ML17139C508

NRR E-mail Capture - (External_Sender) Need Corrected Page 6 for LIC-17-0043

ML17139C508
Person / Time
Site:	Fort Calhoun
Issue date:	05/19/2017
From:	Matzke E Omaha Public Power District
To:	James Kim Special Projects and Process Branch
References
MF9693
Download: ML17139C508 (3)

Text

NRR-PMDAPEm Resource From: MATZKE, ERICK P <ematzke@oppd.com>

Sent: Friday, May 19, 2017 9:32 AM To: Kim, James

Subject:

[External_Sender] RE: Need Corrected Page 6 for LIC-17-0043 Attachments: LIC-17-0043 Records Exemption Attachment page 6.pdf Oops. here you go.

Erick Matzke Senior Nuclear Licensing Engineer Omaha Public Power District Fort Calhoun Station, Mail Stop: FC-2-4 9610 Power Lane, Blair NE 68008 402-533-6855 ematzke@oppd.com

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Original Message-----

From: Kim, James [1]

Sent: Friday, May 19, 2017 7:07 AM To: MATZKE, ERICK P <ematzke@oppd.com>

Subject:

Need Corrected Page 6 for LIC-17-0043 External Email Notice Think before you click! Email sent from prvs=305b90016=James.Kim@nrc.gov

Erick, Attached is the page 6 from LIC-17-0043 dated May 4, 2017. It appears something is missing between lines 2 and 3 in the 2nd paragraph.

If you forward me the corrected page, I'll add it into ADAMS.

Thanks, Jim This e-mail contains Omaha Public Power District's confidential and proprietary information and is for use only by the intended recipient. Unless explicitly stated otherwise, this e-mail is not a contract offer, amendment, or acceptance. If you are not the intended recipient you are notified that disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited.

1

Hearing Identifier: NRR_PMDA Email Number: 3526 Mail Envelope Properties (A238D6A5C1FF1A4393618100BC03701FCF1E83E7)

Subject:

[External_Sender] RE: Need Corrected Page 6 for LIC-17-0043 Sent Date: 5/19/2017 9:31:38 AM Received Date: 5/19/2017 9:31:41 AM From: MATZKE, ERICK P Created By: ematzke@oppd.com Recipients:

"Kim, James" <James.Kim@nrc.gov>

Tracking Status: None Post Office: SEPEX731.oppd.oppd-ds.com Files Size Date & Time MESSAGE 1239 5/19/2017 9:31:41 AM LIC-17-0043 Records Exemption Attachment page 6.pdf 67837 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

LIC-17-0043 Attachment Page 6 Paragraph 50.71(c), states in part: "Records that are required by the regulations in this part or Part 52 of this chapter, by license condition, or by technical specifications must be retained for the period specified by the appropriate regulation, license condition, or technical specification. If a retention period is not otherwise specified, these records must be retained until the Commission terminates the facility license..."

The common and underlying purpose for the records related regulations cited above is to ensure that the licensing and design basis of the facility is understood, documented, preserved and retrievable relative to establishing and maintaining the SSC's safety functions for the life of the facility. These regulations, however, do not consider the reduction in safety related SSCs during the decommissioning process. Removal of the SSCs from the licensing basis has been, or will be, evaluated in accordance with the applicable change process in the regulations, e.g., 10 CFR 50.59, or NRC approved license amendment, to have no adverse public health and safety impact prior to elimination of any records. Elimination of associated records for these SSCs can have no additional impact. Retention of records associated with SSCs that are or will no longer be part of the facility licensing basis serves no safety or regulatory purpose. Ultimately, the SSCs will be physically removed from the facility. Therefore, application of these record requirements in those circumstances does not serve the underlying purpose of the regulations.

Based on the above, the application of the subject record keeping requirements to the FCS records specified above is not required to achieve the underlying purpose of the rule. Thus, special circumstances are present which the NRC may consider, pursuant to 10 CFR 50.12(a)(2)(ii), to grant the requested exemption.

2. 10 CFR 50.12(a)(2)(iii): Compliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted.

The records retention requirements applied by the NRC to the construction and operation of nuclear power plants are intended to demonstrate, on a broad basis, that SSCs and activities are supportive of the safety analysis and the requirements of the NRC license for an operating reactor and operability of its safety functions. The records program requirements provide assurance that records will be captured, indexed, and stored in an environmentally suitable and retrievable condition resulting in a significant volume of records of many forms and a significant associated cost. The burden associated with the operations phase records requirements was understood and considered appropriate by the NRC and their reactor licensees. However, the effect of the operations phase record retention requirements that survived the life of a facility and no longer served an underlying safety purpose were not fully understood or considered. This is the current situation at the decommissioning facilities. The operating reactor records retention requirements to which FCS is currently regulated are no longer necessary nor appropriate in that the SSCs and activities to which many of the records apply are no longer important to the facility, the public or worker health and safety.