ML18135A073
| ML18135A073 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/15/2018 |
| From: | John Lamb Special Projects and Process Branch |
| To: | David Helker Exelon Corp |
| References | |
| L-2017-LLQ-0003 | |
| Download: ML18135A073 (4) | |
Text
1 NRR-DMPSPEm Resource From:
Lamb, John Sent:
Tuesday, May 15, 2018 10:00 AM To:
'david.helker@exeloncorp.com' Cc:
Bonnett, Frederick Paul:(GenCo-Nuc); Richard.Gropp@exeloncorp.com
Subject:
RAIs - Oyster Creek - Request Approval of the Decommissioning Quality Assurance Program (EPID: L-2017-LLQ-0003)
Importance:
High
Dear Mr. Helker:
By letter dated January 7, 2011 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML110070507), Exelon Generation Company, LLC (Exelon or the licensee), submitted its Notification of Permanent Cessation of Power Operations for Oyster Creek Nuclear Generating Station (Oyster Creek). In this letter, Exelon provided notification to the U.S. Nuclear Regulatory Commission (NRC) of its intent to permanently cease power operation no later than December 31, 2019.
By letter dated February 14, 2018 (ADAMS Accession No. ML18045A084), Exelon submitted its updated Notification of Permanent Cessation of Power Operations for Oyster Creek. In this letter, Exelon provided notification to the NRC of its intent to permanently cease power operation no later than October 31, 2018.
By application dated November 30, 2017 (ADAMS Accession No. ML17334A798), Exelon requested approval for the Decommissioning Quality Assurance Program (DQAP) for Renewed Facility Operating License No.
DPR-16 for Oyster Creek. The proposed DQAP is requested to be implemented at Oyster Creek after the required certifications pursuant to Title 10 of the Code of Federal Regulations, Section 82(a)(1) have been docketed. The DQAP reflects changes based on Oyster Creeks proposed decommissioning status.
The NRC staff has reviewed Exelons submittal and determined that additional information is required to enable the NRC staff to make an independent assessment regarding its technical review.
The enclosure to this email provides the request for additional information (RAI). On May 4, 2018, the draft RAI questions were sent to Mr. Richard Gropp, and Mr. Paul Bonnet of your staff to ensure that they were understandable, the regulatory bases for the questions were clear, and to determine if the information was previously docketed. A teleconference was held on May 14, 2018, with Mr. Paul Bonnet of your staff to clarify the RAI questions. Exelon stated they would respond to the RAI within 30 days of the date of this email.
If you have any questions, please contact me at 301-415-3100 or via e-mail at John.Lamb@nrc.gov.
Sincerely, John G. Lamb, Senior Project Manager Special Projects and Process Branch Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No. 50-219
Enclosure:
Request for Additional Information
2 REQUEST FOR ADDITIONAL INFORMATION RELATED TO DECOMMISSIONG QUALITY ASSURANCE PROGRAM FOR OYSTER CREEK NUCLEAR GENERATING STATION EXELON GENERATION COMPANY, LLC DOCKET NO. 50-219 By application dated November 30, 2017 (Agencywide Documents Access and Management System (ADAMS)
Accession No. ML17334A798), Exelon Generation Company, LLC (Exelon or the licensee) submitted a proposed Decommissioning Quality Assurance Program (DQAP) in preparation for the transition of the Oyster Creek Nuclear Generating Station (Oyster Creek) to a permanent defueled condition.
The NRC staff has reviewed Exelon's submittal and determined that additional information is required to enable the U.S. Nuclear Regulatory Commission (NRC) staff to make an independent assessment regarding its technical review.
RAI 1-1 Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix B, Criterion XVIII Audits, requires, in part, that audits shall be performed in accordance with written procedures or check lists by appropriate trained personnel not having direct responsibilities in the areas being audited.
Exelon DQAP Section 1, Organization, and Section 18, Audits, does not clearly articulate how personnel within the Nuclear Oversight (NOS) organization will only conduct audits in areas within the scope of the DQAP with no direct responsibilities.
Clarify how the DQAP meets the above requirement.
RAI 1-2 The regulation 10 CFR Part 50, Appendix B, Criterion XII, Control of Measuring and Test Equipment [M&TE],
requires measures to be established to assure that tools, gages, instruments, and other measuring and testing devices used in activities affecting quality are properly controlled, calibrated, and adjusted at specified periods to maintain accuracy within necessary limits. Criterion XV, Nonconforming Materials, Parts, or Components, requires, in part, that procedures be established, as appropriate, for the identification, documentation, segregation, disposition, and notification to affected organizations of nonconforming parts or components.
NUREG-1536, Standard Review Plan for Spent Fuel Dry Storage Systems at a General License Facility, Revision 1, Chapter 14, Quality Assurance Evaluation, Section 14.5.12.e, Control of Measuring and Test Equipment, requires measures to document the assessment of the validity of previous inspections when M&TE equipment is found out of calibration and take control of the out of calibration equipment.
3 Exelon DQAP Section 12, Control of Measuring and Test Equipment, does not clearly articulate how gages and instruments within the DQAP M&TE program will be documented and assessed for potential extent of condition issues after an out-of-calibration condition is identified. Specifically, use of out-of-calibration M&TE could result in a nonconforming condition of components in which the M&TE was previously used for maintenance or testing of important to safety components. Therefore, procedures should be in place to identify and evaluate the potential for such nonconforming conditions.
Clarify how the DQAP meets the above requirement.
RAI 1-3 The regulation 10 CFR Part 50, Appendix B, Criterion II, Quality Assurance Program, requires, in part, a regular review of the status and adequacy of the quality assurance (QA) program.
NUREG-1757, Decommissioning Plans: Process for Material Licensees, Vol. 1, Revision 2, Section 17.6.2, Quality Assurance Program, requires, in part, a description of how management (above or outside the QA organization) regularly assess the scope, status, adequacy, and compliance of the QA program.
Exelon DQAP Section 2, Quality Assurance Program, removes the requirement of Independent Reviews per American National Standards Institute (ANSI) N18.7-1976.
Clarify how the DQAP meets the above requirement.
Hearing Identifier:
NRR_DMPS Email Number:
371 Mail Envelope Properties (John.Lamb@nrc.gov20180515095900)
Subject:
RAIs - Oyster Creek - Request Approval of the Decommissioning Quality Assurance Program (EPID: L-2017-LLQ-0003)
Sent Date:
5/15/2018 9:59:48 AM Received Date:
5/15/2018 9:59:00 AM From:
Lamb, John Created By:
John.Lamb@nrc.gov Recipients:
"Bonnett, Frederick Paul:(GenCo-Nuc)" <Frederick.Bonnett@exeloncorp.com>
Tracking Status: None "Richard.Gropp@exeloncorp.com" <Richard.Gropp@exeloncorp.com>
Tracking Status: None
"'david.helker@exeloncorp.com'" <david.helker@exeloncorp.com>
Tracking Status: None Post Office:
Files Size Date & Time MESSAGE 6324 5/15/2018 9:59:00 AM Options Priority:
High Return Notification:
No Reply Requested:
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