ML17289A790

NRR E-mail Capture - Oyster Creek - RAI Regarding License Amendment Request for Emergency Plan Changes to Revise the ON-SHIFT Staffing and the Emergency Response Organization Staffing for a Permanently Defueled Condition

ML17289A790
Person / Time
Site:	Oyster Creek
Issue date:	10/16/2017
From:	John Lamb Special Projects and Process Branch
To:	David Helker Exelon Corp
References
Download: ML17289A790 (3)

Text

NRR-PMDAPEm Resource From: Lamb, John Sent: Monday, October 16, 2017 1:23 PM To: 'david.helker@exeloncorp.com' Cc: Bonnett, Frederick Paul:(GenCo-Nuc); Richard.Gropp@exeloncorp.com

Subject:

OYSTER CREEK NUCLEAR GENERATING STATION - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR EMERGENCY PLAN CHANGES TO REVISE THE ON-SHIFT STAFFING AND THE EMERGENCY RESPONSE ORGANIZATION STAFFING FOR A PERMANENTLY DEFUELED CONDITI Importance: High

Dear Mr. Helker:

By letter dated January 7, 2011 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML110070507), Exelon Generation Company, LLC (Exelon or the licensee), submitted its Notification of Permanent Cessation of Power Operations for Oyster Creek Nuclear Generating Station (OCNGS). In this letter, Exelon provided notification to the U.S. Nuclear Regulatory Commission (NRC) of its intent to permanently cease power operation no later than December 31, 2019.

By letter dated February 28, 2017 (ADAMS Accession No. ML17060A289), as supplemented by letter dated September 20, 2017 (ADAMS Accession No. ML17263A066), Exelon submitted a license amendment request for OCNGS. The proposed amendment would revise the site emergency plan regarding on-shift staffing and the emergency response organization staffing for a permanently defueled condition. The NRC staff has reviewed the licensee's submittal and determined additional information is required to enable the NRC staff to make an independent assessment regarding its technical review.

The enclosure to this email provides the request for additional information (RAI). On October 11, 2017, the draft RAI questions were sent to Messrs. , Richard Gropp, and Paul Bonnet of your staff to ensure that they were understandable, the regulatory bases for the questions were clear, and to determine if the information was previously docketed. A teleconference was held on October 16, 2017, with Messrs. Paul Bonnett and Richard Gropp of your staff to clarify the RAI questions. Exelon stated they would respond to the RAI within 30 days of the date of this email.

If you have any questions, please contact me at 301-415-3100 or via e-mail at John.Lamb@nrc.gov.

Sincerely, John G. Lamb, Senior Project Manager Special Projects and Process Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-219

Enclosure:

Request for Additional Information ENCLOSURE By letter dated February 28, 2017 (Agencywide Documents Access and Management System (ADAMS)

Accession No. ML17060A289), as supplemented by letter dated September 20, 2017 (ADAMS Accession No.

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ML17263A066), Exelon Generation Company, LLC (Exelon or the licensee), requested prior U.S. Nuclear Regulatory Commission (NRC) approval of an amendment to the Oyster Creek Nuclear Generating Station (OCNGS) site emergency plan (SEP) in support of Exelons intent to permanently cease power operations at OCNGS no later than December 31, 2019. The proposed amendment to the OCNGS SEP would revise the OCNGS Emergency Response Organization (ERO) on-shift and augmented staffing, based on the certifications for permanent cessation of power operations and permanent removal of fuel from the reactor vessel to the NRC in accordance with §50.82(a)(1)(i) and (ii) to Title 10 of the Code of Federal Regulations (10 CFR).

The requests for additional information (RAI) listed below are necessary to facilitate the technical review being conducted by the NRC staff.

RAI In a letter from Michael P. Gallagher, Exelon Generation Company, LLC (Exelon), dated September 20, 2017, containing Exelons Response to NRC's Request for Additional Information and Supplemental Information, Exelon states in the response to RAI-OCNGS-3:

Exelon has revised the proposed LAR (Reference 1) Table B-1, as provided in Attachment 2 to this submittal. This change restores the two RP Technicians (Item 4, In-Plant Surveys) (increased from one in the proposed LAR (Reference 1)) and the two Maintenance Personnel (Item 5, Repair and Corrective Actions) that are in the current OCNGS SEP. Additionally, Note (c) is being removed from the two designated shift Maintenance Personnel to indicate that they will not have any additional responsibilities and therefore will constitute part of the Minimum Shift Size compliment.

Note (l) which states, One position is filled by a Senior Maintenance Technician, the other position may be filled by an equipment operator was deleted in the original submittal. It was reinstated as part of the RAI response.

It is unclear if the two Maintenance Personnel identified in the RAI response are specifically qualified to perform the duties of the required augmenting Electrical Maintenance and Mechanical Maintenance functions.

The functions of the Electrical Maintenance and Mechanical Maintenance augmented responders need to be addressed per the guidance in NUREG-0654, Table B-1, Repair and Corrective Actions, not by using the guidance in NEI 10-05, which is for onshift staffing.

Additionally, there is no evaluation in the RAI response that two RP Technicians provide sufficient staffing and resources to mitigate an event with emergency classification levels up to and including a General Emergency.

Previous NRC observations of other licensees drills have indicated that the reduced RP staffing did impact the performance of the emergency response organizations ability to implement mitigation actions.

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Hearing Identifier: NRR_PMDA Email Number: 3771 Mail Envelope Properties (John.Lamb@nrc.gov20171016132300)

Subject:

OYSTER CREEK NUCLEAR GENERATING STATION - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR EMERGENCY PLAN CHANGES TO REVISE THE ON-SHIFT STAFFING AND THE EMERGENCY RESPONSE ORGANIZATION STAFFING FOR A PERMANENTLY DEFUELED CONDITI Sent Date: 10/16/2017 1:23:05 PM Received Date: 10/16/2017 1:23:00 PM From: Lamb, John Created By: John.Lamb@nrc.gov Recipients:

"Bonnett, Frederick Paul:(GenCo-Nuc)" <Frederick.Bonnett@exeloncorp.com>

Tracking Status: None "Richard.Gropp@exeloncorp.com" <Richard.Gropp@exeloncorp.com>

Tracking Status: None

"'david.helker@exeloncorp.com'" <david.helker@exeloncorp.com>

Tracking Status: None Post Office:

Files Size Date & Time MESSAGE 5047 10/16/2017 1:23:00 PM Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received: