View source for RA-08-024, Amergen, Energy LLC, License Amendment Request to Remove References to NRC Generic Letter 82-12, Nuclear Power Plant Staff Working Hours.

{{Adams
| number = ML081120430
| issue date = 04/21/2008
| title = Amergen, Energy LLC, License Amendment Request to Remove References to NRC Generic Letter 82-12, Nuclear Power Plant Staff Working Hours.
| author name = Benyak D
| author affiliation = AmerGen Energy Co, LLC, Exelon Generation Co, LLC, Exelon Nuclear
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000219, 05000237, 05000249, 05000254, 05000265, 05000277, 05000278, 05000289, 05000352, 05000353, 05000373, 05000374, 05000454, 05000455, 05000456, 05000457, 05000461
| license number = DPR-016, DPR-019, DPR-025, DPR-044, DPR-056, NPF-011, NPF-018, NPF-037, NPF-039, NPF-062, NPF-066, NPF-072, NPF-077, NPF-085
| contact person = 
| case reference number = 5928-08-20048, GL-82-012, RA-08-024, RS-08-023
| document type = Letter type:RA, License-Application for Facility Operating License (Amend/Renewal) DKT 50, Technical Specifications
| page count = 31
| project = 
| stage = Request
}}

=Text=
{{#Wiki_filter:er                                                            Exel6n An Exelon Company www.exeloncorp.corn Nuclear AmerGen Energy Company, LLC Exelon Generation 4300 Winfield Road 4300 Winfield Road Warrenville, IL_ 60555 Warrenville, I(_ 60555 10 CFR 50.90 RS-08-023 5928-08-20048 RA-08-024 April 21, 2008 U . S . Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos . NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No . 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos . 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Facility Operating License Nos . NPF-11 and NPF-18 NRC Docket Nos . 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos . NPF-39 and NPF-85 NRC Docket Nos . 50-352 and 50-353 Oyster Creek Nuclear Generating Station Facility Operating License No. DPR-16 NRC Docket No. 50-219 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos . 50-277 and 50-278

Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos . 50-254 and 50-265 Three Mile Island Station, Unit 1 Facility Operating License No. DPR-50 NRC Docket No. 50-289 Subject :       License Amendment Request to Remove References to NRC Generic Letter 82-12, "Nuclear Power Plant Staff Working Hours" References :    (1)      VR-SECY-06-0244, "Final Rulemaking - 10 CFR Part 26 - Fitness-for-Duty Programs," dated April 17, 2007 (2)      Federal Register, Vol . 73, No. 62, p. 16966, "Fitness for Duty Programs,"
dated March 31, 2008 In accordance with 10 CFR 50 .90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) request an amendment to the facility operating licenses listed above . The proposed changes remove references to and limits imposed by NRC Generic Letter (GL) 82-12, "Nuclear Power Plant Staff Working Hours." Technical Specifications (TS) for the stations listed above include work hour guidelines required by GL 82-12 in the administrative controls section.
Published on June 15, 1982, these guidelines have been superseded by 10 CFR 26, Subpart I, "Managing Fatigue." The new rule for work hour controls and fatigue management was approved in Reference 1 . Removal of references to GL 82-12 will support the requirement to be in compliance with 10 CFR 26, Subpart I, within 18 months of the rule's publish date . The rule was published on March 31, 2008 (Reference 2).
The attached amendment request is subdivided as follows.
    "    Attachment 1 provides an evaluation supporting the proposed changes.
    "    Attachment 2 provides the marked-up TS pages, with the proposed changes indicated.
    "    Attachment 3 provides a list of regulatory commitments.
The proposed changes have been reviewed and approved by each station's Plant Operations Review Committee in accordance with the requirements of the EGC Quality Assurance Program. The Nuclear Safety Review Board (NSRB) Chairman has reviewed this license amendment request and, consistent with the EGC Quality Assurance Program, has determined that this request does not require NSRB approval due to its administrative nature .
EGC and AmerGen request approval of the proposed changes by April 21, 2009 to support the implementation of the revised rule and meet the NRC's compliance deadline of October 1, 2009 .

U. S. Nuclear Regulatory Commission April 21, 2008 Page 3 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," EGC and AmerGen are notifying the States of Illinois and New Jersey, and the Commonwealth of Pennsylvania of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated State Officials.
Should you have any questions concerning this letter, please contact Ms. Michelle Yun at (630) 657-2818 .
l declare under penalty of perjury that the foregoing is true and correct. Executed on the 21 St day of April 2008 .
Respectfully, Darin M . Benyak Director - Licensing and Regulatory Affairs  : Evaluation of Proposed Changes : Markup of Proposed Technical Specifications Pages : List of Regulatory Commitments

U .S . Nuclear Regulatory Commission April 21, 2008 Page 4 cc:     Regional Administrator - NRC Region I Regional Administrator- NRC Region III NRC Project Manager, NRR - Braidwood Station NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - Three Mile Island Nuclear Station NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Three Mile Island Nuclear Station Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Director, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA Mayor of Lacey Township, Forked River, NJ R. I. McLean, State of Maryland R . R. Janati, Commonwealth of Pennsylvania

ATTACHMENT 1 Evaluation of Proposed Change 1 .0 DESCRIPTION

==2.0  PROPOSED CHANGE==
S

==3.0  BACKGROUND==

==4.0  TECHNICAL ANALYSIS==

5 .0 REGULATORY ANALYSIS 5.1  No Significant Hazards Consideration 5.2  Applicable Regulatory Requirements and Criteria

==6.0  ENVIRONMENTAL CONSIDERATION==

7.0  IMPACT ON PREVIOUS SUBMITTALS

==8.0  REFERENCES==

ATTACHMENT 1 Evaluation of Proposed Change 1 .0      DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) request an amendment to the Facility Operating Licenses listed in the table below.
(*Renewed) Facility Operating Station License Nos.
Braidwood Station, Units 1 and 2                       NPF-72 and NPF-77 B ron Station, Units 1 and 2                        NPF-37 and NPF-66 Clinton Power Station, Unit 1                               NPF-62 Dresden Nuclear Power Station, Units 2 and 3                 *DPR-19 and *DPR-25 LaSalle Count Station, Units 1 and 2                     NPF-11 and NPF-18 Limerick Generating Station, Units 1 and 2                  NPF-39 and NPF-85 Oyster Creek Nuclear Generating Station                          DPR-16 Peach Bottom Atomic Power Station, Units 2 and 3                 *DPR-44 and *DPR-56 Quad Cities Nuclear Power Station, Units 1 and 2                *_DPR-29 and *DPR-30 Three Mile Island Nuclear Station, Unit 1        l               DPR-50 The proposed changes remove references to and limits imposed by NRC Generic Letter (GL) 82-12, "Nuclear Power Plant Staff Working Hours" (Reference 1). Technical Specifications (TS) for the stations listed above either refer or adhere to GL 82-12 work hour guidelines in the administrative controls section. Published on June 15, 1982, these guidelines have been superseded by 10 CFR 26, Subpart I, "Managing Fatigue." The new rule for work hour controls and fatigue management was approved by the NRC Commission on April 17, 2007 (Reference 2). Removal of references to GL 82-12 will support the requirement to be in compliance with 10 CFR 26, Subpart I, within 18 months of the rule's publish date . The rule was published on March 31, 2008 (Reference 3).

==2.0       PROPOSED CHANGE==
S The proposed changes remove references to GL 82-12 from the administrative controls section of TS, which is either TS Section 5 or Section 6 depending on the station. EGC and AmerGen are proposing to remove these references from the sections of their station's TS pages listed in the table below.
Station                                       TS Section Braidwood Station, Units 1 and 2                              5 .2.2.d B ron Station, Units 1 and 2                                5.2.2.d Clinton Power Station, Unit 1                               5.2 .2 .e Dresden Nuclear Power Station, Units 2 and 3                          5.2.2 .d LaSalle Count Station, Units 1 and 2                             5.2 .2 .d Limerick Generating Station, Units 1 and 2                         6.2.2.f Oyster Creek Nuclear Generating Station                           6.2.2 .2 .1 Peach Bottom Atomic Power Station, Units 2 and 3                         5.2 .2.d Quad Cities Nuclear Power Station, Units 1 1and 2                     5.2.2.d Three Mile Island Nuclear Station, Unit                           6.8.1 .j Page 2 of 7

ATTACHMENT 1 Evaluation of Proposed Change

==3.0      BACKGROUND==

On June 15, 1982, the NRC issued GL 82-12, "Nuclear Power Plant Staff Working Hours,"
which was a revision of past guidance and discussions regarding the limitation of work hours to mitigate worker fatigue and the impact of fitness-for-duty on safety . GL 82-12 established overtime guidance for work hours beyond a "normal 8-hour day, 40-hour week ." Issued prior to GL 82-12, GL 82-02, "Nuclear Power Plant Staff Working Hours," requested that all licensees revise the administrative section of their technical specifications to require that administrative procedures follow policy guidelines (Reference 4). GL 82-12 invoked this request. References to GL 82-12, either in name or in guidance, were incorporated into Exelon and AmerGen TS .
On April 17, 2007, the NRC Commissioners approved a final rule amending 10 CFR 26, which revised, reorganized, and clarified drug and alcohol testing programs, partially granted two petitions for rulemaking and established requirements for managing worker fatigue at operating nuclear power plants . Subpart I specifically addresses managing worker fatigue by designating individual break requirements, work hour limits, and annual reporting requirements . Subpart I was published in the Federal Register on March 31, 2008, with a required implementation period of 18 months. Compliance is, therefore, required by October 1, 2009 .
4 .0    TECHNICAL ANALYSIS The new rule, which was established by 10 CFR 26, Subpart I, supersedes GL 82-12 guidance .
10 CFR 26, Subpart I, distinguishes between work hour controls and fatigue management and strengthens requirements for both . Under the new rule, work hour restrictions include not only work hour limitations for rolling 24-hour, 48-hour, and 7-day periods, but also include a required minimum break between work periods and varying required minimum days off. Additionally, Subpart I confines the use of waivers (deviations from restrictions) to situations where overtime is necessary to mitigate or prevent a condition adverse to safety or necessary to maintain the security of the facility . Subpart I also strengthens reporting requirements . Finally, the new rule's work hour controls scope includes operating and maintenance personnel, as well as those directing operating and maintenance personnel, performing work on risk-significant equipment, health physics and chemistry personnel who are a part of the on-site minimum shift complement, the fire brigade leader or advisor, and security personnel .
The proposed changes remove references to and limits imposed by GL 82-12 from the administrative section of TS to support compliance with 10 CFR 26, Subpart I. EGC and AmerGen request approval of the proposed changes by April 21, 2009, to support the implementation across EGC and AmerGen sites of the revised rule and meet the NBC's compliance deadline of October 1, 2009 . Upon compliance, federal regulations will govern the requirements associated with work hour controls and fatigue management at the stations listed in Section 1 .0 . Compliance with 10 CFR 26, Subpart I, will be established concurrently with TS requirements removal . The new work hour controls and fatigue management requirements have been incorporated into the CFR, therefore, it is unnecessary to have work hour control requirements in TS.

ATTACHMENT 1 Evaluation of Proposed Change

==5.0     REGULATORY ANALYSIS==

5.1     No Significant Hazards Consideration Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) request an amendment to the Facility Operating Licenses listed in the table below.
Station                                 (*Renewed) Facility Operating License Nos.
Braidwood Station, Units 1 and 2                            NPF-72 and NPF-77 B ron Station, Units 1 and 2                              NPF-37 and NPF-66 Clinton Power Station, Unit 1                                    NPF-62 Dresden Nuclear Power Station, Units 2 and 3                    *DPR-19 and *DPR-25 LaSalle County Station, Units 1 and 2                        NPF-11 and NPF-18 Limerick Generating Station, Units 1 and 2                      NPF-39 and NPF-85 Oyster Creek Nuclear Generating Station                                DPR-16 Peach Bottom Atomic Power Station, Units 2 and 3                    *DPR-44 and *DPR-56 Quad Cities Nuclear Power Station, Units 1 and 2                   *DPR-29 and *DPR-30 Three Mile Island Nuclear Station, Unit 1                             DPR-50 The proposed changes revise Technical Specification (TS) in the administrative controls section to remove references to NRC Generic Letter (GL) 82-12, "Nuclear Power Plant Staff Working Hours" or work hour requirements based on GL 82-12. This guidance has been superseded by 10 CFR 26, Subpart I, which is more conservative by both increasing the scope of personnel involved and including required minimum break durations and days off. Furthermore, work hour controls are no longer guidance in a generic communication, but are stipulated in the Code of Federal Regulations (CFR) .
According to 10 CFR 50 .92, "Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:
Involve a significant increase in the probability or consequence of an accident previously evaluated; or (2)     Create the possibility of a new or different kid of accident from any accident previously evaluated ; or Involve a significant reduction in a margin of safety .
EGC and AmerGen have evaluated the proposed changes to the TS for the stations listed above, using the criteria in 10 CFR 50 .92, and have determined that the proposed changes do not involve a significant hazards consideration.
The following information is provided to support a finding of no significant hazards consideration.
Page 4 of 7

ATTACHMENT 1 Evaluation of Proposed Change
: 1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?
Response : No The removal of references to GL 82-12 will not remove the requirement to control work hours and manage fatigue. Removal of TS references to GL 82-12 will be performed concurrently with the implementation of the more conservative 10 CFR 26, Subpart I, requirements . The proposed changes do not impact the physical configuration or function of plant structures, systems, or components (SSCs) or the manner in which SSCs are operated, maintained, modified, tested, or inspected . The proposed changes do not impact the initiators or assumptions of analyzed events, nor do they impact the mitigation of accidents or transient events .
Because these new requirements are more conservative with respect to work hour controls and fatigue management, this will not significantly increase the probability or consequence of an accident previously evaluated .
: 2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?
Response : No The proposed changes remove references to GL 82-12 from TS to support the addition of Subpart I to 10 CFR 26. These regulations are more restrictive than the current guidance and would add conservatism to work hour controls and fatigue management . Work hours will continue to be controlled in accordance with NRC requirements . The new rule continues to allow for deviations from controls to mitigate or prevent a condition adverse to safety or necessary to maintain the security of the facility. This ensures that the new rule will not restrict work hours at the expense of the health and safety of the public as well as plant personnel.
The proposed changes do not alter plant configuration, require that new plant equipment be installed, alter assumptions made about accidents previously evaluated, add any initiators, or impact the function of plant SSCs or the manner in which SSCs are operated, maintained, modified, tested, or inspected .
Because the proposed changes do not remove the station's requirement to control work hours and increases the conservatism of work hour controls by changing administrative scheduling requirements, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
: 3. Do the proposed changes involve a significant reduction in a margin of safety?
Response : No Page 5 of 7

ATTACHMENT 1 Evaluation of Proposed Change An input to maintaining the margin of safety is the control of work hours as a tool in managing fatigue. The affected stations will continue their fitness-for-duty and behavioral observation programs, both of which will be strengthened by compliance with the new rule . The proposed changes add conservatism to fatigue management and contribute to the margin of safety .
The proposed changes do not involve any physical changes to plant SSCs or the manner in which SSCs are operated, maintained, modified, tested, or inspected .
The proposed changes do not involve a change to any safety limits, limiting safety system settings, limiting conditions of operation, or design parameters for any SSC . The proposed changes do not impact any safety analysis assumptions and does not involve a change in initial conditions, system response times, or other parameters affecting an accident analysis .
Therefore, the proposed changes do not involve a significant reduction in the margin of safety .
Based upon the above, EGC and AmerGen conclude that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92 (c), and, accordingly, a finding of no significant hazards consideration is justified .
5.2    Applicable Regulatory Requirements and Criteria 10 CFR 50 .36 (d)(5), "Administrative controls," provides the regulatory requirements for the content required in the administrative controls section of TS.
The inclusion of GL 82-12 into the administrative controls section meets the requirement to have administrative controls for "procedures. . . necessary to assure the operation of the facility in a safe manner." Because the requirement to control work hours and manage fatigue is necessitated by 10 CFR 26, Subpart I, it is unnecessary to maintain a reference to work hour controls guidance in TS .
Furthermore, these TS references are in conflict with 10 CFR 26, Subpart I .
Removal of TS references to GL 82-12 guidance is not in conflict with 10 CFR 50.36 (d)(5) and supports station compliance with 10 CFR 26, Subpart I .
In conclusion, based on the considerations discussed above, (1) there is a reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the U . S . NRC's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public .

==6.0     ENVIRONMENTAL CONSIDERATION==

EGC and AmerGen have determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation."
However, the proposed amendment does not involve: (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure . Accordingly, the proposed amendment meets the eligibility criterion for Page 6 of 7

ATTACHMENT 1 Evaluation of Proposed Change categorical exclusion set forth in 10 CFR 51 .22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," Paragraph (c)(10) . Therefore, pursuant to 10 CFR 51 .22, Paragraph (c),
no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
7.0     IMPACT ON PREVIOUS SUBMITTALS This amendment request does not seek to execute changes on TS that currently have pending amendments .

==8.0     REFERENCES==

(1)     NRC Generic Letter 82-12, "Nuclear Power Plant Staff Working Hours," dated June 15, 1982 (2)    VR-SECY-06-0244, "Final Rulemaking -10 CFR Part 26 - Fitness-for-Duty Programs,"
dated April 17, 2007 (3)     Federal Register, Vol . 73, No. 62, p. 16966, "Fitness for Duty Programs," dated March 31, 2008 (4)    NRC Generic Letter 82-02, "Nuclear Power Plant Staff Working Hours," dated February 8, 1982

ATTACHMENT 2 Markup of Proposed Technical Specifications Pages Station Technical Specifications                    Affected Pages Braidwood Station, Units 1 and 2                     5.2-2 B ron Station, Units 1 and 2                         5.2-2 Clinton Power Station, Unit 1                        5.0-3, 5.0-4 Dresden Nuclear Power Station, Units 2 and 3        5.2-2 LaSalle County Station, Units 1 and 2               5 .2-2 Limerick Generating Station, Unit 1                 6-2,6-3 Limerick Generating Station, Unit 2                 6-2,6-3 Oyster Creek Nuclear Generating Station             6-2, 6-2a Peach Bottom Atomic Power Station, Unit 2           5.0-3, 5.0-4 Peach Bottom Atomic Power Station, Unit 3           5.0-3, 5.0-4 Quad Cities Nuclear Power Station, Units 1 and 2    5.2-2 Three Mile Island Station, Unit 1                   6-11

Organization 5 .2 5 .2    Organization 5 .2 .2           ility Staff The facility staff organization shall include the following :
: a. A total of three non-licensed operators for the two units is required in all conditions . At least one of the required non-licensed operators shall be assigned to each unit .
: b. Shift crew composition may be less than the minimum requirement of 10 CFR 50 .54(m)(2)(i) and 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c. A radiation protection technician shall be on site when fuel is in the reactor . The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
: d. Deleted.
: e. The operations manager or the supervisor in charge of the operations shift crews shall hold an SRO license .
: f. The Shift Technical Advisor (STA) shall provide advisory technical support to the Shift Manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the facility .      In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
BRAIDWOOO - UNITS 1 & 2                 5 .2 - 2                          Amendment-98

Organization 5 .2 5 .2    Organization 5 .2 .2        Facility Staff The facility staff organization shall include the following :
: a. A total of three non-licensed operators for the two units is required in all conditions . At least one of the required non-licensed operators shall be assigned to each unit .
: b. Shift crew composition may be less than the minimum requirement of 10 CFR 50 .54(m)(2)(i) and 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c. A radiation protection technician shall be on site when fuel is in the reactor . The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
Deleted .                                 a4 ffiefflbeps
: e. The operations manager or the supervisor in charge of the operations shift crews shall hold an SRO license .
: f. The Shift Technical Advisor (STA) shall provide advisory technical support to the Shift Manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the facility .      In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
BYRON - UNITS 1 & 2                     5 .2 - 2                        Amendment IM

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff       (continued)
: b. At least one licensed RO shall be present in the control room when fuel is in the reactor .        In addition, while the unit is in MODE 1, 2, or 3, at least one licensed SRO shall be present in the control room .
: c. Shift crew composition may be one less than the minimum requirements of 10 CFR 50 .54(m)(2)(i) and Specifications 5 .2 .2 .a and 5 .2 .2 .g for a period of time not to exceed 2 hours to accommodate unexpected absence of on-duty shift crew members, provided immediate action is taken to restore the shift crew composition within the minimum requirements .
: d. A radiation protection technician shall be on site when fuel is in the reactor . The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
Administrative procedures shall be developed and implemente to limit the working hours of unit staff who perform ety related functions (e .g ., licensed SROs, licens tion protection technicians, non-licensed maintenance personnel) .
Adequate shi        coverage shall be maintaine without routine heavy use of o         time . However, in the     ent that unforeseen proble          require substant3    amounts of overtime to be used, or durin extended per ds of shutdown for refueling, major mainte nce,            major plant modification, on a temporary basis the              wing guidelines shall be followed :
idual should not be permitted in any 24 hour period, nor more any 48 hour period, nor more than 72 hou day period, all excluding shift turnover tim (continued)
CLINTON                                       5 . 0-3                    Amendment No . 95'.'

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff      (continued)
Except during extended shutdown periods, the use     o vertime should be considered on an individua of for the entire staff on a shift .
Any deviation ff                              all be authorized by the plant manager                      in accordance with administrative procedure           bcumentation of the basis for granting the deviati Controls shall        ncluded in the proc    res such that individual       mime shall be reviewed mont      by the plant manager      r his designee, to ensure that excess     hours hav     of been assigned . Routine deviation from the      ove idelines is not authorized .
: e.        The operations manager or at least one operations middle manager shall hold an SRO license for Clinton Power Station .
The Shift Technical Advisor (STA) shall provide advisory technical support to the SS in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit . In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
CLINTON                                     5 .0-4                   Amendment No .-1-1-5

Organization 5 .2 5 .2    Organization 5 .2 .2           nit  Staff     (continued)
: a.      A total of three non-licensed operators for the two units             is required in all conditions .      At least one of the required non-licensed operators shall be assigned to each unit .
: b.      Shift crew composition may be less than the minimum requirement of 10 CFR 50 .54(m)(2)(i) and Specifications 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c.      A radiation protection technician shall be on site when fuel is in the reactor .       The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
d.
: e. The operations manager or shift operations        supervisor    shall hold an SRO license .
: f. The Shift Technical Advisor (STA) shall provide advisory technical support to the shift manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit .         In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
Dresden 2    and 3                              5 .2-2               Amendment  No . -~8rsti-S~

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff      (continued) non-licensed operators shall        be assigned to each   unit .
: b. Shift crew composition may be less than the minimum requirement of 10 CFR 50 .54(m)(2)(i) and Specifications 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c. A radiation protection technician shall be on site when fuel is in the reactor .        The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
: d.        The operations manager or shift operations          supervisor shall hold an SRO license .
The Shift Technical Advisor (STA) shall provide advisory technical support to the shift manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit .           In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
LaSalle    1 and 2                            5 .2-2                 Amendment  No . -  ,'- 1~ ;

AMINI,STRATIVE CONTROLS 6 .2 .2 UNIT STAFF
: a. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6 .2 .2-1 ;
: b. At least one licensed Operator shall be in the control room when fuel is in the reactor . In addition, while the unit is in OPERATIONAL CONDITION l, 2, or 3, at least one licensed Senior Operator shall be in the control room ;
: c. A Health Physics Technician* shall be on site when fuel        is in the reactor;
: d. ALL CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Operator or licensed Senior Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation ;
: e.    (Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE TiOi .
: f.                              urea shall be developed and implemented to limit unit staff who perform safety-related' functions e .g .,             ,nior Operators, licensed Operators, health physi-casts, a             operators, and key maintenance personnel) .
Adequate shift       verage shall be maintained without routi use of overtime .        e obJective shall be to have operat work a nominal 40-ho        week while the unit is operati However, in the event t         unforeseen problems          substantial amounts of overtimes to be           or during exte      periods .of shut-down for refueling, rnsior ma        nonce, or       unit modifications, on a temporary basis the follow         guideli s shall be followed :
: 1.       An individual should not be pe straight, excluding shift t An individual should       be permitted to    rk more than 16 hours in any 24-hour pert      nor more than 24 hou    in any 48-hour period, nor more        72 hours in any 7-day pe        all excluding shift turnover, A break     at least 8 hours should be allowed between w*4t periods, inclu     shift turnover time .
kept during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift .
*The Health Physics Technician position may be less than the minimum requirements for a period of time not to exceed 2 hours, in order to accommodate unexpected absence, provided immediate action is taken to fi1T the required position .
LIMERICK - UNIT 1                                  6-2          M0endment No .                    ,
MAP 1 4 200$

UNIT STAFF  (Continued) deviation from the above guidelines shall be authorit the         Manager or personnel designated in admin          ive procedures        i4her levels of management, i      c`ordance with established proce         and with docum       on of the basis for granting the deviation .                  1 be included in the procedures such that ind         a        me shall be reviewed monthly by the Pla        nager, or the ap'p     Late designated personnel t         re that excessive hours have  n      en assigned .
Routi        iation from the above guidelines is not au        Lzed ;
: 9. The individual filling the position of Operations Manager as defined by ANSI/ANS-3 .1-1978 or another Manager in Operations shall hold a Senior Reactor Operator License .
LIMERICK - UNIT 1                         6- 3     Amendment No .

   rSTRATLVE Chi=
ADMI 6 .2_. 2 UNIT STAFF
: a. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6 .2 .2-1 ;
: b. At least one licensed Operator shall be in the control room when fuel is in the reactor .      In addition, while the unit is in OPERATIONAL CONDITION 1,     2, or  3,  at least one licensed Senior Operator shall be in the control room ;
: c. A Health Physics Technician* shall be on site when fuel is in the reactor;
: d. ALL CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Operator or licensed Senior Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation ;
: e.     (Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE TRM.
: f.        (Deleted)              ures shall be developed and implemented to limi unit staff who perform safety-related functi en or Operators, licensed Operators, health operators, and key maintenance personnel)
Adequate shift cove`        e shall be maintained without       tine heavy use of overtime . The          active shall be to have      &rating personnel work a nominal 40-hour wee         hile the unit is      &rating .
However, in the event that un           seen prob       require substantial amounts of overtime to be used, o          uri    extended periods of shut-down for refueling, major maintenanc              major unit modifications, on a temporary basis the followin                   s shall be followed:
: 1.      An individual should         be permitted to straight, excludi       shift turnover time .
An individ       should not be permitted to work more in any       our period, nor more than 24 hours in any 48' peri      nor more than 72 hours in any 7-day period, all ex'    c t turnover time .
*The Health Physics Technician position may be less than the minimum requirements for a period of time not to exceed 2 hours, in order to acco=odate unexpected absence, provided immediate action is taken to fill the required position .
LIMERICK - UNIT 2                                    6-2               Amendment No .  ,      , 102

b, a .2 UNIT STAFF   (Continued)
A break of at least 8 hours should be allowed between work peria luding shift turnover time .
: 4. Except       g extended shutdown periods, the use ~~Wertime should be can    e red on an individual basis         not for the entire staff an a shift .
Any deviation from the above gui m:          shall be authorized by the Plant Manager or personnel desi~9     ed      dministrative procedures or higher levels of manager,        in actor dW with established pro-cedures and with docu ~rrt~~ anon of the ba sis for     nting the devia-tion . Controls         be included in the p rocedures           that individual       time shall be reviewed monthly by the Plan           nager, or the       opriate designated personnel to assure that excessi h      have not been assigned . Routine deviation from the above guidelines is not authorized ; and 9"    The individual filling the position of Operations Manager as defined by ANSI/ANS-3 .1-1978 or another Manager in Operations shall hold a Senior Reactor Operator License .
LIMERICK - UNIT 2                              6- 3           Amendment No . -z,-2&deg;r44 , 69 , 124

composition to within requirements given above. This provision does not permit any shift crew position to be unmanned upon shift change due to an incoming shift crew member being late or absent .
: b. At all times tivhen there is tuel in the %essel, at least one liceiued senior reactor operator shall be on site and one licensed reactor operator should be at the controls .
: c. At all times when there is fuel in the vessel, except when the reactor is in COLD SHUTDOWN or REFUEL mocks, two licensed senior reactor operators and two licensed reactor operators shall be on site, with at least one licensed senior reactor operator in the control room and one licensed reactor operator at the controls .
: d. At least two licensed reactor operators shall be in the control room during all reactor startups, shutdowns, and other periods involving planned control rod manipulations .
: e. All CORE ALTERATIONS shall be directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation.
: f. An individual qualified in radiation protection measures shall be on site when fuel is in the reactor.
: g. (deleted)
: h. Each on duty shift shall include a Shift Technical Advisor except that the Shift Technical Advisors position need not be filled if the reactor is in the refuel or shutdown mode and the reactor is less than 212 F. The Shift Technical Advisor position may be filled by an on-shift Senior Reactor Operator (dual-role SRO/STA) provided the individual meets the requirements of 6.3.3 .
(deleted)                Lshall be developed and implemented to
[taff who perform safety related In the event that          seen problems require subst         amounts of overtime to be used          ring extended periods        utdown for refueling, major maintenance or-maj Rlant modifica             s, on a temporary basis, the following guidelines shall be fo.
An individual shout be perm straight, excludj
: b.        An to     idual should not be permitted to work m i ny 24-hour period, nor more than 24 hours in any period, nor more than 72 hours in any seven-day period, all excluding shift turnover time.
OYSTER CREEK                       6-2               Amendment No.:        , ~            , 20~ .220

A break of at least eight hours should be allowed between work riod, including shift turnover time .
c above, the time required to compl          ift turnover is reak time and is not to      o'unted as work time.
: e.       Except during extended                periods, the use of overtime should be considered on               ual basis and not for the entire staff on a shift.
Ion from the above guidelines shall be       horized by the merit Managers, or higher levels of a anagemen ,
accordance with established procedures and with documents the basis for granting the deviation .
The Senior Manager - Operations or an Operations Manager, and the Shift Manager require Senior Reactor Operators licenses. The licensed Nuclear Plant Operators require a Reactor Operators license .
6.2.2 .3 Individuals who train the operating staff and those who carry out the health physics and quality assurance function shall have sufficient organizational freedom to be independent of operational pressures, however, they may report to the appropriate manager on site.
6.3  Facility Staff Oualificatians 6.3.1   Each member of the unit staff shall meet or exceed the minimum qualifications of ANSUANS 3.1 of 1978 for comparable positions unless otherwise noted in the Technical Specifications, with the following exceptions: 1) the education and experience eligibility requirements for operator license applicants (described in Exelon letter RS-02-100, dated June 19, 2002), and changes thereto, shall be approved by the NRC and described in an applicable station training procedure, and 2) technicians and maintenance personnel who do not meet ANSIIANS 3.1 of 1978, Section 4 .5, are permitted to perform work for which qualification has been demonstrated.
6 .3 .2 The management position responsible for radiological controls shall meet or exceed the qualifications of Regulatory Guide 1 .8 (Rev . 1-R, 9175) . Each other member of the radiation protection organization for which there is a comparable position described in ANSI N18 .1 1971 shall meet or exceed the minimum qualifications specified therein, or in the case of radiation protection technicians, they shall have at least one year's continuous experience in applied radiation protection work in a nuclear facility dealing with radiological problems similar to those encountered in nuclear power stations and shall have been certified by the management position responsible for radiological controls as qualified to perform assigned functions . This certification must be based on an NRC approved, documented program consisting of classroom training with appropriate examinations and documented positive findings by responsible supervision that the individual has demonstrated his ability to perform each specified procedure and assigned function with an understanding of its basis and purpose .
6.3.3   The Shift Technical Advisors shall have a bachelors degree or equivalent in a scientific or engineering discipline with specific training in plant design, response and analysis of the plant for transients and accidents .
OYSTER CREEK                                     6-2a             Amendment No.: 13 ,2^"'^,226, 2"         32

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff   (continued)
: a. A total of five non-licensed Operators shall be assigned for PBAPS Units 2 and 3 at all times .
: b. Each on-duty shift crew composition may be less than the minimum requirements of 10 CFR 50 .54(m)(2)(i) and Specification 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c. An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor . The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
d.
(continued)
PBAPS UNIT 2                              5 . 0-3                    Amendment No .-2148

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff    (continued)
The controls shall include guidelines on working hours t pre adequate shift coverage shall be maintained heavy use of overtime .
Any deviation                               "shall be authorized in advance by the `p                   he plant manager's designee, in accordance           pproved administrative procedures, and with d,             on of the basis for granting the deviation . R                      m the working hour guidelines s s shall be included in the procedures to eriodic independent review be conducted to ensure     f excessive hours have not been assigned .
: e. The senior operations manager or an operations manager shall hold an SRO license .
: f. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit . This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
PBAPS UNIT 2                              5 .0- 4                   Amendment No . -259

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff   (continued)
: a. A total of five non-licensed Operators shall be assigned for PBAPS Units 2 and 3 at all times .
: b. Each on-duty shift crew composition may be less than the minimum requirements of 10 CFR 50 .54(m)(2)(i) and Specification 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c. An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor . The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
d.
(continued)
PBAPS UNIT 3                              5 .0-3                      Amendment No . 243

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff     (continued) controls shall include guidelines on working hours th ensu      dequate shift coverage shall be maintained wi routine          use of overtime .
Any deviation from       e above guidelines      all be authorized in advance by the plan       anager or       plant manager's designee, in accordance wi             ov ed administrative procedures, and with docu         at      of the basis for granting the deviation . Routi         eviation        the working hour guidelines shall          be authorized .
Controls      all be included in the procedures to           re a peri     c independent review be conducted to ensure t cessive hours have not been assigned .
: e. The senior operations manager or an operations manager shall hold an SRO license .
: f. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit .         This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
PBAPS UNIT 3                               5 .0- 4                     Amendment No . -242 2

Organization 5 .2 5 .2    Organization 5 .2 .2         Unit Staff     (continued) a . A total of three non-licensed operators for the two units           is required in all conditions .        At least one of the required non-licensed operators shall be assigned to each unit .
: b. Shift crew composition may be less than the minimum requirement of 10 CFR 50 .54(m)(2)(i) and Specifications 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c. A radiation protection technician shall be on site when fuel is in the reactor .        The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
d.
: e. The operations manager or shift operations supervisor shall hold an SRO license .
: f. The Shift Technical Advisor (STA) shall provide advisory technical support to the shift manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit .         In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
Quad Cities     1 and  2                       5 .2-2               Amendment   No . - ' 44;

6.8 .1   Written procedures shall be established, implemented and maintained covenng the items referenced below :
: a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1 .33, Revision 2, February 1978 .
: b.      Surveillance and test activities of equipment that affects nuclear safety and radioactive waste management equipment.
: c. Refueling Operations.
: d. Security Plan Implementation .
: e. Fire Protection Program Implementation .
: f. Emergency Plan Implementation.
: g. Process Control Program implementation .
: h.      Offsite Dose Calculation Manual Implementation .
: i.      Quality Assurance Program for effluent and environmental monitoring using the guidance in Regulatory Guide 4.15, Revision 1 .
Deleted 6.8.2   Further, each procedure required by 6.8.1 above, and substantive changes thereto, shall be reviewed and approved as described in 6.5 .1 prior to implementation and shall be reviewed periodically as set forth in administrative procedures.
6.8.3   Temporary changes to procedures of 6.8 .1 above may be made provided :
: a. The intent of the original procedure is not altered;
: b. The change is approved by two mernbers of the licensee's management staff qualified in accordance with 6.5.1.14 and knowledgeable in the area affected by the procedure. For changes which may affect the operational status of unit systems or equipment, at least one of these individuals shall be a member of unit management or supervision holding a Senior Reactor Operator's License on the unit
: c. The change is documented, reviewed and approved as described in 6.5 .1 within 14 days of implementation.

ATTACHMENT 3 List of Regulatory Commitments The following table identifies those actions committed to by Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) in this document . Any other statements in the submittal are provided for information purposes and are not considered to be regulatory commitments.
COMMITMENT TYPE COMMITTED           ONE-COMMITMENT DATE            TIME      PROGRAMMATIC ACTION           (Yes/No)
Yes/No Exelon Generation Company, LLC and AmerGen Energy Company, LLC will implement the 10 CFR 26, Subpart I, requirements for managing fatigue at each operating nuclear facility, concurrently with                 By October 1, implementation of the Technical                                 Yes               No 2009 Specification (TS) amendment to remove work hour limitations from TS . The intent of this commitment is to ensure that work hour limitations are controlled by either TS or regulation at all times.}}

=Text=
{{#Wiki_filter:er                                                            Exel6n An Exelon Company www.exeloncorp.corn Nuclear AmerGen Energy Company, LLC Exelon Generation 4300 Winfield Road 4300 Winfield Road Warrenville, IL_ 60555 Warrenville, I(_ 60555 10 CFR 50.90 RS-08-023 5928-08-20048 RA-08-024 April 21, 2008 U . S . Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456 and STN 50-457 Byron Station, Units 1 and 2 Facility Operating License Nos . NPF-37 and NPF-66 NRC Docket Nos. STN 50-454 and STN 50-455 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No . 50-461 Dresden Nuclear Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos . 50-237 and 50-249 LaSalle County Station, Units 1 and 2 Facility Operating License Nos . NPF-11 and NPF-18 NRC Docket Nos . 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos . NPF-39 and NPF-85 NRC Docket Nos . 50-352 and 50-353 Oyster Creek Nuclear Generating Station Facility Operating License No. DPR-16 NRC Docket No. 50-219 Peach Bottom Atomic Power Station, Units 2 and 3 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos . 50-277 and 50-278

Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos . 50-254 and 50-265 Three Mile Island Station, Unit 1 Facility Operating License No. DPR-50 NRC Docket No. 50-289 Subject :       License Amendment Request to Remove References to NRC Generic Letter 82-12, "Nuclear Power Plant Staff Working Hours" References :    (1)      VR-SECY-06-0244, "Final Rulemaking - 10 CFR Part 26 - Fitness-for-Duty Programs," dated April 17, 2007 (2)      Federal Register, Vol . 73, No. 62, p. 16966, "Fitness for Duty Programs,"
dated March 31, 2008 In accordance with 10 CFR 50 .90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) request an amendment to the facility operating licenses listed above . The proposed changes remove references to and limits imposed by NRC Generic Letter (GL) 82-12, "Nuclear Power Plant Staff Working Hours." Technical Specifications (TS) for the stations listed above include work hour guidelines required by GL 82-12 in the administrative controls section.
Published on June 15, 1982, these guidelines have been superseded by 10 CFR 26, Subpart I, "Managing Fatigue." The new rule for work hour controls and fatigue management was approved in Reference 1 . Removal of references to GL 82-12 will support the requirement to be in compliance with 10 CFR 26, Subpart I, within 18 months of the rule's publish date . The rule was published on March 31, 2008 (Reference 2).
The attached amendment request is subdivided as follows.
    "    Attachment 1 provides an evaluation supporting the proposed changes.
    "    Attachment 2 provides the marked-up TS pages, with the proposed changes indicated.
    "    Attachment 3 provides a list of regulatory commitments.
The proposed changes have been reviewed and approved by each station's Plant Operations Review Committee in accordance with the requirements of the EGC Quality Assurance Program. The Nuclear Safety Review Board (NSRB) Chairman has reviewed this license amendment request and, consistent with the EGC Quality Assurance Program, has determined that this request does not require NSRB approval due to its administrative nature .
EGC and AmerGen request approval of the proposed changes by April 21, 2009 to support the implementation of the revised rule and meet the NRC's compliance deadline of October 1, 2009 .

U. S. Nuclear Regulatory Commission April 21, 2008 Page 3 In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," EGC and AmerGen are notifying the States of Illinois and New Jersey, and the Commonwealth of Pennsylvania of this application for changes to the TS by transmitting a copy of this letter and its attachments to the designated State Officials.
Should you have any questions concerning this letter, please contact Ms. Michelle Yun at (630) 657-2818 .
l declare under penalty of perjury that the foregoing is true and correct. Executed on the 21 St day of April 2008 .
Respectfully, Darin M . Benyak Director - Licensing and Regulatory Affairs  : Evaluation of Proposed Changes : Markup of Proposed Technical Specifications Pages : List of Regulatory Commitments

U .S . Nuclear Regulatory Commission April 21, 2008 Page 4 cc:     Regional Administrator - NRC Region I Regional Administrator- NRC Region III NRC Project Manager, NRR - Braidwood Station NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Clinton Power Station NRC Project Manager, NRR - Dresden Nuclear Power Station NRC Project Manager, NRR - LaSalle County Station NRC Project Manager, NRR - Limerick Generating Station NRC Project Manager, NRR - Oyster Creek Nuclear Generating Station NRC Project Manager, NRR - Peach Bottom Atomic Power Station NRC Project Manager, NRR - Quad Cities Nuclear Power Station NRC Project Manager, NRR - Three Mile Island Nuclear Station NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Three Mile Island Nuclear Station Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Director, Bureau of Nuclear Engineering, New Jersey Department of Environmental Protection Chairman, Board of County Commissioners of Dauphin County, PA Chairman, Board of Supervisors of Londonderry Township, PA Mayor of Lacey Township, Forked River, NJ R. I. McLean, State of Maryland R . R. Janati, Commonwealth of Pennsylvania

ATTACHMENT 1 Evaluation of Proposed Change 1 .0 DESCRIPTION

==2.0  PROPOSED CHANGE==
S

==3.0  BACKGROUND==

==4.0  TECHNICAL ANALYSIS==

5 .0 REGULATORY ANALYSIS 5.1  No Significant Hazards Consideration 5.2  Applicable Regulatory Requirements and Criteria

==6.0  ENVIRONMENTAL CONSIDERATION==

7.0  IMPACT ON PREVIOUS SUBMITTALS

==8.0  REFERENCES==

ATTACHMENT 1 Evaluation of Proposed Change 1 .0      DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license or construction permit," Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) request an amendment to the Facility Operating Licenses listed in the table below.
(*Renewed) Facility Operating Station License Nos.
Braidwood Station, Units 1 and 2                       NPF-72 and NPF-77 B ron Station, Units 1 and 2                        NPF-37 and NPF-66 Clinton Power Station, Unit 1                               NPF-62 Dresden Nuclear Power Station, Units 2 and 3                 *DPR-19 and *DPR-25 LaSalle Count Station, Units 1 and 2                     NPF-11 and NPF-18 Limerick Generating Station, Units 1 and 2                  NPF-39 and NPF-85 Oyster Creek Nuclear Generating Station                          DPR-16 Peach Bottom Atomic Power Station, Units 2 and 3                 *DPR-44 and *DPR-56 Quad Cities Nuclear Power Station, Units 1 and 2                *_DPR-29 and *DPR-30 Three Mile Island Nuclear Station, Unit 1        l               DPR-50 The proposed changes remove references to and limits imposed by NRC Generic Letter (GL) 82-12, "Nuclear Power Plant Staff Working Hours" (Reference 1). Technical Specifications (TS) for the stations listed above either refer or adhere to GL 82-12 work hour guidelines in the administrative controls section. Published on June 15, 1982, these guidelines have been superseded by 10 CFR 26, Subpart I, "Managing Fatigue." The new rule for work hour controls and fatigue management was approved by the NRC Commission on April 17, 2007 (Reference 2). Removal of references to GL 82-12 will support the requirement to be in compliance with 10 CFR 26, Subpart I, within 18 months of the rule's publish date . The rule was published on March 31, 2008 (Reference 3).

==2.0       PROPOSED CHANGE==
S The proposed changes remove references to GL 82-12 from the administrative controls section of TS, which is either TS Section 5 or Section 6 depending on the station. EGC and AmerGen are proposing to remove these references from the sections of their station's TS pages listed in the table below.
Station                                       TS Section Braidwood Station, Units 1 and 2                              5 .2.2.d B ron Station, Units 1 and 2                                5.2.2.d Clinton Power Station, Unit 1                               5.2 .2 .e Dresden Nuclear Power Station, Units 2 and 3                          5.2.2 .d LaSalle Count Station, Units 1 and 2                             5.2 .2 .d Limerick Generating Station, Units 1 and 2                         6.2.2.f Oyster Creek Nuclear Generating Station                           6.2.2 .2 .1 Peach Bottom Atomic Power Station, Units 2 and 3                         5.2 .2.d Quad Cities Nuclear Power Station, Units 1 1and 2                     5.2.2.d Three Mile Island Nuclear Station, Unit                           6.8.1 .j Page 2 of 7

ATTACHMENT 1 Evaluation of Proposed Change

==3.0      BACKGROUND==

On June 15, 1982, the NRC issued GL 82-12, "Nuclear Power Plant Staff Working Hours,"
which was a revision of past guidance and discussions regarding the limitation of work hours to mitigate worker fatigue and the impact of fitness-for-duty on safety . GL 82-12 established overtime guidance for work hours beyond a "normal 8-hour day, 40-hour week ." Issued prior to GL 82-12, GL 82-02, "Nuclear Power Plant Staff Working Hours," requested that all licensees revise the administrative section of their technical specifications to require that administrative procedures follow policy guidelines (Reference 4). GL 82-12 invoked this request. References to GL 82-12, either in name or in guidance, were incorporated into Exelon and AmerGen TS .
On April 17, 2007, the NRC Commissioners approved a final rule amending 10 CFR 26, which revised, reorganized, and clarified drug and alcohol testing programs, partially granted two petitions for rulemaking and established requirements for managing worker fatigue at operating nuclear power plants . Subpart I specifically addresses managing worker fatigue by designating individual break requirements, work hour limits, and annual reporting requirements . Subpart I was published in the Federal Register on March 31, 2008, with a required implementation period of 18 months. Compliance is, therefore, required by October 1, 2009 .
4 .0    TECHNICAL ANALYSIS The new rule, which was established by 10 CFR 26, Subpart I, supersedes GL 82-12 guidance .
10 CFR 26, Subpart I, distinguishes between work hour controls and fatigue management and strengthens requirements for both . Under the new rule, work hour restrictions include not only work hour limitations for rolling 24-hour, 48-hour, and 7-day periods, but also include a required minimum break between work periods and varying required minimum days off. Additionally, Subpart I confines the use of waivers (deviations from restrictions) to situations where overtime is necessary to mitigate or prevent a condition adverse to safety or necessary to maintain the security of the facility . Subpart I also strengthens reporting requirements . Finally, the new rule's work hour controls scope includes operating and maintenance personnel, as well as those directing operating and maintenance personnel, performing work on risk-significant equipment, health physics and chemistry personnel who are a part of the on-site minimum shift complement, the fire brigade leader or advisor, and security personnel .
The proposed changes remove references to and limits imposed by GL 82-12 from the administrative section of TS to support compliance with 10 CFR 26, Subpart I. EGC and AmerGen request approval of the proposed changes by April 21, 2009, to support the implementation across EGC and AmerGen sites of the revised rule and meet the NBC's compliance deadline of October 1, 2009 . Upon compliance, federal regulations will govern the requirements associated with work hour controls and fatigue management at the stations listed in Section 1 .0 . Compliance with 10 CFR 26, Subpart I, will be established concurrently with TS requirements removal . The new work hour controls and fatigue management requirements have been incorporated into the CFR, therefore, it is unnecessary to have work hour control requirements in TS.

ATTACHMENT 1 Evaluation of Proposed Change

==5.0     REGULATORY ANALYSIS==

5.1     No Significant Hazards Consideration Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) request an amendment to the Facility Operating Licenses listed in the table below.
Station                                 (*Renewed) Facility Operating License Nos.
Braidwood Station, Units 1 and 2                            NPF-72 and NPF-77 B ron Station, Units 1 and 2                              NPF-37 and NPF-66 Clinton Power Station, Unit 1                                    NPF-62 Dresden Nuclear Power Station, Units 2 and 3                    *DPR-19 and *DPR-25 LaSalle County Station, Units 1 and 2                        NPF-11 and NPF-18 Limerick Generating Station, Units 1 and 2                      NPF-39 and NPF-85 Oyster Creek Nuclear Generating Station                                DPR-16 Peach Bottom Atomic Power Station, Units 2 and 3                    *DPR-44 and *DPR-56 Quad Cities Nuclear Power Station, Units 1 and 2                   *DPR-29 and *DPR-30 Three Mile Island Nuclear Station, Unit 1                             DPR-50 The proposed changes revise Technical Specification (TS) in the administrative controls section to remove references to NRC Generic Letter (GL) 82-12, "Nuclear Power Plant Staff Working Hours" or work hour requirements based on GL 82-12. This guidance has been superseded by 10 CFR 26, Subpart I, which is more conservative by both increasing the scope of personnel involved and including required minimum break durations and days off. Furthermore, work hour controls are no longer guidance in a generic communication, but are stipulated in the Code of Federal Regulations (CFR) .
According to 10 CFR 50 .92, "Issuance of amendment," paragraph (c), a proposed amendment to an operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not:
Involve a significant increase in the probability or consequence of an accident previously evaluated; or (2)     Create the possibility of a new or different kid of accident from any accident previously evaluated ; or Involve a significant reduction in a margin of safety .
EGC and AmerGen have evaluated the proposed changes to the TS for the stations listed above, using the criteria in 10 CFR 50 .92, and have determined that the proposed changes do not involve a significant hazards consideration.
The following information is provided to support a finding of no significant hazards consideration.
Page 4 of 7

ATTACHMENT 1 Evaluation of Proposed Change
: 1. Do the proposed changes involve a significant increase in the probability or consequences of an accident previously evaluated?
Response : No The removal of references to GL 82-12 will not remove the requirement to control work hours and manage fatigue. Removal of TS references to GL 82-12 will be performed concurrently with the implementation of the more conservative 10 CFR 26, Subpart I, requirements . The proposed changes do not impact the physical configuration or function of plant structures, systems, or components (SSCs) or the manner in which SSCs are operated, maintained, modified, tested, or inspected . The proposed changes do not impact the initiators or assumptions of analyzed events, nor do they impact the mitigation of accidents or transient events .
Because these new requirements are more conservative with respect to work hour controls and fatigue management, this will not significantly increase the probability or consequence of an accident previously evaluated .
: 2. Do the proposed changes create the possibility of a new or different kind of accident from any accident previously evaluated?
Response : No The proposed changes remove references to GL 82-12 from TS to support the addition of Subpart I to 10 CFR 26. These regulations are more restrictive than the current guidance and would add conservatism to work hour controls and fatigue management . Work hours will continue to be controlled in accordance with NRC requirements . The new rule continues to allow for deviations from controls to mitigate or prevent a condition adverse to safety or necessary to maintain the security of the facility. This ensures that the new rule will not restrict work hours at the expense of the health and safety of the public as well as plant personnel.
The proposed changes do not alter plant configuration, require that new plant equipment be installed, alter assumptions made about accidents previously evaluated, add any initiators, or impact the function of plant SSCs or the manner in which SSCs are operated, maintained, modified, tested, or inspected .
Because the proposed changes do not remove the station's requirement to control work hours and increases the conservatism of work hour controls by changing administrative scheduling requirements, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
: 3. Do the proposed changes involve a significant reduction in a margin of safety?
Response : No Page 5 of 7

ATTACHMENT 1 Evaluation of Proposed Change An input to maintaining the margin of safety is the control of work hours as a tool in managing fatigue. The affected stations will continue their fitness-for-duty and behavioral observation programs, both of which will be strengthened by compliance with the new rule . The proposed changes add conservatism to fatigue management and contribute to the margin of safety .
The proposed changes do not involve any physical changes to plant SSCs or the manner in which SSCs are operated, maintained, modified, tested, or inspected .
The proposed changes do not involve a change to any safety limits, limiting safety system settings, limiting conditions of operation, or design parameters for any SSC . The proposed changes do not impact any safety analysis assumptions and does not involve a change in initial conditions, system response times, or other parameters affecting an accident analysis .
Therefore, the proposed changes do not involve a significant reduction in the margin of safety .
Based upon the above, EGC and AmerGen conclude that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92 (c), and, accordingly, a finding of no significant hazards consideration is justified .
5.2    Applicable Regulatory Requirements and Criteria 10 CFR 50 .36 (d)(5), "Administrative controls," provides the regulatory requirements for the content required in the administrative controls section of TS.
The inclusion of GL 82-12 into the administrative controls section meets the requirement to have administrative controls for "procedures. . . necessary to assure the operation of the facility in a safe manner." Because the requirement to control work hours and manage fatigue is necessitated by 10 CFR 26, Subpart I, it is unnecessary to maintain a reference to work hour controls guidance in TS .
Furthermore, these TS references are in conflict with 10 CFR 26, Subpart I .
Removal of TS references to GL 82-12 guidance is not in conflict with 10 CFR 50.36 (d)(5) and supports station compliance with 10 CFR 26, Subpart I .
In conclusion, based on the considerations discussed above, (1) there is a reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the U . S . NRC's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public .

==6.0     ENVIRONMENTAL CONSIDERATION==

EGC and AmerGen have determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, "Standards for Protection Against Radiation."
However, the proposed amendment does not involve: (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure . Accordingly, the proposed amendment meets the eligibility criterion for Page 6 of 7

ATTACHMENT 1 Evaluation of Proposed Change categorical exclusion set forth in 10 CFR 51 .22, "Criterion for categorical exclusion; identification of licensing and regulatory actions eligible for categorical exclusion or otherwise not requiring environmental review," Paragraph (c)(10) . Therefore, pursuant to 10 CFR 51 .22, Paragraph (c),
no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
7.0     IMPACT ON PREVIOUS SUBMITTALS This amendment request does not seek to execute changes on TS that currently have pending amendments .

==8.0     REFERENCES==

(1)     NRC Generic Letter 82-12, "Nuclear Power Plant Staff Working Hours," dated June 15, 1982 (2)    VR-SECY-06-0244, "Final Rulemaking -10 CFR Part 26 - Fitness-for-Duty Programs,"
dated April 17, 2007 (3)     Federal Register, Vol . 73, No. 62, p. 16966, "Fitness for Duty Programs," dated March 31, 2008 (4)    NRC Generic Letter 82-02, "Nuclear Power Plant Staff Working Hours," dated February 8, 1982

ATTACHMENT 2 Markup of Proposed Technical Specifications Pages Station Technical Specifications                    Affected Pages Braidwood Station, Units 1 and 2                     5.2-2 B ron Station, Units 1 and 2                         5.2-2 Clinton Power Station, Unit 1                        5.0-3, 5.0-4 Dresden Nuclear Power Station, Units 2 and 3        5.2-2 LaSalle County Station, Units 1 and 2               5 .2-2 Limerick Generating Station, Unit 1                 6-2,6-3 Limerick Generating Station, Unit 2                 6-2,6-3 Oyster Creek Nuclear Generating Station             6-2, 6-2a Peach Bottom Atomic Power Station, Unit 2           5.0-3, 5.0-4 Peach Bottom Atomic Power Station, Unit 3           5.0-3, 5.0-4 Quad Cities Nuclear Power Station, Units 1 and 2    5.2-2 Three Mile Island Station, Unit 1                   6-11

Organization 5 .2 5 .2    Organization 5 .2 .2           ility Staff The facility staff organization shall include the following :
: a. A total of three non-licensed operators for the two units is required in all conditions . At least one of the required non-licensed operators shall be assigned to each unit .
: b. Shift crew composition may be less than the minimum requirement of 10 CFR 50 .54(m)(2)(i) and 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c. A radiation protection technician shall be on site when fuel is in the reactor . The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
: d. Deleted.
: e. The operations manager or the supervisor in charge of the operations shift crews shall hold an SRO license .
: f. The Shift Technical Advisor (STA) shall provide advisory technical support to the Shift Manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the facility .      In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
BRAIDWOOO - UNITS 1 & 2                 5 .2 - 2                          Amendment-98

Organization 5 .2 5 .2    Organization 5 .2 .2        Facility Staff The facility staff organization shall include the following :
: a. A total of three non-licensed operators for the two units is required in all conditions . At least one of the required non-licensed operators shall be assigned to each unit .
: b. Shift crew composition may be less than the minimum requirement of 10 CFR 50 .54(m)(2)(i) and 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c. A radiation protection technician shall be on site when fuel is in the reactor . The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
Deleted .                                 a4 ffiefflbeps
: e. The operations manager or the supervisor in charge of the operations shift crews shall hold an SRO license .
: f. The Shift Technical Advisor (STA) shall provide advisory technical support to the Shift Manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the facility .      In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
BYRON - UNITS 1 & 2                     5 .2 - 2                        Amendment IM

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff       (continued)
: b. At least one licensed RO shall be present in the control room when fuel is in the reactor .        In addition, while the unit is in MODE 1, 2, or 3, at least one licensed SRO shall be present in the control room .
: c. Shift crew composition may be one less than the minimum requirements of 10 CFR 50 .54(m)(2)(i) and Specifications 5 .2 .2 .a and 5 .2 .2 .g for a period of time not to exceed 2 hours to accommodate unexpected absence of on-duty shift crew members, provided immediate action is taken to restore the shift crew composition within the minimum requirements .
: d. A radiation protection technician shall be on site when fuel is in the reactor . The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
Administrative procedures shall be developed and implemente to limit the working hours of unit staff who perform ety related functions (e .g ., licensed SROs, licens tion protection technicians, non-licensed maintenance personnel) .
Adequate shi        coverage shall be maintaine without routine heavy use of o         time . However, in the     ent that unforeseen proble          require substant3    amounts of overtime to be used, or durin extended per ds of shutdown for refueling, major mainte nce,            major plant modification, on a temporary basis the              wing guidelines shall be followed :
idual should not be permitted in any 24 hour period, nor more any 48 hour period, nor more than 72 hou day period, all excluding shift turnover tim (continued)
CLINTON                                       5 . 0-3                    Amendment No . 95'.'

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff      (continued)
Except during extended shutdown periods, the use     o vertime should be considered on an individua of for the entire staff on a shift .
Any deviation ff                              all be authorized by the plant manager                      in accordance with administrative procedure           bcumentation of the basis for granting the deviati Controls shall        ncluded in the proc    res such that individual       mime shall be reviewed mont      by the plant manager      r his designee, to ensure that excess     hours hav     of been assigned . Routine deviation from the      ove idelines is not authorized .
: e.        The operations manager or at least one operations middle manager shall hold an SRO license for Clinton Power Station .
The Shift Technical Advisor (STA) shall provide advisory technical support to the SS in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit . In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
CLINTON                                     5 .0-4                   Amendment No .-1-1-5

Organization 5 .2 5 .2    Organization 5 .2 .2           nit  Staff     (continued)
: a.      A total of three non-licensed operators for the two units             is required in all conditions .      At least one of the required non-licensed operators shall be assigned to each unit .
: b.      Shift crew composition may be less than the minimum requirement of 10 CFR 50 .54(m)(2)(i) and Specifications 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c.      A radiation protection technician shall be on site when fuel is in the reactor .       The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
d.
: e. The operations manager or shift operations        supervisor    shall hold an SRO license .
: f. The Shift Technical Advisor (STA) shall provide advisory technical support to the shift manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit .         In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
Dresden 2    and 3                              5 .2-2               Amendment  No . -~8rsti-S~

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff      (continued) non-licensed operators shall        be assigned to each   unit .
: b. Shift crew composition may be less than the minimum requirement of 10 CFR 50 .54(m)(2)(i) and Specifications 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c. A radiation protection technician shall be on site when fuel is in the reactor .        The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
: d.        The operations manager or shift operations          supervisor shall hold an SRO license .
The Shift Technical Advisor (STA) shall provide advisory technical support to the shift manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit .           In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
LaSalle    1 and 2                            5 .2-2                 Amendment  No . -  ,'- 1~ ;

AMINI,STRATIVE CONTROLS 6 .2 .2 UNIT STAFF
: a. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6 .2 .2-1 ;
: b. At least one licensed Operator shall be in the control room when fuel is in the reactor . In addition, while the unit is in OPERATIONAL CONDITION l, 2, or 3, at least one licensed Senior Operator shall be in the control room ;
: c. A Health Physics Technician* shall be on site when fuel        is in the reactor;
: d. ALL CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Operator or licensed Senior Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation ;
: e.    (Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE TiOi .
: f.                              urea shall be developed and implemented to limit unit staff who perform safety-related' functions e .g .,             ,nior Operators, licensed Operators, health physi-casts, a             operators, and key maintenance personnel) .
Adequate shift       verage shall be maintained without routi use of overtime .        e obJective shall be to have operat work a nominal 40-ho        week while the unit is operati However, in the event t         unforeseen problems          substantial amounts of overtimes to be           or during exte      periods .of shut-down for refueling, rnsior ma        nonce, or       unit modifications, on a temporary basis the follow         guideli s shall be followed :
: 1.       An individual should not be pe straight, excluding shift t An individual should       be permitted to    rk more than 16 hours in any 24-hour pert      nor more than 24 hou    in any 48-hour period, nor more        72 hours in any 7-day pe        all excluding shift turnover, A break     at least 8 hours should be allowed between w*4t periods, inclu     shift turnover time .
kept during extended shutdown periods, the use of overtime should be considered on an individual basis and not for the entire staff on a shift .
*The Health Physics Technician position may be less than the minimum requirements for a period of time not to exceed 2 hours, in order to accommodate unexpected absence, provided immediate action is taken to fi1T the required position .
LIMERICK - UNIT 1                                  6-2          M0endment No .                    ,
MAP 1 4 200$

UNIT STAFF  (Continued) deviation from the above guidelines shall be authorit the         Manager or personnel designated in admin          ive procedures        i4her levels of management, i      c`ordance with established proce         and with docum       on of the basis for granting the deviation .                  1 be included in the procedures such that ind         a        me shall be reviewed monthly by the Pla        nager, or the ap'p     Late designated personnel t         re that excessive hours have  n      en assigned .
Routi        iation from the above guidelines is not au        Lzed ;
: 9. The individual filling the position of Operations Manager as defined by ANSI/ANS-3 .1-1978 or another Manager in Operations shall hold a Senior Reactor Operator License .
LIMERICK - UNIT 1                         6- 3     Amendment No .

   rSTRATLVE Chi=
ADMI 6 .2_. 2 UNIT STAFF
: a. Each on duty shift shall be composed of at least the minimum shift crew composition shown in Table 6 .2 .2-1 ;
: b. At least one licensed Operator shall be in the control room when fuel is in the reactor .      In addition, while the unit is in OPERATIONAL CONDITION 1,     2, or  3,  at least one licensed Senior Operator shall be in the control room ;
: c. A Health Physics Technician* shall be on site when fuel is in the reactor;
: d. ALL CORE ALTERATIONS shall be observed and directly supervised by either a licensed Senior Operator or licensed Senior Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation ;
: e.     (Deleted) - INFORMATION FROM THIS SECTION RELOCATED TO THE TRM.
: f.        (Deleted)              ures shall be developed and implemented to limi unit staff who perform safety-related functi en or Operators, licensed Operators, health operators, and key maintenance personnel)
Adequate shift cove`        e shall be maintained without       tine heavy use of overtime . The          active shall be to have      &rating personnel work a nominal 40-hour wee         hile the unit is      &rating .
However, in the event that un           seen prob       require substantial amounts of overtime to be used, o          uri    extended periods of shut-down for refueling, major maintenanc              major unit modifications, on a temporary basis the followin                   s shall be followed:
: 1.      An individual should         be permitted to straight, excludi       shift turnover time .
An individ       should not be permitted to work more in any       our period, nor more than 24 hours in any 48' peri      nor more than 72 hours in any 7-day period, all ex'    c t turnover time .
*The Health Physics Technician position may be less than the minimum requirements for a period of time not to exceed 2 hours, in order to acco=odate unexpected absence, provided immediate action is taken to fill the required position .
LIMERICK - UNIT 2                                    6-2               Amendment No .  ,      , 102

b, a .2 UNIT STAFF   (Continued)
A break of at least 8 hours should be allowed between work peria luding shift turnover time .
: 4. Except       g extended shutdown periods, the use ~~Wertime should be can    e red on an individual basis         not for the entire staff an a shift .
Any deviation from the above gui m:          shall be authorized by the Plant Manager or personnel desi~9     ed      dministrative procedures or higher levels of manager,        in actor dW with established pro-cedures and with docu ~rrt~~ anon of the ba sis for     nting the devia-tion . Controls         be included in the p rocedures           that individual       time shall be reviewed monthly by the Plan           nager, or the       opriate designated personnel to assure that excessi h      have not been assigned . Routine deviation from the above guidelines is not authorized ; and 9"    The individual filling the position of Operations Manager as defined by ANSI/ANS-3 .1-1978 or another Manager in Operations shall hold a Senior Reactor Operator License .
LIMERICK - UNIT 2                              6- 3           Amendment No . -z,-2&deg;r44 , 69 , 124

composition to within requirements given above. This provision does not permit any shift crew position to be unmanned upon shift change due to an incoming shift crew member being late or absent .
: b. At all times tivhen there is tuel in the %essel, at least one liceiued senior reactor operator shall be on site and one licensed reactor operator should be at the controls .
: c. At all times when there is fuel in the vessel, except when the reactor is in COLD SHUTDOWN or REFUEL mocks, two licensed senior reactor operators and two licensed reactor operators shall be on site, with at least one licensed senior reactor operator in the control room and one licensed reactor operator at the controls .
: d. At least two licensed reactor operators shall be in the control room during all reactor startups, shutdowns, and other periods involving planned control rod manipulations .
: e. All CORE ALTERATIONS shall be directly supervised by either a licensed Senior Reactor Operator or Senior Reactor Operator Limited to Fuel Handling who has no other concurrent responsibilities during this operation.
: f. An individual qualified in radiation protection measures shall be on site when fuel is in the reactor.
: g. (deleted)
: h. Each on duty shift shall include a Shift Technical Advisor except that the Shift Technical Advisors position need not be filled if the reactor is in the refuel or shutdown mode and the reactor is less than 212 F. The Shift Technical Advisor position may be filled by an on-shift Senior Reactor Operator (dual-role SRO/STA) provided the individual meets the requirements of 6.3.3 .
(deleted)                Lshall be developed and implemented to
[taff who perform safety related In the event that          seen problems require subst         amounts of overtime to be used          ring extended periods        utdown for refueling, major maintenance or-maj Rlant modifica             s, on a temporary basis, the following guidelines shall be fo.
An individual shout be perm straight, excludj
: b.        An to     idual should not be permitted to work m i ny 24-hour period, nor more than 24 hours in any period, nor more than 72 hours in any seven-day period, all excluding shift turnover time.
OYSTER CREEK                       6-2               Amendment No.:        , ~            , 20~ .220

A break of at least eight hours should be allowed between work riod, including shift turnover time .
c above, the time required to compl          ift turnover is reak time and is not to      o'unted as work time.
: e.       Except during extended                periods, the use of overtime should be considered on               ual basis and not for the entire staff on a shift.
Ion from the above guidelines shall be       horized by the merit Managers, or higher levels of a anagemen ,
accordance with established procedures and with documents the basis for granting the deviation .
The Senior Manager - Operations or an Operations Manager, and the Shift Manager require Senior Reactor Operators licenses. The licensed Nuclear Plant Operators require a Reactor Operators license .
6.2.2 .3 Individuals who train the operating staff and those who carry out the health physics and quality assurance function shall have sufficient organizational freedom to be independent of operational pressures, however, they may report to the appropriate manager on site.
6.3  Facility Staff Oualificatians 6.3.1   Each member of the unit staff shall meet or exceed the minimum qualifications of ANSUANS 3.1 of 1978 for comparable positions unless otherwise noted in the Technical Specifications, with the following exceptions: 1) the education and experience eligibility requirements for operator license applicants (described in Exelon letter RS-02-100, dated June 19, 2002), and changes thereto, shall be approved by the NRC and described in an applicable station training procedure, and 2) technicians and maintenance personnel who do not meet ANSIIANS 3.1 of 1978, Section 4 .5, are permitted to perform work for which qualification has been demonstrated.
6 .3 .2 The management position responsible for radiological controls shall meet or exceed the qualifications of Regulatory Guide 1 .8 (Rev . 1-R, 9175) . Each other member of the radiation protection organization for which there is a comparable position described in ANSI N18 .1 1971 shall meet or exceed the minimum qualifications specified therein, or in the case of radiation protection technicians, they shall have at least one year's continuous experience in applied radiation protection work in a nuclear facility dealing with radiological problems similar to those encountered in nuclear power stations and shall have been certified by the management position responsible for radiological controls as qualified to perform assigned functions . This certification must be based on an NRC approved, documented program consisting of classroom training with appropriate examinations and documented positive findings by responsible supervision that the individual has demonstrated his ability to perform each specified procedure and assigned function with an understanding of its basis and purpose .
6.3.3   The Shift Technical Advisors shall have a bachelors degree or equivalent in a scientific or engineering discipline with specific training in plant design, response and analysis of the plant for transients and accidents .
OYSTER CREEK                                     6-2a             Amendment No.: 13 ,2^"'^,226, 2"         32

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff   (continued)
: a. A total of five non-licensed Operators shall be assigned for PBAPS Units 2 and 3 at all times .
: b. Each on-duty shift crew composition may be less than the minimum requirements of 10 CFR 50 .54(m)(2)(i) and Specification 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c. An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor . The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
d.
(continued)
PBAPS UNIT 2                              5 . 0-3                    Amendment No .-2148

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff    (continued)
The controls shall include guidelines on working hours t pre adequate shift coverage shall be maintained heavy use of overtime .
Any deviation                               "shall be authorized in advance by the `p                   he plant manager's designee, in accordance           pproved administrative procedures, and with d,             on of the basis for granting the deviation . R                      m the working hour guidelines s s shall be included in the procedures to eriodic independent review be conducted to ensure     f excessive hours have not been assigned .
: e. The senior operations manager or an operations manager shall hold an SRO license .
: f. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit . This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
PBAPS UNIT 2                              5 .0- 4                   Amendment No . -259

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff   (continued)
: a. A total of five non-licensed Operators shall be assigned for PBAPS Units 2 and 3 at all times .
: b. Each on-duty shift crew composition may be less than the minimum requirements of 10 CFR 50 .54(m)(2)(i) and Specification 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c. An individual qualified in radiation protection procedures shall be on site when fuel is in the reactor . The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
d.
(continued)
PBAPS UNIT 3                              5 .0-3                      Amendment No . 243

Organization 5 .2 5 .2    Organization 5 .2 .2        Unit Staff     (continued) controls shall include guidelines on working hours th ensu      dequate shift coverage shall be maintained wi routine          use of overtime .
Any deviation from       e above guidelines      all be authorized in advance by the plan       anager or       plant manager's designee, in accordance wi             ov ed administrative procedures, and with docu         at      of the basis for granting the deviation . Routi         eviation        the working hour guidelines shall          be authorized .
Controls      all be included in the procedures to           re a peri     c independent review be conducted to ensure t cessive hours have not been assigned .
: e. The senior operations manager or an operations manager shall hold an SRO license .
: f. An individual shall provide advisory technical support to the unit operations shift crew in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit .         This individual shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
PBAPS UNIT 3                               5 .0- 4                     Amendment No . -242 2

Organization 5 .2 5 .2    Organization 5 .2 .2         Unit Staff     (continued) a . A total of three non-licensed operators for the two units           is required in all conditions .        At least one of the required non-licensed operators shall be assigned to each unit .
: b. Shift crew composition may be less than the minimum requirement of 10 CFR 50 .54(m)(2)(i) and Specifications 5 .2 .2 .a and 5 .2 .2 .f for a period of time not to exceed 2 hours in order to accommodate unexpected absence of on-duty shift crew members provided immediate action is taken to restore the shift crew composition to within the minimum requirements .
: c. A radiation protection technician shall be on site when fuel is in the reactor .        The position may be vacant for not more than 2 hours, in order to provide for unexpected absence, provided immediate action is taken to fill the required position .
d.
: e. The operations manager or shift operations supervisor shall hold an SRO license .
: f. The Shift Technical Advisor (STA) shall provide advisory technical support to the shift manager in the areas of thermal hydraulics, reactor engineering, and plant analysis with regard to the safe operation of the unit .         In addition, the STA shall meet the qualifications specified by the Commission Policy Statement on Engineering Expertise on Shift .
Quad Cities     1 and  2                       5 .2-2               Amendment   No . - ' 44;

6.8 .1   Written procedures shall be established, implemented and maintained covenng the items referenced below :
: a. The applicable procedures recommended in Appendix "A" of Regulatory Guide 1 .33, Revision 2, February 1978 .
: b.      Surveillance and test activities of equipment that affects nuclear safety and radioactive waste management equipment.
: c. Refueling Operations.
: d. Security Plan Implementation .
: e. Fire Protection Program Implementation .
: f. Emergency Plan Implementation.
: g. Process Control Program implementation .
: h.      Offsite Dose Calculation Manual Implementation .
: i.      Quality Assurance Program for effluent and environmental monitoring using the guidance in Regulatory Guide 4.15, Revision 1 .
Deleted 6.8.2   Further, each procedure required by 6.8.1 above, and substantive changes thereto, shall be reviewed and approved as described in 6.5 .1 prior to implementation and shall be reviewed periodically as set forth in administrative procedures.
6.8.3   Temporary changes to procedures of 6.8 .1 above may be made provided :
: a. The intent of the original procedure is not altered;
: b. The change is approved by two mernbers of the licensee's management staff qualified in accordance with 6.5.1.14 and knowledgeable in the area affected by the procedure. For changes which may affect the operational status of unit systems or equipment, at least one of these individuals shall be a member of unit management or supervision holding a Senior Reactor Operator's License on the unit
: c. The change is documented, reviewed and approved as described in 6.5 .1 within 14 days of implementation.

ATTACHMENT 3 List of Regulatory Commitments The following table identifies those actions committed to by Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen) in this document . Any other statements in the submittal are provided for information purposes and are not considered to be regulatory commitments.
COMMITMENT TYPE COMMITTED           ONE-COMMITMENT DATE            TIME      PROGRAMMATIC ACTION           (Yes/No)
Yes/No Exelon Generation Company, LLC and AmerGen Energy Company, LLC will implement the 10 CFR 26, Subpart I, requirements for managing fatigue at each operating nuclear facility, concurrently with                 By October 1, implementation of the Technical                                 Yes               No 2009 Specification (TS) amendment to remove work hour limitations from TS . The intent of this commitment is to ensure that work hour limitations are controlled by either TS or regulation at all times.}}