Text

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
	ML17263A066
Person / Time
Site:	Oyster Creek
Issue date:	09/20/2017
From:	Gallagher M; Exelon Generation Co
To:	; Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
	CAC MF9352, RA-17-056
	Download: ML17263A066 (18)
	v • d • e

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 michaelp.gallagher@exeloncorp.com 10 CFR 50.90 10 CFR 50.54(q)

RA-17-056 September 20, 2017 U.S. Nuclear Regulatory Commission A TIN: 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) and Supplemental Information Regarding License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Condition

Reference:

1) Letter from Michael P. Gallagher (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "License Amendment Request -

Proposed Changes to the Oyster Creek Emergency Plan for Permanently Oefueled Condition, "dated February 28, 2017, RA-17-012 (ML17060A289)

2) Letter from U.S. Nuclear Regulatory Commission to Bryan C. Hanson (Exelon Generation Company, LLC) - "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 Oefueled Condition (CAC NO. MF9352)," dated September 14, 2017(ML17208A747)

By letter dated February 28, 2017 (Reference 1), Exelon Generation Company, LLC (Exelon) submitted a License Amendment Request (LAR) for Oyster Creek Nuclear Generating Station (OCNGS) . The proposed amendment would revise the site emergency plan (SEP) for the permanently shutdown and defueled condition.

In Reference 2, the U.S. Nuclear Regulatory Commission (NRC) requested additional information (RAI) to support review of the proposed changes. The NRC is requesting that Exelon respond to the RAI within 30 days of the date of the Reference 2 letter.

Accordingly, Attachment 1 of this letter provides Exelon's response to the NRC's RAI and includes supplemental information in support of this amendment request. Attachment 2 includes the revised pages to the proposed OCNGS Emergency Plan "Table OCNGS 8-1 :

U.S. Nuclear Regulatory Commission Response to Request for Additional Information and Supplemental Information to OCNGS License Amendment Request Docket Nos. 50-219 and 72-15 September 20, 2017 Page 2 Minimum Staffing Requirements," (replace pages B-38 through B-40). Attachment 3 includes the revised Commitment to include comments from the New Jersey Department of Environmental Protection Bureau of Nuclear Engineering.

Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRC in Reference 1. The additional information provided in this submittal does not affect the previously stated bases in Reference 1 for concluding that the proposed license amendment does not involve a significant hazards consideration. In addition, the information provided in this submittal does not affect the bases for concluding that neither an environmental impact statement nor an environmental assessment needs to be prepared in connection with the proposed amendment.

The proposed changes are being submitted to the NRC for approval prior to implementation, as required under 10 CFR 50.54(q)(4).

If you have any questions concerning this submittal, please contact Paul Bonnett at (610) 765-5264.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 201h day of September 2017.

Respectfully, Michael P. Gallagher Vice President, License Renewal & Decommissioning Exelon Generation Company, LLC Attachments: 1. Response to NRC's Request for Additional Information and Supplemental Information

2. Revised Marked-Up Pages for OCNGS Emergency Plan "Table OCNGS B-1: Minimum Staffing Requirements"

3. Revised Summary of Regulatory Commitments cc: w/Attachment Regional Administrator - NRC Region I NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station Director, Bureau of Nuclear Engineering - New Jersey Department of Environmental Protection Mayor of Lacey Township, Forked River, NJ

Attachment 1 Response to NRCs Request for Additional Information and Supplemental Information Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-1

SUMMARY

By letter dated February 28, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17060A289) (Reference 1), 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).

Subsequently, in a letter dated September 14, 2017 (Reference 2), the NRC request additional information (RAI) to support its review of the proposed changes. The NRC has requested that Exelon respond to the RAI within 30 days of the date of the Reference 2 letter.

Accordingly, this attachment provides Exelons response to the RAI questions contained in the Reference 2 letter. The specific questions are identified below followed by Exelon's response.

Exelon is providing information to supplement the License Amendment Request (LAR) as contained in the Attachments 2 and 3 of this submittal. Attachment 2 includes the revised pages to the proposed OCNGS Emergency Plan "Table OCNGS B-1: Minimum Staffing Requirements,"

(replaces pages B-38 through B-40). Attachment 3 includes the revised Commitment to include comments from the New Jersey Department of Environmental Protection Bureau of Nuclear Engineering. The revisions are designated by using a cloud around the change. The pages being submitted in this letter supersede in entirety those submitted in Reference 1.

RESPONSE TO RAI QUESTIONS RAI-OCNGS-1 On page 10 in Section 5.1, "On-Shift Staffing Assessment (OSA)," of Attachment 1 to the OCNGS application, Exelon states, in part:

(3) OCNGS will either qualify an existing on-shift person to perform liquid sampling and analysis at various locations throughout the plant or maintain a Chemistry Technician on shift.

On page 31 (Chemistry Technician) in Section 5.3.1, "On-Shift Staffing," of Attachment 1 to the OCNGS application, Exelon states, in part:

OCNGS will either qualify an existing on-shift person to perform sampling and analysis at various locations throughout the plant or maintain a Chemistry Technician on shift. If a Chemistry Technician is placed on shift, the Chemistry Technician may be assigned other collateral duties (e.g., Fire Brigade).

For gaseous releases, the only credible scenario for releasing gas would be to mechanically damage spent fuel during handling or by impact of a heavy object.

Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-2 Activities that could cause mechanical damage will require that a Chemistry Technician be on-site or the radiation monitor listed in gaseous effluent

[Emergency Action Levels (EALs)] is in service, thereby alleviating any reliance on a potentially delayed sample analysis to determine EAL applicability. A new regulatory commitment to revise applicable fuel handling procedures to incorporate this prerequisite is included in Attachment 6.

Based on the above, the proposed change in on-shift operations staffing to qualify the existing [Radiation Protection (RP)] Technician to perform samples is appropriate given the permanent cessation of operations and removal of fuel from the reactor vessel.

In OCNGS letter to the State of New Jersey dated February 10, 2017, provided in Attachment 7 to the OCNGS application, Exelon provided the following as part of its response to Question #7 posed by the New Jersey Bureau of Engineering:

In consideration of deleting on-shift staffing, an evaluation was completed to ensure that necessary actions required to manage various emergency scenarios could still be performed in a timely manner to ensure safety. The conclusion was that six (6) staff personnel can perform the required tasks. As a separate note, the Chemistry function must be maintained and it is expected that a Chemistry Technician will be retained on shift rather than qualifying an RP Technician to perform the Chemistry function.

Please explain the apparent contradiction as to whether a Chemistry Technician will continue to be on shift to perform sampling and analysis at various locations throughout the plant.

Exelon Response to RAI-OCNGS-1 At this point Exelon is not pursuing activities to cross-qualify a Radiation Protection (RP)

Technician to perform chemistry sample analysis; however, OCNGS would like to maintain flexibility in the Emergency Plan to utilize a cross-qualified RP Technician to satisfy the chemistry function in the future. Exelon does not see the statements as contradictory as the chemistry function will be maintained in either case. As stated at the top of page 31 of of the proposed LAR (Reference 1), "[t]he post-shutdown [On Shift Staffing Assessment] OSA confirmed that no chemistry job tasks were noted as being required within the first 90 minutes of any of the analyzed events." At the bottom of page 31 it also states, in part, "There were no identified Chemistry activities identified in the On-Shift Staffing Assessment. The proposed on-shift staffing changes do not impact the capabilities of the on-shift staff to respond to an emergency and continue to comply with the Emergency Plan, site commitments and regulations."

RAI-OCNGS-2 On page 36 ([Technical Support Center (TSC)] Mechanical and Electrical Engineers) in Section 5.3.2, "ERO Minimum Staff," of Attachment 1 to the OCNGS application, Exelon states, in part:

Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-3 The TSC Engineers responsibilities include providing engineering support in response to an accident condition. At OCNGS, the engineers are also qualified to perform the function of the State/local communicator.

The Engineering function will continue to be maintained by the TSC Technical Manager.

Support for this position is also maintained by the [Emergency Operations Facility (EOF)]

Technical Support Manager, which has been designated as a Minimum Staff position per this License Amendment Request. OCNGS staff engineers would be available to provide technical insight for specific issues as needed. ERO members who are engineers and who respond to the ERO Notification in excess of the required fill count for facility activation can be retained to support identified technical issues as necessary.

Additionally, Oyster Creeks work management process ensures engineering support is available 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day/7 days a week to support emergent conditions. Exelon corporate staff is also available to support emergency engineering issues at the station 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months a day/7 days a week.

Please clarify if the TSC Technical Manager is or will be qualified to provide "engineering support in response to an accident condition, "specifically in response to a fuel handling accident or an event resulting in damage to the spent fuel pool (SFP) integrity or the loss of SFP cooling or inventory.

Exelon Response to RAI-OCNGS-2 Yes, the TSC Technical Support Manager will be qualified to provide engineering support in response to a fuel handling accident or an event resulting in damage to the SFP integrity or loss of SFP cooling or inventory. Qualifications for the TSC Technical Manager ERO position selection criteria will align with the current position requirements.

RAI-OCNGS-3 On page 42 (Operations Support Center (OSC) - Non-Minimum Augmented Staff) in Section 5.3.3, "ERO 30 minute and Full Augmented staff," of Attachment 1 to the OCNGS application, Exelon states, in part:

OCNGS proposes to only maintain the OSC Director minimum staff position, and if at any time the OSC Director determines that additional support is necessary to accomplish the mission of the OSC, the OSC Director will contact the Logistics Manager in the EOF to arrange for support by additional personnel.

On page 53 in Section 6.2, "Precedent," of Attachment 1 to the OCNGS application, Exelon further states:

The requested changes to the on-shift staffing and ERO staffing are similar in nature to the post-shutdown changes implemented by Vermont Yankee Nuclear Power Station. The NRC issued a Safety Evaluation Report dated February 4, 2015, entitled "Vermont Yankee Nuclear Power Station - Issuance of Amendment to Renewed Facility Operating License, RE: Changes to the Emergency Plan" (Accession Number ML14346A065).

However, the proposed Table 8.4, "Minimum Staffing Requirements for the ENVY ERO," for the Vermont Yankee Nuclear Power Station, contained in a letter from Entergy Nuclear Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-4 Operations, Inc. to the NRC, dated August 14, 2014 (ADAMS Accession No. ML14231A019), provided the following:

Major Task ENVY Position Title Response Time Offsite Surveys Field monitoring teams (2) 30 min.

Field monitoring teams (2) 60 min.

Onsite (out of plant) Field monitoring teams (1) 30 min.

Field monitoring teams (1) 60 min.

In Plant Surveys RP staff (1) 30 min.

RP staff (1) 60 min.

Mechanical Maintenance Maintenance (1) 60 min.

Rad Waste Operator AO/CRO/NCO 60 min.

Electrical Maintenance / Maintenance (1) 30 min.

I & C Technician Maintenance (1) 60 min.

I & C Technician Maintenance (1) 30 min.

Radiation Protection RP staff (2) 30 min.

RP staff (2) 60 min.

The proposed Table 5-1, "Plant Personnel - Emergency Activity Assignments," for the James A. FitzPatrick Nuclear Power Plant, contained in a letter from Entergy Nuclear Operations, Inc., to the NRC, dated February 4, 2016 (ADAMS Accession No. ML16043A424), provided the following:

Number available within 60 Major Task JAFNPP Position Title minutes Surveys (RP) Specialist 6 Protective actions (RP) Specialist 1 (RP/Chem)

Repair and Corrective Mechanical Maintenance 2 Actions Electrical Maintenance I & C 2 Technician 1 The proposed Table B-1, "OPPD Emergency Response Organization (ERO) Functions and Shift Staff Augmentation Plan," for the Fort Calhoun Station, contained a letter from the Omaha Public Power District to the NRC, dated September 2, 2016 (ADAMS Accession No. ML16246A321), provided the following:

Goals for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Major Task Emergency Positions augmentation Onsite (out of plant) RP Technician 1 RP Technician Protective actions RP Technician 1 RP Technician Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-5 Repair and Corrective Mechanical Maintenance 1 Machinist/or Steam Fitter Actions Mechanic Repair and Corrective Electrical Maintenance 1 Equipment Operator/NCO Actions 1 Electrical Maintenance Technician Repair and Corrective I & C Technician 1 I & C Technician Actions Until the granting of an exemption relieving the licensee of the requirements for full radiological emergency planning, the licensee needs to provide sufficient staffing and resources to mitigate an event with emergency classification levels up to and including a General Emergency. Please provide additional information regarding augmenting RP and maintenance support personnel expected following an Alert classification to support the control room to mitigate an event.

Exelon 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.

These additional three individuals (one RP Technician and 2 Maintenance Personnel) will be required as part of the Minimum Shift Size and will be part of the OSC staffing. This will increase the minimum OSC staffing (Reference 1) to a total of five (OSC Director plus two RP Technicians and two Maintenance Personnel) and the total Minimum Shift Size from six to a total of nine.

Additionally, Exelon has restored Note (l) regarding the requirements for fulfilling the two the required Maintenance positions and Note (d) (replacing proposed Note (b)) to indicate that additional RP, Chemistry and Maintenance personnel may be called-in to augment the on-shift staff depending on the type and extent of the emergency. Exelon has slightly modified Note (d) to align it with its intent under the Full Augmentation Column in the current operational Emergency Plan which has been eliminated in the proposed LAR.

The revised pages reflecting these changes are provided in Attachment 2, of this submittal.

(Proposed LAR (Reference 1), Attachment 3, "Proposed Revision to Site Emergency Plan,"

"Table OCNGS B-1: Minimum Staffing Requirements," replace pages B-38 through B-40 in their entirety.)

RAI-OCNGS-4 On page 42 (Operations Support Center (OSC) - Non-Minimum Augmented Staff) in Section 5.3.3 of Attachment 1 to the OCNGS application, Exelon states, in part:

Events involving a loss of SFP cooling and/or water inventory can be addressed by implementation of normal and emergency SFP inventory makeup strategies Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-6 and mitigating strategies required under license condition C.8, "Mitigation Strategy License Condition" and 10 CFR 50.54(hh)(2).

However, there is no reference to any personnel specifically assigned to perform SFP inventory makeup strategies in the proposed post-shutdown emergency plan[t].

Please explain who implements SFP inventory makeup strategies and verify that the strategies can be implemented by the on-shift personnel and what equipment will be maintained to perform mitigating functions.

Exelon Response to RAI-OCNGS-4 Both the normal and emergency SFP inventory makeup strategies and mitigating strategies required under existing License Condition 2.C.(8) are capable of being performed by the on-shift personnel. OCNGS will maintain procedures and strategies for the movement of any necessary portable equipment that will be relied upon for mitigating the loss of SFP water. Equipment associated with SFP inventory makeup strategies will be available to provide in-depth backup to normal and alternate makeup from installed equipment. These strategies remain unchanged from when they were originally verified. Two on-shift personnel who are trained are sufficient to implement SFP makeup utilizing any of these strategies. Training of the on-shift staff to implement such strategies and on the plans to mitigate the consequences of an event involving a loss-of-water inventory from the SFP will be maintained. The ERO Emergency Director and communications functions are unaffected by the SFP mitigating response.

RAI-OCNGS-5 On page 45 (Emergency Operations Facility (EOF) - Non-Minimum Augmented Staff)

Section 5.3.3 of Attachment 1 to the OCNGS application, Exelon proposes to keep the following ERO Non-Minimum augmented staff EOF positions as minimum staff:

Technical support manager Field team communicator Field monitoring teams (4 persons)

However, Table 5-2, "Emergency Response Organization Non-Minimum Staff," on page 40, lists the Field Monitoring Teams as minimum staff in the OSC.

Please indicate to what location the Field Monitoring Teams will report: the EOF or the OSC.

Exelon Response to RAI-OCNGS-5 Field Monitoring Team personnel report to the EOF. The Field Monitoring Teams are part of the EOF organization as shown in Figure B-1c: Emergency Offsite Organization of the proposed Emergency Plan (Reference 1, Attachment 3). The Field Monitoring Teams were inadvertently listed under the OSC in Tables 2-1, 2-2, 5-1 and 5-2, of Attachment 1 of the proposed LAR (Reference 1) and should have been included under the Emergency Operations Facility (EOF).

RAI-OCNGS-6 In Section 5.3.4, "Assessment of Staff Changes on Off-site Emergency Response Organizational Interfaces," of Attachment 1 to the OCNGS application (page 50), the [Joint Information Center (JIC)] Director position is listed twice with different duties:

Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-7 JIC Director - Coordinate with Federal, state and local agencies, as well as with other organizations involved in the emergency response, to maintain factual consistency of information to be conveyed to the news media/public.

JIC Director - Coordinate with the Corporate Spokesperson, Public Information Director, Federal, State and Local agencies, regarding the content, format and timing of press releases and news briefings.

Please indicate which specific functions the JIC director will perform as provided on this list.

Exelon Response to RAI-OCNGS-6 The bulleted task list in Section 5.3.4, on page 50 of Attachment 1 of the proposed LAR (Reference 1) reflects the tasks where the JIC Director interfaces with the State of New Jersey based on the ERO Task Analysis provided in Attachment 5 to the LAR (Reference 1). The JIC Directors tasks are provided on page 35 of the Task Analysis (Attachment 5, Reference 1). The first task identified by the NRC above for the JIC Director, is identified as task E-JDIR2 (line

426, in the Task Analysis), is based on the Emergency Plan (Part II, Section B.5.c.3) and the second task identified by the NRC above, is identified as task P-JDIR1 (line #430, in the Task Analysis), is based on Exelons implementing procedures. Both of these tasks will be performed by the JIC Director, in addition to the other tasks identified.

RAI-OCNGS-7 On page J-6 (Implementation of Protective Action Recommendations) in "Part II: Planning Standards and Criteria," of the Oyster Creek Radiological Emergency Plan (Procedure EP-OC-1000), provided in Attachment 3 / Appendix A to the OCNGS application, Exelon states:

At a General Emergency classification, Oyster Creek will provide the state with recommendations for protective actions for the public. For incidents involving actual, potential, or imminent releases of radioactive material to the atmosphere, EPA 400-R-92-001, the NRC Response Technical Manual (RTM-96) and NUREG-0654, Supp. 3, Revision 1 are used as the basis for the general public PARs.

In "Part II: Planning Standards And Criteria," and other sections of the OCNGS Radiological Emergency Response Plan, Exelon uses as guidance the U.S. Environmental Protection Agency (EPA) Protective Action Guides (PAG) Manual dated October 1991 -- EPA 400-R-92-001, "Manual of Protective Action Guides and Protective Actions for Nuclear Incidents."

However, the most recent version, EPA-400/R-17/001, dated January 2017 -- PAG Manual:

"Protective Action Guides and Planning Guidance for Radiological Incidents," should be referenced.

Exelon Response to RAI-OCNGS-7 Exelon intends to maintain the version of the U.S. Environmental Protection Agency (EPA)

Protective Action Guides (PAG) Manual dated October 19911 -- EPA 400-R-92-001, "Manual of 1

Re-printed May 1992 Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-8 Protective Action Guides and Protective Actions for Nuclear Incidents," as identified in the current and the proposed Emergency Plans.

RAI-OCNGS-8 Attachment 5, "Oyster Creek Nuclear Generating Station ERO Task Analysis," to the OCNGS application, provides the following, in part:

Note that tasks which are assigned to a person who remains on the Quad Cities ERO were not dispositioned.

It is not clear why Quad Cities is referenced in the OCNGS ERO task analysis.

Please clarify the intent of this statement, or revise accordingly.

Exelon Response to RAI-OCNGS-8 Quad Cites was inadvertently identified; this should be OCNGS.

RAI-OCNGS-9 In Section 5.3.3 (subsections a through d) of Attachment 1 to the OCNGS application, Exelon repeatedly states, in part:

OC will perform a drill to confirm the ability of the post-shutdown ERO to perform the necessary functions of each emergency response facility and to utilize the post-shutdown procedures being developed depicting the revised assignment of duties State and local response organizations will be offered the opportunity to participate, and the NRC and FEMA will be provided advance notice and the opportunity to observe drill activities.

However, Regulatory Commitment contained in Attachment 6 to the OCNGS application does not address statement repeated in Section 5.3.3 that "State and local response organizations will be offered the opportunity to participate, and the NRC and FEMA will be provided advance notice and the opportunity to observe drill activities."

The State of New Jerseys letter to Exelon, dated February 24, 2017, contained in Attachment 7 of the OCNGS application specifically states, in part:

[Bureau of Nuclear Engineering(BNE)] appreciates the invitation to observe and participate in the demonstration drills for the effectiveness of emergency facility operation under the Defueled Emergency Plan. We will withhold final judgment on staffing levels until we observe a drill.

Based on the BNEs comment above, please incorporate the following statement into the regulatory commitment, or provide justification why it should not be included:

State and local response organizations will be offered the opportunity to participate, and the NRC and FEMA will be provided advance notice and the opportunity to observe drill activities.

Response to Request for Additional Information Docket Nos. 50-219 and 72-15 Page A1-9 Exelon Response to RAI-OCNGS-9 This Commitment has been revised to include the BNE comment and is included in Attachment 3 to this submittal. (Proposed LAR (Reference 1), Attachment 6, Summary of Regulatory Commitments, replace in its entirety)

References:

1. Letter from Michael P. Gallagher, (Exelon Generation Company, LLC) to U.S. Nuclear Regulatory Commission - "License Amendment Request - Proposed Changes to the Oyster Creek Emergency Plan for Permanently Defueled Condition," dated February 28, 2017 (ML17060A289) (CAC NO. MF9352)

2. Letter from U.S. Nuclear Regulatory Commission to Bryan C. Hanson (Exelon Generation Company, LLC) - "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 Condition (CAC NO. MF9352)," dated September 14, 2017 (ML17208A747)

Attachment 2 Revised Marked-Up Pages for OCNGS Emergency Plan Table OCNGS B-1: Minimum Staffing Requirements (Replaces pages B-38 through B-40 in Proposed LAR, Attachment 3)