ML16244A311

Request for Additional Information Regarding License Amendment Request for Technical Specifications Section 6.0, Administrative Controls for Permanently Defueled Condition

ML16244A311
Person / Time
Site:	Oyster Creek
Issue date:	10/07/2016
From:	John Lamb Plant Licensing Branch IV
To:	Bryan Hanson Exelon Generation Co
Lamb J, NRR/DORL/LPL1-2, 415-3100
References
TAC MF8108
Download: ML16244A311 (5)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 October 7, 2016

SUBJECT:

OYSTER CREEK NUCLEAR GENERATING STATION -REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST FOR CHANGES TO TECHNICAL SPECIFICATIONS SECTION 6.0, "ADMINISTRATIVE CONTROLS" FOR PERMANENTLY DEFUELED CONDITION (CAC NO. MF8108)

Dear Mr. Hanson:

By letter dated May 17, 2016 (Agencywide Documents Access and Management System Accession No. ML16138A129), Exelon Generation Company, LLC (Exelon or the licensee) submitted to the U.S. Nuclear Regulatory Commission (NRC) a license amendment request for changes to Technical Specification Sections 6.0, Administrative Controls," for permanently defueled condition for Oyster Creek Nuclear Generating Station. The NRC staff has reviewed the licensee's submittal and determined additional information is required to enable the NRC staff to make an independent assessment regarding its technical review. The enclosure to this letter describes this request for additional information (RAI). On September 26, 2016, the draft questions were sent to Mr. David Helker, Mr. Richard Gropp, and Mr. Paul Bonnet of your staff to ensure that they were understandable, the regulatory bases for the questions were clear, and to determine if the information was previously docketed.

A teleconference was held on October 5, 2016, to clarify the RAI questions.

Exelon stated that they would respond to the RAI within 30 days of the date of this letter.

B. Hanson If you have any questions, please contact me at 301-415-3100 or via e-mail at John.Lamb@nrc.gov.

Docket No. 50-219

Enclosure:

Request for Additional Information cc w/encl: Distribution via Listserv Jo n . Lamb, Senior Project Manager Pl n Licensing IV-2 and Decommissioning ra sition Branch Di i ion of Operating Reactor Licensing 0

• e of Nuclear Reactor Regulation REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST FOR CHANGES TO TECHNICAL SPECIFICATIONS 6.0, "ADMINISTRATIVE CONTROLS" FOR PERMANENTLY DEFUELED CONDITION EXELON GENERATION COMPANY, LLC OYSTER CREEK NUCLEAR GENERATING STATION DOCKET NO. 50-219 By letter dated May 17, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML16138A129), Exelon Generation Company, LLC (Exelon or the licensee) submitted to the U.S. Nuclear Regulatory Commission (NRC) a license amendment request (LAA) for changes to Technical Specifications (TS) Section 6.0, Administrative Controls," for permanently defueled condition for the Oyster Creek Nuclear Generating Station (OCNGS). The NRC staff has reviewed the licensee's submittal and has determined that additional information is required to enable the NRC staff to make an independent assessment regarding its technical review. RAI 1. Currently, the Vice President is responsible for overall facility operation in TS 6.1. The Vice President is clearly a "Responsible officer

in accordance with Title 10 of the Code of Federal Regulations (1 O CFR), Part 50, Section 2, "Definitions." Responsible officer means, for the purposes of§ 50.55(e) of this chapter, the president, vice-president, or other individual in the organization of a corporation, partnership, or other entity who is vested with executive authority over activities subject to this part. Will the Plant Manager be vested with similar executive authority that the current Vice President has? 2. In the proposed change to TS 6.1.1, you state the following: "The Plant Manager or delegated designee shall approve, prior to implementation, each proposed test, experiment, or modification to systems or equipment that affect safe storage and maintenance." Briefly explain your succession plan for the "delegated designee?" Enclosure 3. Currently, in TS 6.2: "The Chief Nuclear Officer shall have corporate responsibility for overall plant nuclear safety .... " The proposed change states "A specified corporate officer shall have corporate responsibility for overall facility nuclear safety .... " Responsible officer means, for the purposes of§ 50.55(e) of this chapter, the president, vice-president, or other individual in the organization of a corporation, partnership, or other entity who is vested with executive authority over activities subject to this part. The term "specified corporate officer" is not defined in the Oyster Creek TSs. Define the definition of "specified corporate officer" in the Oyster Creek TSs or change the "specified corporate officer" to an existing defined term. Will the "specified corporate officer

be located onsite at OCNGS or at another location?

Will the "specified corporate officer

be vested with similar executive authority that the current Chief Nuclear Officer has? Will the Plant Manager be the "specified corporate officer

or will it be another person? If the "specified corporate officer

is not the Plant Manager, briefly explain who will fill the "specified corporate position?" 4. Currently, in proposed TS 6.2, the term "non-certified operator

is used. The term certified operator

is not defined in the Oyster Creek TSs. Define the definition of certified operator

in the Oyster Creek TSs or change the "non-certified operator" to an existing defined term. 5. As documented in Enforcement Guidance Memorandum (EGM) 2012-001, "Dispositioning Noncompliance with Administrative Controls Technical Specifications Programmatic Requirements That Extend Test Frequencies and Allow Performance of Missed Tests," the allowances permitted by TS 4.0.2 and TS 1.24 cannot be applied to TS Administrative Controls Program activities such as Oyster Creek's TS Section 6.8.4.a, "Radioactive Effluent Controls Program" unless such activity is associated with a Limiting Condition for Operation Surveillance Requirement.

NRG-approved Technical Specifications Task Force (TSTF) Standard Technical Specifications (STS) Change Traveler TSTF-545, Revision 3, "TS lnservice Testing [IST] Program Removal & Clarify SR [Surveillance Requirement]

Usage Rule Application to Section 5.5 Testing" (ADAMS Accession No. ML15294A555), dated October 21, 2015, addressed the issues identified in EGM 2012-001.

Provide a technical justification on the acceptability of allowing the use of TS 4.0.2 and 1.24 for TS 6.8.4.a activities.

B. Hanson If you have any questions, please contact me at 301-415-3100 or via e-mail at John.Lamb@nrc.gov.

Docket No. 50-219

Enclosure:

Sincerely, IRA! John G. Lamb, Senior Project Manager Plant Licensing IV-2 and Decommissioning Transition Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Request for Additional Information cc w/encl: Distribution via Listserv DISTRIBUTION:

PUBLIC LPL4-2 R/F RidsNrrDorllpl4-2 Resource RidsNrrDraAphb Resource RidsRgn1 MailCenter Resource RidsACRS_MailCTR Resource ADAMS Accession No.: ML16244A311

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NRR/DORL/LPL4-2/PM SKoenick Jlamb 10/6/16 10/7/16