SVPLTR 08-0014, Response to Non-Cited Violations, 05000237-08-007 and 05000249-08-007

Response to Non-Cited Violations, 05000237-08-007 and 05000249-08-007

ML080670201
Person / Time
Site:	Dresden
Issue date:	02/29/2008
From:	Wozniak D Exelon Generation Co, Exelon Nuclear
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
SVPLTR: #08-0014
Download: ML080670201 (10)

Text

Exek~n,.

Exeloni Generation Company, LLC Dresden Nuclear Power Station 6500 North Dresden Road Morris, I L 60450-9765 www.exelonCOTP.COM Nuclear February 29, 2008 SVPLTR: #08-0014 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555-0001 1 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-1 9 and DPR-25 Docket Nos. 50-237 and 50-249

Subject:

Response to NCV 05000237(249)/2008007-0 1

Reference:

Letter from J. Lara (NRC) to C. Pardee (Exelon Generation Company, LLC), "NRC Inspection Report 05000237(249)/2008007," dated January 17, 2008 In the referenced letter, the NRC identified two findings and associated non-cited violations (NCVs) at Dresden Nuclear Power Station (DNPS) of very low safety significance (Green).

The second finding and associated NCV referenced in your inspection report, (i.e., NOV 05000237(249)/2008007-02 was reviewed by Exelon. Generation Company, LLC (EGC). EGC admits the basis for the violation. As such, EGC has placed the issue within the corrective action program and has made appropriate changes to the Technical Specification Bases and the emergency diesel generator (EDG) test procedure. All corrective actions associated with this NCV, including performance of the revised 24-hour endurance run on the three EDGs, have been completed.

However, in accordance with 10 CFR 2.201, "Notice of violation," EGC is contesting the first finding and associated NCV. Specifically, EGC is contesting NCV 05000237(249)/2008007-01, "Failure to Perform a 10 CFR 50.59 Evaluation for Exceeding Continuous Rating on the EDG."

The basis for contesting this finding is provided as an attachment to this letter. This response is being provided in accordance with discussions between EGC (i.e.,, D. Benyak) and NRC Region III (i.e., S. West) on February 14, 2008 and February 21, 2008.

U. S. Nuclear Regulatory Commission February 29, 2008 Page 2 of 2 EGO is contesting the NOV since it establishes the requirement for prior NRC approval if the DNPS EDG predicted loads exceed the EDG continuous rating of 2600 kW. As described in the attachment, this is contrary to the DNPS licensing basis that has been submitted to and accepted by the NRC on a number of occasions. This NRC-accepted licensing basis confirms that the long-term total load of the DNPS EDGs would exceed the continuous rating of 2600 kW, and EDG testing would be conducted at loads less than the predicted design basis peak loads.

The conclusions drawn by the NRC in the referenced Inspection Report constitute a significant revision of the DNPS licensing basis, absent the required backfit analysis, in accordance with the provisions of 10 CFR 50.109, "Backfitting."

If you have any questions regarding this response, please contact Mr. James D. Ellis, Regulatory Assurance Manager, at (815) 416-2800.

Respectfully,

,David B. Wozniak4 Site Vice President Dresden Nuclear Power Station

Attachment:

Response to NOV 05000237(249)/2008007-01 cc: Regional Administrator-NRC Region Ill NRC Senior Resident Inspector -

Dresden Nuclear Power Station Director, Office of Enforcement, NRC

Attachment Response to NCV 05000237(249)/2008007-01 Contested Violation Inspection Report 05000237/2008007; 05000249/2008007 (i.e., Reference 1) identified the following violation:

"The inspectors identified a Severity Level IV NOV associated with the failure to perform a safety evaluation in accordance with 10 CFR 50.59. Specifically, the licensee failed to perform a safety evaluation when non-conservatively changing the design basis loading for the emergency diesel generators (EDG) in the design calculation. This resulted in the expected loading during a design basis accident no longer being bounded by the EDG endurance testing requirements contained in the Technical Specifications (TS). Because the licensee did not also evaluate the effect on the existing endurance test loading requirements, the testing no longer adequately verified the capability of the EDG to power its predicted loading during a LOOP/LOCA. This adverse change increased the probability of a malfunction of equipment important to safety EDG during a LOOP/LOCA event."

Exelon Generation Company, ILLC Position Exelon Generation Company, LLO (EGO) has identified that the NRC-approved Dresden Nuclear Power Station (DNPS) licensing basis for EDG loading is that:

1) Auto-connected loads will remain below the continuous load rating of 2600 kW; and

2) Total loads, both auto-connected and manual, will remain below the 2000-hour rating of 2860 kW.

EGO also has identified that the NRC-approved DNPS licensing basis for the 24-hour EDG endurance test is to demonstrate full-load-carrying capability (i.e., the continuous rating) for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, of which 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> are at a load equal to 105% to 110% of the EDG continuous rating, and 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> are at a load equal to 90% to 100% of the EDG continuous rating.

Given this NRC-approved DNPS licensing basis for EDG loading and testing, the design change in 1994 that is cited in the violation was bounded by this licensing basis, and thus did not require a 10 CFR 50.59 evaluation. Therefore, the violation is not justified.

The discussion below describes the basis for EGO's conclusion regarding the DNPS licensing basis for EDG loading and testing. This includes:

" A description of the original licensing basis as defined in the Safety Analysis Report (SAR) and associated Amendments, and the original Atomic Energy Commission (AEC) Safety Evaluation Report (SER).

" A description of the NRO confirmation of the DNPS licensing basis for EDG loading and testing as part of the Systematic Evaluation Program (SEP).

" A description of the DNPS licensing basis for EDG loading and testing that was submitted and approved by the NRC as part of both the 1995 Technical Specification Page 1 of 8

Attachment Response to NCV 05000237(249)/2008007-01 Upgrade Program (TSUP) and the 2001 Improved Technical Specification (ITS)

Conversion program (i.e., the adoption of the NUREG-1433 ITS).

A discussion addressing the NRC's conclusions in the Inspection Report concerning the regulatory requirements for EDG testing that are applicable to DNPS.

The information provided below is consistent with the information previously provided in June 2006 to both NRR and Region III personnel.

Background

On June 19, 2002, the NRC issued an inspection report (i.e., Reference 2) to document results of a Triennial Fire Protection inspection at DNPS. In the inspection report, unresolved issue (URI) 05000237(249)/2002006-02 was opened. The inspection report stated that because of recent changes to the predicted loads in the EDG loading calculation, the revised loss of offsite power/loss-of-coolant accident (LOOP/LOCA) predicted loads exceeded the EDG continuous load rating. The NRR evaluation of this URI is documented in NRC Task Interface Agreement (TIA) 2005-009 (i.e., Reference 3).

Initial Licensing - DINPS Safety Analysis Report The DNPS SAR was developed in the late-1960s to support initial licensing of IDNPS. The original design of the EIDGs required that the auto-connected loads (i.e., the loads that are automatically sequenced to the EDG following a design basis event) to be less than the EDG's continuous rating of 2600 kW1.

The long-term loads, such as those that are required to support containment cooling, include manual loads such as Containment Cooling Service Water (CCSW) pumps. The SAR indicated that the EDG could be manually loaded to its rated capacity (i.e., 2860 kW) at the discretion of the operator. Figure 8.2.3 of the SAR identifies the starting of CCSW pumps as manual actions, and the figure indicates that starting two CCSW pumps will increase EDG load to 2720 kW, which exceeds the EDG continuous rating, but is well within the 2000-hour rating of 2860 kW.

In 1969, in response to AEC questions, Commonwealth Edison (i.e., the predecessor to EGC, and the original licensee) provided additional information in Amendments 11 and 12 to the SAR regarding EDG sizing and testing.

The applicable AEC question stated:

"Provide an analysis to show that the diesel generator system can automatically and/or manually accept engineered safety feature loads at any point during a DBA and sustain the loss of the largest load during initial loading or at any time during the accident. Submit the 1At DNPS, the original EIDG continuous rating, as documented in the SAR, was 2500 kW and the original 2000-hour rating was 2850 kW. Both ratings were subsequently raised by the EIDG manufacturer to 2600 kW and 2860 kW, respectively.

Page 2 of 8

Attachment Response to NCV 05000237(249)12008007-01 diesel generator overload ratings recommended by the manufacturer and show that your design has adequate margin for all anticipated load conditions."

Commonwealth Edison's response stated, in part:

"The diesel-generator is rated at 2850 kW continuous for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> per year and an overload of 3100 kW. As can be seen by Table 8.2.1 of the FSAR, the normal load will not be near the 2850 kW rating which provides more than adequate margin without the overload condition."

The AEC raised no further questions on the EDGs, and issued SERs for DNPS Units 2 and 3 in 1969 and 1970. In the Unit 2 SER, the AEC concluded:

"Each diesel generator is housed in a separate Class I area and has adequate capacity for emergency loads and/or shutdown loads for one unit. The diesel generators are each rated for continuous service at 2500 kW. The automatically energized loads total 1950 kW."

The Unit 3 SER did not amend this conclusion. Therefore, this statement in the SER, in concert with the information in the SAR and Amendments, confirms that the AEC recognized and accepted that the auto-connected post-accident EDG loads were less than the continuous rating, and the long-term post-accident EDG loads were greater than the EDG continuous rating, but within the 2000-hour rating.

Therefore, the original NRC-approved licensing basis for the DNPS EDGs was that the auto-connected loads would be maintained below the continuous rating and that the total required load for safe shutdown would be maintained below the 2000-hour rating. It should also be noted that the original EDG sizing in the SAR and SERs predated both Regulatory Guides (RGs) and Safety Guides, and therefore RGs and Safety Guides were not part of the original licensing basis for EDG sizing and testing.

Systematic Evaluation Program (SEP)

The NRC evaluated the DNPS EDG loading as a part of a1981 review for SEP Topic VIII-2, "Onsite Emergency Power Systems - Diesel Generator." The EDG loading criterion used in SEP Topic VIII-2 to determine compliance with current regulatory requirements was based upon "Regulatory Guide 1.9, 'Selection of Diesel Generator Set Capacity for Standby Power Supplies'," (i.e., RG 1.9, Revision 2). Regulatory Position C.2 of this document states:

"At the operating license stage of review, the predicted loads should not exceed the short-time rating (as defined in Section 3.7.2 of IEEE Std 387-1977) of the diesel-generator unit."

IEEE Standard 387-1977, "IEEE Standard Criteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations," Section 3.7.2, defines short-time rating as "the electric power output capability that the diesel-generator unit can maintain in the service environment for 2 h[our] in any 24 h[our] period, without exceeding the manufacturer's design limits and without reducing the maintenance interval for the continuous rating." The short-time rating is considered the 2000-hour rating of an EDG, as described by the EDG vendor. This definition is also confirmed in Section 3.7.1 of the IEEE Standard, which defines continuous rating as a different electric output capability (i.e., "the electric power output Page 3 of 8

Attachment Response to NCV 05000237(249)/2008007-01 capability that the diesel-generator unit can maintain in the service environment for 8760 h[our]

of operation per (common) year with only scheduled outages for maintenance").

In the Technical Evaluation for the SEP VIII-2 review (i.e., Reference 4), the NRC confirmed that the DNPS EIDG loading satisfied the requirements of RG 1.9 (i.e., Revision 2), based on the fact that the total auto-connected load was less than the continuous rating of the diesel generators.

"The 2000-hour rating of the diesel generators is 2860 KW at 0.8 power factor. Therefore, the total automatically connected diesel generator loads (at 70% of generator capacity) are within the requirements of Regulatory Guide 1.9."

This confirmation of the IDNPS licensing basis for EIDG loading was reiterated by the NRC in the conclusion of the SEP Technical Evaluation for the topic:

"Automatic diesel generator loading is in compliance with the current licensing criteria."

These conclusions confirm the NRC acceptance of the original licensing basis of the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating as an upper bound design limit on EIDG loading, that is, auto-connected and manually-connected loads would be less than 2860 kW.

TSUP Conversion In the mid 1990s, Commonwealth Edison Company submitted and the NRC approved changes to the DINPS EDG testing requirements as part of TSUP. This project adopted the NUREG-0123 Standard Technical Specifications (i.e., the predecessor to the Improved Technical Specifications that were promulgated in NUREG-1 433, "Standard Technical Specifications, General Electric Plants, BWRI4"). Prior to TSUP, the IDNPS Technical Specifications (TS) did not require a 24-hour EIDG endurance test. The NRC approved the IDNPS TSUP section for EIDG testing in a letter dated September 18,1995 (i.e., Reference 5).

TSUP SR 4.9.8.h required DINPS to perform the 24-hour EIDG endurance test. The SR specified that during the first two hours the EIDG would be loaded to between 2730 and 2860 kW (i.e., 105% to 110% of continuous rating) and for the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> the EIDG be loaded to between 2470 and 2600 kW (i.e., 90% to 100% of continuous rating).

TSUP Bases 3/4.9.A stated that the SRs are "based on the guidance provided in Regulatory Guide 1.9, draft Revision 3 (i.e., 1/1 999), Regulatory Guide 1. 108, Revision 1, and Regulatory Guide 1. 137, Revision 1, as modified by plant specific analysis, diesel generator manufacturer/vendor recommendations and responses to Generic Letter 84-15."

In the TSUP program, Commonwealth Edison Company did not, nor could not commit to the sizing requirements of RG 1.9, Revision 3. These requirements state that, at the operating licensing stage of review, the predicted loads should not exceed the continuous rating. Since this condition is not consistent with the original NRC-approved DNPS licensing basis, as confirmed by the NRC's SEP review, this sizing requirement is not applicable to the IDNPS EDGs.

With respect to EIDG testing, the referenced regulatory documents do not require, nor refer to the premise that the EIDG endurance test acceptance criteria must bound the accident load profile. RG 1.9, Revision 3, Section 2.0, "Testing," subsection 2.2.9, "Endurance and Margin Test," states:

Page 4 of 8

Attachment Response to NCV 05000237(249)/2008007-01 "Demonstrate full-load carrying capability at a power factor between 0.8 and 0.9 for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, of which 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> are at a load equal to 105 to 110 percent of the continuous rating of the emergency diesel generator, and 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> are at a load equal to 90 to 100 percent of its continuous rating. Verify that voltage and frequency requirements are maintained."

RG 1.108, Revision 1, "Periodic Testing of Diesel Generator Units Used as On-site Electric Power Systems at Nuclear Power Plants," Regulatory Position C.2.a.(3), states:

"Demonstrate full-load-carrying capability for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, of which 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> should be at a load equivalent to the continuous rating of the diesel generator and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at a load equivalent to the 2-hour rating of the diesel generator."

The 2-hour rating is defined in IEEE Standard 387-1977, as discussed above, and is considered the 2000-hour rating of the EDG.

The "full-load-carrying capability" in Regulatory Position C.2.a (3) is clarified even further in Regulatory Position C.2.c (2) of RG 1. 108, Revision 1 (i.e., the requirement for periodic EDG testing during normal plant operation). This requirement explicitly describes "full-load-carrying capability" as "continuous rating."

The explicit EDG 24-hour endurance run requirements in RG 1. 108, Revision 1, is also consistent with the testing requirement of RG 1.9, Revision 3, Regulatory Position C.2.2.9, "Endurance and Margin Test."

In summary, neither RG 1. 108, Revision 1, nor RG 1.9, Revision 3 specify any explicit or implicit requirements establish the acceptance criterion for the 24-hour EDG endurance test at a value that bounds the peak accident load for the EDG. EGO has not identified any regulatory requirement or regulatory guidance document, prior to the March 2007 issuance of Revision 4 to RG 1.9 that states this postulated regulatory requirement. In fact, RG 1.9 Revision 4 only states this as a requirement in Regulatory Position 2.2.4, "Rated Load Test," which describes the monthly EDG surveillance test.

Therefore, in the Safety Evaluation (SE ) for TSUP Section 3.9/4.9, the NRC approved SR 4.9.8.h with testing requirements unrelated to expected loads, but as a percentage of the continuous rating, which was consistent with regulatory guidance and industry practice at the time.

ITS Conversion In Reference 6, EGO submitted a license amendment request to convert the DNPS TS to the NUREG-1 433 ITS. As part of that conversion request, EGO once again referenced RG 1.9, Revision 3 and RG 1. 108, Revision 1 in the TS SR Bases as the basis for EDG SRs:

"The SRs for demonstrating the OPERABILITY of the DGs are consistent with the recommendations of Regulatory Guide 1.9 (Ref. 8) [i.e., Revision 3], Regulatory Guide

1. 108 (Ref. 9) [i.e., Revision 1 ], and Regulatory Guide 1. 137 (Ref. 10) [Revision 1 ], as addressed in the UFSAR."

Page 5 of 8

Attachment Response to NCV 05000237(249)/2008007-01 Similar to TSUP, EGO did not, nor could not commit to the sizing requirements of RG 1.9, Revision 3. Therefore, the current licensing basis for the SR acceptance criteria is based on is unchanged from that submitted and approved during the TSUP conversion, i.e., the continuous rating and 2000-hour rating of the EDG, not the accident load profile.

In addition, NUREG 1433, "Standard Technical Specifications, General Electric Plants, BWRI4,"

does not, nor did it at the time, include a requirement to bound the peak kW accident load with the 24-hour EDG endurance run.

With respect to the 24-hour EDG endurance test, NUREG-1 433 Bases section B 3.8. 1, SR 3.8.1.14, states:

"Regulatory Guide 1.108 (Ref. 9), paragraph 2.a.(3), requires demonstration once per [18 months] that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> - 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of which is at a load equivalent to the continuous rating of the DG, and 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of which is at a load equivalent to 110% of the continuous duty rating of the IDG."

Therefore, in the SE for ITS Section 3.8 the NRC approved SR 3.8.1.13 with testing requirements unrelated to expected loads, but as a percentage of the continuous rating, which was consistent with regulatory guidance and industry practice at the time.

TIA 2005-009, Revision 1 The referenced TIA was issued on July 11, 2007. The NRC staff positions stated within the TIA dealt with testing of the EDG. The relevant position is stated below:

"The current EDG endurance test performed by DNPS, at 2340 to 2600 kiloWatts (kW) for 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> and 2730 to 2860 kW for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, is not consistent with the intent of the technical specification (TS) surveillance requirement (SR) for establishing the operability of the EDGs. The current test, does not envelop the actual power demand requirement for the EDG during design-basis conditions. The licensee should submit an amendment request to modify the non-conservative TS SR."

The NRC referenced RG 1.9, Revision 3, in reviewing this issue and in particular Regulatory Position 0.1.5: "At the operating license stage of review, the predicted loads should not exceed the continuous rating of the diesel generator unit." The application of this Regulatory Position is incomplete with respect to the original NRC-approved DNPS licensing basis, as confirmed by the NRC in the subsequent SEP topic review. Therefore, the application of this Regulatory Position to the DNPS EDG testing requirement is incorrect.

As documented above, while the IDNPS licensing basis for EDG testing is RG 1.9, Revision 3 and RG 1.108, Revision 1 (i.e., as committed to in the TSUP and ITS Conversion projects), the licensing basis for EDG sizing was established by the original SAR and Amendments, and the original SER. The NRC's review of SEP Topic VIII-2 confirmed the NRC acceptance of the original licensing basis that total EDG loading (i.e., auto-connected and manual ly-con nected loads) would exceed the continuous rating, but would be less than the 2000-hour rating of 2860 kW.

Page 6 of 8

Attachment Response to NCV 05000237(249)/2008007-01 Since the DNPS licensing basis for EDG sizing is not RG 1.9, Revision 3, the intent of the TS SIR is established by Regulatory Position C.2.a (3) of RG 1. 108, Revision 1, which establishes testing requirements as a percentage of the continuous rating.

Purpose of DNPS EDG Surveillance Requirements In the Reference 1 Inspection Report, the NRC stated the following as one of the premises for the violation:

"Based upon the above considerations, as well as a review of pertinent regulatory guidance documents, the inspectors concluded that the surveillance test loading should bound the accident loading."

EGO disagrees with this premise. The current NRC-approved DNPS licensing basis for EDG testing explicitly commits DNPS to the requirements of RG 1. 108, Revision 1, RG 1.9, Revision 3 as described in the DNPS TS Bases, which are consistent with the NUREG-1 433 Bases.

None of these regulatory documents specify any requirement to establish the acceptance criterion for the 24-hour EDG endurance test at a value that bounds the peak accident load for the EDG.

In addition, EGO has not identified any other regulatory requirement or regulatory guidance document, prior to the March 2007 issuance of Revision 4 to Regulatory Guide 1.9 that explicitly states this postulated regulatory requirement. In fact,, RG 1.9, Revision 4 only states this as a requirement in Regulatory Position 2.2.4, "Rated Load Test," which describes the monthly EDG surveillance test. The establishment of this requirement has been specifically excluded from Regulatory Position 2.2.9, "Endurance and Load Margin Test."

Conclusion EGO asserts that the relevant licensing history demonstrates that the NRC reviewed and approved the DNPS licensing basis for EDG sizing, such that EDG loading could exceed its continuous rating and the total load, including manual loads added by the operator, would not exceed the 2000-hour rating of 2860 kW. Based on this criterion, the results of the January 1994 engineering calculation (i.e., CaIc. No. 731 7-33-1 9-2, "Diesel Generator Loading Under Design Basis Accident Condition," Rev. 18) described in Reference 1 that revised the total manual loading of the EDG to greater than the continuous duty rating was within the NRC approved licensing basis. Therefore, this change did not require a 10 CER 50.59 evaluation, since the total calculated load (i.e., 2655.9 kW) did not exceed the 2000-hour rating of 2860 kW. As such, there was not a violation of 10 CFR 50.59.

The NRC has also incorrectly concluded that the 24-hour EDG endurance test in the DNPS TS exists to demonstrate the EDGsý can meet the actual peak accident load requirements. As stated above, the NRC-approved DNPS licensing basis establishes a test acceptance criterion that is a percentage of the continuous duty rating.

Therefore, the stated NRC basis for NOV 05000237(249)/2008007-01 does not support or justify the violation. As such, EGO requests that the NRC withdraw the violation.

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Attachment Response to NCV 05000237(249)/2008007-01 References

1.

Letter from J. Lara (NRC) to C. Pardee (Exelon Generation Company, LLC), "NRC Inspection Report 05000237/2008007; 05000249/2008007," dated January 17, 2008

2.

Letter from J. A. Grobe (NRC) to J. L. Skolds (Exelon Generation Company, LLC),

"Dresden Nuclear Power Station NRC Inspection Report 50-237/02-06(DRS); 50-249102-06(DRS)," dated June 19, 2002

3.

Memorandum from M. J. Case (NRR) to C. D. Pederson (NRC Region Ill), "Staff Response to TIA 2005-009 Regarding Emergency Diesel Generator Testing, Revision 1, (TAC No. MD 3715)," dated July 11, 2007

4.

Letter from D. M. Crutchfield (NRC) to J. S. Abel (Commonwealth Edison Company),

"SEP Topic VIII-2, Diesel Generators (Dresden Unit 2)," dated June 12, 1981

5.

Letter from J. F. Stang (.NRC) to D. L. Farrar (Commonwealth Edison Company),

"Issuance of Amendments Related to TSUP Section 3/4.9 (TAC Nos. M86743, M86744, M86745 and M86746)," dated September 18, 1995 6

Letter from R. M. Krich, (Commonwealth Edison Company) to NRC, "Request for Technical Specifications Changes for Dresden Nuclear Power Station, Units 2 and 3, LaSalle County Station, Units 1 and 2, and Quad Cities Nuclear Power Station, Units 1 and 2, to Convert to Improved Standard Technical Specifications," dated March 3, 2000 Page 8 of 8