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MONTHYEARML1006200112010-02-25025 February 2010 Oyster Creek, License Amendment Request, Changes to Trunnion Room Secondary Containment Boundary Project stage: Other ML1008200062010-03-23023 March 2010 E-mail, Miller, NRR, to Gropp, Exelon, Acceptance Review for Trunion Room LAR Project stage: Acceptance Review ML1016806172010-06-18018 June 2010 Electronic Transmission, Draft Request for Additional Information Regarding License Amendment Request to Allow Temporary Changes to Secondary Containment Boundary During Shutdown Conditions Project stage: Draft RAI RA-10-059, Response to Draft Request for Additional Information - License Amendment Request to Allow Changes to Secondary Containment Boundary During Shutdown Conditions2010-07-0909 July 2010 Response to Draft Request for Additional Information - License Amendment Request to Allow Changes to Secondary Containment Boundary During Shutdown Conditions Project stage: Draft Request RA-10-079, Supplemental Information Regarding License Amendment Request to Allow Changes to Secondary Containment Boundary During Shutdown Conditions2010-10-14014 October 2010 Supplemental Information Regarding License Amendment Request to Allow Changes to Secondary Containment Boundary During Shutdown Conditions Project stage: Supplement RA-10-080, Supplemental Information Regarding License Amendment Request to Allow Changes to Secondary Containment Boundary During Shutdown Conditions2010-10-15015 October 2010 Supplemental Information Regarding License Amendment Request to Allow Changes to Secondary Containment Boundary During Shutdown Conditions Project stage: Supplement ML1024305512010-10-18018 October 2010 Issuance of Amendment Secondary Containment Boundary Definition During Shutdown Conditions Project stage: Approval 2010-02-25
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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
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Text
Exelon Nuclear wwwexeloncorp.com Exelon.
200 Exelon Way Nuclear Kennett Square, PA 19348 10 CFR 50.90 RA-10-059 July 9,2010 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 Docket No. 50-219
Subject:
Response to Draft Request for Additional Information - License Amendment Request to Allow Changes to Secondary Containment Boundary During Shutdown Conditions
References:
- 1) Letter from Pamela B. Cowan to U.S. Nuclear Regulatory Commission License Amendment Request - Changes to Trunnion Room Secondary Containment Boundary, dated February 25, 2010
- 2) U.S. Nuclear Regulatory Commission facsimile dated June 18,2010, Oyster Creek Nuclear Generating Station - Electronic Transmission, Draft Request for Additional Information Regarding License Amendment Request to Allow Temporary Changes to Secondary Containment Boundary During Shutdown Conditions (TAC No. ME3475)
By letter dated February 25, 2010 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a request to revise the Oyster Creek Nuclear Generating Station (OCNGS) Technical Specifications (TS) to allow the Reactor Building Secondary Containment associated with the Trunnion Room boundary to be relocated on a temporary basis during Cold Shutdown conditions to support refueling and maintenance outage related activities.
Subsequently, on June 18,2010, the U,S. Nuclear Regulatory Commission (NRC) issued a draft Request for Additional Information (RAI) via facsimile (Reference 2). The NRC identified three questions in the draft RAI in which additional information was requested regarding the design of penetration seals and the proposed ventilation system testing in the temporary configuration.
The attachment to this letter restates the NRC's questions followed by Exelon's response.
Exelon has concluded that the information provided in this response does not impact the conclusions of the: 1) Technical Analysis, 2) No Significant Hazards Consideration under the standards set forth in 10 CFR 50.92(c), or 3) Environmental Consideration as provided in the original submittal (Reference 1).
U.S. Nuclear Regulatory Commission License Amendment Request Trunnion Room Secondary Containment Boundary Response to NRC RAJ Docket No. 50-219 July 9,2010 Page 2 There are no regulatory commitments contained in this submittal.
Should you have any questions concerning this letter, please contact Mr. Richard Gropp at (610) 765-5557.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 9th day of July 2010.
Respectfully, Pamela B. Cowan Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC
Attachment:
Response to NRC Draft Request for Additional Information cc: Regional Administrator - NRC Region I NRC Senior Resident Inspector - OCNGS NRC Project Manager, NRR - OCNGS Director, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection
ATTACHMENT Oyster Creek Nuclear Generating Station License Amendment Request Response to NRC Draft Request for Additional Information Changes to Trunnion Room Secondary Containment Boundary During Shutdown Conditions
Attachment License Amendment Request Trunnion Room Secondary Containment Boundary Response to Draft RAJ Page 1 of 3
Background
By letter dated February 25, 2010 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a request to revise the Oyster Creek Nuclear Generating Station (OCNGS) Technical Specifications (TS) to allow the Reactor Building Secondary Containment boundary associated with the Trunnion Room to be relocated from the Trunnion Room outer wall and door, to the Reactor Building inner walls and penetrations located inside the Trunnion Room. The proposed changes would be instituted on a temporary basis during Cold Shutdown conditions in order to support refueling and maintenance outage related activities.
By facsimile on June 18, 2010 (Reference 2), the U.S. Nuclear Regulatory Commission (NRC) transmitted draft Request for Additional Information (RAJ) questions related to this proposed TS change. The NRC identified three questions in the draft RAJ in which additional information was requested regarding the design of penetration seals and the proposed ventilation system testing in the temporary configuration. Each of the NRC's questions are identified below followed by Exefon's response.
NRC Question 1 The license amendment request (LAR) states that "engineered designed closure mechanisms" will be used to ensure that penetrations are closed and secured. Provide a description of the closure mechanisms to be used including their construction materials and the method for attachment to the penetrations.
Response
A review of the applicable plant drawings confirms the existence of four known penetrations inside the Trunnion Room. These penetrations include: 1) a floor/deck drain, 2) a piping penetration/hub drain, 3) a ventilation return duct; and 4) a floor ventilation supply opening.
The identified Heating, Ventilation and Air Conditioning (HVAC) penetrations (i.e., ventilation return duct and floor ventilation supply opening) will be sealed and secured using a formed sheet metal cover (comparable gauge), screws, and suitable sealant compound. These temporary alterations to the identified HVAC penetrations will be designed in accordance with applicable guidance specified in the American Society of Heating, Refrigerating, and Air-Conditioning Engineers (ASHRAE) handbook.
The identified floor/deck drain will be isolated by using a mechanical plug containing a rubber gasket that is rated to withstand the Reactor Building differential pressure conditions that could be encountered.
The identified piping penetration/hub drain will be isolated by using a customized rubber cover
/boot cut-to-fit due to the multiple pipes routed in this floor penetration. The cover will be attached to the piping in this penetration using mechanical hose c1amp(s). The rubber material and clamps used will have the proper mechanical properties to withstand the Reactor Building differential pressure conditions that could be encountered.
Attachment License Amendment Request Trunnion Room Secondary Containment Boundary Response to Draft RAI Page 2 of 3 The materials used in the above applications will be procured and dedicated as "augmented quality," which will require receipt inspection in accordance with OCNGS's quality assurance procurement process. It should be noted that the methods discussed above for sealing and securing the identified penetrations in the Trunnion Room might be modified or substituted if a better closure technique is developed.
In addition, if other penetrations are sUbsequently identified in the Trunnion Room that require sealing they will be appropriately evaluated, isolated, and secured in a manner similar to the criteria discussed above based on the configuration and material composition of the penetration.
NRC Question 2 The wording for proposed Technical Specification (TS) 4.5.G.3 indicates that following movement of the Secondary Containment boundary to the inner walls of the Trunnion room Standby Gas Treatment System testing shall be performed. It is unclear what testing is required by this Specification. Clarify what testing is to be performed and how the proposed TS, as worded, adequately defines this testing.
Response
The Secondary Containment capability periodic test (Le., TS Surveillance Requirement 4.5.G.2) will be performed on the normal Reactor Building pressure boundary prior to installation of the temporary modification. Following achieving Cold Shutdown, the proposed temporary modification to the Trunnion Room Secondary Containment boundary will be installed. Post maintenance testing for the installation will be the operation of the Standby Gas Treatment System (SGTS) to assure that a negative pressure (i.e., greater than or equal to 0.25" of water vacuum) can be established in the Reactor Building with the modified boundary configuration for the Trunnion Room. For the entire duration that the temporary modification is in place, daily observations will be performed to ensure that the penetrations are sealed and secure and the modified boundary remains intact. Periodic testing will be accomplished by performance of normally scheduled SGTS operability testing which verifies that a minimum of 0.25" water vacuum can be established. Therefore, performing initial and periodic SGTS operability testing following installation of the temporary modification, will ensure that Secondary Containment integrity is maintained in accordance with applicable Limiting Condition for Operation (LCO) requirements specified in TS 3.5.G, "Secondary Containment."
NRC Question 3 The proposed change to TS 4.5.G does not appear to ensure that the periodic capability test includes the normal reactor bUilding pressure boundary with regards to the Trunnion room. The current requirements of Section 4.5.G would appear to allow the cold shutdown, prior to refueling, capability test to be counted as the periodic, at least once per operating cycle, test if performed under calm wind conditions. Would the proposed change aI/ow the cold shutdown, prior to refueling, test with the altered reactor building ventilation boundary to be used to satisfy the periodic test requirement?
Attachment License Amendment Request Trunnion Room Secondary Containment Boundary Response to Draft RAJ Page 3 of 3
Response
No. The proposed changes to temporarily modify the Secondary Containment boundary for the Trunnion Room will not affect the requirements of TS Section 4.5.G. The Secondary Containment capability periodic test (Le., TS Surveillance Requirement 4.5.G.2) will continue to be performed on the normal Reactor Building pressure boundary. As discussed in response to Question 2 above, once the temporary modifications are made to the Trunnion Room Secondary Containment boundary, initial and periodic SGTS operability tests will be conducted to ensure that the Reactor Building can be maintained at a minimum of 0.25" water vacuum. A post-modification visual inspection will be performed to confirm that the temporary covers installed on the penetrations/openings have been appropriately removed and that the Trunnion Room Secondary Containment boundary has been returned to the normal configuration (Le.,
outer walls and door).
References
- 1. Letter from Pamela B. Cowan to U.S. Nuclear Regulatory Commission License Amendment Request - Oyster Creek Nuclear Generating Station Changes to Trunnion Room Secondary Containment Boundary, dated February 25, 2010
- 2. U.S. Nuclear Regulatory Commission facsimile dated June 18, 2010, Oyster Creek Nuclear Generating Station - Electronic Transmission, Draft Request for Additional Information Regarding License Amendment Request to Allow Temporary Changes to Secondary Containment Boundary During Shutdown Conditions (TAC No. ME3475)