ML23103A323

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Submittal of Updated Final Safety Analysis Report, Rev. 26, Summary of Revised Regulatory Commitments for Hope Creek, Summary of Changes to PSEG Nuclear LLC, Quality Assurance Topical Report, NO-AA-10, Rev. 89
ML23103A323
Person / Time
Site: Salem, Hope Creek  PSEG icon.png
Issue date: 04/13/2023
From: Montgomery R
Public Service Enterprise Group
To:
Office of Nuclear Reactor Regulation, Document Control Desk
Shared Package
ML23103A322 List:
References
LR-N23-0027, NEI 99-04
Download: ML23103A323 (1)
v • d • e


Text

PSEG Nuclear LLC P.O. Box 236, Hancocks Bridge, NJ 08038-0236 10 CFR 50.71(e) 10 CFR 50.54(a)(3) 10 CFR 71.106(b) 10 CFR 54.37(b)

NEI 99-04 LR-N23-0027 April 13, 2023 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Hope Creek Generating Station Renewed Facility Operating License No. NPF-57 NRC Docket No. 50-354 Salem Generating Station - Unit 1 and Unit 2 Renewed Facility Operating License Nos. DPR-70 and DPR-75 NRC Docket Nos. 50-272 and 50-311

Subject:

Submittal of Hope Creek Generating Station Updated Final Safety Analysis Report, Revision 26, Summary of Revised Regulatory Commitments for Hope Creek, Summary of changes to PSEG Nuclear LLC Quality Assurance Topical Report, NO-AA-10, Revision 89 and 10 CFR 54.37(b) review results for Hope Creek PSEG Nuclear LLC (PSEG) hereby submits:

Revision No. 26 to the Hope Creek Generating Station Updated Final Safety Analysis Report (UFSAR) in accordance with the requirements of 10 CFR 50.71(e)(4) and 10 CFR 50.4(b)(6)

The results of a review performed as required by 10 CFR 54.37(b) to identify any newly-identified Structure, System or Component (SSC) that would be subjected to an aging management review or evaluation of time-limited aging analyses (TLAAs) in accordance with 10 CFR 54.21

10 CFR 50.71(e) 10 CFR 50.54(a)(3) 10 CFR 71.106(b)

Page 2 10 CFR 54.37(b)

LR-N23-0027 NEI 99-04 A summary of changed/closed regulatory commitments that were not reported by other means during 2021 and 2022 in accordance with NEI 99-04 A summary of changes made by Revision No. 89 to the PSEG Nuclear LLC Quality Assurance Topical Report (QATR), NO-AA-10, which documents a change to the Salem/Hope Creek (SHC) Quality Assurance Program (QAP) in accordance with the requirements of 10 CFR 50.54(a)(3) and 10 CFR 71.106(b)

Revision No. 26 to the Hope Creek UFSAR is being submitted in its entirety electronically and contains identified text, table and figure changes required to reflect the plant configuration as of November 30, 2022, six months prior to this submittal.

In addition, there are general editorial changes. In accordance with 10 CFR 50.71(e)(2)(ii), a summary of changes made under the provisions of 10 CFR 50.59 but not previously submitted to the Commission is provided in . The previous revision to the Hope Creek UFSAR was issued on November 15, 2021.

Based on NRC Regulatory Issue Summary (RIS) 2015-17, "Review and Submission of Updates to Final Safety Analysis Reports, Emergency Preparedness Documents, and Fire Protection Documents," PSEG has reviewed Revision 26 of the UFSAR for security-related information (SRI). Consequently, Revision 26 of the UFSAR is being provided in its entirety as two separate submittals. This submittal redacts the information that is SRI and designates it as "Security-Related Information - Withheld Under 10 CFR 2.390." This version is suitable for public disclosure. A separate submittal contains the SRI.

In accordance with the Nuclear Energy Institute (NEI) process for managing Nuclear Regulatory Commission (NRC) commitments and associated NRC notifications, PSEG performed a review of regulatory commitments to determine if there were any Hope Creek changed/closed commitments that were not reported by other means during 2021 and 2022. The review concluded that there were 3 changed or closed commitments during that time period and a summary of that review is provided in .

An evaluation was completed to determine whether any newly-identified Systems, Structures, or Components (SSCs) existed in support of submitting Hope Creek UFSAR Revision 26. This evaluation involved reviewing pertinent documentation for the period subsequent to the last Hope Creek UFSAR revision. The evaluation concluded that there were no newly-identified SSCs and no changes to the Hope Creek current licensing basis that would have caused any newly-identified SSCs for which aging management reviews or time-limited aging analyses would apply.

10 CFR 50.71(e) 10 CFR 50.54(a)(3) 10 CFR 71 .106(b)

Page 3 10 CFR 54.37(b)

LR-N23-0027 NEI 99-04 PSEG has developed Revision 89 of the SHC Quality Assurance Topical Report, which governs the QAP. The changes to the QATR were made in accordance with the requirements of 10 CFR 50.54(a)(3) and 10 CFR 71 .106(b). The changes involved no reduction in commitments and therefore did not require prior NRC approval. 10 CFR 50.54(a)(3) requires that changes that do not reduce the commitments be submitted in accordance with 10 CFR 50.71(e). Revision 89 is the current version of the QATR that is in use at PSEG, and became effective on April 7, 2023.

As required by 10 CFR 50.71 (e)(2)(i), I certify that to the best of my knowledge , the information contained in the Enclosures and Attachments to this letter, which pertains to the Hope Creek UFSAR Revision 26, accurately reflects information and analyses submitted to the NRC, or prepared pursuant to NRC requirements as described above. There are no regulatory commitments contained in this letter.

A summary of the changes made to the QATR in Revision 89 is provided in of this letter.

If you have any questions or require additional information , please do not hesitate to contact Mr. Lee Marabella, at (856) 339-1208.

Sin~dY A. . ,,-----

Richard Montgomery Manager, Licensing PSEG Nuclear, LLC

Attachment:

1. Summary Report of UFSAR Changes
2. Summary Report of Hope Creek Changed/Closed Regulatory Commitments

Enclosures:

1. Hope Creek UFSAR Rev. 26 (redacted version suitable for public disclosure)
  • One file submitted electronically
2. Quality Assurance Topical Report, REV. 89, Revision Summary

10 CFR 50.71(e) 10 CFR 50.54(a)(3) 10 CFR 71.106(b)

Page 4 10 CFR 54.37(b)

LR-N23-0027 NEI 99-04 CC (Cover letter, Attachments 1 and 2, Enclosures 1 and 2)

Administrator - Region I - USNRC USNRC Project Manager USNRC Senior Resident Inspector - Hope Creek USNRC Senior Resident Inspector - Hope Creek Chief, New Jersey Bureau of Nuclear Engineering

LR-N23-0027 Attachment 1 Summary Report of UFSAR Changes

LR-N23-0027 Summary Report Of UFSAR Changes CN # SECTION DESCRIPTION BASIS HCN 17-008 Appdx 9A, Tables 9A- Delete historical information from HC Fire Protection 1, -6 thru -19, -21 UFSAR Appendix 9A which is the original Change thru -35, -40 thru -51, plant compliance document to 10CFR50, Regulatory

-56 thru -78, -80 thru - Appendix R and remove information Review 86, -88 thru -103, related to post fire safe shutdown, performed by F9A-14, -15A, -16A, -

17A, thru -31 combustible loading and breaker Engineering coordination that is contained in Fire Services Protection Programmatic Standards HC.ER-PS.FP-0001-A3 & A5 and engineering calculations.

HCN 18-012 8.2, F8.2-2 Hope Creek switchyard expansion with 3 10 CFR 50.59 new 500 Kv breakers, a new 500/230Kv screening stepdown transformer for new 230Kv performed for Silver Line Run transmission line DCP 80120447 connection.

HCN 19-009 8.2, F8.2-2 Replace and renumber switchyard 10 CFR 50.59 transformers SLP1 & SLP2 to SLP5 & screening SLP6. performed for DCP 80123797 HCN 19-012 1.8 Installs the Purate (Chlorine Dioxide) 10 CFR 50.59 R2 biocide water treatment system for the screening circulating water system. performed for DCP 80122148 HCN 20-002 1.8 Emergency Diesel Generator Fuel Oil A 50.59 Storage Tank inspection frequency applicability changed from 10Years to 15Years. review identified Change is to take exception to the that this change is 10Year frequency in Reg. Guide 1.137 fully controlled by and instead state it the frequency is in the SFCP accordance with the Surveillance Frequency Control Program (SFCP).

HCN 20-003 3.5, 10.2 Revise the missile probability of the 10 CFR 50.59 turbine train via a complete failure of the screening turbines control and safety systems performed by based on new information provided by Hope Creek Plant GE. Engineering HCN 20-009 9.2 Addition of a keylock bypass switch in the 10 CFR 50.59 Main Control Room to allow operators to evaluation bypass an isolation signal to the HV-2207 performed for Reactor Auxiliaries Cooling System DCP 80127117 (RAC) heat exchanger header inlet valve and HV-2346 RACS heat exchanger header outlet valve on the common Station Service Water header.

1

LR-N23-0027 Summary Report Of UFSAR Changes CN # SECTION DESCRIPTION BASIS HCN 21-005 9.1, T9.1 Update to FSAR to remove Fuel Pool Cooling 10 CFR 50.59 pumps low flow trips. screening performed for DCP 80128780 HCN 21-012 2.3, T2.3, F2.3 Update to the FSAR for Meteorological 10 CFR 50.59 Tower equipment replacement. screening performed for DCP 80128616 HCN 21-018 Appendix-A Add wording to the Selective Leaching of 10 CFR 50.59 Materials Aging Management Program, screening stating that the sample size may be performed by reduced if material loss due to selective Hope Creek Plant leaching is identified in at least one Engineering sample for a specific material and environmental combination. .

HCN 21-019 3.6, 15.2 Revise these sections to document that 10 CFR 50.59 the Low-Low Suction Pressure Trips to screen performed the "B" and "C" Reactor Feedwater for TCCP 4HT-Pumps has been temporarily defeated by 21-012 TCCP 4HT-21-012.

HCN 21-020 7.7 The recirculation pump main discharge 10 CFR 50.59 valve not being fully open condition to screening limit the recirculation pump speed performed for setpoint signal to 30% is removed. DCP 80129840 HCN 21-023 Appendix-9A Clarify the description of combustible Fire Protection materials allowances of Room 5707 in Change UFSAR Appendix 9A Section 9A.6.5.1.h. Regulatory Review performed by Engineering Programs HCN 22-003 5.4 Allow the Reactor Water Clean Up 10 CFR 50.59 bottom head drain line suction path to be evaluation isolated during normal operation. performed for TCCP 4HT 023 HCN 22-004 8.2 Revise text to reflect current 10 CFR 50.59 Pennsylvania-New Jersey Maryland screening (PJM) practice for performing grid performed for stability studies. DCP 80130400 HCN 22-005 8.2 Revise Section 8.2.1.1 for the description 10 CFR 50.59 of the Red Lion protection scheme screening configuration to be consistent with Rev. 1 performed for of DEC 80127900 and removal of direct DCP 80127900 transfer trip (DTT) input to backup 5015 Line Relay Protection scheme.

2

LR-N23-0027 Summary Report Of UFSAR Changes CN # SECTION DESCRIPTION BASIS HCN 22-010 Appendix-9A Update Section 1.e.1.2.b with the correct Fire Protection breaker to remove High Pressure Coolant Change Injection (HPCI) from service. Regulatory Review performed by Engineering HCN 22-015 T5.2 UFSAR Table 5.2-3 revised to add note 10 CFR 50.59 to state that the Setpoint of the H SRV screen performed has been temporarily raised from 1108 for TCCP 4HT-psig to 1130 psig per TCCP 4HT22-011 22-011 (80131734)

HCN 22-016 MTOC, 15.2, Revise sections to incorporate cycle 10 CFR 50.59 Appdx. 15D TOC, specific reload analysis results for Cycle screening Appdx. 15D, F15D, 25. Correct formatting, add information performed for T15D for new methodology, and clarify existing DCP 80129619 information.

3

LR-N23-0027 Attachment 2 Summary Report of Hope Creek Changed/Closed Regulatory Commitments

LR-N23-0027 Summary Report Of Hope Creek Changed/Closed Regulatory Commitments Original Commitment Changed/Closed Commitment Justification for Change Complete hardware This one-time commitment is PSEG Nuclear LLC installation of Open Phase closed per NRC letter to completed installation of open Condition Initiative and PSEG dated March 11, 2022, phase protection equipment activation of OPC monitoring Hope Creek Nuclear at Hope Creek Generating and alarm functions. Generating Station - Station.

Closeout of Bulletin 2012-01, Source Documents: Design Vulnerability in Hope Creek Nuclear NEI letter to NRC dated Electric Power System Generating Station -

October 9, 2013, Industry (ADAMS Accession No. Reissued Temporary Initiative on Open Phase ML22060A057); Instruction 2515/194 Report Condition, (ADAMS 05000354/2020010, dated Accession No. Date of Change: April 8, 2020 (ADAMS ML13333A147). July 14, 2022 Accession No. ML20098F407).

NEI letter to NRC dated March 16, 2015, Industry Hope Creek Nuclear Initiative on Open Phase Generating Station -

Condition, Revision 1, Temporary Instruction (ADAMS Accession No. 2515/194 Report ML15075A455). 05000272/2021011 and 05000311/2021011, dated

References:

September 30, 2021 (ADAMS CM-HC-2014-908 Accession No.

70219588 / 0020 ML21272A263).

1

LR-N23-0027 Summary Report Of Hope Creek Changed/Closed Regulatory Commitments Original Commitment Changed/Closed Commitment Justification for Change Enable automated trip This one-time commitment is PSEG Nuclear LLC function. Implementation of closed per NRC letter to completed installation of open Voluntary Industry Initiative PSEG dated March 11, 2022, phase protection equipment for OPC protection Hope Creek Nuclear at Hope Creek Generating completed. Generating Station - Station without the automated Closeout of Bulletin 2012-01, trip function. The station Source Documents: Design Vulnerability in relies on operator manual NEI letter to NRC dated Electric Power System action to diagnose and October 9, 2013, Industry (ADAMS Accession No. mitigate an open phase Initiative on Open Phase ML22060A057); condition.

Condition, (ADAMS Accession No. Date of Change: Hope Creek Nuclear ML13333A147). July 14, 2022 Generating Station -

Reissued Temporary NEI letter to NRC dated Instruction 2515/194 Report March 16, 2015, Industry 05000354/2020010, dated Initiative on Open Phase April 8, 2020 (ADAMS Condition, Revision 1, Accession No.

(ADAMS Accession No. ML20098F407).

ML15075A455).

Hope Creek Nuclear NEI email to NRC dated June Generating Station -

6, 2019, Industry Initiative on Temporary Instruction Open Phase Condition, 2515/194 Report Revision 3, (ADAMS 05000354/2021011, dated Accession No. September 30, 2021 (ADAMS ML19163A176). Accession No. ML21272A263).

References:

CM-HC-2014-909 702196559588 / 0020 2

LR-N23-0027 Summary Report Of Hope Creek Changed/Closed Regulatory Commitments Original Commitment Changed/Closed Commitment Justification for Change PSEG will continue to perform PSEG will continue to perform Reactive loading of Hope Creek VAR loading for the Hope Creek VAR loading for the Hope Creek emergency diesel generators EDGs on an 18-month EDGs periodically. The EDG (EDG) is periodically performed frequency. The EDG loading will loading will be consistent with as required by NRC Regulatory be consistent with EDG load EDG load calculation B-9.0(Q) Guide 1.9, NRC Information calculation B-9.0(Q) and the and the guidance of Regulatory Notice, and the PSEG response guidance of Regulatory Guide Guide 1.9 revision 3. Currently, to NRC inspection report 50-1.9 revision 3. Currently, the the EDG load calculation 354/92-80. Performance of the EDG load calculation demonstrates that worse case EDGs supports extending the demonstrates that worse case design basis accident loading periodicity. Future adjustments design basis accident loading does not exceed the continuous to the test frequency will be does not exceed the continuous rating of the EDGs, therefore controlled by the site Equipment rating of the EDGs, therefore demonstration of VAR loading Reliability program.

demonstration of VAR loading above the continuous rating of above the continuous rating of the EDGs is not necessary and the EDGs is not necessary and will not be performed.

will not be performed

References:

Source Documents: Date of Change:

CM-HC-1992-913 NLR-N92022, letter from PSEG October 24, 2022.

to NRC, Response to Issues WO 70221038 NRC Information Notice 91-13, Identified during the Electrical WO 70222012 Inadequate Testing of Distribution System Functional Emergency Diesel Generators Inspection, dated February 25, (EDGs), March 4, 1991 1992 (ADAMS Accession No.

(ADAMS Accession No. 9203090255);

9102260165);

NLR-92166, letter from PSEG to NRC Inspection Report 50- NRC, Electrical Distribution 354/92-80, Electrical System Functional Inspection Distribution System Functional (EDSFI) Hope Creek Generating Inspection of Hope Creek Station, dated December 23, Generating Station, dated May 1992 (ADAMS Accession No.

28, 1992 (ADAMS Accession 9212300026);

No. 9206090232).

PSEG Commitment Evaluation Summary for CD-225G, dated June 2, 2005.

3

Enclosure 2 Quality Assurance Topical Report, REV. 89, Revision Summary 1

NO-AA-400-001 Revision 10 ATTACHMENT 1 QATR Approval Form Page 1 of 1 PSEG Nuclear LLC NO-AA-10 Revision 89 QUALITY ASSURANCE TOPICAL REPORT (QATR)

Effective: 4/7/23 Date Reviewed by:

Joseph Thompson / per attached email 04/03/2023 Manager Nuclear Oversight Audits (Print/Sign) Date Approved for Implementation by:

Eric Carr / per attached email 04/04/2023 President & Chief Nuclear Officer, PSEG Nuclear Date (Print/Sign)

Page 1 of 26

NO-AA-400-001 Revision 10 ATTACHMENT 2 PSEG NUCLEAR LLC - QUALITY ASSURANCE TOPICAL REPORT NO-AA-10, REV. 89, REVISION

SUMMARY

Revision 89 Effective Date - April 7, 2023 The following is a description of the changes being made to the PSEG Nuclear Quality Assurance Topical Report (QATR) in revision 89. The changes are a result of organizational changes, alignment to latest NRC endorsed document for laboratory testing and relocating information in the Salem and Hope Creek Technical Specifications. This revision to the QATR will be submitted to the NRC for post implementation review as tracked by Order 80095829 Operation 0720. A review, in accordance with HU-AA-1101, determined that formal change management plan was not required for the changes taking place.

The key changes to the QATR made in this revision include:

  • Realign organization titles and positions
  • Implemented corrective actions to address 2022 NIEP evaluation o Update to NEI 14-05 revision 1 endorsed by NRC allowing the use of ISO / IEC 17025 General requirements for the competence of testing and calibration la-boratories: 2017 edition o Delete ANSI N18.7-1976/ANS-3.2 inadvertently left in a previous QATR revision
  • Relocate ANSI/ANS 3.1-1981 from the Salem & Hope Creek Technical Specifications to the PSEG QATR Based on the results of 10 CFR 50.54(a) / 10 CFR 71.106(b) evaluations, the changes being made to the QATR in revision 89 do not represent a reduction in commitment and thus do not require prior approval from the NRC before implementation.

A more detailed summary of the changes is provided on the following pages.

Page 2 of 26

NO-AA-400-001 Revision 10 ATTACHMENT 2 NO-AA-10, REV. 89, QATR REVISION

SUMMARY

(CONTD)

Revision details -

1. CHAPTER 1, ORGANIZATION Specific changes to this chapter included:

- Section 2.1, delete (Refer to Figure 1-1 for simplified organizational relationship chart.) and de-lete Figure 1-1 from Table of Contents. [Request # 23-60]

- Section 2.2.2, delete the portion of the sentence In lieu of ANSI N18.7-1976/ANS-3.2 require-ments, [Request # 23-59]

- In Section 2.2.3, change to Senior Vice President Nuclear Operations, Vice President Corporate Operations Support, Executive Director Regulatory Affairs & Nuclear Oversight, and Senior Direc-tor Fleet Operations Support. [Request # 20-57]

- In Section 2.2.3 1. Add in first sentence report to the Senior Vice President Nuclear Operations and

- In Section 2.2.3 2., Delete , and projects and add in and ahead of fuels. Add in Senior prior to Director of Engineering Services. Move paragraph starting with The Nuclear Projects Direc-tor to Section 2.2.3 3. Move paragraph starting with Matrixed to the Engineering organiza-tion to Section 2.2.3 3.

- In Section 2.2.3 3., Move the word Manager prior to Outage Services.

Change Executive Director Corporate Operations to Vice President Nuclear Corporate Opera-tions Support.

Add projects to the organizations that report to Vice President Nuclear Corporate Operations Sup-port.

Change Fire Protection Manager to Fire Protection Management.

Change Maintenance Services Manager to Manager of Maintenance Services.

Change Nuclear Projects Director to Director of Projects, and the same to report to Vice Presi-dent Nuclear Corporate Operations instead of Vice President of Engineering.

Change Matrixed to the Engineering organization is corporate support for information technology to Matrixed to Vice President Nuclear Corporate Operations is corporate support for information technology.

Change Information Technology Manager to Technology Group Product Manager.

- Change position titles in Sections 2.2.3 4., 2.2.3 5., and 2.2.3 6. to align with changes specified in Section 2.2.3.

-In Section 2.2.3 5. Delete and learning program manager.

-In Section 2.2.3 6. Change Nuclear Training Director to Senior Director Nuclear Training

- In Section 2.2.3 7. Delete and Independent Inspector candidates

- Change position title to Executive Director Regulatory Affairs and Nuclear Oversight Delete the Laboratory and Testing Services Quality Assurance Manager. Change Superintendent to Non-Destructive Examination (NDE) Independent Inspection Superintendent.

- Replace the words a matrixed with an explicit communication and delete (i.e. a dotted line re-porting relationship)

- In Section 2.2.3 8. Delete Business Support and add in of Finance Nuclear after Director.

Page 3 of 26

NO-AA-400-001 Revision 10 ATTACHMENT 2 NO-AA-10, Rev. 89, QATR Revision Summary (Contd)

- Change Nuclear Procurement Director to Director of Procurement

-Section 2.3 Change Organizational effectiveness to Site sustainability

-Section 2.3.2 Change organizational effectiveness to site sustainability in each paragraph.

-Figure 1-1, delete Figure 1-1 Simplified Organizational Relationship Chart

[Request #s 20-57 & 23-60]

2. CHAPTER 4, PROCUREMENT DOCUMENT CONTROL Specific changes to this chapter included:

- Section 2.2.5 1.a Change ISO/IEC-17025:2005 to ISO/IEC-17205-2017 (also in Sections 2.2.5 2.a & 2.2.5 3.a)

-Section 2.2.5 1.a delete the following statement or other NRC endorsed guidance.

- Section 2.2.5 1.d Add in paragraph from Final Safety Evaluation by the Office of Nuclear Reactor Regulation for the Nuclear Energy Institute Technical Report 14-05-A, Guidelines for the Use of Accreditation in lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services revision 1, Section 3.4 2) 1.d.

- Sections 2.2.5 2.d. & 2.2.5 2.e replace paragraphs with wording in NEI 14-05A, 2017 Sections 3.4

2) 2.d & e. Add additional paragraphs in Sections 2.2.5 2.f., and 2.2.5 2.g with wording from NEI 14-05A, 2017 Sections 3.4 2) 2.f & g.

[Request # 23-58]

3. CHAPTER 7, CONTROL OF PURCHASED MATERIAL, EQUIPMENT AND SER-VICES Specific changes to this chapter included:

- Section 2.4.8 1.a Change ISO/IEC-17025:2005 to ISO/IEC-17205-2017 and delete or other NRC endorsed guidance.

- Section 2.4.8 2.a Change ISO/IEC-17025:2005 to ISO/IEC-17205-2017 [Request # 23-58]

4. CHAPTER 18, AUDITS/ASSESSMENTS Specific changes to this chapter included:

- Section 2.1.4 Delete paragraph for annual review of security program per 10 CFR 37.

[Request # 20-56]

- Section 2.2 1.a Change ISO/IEC-17025:2005 to ISO/IEC-17205-2017 and delete or other NRC endorsed guidance.

- Section 2.2 2.a Change ISO/IEC-17025:2005 to ISO/IEC-17205-2017 and delete or other NRC endorsed guidance. [Request # 23-58]

- Section 2.3 change Director Regulatory Operations to Executive Director Regulatory Affairs &

Nuclear Oversight [Request # 23-60]

Page 4 of 26

NO-AA-400-001 Revision 10 ATTACHMENT 2 NO-AA-10, Rev. 89, QATR Revision Summary (Contd)

5. APPENDIX C, CODES, STANDARDS AND GUIDES Specific changes to this chapter included:

- Appendix C.1.3.1 a revised paragraph to Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1981 for comparable positions, except for the individual designated as the Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, the individual designated as the operations manager who shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1981 except as modified by Specification 6.3.3, and the licensed operators who shall comply with the requirements of 10 CFR Part 55.

- Appendix C.1.3.1 b and C.1.3.1. c. are deleted. Revise Appendix C.1.3.1 d to C.1.3.1. b and C.1.3.1 e and C.1.3.1. c.

- Appendix C.1.3.2 a revised paragraph to Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the individual designated as the Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, the individual designated as the Operations Manager who shall meet or exceed the minimum qualifications of ANSI N18.1-1971 except as modified by Speci-fication 6.3.3, and the licensed operators who shall comply with the requirements of 10 CFR 55.

- Revise Note: After Appendix C Section 1.3.2 c to Actual staff qualifications, however, is gov-erned by the Salem UFSAR and QATR commitment to ANSI 3.1-1981. ANSI 3.1-1981 has more stringent and exacting standards than ANSI N18.1-1971.

- Appendix C.1.3.2 b and C.1.3.2. c. are deleted. Revise C.1.3.2 d to C.1.3.2. b and C.1.3.2 e and C.1.3.2 c.

[Request # 23-61]

Page 5 of 26

NO-AA-400-001 Revision 10 ATTACHMENT 2 SUPPORTING INFORMATION 10 CFR 50.54(a) EVALUATIONS FOR THE PSEG NUCLEAR LLC QUALITY ASSURANCE TOPICAL REPORT, REVISION 89 Purpose -

To process required changes to the PSEG Nuclear LLC, Quality Assurance Topical Report (QATR), NO-AA-10, revision 89.

Scope -

This change to the QATR involves Company organizational changes and alignment of re-sponsibilities to improve efficiency and effectiveness. The following are the specific changes:

  • Realign organization titles and positions
  • Implemented corrective actions to address 2022 NIEP evaluation o Update to NEI 14-05 revision 1 endorsed by NRC allowing the use of ISO / IEC 17025 General requirements for the competence of testing and calibration la-boratories: 2017 edition o Delete ANSI N18.7-1976/ANS-3.2 inadvertently left in a previous QATR revision

To support the revision 89 changes made to the PSEG Nuclear LLC QATR, the attached 10 CFR 50.54(a)/10 CFR 71.106(b) evaluations were performed in accordance with pro-cedure NO-AA-400-001, Quality Assurance Topical Report Changes, Revision 10. - General Content Changes to the QATR Conclusion -

Based on the results of the 10 CFR 50.54(a)/10 CFR 71.106(b) evaluation, revision 89 chang-es to the QATR do not represent a reduction in commitment to the PSEG Nuclear QA Pro-gram and thus do not require NRC approval prior to implementation.

Page 6 of 26

NO-AA-400-001 Revision 10 NO-AA-10, Rev. 89, QATR Revision 10CFR50.54(a)/10CFR71.106(b) Evaluation Attachment 2 To support the changes made to the PSEG Nuclear LLC, Quality Assurance Topi-cal Report (QATR) in Revision 89, the following 10 CFR 50.54(a) / 10 CFR 71.106(b) evaluations were performed addressing change request 20-56, 20-57, 23-58, 23-59, 23-60, and 23-61.

Page 7 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report According to 10 CFR 50.54(a)(3) and 10 CFR 71.106(b), a proposed change to a previously ac-cepted quality assurance program description can be made without prior NRC approval provided the change does not reduce the commitments in the program description as previously accepted by the NRC. Question number 3.* below cannot be applied to changes that would vary the companys com-mitment to the 10 CFR 71 QAP requirements.

The following questions must be applied for each individual change to the QATR to determine if NRC approval is required before the change is implemented. The evaluator must provide the SAP number tracking the change, a brief summary of the change, and the detailed rationale for a yes or no response to each question.

Charles Brown / 12-247 Evaluator Name / Badge No.

SAP Order 80095829 / Operation 0660 (Change Request #20-56)

SAP Tracking Number:

Summary of Proposed Change(s): Delete paragraph in Chapter 18, Section 2.1.4: An annual review of the con-tent and implementation of the security program required to meet the requirements of 10 CFR 37, Physical Pro-tection of Category 1 and Category 2 Quantities of Radioactive Material shall be performed in an assessment or audit activity.

No. Question / Rationale Reduction in commitment Yes - No 1.

Does the proposed change involve administrative improvements and clarifications, spelling corrections, punctuation, or editorial items? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column No or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: The requirement of 10 CFR 37 for an annual review is as follows:

§ 37.55 Security program review.

(a) Each licensee shall be responsible for the continuing effectiveness of the security program.

Each licensee shall ensure that the security program is reviewed to confirm compliance with the requirements of this subpart and that comprehensive actions are taken to correct any noncom-pliance that is identified. The review must include the radioactive material security program con-tent and implementation. Each licensee shall periodically (at least annually) review the security program content and implementation.

The regulation does not require the annual review be performed by an independent oversight group. Benchmarking of other utilities determined the review required by 10 CFR 37.55 is usually performed by the Security Department, not by an independent oversight group.

The current QATR requirement to perform an annual review of the content and implementation of the security program required to meet the requirements of 10 CFR 37 in an assessment or au-dit activity was added as part of the changes to revision 84 of the QATR.

Page 8 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report (continued)

No. Question / Rationale Reduction in commitment Yes - No 2.

Does the proposed change involve the use of a QA standard approved by the NRC which is more recent than the QA standard in the licensees current QA program at the time of the change? If the answer is Yes indicate a No in adjacent column. If the answer is No No indicate a Yes in the adjacent column or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: The 10 CFR 37.55 regulation does not require the annual review be per-formed by an independent oversight group. Benchmarking of other utilities determined the review required by 10 CFR 37.55 is normally performed by the Security organization and not by the independent oversight group.

3.* Does the proposed change involve the use of a quality assurance alternative or excep-tion approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensees facility? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column or provide ra- No tionale below on why there is no reduction in commitment (RIC) and place a No in ad-jacent column.

Explain how all of the NRC approval bases from the SER are incorporated or covered by the PSEG QA Program, if applicable.

Rationale: The answer is no with the basis for no reduction of commitment since 10 CFR 37.55 regulation does not require the annual review be performed by an independent oversight group. Nuclear Oversight does perform a security audit to satisfy 10 CFR 73 requirements and does ensure that the annual 10 CFR 37 assessment is performed. Au-dit Template P3A-1 Security Organization, verification detail P3A-1.2 H. Verify review of the security program for physical control of category 1 and category 2 quantities of radi-oactive material is performed at least annually satisfying 10 CFR 37.55 criteria.

Page 9 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report (continued)

No. Question / Rationale Reduction in commitment Yes - No

4. Does the proposed change (to the extent allowable by the applicable facility Technical Specifications) involve the use of generic organizational position titles that clearly de-note the position function, supplemented as necessary by descriptive text, rather than specific titles? If the answer is Yes indicate a No in adjacent column. If the answer No is No indicate a Yes in the adjacent column or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: This change does not impact any position titles. This question is not appli-cable based on the details related to this proposed change.

5. Does the proposed change (to the extent allowable by the applicable facilitys Technical Specifications) involve the use of generic organizational charts to indicate functional relationships, authorities, and responsibilities, or, alternately, the use of descriptive text? If the answer is Yes indicate a No in adjacent column. If the answer is No No indicate a Yes in the adjacent column or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: This change has no impact on the organization chart or responsibilities re-lated to perform activities to support implementation of the Quality Assurance Pro-gram. This question is not applicable based on the details related to this proposed change.

Page 10 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report (continued)

No. Question / Rationale Reduction in commitment Yes - No

6. Does the proposed change involve the elimination of quality assurance program infor-mation that duplicates language in quality assurance regulatory guides and quality as-surance standards to which the licensee is committed? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column No or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: This change is not related to the duplication of language. The basis for the change is to align the performance of the 10 CFR 37 annual assessment with industry practice.

7.

Does the proposed change involve organizational revisions that ensure that persons and organizations performing quality assurance functions continue to have the requisite au-thority and organizational freedom, including sufficient independence from cost and No schedule when opposed to safety considerations? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column or pro-vide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: This change does not involve any impact any organizations that are perform-ing quality assurance functions. The Nuclear Oversight Organization will continue to perform Security audits and include verification that the 10 CFR 37 annual assessment is performed. There is no requirement for the annual review of 10 CFR 37 to be per-formed by an independent organization.

If a no is in the reduction in commitment column for each question, then the proposed change is not considered a reduction in commitment and can be made without prior NRC approval in accordance with 10 CFR 50.54(a)(3) and 10 CFR 71.106(b). If a yes is in the reduction in commitment column for any question, then the change is considered to be a reduction in commitment requiring NRC approval in accordance with 10 CFR 50.54(a)(4) and 10 CFR 71.106(b).

X Change does not need prior NRC approval prior to implementation Change requires NRC approval prior to implementation NOS Evaluator: Charles Brown (SAP#80095829/0660) Date: __3/23/23____

(Print Name & Sign)

Review NOS Supervisor: Van McPherson (SAP#80095829/0660) Date: ___3/23/23__

(Print Name & Sign)

Approval Manager NOS Audits: Joseph Thompson (SAP#80095829/0660) Date: ___3/23/23__

(Print Name & Sign)

Page 11 of 26

NO-AA-400-001 Revision 10 , Evaluation of Proposed Change to Quality Assurance Topical Report According to 10 CFR 50.54(a)(3) and 10 CFR 71.106(b), a proposed change to a previously accepted quality assurance program description can be made without prior NRC approval provided the change does not reduce the commitments in the program description as previously accepted by the NRC.

Question number 3.* below cannot be applied to changes that would vary the companys commitment to the 10 CFR 71 QAP requirements.

The following questions must be applied for each individual change to the QATR to determine if NRC approval is required before the change is implemented. The evaluator must provide the SAP number tracking the change, a brief summary of the change, and the detailed rationale for a yes or no re-sponse to each question.

Charles Brown / 12-247 Evaluator Name / Badge No.

SAP Order 80095829 / Operations 0670 and 0700 (Change Request # 20-57 SAP Tracking Number:

& 23-60)

Summary of Proposed Change(s): Align Organization Titles and Positions based on organizational changes per-formed during the past few years. (Notification 20929695). The Central Maintenance Shop was eliminated. The work is performed by Station Maintenance or per a contract to a qualified vendor. Some additional Vice Presi-dent titles were added and Projects and Technology Group Products were aligned under Vice President Corpo-rate Operations Support. Deletion of Figure 1-1 Simplified Organizational Relationship Chart.

No. Question / Rationale Reduction in commitment Yes - No 1.

Does the proposed change involve administrative improvements and clarifications, spelling corrections, punctuation, or editorial items? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column No or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: The basis for the change does provide some administrative improvements by removing redundancy between the written text and Figure 1-1 Simple Organization Re-lationship Chart by deleting Figure 1-1. There is no reduction in commitment based on all the responsibilities to implement the quality assurance program are being per-formed. The Organizational title changes, organizational alignment for some groups, and organization elimination (central maintenance) did not impact implementation of the quality assurance program.

Page 12 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report (continued)

No. Question / Rationale

2. Does the proposed change involve the use of a QA standard approved by the NRC which is more recent than the QA standard in the licensees current QA program at the time of the change? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column or provide rationale below on why there is No no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: There is no approved NRC standard more recent related to Organization that is being used. The rational on why there is no RIC is as follows: The changes in Chapter 1 Organization and Chapter 18 were made for better alignment with all the Quality As-surance Program requirements being implemented. The elimination of redundancy be-tween the written text and Figure 1-1 is in line with other sites approved QATR revisions that simplified Chapter 1 Organization Chart (e.g. See Constellation Energy Generation, LLC Quality Assurance Topical Report revision 98 (no figure included)).

3.* Does the proposed change involve the use of a quality assurance alternative or excep-tion approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensees facility? If the answer is Yes indicate a No in adja- No cent column. If the answer is No indicate a Yes in the adjacent column or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Explain how all of the NRC approval bases from the SER are incorporated or covered by the PSEG QA Program, if applicable.

Rationale: This change does not involve the use of a quality assurance alternative or exception approved by an NRC safety evaluation. This is not a reduction in commitment based on all QA Program responsibilities and requirements are being implemented by the Organizations described in Chapter 1. The level of detail in Chapter 1 Organization is more detailed or consistent with other sites Quality Assurance Program licensing basis document (e.g., Constellation Energy Generation, LLC. Quality Assurance Topical Report, NO-AA-10 revision 98 and Entergy Quality Assurance Program Manual, revision 42).

Page 13 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report (continued)

No. Question / Rationale Reduction in commitment Yes - No

4. Does the proposed change (to the extent allowable by the applicable facility Technical Specifications) involve the use of generic organizational position titles that clearly de-note the position function, supplemented as necessary by descriptive text, rather than No specific titles? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: This change is related to the use of organizational position titles that clearly denote the positions function, with descriptive text.

5. Does the proposed change (to the extent allowable by the applicable facilitys Technical Specifications) involve the use of generic organizational charts to indicate functional re-lationships, authorities, and responsibilities, or, alternately, the use of descriptive text? No If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: This change does not use generic organizational charts to indicate functional relationships, authorities, and responsibilities. This change does use specific position titles and descriptive text to address the relationships, authorities, and responsibilities for implementing the Quality Assurance Program.

No. Question / Rationale Reduction in commitment Yes - No

6. Does the proposed change involve the elimination of quality assurance program infor-mation that duplicates language in quality assurance regulatory guides and quality as-surance standards to which the licensee is committed? If the answer is Yes indicate a No No in adjacent column. If the answer is No indicate a Yes in the adjacent column or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: This change is related to the duplication of language and a figure depicting the same information as the text. The basis for the change is to align the station posi-tion titles and organizational alignment with the current documents that are implement-ing the Quality Assurance Program and reduce duplication.

Page 14 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report (continued)

No. Question / Rationale Reduction in commitment Yes - No

7. Does the proposed change involve organizational revisions that ensure that persons and organizations performing quality assurance functions continue to have the requisite au-thority and organizational freedom, including sufficient independence from cost and No schedule when opposed to safety considerations? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column or pro-vide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: This change does involve changes to the organization which have no impact on organizational freedom. There was no change to persons or organizations perform-ing quality assurance functions that were affected.

If a no is in the reduction in commitment column for each question, then the proposed change is not con-sidered a reduction in commitment and can be made without prior NRC approval in accordance with 10 CFR 50.54(a)(3) and 10 CFR 71.106(b). If a yes is in the reduction in commitment column for any question, then the change is considered to be a reduction in commitment requiring NRC approval in accordance with 10 CFR 50.54(a)(4) and 10 CFR 71.106(b).

X Change does not need prior NRC approval prior to implementation Change requires NRC approval prior to implementation NOS Evaluator: Charles Brown/ Evan Humes (SAP#80095829/0670 & 0700) Date: __3/23/23___

(Print Name & Sign)

Review NOS Supervisor: Van McPherson (SAP#80095829/0670 & 0700) Date: ___3/23/23__

(Print Name & Sign)

Approval Manager NOS Audits: Joseph Thompson (SAP#80095829/0670 & 0700) Date: _ 3/23/23 (Print Name & Sign)

Page 15 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report According to 10 CFR 50.54(a)(3) and 10 CFR 71.106(b), a proposed change to a previously accepted quality assurance program description can be made without prior NRC approval provided the change does not reduce the commitments in the program description as previously accepted by the NRC.

Question number 3.* below cannot be applied to changes that would vary the companys commitment to the 10 CFR 71 QAP requirements.

The following questions must be applied for each individual change to the QATR to determine if NRC approval is required before the change is implemented. The evaluator must provide the SAP number tracking the change, a brief summary of the change, and the detailed rationale for a yes or no re-sponse to each question.

Charles Brown / 12-247 Evaluator Name / Badge No.

SAP Order 80095829 / Operation 0680 (Change Request #23-58)

SAP Tracking Number:

Summary of Proposed Change(s): Delete wording or other NRC endorsed guidance in Chapters 4 Section 2.2.5.1.a, Chapter 7 Section 2.4.8.1.a, and Chapter 18 Section 2.2.1.a.

Update the following to Chapters from ISO/IEC-17025:2005 to ISO/IEC-17205-2017: Chapters 4 Sections 2.2.5 1.a, 2.2.5 2.a, and 2.2.5 3.a ; Chapter 7 Sections 2.4.8 1.a and 2.4.8 2.a ; and Chapter 18 Sections 2.2 1.a. and 2.2 2.a.

Add in detail from NEI 14-05-A, Guidelines for the Use of Accreditation in lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services revision 1: in Chapter 4 Section 2.2.5 1d. Add in new paragraphs (related to remote assessments); Add in new paragraphs to Sections 2.2.5 2.d, 2.2.5 2.e, 2.2.5 2.f.,

2.2.5 2.g replacing existing wording in Section 2.2.5 2.d. & 2.2.5 2.e paragraphs.

No. Question / Rationale Reduction in commitment Yes - No 1.

Does the proposed change involve administrative improvements and clarifications, spelling corrections, punctuation, or editorial items? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column No or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: The proposed change does involve an administrative improvement aligning the commercial grade dedication process with the latest NRC endorsed standard. The change updates the NRC endorsed guidance in accordance with NEI 14-05A, Guidelines for the Use of Accreditation in lieu of Commercial Grade Surveys for Procurement of La-boratory Calibration and Test Services, Revision 1. (NRC Final Safety Evaluation, Nos.

ML20322A454 and ML20322A019)

Page 16 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report (continued)

No. Question / Rationale Reduction in commitment Yes - No 2.

Does the proposed change involve the use of a QA standard approved by the NRC which is more recent than the QA standard in the licensees current QA program at the time of the change? If the answer is Yes indicate a No in adjacent column. If the answer is No No indicate a Yes in the adjacent column or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: The answer to this question is Yes. The change updates the NRC endorsed guidance of NEI 14-05A, Guidelines for the Use of Accreditation in lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, Revision 1.

(NRC Final Safety Evaluation, Nos. ML20322A454 and ML20322A019) 3.* Does the proposed change involve the use of a quality assurance alternative or excep-tion approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensees facility? If the answer is Yes indicate a No in adjacent No column. If the answer is No indicate a Yes in the adjacent column or provide ra-tionale below on why there is no reduction in commitment (RIC) and place a No in ad-jacent column.

Explain how all of the NRC approval bases from the SER are incorporated or covered by the PSEG QA Program, if applicable.

Rationale: The answer to this question is Yes. There is a corresponding NRC safety eval-uation accepting this industry standard. The change updates the NRC endorsed guid-ance of NEI 14-05A, Guidelines for the Use of Accreditation in lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services, Revision 1, 2017 edition. (NRC Final Safety Evaluation, Nos. ML20322A454 and ML20322A019)

Page 17 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report (continued)

No. Question / Rationale Reduction in commitment Yes - No

4. Does the proposed change (to the extent allowable by the applicable facility Technical Specifications) involve the use of generic organizational position titles that clearly de-note the position function, supplemented as necessary by descriptive text, rather than specific titles? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column or provide rationale below on why there is No no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: This change does not impact any position titles. This question is not applica-ble based on the details related to this proposed change.

5. Does the proposed change (to the extent allowable by the applicable facilitys Technical Specifications) involve the use of generic organizational charts to indicate functional re-lationships, authorities, and responsibilities, or, alternately, the use of descriptive text?

If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column or provide rationale below on why there is no reduction No in commitment (RIC) and place a No in adjacent column.

Rationale: This change has no impact on the organization chart or responsibilities relat-ed to perform activities to support implementation of the Quality Assurance Program.

This question is not applicable based on the details related to this proposed change.

Page 18 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report (continued)

No. Question / Rationale Reduction in commitment Yes - No

6. Does the proposed change involve the elimination of quality assurance program infor-mation that duplicates language in quality assurance regulatory guides and quality as-surance standards to which the licensee is committed? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column No or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: This change is not related to the duplication of language. The basis for the change is to align the QATR with the current approved industry standard and NRC en-dorsed document.

7.

Does the proposed change involve organizational revisions that ensure that persons and organizations performing quality assurance functions continue to have the requisite au-thority and organizational freedom, including sufficient independence from cost and No schedule when opposed to safety considerations? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column or pro-vide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: This change does not involve any impact to any organizations that are per-forming quality assurance functions.

If a no is in the reduction in commitment column for each question, then the proposed change is not considered a reduction in commitment and can be made without prior NRC approval in accordance with 10 CFR 50.54(a)(3) and 10 CFR 71.106(b). If a yes is in the reduction in commitment column for any question, then the change is considered to be a reduction in commitment requiring NRC approval in accordance with 10 CFR 50.54(a)(4) and 10 CFR 71.106(b).

X Change does not need prior NRC approval prior to implementation Change requires NRC approval prior to implementation NOS Evaluator: Charles Brown (SAP#80095829/0680) Date: __3/23/23____

(Print Name & Sign)

Review NOS Supervisor: Van McPherson (SAP#80095829/0680) Date: __3/23/23____

(Print Name & Sign)

Approval Manager NOS Audits: Joseph Thompson (SAP#80095829/0680) Date: __3/23/23____

(Print Name & Sign)

Page 19 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report According to 10 CFR 50.54(a)(3) and 10 CFR 71.106(b), a proposed change to a previously accepted quality as-surance program description can be made without prior NRC approval provided the change does not reduce the commitments in the program description as previously accepted by the NRC. Question number 3.* below cannot be applied to changes that would vary the companys commitment to the 10 CFR 71 QAP requirements.

The following questions must be applied for each individual change to the QATR to determine if NRC approval is required before the change is implemented. The evaluator must provide the SAP number tracking the change, a brief summary of the change, and the detailed rationale for a yes or no response to each question.

Charles Brown / 12-247 Evaluator Name / Badge No.

SAP Order 80095829 / Operation 0690 (Change Request #23-59)

SAP Tracking Number:

SAP Order 80095829 / Operation 0710 (Change Request #23-61)

Summary of Proposed Change(s): Delete first portion of sentence that starts with In lieu of ANSI N18.7-1976/ANS-3.2 requirements in Chapters 1, Section 2.2.2 [#23-59]

Revise wording in Appendix C.1.3.1 a to: Each member of the unit staff shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1981 for comparable positions, except for the individual designated as the Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, the individual designated as the operations manager who shall meet or exceed the minimum qualifications of ANSI/ANS 3.1-1981 except as modified by Specification 6.3.3, and the licensed operators who shall comply with the requirements of 10 CFR Part 55.

Delete exiting Appendix C.1.3.1 b and C.1.3.1. c. Change C.1.3.1 d to C.1.3.1. c and C.1.3.1 e and C.1.3.1. d.

Revise wording in Appendix C.1.3.2 a to: Each member of the facility staff shall meet or exceed the minimum qualifications of ANSI N18.1-1971 for comparable positions, except for the individual designated as the Radiation Protection Manager who shall meet or exceed the qualifications of Regulatory Guide 1.8, September 1975, the individual designated as the Opera-tions Manager who shall meet or exceed the minimum qualifications of ANSI N18.1-1971 except as modified by Specification 6.3.3, and the licensed operators who shall comply with the requirements of 10 CFR 55.

Revise Note: After Appendix C Section 1.3.2 c to: Actual staff qualifications, however, is governed by the Salem UFSAR and QATR commitment to ANSI 3.1-1981. ANSI 3.1-1981 has more stringent and exacting standards than ANSI N18.1-1971.

Delete exiting Appendix C.1.3.2 b and C.1.3.2. c. Change C.1.3.2 d to C.1.3.2. c and C.1.3.2 e and C.1.3.2 d. [#23-61]

No. Question / Rationale Reduction in commitment Yes - No 1.

Does the proposed change involve administrative improvements and clarifications, spelling corrections, punctuation, or editorial items? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column No or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: The proposed changes are administrative improvements. Removing a portion of the sentence corrects an error of omission (See Notification 20915298 as corrective action). The second change supports a Salem and Hope Creek technical specifications (TS) change by relocating a requirements from the TS to the QATR. Per LAR S22-03 &

H22-01 to remove the ANSI Qualifications from the Salem and Hope Creek Technical Specifications and included them in the PSEG QATR. (NRC SER referenced in 2 below).

Page 20 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report (continued)

No. Question / Rationale Reduction in commitment Yes - No 2.

Does the proposed change involve the use of a QA standard approved by the NRC which is more recent than the QA standard in the licensees current QA program at the time of the change? If the answer is Yes indicate a No in adjacent column. If the answer is No No indicate a Yes in the adjacent column or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: These proposed change does involve the use a QA standard approved by the NRC that is more recent than the QA standard in a licensing document. In QATR revision 85, the exceptions to the off-site review committee were approved by the NRC in an SER dated January 13, 2005 issued to NMC - ADAMS Accession Number ML050210276. This change provided the basis to remove the portion of the sentence related to ANSI N18.7-1976 / ANS 3.2. NRC SER addresses Hope Creek Generating Station and Salem Nuclear Generating Station, Unit Nos. 1 and 2 Issuance of Amendment Nos. 233, 344, And 325 Re: Relocate Technical Specification Staff Qualification Requirements to the PSEG Quality Assurance Topical Report (EPID L-2022-LLA-0092) dated March 9, 2023 (Adams Acces-sion No. ML23037A971).

3.* Does the proposed change involve the use of a quality assurance alternative or excep-tion approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensees facility? If the answer is Yes indicate a No in adjacent No column. If the answer is No indicate a Yes in the adjacent column or provide ra-tionale below on why there is no reduction in commitment (RIC) and place a No in ad-jacent column.

Explain how all of the NRC approval bases from the SER are incorporated or covered by the PSEG QA Program, if applicable.

Rationale: The answer to this question is Yes based on the two SERs that are referenced in question 2 above.

Page 21 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report (continued)

No. Question / Rationale Reduction in commitment Yes - No

4. Does the proposed change (to the extent allowable by the applicable facility Technical Specifications) involve the use of generic organizational position titles that clearly de-note the position function, supplemented as necessary by descriptive text, rather than specific titles? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column or provide rationale below on why there is No no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: This change does not impact any position titles. This question is not applica-ble based on the details related to this proposed changes.

5. Does the proposed change (to the extent allowable by the applicable facilitys Technical Specifications) involve the use of generic organizational charts to indicate functional re-lationships, authorities, and responsibilities, or, alternately, the use of descriptive text?

If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column or provide rationale below on why there is no reduction No in commitment (RIC) and place a No in adjacent column.

Rationale: This change has no impact on the organization chart or responsibilities relat-ed to perform activities to support implementation of the Quality Assurance Program.

This question is not applicable based on the details related to this proposed changes.

Page 22 of 26

NO-AA-400-001 Revision 10 Attachment 3, Evaluation of Proposed Change to Quality Assurance Topical Report (continued)

No. Question / Rationale Reduction in commitment Yes - No

6. Does the proposed change involve the elimination of quality assurance program infor-mation that duplicates language in quality assurance regulatory guides and quality as-surance standards to which the licensee is committed? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column No or provide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: These changes are not related to the duplication of language. The basis for the changes is to align the QATR with the licensing basis documents and implementing procedures, based on approved technical specification change and previous QATR revi-sion.

7.

Does the proposed change involve organizational revisions that ensure that persons and organizations performing quality assurance functions continue to have the requisite au-thority and organizational freedom, including sufficient independence from cost and No schedule when opposed to safety considerations? If the answer is Yes indicate a No in adjacent column. If the answer is No indicate a Yes in the adjacent column or pro-vide rationale below on why there is no reduction in commitment (RIC) and place a No in adjacent column.

Rationale: This change does not involve any impact to any organizations that are per-forming quality assurance functions.

If a no is in the reduction in commitment column for each question, then the proposed change is not considered a reduction in commitment and can be made without prior NRC approval in accordance with 10 CFR 50.54(a)(3) and 10 CFR 71.106(b). If a yes is in the reduction in commitment column for any question, then the change is considered to be a reduction in commitment requiring NRC approval in accordance with 10 CFR 50.54(a)(4) and 10 CFR 71.106(b).

X Change does not need prior NRC approval prior to implementation Change requires NRC approval prior to implementation NOS Evaluator: Charles Brown (SAP#80095829/0690 & 0710) Date: __3/23/23____

(Print Name & Sign)

Review NOS Supervisor: Van McPherson (SAP#80095829/0690 & 0710) Date: __3/23/23____

(Print Name & Sign)

Approval Manager NOS Audits: Joseph Thompson (SAP#80095829/0690 & 0710) Date: __3/23/23____

(Print Name & Sign)

Page 23 of 26

Humes, Evan H.

From: Thompson, Joseph (Nuclear)

Sent: Monday, April 3, 2023 2:53 PM To: Humes, Evan H.

Cc: Brown, Charles J.; McPherson Jr, Van

Subject:

RE: NO-AA-10 QATR Rev. 89 for approval Follow Up Flag: Follow up Flag Status: Flagged As Manager Nuclear Oversight Audits, this email serves as signature for my review of the following document, with an effective date of 4/7/2023:

NOAA10, revision 89, Quality Assurance Topical Report (QATR)

From: Humes, Evan H. <Evan.Humes@pseg.com>

Sent: Monday, April 3, 2023 2:51 PM To: Thompson, Joseph (Nuclear) <Joseph.Thompson@pseg.com>

Cc: Brown, Charles J. <Charles.Brown2@pseg.com>; McPherson Jr, Van <Van.McPhersonJr@pseg.com>

Subject:

NOAA10 QATR Rev. 89 for approval

Joe, If you approve the attached revision 89 of NOAA10, please replay with the following text:

As Manager Nuclear Oversight Audits, this email serves as signature for my review of the following document, with an effective date of 4/7/2023:

NOAA10, revision 89, Quality Assurance Topical Report (QATR)

Thank you, Evan EVAN HUMES l Nuclear Quality Assurance Auditor T. +1.862-849-5635 1

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Humes, Evan H.

From: Carr, Eric Sent: Tuesday, April 4, 2023 8:55 AM To: Humes, Evan H.

Cc: Mannai, David; McPherson Jr, Van; Brown, Charles J.; Thompson, Joseph (Nuclear)

Subject:

RE: NO-AA-10, R89 QATR for review and approval As President and Chief Nuclear Officer, PSEG Nuclear, this email serves as my approval to implement the following document, with an effective date of 4/7/2023:

NOAA10, revision 89, Quality Assurance Topical Report (QATR)

Eric Carr From: Humes, Evan H. <Evan.Humes@pseg.com>

Sent: Tuesday, April 4, 2023 7:37 AM To: Carr, Eric <Eric.Carr@pseg.com>

Cc: Mannai, David <David.Mannai@pseg.com>; McPherson Jr, Van <Van.McPhersonJr@pseg.com>; Brown, Charles J.

<Charles.Brown2@pseg.com>; Thompson, Joseph (Nuclear) <Joseph.Thompson@pseg.com>

Subject:

NOAA10, R89 QATR for review and approval Good morning Eric, Please see the attached final draft of NOAA10, Quality Assurance Topical Report, Revision 89 for your review and approval, with the supporting documents.

To comply with the remote signature guidelines of ADAA106 Signature Authority, if you approve this revision, please cut and paste the below text in reply to this email:

The following is a brief summary of the changes:

Realigned organization titles and positions Implemented corrective actions to address 2022 NIEP evaluation o Update to NEI 1405 revision 1 endorsed by NRC allowing the use of ISO / IEC 17025 General requirements for the competence of testing and calibration laboratories: 2017 edition o Delete a sentence inadvertently left in a previous QATR revision Delete 10 CFR 37 NOS Assessment Relocate ANSI/ANS 3.11981 from the Salem & Hope Creek Technical Specifications to the PSEG QATR If you wish a more detailed review, a line by line PDF comparison to the current revision can be found here:

"M:\Shared\Humes\[Compare Report] NOAA10_R89 Final Draft compared to R88.pdf" If you have any more questions, please reach out to Joe Thompson at 8564041169 or Charlie Brown at 3152438788.

Thank you, Evan EVAN HUMES l Nuclear Quality Assurance Auditor T. +1.862-849-5635 1

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