ML071520162

Fleet - Revision to Quality Topical Report

ML071520162
Person / Time
Site:	Dresden, Peach Bottom, Oyster Creek, Byron, Braidwood, Limerick, Clinton, Quad Cities, Zion, LaSalle, 07100008, Crane
Issue date:	07/24/2007
From:	Gratton C NRC/NRR/ADRO/DORL/LPLIII-2
To:	Crane C Exelon Generation Co
Gratton C, NRR/DORL, 415-1055
References
TAC MD4400, TAC MD4401, TAC MD4402, TAC MD4403, TAC MD4404, TAC MD4405, TAC MD4406, TAC MD4407, TAC MD4408, TAC MD4409, TAC MD4410, TAC MD4411, TAC MD4412, TAC MD4413, TAC MD4414, TAC MD4415, TAC MD4416
Download: ML071520162 (13)

Text

July 24, 2007 Mr. Christopher M. Crane President and Chief Nuclear Officer Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555

SUBJECT:

BRAIDWOOD STATION, UNITS 1 AND 2; BYRON STATION, UNIT NOS. 1 AND 2; CLINTON POWER STATION, UNIT NO. 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 NUCLEAR GENERATING STATION; PEACH BOTTOM ATOMIC POWER STATION, UNITS 1, 2, AND 3; QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2; THREE MILE ISLAND NUCLEAR STATION, UNIT 1; AND ZION NUCLEAR POWER STATION, UNITS 1 AND 2 - REVISION TO THE QUALITY ASSURANCE TOPICAL REPORT (TAC NOS. MD4400, MD4401, MD4402, MD4403, MD4404, MD4405, MD4406, MD4407, MD4408, MD4409, MD4410, MD4411, MD4412, MD4413, MD4414, MD4415, MD4416)

By letter dated January 22, 2007, Exelon Energy Company, LLC (Exelon), and AmerGen Energy Company, LLC (AmerGen), submitted a proposed revision to the Quality Assurance Topical Report (QATR). This revision to the Exelon and AmerGen QATR was submitted in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR),

Part 50, Section 50.54(a)(4). The proposed changes constitute a reduction in commitments and therefore, requires the Nuclear Regulatory Commission (NRC) staffs approval prior to implementation. The NRC staff also evaluated the proposed QATR revision in accordance with Parts 71 and 72; the results of the review were provided from the Office of Nuclear Material Safety and Safeguards.

This revision would delete Section 2.3.1 of Chapter 5 of the QATR, Instructions, Procedures and Drawings, that currently requires a Plant Operations Review Committee review of applicable administrative changes to Fire Protection procedures prior to implementation.

The NRC staffs review and bases for finding the proposed changes to be acceptable are documented in the attached safety evaluation. The proposed QATR continues to satisfy the standards and regulations, and is therefore, acceptable.

C. Crane If you have any questions regarding this letter, please contact me at 301-415-1055.

Sincerely,

/RA/

Christopher Gratton, Senior Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456 and STN 50-457; STN 50-454 and STN 50-455; 50-461;50-010, 50-237, 50-249, and 72-37; 50-373 and 50-374; 50-352 and 50-353; 50-219 and 72-15; 50-171, 50-277, 50-278, and 72-29; 50-254, 50-265, and 72-53; 50-289; 50-295 and 50-304; and 71-008

Enclosure:

Safety Evaluation cc w/encl: See next page

C. Crane If you have any questions regarding this letter, please contact me at 301-415-1055.

Sincerely,

/RA/

Christopher Gratton, Senior Project Manager Plant Licensing Branch III-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. STN 50-456 and STN 50-457; STN 50-454 and STN 50-455; 50-461;50-010, 50-237, 50-249, and 72-37; 50-373 and 50-374; 50-352 and 50-353; 50-219 and 72-15; 50-171, 50-277, 50-278, and 72-29; 50-254, 50-265, and 72-53; 50-289; 50-295 and 50-304; and 71-008

Enclosure:

Safety Evaluation cc w/encl: See next page DISTRIBUTION:

PUBLIC RidsNrrDeEqvb LPL3-2 R/F RidsNrrDorl PPrescott, NRR RidsOgcRp RidsNrrLAEWhitt KScales, NRR RidsNrrDorlLPL3-2 RidsNrrPMCGratton RLewis, NMSS RidsNrrPPBamford RidsNrrPMSSands RidsAcrsAcnwMailCenter RidsNrrPMJHughey RidsNrrPMRKuntz RidsNrrDorlDpr RidsNrrPMEMiller RidsNrrPMMThorpe-Kavanaugh JBuckley, FSME RidsRgn3MailCenter ADAMS ACCESSION NO.: ML071520162 OFFICE:

NRR/LPL3-2/PM NRR/LPL3-2/LA NRR/DE/EQVB NMSS/LID/BC FSME/DURLD/BC NRR/LPL3-2/BC NAME:

CGratton EWhit DThatcher RLewis (CGratton for KWilliams Acting BC JBuckley RGibbs (LRaghavan for)

DATE:

7/20/07 7/20/07 6/1/07 7/17/07 6/11/07 7/24/07 OFFICIAL FILE COPY

Enclosure SAFETY EVALUATION BY THE OFFICE NUCLEAR REACTOR REGULATION RELATED TO A CHANGE TO QUALITY ASSURANCE TOPICAL REPORT BRAIDWOOD STATION, UNITS 1 AND 2; BYRON STATION, UNIT NOS. 1 AND 2; CLINTON POWER STATION, UNIT NO. 1; DRESDEN NUCLEAR POWER STATION, UNITS 1, 2, AND 3, AND INDEPENDENT SPENT FUEL STORAGE FACILITY (ISFSI);

LASALLE COUNTY STATION, UNITS 1 AND 2; LIMERICK GENERATING STATION, UNITS 1 AND 2; OYSTER CREEK NUCLEAR GENERATING STATION AND ISFSI; PEACH BOTTOM ATOMIC POWER STATION, UNITS 1, 2 AND 3, AND ISFSI; QUAD CITIES NUCLEAR POWER STATION, UNITS 1 AND 2, AND ISFSI; THREE MILE ISLAND STATION, UNIT 1; AND ZION NUCLEAR POWER STATION, UNITS 1 AND 2 EXELON GENERATION COMPANY, LLC, AND AMERGEN ENERGY COMPANY, LLC DOCKET NOS. STN 50-456 AND STN 50-457; STN 50-454 AND STN 50-455; 50-461;50-010; 50-237, 50-249, AND 72-37; 50-373 AND 50-374; 50-352 AND 50-353; 50-219 AND 72-15; 50-171, 50-277, 50-278, AND 72-29; 50-254, 50-265, AND 72-53; 50-289; 50-295 AND 50-304; AND 71-008

1.0 INTRODUCTION

By letter dated January 22, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML070220229), Exelon Energy Company, LLC (Exelon), and AmerGen Energy Company, LLC (AmerGen), submitted a proposed revision to the Quality Assurance Topical Report (QATR). This revision would delete Section 2.3.1 of Chapter 5, Instructions, Procedures and Drawings, that currently requires a Plant Operations Review Committee (PORC) review of administrative changes to fire protection program procedures prior to implementation. Exelon and AmerGen submitted this request in accordance with the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.54(a)(4). The proposed changes constitute a reduction in commitments and therefore, require the NRC staffs approval prior to implementation. The NRC staff also evaluated the proposed QATR revision in accordance with Parts 71 and 72; the results of the review were provided from the Office of Nuclear Material Safety and Safeguards (NMSS) in a letter dated May 23, 2007 (ADAMS Accession No. ML071520092).

2.0 REGULATORY EVALUATION

The NRCs regulatory requirements related to quality assurance (QA) programs are set forth in Appendix B to 10 CFR Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, 10 CFR 50.34(b)(6)(ii), and 10 CFR 50.54(a). Appendix B to 10 CFR Part 50 establishes QA requirements for the design, construction, and operation of structures, systems, and components (SSCs) of the facility. The pertinent requirements of Appendix B to 10 CFR Part 50 apply to all activities affecting the safety-related functions of those SSCs, and include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying.

Paragraph 50.34(b)(6)(ii), Contents of applications; technical information, requires that every applicant for an operating license include information in its final safety analysis report (FSAR) on the managerial and administrative controls to be used to assure safe operation. The information on the controls shall also include a discussion of how the applicable requirements of Appendix B to 10 CFR Part 50 will be satisfied.

Paragraph 50.54(a), Conditions of licenses, states that licensees may make a change to a previously accepted QA program description included or referenced in the FSAR without prior NRC approval, provided the change does not reduce the commitments in the program description as accepted by the NRC. Changes to the QA program description that do reduce the commitments must be submitted to the NRC and receive NRCs staff approval prior to implementation.

3.0 TECHNICAL EVALUATION

Chapter 5, Section 2.3.1 of the QATR currently contains a commitment for the PORC to review applicable administrative procedures prior to implementation. The licensee proposed modifying Section 2.3.1 of the QATR to allow changes to be made without PORC approval for the fire protection program only, provided the changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire.

The NRC staff previously issued Regulatory Issue Summary (RIS)99-002, Relaxation of the Technical Specification Requirements for PORC Review of Fire Protection Program Changes.

The RIS identifies a method of meeting requirements for PORC review of the fire protection program and its implementing procedure. The RIS outlines the following regulatory controls to ensure the continued effectiveness of the fire protection program:

(1)

A license condition that the licensee may make changes to the approved fire protection program without prior Commission approval only if those changes would not adversely affect the ability to achieve and maintain safe shutdown in an event of a fire.

(2)

Since the fire protection program is included in the FSAR, the provisions of 10 CFR 50.59 apply. This regulation prohibits changes to the facility without prior Commission approval if it is determined that the change constitutes an unreviewed safety question [i.e., meets current 10 CFR 50.59 requirements].

(3)

The technical specifications (TSs) require the offsite safety review committee to inspect and audit the fire protection program.

(4)

The TSs require written procedures and administrative policies to implement the fire protection program.

The NRC staff reviewed the above revision to Section 2.3.1 in Chapter 5 of the QATR described in Exelons and AmerGens January 22, 2007, request. The NRC staff ensured that Exelon and AmerGen had appropriate regulatory controls for the fire protection program in either the technical specifications or the revised QATR that are consistent with RIS 99-002.

The NRC staff also evaluated the changes against the requirements for licensed activities under 10 CFR Parts 71 and 72.

4.0 CONCLUSION

The NRC staff concludes that the QATR continues to comply with Appendix B to 10 CFR Part 50 and the facilities included the necessary regulatory controls and therefore, the change is acceptable. In a letter dated May 23, 2007, NMSS staff found the revisions to the QATR to be acceptable for licensing activities under Parts 71 and 72.

5.0 REFERENCES

1.

Regulatory Issue Summary 99-002, Relaxation of the Technical Specification Requirements for PORC Review of Fire Protection Program Changes, October 13, 1999.

2.

Office of Nuclear Reactor Regulation Safety Evaluation, Revision to Quality Assurance Program Manual, Entergy Operations, Inc., Arkansas Nuclear One, Units 1 and 2; Grand Gulf Nuclear Station, Unit 1; River Bend Station; and Waterford Steam Electric Station, Unit 3. (ADAMS Accession No. ML013370290).

Principal Contributors: K. Scales P. Prescott Date: July 24, 2007

Byron/Braidwood Stations cc:

Dwain W. Alexander, Project Manager via e-mail 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 via e-mail Regional Administrator, Region III U.S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 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 1035 Outer Park Dr.

Springfield, IL 62704 Plant Manager - Byron Station via e-mail Site Vice President - Byron via e-mail U.S. Nuclear Regulatory Commission Braidwood Resident Inspectors Office 35100 S. Rt. 53, Suite 79 Braceville, IL 60407 County Executive via e-mail Plant Manager - Braidwood Station via e-mail Ms. Bridget Little Rorem Appleseed Coordinator via e-mail Document Control Desk - Licensing via e-mail Site Vice President - Braidwood via e-mail Senior Vice President - Operations Support via e-mail

Byron/Braidwood Stations Clinton Power Station, Unit 1 cc:

cc:

Director - Licensing and Regulatory Affairs via e-mail Manager Regulatory Assurance - Braidwood via e-mail Manager Regulatory Assurance - Byron via e-mail Associate General Counsel via e-mail Vice President - Regulatory Affairs via e-mail Manager Licensing via e-mail Senior Vice President - Midwest Operations via e-mail Manager Regulatory Assurance - Clinton via e-mail Site Vice President - Clinton Power Station via e-mail Plant Manager - Clinton Power Station via e-mail 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 via e-mail

Dresden and Quad Cities Nuclear Power Stations, Units 1 and 2 cc:

Site Vice President - Dresden Nuclear Power Station via e-mail Plant Manager - Dresden Nuclear Power Station via e-mail Manager Regulatory Assurance - Dresden via e-mail 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 Site Vice President - Quad Cities via e-mail Plant Manager - Quad Cities via e-mail Manager Regulatory Assurance - Quad Cities via e-mail Quad Cities Resident Inspectors Office U.S. Nuclear Regulatory Commission 22712 206th Avenue N.

Cordova, IL 61242 David C. Tubbs MidAmerican Energy Company via e-mail 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 via e-mail Plant Manager - LaSalle County Station via e-mail Manager Regulatory Assurance - LaSalle via e-mail 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, Region I U.S. Nuclear Regulatory Commission 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 Vice President - Operations, Mid-Atlantic Exelon Generation Company, LLC 200 Exelon Way, KSA 3-N Kennett Square, PA 19348 Vice President Licensing and Regulatory Affairs Exelon Generation Company, LLC 4300 Winfield Road Warrenville, IL 60555 Director Licensing and Regulatory Affairs Exelon Generation Company, LLC 200 Exelon Way, KSA 3-E Kennett Square, PA 19348 Manager Licensing 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

Limerick Generating Station, Unit Nos. 1 and 2 cc:

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 Associate General Counsel Exelon Generating Company, LLC 4300 Winfield Road Warrenville, IL 60555 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 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

Peach Bottom Atomic Power Station, Unit Nos. 2 and 3 cc:

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 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 Ronald Bellamy, Region I U.S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Michael A. Schoppman Framatome ANP Suite 705 1911 North Ft. Myer Drive Rosslyn, VA 22209 Eric Epstein TMI Alert 4100 Hillsdale Road Harrisburg, PA 17112 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 Kathryn M. Sutton, Esquire Morgan, Lewis, & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004 Kent Tosch, Chief New Jersey Department of Environmental Protection Bureau of Nuclear Engineering CN 415 Trenton, NJ 08625 Mayor of Lacey Township 818 West Lacey Road Forked River, NJ 08731

Oyster Creek Nuclear Generating Station cc:

Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 445 Forked River, NJ 08731 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 Oyster Creek Nuclear Generating Station Plant Manager AmerGen Energy Company, LLC P.O. Box 388 Forked River, NJ 08731 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