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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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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,
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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