LIC-04-0107, Revised Generic Letter 2003-01, Control Room Habitability Commitments

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Revised Generic Letter 2003-01, Control Room Habitability Commitments
ML042790399
Person / Time
Site: Fort Calhoun Omaha Public Power District icon.png
Issue date: 10/05/2004
From: Phelps R
Omaha Public Power District
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-03-001, LIC-04-0107
Download: ML042790399 (3)


Text

Omaha Public Power District 444 South 16th Street Mall Omaha NE 68102-2247 October 5,2004 LIC-04-0107 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

References:

1. Docket No. 50-285
2. NRC Generic Letter 2003-01, Control Room Habitability, dated June 12,2003 (NRC-03-109)
3. Letter from OPPD (R. T. Ridenoure) to NRC (Document Control Desk) dated December 5, 2003, Response to Generic Letter 2003-01, Control Room Habitability (LIC-03-0150)

SUBJECT:

Revised Generic Letter 2003-01, Control Room Habitability Commitments This letter modifies and deletes commitments made in the Omaha Public Power District (OPPD) response (Reference 3) to Generic Letter 2003-0 1, Control Room Habitability (Reference 2). The commitments were related to a future license amendment request (LAR) revising the Fort Calhoun Station, Unit No. 1 (FCS) Technical Specifications (TSs) to incorporate changes proposed in Technical Specification Task Force (TSTF)-448, Control Room Habitability.

The first commitment noted in Reference 3 was to submit a LAR within 120 days of the NRCs best and final offer on TSTF-448. This terminology was suggested by the Nuclear Energy Institute (NEI) to licensees in order to expedite licensing action submittals without waiting for final NRC approval of TSTF-448. The phrase best and final offer is open to interpretation, especially in light of continuing discussion of significant TSTF-448 content, and lack of finalization and approval by the NRC. Therefore, OPPD is revising the commitment to state that OPPD will submit a LAR within 120 days of NRC approval of TSTF-448. This will enable OPPD to submit a LAR that more accurately reflects the approved TSTF, and will facilitate LAR review and approval for both OPPD and the NRC.

The second commitment in Reference 3 stated that OPPD would finalize the Standing Order SO-G-115, FCS Control Room Integrity Program prior to submittal of the LAR.

(TSTF-448 introduces a new specification requiring the establishment of a Control Room Integrity Program to ensure that control room integrity is maintained for radiological, toxic gas, and smoke events.) Based again on the lack of finalization for TSTF-448, this commitment is unnecessary and should be deleted.

The third and final commitment identified in Reference 3 was to implement the license amendment and SO-G-115 within the period requested in the LAR. This commitment is unnecessary and should be deleted, because amendment implementation is an established and required practice associated with all LARS.

Employment with Equal Opportunity

.~ -

U. S. Nuclear Regulatory Commission LIC-04-0107 Page 2 contains tables showing the original commitments made in Reference 3, and the revision and deletions described in this letter.

If you have any questions or require additional information, please contact Tom Matthews at (402) 533-6938.

Sincerely, R. L. Phelps J Division Manager Nuclear Engineering RLP/MLE/mle

Attachment:

Revised GL-2003-01 Response Commitments

LIC-04-0 107 Attachment Page 1 December 5,2003 (Original) OPPD GL 2003-01 Response Commitments No. Commitment Due Date Within 120 days of the NRCs best Submit CRH LAR,to include specific exceptions to RG 1 and final offer on 1.196/1.197and justification for the exceptions (AR 33774).

TSTF-448, Revision 1 Finalize SO-G-115, FCS Control Room Integrity Program, (AR Prior to Submittal 2

3 3 774). of CRH LAR Following NRC approval of CRH Implement CRH License Amendment & SO-G-115.

LAR & within 3

implementation period requested in CRH LAR October 5,2004 (Revised) OPPD GL-2003-01 Response Commitment n N ~ .I Commitment I DueDate Within 120 days of Submit CRH LAR to include specific exceptions to RG NRC approval of 1

1.196A.197 and justification for the exceptions. (AR 33774) TSTF-448

Text

Omaha Public Power District 444 South 16th Street Mall Omaha NE 68102-2247 October 5,2004 LIC-04-0107 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555

References:

1. Docket No. 50-285
2. NRC Generic Letter 2003-01, Control Room Habitability, dated June 12,2003 (NRC-03-109)
3. Letter from OPPD (R. T. Ridenoure) to NRC (Document Control Desk) dated December 5, 2003, Response to Generic Letter 2003-01, Control Room Habitability (LIC-03-0150)

SUBJECT:

Revised Generic Letter 2003-01, Control Room Habitability Commitments This letter modifies and deletes commitments made in the Omaha Public Power District (OPPD) response (Reference 3) to Generic Letter 2003-0 1, Control Room Habitability (Reference 2). The commitments were related to a future license amendment request (LAR) revising the Fort Calhoun Station, Unit No. 1 (FCS) Technical Specifications (TSs) to incorporate changes proposed in Technical Specification Task Force (TSTF)-448, Control Room Habitability.

The first commitment noted in Reference 3 was to submit a LAR within 120 days of the NRCs best and final offer on TSTF-448. This terminology was suggested by the Nuclear Energy Institute (NEI) to licensees in order to expedite licensing action submittals without waiting for final NRC approval of TSTF-448. The phrase best and final offer is open to interpretation, especially in light of continuing discussion of significant TSTF-448 content, and lack of finalization and approval by the NRC. Therefore, OPPD is revising the commitment to state that OPPD will submit a LAR within 120 days of NRC approval of TSTF-448. This will enable OPPD to submit a LAR that more accurately reflects the approved TSTF, and will facilitate LAR review and approval for both OPPD and the NRC.

The second commitment in Reference 3 stated that OPPD would finalize the Standing Order SO-G-115, FCS Control Room Integrity Program prior to submittal of the LAR.

(TSTF-448 introduces a new specification requiring the establishment of a Control Room Integrity Program to ensure that control room integrity is maintained for radiological, toxic gas, and smoke events.) Based again on the lack of finalization for TSTF-448, this commitment is unnecessary and should be deleted.

The third and final commitment identified in Reference 3 was to implement the license amendment and SO-G-115 within the period requested in the LAR. This commitment is unnecessary and should be deleted, because amendment implementation is an established and required practice associated with all LARS.

Employment with Equal Opportunity

.~ -

U. S. Nuclear Regulatory Commission LIC-04-0107 Page 2 contains tables showing the original commitments made in Reference 3, and the revision and deletions described in this letter.

If you have any questions or require additional information, please contact Tom Matthews at (402) 533-6938.

Sincerely, R. L. Phelps J Division Manager Nuclear Engineering RLP/MLE/mle

Attachment:

Revised GL-2003-01 Response Commitments

LIC-04-0 107 Attachment Page 1 December 5,2003 (Original) OPPD GL 2003-01 Response Commitments No. Commitment Due Date Within 120 days of the NRCs best Submit CRH LAR,to include specific exceptions to RG 1 and final offer on 1.196/1.197and justification for the exceptions (AR 33774).

TSTF-448, Revision 1 Finalize SO-G-115, FCS Control Room Integrity Program, (AR Prior to Submittal 2

3 3 774). of CRH LAR Following NRC approval of CRH Implement CRH License Amendment & SO-G-115.

LAR & within 3

implementation period requested in CRH LAR October 5,2004 (Revised) OPPD GL-2003-01 Response Commitment n N ~ .I Commitment I DueDate Within 120 days of Submit CRH LAR to include specific exceptions to RG NRC approval of 1

1.196A.197 and justification for the exceptions. (AR 33774) TSTF-448