RA-15-089, Fleet Commitment to Maintain Severe Accident Management Guidelines

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Fleet Commitment to Maintain Severe Accident Management Guidelines
ML15338A125
Person / Time
Site: Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Oyster Creek, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, LaSalle, Crane
Issue date: 12/04/2015
From: Jim Barstow
Exelon Generation Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
RA-15-089, RS-15-285, TMI-15-120
Download: ML15338A125 (18)


Text

Exelon Generation RS-15-285 RA-15-089 TMl-15-120 December 4, 2015 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 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 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 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 Docket Nos. 50-220 and 50-41 O Oyster Creek Nuclear Generating Station, Unit 1 Renewed 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

U.S. Nuclear Regulatory Commission Commitment to Maintain SAMGs December 4, 2015 Page 2 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRG Docket Nos. 50-254 and 50-265 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRG Docket No. 50-244 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRG Docket No. 50-289

Subject:

Exelon Generation Company, LLC Fleet Commitment to Maintain Severe Accident Management Guidelines The Nuclear Energy Institute (NEI) Nuclear Strategic Issues Advisory Committee (NSIAC) recently approved an Industry Initiative to implement and maintain Severe Accident Management Guidelines (SAMGs). This letter establishes commitments related to SAMG for the EGG fleet sites listed above. These guidelines would be used by emergency response personnel during accident conditions that progress beyond the mitigation capabilities described in Emergency Operating Procedures (EOPs). SAMG strategies are intended to arrest the progression of fuel damage, maintain the capability of the containment as long as possible, and minimize radiological releases.

It is expected that NRG staff personnel will conduct periodic inspection of our SAMGs and performance deficiencies, if any, will be assessed using the Reactor Oversight Process. We also understand that inspection activities will not extend to NRG review and approval of SAMG strategies, or the use of equipment described in the SAMGs.

This letter contains new regulatory commitments, which are identified in the enclosures to this letter.

If you have any questions regarding this report, please contact Ronald Gaston at 630-657-3359.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 4th day of December 2015.

Respectfully submitted, a ~ ~

James Barstow Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC

U.S. Nuclear Regulatory Commission Commitment to Maintain SAMGs December 4, 2015 Page 3

Enclosures:

1. EGC Corporate Engineering - Summary of Regulatory Commitments
2. Braidwood Station, Units 1 and 2 - Summary of Regulatory Commitments
3. Byron Station, Units 1 and 2 - Summary of Regulatory Commitments
4. Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Summary of Regulatory Commitments
5. Clinton Power Station, Unit 1 - Summary of Regulatory Commitments
6. Dresden Nuclear Power Station, Units 2 and 3 - Summary of Regulatory Commitments
7. LaSalle County Station, Units 1 and 2 - Summary of Regulatory Commitments
8. Limerick Generating Station, Units 1 and 2 - Summary of Regulatory Commitments
9. Nine Mile Point Nuclear Station, Units 1 and 2 - Summary of Regulatory Commitments 1 O. Oyster Creek Nuclear Generating Station - Summary of Regulatory Commitments
11. Peach Bottom Atomic Power Station, Units 2 and 3 - Summary of Regulatory Commitments
12. Quad Cities Nuclear Power Station, Units 1 and 2 - Summary of Regulatory Commitments
13. R. E. Ginna Nuclear Power Plant - Summary of Regulatory Commitments
14. Three Mile Island Nuclear Station, Unit 1 - Summary of Regulatory Commitments

U.S. Nuclear Regulatory Commission Commitment to Maintain SAMGs December 4, 2015 Page 4 cc:

Director, Office of Nuclear Reactor Regulation Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector-Calvert Cliffs Nuclear Power Plant 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 - Nine Mile Point Nuclear 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 - R. E. Ginna Nuclear Power Plant NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR - Braidwood Station NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Calvert Cliffs Nuclear Power Plant 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, NRA - Limerick Generating Station NRC Project Manager, NRR - Nine Mile Point Nuclear 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 - R. E. Ginna Nuclear Power Plant NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Manager, 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 S. T. Gray, State of Maryland R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

1.

EGC - Corporate Engineering

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

EGC will consider the site SAMGs within plant configuration management processes October 31, 2016 No Yes in order to ensure that the SAMGs reflect changes to the facility over time.

1.

Braidwood Station, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Braidwood Station, Units 1 and 2 will update the site SAMGs to future revisions of the PWROG generic severe accident technical Within 2 refueling guidelines, and the SAMGs will be integrated outages or 3 years with other emergency response guideline of the publication sets and symptom-based Emergency date of the No Yes Operating Procedures, and validated, using guidelines, the guidance in NEI 14-01, "Emergency whichever is Response Procedures and Guidelines for greater Beyond Design Basis Events and Severe Accidents".

1.

Byron Station, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Byron Station, Units 1 and 2 will update the site SAMGs to future revisions of the PWROG generic severe accident technical Within 2 refueling guidelines, and the SAMGs will be integrated outages or 3 years with other emergency response guideline of the publication sets and symptom-based Emergency date of the No Yes Operating Procedures, and validated, using guidelines, the guidance in NEI 14-01, "Emergency whichever is Response Procedures and Guidelines for greater Beyond Design Basis Events and Severe Accidents".

1.

Calvert Cliffs Nuclear Power Plant, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Calvert Cliffs Nuclear Power Plant, Units 1 and 2 will update the site SAMGs to future revisions of the PWROG generic severe accident technical guidelines, and the Within 2 refueling SAMGs will be integrated with other outages or 3 years emergency response guideline sets and of the publication symptom-based Emergency Operating date of the No Yes Procedures, and validated, using the guidelines, guidance in NEI 14-01, "Emergency whichever is Response Procedures and Guidelines for greater Beyond Design Basis Events and Severe Accidents".

1.
2.

Clinton Power Station, Unit 1

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Clinton Power Station, Unit 1 will update the site SAMGs to revision 3 of the BWROG June 30, 2017 Yes No generic severe accident guidelines (published February, 2013).

Clinton Power Station, Unit 1 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be integrated Within 2 refueling with other emergency response guideline outages or 3 years sets and symptom-based Emergency of the publication Operating Procedures, and validated, using date of the No Yes the guidance in NEI 14-01, "Emergency guidelines, Response Procedures and Guidelines for whichever is Beyond Design Basis Events and Severe greater Accidents". 1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident guidelines.

1.
2.

Dresden Nuclear Power Station, Units 2 and 3

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Dresden Nuclear Power Station, Units 2 and 3 will update the site SAMGs to revision 3 of June 30, 2017 Yes No the BWROG generic severe accident guidelines (published February, 2013).

Dresden Nuclear Power Station, Units 2 and 3 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be integrated with other Within 2 refueling emergency response guideline sets and outages or 3 years symptom-based Emergency Operating of the publication Procedures, and validated, using the date of the No Yes guidance in NEI 14-01, "Emergency guidelines, Response Procedures and Guidelines for whichever is Beyond Design Basis Events and Severe Accidents". 1 greater Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident guidelines.

1.
2.

LaSalle County Station, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRG for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

LaSalle County Station, Units 1 and 2 will update the site SAMGs to revision 3 of the June 30, 2017 Yes No BWROG generic severe accident guidelines (published February, 2013).

LaSalle County Station, Units 1 and 2 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be Within 2 refueling integrated with other emergency response outages or 3 years guideline sets and symptom-based of the publication Emergency Operating Procedures, and date of the No Yes validated, using the guidance in NEI 14-01, guidelines, "Emergency Response Procedures and whichever is Guidelines for Beyond Design Basis Events greater and Severe Accidents".1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident guidelines.

1.
2.

Limerick Generating Station, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED I COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Limerick Generating Station, Units 1 and 2 will update the site SAMGs to revision 3 of June 30, 2017 Yes No the BWROG generic severe accident guidelines (published February, 2013).

Limerick Generating Station, Units 1 and 2 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be integrated with other Within 2 refueling emergency response guideline sets and outages or 3 years symptom-based Emergency Operating of the publication Procedures, and validated, using the date of the No Yes guidance in NEI 14-01, "Emergency guidelines, Response Procedures and Guidelines for whichever is Beyond Design Basis Events and Severe greater Accidents". 1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident guidelines.

I

I

1.
2.

Nine Mile Point Nuclear Station, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

I COMMITTED I COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Nine Mile Point Nuclear Station, Units 1 and 2 will update the site SAMGs to revision June 30, 2017 Yes No 3 of the BWROG generic severe accident guidelines (published February, 2013).

Nine Mile Point Nuclear Station, Units 1 and 2 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be integrated with other Within 2 refueling emergency response guideline sets and outages or 3 years symptom-based Emergency Operating of the publication Procedures, and validated, using the date of the No Yes guidance in NEI 14-01, "Emergency guidelines, Response Procedures and Guidelines for whichever is Beyond Design Basis Events and Severe greater Accidents". 1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident guidelines.

I

1.
2. 0 Oyster Creek Nuclear Generating Station

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRG for the NRC's information and are not regulatory commitments.)

COMMITTED I COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Oyster Creek Nuclear Generating Station will update the site SAMGs to revision 3 of the June 30, 2017 Yes No BWROG generic severe accident guidelines (published February, 2013).

Oyster Creek Nuclear Generating Station will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be Within 2 refueling integrated with other emergency response outages or 3 years guideline sets and symptom-based of the publication Emergency Operating Procedures, and date of the No Yes validated, using the guidance in NEI 14-01, guidelines, "Emergency Response Procedures and whichever is Guidelines for Beyond Design Basis Events greater and Severe Accidents". 1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident quidelines.

I

1.
2. 1 Peach Bottom Atomic Power Station, Units 2 and 3

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Peach Bottom Atomic Power Station, Units 2 and 3 will update the site SAMGs to revision June 30, 2017 Yes No 3 of the BWROG generic severe accident guidelines (published February, 2013).

Peach Bottom Atomic Power Station, Units 2 and 3 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be integrated with other Within 2 refueling emergency response guideline sets and outages or 3 years symptom-based Emergency Operating of the publication Procedures, and validated, using the date of the No Yes guidance in NEI 14-01, "Emergency guidelines, Response Procedures and Guidelines for whichever is Beyond Design Basis Events and Severe greater Accidents". 1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident Quidelines.

1.
2. 2 Quad Cities Nuclear Power Station, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Quad Cities Nuclear Power Station, Units 1 and 2 will update the site SAMGs to revision June 30, 2017 Yes No 3 of the BWROG generic severe accident guidelines (published February, 2013).

Quad Cities Nuclear Power Station, Units 1 and 2 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be integrated with other Within 2 refueling emergency response guideline sets and outages or 3 years symptom-based Emergency Operating of the publication Procedures, and validated, using the date of the No Yes guidance in NEI 14-01, "Emergency guidelines, Response Procedures and Guidelines for whichever is Beyond Design Basis Events and Severe greater Accidents". 1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident guidelines.

1. 3 R. E. Ginna Nuclear Power Plant

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

R. E. Ginna Nuclear Power Plant will update the site SAMGs to future revisions of the PWROG generic severe accident technical Within 2 refueling guidelines, and the SAMGs will be integrated outages or 3 years with other emergency response guideline of the publication sets and symptom-based Emergency date of the No Yes Operating Procedures, and validated, using guidelines, the guidance in NEI 14-01, "Emergency whichever is Response Procedures and Guidelines for greater Beyond Design Basis Events and Severe Accidents".

1. 4 Three Mile Island Nuclear Station, Unit 1

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRG for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Three Mile Island Nuclear Station, Unit 1 will update the site SAMGs to future revisions of the PWROG generic severe accident Within 2 refueling technical guidelines, and the SAMGs will be outages or 3 years integrated with other emergency response of the publication guideline sets and symptom-based date of the No Yes Emergency Operating Procedures, and guidelines, validated, using the guidance in NEI 14-01, whichever is "Emergency Response Procedures and greater Guidelines for Beyond Design Basis Events and Severe Accidents".

Exelon Generation RS-15-285 RA-15-089 TMl-15-120 December 4, 2015 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 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. 50-317 and 50-318 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 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352 and 50-353 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 Docket Nos. 50-220 and 50-41 O Oyster Creek Nuclear Generating Station, Unit 1 Renewed 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

U.S. Nuclear Regulatory Commission Commitment to Maintain SAMGs December 4, 2015 Page 2 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRG Docket Nos. 50-254 and 50-265 R. E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRG Docket No. 50-244 Three Mile Island Nuclear Station, Unit 1 Renewed Facility Operating License No. DPR-50 NRG Docket No. 50-289

Subject:

Exelon Generation Company, LLC Fleet Commitment to Maintain Severe Accident Management Guidelines The Nuclear Energy Institute (NEI) Nuclear Strategic Issues Advisory Committee (NSIAC) recently approved an Industry Initiative to implement and maintain Severe Accident Management Guidelines (SAMGs). This letter establishes commitments related to SAMG for the EGG fleet sites listed above. These guidelines would be used by emergency response personnel during accident conditions that progress beyond the mitigation capabilities described in Emergency Operating Procedures (EOPs). SAMG strategies are intended to arrest the progression of fuel damage, maintain the capability of the containment as long as possible, and minimize radiological releases.

It is expected that NRG staff personnel will conduct periodic inspection of our SAMGs and performance deficiencies, if any, will be assessed using the Reactor Oversight Process. We also understand that inspection activities will not extend to NRG review and approval of SAMG strategies, or the use of equipment described in the SAMGs.

This letter contains new regulatory commitments, which are identified in the enclosures to this letter.

If you have any questions regarding this report, please contact Ronald Gaston at 630-657-3359.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 4th day of December 2015.

Respectfully submitted, a ~ ~

James Barstow Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC

U.S. Nuclear Regulatory Commission Commitment to Maintain SAMGs December 4, 2015 Page 3

Enclosures:

1. EGC Corporate Engineering - Summary of Regulatory Commitments
2. Braidwood Station, Units 1 and 2 - Summary of Regulatory Commitments
3. Byron Station, Units 1 and 2 - Summary of Regulatory Commitments
4. Calvert Cliffs Nuclear Power Plant, Units 1 and 2 - Summary of Regulatory Commitments
5. Clinton Power Station, Unit 1 - Summary of Regulatory Commitments
6. Dresden Nuclear Power Station, Units 2 and 3 - Summary of Regulatory Commitments
7. LaSalle County Station, Units 1 and 2 - Summary of Regulatory Commitments
8. Limerick Generating Station, Units 1 and 2 - Summary of Regulatory Commitments
9. Nine Mile Point Nuclear Station, Units 1 and 2 - Summary of Regulatory Commitments 1 O. Oyster Creek Nuclear Generating Station - Summary of Regulatory Commitments
11. Peach Bottom Atomic Power Station, Units 2 and 3 - Summary of Regulatory Commitments
12. Quad Cities Nuclear Power Station, Units 1 and 2 - Summary of Regulatory Commitments
13. R. E. Ginna Nuclear Power Plant - Summary of Regulatory Commitments
14. Three Mile Island Nuclear Station, Unit 1 - Summary of Regulatory Commitments

U.S. Nuclear Regulatory Commission Commitment to Maintain SAMGs December 4, 2015 Page 4 cc:

Director, Office of Nuclear Reactor Regulation Regional Administrator - NRC Region I Regional Administrator - NRC Region Ill NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector-Calvert Cliffs Nuclear Power Plant 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 - Nine Mile Point Nuclear 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 - R. E. Ginna Nuclear Power Plant NRC Senior Resident Inspector - Three Mile Island Nuclear Station, Unit 1 NRC Project Manager, NRR - Braidwood Station NRC Project Manager, NRR - Byron Station NRC Project Manager, NRR - Calvert Cliffs Nuclear Power Plant 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, NRA - Limerick Generating Station NRC Project Manager, NRR - Nine Mile Point Nuclear 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 - R. E. Ginna Nuclear Power Plant NRC Project Manager, NRR - Three Mile Island Nuclear Station, Unit 1 Illinois Emergency Management Agency - Division of Nuclear Safety Director, Bureau of Radiation Protection - Pennsylvania Department of Environmental Resources Manager, 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 S. T. Gray, State of Maryland R. R. Janati, Chief, Division of Nuclear Safety, Pennsylvania Department of Environmental Protection, Bureau of Radiation Protection

1.

EGC - Corporate Engineering

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

EGC will consider the site SAMGs within plant configuration management processes October 31, 2016 No Yes in order to ensure that the SAMGs reflect changes to the facility over time.

1.

Braidwood Station, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Braidwood Station, Units 1 and 2 will update the site SAMGs to future revisions of the PWROG generic severe accident technical Within 2 refueling guidelines, and the SAMGs will be integrated outages or 3 years with other emergency response guideline of the publication sets and symptom-based Emergency date of the No Yes Operating Procedures, and validated, using guidelines, the guidance in NEI 14-01, "Emergency whichever is Response Procedures and Guidelines for greater Beyond Design Basis Events and Severe Accidents".

1.

Byron Station, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Byron Station, Units 1 and 2 will update the site SAMGs to future revisions of the PWROG generic severe accident technical Within 2 refueling guidelines, and the SAMGs will be integrated outages or 3 years with other emergency response guideline of the publication sets and symptom-based Emergency date of the No Yes Operating Procedures, and validated, using guidelines, the guidance in NEI 14-01, "Emergency whichever is Response Procedures and Guidelines for greater Beyond Design Basis Events and Severe Accidents".

1.

Calvert Cliffs Nuclear Power Plant, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Calvert Cliffs Nuclear Power Plant, Units 1 and 2 will update the site SAMGs to future revisions of the PWROG generic severe accident technical guidelines, and the Within 2 refueling SAMGs will be integrated with other outages or 3 years emergency response guideline sets and of the publication symptom-based Emergency Operating date of the No Yes Procedures, and validated, using the guidelines, guidance in NEI 14-01, "Emergency whichever is Response Procedures and Guidelines for greater Beyond Design Basis Events and Severe Accidents".

1.
2.

Clinton Power Station, Unit 1

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Clinton Power Station, Unit 1 will update the site SAMGs to revision 3 of the BWROG June 30, 2017 Yes No generic severe accident guidelines (published February, 2013).

Clinton Power Station, Unit 1 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be integrated Within 2 refueling with other emergency response guideline outages or 3 years sets and symptom-based Emergency of the publication Operating Procedures, and validated, using date of the No Yes the guidance in NEI 14-01, "Emergency guidelines, Response Procedures and Guidelines for whichever is Beyond Design Basis Events and Severe greater Accidents". 1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident guidelines.

1.
2.

Dresden Nuclear Power Station, Units 2 and 3

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Dresden Nuclear Power Station, Units 2 and 3 will update the site SAMGs to revision 3 of June 30, 2017 Yes No the BWROG generic severe accident guidelines (published February, 2013).

Dresden Nuclear Power Station, Units 2 and 3 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be integrated with other Within 2 refueling emergency response guideline sets and outages or 3 years symptom-based Emergency Operating of the publication Procedures, and validated, using the date of the No Yes guidance in NEI 14-01, "Emergency guidelines, Response Procedures and Guidelines for whichever is Beyond Design Basis Events and Severe Accidents". 1 greater Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident guidelines.

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LaSalle County Station, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRG for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

LaSalle County Station, Units 1 and 2 will update the site SAMGs to revision 3 of the June 30, 2017 Yes No BWROG generic severe accident guidelines (published February, 2013).

LaSalle County Station, Units 1 and 2 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be Within 2 refueling integrated with other emergency response outages or 3 years guideline sets and symptom-based of the publication Emergency Operating Procedures, and date of the No Yes validated, using the guidance in NEI 14-01, guidelines, "Emergency Response Procedures and whichever is Guidelines for Beyond Design Basis Events greater and Severe Accidents".1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident guidelines.

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2.

Limerick Generating Station, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED I COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Limerick Generating Station, Units 1 and 2 will update the site SAMGs to revision 3 of June 30, 2017 Yes No the BWROG generic severe accident guidelines (published February, 2013).

Limerick Generating Station, Units 1 and 2 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be integrated with other Within 2 refueling emergency response guideline sets and outages or 3 years symptom-based Emergency Operating of the publication Procedures, and validated, using the date of the No Yes guidance in NEI 14-01, "Emergency guidelines, Response Procedures and Guidelines for whichever is Beyond Design Basis Events and Severe greater Accidents". 1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident guidelines.

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Nine Mile Point Nuclear Station, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

I COMMITTED I COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Nine Mile Point Nuclear Station, Units 1 and 2 will update the site SAMGs to revision June 30, 2017 Yes No 3 of the BWROG generic severe accident guidelines (published February, 2013).

Nine Mile Point Nuclear Station, Units 1 and 2 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be integrated with other Within 2 refueling emergency response guideline sets and outages or 3 years symptom-based Emergency Operating of the publication Procedures, and validated, using the date of the No Yes guidance in NEI 14-01, "Emergency guidelines, Response Procedures and Guidelines for whichever is Beyond Design Basis Events and Severe greater Accidents". 1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident guidelines.

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2. 0 Oyster Creek Nuclear Generating Station

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRG for the NRC's information and are not regulatory commitments.)

COMMITTED I COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Oyster Creek Nuclear Generating Station will update the site SAMGs to revision 3 of the June 30, 2017 Yes No BWROG generic severe accident guidelines (published February, 2013).

Oyster Creek Nuclear Generating Station will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be Within 2 refueling integrated with other emergency response outages or 3 years guideline sets and symptom-based of the publication Emergency Operating Procedures, and date of the No Yes validated, using the guidance in NEI 14-01, guidelines, "Emergency Response Procedures and whichever is Guidelines for Beyond Design Basis Events greater and Severe Accidents". 1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident quidelines.

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2. 1 Peach Bottom Atomic Power Station, Units 2 and 3

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Peach Bottom Atomic Power Station, Units 2 and 3 will update the site SAMGs to revision June 30, 2017 Yes No 3 of the BWROG generic severe accident guidelines (published February, 2013).

Peach Bottom Atomic Power Station, Units 2 and 3 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be integrated with other Within 2 refueling emergency response guideline sets and outages or 3 years symptom-based Emergency Operating of the publication Procedures, and validated, using the date of the No Yes guidance in NEI 14-01, "Emergency guidelines, Response Procedures and Guidelines for whichever is Beyond Design Basis Events and Severe greater Accidents". 1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident Quidelines.

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2. 2 Quad Cities Nuclear Power Station, Units 1 and 2

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Quad Cities Nuclear Power Station, Units 1 and 2 will update the site SAMGs to revision June 30, 2017 Yes No 3 of the BWROG generic severe accident guidelines (published February, 2013).

Quad Cities Nuclear Power Station, Units 1 and 2 will update the site SAMGs to future revisions of the BWROG generic severe accident technical guidelines, and the SAMGs will be integrated with other Within 2 refueling emergency response guideline sets and outages or 3 years symptom-based Emergency Operating of the publication Procedures, and validated, using the date of the No Yes guidance in NEI 14-01, "Emergency guidelines, Response Procedures and Guidelines for whichever is Beyond Design Basis Events and Severe greater Accidents". 1 Note 1 - Use of NEI 14-01 guidance begins with the update to revision 4 of the BWROG generic severe accident guidelines.

1. 3 R. E. Ginna Nuclear Power Plant

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRC for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

R. E. Ginna Nuclear Power Plant will update the site SAMGs to future revisions of the PWROG generic severe accident technical Within 2 refueling guidelines, and the SAMGs will be integrated outages or 3 years with other emergency response guideline of the publication sets and symptom-based Emergency date of the No Yes Operating Procedures, and validated, using guidelines, the guidance in NEI 14-01, "Emergency whichever is Response Procedures and Guidelines for greater Beyond Design Basis Events and Severe Accidents".

1. 4 Three Mile Island Nuclear Station, Unit 1

SUMMARY

OF REGULATORY COMMITMENTS The following table identifies commitments made in this document. (Any other actions discussed in the submittal represent intended or planned actions. They are described to the NRG for the NRC's information and are not regulatory commitments.)

COMMITTED COMMITMENT TYPE COMMITMENT DATE OR ONE-TIME ACTION PROGRAMMATIC "OUTAGE" (Yes/No)

(Yes/No)

Three Mile Island Nuclear Station, Unit 1 will update the site SAMGs to future revisions of the PWROG generic severe accident Within 2 refueling technical guidelines, and the SAMGs will be outages or 3 years integrated with other emergency response of the publication guideline sets and symptom-based date of the No Yes Emergency Operating Procedures, and guidelines, validated, using the guidance in NEI 14-01, whichever is "Emergency Response Procedures and greater Guidelines for Beyond Design Basis Events and Severe Accidents".