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MONTHYEARML15148A5762015-06-11011 June 2015 Response Regarding Phase 2 Staffing Submittal Associated with Near-Term Task Force Recommendation 9.3 Related to the Fukushima Dai-Ichi Nuclear Power Plant Accident Project stage: Other 2015-06-11
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Category:Letter
MONTHYEARIR 05000352/20250102024-09-10010 September 2024 Information Request for Quadrennial Baseline Comprehensive Engineering Team Inspection; Notification to Perform Inspection 05000352/2025010 and 05000353/2025010 IR 05000352/20230022024-09-0404 September 2024 Reissued Integrated Inspection Report 05000352/2023002 and 05000353/2023002 IR 05000352/20240052024-08-29029 August 2024 Updated Inspection Plan for Limerick Generating Station, Units 1 and 2 (Report 05000352/2024005 and 05000353/2024005) ML24241A1952024-08-28028 August 2024 License Amendment Request for Modification to Technical Specification 3.6.1.2 and Main Steam Isolation Valve Leakage Rate Requirements ML24239A3972024-08-23023 August 2024 Rssc Wire & Cable LLC Dba Marmon - Part 21 Final Notification - 57243-EN 57243 IR 05000352/20240022024-08-12012 August 2024 Integrated Inspection Report 05000352/2024002 and 05000353/2024002 ML24220A2392024-08-12012 August 2024 Correction to Technical Specification Page 3/4 3-11 in Amendment No. 225 ML24222A6772024-08-0909 August 2024 Response to Request for Additional Information for Application to Revise Technical Specifications to Adopt TSTF-591-A, “Revise Risk Informed Completion Time (RICT) Program” Revision 0 and Revise 10 CFR 50.69 License Condition ML24204A0712024-07-29029 July 2024 Issuance of Amendment Nos. 263 and 225 Technical Specifications for Main Steam Line Tunnel Temperature ML24208A0962024-07-25025 July 2024 57243-EN 57243 - Rssc Wire & Cable LLC, Dba Marmon - Part 21 Notification ML24208A1592024-07-25025 July 2024 Regulatory Audit Plan Supporting Review of the System Development Portion of Limerick Digital Instrumentation and Controls License Amendment Request (EPID L-2022-LLA-0140) - Non-Proprietary ML24201A1662024-07-19019 July 2024 Response to Request for Additional Information for License Amendment Request for Proposed Changes to the Technical Specification Isolation Actuation Instrumentation Tables and New Turbine Enclosure Main Steam L ML24199A1842024-07-15015 July 2024 RAI-LAR for Limerick EPID: L-2024-LLA-0079- Use This Version RS-24-070, Independent Spent Fuel Storage Installation, Nine Mile Point, Units 1 and 2, Quad Cities, Units 1 and 2, R. E. Ginna - Nuclear Radiological Emergency Plan Document Revisions2024-07-12012 July 2024 Independent Spent Fuel Storage Installation, Nine Mile Point, Units 1 and 2, Quad Cities, Units 1 and 2, R. E. Ginna - Nuclear Radiological Emergency Plan Document Revisions ML24180A1572024-06-28028 June 2024 Request to Return and Replace WEC Documents (EQ-EV-386-GLIM, EQ-QR- 433-GLIM, and APP-GW-GLR-611), to Meet 10CFR2.390 Request to Withdraw from Public Disclosure Requirements ML24170A7702024-06-20020 June 2024 Individual Notice of Consideration of Issuance of Amendments to Renewed Facility Operating Licenses, Proposed No Significant Hazards Consideration Determination, Opportunity for Hearing(Epid L-2024-LLA-0079) LTR ML24166A1142024-06-14014 June 2024 Response to Requests for Additional Information (RAIs 15 Through 23) for License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems RS-24-061, Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Examinations2024-06-14014 June 2024 Constellation Energy Generation, LLC, Response to NRC Regulatory Issue Summary 2024-01, Preparation and Scheduling of Operator Licensing Examinations ML24165A2642024-06-13013 June 2024 License Amendment Request for Proposed Changes to the Technical Specification Isolation Actuation Instrumentation Tables and New Turbine Enclosure Main Steam Line Tunnel Temperature TS 3/4.7.9 ML24151A2882024-06-10010 June 2024 Request for Withholding Information from Public Disclosure ML24151A2012024-06-10010 June 2024 Request for Withholding Information from Public Disclosure ML24150A0242024-05-29029 May 2024 Notification of Commercial Grade Dedication Inspection (05000352/2024012 and 05000353/2024012) and Request for Information ML24149A2112024-05-28028 May 2024 Supplement to License Amendment Request to Revise Technical Specifications and Exemption Request from Requirements of 10CFR50.62 ATWS Rule to Support the Digital Modernization Project Installation ML24079A0762024-05-23023 May 2024 Issuance of Amendments to Adopt TSTF 264 IR 05000352/20243022024-05-20020 May 2024 Revised Initial Operator Licensing Examination Report 05000352/2024302 and 05000353/2024302 RS-24-055, 2023 Corporate Regulatory Commitment Change Summary Report2024-05-17017 May 2024 2023 Corporate Regulatory Commitment Change Summary Report IR 05000352/20240012024-05-0707 May 2024 Integrated Inspection Report 05000352/2024001 and 05000353/2024001 ML24124A0432024-05-0303 May 2024 Response to Requests for Additional Information (RAIs 9 Through 14) for License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with RS-24-038, Relief Request Concerning Extension of Permanent Relief from Ultrasonic Examination of Reactor Pressure Vessel Circumferential Shell Welds2024-05-0202 May 2024 Relief Request Concerning Extension of Permanent Relief from Ultrasonic Examination of Reactor Pressure Vessel Circumferential Shell Welds RS-24-041, Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests2024-04-30030 April 2024 Alternative Request to Utilize Code Case OMN-32, Alternative Requirements for Range and Accuracy of Pressure, Flow, and Differential Pressure Instruments Used in Pump Tests ML24114A3222024-04-23023 April 2024 Supplement to License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System (PPS) - Pivot to Unit ML24109A0702024-04-18018 April 2024 Supplement to License Amendment Request to Revise Technical Specifications and Exemption Request from Requirements of 10CFRC50.52 ATWS Rule to Support the Digital Modernization Project Installation . ML24093A0912024-04-17017 April 2024 Revised Estimated Review Completion Date Concerning License Amendment Request to Replace Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System ML24106A1832024-04-15015 April 2024 Submittal of Changes to Technical Specifications Bases ML24103A2042024-04-12012 April 2024 Constellation Energy Generation, LLC, Application to Revise Technical Specifications to Adopt TSTF-591-A, Revise Risk Informed Completion Time (RICT) Program Revision 0 and Revise 10 CFR 50.69 License Condition ML24096A1372024-04-0505 April 2024 Request for Exemption from Certain Requirements of 10 CFR 72.212 and 10 CFR 72.214 for Limerick Generating Station – Holtec MPC-89CBS RS-24-002, Constellation Energy Generation, LLC - Annual Property Insurance Status Report2024-04-0101 April 2024 Constellation Energy Generation, LLC - Annual Property Insurance Status Report IR 05000352/20244012024-03-19019 March 2024 Security Baseline Inspection Report 05000352/2024401 and 05000353/2024401 IR 05000352/20240102024-03-18018 March 2024 Biennial Problem Identification and Resolution Inspection Report 05000352/2024010 and 05000353/2024010 ML24078A2752024-03-18018 March 2024 Response to Requests for Additional Information (RAIs 5, 6, 7, and 8) for License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog ML24067A2942024-03-0707 March 2024 Response to Requests for Additional Information (RAI 4, RAI 1.c Revision) for License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related. IR 05000352/20230062024-02-28028 February 2024 Annual Assessment Letter for Limerick Generating Station, Units 1 and 2 (Reports 05000352/2023006 and 05000353/2023006) ML24057A4272024-02-26026 February 2024 Response to Requests for Additional Information (RAIs 1, 2, and 3) for License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control ML24088A1102024-02-25025 February 2024 Fairbanks Morse (Fm) Part 21 Notification Report Number 23-01 Re Asco Stainless Steel Solenoid Valves ML24039A0762024-02-12012 February 2024 Senior Reactor and Reactor Operator Initial License Examinations IR 05000352/20243012024-02-0202 February 2024 Initial Operator Licensing Examination Report 05000352/2024301 and 05000353/2024301 IR 05000352/20230042024-01-31031 January 2024 Integrated Inspection Report 05000352/2023004 and 05000353/2023004 IR 05000352/20240112024-01-31031 January 2024 Information Request to Support Post-Approval Site Inspection for License Renewal; Inspection Report 05000352/2024011 ML24026A2962024-01-26026 January 2024 Supplement to License Amendment Request to Revise the Licensing and Design Basis to Incorporate the Replacement of Existing Safety-Related Analog Control Systems with a Single Digital Plant Protection System (PPS)- Syrs, . ML24004A0342024-01-17017 January 2024 Exemption from Select Requirements of 10 CFR Part 73 (EPID L-2023-LLE-0026 (Security Notifications, Reports, and Recordkeeping and Suspicious Activity Reporting)) 2024-09-04
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 June11,2015 Mr. Bryan C. Hanson President and Chief Nuclear Officer Exelon Nuclear 4300 Winfield Rd.
Warrenville, IL 60555
SUBJECT:
LIMERICK GENERATING STATION, UNITS 1 AND 2 - RESPONSE REGARDING PHASE 2 STAFFING SUBMITTALS ASSOCIATED WITH NEAR-TERM TASK FORCE RECOMMENDATION 9.3 RELATED TO THE FUKUSHIMA DAl-ICHI NUCLEAR POWER PLANT ACCIDENT (TAC NOS.
MF5377 AND MF5378)
Dear Mr. Hanson:
By letter dated March 12, 2012 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML12053A340), the U.S. Nuclear Regulatory Commission (NRC) issued a request for information pursuant to Title 10 of the Code of Federal Regulations (1 O CFR) Part 50, Section 50.54(f) (hereafter referred to as the 50.54{f) letter), regarding Recommendations 2.1 (seismic and flooding evaluations), 2.3 (seismic and flooding walkdowns), and 9.3 (emergency preparedness communication and staffing) of the Near-Term Task Force (NTTF) review of insights from the Fukushima Dai-icni accident. With respect to Recommendation 9.3, Enclosure 5 to the NRC's letter requested licensees and holders of construction permits to assess their means to power communications equipment onsite and offsite during a prolonged station blackout (SBO) event and to perform a staffing assessment to determine the staff required to fill all necessary positions in response to a multi-unit event.
The 50.54(f) letter in part, required licensee responses pursuant to the provisions of 10 CFR 50.54(f) pertaining to onsite and augmented staff availability to implement the strategies discussed in the emergency plan and/or plant operating procedures including new staff or functions resulting from the assessment, any identified collateral duties, an implementation schedule to perform the assessments, any identified modifications, and any changes that have been made or will be made to the emergency plan regarding or-1-shift or augmented staffing. In addition, NTTF Recommendation 9.3 has a dependency on the implementation of NTTF Recommendation 4.2 (mitigating strategies). As a result of this dependency, licensees responded to the 50.54(f) letter in phases. The Phase 1 staffing assessment requested licensees to evaluate their ability to respond to a multi-unit extended loss of alternating current (ac) power (ELAP) event utilizing existing processes and procedures. The licensee responses to the 50.54(f) letter for Phase 1 staffing assessments for multi-unit sites were received and evaluated by the NRC staff by April 30, 2013. The staff issued acknowledgement letters to all licensees with multi-unit sites, with the exception of San Onofre Nuclear Generating Station, by April 28, 2014.
B. Hanson Licensees were also requested to submit for NRC staff review a Phase 2 staffing assessment, which provides an assessment of the staffing necessary to perform the functions related to the strategies developed in response to NTTF Recommendation 4.2 and the resulting Order EA 049, "Order to Modify Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events [BDBEE]" (ADAMS Accession No. ML12054A736).
Licensees were requested to provide their Phase 2 Staffing Assessments to the NRC no later than four months prior to the beginning of their second refueling outage (as used in the context of NRC Order EA-12-049). By letter dated December 5, 2014 (ADAMS Accession No.
ML14339A754), Exelon Generation Company, LLC (the licensee) submitted its Phase 2 staffing assessment for Limerick Generating Station, Units 1 and 2 to the NRC in response to the 50.54(f) letter. This submittal also references a non-public (Safeguards Information) attachment submitted by separate letter on the same date.
The NRC staff reviewed your Phase 2 assessment for staffing in accordance with the assumptions and guidelines of Sections 2.2, 2.3, and 3 of the Nuclear Energy Institute (NEI) guidance document NEI 12-01, "Guideline for Assessing Beyond Design Basis Accident Response Staffing and Communications Capabilities," (ADAMS Accession No. ML12125A412),
which was endorsed by the NRC staff by letter dated May 15, 2012 (ADAMS Accession No.
ML12131A043). The NRC staff noted that you assessed your current onsite minimum staffing levels to identify any enhancements needed to respond following a beyond-design-basis large-scale natural event, and to ensure that the strategies contained in the existing emergency plan and/or plant operating procedures, such as those used in response to a SBO, can be performed by the site staff. Your assessment assumed that a large-scale natural event causes: (1) an ELAP, (2) all units on the site to be affected, and (3) access to the site to be impeded for a minimum of six hours. You also assessed your capability to perform the site specific functions related to the strategies developed in response to NTTF Recommendation 4.2 and the resulting Order EA-12-049. You conducted independent reviews and concluded, based on your staffing assessment, that the existing on-shift minimum staff is sufficient to implement the existing loss of all ac power, multi-unit event response strategies, including those strategies developed to support the requirements of NRC Order EA-12-049, while supporting performance of the required emergency planning duties without unacceptable collateral duties.
The NRC staff reviewed your Phase 2 staffing submittal and confirmed that your existing emergency response resources, as described in your emergency plan, are sufficient to perform the required plant actions and emergency plan functions, and implement the multi-unit event response strategies that were developed in response to NRC Order EA-12-049 without the assignment of collateral duties that would impact the performance of assigned emergency plan functions.
As a result, the NRC staff concludes that your Phase 2 staffing submittal adequately addresses the response strategies needed to respond to a BDBEE using your procedures and guidelines.
The NRC staff will verify the implementation of your staffing capabilities through the inspection program.
B. Hanson If you have any questions regarding this letter, please contact Stephen Philpott at (301) 415-2365 or via email at Stephen.Philpott@nrc.gov.
Mandy K. Halter, Acting Branch Chief Orders Management Branch Japan Lessons-Learned Division Office of Nuclear Reactor Regulation Docket Nos. 50-352 and 50-353 cc: Distribution via Listserv
ML15148A576 *via email OFFICE NRR/JLD/JOMB/PM NRR/JLD/LA NSIR/DPR/DDEP/NRLB/BC* NRR/JLD/JOMB/BC(A)
NAME SPhilpott Slent ARivera (KThomas for) MHalter DATE 06/05/15 05/29/15 06/10/15 06/11/15