ML20195B230
| ML20195B230 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Byron, Braidwood, Quad Cities, Zion, LaSalle  |
| Issue date: | 05/19/1999 |
| From: | Krich R COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20195B233 | List: |
| References | |
| NUDOCS 9905280191 | |
| Download: ML20195B230 (7) | |
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Commonwealth Edison Company e
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14(X) Opus Place e
Downers C, rove. IL F415-5701 i
May 19,1999 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 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 Dresden Nuclear Power Station, Units 1,2 and 3 Facility Operating License Nos. DPR-2, DPR-19 and DPR-25 NRC Docket Nos. 50-10. 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
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Quad Cities Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254 and 50-265 Zion Nuclear Power Station, Units 1 and 2 Facility Operating License Nos. DPR-39 and DPR-48 NRC Docket Nos. 50-295 and 50-304 i
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Subject:
Proposed Changes to the Commonwealth Edison Company Quality Assurance Program Pursuant to 10 CFR 50.54(a)(3) and 10 CFR 50.4(b)(7), we are requesting
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Nuclear Regulatory Commission (NRC) approval of three proposed changes to I
the Commonwealth Edison (Comed) Company Quality Assurance Topical Report l
9905200191 990519 PDR ADOCK 05000010 W
PDR A Unicom Company
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M:y 19,1999 :
U. S. Nuclear Regulatory. Commission Page 2 (QATR), CE-1-A, Revision 66a. We consider these proposed changes to be reductions in commitments and, in accordance with 10 CFR 50.54(a)(3), NRC approvalis required prior to implementation of these changes. The three proposed changes are summarized below.
The first proposed change involves the quality requirements to be applied to structures, systems, components (SSCs) and activities at Zion Nuclear Power
' Station (ZNPS). In the permanently defueled condition of ZNPS, there are no longer any SSCs classified safety related. Certain SSCs and activities have been classified important to the defueled condition. The Quality Assurance Program is being revised to apply augmented quality requirements to those SSCs and activities.
The second proposed change involves the review responsibilities of the Nuclear Safety Review Board (NSRB). The NSRB is currently required to review all changes to the Generating Stations Emergency Plan (GSEP) prior to implementation of the change. This review responsibility is being revised to only require changes to the GSEP that meet the threshold for NRC review and approval in accordance with 10 CFR 50.54(q) to be reviewed by the NSRB prior to implementation of the change.
The third proposed change involves the Quality Assurance Program Database. it is currently an element of the Quality Assurance Manual and it contains a cross-reference between the Quality Assurance Program and source documents, and a cross-reference to the responsible department and implementing procedures.
The database is being eliminated as an element of the Quality Assurance Manual.
.i Attachment A describes the proposed changes in more detail, the reason for the -
change, and the basis for concluding that the revised Quality Assurance Program incorporating the proposed changes continues to satisfy the criteria of 10 CFR 50, Appendix B. Attachment B contains the revised pages of the QATR.
If you have any questions regarding this submittal, please contact K. A. Ainger at (630)663-7350.
i Respectfully, t
R. M. Krich Vice President - Regulatory Services j
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4 May 19,1999 1
U. S. Nuclear Regulatory Commission Page 3' Attachments cc:
. Regional Administrator-NRC Region lli NRC Senior Resident inspector, Braidwood Station o
NRC Senior Resident inspector, Byron Station NRC Senior Resident inspector, Dresden Nuclear Power Station NRC Senior Resident inspector, LaSalle County Station NRC Senior Resident inspector, Quad Cities Nuclear Power Station i-5 i
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ATTACHMENT A I
Description of Proposed Changes to Comed Quality Assurance Topical Report
References:
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NRC letter, " Certification of Perrnanent Cessation of Power Operation and Permanent Removal of Fuel from the Reactor for Zion Nuclear Power Station, Units 1 and 2," dated May 4, 1998 (2)
Comed letter, " Submittal of Defueled Safety Analysis Report," dated November 10,1998 Zion Nuclear Power Station Quality Reauirements in the Reference 1 letter, the NRC acknowledged that, pursuant to 10 CFR 50.82(a)(2), the 10 CFR Part 50 licenses for Zion Nuclear Power Station, Units 1 j
and 2 (ZNPS) no longer authorize operation of the reactors or emplacement or retention of fuelin the reactor vessels. Accordingly, most of the previously analyzed accidents are no longer possible at ZNPS. The Zion Station Defueled 4
Safety Analysis Report (Reference 2) contains the remaining accident analyses that reflect the permanently defueled condition of ZNPS. Consistent with the revised accident analyses, the classification of structures, systems and components (SSCs) was redefined in the Zion Station Defueled Safety Analysis Report (DSAR). There are no longer any SSCs classified safety related.
Therefore, it is not necessary to apply all the quality requirements of the Quality 1
Assurance Program to the SSCs and activities at ZNPS. A new classification has been developed in the DSAR for SSCs and activities determined to be important to the defueled condition. Augmented quality requirements, defined in the DSAR, will be applied to those SSCs and activities.
Section 2 of the QATR describes the Quality Assurance Program and refers to Section 19, " Augmented Quality," concerning application of the program to certain SSCs and activities to a degree consistent with their importance to safety.
We are proposing to modify Section 2 to indicate that the quality requirements applicable to ZNPS are referenced in Section 19 of the QATR and the requirements in Sections 3 through 18 no longer apply.
Section 19 of the QATR describes how the Quality Assurance Program is applied in a graded manner (i.e., augmented quality) to certain areas and activities that are not defined as safety related. We are proposing to modify Section 19 to indicate that the augmented quality requirements to be applied to SSCs and
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activities determined to be important to the defueled condition at ZNPS are defined.in the DSAR.
? The quality requirements for SSCs and activities at ZNPS' are being redefined commensurate with the reduction in risk' associated with the permanently defueled condition of ZNPS. It is no longer necessary to apply all the quality
. requirements in the QATR to SSCs and activities at ZNPS since there are no longer any SSCs classified safety related.. Consistent with the policy on Augmented Quality stated in Section 19.1 of the QATR, quality requirements will be applied in a graded manner _to SSCs and activities that are important to the defueled condition at ZNPS.' As a result, the proposed Quality Assurance Program incorporating augmented quality requirements for ZNPS will continue to satisfy the criteria of 10 CFR 50; Appendix B.
l The following sections and pages in the QATR are affected by this proposed change.
Section Subsection
.Page 2
- 3.1 2-1, 2-2 5
3.3 (Note) 5-2 --
17 3.10 (Note) 17-3 3.10.1 item k 17-4 3.10.2 items n - t 17-5,17-6 19 3
19-1 Nuclear Safety Review Board (NSRB) Review Responsibilities The review responsibilities of the NSRB are described in Section 20A.3.4 of the QATR. The NSRB is currently required to review all changes to the Generating Stations Emergency Plan (GSEP) prior to implementation of the change. We are proposing to revise the NSRB review responsibilities regarding changes to the
- GSEP. Changes to the GSEP that we determine do not require NRC review and
. approval in accordance with 10 CFR 50.54(q) would no longer require NSRB review prior to implementation of those changes. NSRB review of those changes, after their implementation, would be required.
' This change in NSRB review responsibility is being proposed so changes to the GSEP that do not reduce the effectiveness of the plan and continue _ to meet the standards in 10 CFR 50.47(b) and the requirements in 10 CFR 50, Appendix E can be implemented more efficiently.
NRC Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," Revision 2, February 1978, endorses American National Standards A-2
Institute (ANSI) Standard N18.7-1976, " Administrative Controls and Quality Assuraryce for the Operational Phase of Nuclear Power Plants," as an adequate b' asis for complying with the quality assurance program requirements of Appendix B to 10 CFR 50, subject to the positions stated in Section C,
" Regulatory Position." There is no regulatory position in Regulatory Guide 1.33 requiring independent review of proposed changes to an emergency plan and proposed changes to an emergency plan are not included in Section 4.3.4,
" Subjects Requiring Independent Review," of ANSI N18.7-1976. Accordingly, the criteria of 10 CFR 50, Appendix B would continue to be satisfied in light of this proposed change to NSRB review responsibilities.
The following section and page in the QATR are affected by this proposed change.
Section Subsection Page 20A 3.4.9 20A-3 Quality Assurance Proaram Database Section 2 of the QATR, subsection 3.6 " Quality Assurance Manual," states that the Quality Assurance Manual consists of the Quality Assurance Program document and the Quality Assurance Program Database. The Quality Assurance Program Database contains a cross-reference between the Quality Assurance Program and source documents, and a cross-reference to the responsible department and implementing procedures. We are proposing to eliminate this database as an element of the Quality Assurance Manual.
We are proposing to eliminate this database because the administrative burden to maintain it outweighs the benefit of the database. The cross-reference between the Quality Assurance Program and source documents is redundant to the QATR and is not widely used. Development of the cross-reference to the responsible department and implementing procedures was stopped because it was determined that current processes and controls are sufficient to ensure Quality Assurance Program requirements are met and that appropriate procedures are used.
The QATR currently contains the quality assurance requirements to ensure the criteria of 10 CFR 50, Appendix B are satisfied. Corresponding source documents (e.g., industry standards) are also currently referenced in the QATR.
Current administrative processes and controls beside the Quality Assurance l
Program Database are effective in defining department responsibilities and corresponding implementing procedures to ensure the Quality Assurance Program requirements are fulfilled. Therefore, the criteria of 10 CFR 50, 1
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Appendix B would continue to be satisfied without the Quality Assurance Prograrp Database.
The following sections and pages in the QATR are affected by this proposed change.
Section Subsection Page 1
4 1-24 2
3.3 2-4 3.6 2-6 4
2-6 3
4 34 4
4 4-4 5
2 5-2 4
5-4 6
4 S-3 7
2 7-1 4
7-11 8
4 8-3 9
4 9-3 10 4
10-4 11 4
11-12 12 4
12-4 13 4
13-3 j
14 4
14-4 i
15 4
15-4 16 4
16-6 17 4
17-6 18 4
18-5 19 2
19-1 4
19-4 A-4 i
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