ML14247A586

Request for Additional Information Regarding License Amendment Request to Revise Snubber Surveillance Requirements (Tac No. MF4124)

ML14247A586
Person / Time
Site:	Oyster Creek
Issue date:	09/16/2014
From:	John Lamb Plant Licensing Branch 1
To:	Pacilio M Exelon Nuclear
Lamb J
References
TAC MF4124
Download: ML14247A586 (6)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 September 16,2014 Mr. Michael J. Pacilio President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION- REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO REVISE SNUBBER SURVEILLANCE REQUIREMENTS (TAC NO. MF4124)

Dear Mr. Pacilio:

By letter dated April 30, 2014 (Agencywide Documents Access and Management System Accession No. ML14127A435), Exelon Generation Company, LLC (Exelon) requested an amendment to the technical specifications (TS), Appendix A of Renewed Facility Operating License No. DPR-16, for Oyster Creek Nuclear Generating Station (OCNGS). The proposed amendment would revise OCNGS snubber surveillance requirements contained in TS 4.5.M, "Shock Suppressors (Snubbers)."

The U.S. Nuclear Regulatory Commission staff has reviewed the amendment request submitted by Exelon and determined that additional information is needed as set forth in the enclosure.

On August 14, 2014, the draft questions were sent to Mr. David Helker and Mr. Richard Gropp of your staff, to ensure that the questions were understandable, the regulatory basis for the questions was clear, and to determine if the information was previously docketed. On September 2, 2014, a conference call was held to clarify the questions. Mr. Gropp indicated that Exelon will submit a response by October 17, 2014.

M. Pacilio If you have any questions, please contact me at (301) 415-31 00 or via e-mail at John.Lamb@nrc.gov.

. Lamb, Senior Project Manager icensing Branch 1-2 Di 1 1on of Operating Reactor Licensing 0 i e of Nuclear Reactor Regulation Docket No. 50-219

Enclosure:

Request for Additional Information cc w/encl: Distribution via ListServ

REQUEST FOR ADDITIONAL INFORMATION REGARDING PROPOSED LICENSE AMENDMENT REQUEST CHANGES TO SNUBBER SURVEILLANCE REQUIREMENTS EXELON GENERATION COMPANY, LLC (EGC)

OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219 (TAC NO. MF4124)

By letter dated April 30, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14127A435), Exelon Generation Company, LLC (EGC or the licensee) submitted a license amendment request (LAR) for Oyster Creek Nuclear Generating Station. The proposed amendment would revise the Technical Specification (TS) requirements for snubbers to conform to planned revisions to the inservice inspection (lSI) program.

The Nuclear Regulatory Commission (NRC) staff has reviewed the information the licensee provided that supports the proposed LAR and have the following requests for additional information (RAI).

In Attachment 2, "Markup of Technical Specification Pages," the licensee deleted all the information related to Snubber Inspection Program, in TS 4.5.M Surveillance Requirements (SR), and added the Administrative Controls of "Snubber Inspection Program," under TS 4.5.M.1. The added details are from Insert 1 on TS Page 4.5-6 (details of Insert 1 is as specified on TS Page 4.5-18). Please specify and explain the reason to include Administrative Controls of "Snubber Inspection Program," in the TS 4.5.M instead of including it in TS Administrative Controls Section of TS 6.8. Alternatively, revise the markup to include the Administrative Controls of "Snubber Inspection Program" in TS Administrative Controls Section of TS 6.8.

In Attachment 2, "Markup of Technical Specification Pages," the licensee deleted all the information related to Snubber Inspection Program, in Technical Specification (TS) 4.5.M Surveillance Requirements. The first paragraph of TS 4.5.M.1.f, states that "[a] record of the service life of each snubber, the date of which the designated service life commence and installation and maintenance records on which the designated service life is based shall be maintained as required by Specification 6.1 0.2.1." Given the continued presence of specification 6.1 0.2.1, it is not clear to the NRC staff it is possible to remove the deleted material from this TS.

Please justify the removal of this material or reinstate it.

Enclosure

Attachment 5, "Snubber Administrative Program Document," Section 3.0, "Snubber Plan,"

states, in part, that Procedure ER-AA-330-004 implements "Visual Examination of Snubbers,"

whereas Section 3.3.1 states that the visual examination of all snubbers included in the program shall be performed in accordance with procedures ER-AA-330-004 and ER-AA-335-016.

Please explain the difference between procedures ER-AA-330-004 and ER-AA-335-016. , "Markup of Technical Specification Pages," Insert 1 on page 4.5-18, Item d, states that "120-month program updates shall be made in accordance with 10 CFR 50.55a (including 10 CFR 50.55a(b)(3)(v)) subject to limitation and modifications listed therein." In the current 10 CFR 50.55a, the wordings "limitation and modifications," has been changed to "Conditions." Therefore, please revise the TS markup accordingly.

• .. ML14247A586 *via e-mail OFFICE LPL 1-2/PM LPL 1-2/PM LPL 1-2/LA* N RR/DE/EPN B* LPL 1-2/BC (A)

NAME RGiadney Jlamb A Baxter GBedi RSchaaf DATE 09/04/2014 09/04/14 09/05/14 09/08/14 09/16/14