
Question 4 The Notices of Enforcement Discretion (NOEDs) referenced in the application provide lists of compensatory actions and additional committed actions. The NRC's basis for the NOEDs considered the compensatory measures to reduce the probability of a plant transient while ensuring the availability of other safety related equipment. Please describe how each compensatory action is addressed in the proposed change or demonstrate why it is not necessary. (Compensatory actions: 1) both ATWS recirculation pump trip systems would be protected, 2} the reactor protection system (RPS) would be protected, and 3) all production risk activities would be prohibited)
September 23, 2010 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville,IL 60555 SUB~IECT: DRESDEN NUCLEAR POWER STATION, UNITS 2 AND 3, AND QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION RELATED TO EXELON GENERATION COMPANY'S REQUEST TO AMEND STANDBY LIQUID CONTROL TECHNICAL SPECIFICATIONS (TAC NOS. ME2567 THRU ME2670)
Dear Mr. Pacilio:
By letter to the Nuclear Regulatory Commission (NRC) dated November 10, 2009, Exelon Generation Company, LLC submitted a request to amend the technical specifications (TSs) to extend the completion time for Condition B of TS 3.1.7 from 8 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for the Dresden, Units 2 and 3, and Quad Cities Nuclear Power Station, Units 1 and 2.
The NRC staff is reviewing your submittal and has determined that additional information is required to complete the review. The specific information requested is addressed in the enclosure to this letter. During a discussion with your staff on September 21,2010, it was agreed that you would provide a response by October 12, 2010.
The NRC staff considers that timely responses to requests for additional information help ensure sufficient time is available for staff review and contribute toward the NRC's goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please contact me at (301) 415-1055.
Sincerely, IRA!
Christopher Gratton, Senior Project Manager Plant Licensing Branch 111-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-237, 50-249, 50-254, and 50-265
Enclosure:
Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION:
PUBLIC LPL3-2 RlF RidsNrrDorlLpl3-2 Resource RidsNrrPMDresden Resource RidsNrrLATHarris Resource RidsOgcRp Resource RidsAcrsAcnw_MailCTR Resource MBlumberg, NRR KDesai, NRR RidsRgn3MailCenter Resource RidsNrrDoriDpr Resource AHowe, NRR JGall, NRR ADAMS Accession No.: ML102660195 NRR-088 LPL3,-2/F)M I LPL3-2/LA -2/BC LPL3-2/PM NAME CGratton THarris/BTully fo Ison CGratton DATE 9/23/10 9/23/10 9/23/10 OFFICIAL RECORD COpy