RA-08-076, Request Approval of Change to Exelon Generation Company, LLC, and Amergen Energy Company, LLC, Quality Assurance Topical Report
| ML082140111 | |
| Person / Time | |
|---|---|
| Site: | Dresden, Peach Bottom, Oyster Creek, Byron, Braidwood, Limerick, Clinton, Quad Cities, Zion, LaSalle, 07100008, Crane  |
| Issue date: | 07/31/2008 |
| From: | Simpson P AmerGen Energy Co, Exelon Generation Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| RA-08-076, RS-08-093 | |
| Download: ML082140111 (11) | |
Text
Exelon Generation www.exeloncorp.com 4300 Winfield Road Warrenville, IL 60555 RS-08-093 RA-08-076 July 31, 2008 U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, DC 20555-0001 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, STN 50-455 and 72-68 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 Dresden Nuclear Power Station, Units 1, 2, and 3 Facility Operating License No. DPR-2 Renewed Facility Operating License Nos. DPR-19 and DPR-25 NRC Docket Nos.50-010, 50-237, 50-249, and 72-37 LaSalle County Station, Units 1 and 2 Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373 and 50-374 Limerick Generating Station, Units 1 and 2 Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352_50-353 and 72-65 Oyster Creek Nuclear Generating Station Facility Operating License No. DPR-16 NRC Docket Nos. 50-219 and 72-15 Exel6n Nuclear 10 CFR 50.54(0)(4)
U. S. Nuclear Regulatory Commission Page 2 July 31, 2008 Peach Bottom Atomic Power Station, Units 1, 2, and 3 Facility Operating License No. DPR-12 Renewed Facility Operating License Nos. DPR-44 and DPR-56 NRC Docket Nos. 50-171, 50-277, 50-278, and 72-29 Quad Cities Nuclear Power Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-29 and DPR-30 NRC Docket Nos. 50-254, 50-265, and 72-53 Three Mile Island Station, Unit 1 Facility Operating License No. DPR-50 NRC Docket No. 50-289 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 Exelon Generation Company, LLC and AmerGen Energy Company, LLC 10 CFR 71, "Packaging and Transportation of Radioactive Material" NRC Docket No.71-008 Subject :
Request for Approval of Change to Exelon Generation Company, LLC, and AmerGen Energy Company, LLC, Quality Assurance Topical Report In accordance with 10 CFR 50.54(a)(4), Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen), requests approval of a proposed change to the Quality Assurance Topical Report (QATR). The proposed change is a reduction in commitment, and in accordance with 10 CFR 50.54(a)(4), NRC approval is required prior to implementation.
The proposed change deletes the requirement to have new or revised administrative procedures, recommended by Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operations)," reviewed by the plant's operations review committee prior to implementation. to this letter describes the proposed QATR change in more detail, the reason for the change, and the basis for concluding that the revised QATR continues to satisfy the criteria of 10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants." Attachment 2 contains a markup of the affected QATR page.
U. S. Nuclear Regulatory Commission Page 3 July 31, 2008 In accordance with 10 CFR 50.54 (a)(4)(iv), this change to the QATR shall be regarded as accepted by the NRC upon receipt of a letter to that effect or 60 days after submittal of this request, whichever occurs first.
If you have any questions concerning this request, please contact Mr. Ken Nicely at (630) 657-2803.
Patrick R. Simpson Manager - Licensing Attachments :
1.
Evaluation of Proposed Change
- 2.
Markup of Proposed Quality Assurance Topical Report Change
cc :
Regional Administrator - NRC Region I Regional Administrator - NRC Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Oyster Creek Nuclear Generating Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station NRC Senior Resident Inspector - Three Mile Island Station
Introduction The Exelon Generation Company, LLC (EGC) and AmerGen Energy Company, LLC (AmerGen)
Quality Assurance Topical Report (QATR) ensures conformance to 10 CFR 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants." In accordance with 10 CFR 50.54(a)(4), EGC and AmerGen request NRC approval of a proposed change to the QATR. The proposed change removes the requirement to have new or revised administrative procedures, recommended by Regulatory Guide 1.33, "Quality Assurance Program Requirements (Operations)," reviewed by the plant's operations review committee (PORC) prior to implementation. This proposed QATR change is considered a reduction in commitment and therefore, NRC approval is required prior to implementation.
Background
ATTACHMENT 1 Evaluation of Proposed Change The EGC and AmerGen Quality Assurance Program (QAP) complies with the administrative controls and quality assurance requirements contained in the specific American National Standards Institute (ANSI) or American Nuclear Society (ANS) standards committed to by each site.' These standards define the scope of review for a Plant Safety Review Committee (i.e.,
PORC) as well as the requirements for the review and approval of documents including administrative procedures.
The EGC and AmerGen QATR previously approved by the NRC requires that new or revised administrative procedures, recommended by Regulatory Guide (RG) 1.33, "Quality Assurance Program Requirements," be submitted to the PORC for review and approval prior to implementation.
EGC and AmerGen consider that this mandatory PORC review requirement creates an unnecessary administrative burden without any compensating increase in nuclear safety.
Proposed Change EGC and AmerGen are requesting NRC approval to remove the requirement to obtain PORC review and approval of all new and revised RG 1.33 recommended administrative procedures.
Currently, the QATR, Chapter 5, "Instructions, Procedures and Drawings," Section 2.3.1, states :
"Applicable Administrative Procedures recommended by Regulatory Guide 1.33 shall be submitted to the Plant Operations Review Committee (PORC) as applicable, for review prior to implementation. The PORC shall recommend approval or disapproval based on their review. "
EGC and AmerGen propose deleting this sentence to eliminate this administrative requirement.
' ANSI N18.7-1976/ANS 3.2 (Limerick, Oyster Creek, Three Mile Island, Clinton) ; ANSI N18.7-1972 (Peach Bottom); ANSI/ANS 3.2-1988 (Braidwood, Byron, Dresden, LaSalle, Quad Cities)
Justification for Change ATTACHMENT 1 Evaluation of Proposed Change The standards which define, in part, the administrative controls for the EGC and AmerGen nuclear plants contain guidance to assure that appropriate review and approval is provided for procedures and changes to those procedures. Considering the three standards which cover these requirements for the EGC and AmerGen nuclear plants, the relevant sections of standards addressing approval of procedures and changes to procedures are as follows.
ANSI N18.7 - 1972, "Administrative Controls for Nuclear Power Plants during Operational Phase"
" 4.3 - Subjects Requiring Independent Review
" 5.0 - Facility Administrative Polices and Procedures
" 5.4 - Review and Approval of Procedures ANSI N18.7 - 1976 /.ANS 3.2, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" 4.3.4 - Subjects Requiring Independent Review
" 5.2.15 - Review, Approval and Control of Procedures
" 5.3 - Preparation of Instructions and Procedures ANSI/ANS 3.2 - 1988, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants"
" 4.3.1 - Scope of Review (Plant Safety Review Committee)
" 5.2.15 - Review, Approval and Control of Documents The requirements in these various documents for the control, review and approval of procedures, including those associated with RG 1.33 recommended administrative procedures are described in the following tables.
ATTACHMENT 1 Evaluation of Proposed Change Section ANSI N18.7 - 1976 (Applicable to Clinton, Limerick, Oyster Creek and TMI Stations 4.3.4 The following subjects shall be reported to and reviewed by the independent review body:
4.3.4.1 Written safety evaluations of changes in the facility as described in the Safety Analysis Report and tests or experiments not described in the Safety Analysis Report which are completed without prior NRC approval under the provisions of 10 CFR 50.59(a)(1). This review is to verify that such changes, tests or experiments did not involve a change in the technical specifications or an unreviewed safety question as defined in 10 CFR 50.59(a)(2). to procedures, equipment, or systems completed under the provisions of § 50.59 (b), Part 50, Title 10, Code of Federal Regulations to verify that such changes do constitute unreviewed safety
, questions.
4.3.4.2 Proposed changes in procedures, proposed changes in the facility, or propose tests or experiments, any of which involves a change in the technical specifications or an unreviewed safety question as defined in 10 CFR 50.59(c).
Matters of this kind shall be referred to the independent review body by the onsite operating organization following its review, or by other functional organizational units within the owner organization, prior to implementation.
4.3.4.5 Any other matter involving safe operation of the nuclear power plant which an independent reviewer deems appropriate for consideration, or which is Section ANSI N18.7 - 1972 A : ~licable to Peach Bottom Atomic Power Station 4.3 The following subjects shall be reported to and reviewed by the independent review and audit group:
4.3.1 Evaluations of proposed changes to procedures, equipment, or systems completed under the provisions of § 50.59 (b), Part 50, Title 10, Code of Federal Regulations to verify that such changes do constitute unreviewed safety questions.
4.3.3 Proposed changes in procedures, equipment, or systems which may involve an unreviewed safety question as defined in § 50.59 (c), Part 50, Title 10, Code of Federal Regulations; or changes which are referred by the operating organization.
5.0 5.1 [In part]...policies shall assure that documents, including revisions or changes, are reviewed for adequacy and approved for release by authorized personnel...
5.4
[In part] In the case of proposed changes to procedures having safety significance, the plant management shall arrange for further review, including the review specified in 4.3 [Subjects Requiring Independent Review], prior to final approval or disapproval by the management representative assigned approval authority,
ATTACHMENT 1 Evaluation of Proposed Change Consistent throughout these Quality Standards is the requirement to have procedure changes reviewed by authorized and qualified individuals. Other requirements such as having the Plant Safety Review Committee (i.e., PORC) review changes that may constitute an unreviewed safety question have been modified by changes to 10 CFR 50.59 with the concept of an "unreviewed safety question" being replaced by the determination that a change can be made without prior NRC approval. The criteria that determine if a change can be made focus on conformance to previously established and/or approved acceptance criteria. The current PORC charter is to review those changes that could impact nuclear safety or involve a full 10 CFR 50.59 evaluation. The requirement for the PORC to review all new or revised (other than editorial or administrative) RG 1.33 recommended administrative procedures prior to implementation, regardless of the lack of nuclear safety implications, is not based on any of the ANSI Quality Assurance standards to which EGC and AmerGen are committed.
Section ANS/ANSI 3.2 - 1988 (Applicable to Braidwood, B ron, Dresden, LaSalle and Quad Cities Stations 4.3.1 The following subjects shall be reported to and reviewed by the independent review and audit group:
4.3.1 Evaluations of proposed changes to procedures, equipment, or systems completed under the provisions of § 50.59 (b), Part 50, Title 10, Code of Federal Regulations to verify that such changes do not constitute unreviewed safety questions.
4.3.3 Proposed changes in procedures, equipment, or systems which may involve an unreviewed safety question as defined in § 50.59 (c), Part 50, Title 10, Code of Federal Regulations; or changes which are referred by the operating organization 5.2.15 5.1 [In part] The administrative controls and quality assurance program shall control and coordinate the approval, issuance, and revision of documents which prescribe all activities affecting quality. Such documents include those which describe organizational interfaces, or which prescribe activities affecting structures, systems, or components. These documents also include administrative procedures.... Documents, including revisions or changes, shall be reviewed for adequacy by appropriately qualified personnel.... Documents shall be approved for release b authorized personnel...
Section ANSI N18.7 - 1976 A : #licable to Clinton, Limerick, Oyster Creek and TNII Stations referred to the independent reviewers by the onsite operating organization by the onsite operating organization or by functional organizational units within the owner organization.
5.2.15 5.2.15 [In part]...measures shall assure that documents, including revisions or changes, are reviewed for adequacy by appropriately qualified personnel and approved for release b authorized personnel...
5.3
[In part] Procedures shall be prepared and approved prior to implementation as required by 4.3 [Independent Review Program] and 5.2.15 [Review, Approval and Control of Procedures].
In addition to the reviews required by EGC and AmerGen administrative controls, Appendix B, "Audit Frequency," of the EGC and AmerGen QATR requires that a Nuclear Oversight Department audit be conducted on procedure adherence at least every 24 months. The QATR also requires a review of randomly selected procedures to ensure that the programmatic control processes used to assure that procedures are technically and administratively correct prior to use are resulting in timely and accurate procedure revisions. This review is performed every 24 months.
In summary, the mandatory PORC review of all new or revised EGC and AmerGen RG 1.33 recommended administrative procedures is an unnecessary burden on PORC. Limiting the PORC review to all new or revised procedures that impact nuclear safety is consistent with the Quality Assurance requirements (i.e., ANSI) that form the basis of the QATR by maintaining an independent review of these procedures. Approval of this change would allow the PORC the flexibility to determine which procedures the committee should review based on the procedure's importance and impact on nuclear safety.
Precedent ATTACHMENT 1 Evaluation of Proposed Change The NRC approved this change for Entergy Operations, Inc. in 2001.
Reference Letter from J. L. Minns (NRC) to M. A. Krupa, "Arkansas Nuclear One, Units 1 and 2; Grand Gulf Nuclear Station, Unit 1 ; River Bend Station; and Waterford Steam Electric Station, Unit 3 -
Revision to the Quality Assurance Program Manual" dated December 5, 2001 (NRC Agencywide Documents Access and Management System (ADAMS) Accession No.
ATTACHMENT 2 Markup of Proposed Quality Assurance Topical Report Change
INSTRUCTIONS, PROCEDURES, AND CHAPTER 5 DRAWINGS These documents shall include or reference appropriate quantitative or qualitative acceptance criteria for determining that prescribed activities have been satisfactorily accomplished.
The procedures will be independently reviewed and evaluated by other involved company organizations with interface responsibilities and the comments forwarded to the issuing department.
2.3.
Procedures and Programs Review and approval of site procedures are performed in accordance with technical specification requirements as delineated in the Technical Review or Station Qualified Review (SQR) programs.
2.3.1.
Technical Review and Control 1.
Procedures required by a station's Technical Specifications and other procedures which affect nuclear safety, as determined by the manager responsible for station operation, and changes thereto, other than editorial or typographical changes, shall be reviewed as follows prior to implementation, except as noted in item 5 (below).
Each procedure or procedure change shall be independently reviewed by a qualified individual knowledgeable in the area affected other than the individual who prepared the procedure or procedure change. This review shall include a determination of whether or not additional cross-disciplinary reviews are necessary.
If deemed necessary, the reviews shall be performed by the qualified review personnel of the appropriate discipline(s).
dirsappWal based OR th8iF Fey; Changes to the approved fire protection program may be made without prior PORC approval provided that the changes would not adversely affect the ability to achieve and maintain safe shutdown in the event of a fire, and specific features of the approved program may be altered provided such changes do not otherwise involve a change to the Operating License or technical specifications, or require an exemption.
Reviews of procedures or changes to procedures, that describe the means for controlling or operating structure, systems, and/or components as described in the UFSAR, will include a review to determine if NRC review and approval is necessary prior to the implementation of the procedure activity. This review is based on the review of a written 10CFR50.59/72.48 review and evaluation prepared by qualified individual(s), or documentation that a Page 2 of 4 Revision 80