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| * The accrediting body is either National Voluntary Laboratory Accreditation Program (NVLAP) or an accrediting body recognized by NVLAP through an International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA). | | * The accrediting body is either National Voluntary Laboratory Accreditation Program (NVLAP) or an accrediting body recognized by NVLAP through an International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA). |
| In accordance with 10 CFR 50.54(a)(3)(ii), a licensee may make a change to a previously accepted QAP description included or referenced in the Safety Analysis Report, without prior NRC approval, if the change uses a quality assurance alternative or exception approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensees facility. PSEGs letter dated June 20, 2007, stated that the change regarding calibration services was based on invoking 10 CFR 50.54(a)(3)(ii) as a quality assurance alternative approved by an NRC safety evaluation. Specifically, PSEG cited an NRC safety evaluation dated September 28, 2005, associated with a QAP change submitted by Arizona Public Service (APS). | | In accordance with 10 CFR 50.54(a)(3)(ii), a licensee may make a change to a previously accepted QAP description included or referenced in the Safety Analysis Report, without prior NRC approval, if the change uses a quality assurance alternative or exception approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensees facility. PSEGs letter dated June 20, 2007, stated that the change regarding calibration services was based on invoking 10 CFR 50.54(a)(3)(ii) as a quality assurance alternative approved by an NRC safety evaluation. Specifically, PSEG cited an NRC safety evaluation dated September 28, 2005, associated with a QAP change submitted by Arizona Public Service (APS). |
| The APS QAP change, for Palo Verde Nuclear Generating Station (PVNGS), was submitted to the NRC by letter dated September 5, 2004 (ADAMS Accession No. | | The APS QAP change, for Palo Verde Nuclear Generating Station (PVNGS), was submitted to the NRC by letter dated September 5, 2004 (ADAMS Accession No. ML042590501). In its letter, APS requested that the NRC approve a change to the PVNGS QAP that would provide for acceptance of accreditation of commercial-grade calibration services by a nationally recognized accrediting body (AB), using procedures consistent with international standards and guidelines. The NRC found APS proposed change acceptable with clarifying bases as documented in the staffs safety evaluation dated September 28, 2005 (ADAMS Accession No. ML052710224). The staffs approval of APSs proposed change was limited to NVLAP and the American Association for Laboratory Accreditation (A2LA), which were the two US-based signatories to the ILAC MRA at the time. |
| ML042590501). In its letter, APS requested that the NRC approve a change to the PVNGS QAP that would provide for acceptance of accreditation of commercial-grade calibration services by a nationally recognized accrediting body (AB), using procedures consistent with international standards and guidelines. The NRC found APS proposed change acceptable with clarifying bases as documented in the staffs safety evaluation dated September 28, 2005 (ADAMS Accession No. ML052710224). The staffs approval of APSs proposed change was limited to NVLAP and the American Association for Laboratory Accreditation (A2LA), which were the two US-based signatories to the ILAC MRA at the time. | |
| Although PSEGs justification on page 5 of its letter dated June 20, 2007, acknowledges that the basis for the NRCs approval of the APS request was limited to NVLAP and A2LA, the wording in the QATR (i.e., bullet shown above) could be interpreted to recognize all ABs through the ILAC MRA. Please clarify the intent of this change.}} | | Although PSEGs justification on page 5 of its letter dated June 20, 2007, acknowledges that the basis for the NRCs approval of the APS request was limited to NVLAP and A2LA, the wording in the QATR (i.e., bullet shown above) could be interpreted to recognize all ABs through the ILAC MRA. Please clarify the intent of this change.}} |
Letter Sequence Draft RAI |
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MONTHYEARML0813405292008-05-13013 May 2008 and Salem Nuclear Generating Station, Unit Nos. 1 and 2, Draft Request for Additional Information, Changes to Quality Assurance Program Project stage: Draft RAI 2008-05-13
[Table View] |
and Salem Nuclear Generating Station, Unit Nos. 1 and 2, Draft Request for Additional Information, Changes to Quality Assurance Program (TAC Nos. MD5863, MD5864, and MD5865)ML081340529 |
Person / Time |
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Site: |
Salem, Hope Creek ![PSEG icon.png](/w/images/c/cc/PSEG_icon.png) |
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Issue date: |
05/13/2008 |
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From: |
Richard Ennis NRC/NRR/ADRO/DORL/LPLI-2 |
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To: |
Chernoff H NRC/NRR/ADRO/DORL/LPLI-2 |
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Ennis R, NRR/DORL, 415-1420 |
References |
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TAC MD5863, TAC MD5864, TAC MD5865 |
Download: ML081340529 (4) |
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Category:Memoranda
MONTHYEARML23276A6242023-10-12012 October 2023 Summary of the Closed Meeting with PSEG Nuclear LLC and Westinghouse Electric Company to Discuss Cobalt-60 Production at Salem Nuclear Generating Station ML21277A2472021-11-0505 November 2021 Notification of Significant Licensing Action - Proposed Issuance of Order Approving the Transfer of Licenses for Which a Hearing Has Been Requested - Exelon Generation Company, LLC; Et. Al ML20150B6152020-11-23023 November 2020 Memo to File: Environmental Assessment and Finding of No Significant Impact and NRC Financial Analysis for Exelon Generation Co., LLC Decommissioning Funding Plan Submitted in Accordance with 10 CFR 72.30(b) and (C) for Salem ISFSI ML18269A2522018-10-12012 October 2018 F&O Closure Observation Hope Creek Fire PRA ML17023A1452017-01-23023 January 2017 Summary of Teleconference with PSEG Regarding Hope Creek HPCI ML16259A2042016-09-20020 September 2016 Hope Creek Generating Station - Safety Evaluation - Request to revise technical specifications - safety limit minimum critical power ratio.(TAC NO. MF7793) ML16088A2042016-03-28028 March 2016 Memo T Bowers from s Ruffin, Technical Assistance Requests - Review 2015 Tri-Annual Decommissioning Funding Plans for Multiple Independent Spent Fuel Storage Installations W/ Encl 2 (Template) ML16088A2052016-03-28028 March 2016 Enclosure 1 - (72.30 DFP Reviews to Be Completed 2015) - Memo T Bowers from s Ruffin, Technial Assistance Requests - Review 2015 Tri-Annual Decommissioning Funding Plans for Multiple Independent Spent Fuel Storage Installations ML15075A2602015-03-24024 March 2015 Request for Additional Information Spring 2014 Steam Generator Tube Inspections ML15015A6772015-01-16016 January 2015 Forthcoming Closed Meeting with PSEG Nuclear, LLC, Regarding a Planned Digital Instrumentation and Controls License Amendment Request Associated with Hope Creek Generating Station, Unit 1 ML14295A3342014-10-21021 October 2014 Memo_Transmittal of NUREG-XXXX, Development of a Statistical Testing Approach for Quantifying Software Reliability and Application to an Example System. ML14167A1592014-09-0202 September 2014 Summary of Category 1 Public Meeting with Salem Nuclear Generating Station, Units 1 and 2 to Discuss Seismic Hazard Reevaluations Associated with Implementation of Japan Lessons-Learned Near-Term Task Force Recommendation 2.1 Seismic IR 05000272/20132022013-12-20020 December 2013 IR 05000272-13-202, 05000311-13-202 & 05000354-13-201, September 9-13, 2013, Salem Nuclear Generating Station and Hope Creek Generating Station - Cover Letter ML13309A0802013-12-11011 December 2013 Memorandum to File: Transcript for 10 CFR 2.206 Petition from Beyond Nuclear (Et Al) Regarding General Electric Mark I and Mark II Boiling-Water Reactors ML13233A1132013-08-22022 August 2013 Notice of Forthcoming Meeting with PSEG Nuclear, LLC Regarding a Planned Digital Instrumentation and Controls License Amendment Request Associated with Hope Creek Generating Station, Unit 1 ML13154A4952013-06-0404 June 2013 Rai'S Following Ifib Analysis of Pseg'S 2013 Decommissioning Funding Status Report for Hope Creek Generating Station ML12314A1572012-11-14014 November 2012 Notice of Forthcoming Meeting with PSEG Nuclear, LLC, Regarding Final Supplemental Reponse to Generic Letter 2004-02 for Salem Generating Station, Units 1 and 2 ML13196A2202012-06-0606 June 2012 Memo from B. Balsam, NRR and D. Logan, NRR to J. Susco, NRR on Summary of Section 7 Consultation Activities Related to the National Marine Fisheries Service'S Final Rule to List the Atlantic Sturgeon ML1209002372012-03-29029 March 2012 and Salem Nuclear Generating Station, Unit Nos. 1 and 2, Draft Request for Additional Information ML1200301892012-01-0303 January 2012 Draft Request for Additional Information ML1129901422011-10-25025 October 2011 Draft Request for Additional Information ML1129700652011-10-21021 October 2011 Summary of PSEG Drop-in Visit, 9-28-2011 and Slides ML11250A1712011-09-14014 September 2011 Notice of Forthcoming Meeting with Petitioner Requesting Action Under 10 CFR 2.206 Regarding Immediate Suspension of the Operating Licenses of General Electric (GE) Mark 1 Boiling Water Reactors (Bwrs) ML1123511452011-08-24024 August 2011 Forthcoming Meeting with PSEG Nuclear LLC (PSEG) to Discuss Proposed License Amendment Regarding Reactor Coolant System Activity for Salem Nuclear Generating Station, Unit Nos. 1 and 2 ML1118605722011-07-0505 July 2011 Draft Request for Additional Information ML11181A1772011-06-30030 June 2011 June 29, 2011 Summary of Public Meeting to Discuss Observations and Lessons Learned During the Hope Creek Nuclear Generating Station Application of the Nuclear Energy Institute'S Nuclear Safety Culture Assessment Process ML11137A0762011-06-0202 June 2011 Summary of Telephone Conference Call Held on May 11, 2011, Between the U.S. Nuclear Regulatory Commission and PSEG Nuclear, LLC, Concerning the Hope Creek License Condition for the Drywell ML11130A0062011-05-26026 May 2011 Summary of Telephone Conference Call Held on May 5, 2011, Between the U.S. Nuclear Regulatory Commission and PSEG Nuclear, LLC, Concerning Questions Pertaining to the Salem Nuclear Generating Station, Units 1 and 2, License Renewal Applicat ML11126A0962011-05-12012 May 2011 Notice of Meeting with Petitioner Requesting Action Under 10CFR2.206 Regarding Immediate Suspension of Operating Licenses of General Electric Mark 1 Boiling Water Reactors ML11105A0372011-05-0404 May 2011 Summary of Telephone Conference Call Held on March 25, 2011, Between the U.S. Nuclear Regulatory Commission and PSEG Nuclear, LLC, Concerning Findings on the Hope Creek Generating Station Gas Turbine ML1111601502011-04-25025 April 2011 Draft Request for Additional Information ML1111108862011-04-20020 April 2011 and Salem Nuclear Generating Station, Unit Nos. 1 and 2, Draft Request for Additional Information ML1110911182011-04-19019 April 2011 Draft Request for Additional Information ML1107606042011-04-0505 April 2011 January 25, 2011, Summary of Telephone Conference Call Held Btw the USNRC and PSEG Nuclear, LLC, Concerning Information on Buried Piping Inspections at the Salem Nuclear Generating Station, Units 1 and 2, License Renewal Application LR-N11-0087, 2011 Annual Report - Guarantees of Payment of Deferred Premiums2011-03-31031 March 2011 2011 Annual Report - Guarantees of Payment of Deferred Premiums ML1106801152011-03-0808 March 2011 Draft Request for Additional Information ML1106302902011-03-0303 March 2011 Draft Request for Additional Information ML1106005572011-03-0101 March 2011 Minutes of the Meeting of the Subcommittee on Plant License Renewal Regarding Hope Creek Generating Plant on November 3, 2010, in Rockville, Maryland ML1100501452011-02-0909 February 2011 Summary of Telephone Conference Call Held on December 8, 2010, Between the U.S. Nuclear Regulatory Commission and PSEG Nuclear, LLC, Concerning Draft Response to Request for Additional Information Pertaining to the Salem Nuclear Generating ML1035005662011-02-0909 February 2011 Summary of Telephone Conference Call Held on 11/18/10 Between the USNRC and PSEG Nuclear, LLC, Concerning Draft Response to the Salem Nuclear Generating Station, Units 1 and 2, Request for Additional Information, and Concerning NRC Open Ite ML1036307352011-02-0909 February 2011 Summary of Telephone Conference Call Held on September 16, 2010, Between the U.S. Nuclear Regulatory Commission and PSEG Nuclear LLC, Concerning Questions Pertaining to the Salem Nuclear Generating Station, Units 1 & 2, License Renewal App ML1034909292011-02-0909 February 2011 Summary of Telephone Conference Call Held on November 18, 2010, Between the U.S. Nuclear Regulatory Commission and PSEG Nuclear, LLC, Concerning Findings on the Hope Creek Generating Station Recent Outage ML1103901752011-02-0707 February 2011 Draft Request for Additional Information ML1035606562011-01-26026 January 2011 12/13/10 Summary of Telephone Conference Call Held on 12/13/10 Btw the USNRC and PSEG Nuclear, LLC, Concerning Draft Requests for Additional Information Pertaining to the Salem Nuclear Generating Station, Units 1 and 2, License Renewal Appl ML1100501562011-01-26026 January 2011 Summary of Telephone Conference Call Held on September 27, 2010, Between the U.S. Nuclear Regulatory Commission and PSEG Nuclear, LLC, Concerning Questions Pertaining to the Salem Nuclear Generating Station, Units 1 and 2 ML1101901352011-01-18018 January 2011 Draft Request for Additional Information ML1035401842011-01-0707 January 2011 10/08/10 Summary of Telephone Conference Call Held Btw the USNRC and PSEG Nuclear, LLC, Concerning Questions Pertaining to the Salem Nuclear Generating Station, Units 1 and 2, License Renewal Application ML1036304612010-12-28028 December 2010 Draft Request for Additional Information ML1035404812010-12-20020 December 2010 Draft Request for Additional Information ML1030103862010-11-0505 November 2010 Advisory Committee on Reactor Safeguards Review of the Salem Nuclear Generating Station, Units 1 and 2, License Renewal Application - Safety Evaluation Report with Open Items 2023-10-12
[Table view] Category:Request for Additional Information (RAI)
MONTHYEARML22333A9022022-11-29029 November 2022 NRR E-mail Capture - Final Iolb RAI - Salem 1 and 2 LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG ML22318A1062022-11-14014 November 2022 Information Request for Quadrennial Baseline Comprehensive Engineering Team Inspection; Notification to Perform Inspection 05000272/2023011 and 05000311/2023011 ML22290A2202022-10-17017 October 2022 NRR E-mail Capture - Final RAI - Salem 1 and 2 LAR to Revise TS to Extend Allowed Outage Time for Inoperable EDG ML22055A0702022-02-22022 February 2022 NRR E-mail Capture - Final RAI - Salem 1-Relief Request Associated with Fourth Inservice Inspection (ISI) Interval Limited Examinations (L-2021-LLR-0085) ML22006A3212022-01-0606 January 2022 NRR E-mail Capture - Final RAI - Hope Creek - Revise TS Limits for Ultimate Heat Sink ML21300A0222021-10-27027 October 2021 Notification of Conduct of a Fire Protection Team Inspection ML21256A1902021-09-10010 September 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21144A2132021-05-24024 May 2021 NRR E-mail Capture - Exelon Generation Company, LLC - Request for Additional Information Regarding License Transfer Application ML21068A4142021-03-0909 March 2021 NRR E-mail Capture - Final RAI for Salem Unit 1 LAR to Revise and Relocate Pressurizer Overpressure Protection System Limits to Pressure and Temperature Limits Report ML21041A3972021-02-18018 February 2021 Request for Additional Information Revise Low Pressure Safety Limit to Address General Electric Part-21 Safety Communications (Non-Proprietary) ML21043A1442021-02-11011 February 2021 NRR E-mail Capture - Salem - Final RAI Alternative for Examination of ASME Section XI, Category B-B, Item Number B2.11and B2.12 (L-2020-LRR-0103) ML21021A2592021-01-21021 January 2021 NRR E-mail Capture - Final RAI - Salem 1 - Steam Generator Tube Inspection Report ML20295A4922020-10-21021 October 2020 NRR E-mail Capture - Hope Creek - Final RAI Revise ECCS TS with Respect to HPCI System Inoperability (L-2020-LLA-0131) ML20281A5172020-10-13013 October 2020 Notification of Conduct of a Fire Protection Team Inspection ML18267A1712018-09-21021 September 2018 NRR E-mail Capture - Final RAI from PRA Branch: Revise Technical Specifications to Increase Inverter AOT Extension (L-2018-LLA-0140) ML18264A0122018-09-20020 September 2018 NRR E-mail Capture - Final RAI from I&C Branch: Revise Technical Specifications to Increase Inverter AOT Extension (L-2018-LLA-0140) ML18263A1442018-09-12012 September 2018 NRR E-mail Capture - Final RAI from Apla: Revise Technical Specifications to Increase Inverter AOT Extension (L-2018-LLA-0101) ML18250A3132018-09-0606 September 2018 NRR E-mail Capture - Final RAI: Revise Technical Specifications to Increase Inverter AOT Extension (L-2018-LLA-0140) ML18250A3142018-09-0606 September 2018 NRR E-mail Capture - Final RAI: Revise Technical Specifications to Increase Inverter AOT Extension (L-2018-LLA-0101) ML18171A3212018-06-20020 June 2018 NRR E-mail Capture - Final RAI: Revise Technical Specifications to Adopt TSTF-411 and 418 (L-2017-LLA-0442) ML18150A6912018-05-30030 May 2018 NRR E-mail Capture - Hope Creek - Final RAI Revise TS to Adopt TSTF-542 ML18120A2482018-04-27027 April 2018 Information Request for the Cyber-Security Inspection, Notification to Perform Inspection 05000354/2018403 ML18094B0832018-04-0505 April 2018 Enclosurequest for Additional Information (Letter to P. Duke RAI Regarding Entergy Operations, Inc.'S Decommissioning Funding Plan Update for Salem and Hope Creek, and Peach Bottom ISFSIs Docket Nos. 72-48 and 72-29) ML18067A1482018-03-0808 March 2018 Enclosurequest for Additional Information (Letter to P. R. Simpson Request for Additional Information Regarding Exelon Generating Company, Llc'S Decommissioning Funding Plan Update for Independent Spent Fuel Storage Installation) ML17349A0812017-12-14014 December 2017 NRR E-mail Capture - Final Request for Additional Information for Reactor Systems Branch (Srxb) - Hope Creek Mur ML17348A9972017-12-14014 December 2017 NRR E-mail Capture - Final Request for Additional Information for Steam Dryer Analysis with the Hope Creek Measurement Uncertainty Recapture Uprate Request (L-2017-LLS-002) ML17348A6242017-12-14014 December 2017 NRR E-mail Capture - Final Request for Additional Information for Human Factors Associated with the Hope Creek Measurement Uncertainty Recapture Uprate Request (L-2017-LLS-002) ML17331A0072017-11-21021 November 2017 E-mail Regarding Final Eicb Request for Additional Information - Hope Creek Power Uprate ML17348A6282017-11-21021 November 2017 NRR E-mail Capture - Draft Request for Additional Information for Steam Dryer Analysis with the Hope Creek Measurement Uncertainty Recapture Uprate Request (L-2017-LLS-002) ML17324A2602017-11-17017 November 2017 NRR E-mail Capture - Final Request for Additional Information - Hope Creek Mur Electrical Instrumentation and Controls ML17320A2152017-11-16016 November 2017 NRR E-mail Capture - Hope Creek Measurement Uncertainty Recapture Application Review - Electrical Engineering (Eeob) Request for Additional Information (L-2017-LLS-0002) ML17290B0132017-10-17017 October 2017 NRR E-mail Capture - Hope Creek Mur Request for Additional Information for Apla and Snpb ML17222A1652017-08-10010 August 2017 NRR E-mail Capture - Hope Creek: Final Request for Information, Pressure-Temperature Limit Report Request (MF9502) ML17212B1152017-07-31031 July 2017 Request for Additional Information - Salem Units 1 and 2 - Containment Fan Coil Unit Allowed Outage Time Amendment Request (CACs MF9364 and MF9365) ML17199A1122017-07-18018 July 2017 Request for Additional Information - Salem Units 1 and 2 - Accident Monitoring Instrumentation License Amendment Request (CAC Nos. MF8859 & MF8860) ML17192A1672017-07-11011 July 2017 Request for Additional Information - Salem Unit 1 - Steam Generator Tube Inspection Report ML17181A1352017-06-29029 June 2017 NRR E-mail Capture - Request for Additional Information Related to Hope Creek and Salem Emergency Action Level Scheme Change License Amendment Request (MF9268/69/70) ML17164A4062017-06-13013 June 2017 NRR E-mail Capture - Hope Creek - Final Request for Additional Information Concerning ILRT (MF8462) ML17115A4032017-05-0909 May 2017 Request for Additional Information Regarding Relief Request SC-14R-171 - Use of Code Cases N-695-1 and N-696-1 ML17027A3282017-02-27027 February 2017 Request for Additional Information Regarding License Amendment Request to Permanently Extend Type a and Type C Leak Rate Test Frequencies ML16321A4642016-11-21021 November 2016 and Salem Nuclear Generating Station, Unit Nos. 1 and 2 - Request for Additional Information Regarding License Amendment Request to Remove Certain Training Requirements ML16277A5142016-11-0303 November 2016 Request for Additional Information Regarding License Amendment Request to Permit Operability of Low Pressure Coolant Injection While Aligned to Shutdown Cooling ML16271A2052016-11-0202 November 2016 Request for Additional Information Regarding Request to Delete Technical Specifications Action Statement 3.4.2.1.b Associated with Stuck Open Safety/Relief Valves ML16231A4272016-08-24024 August 2016 Request for Additional Information Regarding Relief Request VR-02, Associated with the Fourth 10-Year Inservice Test Interval ML16217A4302016-08-17017 August 2016 Request for Additional Information Regarding Digital Power Range Neutron Monitoring System Upgrade ML16218A0052016-08-11011 August 2016 Request for Additional Information Concerning Request for an Extension to Enforcement Guidance Memorandum 12-001 ML16195A4492016-07-14014 July 2016 Request for Additional Information Regarding Chilled Water System Modifications ML16188A4152016-07-0707 July 2016 Request for Additional Information Aging Management Program Plan for Reactor Vessel Internals ML16007A1742016-05-31031 May 2016 Request for Additional Information Regarding Review of Post-EPU Steam Dryer Stress Calculation Acoustic Circuit Model Software Error ML16089A0792016-05-0505 May 2016 Request for Additional Information Regarding Relief Requests GR-01, PR-01, PR-02, VR-01, and VR-02, Associated with the Fourth 10-Year Inservice Test Interval 2022-02-22
[Table view] |
Text
May 13, 2008 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Richard B. Ennis, Senior Project Manager /ra/
Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
HOPE CREEK GENERATING STATION AND SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MD5863, MD5864, AND MD5865)
The attached draft request for information (RAI) was transmitted on May 13, 2008, to Mr. Jeff Keenan of PSEG Nuclear LLC (the licensee). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensee=s submittals dated June 20, 2007, August 31, 2007, and October 17, 2007, which provided changes to the Quality Assurance Program (QAP) for Hope Creek Generating Station and Salem Nuclear Generating Station, Unit Nos. 1 and 2.
This memorandum and the attachment do not convey or represent an NRC staff position regarding the licensees submittals.
Docket Nos. 50-354, 50-272 and 50-311
Attachment:
Draft RAI
May 13, 2008 MEMORANDUM TO: Harold K. Chernoff, Chief Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Richard B. Ennis, Senior Project Manager /ra/
Plant Licensing Branch I-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
SUBJECT:
HOPE CREEK GENERATING STATION AND SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2, DRAFT REQUEST FOR ADDITIONAL INFORMATION (TAC NOS. MD5863, MD5864, AND MD5865)
The attached draft request for information (RAI) was transmitted on May 13, 2008, to Mr. Jeff Keenan of PSEG Nuclear LLC (the licensee). This information was transmitted to facilitate an upcoming conference call in order to clarify the licensee=s submittals dated June 20, 2007, August 31, 2007, and October 17, 2007, which provided changes to the Quality Assurance Program (QAP) for Hope Creek Generating Station and Salem Nuclear Generating Station, Unit Nos. 1 and 2.
This memorandum and the attachment do not convey or represent an NRC staff position regarding the licensee's submittals.
Docket Nos. 50-354, 50-272 and 50-311
Attachment:
Draft RAI DISTRIBUTION PUBLIC RidsNrrDorlLpl1-2 DThatcher, DE/EQVB PDI-2 Reading RidsNrrPMREnnis RidsNrrDorlDpr VHall, DE/EQVB ACCESSION NO.: ML081340529 OFFICE PDI-2/PM NAME REnnis DATE 5/13/2008 OFFICIAL RECORD COPY
DRAFT REQUEST FOR ADDITIONAL INFORMATION REGARDING CHANGES TO THE QUALITY ASSURANCE PROGRAM FOR HOPE CREEK GENERATING STATION AND SALEM NUCLEAR GENERATING STATION, UNIT NOS. 1 AND 2 DOCKET NOS. 50-354, 50-272 AND 50-311 By letters dated June 20, 2007, August 31, 2007, and October 17, 2007 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML071770285, ML072560712, and ML072980678, respectively), PSEG Nuclear, LLC (PSEG or the licensee) submitted changes to the Quality Assurance Program (QAP) for Hope Creek Generating Station (Hope Creek) and Salem Nuclear Generating Station (Salem), Unit Nos. 1 and 2. The Nuclear Regulatory Commission (NRC) staff has reviewed the changes to the QAP and would like to discuss the following to clarify the submittals.
- 1) As discussed in the licensees letter dated October 17, 2007, PSEG has developed Revision 78 of the Salem/Hope Creek (SHC) Quality Assurance Topical Report (QATR) which governs the QAP. This version of the SHC QATR, NO-AA-10, replaces the previous version, NO-SH-10, which was submitted to the NRC in PSEGs letter dated June 20, 2007. The document number for the QATR was changed for records management purposes since the previous planned merger with Exelon is no longer planned.
Each of the licensees letters dated June 20, 2007, August 31, 2007, and October 17, 2007, indicated that the changes to the QATR did not involve any reductions in commitments and, as such, did not require prior NRC approval in accordance with the requirements in Section 50.54(a)(3) of Title 10 of the Code of Federal Regulations (10 CFR).
Pages 3 through 5 of PSEGs letter dated June 20, 2007, provided the licensees evaluation of changes made to the QATR, without prior NRC approval, in accordance with the provisions to 10 CFR 50.54(a)(3)(i) and 10 CFR 50.54(a)(3)(ii). One of these changes pertains to QATR Chapter 7, Section 2.4.8, Acceptance of Calibration Services. This change to the QATR states, in part, that:
For suppliers of commercial grade calibration services with accreditation by a nationally recognized accrediting body, a documented review of the suppliers accreditation by the purchaser may be used in lieu of inspections or test following delivery or in-process surveillances during performances of this service. This review shall include, at a minimum, all of the following:
Attachment
- The accrediting body is either National Voluntary Laboratory Accreditation Program (NVLAP) or an accrediting body recognized by NVLAP through an International Laboratory Accreditation Cooperation (ILAC) Mutual Recognition Arrangement (MRA).
In accordance with 10 CFR 50.54(a)(3)(ii), a licensee may make a change to a previously accepted QAP description included or referenced in the Safety Analysis Report, without prior NRC approval, if the change uses a quality assurance alternative or exception approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensees facility. PSEGs letter dated June 20, 2007, stated that the change regarding calibration services was based on invoking 10 CFR 50.54(a)(3)(ii) as a quality assurance alternative approved by an NRC safety evaluation. Specifically, PSEG cited an NRC safety evaluation dated September 28, 2005, associated with a QAP change submitted by Arizona Public Service (APS).
The APS QAP change, for Palo Verde Nuclear Generating Station (PVNGS), was submitted to the NRC by letter dated September 5, 2004 (ADAMS Accession No. ML042590501). In its letter, APS requested that the NRC approve a change to the PVNGS QAP that would provide for acceptance of accreditation of commercial-grade calibration services by a nationally recognized accrediting body (AB), using procedures consistent with international standards and guidelines. The NRC found APS proposed change acceptable with clarifying bases as documented in the staffs safety evaluation dated September 28, 2005 (ADAMS Accession No. ML052710224). The staffs approval of APSs proposed change was limited to NVLAP and the American Association for Laboratory Accreditation (A2LA), which were the two US-based signatories to the ILAC MRA at the time.
Although PSEGs justification on page 5 of its letter dated June 20, 2007, acknowledges that the basis for the NRCs approval of the APS request was limited to NVLAP and A2LA, the wording in the QATR (i.e., bullet shown above) could be interpreted to recognize all ABs through the ILAC MRA. Please clarify the intent of this change.