ML18149A293

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License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements
ML18149A293
Person / Time
Site: Peach Bottom, Limerick  Constellation icon.png
Issue date: 05/10/2018
From: Jim Barstow
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
Shared Package
ML18149A290 List:
References
Download: ML18149A293 (3)


Text

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~ Exelon Generation 200 Exelon Way Kennett Square. PA 19348 www.exeloncorp.com 10 CFR 50J~O.

10 CFR 50.54(q)

May 10, 2018 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, DC 20555-0001 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRG Docket Nos. 50-352, 50-353, and 72-65 Peach Bottom Atomic Power Station, Units 1, 2, and 3 Facility Operating [Possession Only] License No. DPR-12 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRG Docket Nos. 50-171, 50-277, 50-278 and 72-79

Subject:

License Amendment Request for Approval of Changes to Emergency Plan Staffing Requirements Pursuant to 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit," Exelon Generation Company, LLC (Exelon) requests amendments to licenses for the facilities listed above.

10 CFR 50.47(b) and 10 CFR 50, Appendix E establish emergency planning standards that require: 1) adequate staffing, 2) satisfactory performance of key functional areas and critical tasks, and 3) timely augmentation of the response capability.

Exelon is requesting U.S. Nuclear Regulatory Commission (NRG) approval of proposed changes to the Radiological Emergency Preparedness Plans for the facilities listed above. The proposed changes would revise certain Emergency Response Organization (ERO) positions for facilities listed with the minimum staff ERO guidance specified in draft Revision 2 of NUREG-0654/FEMA-REP-1, "Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of Nuclear Power Plants."

The proposed changes have been reviewed considering the requirements of 10 CFR 50.47, "Emergency plans," paragraph (b), 10 CFR 50 Appendix E, "Emergency Planning and Preparedness for Production and Utilization Facilities," and other applicable emergency preparedness NRG guidance documents. An evaluation of the proposed changes pursuant to 1o CFR 50.54, "Conditions of licenses," paragraph (q), "Emergency plans," determined that the proposed changes result in a reduction in effectiveness of the Emergency Plans for the affected . c' facilities and, therefore, require prior NRG approval. Jr,)(4?

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U.S. Nuclear Regulatory Commission License Amendment Request Changes to Emergency Plan Staffing Docket Nos. 50-352, 50-353, 72-65, 50-171, 50-277, 50-278, and 72-79 May 10, 2018 Page 2 Exelon has concluded that the proposed changes present no significant hazards consideration under the standards set forth in 10 CFR 50.92, "Issuance of amendments."

The proposed changes have been reviewed by the Plant Operations Review Committees at each site in accordance with the. requirements of the Exelon Quality Assurance Program.

The following enclosures, along with supporting attachments, are provided which contain an evaluation of the proposed changes, including a detailed description, technical and regulatory evaluations including a no significant hazards consideration, and environmental consideration for each facility.

  • Enclosure 1 - Limerick Generating Station, Units 1 and 2 - Evaluation of Proposed Changes o Attachment 1A - Emergency Plan Marked-up Pages o Attachment 1B - Emergency Plan Clean Copy Pages
  • Enclosure 2 - Peach Bottom Atomic Power Station, Units 2 and 3 - Evaluation of Proposed Changes o Attachment 2A - Emergency Plan Marked-up pages o Attachment 28 - Emergency Plan Clean Copy pages
  • Enclosure 3 - Assessment of ERO Minimum Staff and Full-Augmented Staff Positions Removed
  • Enclosure 4 - Summary of Commitments
  • Enclosure 5 - Information Related to Review of Proposed Changes by the States This amendment request includes a regulatory commitment as described in Enclosure 4 of this submittal. Exelon plans to conduct a confirmation Emergency Preparedness Drill at one of the affected stations under this License Amendment Request to demonstrate that no loss of function will result due to the proposed changes in the ERO.

Exelon is requesting approval of the proposed license amendments by September 1, 2019.

Once approved, Exelon is requesting that the amendments for the affected facilities be implemented no later than December 31, 2019.

In accordance with 10 CFR 50.91, "Notice for public comment; State consultation," paragraph (b), Exelon is notifying the Commonwealth of Pennsylvania of this application for these license amendments by transmitting a copy of this letter and the supporting attachments to the designated State Official.

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U.S. Nuclear Regulatory Commission License Amendment Request Changes to Emergency Plan Staffing Docket Nos. 50-352, 50-353, 72-65, 50-171, 50-277, 50-278, and 72-79 May 10, 2018 Page3 If you have any questions regarding this submittal, please contact Richard Gropp at (610) 765-5557.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 1Qth day of May 2018.

Resp~tl~ ~

James Barstow Director, Licensing and Regulatory Affairs Exelon Generation Company, LLC Enclosures (including supporting attachments) (CD copy):

1) Limerick Generating Station, Units 1 and 2 - Evaluation of Proposed Changes
2) Peach Bottom Atomic Power Station, Units 2 and 3 - Evaluation of Proposed Changes
3) Assessment of ERO Minimum Staff and Full-Augmented Staff Positions Removed
4) Summary of Regulatory Commitments
5) Information Related to Review of Proposed Changes by the States cc: w/ Enclosures (including supporting attachments) (CD copy)

Regional Administrator - NRG Region I NRG Senior Resident Inspector - Limerick Generating Station NRG Senior Resident Inspector - Peach Bottom Atomic Power Station NRG Project Manager, NRR - Limerick Generating Station NRG Project Manager, NRR - Peach Bottom Atomic Power Station Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Protection R.R. Janati, Pennsylvania Bureau of Radiation Protection S.T. Gray, State of Maryland