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EPID:L-2017-LLQ-0003, Request for Approval of Decommissioning Quality Assurance Program, Revision 0 for Oyster Creek Nuclear Generating Station (Open) |
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Category:Letter type:RA
MONTHYEARRA-19-091, Commitment Change Summary Report - 20192019-12-27027 December 2019 Commitment Change Summary Report - 2019 RA-19-080, Response to Request for Additional Information (RAI) Related to Oyster Creek Nuclear Generating Station - Post-Shutdown Decommissioning Activities Report2019-10-18018 October 2019 Response to Request for Additional Information (RAI) Related to Oyster Creek Nuclear Generating Station - Post-Shutdown Decommissioning Activities Report RA-19-076, Request for Continuation of NRC Actions and Approvals Following Transfer of the Licenses from Exelon Generation to Holtec Decommissioning International, LLC2019-09-12012 September 2019 Request for Continuation of NRC Actions and Approvals Following Transfer of the Licenses from Exelon Generation to Holtec Decommissioning International, LLC RA-19-065, Signature Verification and Acceptance of Amendment 19 to Indemnity Agreement No B-37 to Renewed Facility License No. DPR-162019-08-28028 August 2019 Signature Verification and Acceptance of Amendment 19 to Indemnity Agreement No B-37 to Renewed Facility License No. DPR-16 RA-19-052, Security Plan, Training Qualification Plan, Safeguards Contingency Plan, (Revision 18)2019-06-11011 June 2019 Security Plan, Training Qualification Plan, Safeguards Contingency Plan, (Revision 18) RA-19-023, Annual Radioactive Effluent Release Report for 20182019-04-30030 April 2019 Annual Radioactive Effluent Release Report for 2018 RA-19-019, Submittal of Changes to Technical Specifications Bases2019-04-12012 April 2019 Submittal of Changes to Technical Specifications Bases RA-19-012, Supplement for License Amendment Request - License Condition Revision for Removal of Cyber Security Plan Requirements2019-03-0707 March 2019 Supplement for License Amendment Request - License Condition Revision for Removal of Cyber Security Plan Requirements RA-19-007, Response to RAI and Supplemental Information Re Request for Changing Emergency Preparedness License Amendment 294 Effective Date (Change to Adiabatic Heat-Up Calculation)2019-02-13013 February 2019 Response to RAI and Supplemental Information Re Request for Changing Emergency Preparedness License Amendment 294 Effective Date (Change to Adiabatic Heat-Up Calculation) RA-19-003, Amendment No. 17 to Indemnity Agreement No. 8-372019-01-0808 January 2019 Amendment No. 17 to Indemnity Agreement No. 8-37 RA-18-103, Annual Sea Turtle Incidental Take Report - 20182018-12-13013 December 2018 Annual Sea Turtle Incidental Take Report - 2018 RA-18-080, License Amendment Request: License Condition Revision for Removal of Cyber Security Plan Requirements2018-11-12012 November 2018 License Amendment Request: License Condition Revision for Removal of Cyber Security Plan Requirements RA-18-098, License Amendment Request Supplement - Proposed Change of Effective and Implementation Dates of License Amendment No. 294, Oyster Creek Emergency Plan for Permanently Defueled Emergency Plan and Emergency Action Level Scheme2018-11-0606 November 2018 License Amendment Request Supplement - Proposed Change of Effective and Implementation Dates of License Amendment No. 294, Oyster Creek Emergency Plan for Permanently Defueled Emergency Plan and Emergency Action Level Scheme RA-18-097, Exelon Nuclear Radiological Emergency Plan and Addendum Revisions2018-10-24024 October 2018 Exelon Nuclear Radiological Emergency Plan and Addendum Revisions RA-18-092, License Amendment Request - Proposed Change of Effective and Implementation Dates of License Amendment No. 294, Oyster Creek Emergency Plan for Permanently Defueled Emergency Plan and Emergency Action Level Scheme2018-10-22022 October 2018 License Amendment Request - Proposed Change of Effective and Implementation Dates of License Amendment No. 294, Oyster Creek Emergency Plan for Permanently Defueled Emergency Plan and Emergency Action Level Scheme RA-18-093, Request to Reinitiate Consultation Regarding the OCNGS Sea Turtle Incidental Take Statement2018-10-16016 October 2018 Request to Reinitiate Consultation Regarding the OCNGS Sea Turtle Incidental Take Statement RA-18-091, Request to Reclassify Oyster Creek Nuclear Generating Station Under 10 CFR 171.15, Annual Fees: Reactor Licenses and Independent Spent Fuel Storage Licenses2018-10-0101 October 2018 Request to Reclassify Oyster Creek Nuclear Generating Station Under 10 CFR 171.15, Annual Fees: Reactor Licenses and Independent Spent Fuel Storage Licenses RA-18-090, Notice Regarding Proposed Amendment No. 1 to Master Terms for Decommissioning Trust Agreements2018-10-0101 October 2018 Notice Regarding Proposed Amendment No. 1 to Master Terms for Decommissioning Trust Agreements RA-18-083, Certification of Permanent Removal of Fuel from the Reactor Vessel for Oyster Creek Nuclear Generating Station2018-09-25025 September 2018 Certification of Permanent Removal of Fuel from the Reactor Vessel for Oyster Creek Nuclear Generating Station RA-18-088, Radiological Emergency Plan Addendum Revision. Includes EP-AA-1010, Addendum 3, Revision 4, Emergency Action Levels for Oyster Creek.2018-09-25025 September 2018 Radiological Emergency Plan Addendum Revision. Includes EP-AA-1010, Addendum 3, Revision 4, Emergency Action Levels for Oyster Creek. RA-18-087, Response to Request for Additional Information (RAI) Related to Post-Shutdown Decommissioning Activities Report2018-09-24024 September 2018 Response to Request for Additional Information (RAI) Related to Post-Shutdown Decommissioning Activities Report RA-18-084, Secondary Containment Capability Test2018-09-14014 September 2018 Secondary Containment Capability Test RA-18-078, Submittal of Sea Turtle Incidental Take Report 2018-0042018-08-15015 August 2018 Submittal of Sea Turtle Incidental Take Report 2018-004 RA-18-077, Sea Turtle Incidental Take Report 2018-0032018-08-14014 August 2018 Sea Turtle Incidental Take Report 2018-003 RA-18-072, Pressure and Temperature Limit Report Revision 12018-06-29029 June 2018 Pressure and Temperature Limit Report Revision 1 RA-18-066, Response to Questions Pertaining to Licensed Operator2018-06-18018 June 2018 Response to Questions Pertaining to Licensed Operator RA-18-070, Submittal of Sea Turtle Incidental Take Report 2018-001 on June 04, 20182018-06-0808 June 2018 Submittal of Sea Turtle Incidental Take Report 2018-001 on June 04, 2018 RA-18-068, Response to Request for Additional Information (RAI) Regarding Request for Approval of Decommissioning Quality Assurance Program, Revision 0 for Oyster Creek Nuclear Generating Station2018-06-0606 June 2018 Response to Request for Additional Information (RAI) Regarding Request for Approval of Decommissioning Quality Assurance Program, Revision 0 for Oyster Creek Nuclear Generating Station RA-18-065, Registration of Use of Cask to Store Spent Fuel2018-05-31031 May 2018 Registration of Use of Cask to Store Spent Fuel RA-18-059, Request for Relief and Rescission of Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events2018-05-30030 May 2018 Request for Relief and Rescission of Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events RA-18-055, 10 CFR 50.46 Annual Report2018-05-23023 May 2018 10 CFR 50.46 Annual Report RA-18-053, Update to Spent Fuel Management Plan2018-05-21021 May 2018 Update to Spent Fuel Management Plan RA-18-052, Supplement to Request for Exemption from 10 CFR 50.54(w)(1), Concerning On-Site Property Damage Insurance and Supplement to Request for Exemption from 10 CFR 140.11(a)(4), Concerning Primary and Secondary ...2018-05-0808 May 2018 Supplement to Request for Exemption from 10 CFR 50.54(w)(1), Concerning On-Site Property Damage Insurance and Supplement to Request for Exemption from 10 CFR 140.11(a)(4), Concerning Primary and Secondary ... RA-18-049, Registration of Use of Cask to Store Spent Fuel2018-05-0707 May 2018 Registration of Use of Cask to Store Spent Fuel RA-18-046, Oyster Creek, Transmittal of Annual Radiological Environmental Operating Report for 20172018-04-30030 April 2018 Oyster Creek, Transmittal of Annual Radiological Environmental Operating Report for 2017 RA-18-047, Annual Radioactive Effluent Release Report for 20172018-04-30030 April 2018 Annual Radioactive Effluent Release Report for 2017 RA-18-018, Submittal of Changes to Technical Specifications Bases2018-04-13013 April 2018 Submittal of Changes to Technical Specifications Bases RA-18-021, Request for Exemption from Record Retention Requirements2018-04-12012 April 2018 Request for Exemption from Record Retention Requirements RA-18-028, Request for Rescission of Commission Order Modifying License with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109)2018-04-12012 April 2018 Request for Rescission of Commission Order Modifying License with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe Accident Conditions (Order Number EA-13-109) RA-18-027, Request for Rescission of Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051)2018-04-12012 April 2018 Request for Rescission of Commission Order Modifying Licenses with Regard to Reliable Spent Fuel Pool Instrumentation (Order Number EA-12-051) RA-18-036, Response to Request for Additional Information (RAI) and Supplement Regarding License Amendment Request - Proposed Defueled Technical Specifications and Revised License Conditions for Permanently Defueled ...2018-03-29029 March 2018 Response to Request for Additional Information (RAI) and Supplement Regarding License Amendment Request - Proposed Defueled Technical Specifications and Revised License Conditions for Permanently Defueled ... RA-18-019, Request for Exemption from 10 CFR 50.54(w)(1), Concerning On-Site Property Damage Insurance2018-03-29029 March 2018 Request for Exemption from 10 CFR 50.54(w)(1), Concerning On-Site Property Damage Insurance RA-18-020, Request for Exemption from 1 O CFR 140.11 (a)(4), Concerning Primary and Secondary Liability Insurance2018-03-29029 March 2018 Request for Exemption from 1 O CFR 140.11 (a)(4), Concerning Primary and Secondary Liability Insurance RA-18-032, Revision to Commitments Relating to Resolution of Anchor Darling Double Disc Gate Valve Part 21 Issues2018-03-27027 March 2018 Revision to Commitments Relating to Resolution of Anchor Darling Double Disc Gate Valve Part 21 Issues RA-18-034, Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv)2018-03-22022 March 2018 Request for Exemption from 10 CFR 50.82(a)(8)(i)(A) and 10 CFR 50.75(h)(1)(iv) RA-18-015, Withdrawal of Application to Revise Technical Specifications to Implement BWRVIP-18, Revision 2-A and Relief Request for Extension of Torus Examinations2018-02-15015 February 2018 Withdrawal of Application to Revise Technical Specifications to Implement BWRVIP-18, Revision 2-A and Relief Request for Extension of Torus Examinations RA-18-014, Response to Request for Additional Information (RAI) and Supplemental Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Emergency Plan and Emergency Action Level Scheme2018-02-13013 February 2018 Response to Request for Additional Information (RAI) and Supplemental Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Emergency Plan and Emergency Action Level Scheme RA-18-008, Summary of Changes to Quality Assurance Topical Report, NO-AA-102018-02-0808 February 2018 Summary of Changes to Quality Assurance Topical Report, NO-AA-10 RA-18-010, Supplement to Relief Request for Extension of Torus Examinations2018-01-24024 January 2018 Supplement to Relief Request for Extension of Torus Examinations RA-17-086, Commitment Change Summary Report - 20172017-12-21021 December 2017 Commitment Change Summary Report - 2017 2019-09-12
[Table view] Category:Response to Request for Additional Information (RAI)
MONTHYEARML21168A0172021-06-10010 June 2021 E-mail from HDI: RAI Response ML21168A0182021-06-10010 June 2021 E-mail from HDI: RAI Response (Attachment) ML21120A1102021-04-30030 April 2021 Response to Request for Additional Information (RAI) - License Amendment Request to Approve the Oyster Creek Nuclear Generating Station Independent Fuel Storage Installation Only Emergency Plan ML20345A1462020-12-0909 December 2020 E-mail - Response to Request for Additional Information: HDI Request for One-Time Exemption from Part 73, Appendix B FOF Requirements RA-19-080, Response to Request for Additional Information (RAI) Related to Oyster Creek Nuclear Generating Station - Post-Shutdown Decommissioning Activities Report2019-10-18018 October 2019 Response to Request for Additional Information (RAI) Related to Oyster Creek Nuclear Generating Station - Post-Shutdown Decommissioning Activities Report ML19162A2242019-06-11011 June 2019 NRC to NMFS, NRC Responses to NMFS Requests for Additional Information for Oyster Creek ESA Section 7 Consultation RA-19-007, Response to RAI and Supplemental Information Re Request for Changing Emergency Preparedness License Amendment 294 Effective Date (Change to Adiabatic Heat-Up Calculation)2019-02-13013 February 2019 Response to RAI and Supplemental Information Re Request for Changing Emergency Preparedness License Amendment 294 Effective Date (Change to Adiabatic Heat-Up Calculation) RA-18-087, Response to Request for Additional Information (RAI) Related to Post-Shutdown Decommissioning Activities Report2018-09-24024 September 2018 Response to Request for Additional Information (RAI) Related to Post-Shutdown Decommissioning Activities Report RA-18-068, Response to Request for Additional Information (RAI) Regarding Request for Approval of Decommissioning Quality Assurance Program, Revision 0 for Oyster Creek Nuclear Generating Station2018-06-0606 June 2018 Response to Request for Additional Information (RAI) Regarding Request for Approval of Decommissioning Quality Assurance Program, Revision 0 for Oyster Creek Nuclear Generating Station RS-18-061, Response to Request for Additional Information Regarding Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (Isfsis)2018-05-0202 May 2018 Response to Request for Additional Information Regarding Decommissioning Funding Plans for Independent Spent Fuel Storage Installations (Isfsis) RA-18-014, Response to Request for Additional Information (RAI) and Supplemental Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Emergency Plan and Emergency Action Level Scheme2018-02-13013 February 2018 Response to Request for Additional Information (RAI) and Supplemental Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Emergency Plan and Emergency Action Level Scheme ML18011A0872018-01-30030 January 2018 Letter to Senator Cory Booker from Chairman Svinicki Regarding Constituent Questions Regarding the Decommissioning of Oyster Creek Nuclear Generating Station in Lacey Township, New Jersey - Enclosure RA-17-078, Response to Request for Additional Information (RAI) Regarding Request for Exemption from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E2017-12-0606 December 2017 Response to Request for Additional Information (RAI) Regarding Request for Exemption from Portions of 10 CFR 50.47 and 10 CFR Part 50, Appendix E RA-17-071, Response to Request for Additional Information (RAI) and Supplemental Information Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Condition2017-11-10010 November 2017 Response to Request for Additional Information (RAI) and Supplemental Information Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Condition RA-17-056, Response to Request for Additional Information (RAI) and Supplemental Information Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Condition2017-09-20020 September 2017 Response to Request for Additional Information (RAI) and Supplemental Information Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Condition RA-17-013, Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 3, Flooding Focused Evaluation Summary Submittal2017-04-28028 April 2017 Response to March 12, 2012, Request for Information Enclosure 2, Recommendation 2.1, Flooding, Required Response 3, Flooding Focused Evaluation Summary Submittal RS-17-053, Response to Request for Additional Information Regarding Generic Letter 2016-012017-04-27027 April 2017 Response to Request for Additional Information Regarding Generic Letter 2016-01 RA-16-093, Response to Request for Additional Information and Supplemental Information Regarding Proposed Changes to Technical Specifications Section 6.0 Administrative Controls for Permanently Defueled Condition2016-11-0202 November 2016 Response to Request for Additional Information and Supplemental Information Regarding Proposed Changes to Technical Specifications Section 6.0 Administrative Controls for Permanently Defueled Condition RA-16-065, Seventh Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No. EA-12-049)2016-08-26026 August 2016 Seventh Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order No. EA-12-049) RA-16-058, Response to Request for Additional Regarding Approval of Certified Fuel Handler Training Program2016-06-0808 June 2016 Response to Request for Additional Regarding Approval of Certified Fuel Handler Training Program RA-16-049, Response to Request for Additional Information Regarding Requests to Withhold Emergency Preparedness Documents from Public Disclosure2016-05-26026 May 2016 Response to Request for Additional Information Regarding Requests to Withhold Emergency Preparedness Documents from Public Disclosure NEI 12-01, Response to March 12, 2012, Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency..2016-05-11011 May 2016 Response to March 12, 2012, Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendations of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident, Enclosure 5, Recommendation 9.3, Emergency.. RA-16-017, Supplemental Response to Nrg Audit Review Request for Additional Information Regarding Fukushima Lessons Learned - Flood Hazard Reevaluation Report2016-04-15015 April 2016 Supplemental Response to Nrg Audit Review Request for Additional Information Regarding Fukushima Lessons Learned - Flood Hazard Reevaluation Report RA-16-029, Response to Request for Additional Information Regarding Preliminary Decommissioning Cost Estimate2016-04-0505 April 2016 Response to Request for Additional Information Regarding Preliminary Decommissioning Cost Estimate RA-16-008, Response to Request for Additional Information Regarding Request for Extension to Comply with Phase 2 of NRC Order EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe..2016-02-15015 February 2016 Response to Request for Additional Information Regarding Request for Extension to Comply with Phase 2 of NRC Order EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under Severe.. RA-15-091, High Frequency Supplement to Seismic Hazard Screening Report, Response to NRC Request for Information, Per 10CFR50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident2015-12-0404 December 2015 High Frequency Supplement to Seismic Hazard Screening Report, Response to NRC Request for Information, Per 10CFR50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident RA-15-057, Supplemental Response to Request for Additional Information Regarding Request for Extension to Comply with NRC Order EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under..2015-10-0101 October 2015 Supplemental Response to Request for Additional Information Regarding Request for Extension to Comply with NRC Order EA-13-109: Order Modifying Licenses with Regard to Reliable Hardened Containment Vents Capable of Operation Under.. 2021-06-10
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Michael P. Gallagher Exelon Nuclear Exelon Generation Vice President License Renewal and Decommissioning 200 Exelon Way Kennett Square, PA 19348 610 765 5958 Office 610 765 5658 Fax www.exeloncorp.com m1chaelp.gallagher@exeloncorp com 10 CFR 50.54(a)(4)
RA-18-068 June 6, 2018 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15
Subject:
Response to Request for Additional Information (RAI) Regarding Request for Approval of Decommissioning Quality Assurance Program, Revision O for Oyster Creek Nuclear Generating Station
Reference:
- 1) Letter from Michael P. Gallagher, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Request for Approval of Decommissioning Quality Assurance Program, Revision 0 for Oyster Creek Nuclear Generating Station," dated November 30, 2017 (ML17334A798)
- 2) U.S. Nuclear Regulatory Commission Electronic Mail Request to David Helker, et al., (Exelon Generation Company, LLC) - Draft RAI for Oyster Creek DQAP (EPID: L-2017-LLQ-003), dated May 4, 2018
- 3) U.S. Nuclear Regulatory Commission Electronic Mail Request to David Helker (Exelon Generation Company, LLC) - RAls - Oyster Creek -
Request Approval of the Decommissioning Quality Assurance Program (EPID: L-2017-LLQ-0003), dated May 15, 2018 (ML18135A073)
By letter dated November 30, 2017 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a proposed Decommissioning Quality Assurance Program (DQAP) for U.S. Nuclear Regulatory Commission (NRC) review and approval in preparation for the transition of the Oyster Creek Nuclear Generating Station (OCNGS) to a permanent defueled condition.
Subsequently, in an electronic mail request dated May 4, 2018 (Reference 2), the NRC issued a draft Request for Additional Information (RAI) indicating that it had reviewed the information submitted in the Reference 1 letter and that additional clarifying information was needed to support its continued review. The draft RAI in Reference 2 was further discussed during a teleconference between Exelon and NRC representatives held on May 14, 2018. As a result of the discussions, it was determined that no modification to the draft RAI was needed and the
U.S. Nuclear Regulatory Commission Response to Request for Additional Information Docket Nos. 50-219 and 72-15 June 6, 2018 Page 2 NRC subsequently issued a formal RAI via electronic mail on May 15, 2018 (Reference 3), and requested a response within 30 days of the date of this electronic mail message.
Accordingly, Attachment 1 of this letter provides Exelon's responses to the NRC's RAI in support of this DQAP request. Attachment 2 provides the clean copy of the DQAP pages. The DQAP pages being submitted in this letter supersede in entirety those pages previously submitted in Reference 1 .
There are no regulatory commitments contained in this submittal.
If you have any questions concerning this submittal, please contact Paul Bonnett at (610) 765-5264.
Respectfully, Michael P. Gallagher Vice President, License Renewal & Decommissioning Exelon Generation Company, LLC : Response to NRC's Request for Additional Information : Clean Replacement Pages - Decommissioning Quality Assurance Program (DQAP) cc: w/Attachments Regional Administrator - NRC Region I NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Project Manager, NRA - Oyster Creek Nuclear Generating Station Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ
U.S. Nuclear Regulatory Commission Response to Request for Additional Information Docket Nos. 50-219 and 72-15 June 6, 2018 Page 3 bee: w/o Attachments Senior Vice President Mid-Atlantic Operations Site Vice President - Oyster Creek Nuclear Generating Station Plant Manager - Oyster Creek Nuclear Generating Station Director, Operations - Oyster Creek Nuclear Generating Station Director, Training - Oyster Creek Nuclear Generating Station wlAttachments Senior Manager, Decommissioning - Cantera Site Decommissioning Director - Oyster Creek Nuclear Generating Station Regulatory Assurance Manager - Oyster Creek Nuclear Generating Station Manager, Licensing and Regulatory Affairs - KSA Director, Emergency Preparedness - Cantara Records Management - KSA Commitment Tracking Coordinator - East
Attachment 1 Response to NRC's Request for Additional Information Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-1 of A1-3
SUMMARY
By letter dated November 30, 2017 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a proposed Decommissioning Quality Assurance Program (DQAP) for U.S. Nuclear Regulatory Commission (NRC) review and approval in preparation for the transition of the Oyster Creek Nuclear Generating Station (OCNGS) to a permanent defueled condition.
Subsequently, in an electronic mail request dated May 4, 2018 (Reference 2), the NRC issued a draft Request for Additional Information (RAI) indicating that it had reviewed the information submitted in the Reference 1 letter and that additional clarifying information was needed to support its continued review. The draft RAI in Reference 2 was further discussed during a teleconference between Exelon and NRC representatives held on May 14, 2018. As a result of the discussions, it was determined that no modification to the draft RAI was needed and the NRC subsequently issued a formal RAI via electronic mail on May 15, 2018 (Reference 3), and requested a response within 30 days of the date of this electronic mail message.
Accordingly, this attachment provides Exelon's responses to the NRC's RAI in support of this DQAP request. Attachment 2 provides the clean copy of the DQAP pages. The DQAP pages being submitted in this letter supersede in entirety those pages previously submitted in Reference 1.
RESPONSE TO RAI QUESTIONS RAl-OC-1 Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix B, Criterion XVIII "Audits," requires, in part, that audits shall be performed in accordance with written procedures or check lists by appropriate trained personnel not having direct responsibilities in the areas being audited .
Exelon DQAP Section 1, "Organization," and Section 18, "Audits," does not clearly articulate how personnel within the Nuclear Oversight (NOS) organization will only conduct audits in areas within the scope of the DQAP with no direct responsibilities.
Clarify how the DQAP meets the above requirement.
Exelon's Response to RAl-OC-1:
Section 1.2.1 describes the management position responsible for Nuclear Oversight. That description requires Nuclear Oversight personnel reporting to that management position to have sufficient authority and organizational freedom to identify any quality problems and to verify implementation of corrective actions. The wording also requires Nuclear Oversight personnel to have direct access to appropriate levels of management necessary to perform their function independent from cost and schedule. While Exelon believes that this adequately defines the independence of the Nuclear Oversight personnel, Exelon would propose to clarify and reinforce this information with the following additional wording in Section 18.1 highlighted in bold italics below:
18.1. Measures shall be established for a system of planned and documented audits in order to verify compliance with all aspects of the DQAP, and determine the effective implementation of programs covered by the DQAP. Internal and supplier audits are conducted in accordance with written procedures or checklists. Audit personnel shall not have direct responsibilities in the areas to be audited.
Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-2 of A1-3 RAl-OC-2 The regulation 10 CFR Part 50, Appendix B, Criterion XII, "Control of Measuring and Test Equipment [M&TE]," requires measures to be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits. Criterion XV, "Nonconforming Materials, Parts, or Components," requires, in part, that procedures be established, as appropriate, for the identification, documentation, segregation, disposition, and notification to affected organizations of nonconforming parts or components.
NUREG-1536, "Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility," Revision 1, Chapter 14, "Quality Assurance Evaluation," Section 14.5.12.e, "Control of Measuring and Test Equipment," requires measures to document the assessment of the validity of previous inspections when M&TE equipment is found out of calibration and take control of the out of calibration equipment.
Exelon DQAP Section 12, "Control of Measuring and Test Equipment," does not clearly articulate how gages and instruments within the DQAP M&TE program will be documented and assessed for potential extent of condition issues after an out-of-calibration condition is identified.
Specifically, use of out-of-calibration M&TE could result in a nonconforming condition of components in which the M&TE was previously used for maintenance or testing of important to safety components. Therefore, procedures should be in place to identify and evaluate the potential for such nonconforming conditions.
Clarify how the DQAP meets the above requirement.
Exelon's Response to RAl-OC-2:
Section 12. 7 requires, in part, that out-of-calibration M&TE be processed in accordance with approved procedures. Exelon's standard governance for processing M&TE found out-of-calibration includes guidance for evaluation of components in which work was previously performed with the suspect equipment consistent with American Society of Mechanical Engineers (ASME) standard NQA-1, "Quality Assurance Requirements for Nuclear Facility Applications,"
and other industry standards.
To clarify this requirement in the DQAP document, Exelon would propose adding the following additional wording in Section 12.7 highlighted in bold italics below:
- 12. 7 M& TE which is found to be damaged, out-of-calibration or for which accuracy is suspect, shall be tagged and segregated and processed in accordance with approved procedures.
When M& TE is found to be out-of-tolerance, an evaluation is made of its previous uses to determine corrective action.
RAl-OC-3 The regulation 10 CFR Part 50, Appendix B, Criterion II, "Quality Assurance Program," requires, in part, a regular review of the status and adequacy of the quality assurance (QA) program.
NUREG-1757, "Decommissioning Plans: Process for Material Licensees," Vol. 1, Revision 2, Section 17.6.2, "Quality Assurance Program," requires, in part, a description of how management (above or outside the QA organization) regularly assess the scope, status, adequacy, and compliance of the QA program.
Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-3 of A1-3 Exelon DQAP Section 2, "Quality Assurance Program," removes the requirement of Independent Reviews per American National Standards Institute (ANSI) N18.7-1976.
Clarify how the DQAP meets the above requirement.
Exelon's Response to RAl-OC-3:
Exelon is not committing to meet the requirements of ANS-3.2, ANSI N18.7-1976 or subsequent revisions of the standard. This standard is clearly written to address Administrative Controls and QA for the Operational Phase of Nuclear Power Plants. The Operational Phase is defined in Section 2 of the document as the period of time during which the principal activity is associated with normal operation of the plant. The phase ends with plant decommissioning. The Exelon DQAP reflects the requirements of NQA-1, Basic Requirement 2, in that it requires management of organizations implementing the QA program to regularly assess the adequacy for that part of the program for which they are responsible and assure effective implementation. In addition, the DQAP reflects requirements of NQA-1, Basic Requirement 18, for planned and scheduled audits to verify compliance with all aspects of the QA Program.
To clarify this requirement in the DQAP document, Exelon would propose adding the following additional wording in Appendix D, General Administrative Requirements, highlighted in bold italics below:
Appendix D General Administrative Requirements D.5. Safety Review Committee D.5.1. The Safety Review Committee (SRC) serves the CNO as an on-site review body that performs procedure and program reviews for decommissioning activities and ISFSI operation as necessary on matters of Nuclear Safety. Details regarding the membership, quorum, agenda, and meeting schedule are contained in implementing procedures.
REFERENCES:
- 1) Letter from Michael P. Gallagher, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "Request for Approval of Decommissioning Quality Assurance Program, Revision O for Oyster Creek Nuclear Generating Station," dated November 30, 2017 (ML17334A798)
- 2) U.S. Nuclear Regulatory Commission Electronic Mail Request to David Helker, et al.,
(Exelon Generation Company, LLC) - Draft RAI for Oyster Creek DQAP (EPID: L-2017-LLQ-003), dated May 4, 2018
- 3) U.S. Nuclear Regulatory Commission Electronic Mail Request to David Helker (Exelon Generation Company, LLC) - RAls - Oyster Creek - Request Approval of the Decommissioning Quality Assurance Program (EPID: L-2017-LLQ-0003), dated May 15, 2018 (ML18135A073)
Attachment 2 Clean Replacement Pages - Decommissioning Quality Assurance Program (DQAP)
12.6. Calibration reference standards shall be based on nationally recognized standards or accepted values of natural physical constants. Where national standards do not exist, the basis for the calibration shall be documented.
Special calibration and control measures are not required when normal commercial practices provide adequate accuracy (e.g., rulers, tape measures, levels, and other such devices).
- 12. 7. M&TE which is found to be damaged, out-of-calibration or for which accuracy is suspect, shall be tagged and segregated and processed in accordance with approved procedures. When M&TE is found to be out-of-tolerance, an evaluation is made of its previous uses to determine corrective action.
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- 18. AUDITS 18.1 . Measures shall be established for a system of planned and documented audits in order to verify compliance with all aspects of the DQAP, and determine the effective implementation of programs covered by the DQAP.
Internal and supplier audits are conducted in accordance with written procedures or checklists. Audit personnel shall not have direct responsibilities in the areas to be audited.
18.2. The internal audit program is conducted on a performance driven frequency that is commensurate with the status and importance of the activity to be completed but does not exceed 24-months, unless otherwise required by regulation. Audits may be extended beyond their originally scheduled due date based on the following criteria:
A. Audits shall be performed at the intervals designated and the schedules are based on the month in which the audit starts.
- 8. A maximum extension not to exceed 25 percent of the audit interval is allowed unless restricted by regulation .
C. When an audit interval extension greater than one month is used, the next audit for that particular audit area is scheduled from the original anniversary month rather than from the month of the extended audit.
D. Item 8 applies to supplier audits and evaluations except that a total combined interval for any three (3) consecutive inspection or audit intervals does not exceed 3.25 times the specified inspection or audit interval.
18.3. Audit scheduling, preparation, personnel selection, personnel qualification, performance, reporting, response, follow-up, and records management for audits are performed in accordance with written procedures. Audit scopes and schedules are based upon the status of work progress, activities being performed, regulatory requirements, and/or experience with the organization being audited. An audit schedule shall be maintained, reviewed, and revised as necessary at least annually, to ensure that programs receive necessary audits to support regulatory compliance.
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Appendix D Page 2 of 2 GENERAL ADMINISTRATIVE REQUIREMENTS D.3. Services D.3.1. The Company procures services from qualified suppliers. It is not necessary that these suppliers have a quality assurance program approved by the licensee, however, suppliers should provide a quality assurance program that includes the quality assurance program elements presented in Regulatory Guide 4.15, Quality Assurance for Radiological Monitoring Programs (Normal Operations) - Effluent Streams and the Environment, and routinely provide program data summaries sufficiently detailed to permit evaluation of the program for the following areas:
- Radiological environmental monitoring.
D.4. License Renewal D.4.1. Consistent with the requirements of 10 CFR 54.21 (a)(3), the Company implements the requirements of DQAP Section 1 through 18 for aging management activities related to safety related SSCs as described by licensing documents for those systems that remain active.
D.4.2. Additionally, to manage the aging effects of non-safety related SSCs that were determined to be within the scope of License Renewal, the Company implements the administrative controls, corrective actions and confirmation processes described in DQAP Sections 6, 16 and the applicable requirements of this appendix.
D.5. Safety Review Committee D.5.1. The Safety Review Committee (SAC) serves the CNO as an on-site review body that performs procedure and program reviews for decommissioning activities and ISFSI operation as necessary on matters of Nuclear Safety.
Details regarding the membership, quorum, agenda, and meeting schedule are contained in implementing procedures.
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