RA-19-012, Supplement for License Amendment Request - License Condition Revision for Removal of Cyber Security Plan Requirements

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Supplement for License Amendment Request - License Condition Revision for Removal of Cyber Security Plan Requirements
ML19066A317
Person / Time
Site: Oyster Creek
Issue date: 03/07/2019
From: Gallagher M
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
RA-19-012
Download: ML19066A317 (4)


Text

Michael P. Gallagher Exelon Nuclear Exelon Generation Vice President License Renewal and Decomm1ss1oning 200 Exelon Way Kennett Square, PA 19348 610 765 5958 Office 610 765 5658 Fax www.exeloncorp.com m1chael p.gallagher@exeloncorp.com 10 CFR 50.90 RA-19-012 March 7, 2019 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555-0001 Oyster Creek Nuclear Generating Station Renewed Facility Operating License No. DPR-16 USNRC Docket Nos. 50-219 and 72-15

Subject:

Supplement for License Amendment Request - License Condition Revision for Removal of Cyber Security Plan Requirements

References:

1. Letter from Michael P. Gallagher, Exelon Generation Company, LLC to U.S. Nuclear Regulatory Commission - "License Amendment Request - License Condition Revision for Removal of Cyber Security Plan Requirements," dated November 12, 2018 (ADAMS Accession No. ML18317A022)
2. Letter from U.S. Nuclear Regulatory Commission - "Oyster Creek Nuclear Generating Station - Issuance of Amendment Re: License Amendment Request to Revise the Cyber Security Milestone 8 Completion Date (GAG No. MF9550: EPID L 2017-LLA-0193)," dated December 22, 2017 (ADAMS Accession No. ML17289A222)
3. Letter from Michael P. Gallagher, Exelon Generation Company, LLC to U.S. Nuclear Regulatory Commission - "Request for Exemptions from Portions of 10 CFR 50.47 and 10 CFR Part 50 Appendix E,"

dated August 22, 2017 (ADAMS Accession No. ML17234A082)

4. Letter from U.S. Nuclear Regulatory Commission - "Oyster Creek Nuclear Generating Station - Exemptions from Certain Emergency Planning Requirements and Related Safety Evaluation (GAG No.

MG0153: EPID L-2017-LLE-0020),"dated October 16, 2018 (ADAMS Accession No. ML18220A980)

5. Letter from Michael P. Gallagher, Exelon Generation Company, LLC to U.S. Nuclear Regulatory Commission - "License Amendment Request - Proposed Change of Effective and Implementation Dates of License Amendment No. 294, Oyster Creek Emergency Plan for

U.S. Nuclear Regulatory Commission OCNGS License Condition Revision for Removal of Cyber Security Plan Requirements Docket Nos. 50-219 and 72-15 March 7, 2019 Page 2 Permanently Defueled Emergency Plan and Emergency Action Level Scheme," dated October 22, 2018 (ADAMS Accession No. ML18295A384)

6. Letter from Michael P. Gallagher, Exelon Generation Company, LLC to U.S. Nuclear Regulatory Commission - "License Amendment Request Supplement - Proposed Change of Effective and Implementation Dates of License Amendment No. 294, Oyster Creek Emergency Plan for Permanently Defue/ed Emergency Plan and Emergency Action Level Scheme," dated November 6, 2018 (ADAMS Accession No. ML 1831 OA306)
7. Letter from Michael P. Gallagher, Exelon Generation Company, LLC to U.S. Nuclear Regulatory Commission - "Response to Request for Additional Information (RA/) and Supplemental Information Regarding Request for Changing Emergency Preparedness License Amendment No. 294 Effective Date (Change to Adiabatic Heat-up Calculation)

(EPID: L-2018-LLA-0305)," dated February 13, 2019 (ADAMS Accession No. ML19044A643)

8. Letter from Michael P. Gallagher, Exelon Generation Company, LLC to U.S. Nuclear Regulatory Commission - "Certification of Permanent Removal of Fuel from the Reactor Vessel for Oyster Creek Nuclear Generating Station," dated September 25, 2018 (ADAMS Accession No. ML18268A258)

By letter dated November 12, 2018 (Reference 1), Exelon Generation Company, LLC (Exelon),

submitted a license amendment request (LAA) for an amendment to the Renewed Facility Operating License (RFOL) No. DPR-16 for Oyster Creek Nuclear Generating Station (OCNGS).

Specifically, the request was to remove the existing Cyber Security Plan (CSP) requirements contained in License Condition 2.C.(4) of the OCNGS RFOL and removal of the commitment to fully implement the CSP by the Milestone 8 (MS8) commitment date of August 31, 2021 (Reference 2).

The purpose of this letter is to request the U.S. Nuclear Regulatory Commission (NRC) for an earlier approval date of June 1, 2019, with an effective date of June 29, 2019, for the LAA.

In Reference 1, Exelon requested approval of the proposed license amendment by September 17, 2019, with an implementation date within 60 days of the later of either the date of the license amendment or the date when all the spent fuel stored in the spent fuel pool (SFP) has decayed beyond the minimum cooling time that would allow sufficient time prior to clad ignition (1 O hours) to mitigate a SFP drain down in the adiabatic case.

By letter dated August 22, 2017 (Reference 3) Exelon requested exemptions from specific Emergency Planning (EP) requirements. In support of the requested EP exemptions, Exelon provided the NRC with an OCNGS site-specific analysis (Calculation C-1302-226-E310-457, Revision O, "Oyster Creek Nuclear Generating Station Zirconium Fire Analysis for Drained Spent Fuel Pool') (OCNGS site-specific Zirconium Fire Analysis (Revision 0)) that supported a 12-month

U.S. Nuclear Regulatory Commission OCNGS License Condition Revision for Removal of Cyber Security Plan Requirements Docket Nos. 50-219 and 72-15 March 7, 2019 Page3 decay period to when sufficient time has passed such that the spent fuel stored in the spent fuel pool would not reasonably heat up to clad ignition temperature within 1O hours (Zirconium Fire Window). The NRG approved the requested EP exemptions on October 16, 2018 (Reference 4),

based, in part, on the OCNGS site-specific Zirconium Fire Analysis (Revision 0).

By letter dated October 22, 2018 (Reference 5), and supplemented on November 6, 2018 (Reference 6), and February 13, 2019 (Reference 7), Exelon submitted a request to revise the effective date of the EP exemption to an earlier date based on revision of the OCNGS site-specific Zirconium Fire Analysis. Revision of the OCNGS Zirconium Fire Analysis resulted in a reduced required spent fuel decay period to the end of the zirconium ignition from 12 months (365 days) to a period of 9.38 months (285 days) after the final reactor shut down. Revision 2 of OCNGS Zirconium Fire Analysis has been provided to the NRG in Reference 7 (as Attachment 2). The earlier effective date of this exemption request is predicated upon NRG approval of Exelon's EP exemption to an earlier date (References 5, 6, and 7).

Based on the permanent shutdown of OCNGS on September 17, 2018 (Reference 8), the decay period of 9.38 months will occur June 29, 2019. Therefore, Exelon is requesting an effective date of June 29, 2019, with a 30-day implementation date no later than July 29, 2019. There are no other changes to the CSP LAA (Reference 1) other than requesting the earlier dates based the revised OCNGS site-specific Zirconium Fire Analysis (Revision 2) provided to the NRG in Reference 7 (Attachment 2).

Exelon has reviewed the information supporting a finding of no significant hazards consideration and the environmental consideration provided to the NRG in Reference 1. The changes proposed in this supplement do not affect the bases for concluding that the proposed license amendment does not involve a significant hazards consideration. Furthermore, the additional information provided in this response 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.

These proposed changes have been reviewed and approved by the OCNGS Safety Review Committee in accordance with the requirements of the Exelon Decommissioning Quality Assurance Program.

Exelon requests approval of the proposed license amendment by June 1, 2019.

In accordance with 10 CFR 50.91, a copy of this license amendment request, with attachments, is being provided to the designated State Official.

If you should have any questions or require additional information, please contact Mr. Paul Bonnett at 610-765-5264.

U.S. Nuclear Regulatory Commission OCNGS License Condition Revision for Removal of Cyber Security Plan Requirements Docket Nos. 50-219 and 72-15 March 7, 2019 Page 4 I declare under penalty of perjury that the foregoing is true and correct. Executed on the 7th day of March 2019.

Respectfully,

~~ -

Michael P. Gallagher Vice President, License Renewal & Decommissioning Exelon Generation Company, LLC cc: USNRC Region I, Regional Administrator USNRC Project Manager, NMSS/DUWP/RDB - Oyster Creek Nuclear Generating Station Director, Bureau of Nuclear Engineering, New Jersey Dept. of Environmental Protection Mayor of Lacey Township, Forked River, NJ