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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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COMMENT RESOLUTION:
Your submittal dated March 16, 2021 (ADAMS Accession No. ML21075A337) contained the following language (or concept) that was used in the Safety Evaluation Report. The comments to be resolved appear as bullets following the highlighted text.
HDI ClarificationBasis for the request to amend the OCNGS Renewed Facility License and Associated Technical Specifications:
Once all spent fuel assemblies have been transferred to dry cask storage on the ISFSI pad, several decommissioning plants currently in the decommissioning process, including Kewaunee (ML15261A236), Crystal River Unit 3 (ML16243A249), Vermont Yankee (ML17206A200), San Onofre Units 2 and 3 (ML16355A014) and Fort Calhoun (ML18275A323) have revised the Post Defueled Technical Specifications to reflect the requirements for ISFSI only decommissioning. The precedence in these applications as well as the NRC Safety Evaluation Reports approving these applications provided the basis for HDIs proposed amendment to the OCNGS Renewed Facility Operating License and associated Technical Specifications.
License Condition 2.C.(16)
The licensee proposed to delete this license condition in its entirety. This license condition involves management of license renewal application (LRA) commitments. The purpose of these LRA commitments was to ensure that the aging effects of equipment important to the safe operation of the reactor are managed so that the functionality of SSCs are maintained during the facility's period of extended operation. In letter dated March 9, 2009 (ADAMS Accession No. ML090720894), Exelon documented that it had completed implementation of commitments that were required by April 2009 for Oyster Creek and entering the period of extended operation.
For a permanently shutdown facility where all spent fuel has been located within the ISFSI, most of the equipment subject to aging management programs are no longer in use and functionality does not need to be maintained. However, during decommissioning some equipment, such as for equipment related to the fire protection system to address fire events that could result in radiological hazards per the requirements of 10 CFR 50.48(f), may be required beyond the permanent cessation of operations and therefore may be subject to an aging management program.
NRC Clarification Request 1)
- This section is a little confusing and hard to follow. We say here that equipment related to fire protection may be required beyond permanent cessation of operations. But later we conclude that there is no equipment needing aging management. We also say that these commitments were moved to the DSAR.
HDI Clarification for Request 1:
The highlighted paragraph above (found on page 9 of 36 of the Enclosure to HDI-OC 021) is intended to demonstrate that following permanent shutdown most Systems, Structures and Components (SSCs) that are needed for safe of operation of the reactor are no longer in use and their functionality is no longer necessary, and therefore the
aging management commitments are no longer applicable. However, during decommissioning, are there may be some SSCs that, due to potential radiological hazards, may continue to be subjected to aging management commitments. At permanent cessation of operations, the OCNGS SSCs were evaluated and assessed using 10 CFR 50.59 and 10 CFR 54.21 to determine those SSCs that, after permanent shutdown, remained subject to aging management commitments. OCNGS UFSAR Revision 21, submitted to NRC on October 15, 2019 was a complete revision of the UFSAR issued to reflect the Post Defueled Technical Specifications (ML18227A338) and was renamed as Revision 0 of the Decommissioning Safety Analysis Report (DSAR) . The Aging Management Programs including LRA commitments are included in DSAR, and specific SSCs are identified in DSAR Appendix A. The OCNGS commitments for aging management will continue to be maintained in the DSAR and updated in accordance with 10 CFR 50.71(e). Changes to these aging management commitments continue to be evaluated in accordance with 10 CFR 50.59 In addition, all fire protection requirements associated with 10 CFR 50.48(f) are in compliance with the regulations and are controlled within the OCNGS fire protection program and therefore do not require separate aging management requirements.
In summary, the Aging Management Program and LRA commitments included in the OCNGS DSAR remain in compliance with the licensing basis for the OCNGS Renewed Facility License. Changes to the program and LRA commitments are reviewed in accordance with the 10 CFR 50.59 regulations.
NRC Request for Clarification 2:
HDI Clarification for Request 2:
Upon NRC approval of License Renewal in September 2008 (Safety Evaluation Report and Supplements Accession Nos. ML062300330, ML063630424, ML070890637 and ML080230078), and Exelon completion of the implementation of the commitments in April 2009, OCNGS entered the period of extended operation. At that time, consistent with 10 CFR 50.71(e), the Aging Management Program and License Renewal Amendment (LRA) commitments were included in the OCNGS UFSAR. As discussed previously, following permanent shutdown, the UFSAR was revised to reflect the Post Defueled Technical Specifications (ML18227A338) and was renamed as Revision 0 of the Decommissioning Safety Analysis Report (DSAR).
As explained previously, all fire protection requirements associated with 10 CFR 50.48(f) are controlled within the OCNGS fire protection program and therefore do not require separate aging management requirements.
Prior to cessation of operations, Oyster Creek LRA commitments for aging management were incorporated into Appendix A, "Defueled Safety Analysis Report Supplement (Aging Management), of the DSAR, which is updated in accordance with 10 CFR 50.71(e). Changes to these license renewal commitments continue to be evaluated and controlled pursuant to the change review requirement criteria identified 10 CFR 50.59 and 10 CFR 50.71(e). On this basis, the NRC staff has previously found that update and or removal of license renewal
commitments identified in the DSAR acceptable per the established controls provided for maintaining the DSAR.
NRC Request for Clarification 3:
- Was this a previous amendment? If so, please add the date and ML# for the amendment.
HDI Clarification for Request 3:
The changes to eliminate the license condition for the license renewal commitments due to the inclusion of the commitments in the DSAR is based on the previous precedence for relocating administrative requirements to either the QA plan or other licensee-controlled documents and controlling them in accordance with 10 CFR 50.54(a), 10 CFR 50.71(e), 10 CFR 50.48(f) and 10 CFR 50.59. The precedence for this that was considered in the OCNGS requested amendment includes the Fort Calhoun request for amendment to the FCS Renewed Facility License and associated Technical Specifications to reflect the requirements for ISFSI only decommissioning (ML18275A323 request for amendment and ML19297D674 NRC Safety Evaluation Report).
There is no other equipment meeting the requirements of the aging management program that is needed in the ISFSI only facility condition. The spent fuel storage cask systems located in an ISFSI are subject to their own Certificate of Compliance and Cask Technical Specification requirements. These cask protection requirements are not referenced or identified by License Condition 2.C.(16). On this basis, the NRC staff finds the deletion of the aging management license condition acceptable.
NRC Request for Clarification 4:
- See comment above. Is fire equipment aging management an issue? If so, how is it being handled.
HDI Clarification for Request 4:
All fire protection requirements associated with 10 CFR 50.48(f) are controlled within the OCNGS fire protection program and therefore do not require separate aging management requirements.