LIC-16-0001, Response to NRC Request for Additional Information Technical Specification Administrative Changes

Response to NRC Request for Additional Information Technical Specification Administrative Changes

ML16032A220
Person / Time
Site:	Fort Calhoun
Issue date:	01/27/2016
From:	Marik S Omaha Public Power District
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
CAC MF6645, LIC-16-0001
Download: ML16032A220 (2)

Text

LIC-16-0001 January 27, 2016 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Fort Calhoun Station (FCS), Unit 1 Renewed Facility Operating license No. DPR-40 NRC Docket No. 50-285

Subject:

Response to NRC Request for Additional Information RE: Technical Specification Administrative Changes (CAC No. MF6645)

References:

1. Letter from OPPD (L. P. Cortopassi) to NRC (Document Control Desk), "License Amendment Request (LAR) 15*04, Application to Revise Technical Specification for Administrative Changes," dated August 20, 2015 (LIC 0053) (ML15233A494)

2. Letter from NRC (C. F. Lyon) to OPPD (L. P. Cortopassi), *Fort Calhoun Station, Unit No. 1 - Request for Additional Information RE: Technical Specification Administrative Changes (CAC No. MF6645), n dated December 15, 2015 (NRC-15-105) (ML15343A108)

Attached is the Omaha Public Power District (OPPD) response to an NRC request for additional information (RAI) (Reference 2) regarding License Amendment Request (LAR) 15-04 (Reference 1), which proposed administrative changes to the Fort Calhoun Station, Unit No. 1, Technical Specifications.

This letter contains no regulatory commitments.

lf you should have any questions regarding this submittal or require additional information, please contact Mr. Brad Blome at 402-533-7270.

YiffitJ Shane M. Marik Site Vice President and CNO SMM/BRH/mle

Attachment:

c: M. L. Dapas, NRC Regional Administrator, Region IV C. F. Lyon, NRC Senior Project Manager S. M. Schneider, NRC Senior Resident Inspector 444 SOUTH 16TH STREET MALL

• OMAHA, NE 68102-2247

LIC-16-0001 Attachment Page 1 REQUEST FOR ADDITIONAL INFORMATION LICENSE AMENDMENT REQUEST OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION. UNJT NO. 1 DOCKET NO. 50-285 By letter dated August 20, 2015 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML15233A494), Omaha Public Power District (the licensee) submitted a license amendment request to make administrative changes to the Technical Specifications for Fort Calhoun Station, Unit No. 1 (FCS).

The U.S. Nuclear Regulatory Commission staff has reviewed the information provided in the application and determined that additional information is required in order to complete its formal review of the request.

In its appllcation, the licensee proposed to add an allowance for a designee for the Manager Radiation Protection (MRP) to clarify that a designated alternate to the MRP may control keys to locked high radiation areas. The licensee stated that use of a designated altemate to the MRP is consistent with the guidance approved by the NRC staff In NUREG-1432, Standard Technical Specifications (STS). However, citing the STS as justification for the proposed change Is Insufficient, particularly since FCS does not have STS.

Please provide specific justification for the proposed change to add a designated alternate totheMRP.

OPPD Response As stated in OPPD's application, Fort Calhoun Station is implementing Exelon procedures and processes. Procedure RP-AA-460, "Controls for High and Locked High Radiation Areas" provides administrative and physical controls and instructions for access to high radiation areas and locked high radiation areas. Guidance for the issuance of keys to locked high radiation areas (LHRA) is detailed and comprehensive. The procedure states that padlocks and keys used for control of LHRAs are administered by Radiation Protection Supervision. RP-M-460 references NRC Regulatory Guide (RG) 8.38 "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants." As stated in RG 8.38, Regulatory Position C.2.6, <<Controls of Keys to High Radiation Areas:"

"The shift supervisor or radiation protection manager (or their respective designees) should administratively control the issuance of keys to, and return of keys by, personnel requiring access to high radiation areas.*

Thus, the proposed allowance for a designated alternate to the MRP to control keys to locked high radiation areas is consistent with RG 8.38, Regulatory Position C.2.6.