ML15307A013

Issuance of Amendment No. 286, Request to Make Administrative Changes to the Technical Specifications to Update Titles, Delete Obsolete Actions in Appendix B, and Relocate a Definition

ML15307A013
Person / Time
Site:	Fort Calhoun
Issue date:	02/23/2016
From:	Lyon C Plant Licensing Branch IV
To:	Marik S Omaha Public Power District
Lyon C
References
CAC MF6645
Download: ML15307A013 (22)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 23, 2016 Mr. Shane M. Marik Site Vice President and Chief Nuclear Officer Omaha Public Power District Fort Calhoun Station 9610 Power Lane, Mail Stop FC-2-4 Blair, NE 68008

SUBJECT:

FORT CALHOUN STATION, UNIT NO. 1 - ISSUANCE OF AMENDMENT RE:

ADMINISTRATIVE CHANGES TO TECHNICAL SPECIFICATIONS (CAC NO. MF6645)

Dear Mr. Marik:

The U.S. Nuclear Regulatory Commission has issued the enclosed Amendment No. 286 to Renewed Facility Operating License No. DPR-40 for the Fort Calhoun Station, Unit No. 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated August 20, 2015, as supplemented by letter dated January 27, 2016.

The amendment makes administrative changes to update personnel and committee titles in the Technical Specifications (TSs), deletes outdated or completed additional actions contained in Appendix B, Additional Conditions, of the license, and relocates the definition of Process Control Program from the TSs to the Updated Safety Analysis Report. The changes were proposed by the licensee to use consistent terminology with Exelon Generation Company, LLC, as part of their Operating Services Agreement.

A copy of the related Safety Evaluation is also enclosed. The Notice of Issuance will be included in the Commission's next biweekly Federal Register notice.

Sincerely, Carl F. Lyon, Project Manager Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-285

Enclosures:

1. Amendment No. 286 to DPR-40

2. Safety Evaluation cc w/encls: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 OMAHA PUBLIC POWER DISTRICT DOCKET NO. 50-285 FORT CALHOUN STATION, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 286 Renewed License No. DPR-40

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment by the Omaha Public Power District (the licensee), dated August 20, 2015, as supplemented by letter dated January 27, 2016, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D. The issuance of this license amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and ali applicable requirements have been satisfied.

Enclosure 1

ATTACHMENT TO LICENSE AMENDMENT NO. 286 RENEWED FACILITY OPERATING LICENSE NO. DPR-40 DOCKET NO. 50-285 Replace the following pages of the Renewed Facility Operating License No. DPR-40, Appendix A, Technical Specifications, and Appendix B, Additional Conditions, with the attached revised pages. The revised pages are identified by amendment number and contain vertical lines indicating the areas of change.

Operating License REMOVE INSERT Appendix A Technical Specifications REMOVE INSERT TOC - Page 3 TOC - Page 3 Definitions - Page 3 Definitions - Page 3 Definitions - Page 7 Definitions - Page 7 2.15 - Page 13 2.15- Page 13 5.0 - Page 2 5.0 - Page 2 5.0 - Page 11 5.0- Page 11 5.0- Page 15 5.0 - Page 15 5.0-Page16 5.0 - Page 16 Appendix B. Additional Conditions REMOVE INSERT Appendix B - Page 1 Appendix B - Page 1

2. Accordingly, Renewed Facility Operating License No. DPR-40 is amended by changes as indicated in the attachment to this license amendment, and paragraph 3. B. of Renewed Facility Operating License No. DPR-40 is hereby amended to read as follows:

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 286, are hereby incorporated in the license. Omaha Public Power District shall operate the facility in accordance with the Technical Specifications.

In addition, paragraph 3.F of Renewed Facility Operating License No. DPR-40 is hereby amended to read as follows:

F. Appendix B The Additional Conditions contained in Appendix B, as revised through Amendment No. 286, are hereby incorporated into this license. Omaha Public Power District shall operate the facility in accordance with the Appendix B Additional Conditions.

3. Appendix B, Additional Conditions, to Renewed Facility Operating License DPR-40 is amended to delete license conditions (1) and (2), designated as Amendment Nos. 181 and 257, respectively.

4. The license amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Robert J. Pascarelli, Chief Plant Licensing Branch IV-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License No. DPR-40 and Technical Specifications Date of Issuance: February 23, 2016

(4) Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source, or special nuclear material without restriction to chemical or physical form for sample analysis or instrument calibration or when associated with radioactive apparatus or components; (5) Pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by operation of the facility.

3. This renewed license shall be deemed to contain and is subject to the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 and 50.59 of Part 50, and Section 70.32 of Part 70; and is, subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

A. Maximum Power Level Omaha Public Power District is authorized to operate the Fort Calhoun Station, Unit 1, at steady state reactor core power levels not in excess of 1500 megawatts thermal (rate power).

B. Technical Specifications The Technical Specifications contained in Appendix A, as revised through Amendment No. 286 are hereby incorporated in the license. Omaha Public Power District shall operate the facility in accordance with the Technical Specifications.

C. Security and Safeguards Contingency Plans The Omaha Public Power District shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The plans, which contain Safeguards Information protected under 10 CFR 73.21, are entitled: "Fort Calhoun Station Security Plan, Training and Qualification Plan, Safeguards Contingency Plan," submitted by letter dated May 19, 2006.

OPPD shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The OPPD CSP was approved by License Amendment No. 266 and modified by License Amendment No. 284.

Renewed Operating License No. DPR-40 Amendment No. 286

The Updated Final Safety Analysis Report supplement, as revised, shall be included in the next scheduled update to the Updated Final Safety Analysis Report required by 10 CFR 50.71 (e)(4) following issuance of this renewed license. Until that update is complete, the Omaha Public Power District may make changes to the programs and activities described in the supplement without prior Commission approval, provided that the Omaha Public Power District evaluates each such change pursuant to the criteria set forth in 10 CFR 50.59 and otherwise complies with the requirements in that section.

F. Appendix B The Additional Conditions contained in Appendix B, as revised through Amendment No. 286, are hereby incorporated into this license. Omaha Public Power District shall operate the facility in accordance with the Appendix B Additional Conditions.

Mitigation Strategy License Condition Develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders Renewed Operating License No. DPR-40 Amendment No. 286

TECHNICAL SPECIFICATION TABLE OF CONTENTS (Continued) 5.0 ADMINISTRATIVE CONTROLS 5.1 Responsibility 5.2 Organization 5.3 Facility Staff Qualifications 5.4 Training 5.5 Not Used 5.6 Not Used 5.7 Not Used 5.8 Procedures 5.9 Reporting Requirements 5.9.1 Not Used 5.9.2 Not Used 5.9.3 Special Reports 5.9.4 Unique Reporting Requirements 5.9.5 Core Operating Limits Report (COLR) 5.9.6 Reactor Coolant System (RCS) Pressure-Temperature Limits Report (PTLR) 5.10 Record Retention 5.11 Radiation Protection Program 5.12 DELETED 5.13 Secondary Water Chemistry 5.14 Systems Integrity 5.15 Post-Accident Radiological Sampling and Monitoring 5.16 Radiological Effluents and Environmental Monitoring Programs 5.16.1 Radioactive Effluent Controls Program 5.16.2 Radiological Environmental Monitoring Program 5.17 Offsite Dose Calculation Manual (ODCM) 5.18 DELETED 5.19 Containment Leakage Rate Testing Program 5.20 Technical Specification (TS) Bases Control Program 5.21 Containment Tendon Testing Program 5.22 Diesel Fuel Oil Testing Program 5.23 Steam Generator (SG) Program 5.24 Control Room Habitability Program 6.0 INTERIM SPECIAL TECHNICAL SPECIFICATIONS 6.1 DELETED 6.2 DELETED 6.3 DELETED 6.4 DELETED TOC - Page 3 Amendment No. 32,34,43,54,55,57, 73,80,86,89,93,99, 141, 152, 157, 184, 185, 221 236, 237,246,252, ~

286

TECHNICAL SPECIFICATION DEFINITIONS REACTOR OPERATING CONDITIONS (Continued)

Physics Testing Testing performed under written procedures approved by Plant Operations Review Committee to determine CEA worths and other core nuclear parameters. Deviations from normal operating practice which are necessary to enable some of these tests to be performed are permitted in accordance with: 1) the specific provisions of these technical specifications, 2) authorization under the provisions of 10 CFR 50.59, or 3) other approval of the Commission.

PROTECTIVE SYSTEMS Reactor Trip The de-energizing of the CEDM magnetic clutch holding coils which releases the CEA's and allows them to drop into the core.

Instrument Channel One of four independent measurement channels complete with the sensors, sensor power supply units, amplifiers, and trip modules provided for each safety parameter.

Reactor Protective System Logid 1)

The system which utilizes relay contact outputs from individual instrument channels to provide the reactor trip signal for de-energizing the magnetic clutch power supplies. The logic system is wired to provide a reactor trip on a 2-of-4 or 2-of-3 basis for any given input parameter.

Definitions - Page 3 Amendment No. J2- 286

TECHNICAL SPECIFICATIONS DEFINITIONS Azimuthal Power Tilt - Tq Azimuthal Power Tilt shall be the power asymmetry between azimuthally symmetric fuel assemblies.

Maximum Radial Peaking Factor (FRT)

The Maximum Radial Peaking Factor is the maximum ratio of the individual fuel pin power to the core average pin power integrated over the total core height, including tilt. The FRT limit is provided in the Core Operating Limits Report.

Dose Equivalent 1-131 That concentration of 1-131 (<!>Ci/gm) which alone would produce the same thyroid dose as the quantity and isotopic mixture of 1-131, 1-132, 1-133, 1-134 and 1-135 actually present. In other

words, Dose Equivalent 1-131 (<l>Ci/gm) = <l>Ci/gm of 1-131

+ 0.0361 x <l>Ci/gm of 1-132

+ 0.270 x <l>Ci/gm of 1-133

+ 0.0169 x <l>Ci/gm of 1-134

+ 0.0838 x <l>Ci/gm of 1-135 Definitions - Page 7 Amendment No. 32,38,67,86,141,152, 160,196,202, 2e9 286

TECHNICAL SPECIFICATIONS TABLE 2-3 (Continued)

If the channel becomes inoperable, that channel must be placed in the bypassed condition within eight hours from time of discovery of loss of operability. If the channel is not returned to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> from time of discovery of loss of operability, one of the eight channels may continue to be placed in the bypassed condition provided the Plant Operations Review Committee has reviewed and documented the judgment concerning prolonged operation in bypass of the inoperable channel. The channel shall be returned to OPERABLE status no later than during the next cold shutdown. If one of the four channels on one steam generator is in prolonged bypass and a channel on the other steam generator becomes inoperable, the second inoperable channel must be placed in bypass within eight hours from time of discovery of loss of operability. If one of the inoperable channels is not returned to OPERABLE status within seven days from the time of discovery of the second loss of operability, the unit must be placed in hot shutdown within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

If one channel becomes inoperable, that channel must be placed in the bypassed condition within eight hours from time of discovery of loss of operability. If the channel is not returned to OPERABLE status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> from time of discovery of loss of operability, one of the eight channels may continue to be placed in the bypassed condition provided the Plant Operations Review Committee has reviewed and documented the judgment concerning prolonged operation in bypass of the inoperable channel. The channel shall be returned to OPERABLE status no later than during the next cold shutdown. If a channel is in prolonged bypass and a channel on the opposite train becomes inoperable, the second inoperable channel must be placed in bypass within eight hours from time of discovery of loss of operability. If one of the inoperable channels is not returned to OPERABLE status within seven days from the time of discovery of the second loss of operability, the unit must be placed in hot shutdown within the following 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.

k Specification 2.15.1 (2) is applicable.

Specification 2.15.1 (3) is applicable. If ESF Logic Subsystems A and B are inoperable, enter Specification 2.0.1.

m Steam Generator Low Pressure permissive is required for actuation.

n Auto removal of bypass prior to exceeding 600 psia.

2.15 - Page 13 Amendment No. BB,173,194,249,255, 2-7Q 286

TECHNICAL SPECIFICATIONS 5.0 ADMINISTRATIVE CONTROLS 5.2 Organization (Continued)

b. An Operator or Technician qualified in Radiation Protection Procedures shall be onsite when fuel is in the reactor.

c. All core alterations shall be directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator limited to fuel handling who has no other concurrent responsibilities during the operation.

d. Fire protection program responsibilities are assigned to those positions and/or groups designated by asterisks in USAR 12.1-1through12.1-4 according to the procedures specified in Section 5.8 of the Technical Specifications.

e. The Manager - Shift Operations, the Shift Managers, and the Unit Supervisors shall hold a senior reactor operator license. The Licensed Operators shall hold a reactor operator license.

5.3 Facility Staff Qualification 5.3.1 Each member of the plant staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, with the exception of the Manager - Radiation Protection (MRP) and the Shift Technical Advisor (STA), the senior reactor operator licensees, and the reactor operator licensees, who shall meet the requirements set forth in Regulatory Guide 1.8, Revision 3, dated May 2000, entitled "Qualification and Training of Personnel for Nuclear Power Plants."

5.0 - Page 2 Amendment No. 38,54,85,115, 160,181,1Q0,202, ~

286

TECHNICAL SPECIFICATIONS 5.0 ADMINISTRATIVE CONTROLS 5.10 Record Retention 5.10.1 Records shall be retained as described in the Quality Assurance Program.

5.11 Radiation Protection Program Procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR Part 20 and shall be approved, maintained and adhered to for all operations involving personnel radiation exposure.

5.11.1 In lieu of the "control device" required by paragraph 20.1601 (a) of 10 CFR Part 20, and as an alternative method allowed under ' 20.1601 (c), each high radiation area (as defined in ' 20.1601) in which the intensity of radiation is 1000 mrem/hr or less shall be barricaded and conspicuously posted as a high radiation area and entrance thereto shall be controlled by required issuance of a Radiation Work Permit.* Any individual or group of individuals permitted to enter such areas shall be provided with or accompanied by one or more of the following:

a. A radiation monitoring device which continuously indicates the radiation dose rate in the area.

b. A radiation monitoring device which continuously integrates the radiation dose rate in the area and alarms when a preset integrated dose is received. Entry into such areas with this monitoring device may be made after the dose rate level in the area has been established and personnel have been made knowledgeable of them.

c. An individual qualified in radiation protection procedures who is equipped with a radiation dose rate monitoring device. This individual shall be responsible for providing positive control over the activities within the area and shall perform periodic radiation surveillance at the frequency specified by the Manager-Radiation Protection (MRP) in the Radiation Work Permit.

5.11.2 The requirements of 5.11.1, above, shall also apply to each high radiation area in which the intensity of radiation is greater than 1000 mrem/hr** but less than 500 rads/hr***

(Locked High Radiation Area). In addition, locked doors shall be provided to prevent unauthorized entry into such areas and the keys shall be maintained under the administrative control of the Shift Manager on duty and/or the MRP (or designee) with the following exception:

a. In lieu of the above, for accessible localized Locked High Radiation Areas located in large areas such as containment, where no lockable enclosure exists in the immediate vicinity to control access to the Locked High Radiation Area and no such enclosure can be readily constructed, then the Locked High Radiation Area shall be:

• Radiation Protection personnel shall be exempt from the RWP issuance requirement during the performance of their assigned radiation protection duties, provided they comply with approved radiation protection procedures for entry into high radiation areas.

• • At 30 centimeters (12 inches) from the radiation source or from any surface penetrated by the radiation.

• • • At 1 meter from the radiation source or from any surface penetrated by the radiation.

5.0 - Page 11 Amendment No. 28,61,132,164,184, 190,202,203,~

286

TECHNICAL SPECIFICATIONS 5.0 ADMINISTRATIVE CONTROLS 5.16 Radiological Effluents and Environmental Monitoring Programs (Continued)

a. Monitoring, sampling, analysis, and reporting of radiation and radionuclides in the environment in accordance with the methodology and parameters in the ODCM.

b. A Land Use Census to ensure that changes in the use of areas at and beyond the site boundary are identified and that modifications to the monitoring program are made if required by the results of this census.

c. Participation in an lnterlaboratory Comparison Program to ensure that independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample matrices are performed as part of the quality assurance program for environmental monitoring.

5.17 Offsite Dose Calculation Manual (ODCM)

Changes to the ODCM:

a. Shall be documented and records of reviews performed shall be retained as required by the Quality Assurance Program. This documentation shall contain:

1. Sufficient information to support the change together with the appropriate analyses or evaluations justifying the change(s) and

2. A determination that the change will maintain the level of radioactive effluent control required by 10 CFR 20.1302, 40 CFR Part 190, 10 CFR 50.36a, and Appendix I to 10 CFR Part 50 and not adversely impact the accuracy or reliability of effluent, dose, or setpoint calculations.

b. Shall become effective after review and acceptance by the Plant Operations Review Committee and the approval of the plant manager.

c. Temporary changes to the ODCM may be made in accordance with Technical Specification 5.8.2.

d. Shall be submitted to the Nuclear Regulatory Commission in the form of a complete, legible copy of the entire ODCM as a part of or concurrent with the Annual Radioactive Effluent Release Report for the period of the report in which any change to the ODCM was made. Each change shall be identified by markings in the margin of the affected pages, clearly indicating the area of the page that was changed and shall indicate the date (e.g., month/year) the change was implemented.

5.18 DELETED 5.0- Page 15 Amendment No. 152, 164, 202, 237 286

TECHNICAL SPECIFICATIONS 5.0 ADMINISTRATIVE CONTROLS 5.19 Containment Leakage Rate Testing Program

a. A program shall be established to implement the leakage rate testing of the containment as required by 10 CFR 50.54(0) and 10 CFR 50, Appendix J, Option B, as modified by approved exemptions. This program shall be in accordance with the guidelines contained in Regulatory Guide 1.163, "Performance-Based Containment Leak-Test Program, dated September 1995," as modified by the following exceptions:

(1) If the Personnel Air Lock (PAL) is opened during periods when containment integrity is not required, the PAL door seals shall be tested at the end of such periods and the entire PAL shall be tested within 14 days after RCS temperature Tcold > 21 OEF.

(2) Type A tests may be deferred for penetrations of the steel pressure retaining boundary where the nominal diameter does not exceed one inch.

(3) Elapsed time between consecutive Type A tests used to determine performance shall be at least 24 months or refueling interval.

b. The containment design accident pressure (Pa) is 60 psig.

5.0 - Page 16 Amendment No. 152,185, 202, 220,237, 259 286

TECHNICAL SPECIFICATIONS Appendix B Additional Conditions Renewed Facility Operating License No. DPR-40 Omaha Public Power District shall comply with the following conditions on the schedules noted below:

Amendment Implementation Number Additional Conditions Date Appendix B - Page 1 Amendment No. 181, 255, 257, 260, 286

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 286 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-40 OMAHA PUBLIC POWER DISTRICT FORT CALHOUN STATION, UNIT NO. 1 DOCKET NO. 50-285

1.0 INTRODUCTION

By application dated August 20, 2015, as supplemented by letter dated January 27, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML15233A494 and ML16032A220, respectively), Omaha Public Power District (OPPD, the licensee) requested changes to the Technical Specifications (Appendix A to Renewed Facility Operating License No. DPR-40) for the Fort Calhoun Station, Unit No. 1 (FCS).

The proposed amendment would make administrative changes to update personnel and committee titles in the Technical Specifications (TSs), delete outdated or completed additional actions contained in Appendix B, Additional Conditions, of the license, and relocate the definition of Process Control Program (PCP) from the TSs to the Updated Safety Analysis Report (USAR). The changes are proposed by the licensee to use consistent terminology with Exelon Generation Company, LLC (Exelon), as part of their Operating Services Agreement.

Specifically, the licensee proposes the following changes:

1. The title for the "Plant Review Committee" is being revised to "Plant Operations Review Committee." This proposed change revises the TS definition of Physics Testing, footnotes i and j in TS Table 2-3. and TS 5.17.b.

2. The "Control Room Supervisor" title is being revised to "Unit Supervisor." This proposed change revises TS 5.2.e.

3. The term "Restricted High Radiation Area" is being revised to "Locked High Radiation Area." This proposed change revises TS 5.11.2. In addition, allowance for a designee for the Manager Radiation Protection is being added to clarify that a designated alternate to the Manager Radiation Protection may control keys to locked high radiation areas.

Enclosure 2

4. The licensee proposes to relocate the definition and program requirements of the PCP to the USAR/plant procedures. This proposed change modifies the table of contents and deletes the definition and TS 5.18.

5. The licensee proposes the following additional administrative changes in Appendix B, Additional Conditions, of Renewed Facility Operating License No. DPR-40:

• Deletion of Additional Condition ( 1) for Amendment No. 181, which currently states:

(1) The licensee is authorized to relocate certain technical specification requirements to licensee-controlled documents. Implementation of this amendment shall include the relocation of these technical specification requirements to the appropriate documents, as described in the licensee's application dated November 20, 1996, as supplemented by letters dated February 20, 1997, and March 25, 1997, and evaluated in the staffs safety evaluation dated March 27, 1997.

• Deletion of Additional Condition (2) for Amendment No. 257, which currently states:

(2) Upon implementation of Amendment No. 257 adopting TSTF-448, Revision 3, the determination of control room envelope (CRE) unfiltered air inleakage as required by TS 3.1, Table 3-3, Item 10.b. in accordance with TS 5.24c.(i), the assessment of CRE habitability as required by Specification 5.24c.(ii), and the measurement of CRE pressure as required by Specification 5.24d, shall be considered met. Following implementation:

(a) The first performance of TS 3.1, Table 3-3, Item 1O.b., in accordance with Specification 5.24c.(i), shall be within the next 18 months as the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, Specification 5.24c(ii), shall be within the next 9 months as the time period since the most recent successful tracer gas test is greater than 3 years.

(c) The first performance of the periodic measurement of CRE pressure, Specification 5.24d., shall be within the next 138 days.

2.0 REGULATORY EVALUATION

The U.S. Nuclear Regulatory Commission (NRC) regulatory requirements related to the content of the TSs are set forth in Title 1O of the Code of Federal Regulations (10 CFR), Section 50.36.

This regulation requires that the TSs include items in five specific categories. These categories include: 1) safety limits, limiting safety system settings and limiting control settings, 2) limiting conditions for operation, 3) surveillance requirements, 4) design features, and 5) administrative controls. However, the regulation does not specify the particular TSs to be included in a plant's license.

The regulations in 10 CFR 50.36(c)(5) state, in part, that:

Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

The specific content of the administrative controls section of the TS is, therefore, that information that the Commission deems essential for the safe operation of the facility that is not already adequately covered by other regulations. Accordingly, the NRC staff has determined that requirements that are not specifically required under 10 CFR 50.36(c)(5) and that are not otherwise necessary for operation of the facility in a safe manner, can be removed from administrative controls.

The NRC's regulatory requirements related to controls on work hour limitations are prescribed in 10 CFR Part 26, Subpart I-Managing Fatigue.

The NRC staff evaluated the licensee's proposed changes under the regulatory requirements of 10 CFR 50.36 and 10 CFR Part 26, Subpart I. NRC guidance on the changes is also provided in NRC Regulatory Guide (RG) 8.38, Revision 1, "Control of Access to High and Very High Radiation Areas in Nuclear Power Plants" (ADAMS Accession No. ML061350096).

3.0 TECHNICAL EVALUATION

On August 17, 2012, OPPD and Exelon entered into a 20-year Operating Services Agreement by which Exelon, as contractor to OPPD, manages day-to-day operations at FCS. The agreement is enclosed with OPPD's letter to the NRC dated March 1, 2013 (ADAMS Accession No. ML13066A037); the agreement is proprietary information and, accordingly, is withheld from public disclosure in accordance with 10 CFR 2.390. OPPD is implementing procedures and processes from Exelon at FCS as part of the agreement and, as a result, requested that certain TSs be revised to use consistent terminology.

The licensee proposes to change the title for the "Plant Review Committee" to "Plant Operations Review Committee," and the title of the "Control Room Supervisor" to "Unit Supervisor." The proposed changes are administrative in nature and have no technical implications with respect to the station organization, responsibilities, or unit staffing requirements, and are, therefore, acceptable to the NRC staff.

The licensee proposes to change the term "Restricted High Radiation Area" to "Locked High Radiation Area." The proposed change is administrative in nature and has no technical implications. Specific terminology for the defined area is not required by 10 CFR 20.1601, "Control of access to high radiation areas," paragraph (a)(3); and, in general, the term "Locked High Radiation Area" is widely used throughout the industry. Therefore, the change is acceptable to the NRC staff.

In addition, the licensee proposes to add 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 (LHRAs). As stated above, the licensee is implementing Exelon procedures and processes at FCS. 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 LHRAs is detailed and comprehensive. The procedure states that padlocks and keys used for control of LHRAs are administered by Radiation Protection Supervision. RP-AA-460 references NRC RG 8.38. As stated in RG 8.38, Revision 1, 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.

The proposed allowance for a designated alternate to the MRP to control keys to LHRAs is consistent with RG 8.38, Revision 1, Regulatory Position C.2.6 and, therefore, is acceptable to the NRC staff.

The licensee proposes to relocate the PCP from the TSs to the USAR. At FCS, reports are included in TS 5.9, "Reporting Requirements." TS 5.9.4.a, "Annual Radioactive Effluent Release Report," contains similar wording to standard TS 5.6.2. TS 5.9.4.a states that:

The Annual Radioactive Effluent Release Report covering the operation of the unit during the previous calendar year of operation shall be submitted before May 1 of each year. The report shall include a summary of the quantities of radioactive liquid and gaseous effluents and solid waste released from the unit.

The material provided shall be 1) consistent with the objectives outlined in the ODCM and PCP, and 2) in conformance with 10 CFR 50.36a and Section IV.8.1 of Appendix I to 10 CFR 50.

The PCP is described in USAR Section 11.3, and the licensee will update the section to relocate the TS requirement. USAR Section 11.3.2.9 currently states that the plant review committee is responsible for reviewing changes, and USAR Section 11.3.2.10 currently states that copies of PCP will be included with Annual Radioactive Effluent Report. The USAR does not currently contain a definition of the PCP, and the licensee proposes to revise USAR Section 11.3 as necessary to relocate the TS requirement.

The NRC staff previously concluded that it is not necessary to include the PCP in the TSs because the information in it is adequately regulated by the requirements of 10 CFR 50.36a and portions of other applicable regulations (10 CFR Parts 20, 61, and 71 ). In addition, changes to

the USAR, including the PCP, continue to be controlled under 10 CFR 50.59. Therefore, the PCP may be relocated to a licensee-controlled program (i.e., the USAR). Since changes to the USAR, including the PCP, continue to be controlled under 10 CFR 50.59, the NRC staff concludes that the relocation of the FCS PCP to the USAR is acceptable.

The licensee proposes the following additional administrative changes to Appendix B, Additional Conditions, of Renewed Facility Operating License No. DPR-40:

• Deletion of Additional Condition (1) for Amendment No. 181.

Amendment No. 181 relocated controls for plant staff working hours to USAR Section 12.1.5.

This USAR section continues to describe controls on work hour limitations; however, with the issuance of 10 CFR Part 26, Subpart I and TS Amendment No. 262, it is no longer necessary to contain this additional condition in the TS to ensure that the limitations will be followed as the controls are implemented through regulation. Therefore, deletion of this condition is acceptable to the NRC staff.

• Deletion of Additional Condition (2) for Amendment No. 257.

Amendment No. 257 was issued on June 30, 2008, with an implementation date of within 270 days of its issuance. This additional condition specified when first performances of specific items were required to be complete. The requirement of Condition (2)(a) for the first performance of TS 3.1 Table 3-3, Item 1O.b, tracer gas testing, was performed in January 2010.

The requirement of Condition (2)(b) for the first performance of the periodic assessment of control room envelope (CRE) habitability was performed in January 2010. The requirement of Condition (2)(c) for the first performance of periodic measurement of CRE pressure in accordance with TS 5.24d was performed in June 2009. Since the first performances of these tests have been completed, the additional condition contained in Appendix B to the operating license is no longer necessary. Therefore, deletion of this condition is acceptable to the NRC staff.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Nebraska State official, Ms. J. Schmitt, was notified on November 16, 2015, of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes recordkeeping, reporting, or administrative procedures or requirements; the name, position, or title of an officer of the licensee or permit holder, including but not limited to, the radiation safety officer or quality assurance manager; and the format of the license or permit or otherwise makes editorial, corrective or other minor revisions, including the updating of NRC approved references. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration and there

has been no public comment on such finding published in the Federal Register on October 13, 2015 (80 FR 61486). Accordingly, the amendment meets the eligibility criteria for categorical exclusions set forth in 10 CFR 51.22(c)(10). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: F. Lyon, NRR/DORL/LPL4-1 Date: February 23, 2016

ML15307A013 *Previously concurred OFFICE NRR/DORL/LPL4-1 /PM NRR/DORL/LPL4-1 /LA NRR/DSS/STSB/BC NAME Flyon JBurkhardt* RElliott DATE 2/1/16 11/4/15 2/12/16 OFFICE OGG (NLO) NRR/DORL/LPL4-1/BC NRR/DORL/LPL4-1/PM NAME BMizuno RPascarelli FL yon DATE 2/22/16 02/23/16 2/23/16