ML063210338
| ML063210338 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Peach Bottom, Oyster Creek, Byron, Braidwood, Limerick, Clinton, Quad Cities, Zion, LaSalle, Crane  |
| Issue date: | 11/15/2006 |
| From: | Gratton C NRC/NRR/ADRO/DORL/LPLIII-2 |
| To: | Simpson P Exelon Generation Co |
| GRATTON C | |
| References | |
| TAC MD1270, TAC MD1271, TAC MD1272, TAC MD1273, TAC MD1274, TAC MD1275, TAC MD1276, TAC MD1277, TAC MD1278, TAC MD1279, TAC MD1280, TAC MD1281, TAC MD1282, TAC MD1283, TAC MD1284, TAC MD1285, TAC MD1286 | |
| Download: ML063210338 (14) | |
Text
November 15, 2006 Mr. Patrick R. Simpson Manager - Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
SUBJECT:
APPROVAL OF EXELON GENERATION COMPANY, LLC, AND AMERGEN ENERGY COMPANY, LLC, QUALITY ASSURANCE PROGRAM CHANGES REGARDING THE REASSIGNMENT OF INDEPENDENT REVIEW (TAC NOS. MD1270, MD1271, MD1272, MD1273, MD1274, MD1275, MD1276, MD1277, MD1278, MD1279, MD1280, MD1281, MD1282, MD1283, MD1284, MD1285, AND MD1286)
Dear Mr. Simpson:
By letter to the Nuclear Regulatory Commission (NRC) dated April 24, 2006, as supplemented by letter dated June 29, 2006, Exelon Generation Company, LLC and AmerGen Energy Company, LLC (the licensees), submitted a proposed change to Quality Assurance Topical Report (QATR), NO-AA-10, Revision 77, for NRC review and approval, in accordance with Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54(a)(4). The topical report describes the Appendix B quality assurance (QA) program applicable to the nuclear fleet of 21 nuclear reactors owned by the licensees.
The proposed change would reassign the Nuclear Safety Review Board (NSRB) independent review responsibilities for technical specification changes, license amendments, and emergency plan changes to the Plant Operations Review Committee (PORC). The licensees cite as precedent a similar change approved by the NRC for Nuclear Management Company, LLC, on January 13, 2005, which reassigns NSRB reviews to other site organizations. Pursuant to 10 CFR 50.54(a)(3)(ii), licensees may adopt previously approved alternatives, provided that the bases of the NRC approval are applicable to the licensees facility.
Based on our review of the changes to the QA program that are described in the licensees submittals, the NRC staff concludes that the proposed alternative, to reassign to the PORC the NSRB independent review responsibilities for the review of TS changes, license amendments, and changes to the emergency plan, is acceptable. The enclosed safety evaluation documents the basis for our conclusion that the proposed changes to the QA program are acceptable.
P. Simpson If you have any questions, please contact me at (301) 415-1055.
Sincerely,
/RA/
Christopher Gratton, Sr. Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-456, 50-457, 50-454, 50-455, 50-461,50-010, 50-237, 50-249, 72-37, 50-373, 50-374, 50-352, 50-353, 50-219, 72-15, 50-171, 50-277, 50-278, 72-29, 50-254, 50-265, 72-53, 50-289, 50-295, and 50-304
Enclosure:
Safety Evaluation cc w/encl: See next page
- SE Input dated Office DORL/LPL3-2/PM DORL/LPL3-2/LA DE/EQVA/BC DORL/LPL3-2/BC Name CGratton DClarke DThatcher*
DCollins Date 11/15/06 11/15/06 10/05/2006 11/15/06
ENCLOSURE SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PROPOSED CHANGE TO THE QUALITY ASSURANCE PROGRAM QUALITY ASSURANCE PROGRAM CONSOLIDATION EXELON GENERATION COMPANY, LLC, AND AMERGEN ENERGY COMPANY, LLC BYRON STATION, UNIT NOS. 1 AND 2 BRAIDWOOD STATION, UNIT NOS. 1 AND 2 CLINTON POWER STATION, UNIT 1 DRESDEN NUCLEAR POWER STATION, UNITS 1, 2, AND 3 LASALLE COUNTY STATION, UNITS 1 AND 2 LIMERICK GENERATING STATION, UNITS 1 AND 2 OYSTER CREEK GENERATING STATION PEACH BOTTOM ATOMIC POWER STATION, UNITS 1, 2, AND 3 QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2 THREE MILE ISLAND, UNIT 1 ZION NUCLEAR POWER STATION, UNITS 1 AND 2 DOCKET NOS. STN 50-456 AND STN 50-457; STN 50-454 AND STN 50-455; 50-461; 50-10, 50-237 AND 50-249; 50-373 AND 50-374; 50-352 AND 50-353; 50-219, 50-171, 50-277 AND 50-278; 50-254 AND 50-265; 50-289; AND 50-295 AND 50-304
1.0 INTRODUCTION
By letter to the Nuclear Regulatory Commission (NRC) dated April 24, 2006 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML061140437), as supplemented by letter dated June 29, 2006 (ADAMS Accession No. ML061290590), Exelon Generation Company, LLC, and AmerGen Energy Company, LLC (the licensees), submitted a proposed change to Quality Assurance Topical Report (QATR), NO-AA-10, Revision 77, for NRC review and approval in accordance with Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(a)(4). The topical report describes the Appendix B quality assurance (QA) program, applicable to the nuclear fleet of 21 nuclear reactors owned by the licensees.
The proposed change would reassign Nuclear Safety Review Board (NSRB) independent review responsibilities for technical specification (TS) changes, license amendments, and emergency plan changes to the Plant Operations Review Committee (PORC). The licensees cite as precedent a similar change approved by the NRC on January 13, 2005 (ADAMS Accession No. ML050210276), which reassigns NSRB reviews to other site organizations.
Pursuant to 10 CFR 50.54(a)(3)(ii), licensees may adopt previously approved alternatives, provided that the bases of the NRC approval are applicable to the licensees facility.
2.0 REGULATORY EVALUATION
The NSRB, as described in Chapter 1, Section 2.2.3.5 of the QATR, reports to and advises the president and chief nuclear officer of the results of its independent oversight of plant operations related to safe operation of the station and the companys nuclear program relative to nuclear safety. The PORC, as described in Chapter 1, Section 2.3.5 of the QATR, is an on-site, multi-disciplined committee, responsible for review of activities that affect nuclear safety, reports to, and advises the management position responsible for plant operation on matters relative to nuclear safety.
Guidance for NRC staff reviews of licensee assessments of operating phase activities important to safety is provided in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, Section 13.4, Operational Review. The NSRB and PORC review functions originated as TS administrative controls, as defined by the regulation in 10 CFR 50.36(c)(5). These review functions were relocated to licensee QA program descriptions in accordance with NRC Administrative Letter 95-06, Relocation of Technical Specification Administrative Controls Related to Quality Assurance. Operational reviews are addressed by American National Standards Institute (ANSI) N18.7 (American Nuclear Society (ANS) 3.2), Sections 4.4 and 4.7, as endorsed by Regulatory Guide 1.33, Quality Assurance Program Requirements. Site-specific commitments with respect to operational reviews are described in the QATR, Appendix C, Section 1.1, Codes and Standards.
3.0 TECHNICAL EVALUATION
The QATR contains a commitment for each of the licensees 21 plants to follow the guidance of ANSI N18.7 (ANS 3.2), with respect to operational reviews. Therefore, through reference, the QATR requires the NSRB for each site to review TS changes, license amendments, and changes to the emergency plan prior to submittal to the NRC. Current plant implementing procedures require reviews of these changes by both PORC and NSRB.
A primary objective for performing independent reviews is that the body performing the independent review has organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations. In its April 24, 2006, proposed change, the licensees state that the QATR has been revised to require that, should a voting PORC member have a potential conflict of interest in a change under review, another PORC member will satisfy committee quorum requirements when voting on approval of the pending change.
The revised QATR also requires PORC reviews of these changes to maintain safety considerations paramount, as opposed to cost or schedule considerations.
The QATR commits the NSRB to perform an oversight function of the activities performed by PORC. In its oversight role, the NSRB is responsible for assessing the effectiveness of PORC reviews with regard to nuclear safety. In response to the NRC staffs request for additional information, the licensees letter dated June 29, 2006, provides information on how the NSRB assesses the effectiveness of PORC reviews. The NSRB reviews PORC meeting minutes and nuclear oversight reports related to its assessment of PORC effectiveness. PORC meeting minutes are required by procedures to be sufficiently detailed for NSRB to assess the effectiveness of PORC reviews. Meeting minutes include a detailed description of items reviewed, key discussion points with questions/responses, and the recommendation, including the basis for the determination made.
The NRC staff finds that, while this change removes the NSRB direct review of TS changes, license amendments, and changes to the emergency plan, PORC minutes and nuclear oversight assessment reports provide sufficient detail for NSRB to evaluate the safety issues considered and the conclusions reached by the PORC.
The NRC staff finds that, given the constraint that PORC members having a potential conflict of interest refrain from voting on documents under review, and NSRB oversight of PORC activities, PORC reviews provide sufficient organizational freedom to function as an independent review body. The NRC staff also finds the proposed reassignment of NSRB review responsibilities for TS changes, license amendments, and changes to the emergency plan, given the conditions of the QATR revisions, to be acceptable. The NRC staff further finds that there is reasonable assurance that PORC reviews will be sufficiently independent of cost and schedule pressures to serve as an independent review body for performing the review of TS changes, license amendments, and emergency plan changes requiring NRC approval. As previously described, the NSRB retains its current function of evaluating the effectiveness of PORC reviews with regard to plant safety.
4.0 CONCLUSION
Based on review of the changes to the QA programs, as described in the licensees submittal, the NRC staff concludes that the proposed alternative, to reassign to PORC the NSRB independent review responsibilities for review of TS changes, license amendments, and changes to the emergency plan, is acceptable.
Principal Contributors: A. Rivera-Varona K. Heck Date:
Byron/Braidwood Stations cc:
Dwain W. Alexander, Project Manager Westinghouse Electric Corporation Energy Systems Business Unit Post Office Box 355 Pittsburgh, PA 15230-0355 Howard A. Learner Environmental Law and Policy Center of the Midwest 35 East Wacker Dr., Suite 1300 Chicago, IL 60601-2110 U.S. Nuclear Regulatory Commission Byron Resident Inspectors Office 4448 N. German Church Road Byron, IL 61010-9750 Regional Administrator, Region III U.S. Nuclear Regulatory Commission Suite 210 2443 Warrenville Road Lisle, IL 60532-4351 Ms. Lorraine Creek RR 1, Box 182 Manteno, IL 60950 Chairman, Ogle County Board Post Office Box 357 Oregon, IL 61061 Mrs. Phillip B. Johnson 1907 Stratford Lane Rockford, IL 61107 Attorney General 500 S. Second Street Springfield, IL 62701 Illinois Emergency Management Agency Division of Disaster Assistance &
Preparedness 110 East Adams Street Springfield, IL 62701-1109 Plant Manager - Byron Station Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 Site Vice President - Byron Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 U.S. Nuclear Regulatory Commission Braidwood Resident Inspectors Office 35100 S. Rt. 53, Suite 79 Braceville, IL 60407 County Executive Will County Office Building 302 N. Chicago Street Joliet, IL 60432 Plant Manager - Braidwood Station Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Ms. Bridget Little Rorem Appleseed Coordinator 117 N. Linden Street Essex, IL 60935 Document Control Desk - Licensing Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Site Vice President - Braidwood Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Senior Vice President - Operations Support Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555
Byron/Braidwood Stations cc:
Director - Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Regulatory Assurance - Braidwood Exelon Generation Company, LLC 35100 S. Rt. 53, Suite 84 Braceville, IL 60407-9619 Manager Regulatory Assurance - Byron Exelon Generation Company, LLC 4450 N. German Church Road Byron, IL 61010-9794 Assistant General Counsel Exelon Generation Company, LLC 200 Exelon Way Kennett Square, PA 19348 Vice President - Regulatory & Legal Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Manager Licensing - Braidwood/Byron Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Senior Vice President - Midwest Operations Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Clinton Power Station, Unit 1 cc:
Manager Regulatory Assurance - Clinton AmerGen Energy Company, LLC Clinton Power Station RR3, Box 228 Clinton, IL 61727-9351 Site Vice President - Clinton Power Station AmerGen Energy Company, LLC Clinton Power Station RR 3, Box 228 Clinton, IL 61727-9351 Plant Manager - Clinton Power Station AmerGen Energy Company, LLC Clinton Power Station RR 3, Box 228 Clinton, IL 61727-9351 Resident Inspector U.S. Nuclear Regulatory Commission RR #3, Box 229A Clinton, IL 61727 Chairman of DeWitt County c/o County Clerks Office DeWitt County Courthouse Clinton, IL 61727 J. W. Blattner Project Manager Sargent & Lundy Engineers 55 East Monroe Street Chicago, IL 60603
Dresden and Quad Cities Nuclear Power Stations, Units 1 and 2 cc:
Site Vice President - Dresden Nuclear Power Station Exelon Generation Company, LLC 6500 N. Dresden Road Morris, IL 60450-9765 Plant Manager - Dresden Nuclear Power Station Exelon Generation Company, LLC 6500 N. Dresden Road Morris, IL 60450-9765 Manager Regulatory Assurance - Dresden Exelon Generation Company, LLC 6500 N. Dresden Road Morris, IL 60450-9765 U.S. Nuclear Regulatory Commission Dresden Resident Inspectors Office 6500 N. Dresden Road Morris, IL 60450-9766 Chairman Grundy County Board Administration Building 1320 Union Street Morris, IL 60450 Regional Administrator U.S. NRC, Region III 801 Warrenville Road Lisle, IL 60532-4351 Site Vice President - Quad Cities Exelon Generation Company, LLC 22710 206th Avenue N.
Cordova, IL 61242-9740 Plant Manager - Quad Cities Exelon Generation Company, LLC 22710 206th Avenue N.
Cordova, IL 61242-9740 Regulatory Assurance Manager - Quad Cities Exelon Generation Company, LLC 22710 206th Avenue N.
Cordova, IL 61242-9740 Quad Cities Resident Inspectors Office U.S. Nuclear Regulatory Commission 22712 206th Avenue N.
Cordova, IL 61242 David C. Tubbs MidAmerican Energy Company One River Center Place 106 E. Second, P.O. Box 4350 Davenport, IA 52808-4350 Vice President - Law and Regulatory Affairs MidAmerican Energy Company One River Center Place 106 E. Second Street P.O. Box 4350 Davenport, IA 52808 Chairman Rock Island County Board of Supervisors 1504 3rd Avenue Rock Island County Office Bldg.
Rock Island, IL 61201 LaSalle County Station, Units 1 and 2 cc:
Site Vice President - LaSalle County Station Exelon Generation Company, LLC 2601 North 21st Road Marseilles, IL 61341-9757 Plant Manager - LaSalle County Station Exelon Generation Company, LLC 2601 North 21st Road Marseilles, IL 61341-9757
LaSalle County Station, Units 1 and 2 cc:
Manager Regulatory Assurance - LaSalle Exelon Generation Company, LLC 2601 North 21st Road Marseilles, IL 61341-9757 U.S. Nuclear Regulatory Commission LaSalle Resident Inspectors Office 2605 North 21st Road Marseilles, IL 61341-9756 Phillip P. Steptoe, Esquire Sidley and Austin One First National Plaza Chicago, IL 60603 Assistant Attorney General 100 W. Randolph St. Suite 12 Chicago, IL 60601 Chairman LaSalle County Board 707 Etna Road Ottawa, IL 61350 Chairman Illinois Commerce Commission 527 E. Capitol Avenue, Leland Building Springfield, IL 62706 Robert Cushing, Chief, Public Utilities Division Illinois Attorney General's Office 100 W. Randolph Street Chicago, IL 60601 Regional Administrator U.S. NRC, Region III 801 Warrenville Road Lisle, IL 60532-4351 Zion Nuclear Power Station cc:
Decommissioning Plant Manager - Zion Exelon Generation Company, LLC 101 Shiloh Boulevard Zion, IL 60099-2797 Regulatory Assurance Engineer - Zion Exelon Generation Company, LLC 101 Shiloh Boulevard Zion, IL 60099-2797
Limerick Generating Station, Unit Nos. 1 and 2 cc:
Site Vice President Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Plant Manager Limerick Generating Station Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Regulatory Assurance Manager - Limerick Exelon Generation Company, LLC P.O. Box 2300 Sanatoga, PA 19464 Director Licensing and Regulatory Affairs Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Manager Licensing Limerick Generating Station Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Correspondence Control Desk Exelon Generation Company, LLC P.O. Box 160 Kennett Square, PA 19348 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Senior Resident Inspector U.S. Nuclear Regulatory Commission Limerick Generating Station P.O. Box 596 Pottstown, PA 19464 Library U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Director, Bureau of Radiation Protection Pennsylvania Dept. of Environmental Protection Rachel Carson State Office Building P.O. Box 8469 Harrisburg, PA 17105-8469 Chairman Board of Supervisors of Limerick Township 646 West Ridge Pike Linfield, PA 19468 Dr. Judith Johnsrud National Energy Committee Sierra Club 433 Orlando Avenue State College, PA 16803 Oyster Creek Nuclear Generating Station cc:
Site Vice President - Oyster Creek Nuclear Generating Station AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Senior Vice President of Operations AmerGen Energy Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Kathryn M. Sutton, Esquire Morgan, Lewis, & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004
Oyster Creek Nuclear Generating Station cc:
Kent Tosch, Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 Regional Administrator, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731 Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 445 Forked River, NJ 08731 Director - Licensing and Regulatory Affairs AmerGen Energy Company, LLC Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Manager Licensing - Oyster Creek Exelon Generation Company, LLC Correspondence Control P.O. Box 160 Kennett Square, PA 19348 Regulatory Assurance Manager Oyster Creek AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Ron Bellamy, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406-1415 Correspondence Control Desk AmerGen Energy Company, LLC 200 Exelon Way, KSA 1--1 Kennett Square, PA 19348 Oyster Creek Nuclear Generating Station Plant Manager AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 cc:
Site Vice President Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Plant Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Regulatory Assurance Manager Peach Bottom Atomic Power Station Exelon Generation Company, LLC 1848 Lay Road Delta, PA 17314 Resident Inspector U.S. Nuclear Regulatory Commission Peach Bottom Atomic Power Station P.O. Box 399 Delta, PA 17314 Mr. Roland Fletcher Department of Environment Radiological Health Program 2400 Broening Highway Baltimore, MD 21224
Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 cc:
Board of Supervisors Peach Bottom Township 545 Broad Street Ext.
Delta, PA 17314-9203 Mr. Richard McLean Power Plant and Environmental Review Division Department of Natural Resources B-3, Tawes State Office Building Annapolis, MD 21401 Manager-Financial Control & Co-Owner Affairs Public Service Electric and Gas Company P.O. Box 236 Hancocks Bridge, NJ 08038-0236 Three Mile Island Nuclear Station, Unit 1 cc:
Site Vice President - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P. O. Box 480 Middletown, PA 17057 Chairman Board of County Commissioners of Dauphin County Dauphin County Courthouse Harrisburg, PA 17120 Chairman Board of Supervisors of Londonderry Township R.D. #1, Geyers Church Road Middletown, PA 17057 Three Mile Island Nuclear Station, Unit 1 cc:
Senior Resident Inspector (TMI-1)
U.S. Nuclear Regulatory Commission P.O. Box 219 Middletown, PA 17057 Plant Manager - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P. O. Box 480 Middletown, PA 17057 Regulatory Assurance Manager - Three Mile Island Nuclear Station, Unit 1 AmerGen Energy Company, LLC P.O. Box 480 Middletown, PA 17057 Michael A. Schoppman Framatome ANP Suite 705 1911 North Ft. Myer Drive Rosslyn, VA 22209 Vice President, General Counsel and Secretary AmerGen Energy Company, LLC 2301 Market Street, S23-1 Philadelphia, PA 19101 Eric Epstein TMI Alert 4100 Hillsdale Road Harrisburg, PA 17112