ML18054B359

Slide: NRC Pre-Submittal Meeting for Exelon Fleet LAR to Relocate TS Unit Staff Qualification ANSI Requirements to the QATR, February 27, 2018, Profile Info: Submitted by Frank Mascitelli

ML18054B359
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Oyster Creek, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, LaSalle, 07201036, 07000650
Issue date:	02/27/2018
From:	Exelon Generation Co, Exelon Nuclear
To:	Blake Purnell Plant Licensing Branch III
Purnell B, NRR/DORL,/LPLIII, 415-1380
References
Download: ML18054B359 (9)

Text

NRC Pre-Submittal Meeting for Exelon Fleet LAR to Relocate the TS Unit Staff Qualification ANSI Requirements to the Exelon QATR February 27, 2018

Purpose for Discussion

• Discuss evolution of current proposed Fleet License Amendment Request (LAR)

• Provide overview of current LAR

• Discuss 6-month turnaround request

• Discuss the QATR proposed Mark-ups

• Adoption of ANSI/ANS 3.1-2014 via RG 1.8 Rev 4 QATR revision 2

Opening Remarks

• Executive Sponsor for LAR- Julie Sickle

• Chair of the ANS working level committee that developed ANSI/ANS-3.1-2014 3

Evolution

• 11/14 ANSI/ANS-3.1-2014 approved

• 3/22/16 Initial Exelon Pre-submittal meeting

• 4/6/16 Pre-Submittal NRC meeting summary

• 3/27/17 NRC approves TVA LAR to relocate TS ANSI requirements to TVA QAP

• Fall/17 Exelon decides to change original LAR scope to:

Relocate the TS ANSI requirements to the Exelon Quality Assurance Topical Report

• Feb/18 Fleet LAR internally reviewed and approved

• 2/27/18 Pre-submittal meeting

• 3/1/18 Submit Fleet LAR to NRC 4

LAR Overview

• Current Technical Specification Requirements for TS 5/6.3.1(Unit/Plant/Facility Staff Qualifications):

ANS-3.1/N18.1-1971

• Braidwood, Byron, Calvert Cliffs, Dresden, Ginna, LaSalle, Peach Bottom, Nine Mile Point Unit 1, Quad Cities ANSI/ANS-3.1-1978

• Clinton, Limerick, FitzPatrick, Nine Mile Point Unit 2, Three Mile Island Unit 1

• Proposed Technical Specification Requirements:

Each member of the unit [facility or plant] staff shall meet or exceed the minimum qualifications referenced for comparable positions as specified in the Exelon Quality Assurance Topical Report 5

LAR Overview

• TS verbatim wording relocated to QATR

• Minor exceptions for FitzPatrick

• Oyster Creek not included in Fleet Submittal

• Complies with the requirements of AL 95-06 (Relocation of Technical Specification Administrative Controls Related to Quality Assurance)

• These ANSI Standards are considered quality assurance controls

• Consistent with TVA precedence for Browns Ferry and Sequoyah (ML16105A287) 6

6-Month Turnaround

• The 6-month turnaround will position Exelon to more efficiently adopt and implement the ANSI-2014 standard upon issuance of RG 1.8 Rev 4 Prevents an additional year delay in Exelon achieving a common fleet standard and alignment for staff qualifications if no LAR is needed at the time RG 1.8 Rev 4 is issued

• In 3/22/16 pre-submittal meeting NRC advised not to submit until NRC vetted the ANSI-2014 standard via the RG 1.8 Rev 4 process

• In 3/22/16 meeting NRC had anticipated that the draft RG 1.8 Rev 4 would be noticed for public comments by end of May 2016

• Draft RG 1.8 Rev 4 was noticed for public comments on 2/12/18

• Exelon has had a project in place for 3 years to adopt the ANSI-2014 standard 7

QATR-Mark-ups

• TS wording relocated verbatim to QATR

• FitzPatrick minor exceptions:

Referenced Entergy QAP exceptions TS 5.3.1 is already in most recent QATR revision TS 5.2.2.f requires STAs at FitzPatrick to comply to the ANSI 1993 standard

• Mark-ups throughout QATR Appendix C (Codes, Standards and Guides)

• Proposed revisions are consistent with existing format for taking exceptions to RG compliance on a station by station basis 8

RG 1.8 Rev 4 QATR revision

• Exelon will implement the approved TS amendments within 60 days

• No training standards are changed; only change management is to issue revised TS and revise the QATR as proposed

• After ANSI/ANS-3.1-2014 is endorsed via approved RG 1.8 Rev 4, Exelon will again revise the QATR via 10 CFR 50.54(a) evaluation process to adopt it

• NRC exceptions to the ANSI/ANS-3.1-2014 that will be in the approved RG 1.8 Rev 4 will be carefully reviewed

• It is expected that the subsequent 10 CFR 50.54(a) evaluation will not be a reduction in commitment 9