ML18054B359

Slide: NRC Pre-Submittal Meeting for Exelon Fleet LAR to Relocate TS Unit Staff Qualification ANSI Requirements to the QATR, February 27, 2018, Profile Info: Submitted by Frank Mascitelli

ML18054B359
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Oyster Creek, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, LaSalle, 07201036, 07000650
Issue date:	02/27/2018
From:	Exelon Generation Co, Exelon Nuclear
To:	Purnell B A Plant Licensing Branch III
Purnell B A, NRR/DORL,/LPLIII, 415-1380
References
Download: ML18054B359 (9)

Text

NRC Pre-Submittal Meeting for Exelon Fleet LAR to Relocate the TS Unit Staff Qualification ANSI Requirements to the Exelon QATR February 27, 2018 Purpose for Discussion*Discuss evolution of current proposed Fleet License Amendment Request (LAR)*Provide overview of current LAR

• Discuss 6-month turnaround request

• Discuss the QATR proposed Mark-ups

• Adoption of ANSI/ANS 3.1-2014 via RG 1.8 Rev 4 QATR revision 2

Opening Remarks*Executive Sponsor for LAR-Julie Sickle*Chair of the ANS working level committee that developed ANSI/ANS-3.1-2014 3

Evolution*11/14ANSI/ANS-3.1-2014 approved*3/22/16Initial Exelon Pre-submittal meeting

• 4/6/16Pre-Submittal NRC meeting summary

• 3/27/17NRC approves TVA LAR to relocate TS ANSI requirements to TVA QAP*Fall/17Exelon decides to change original LAR scope to: Relocate the TS ANSI requirements to the

Exelon Quality Assurance Topical Report*Feb/18Fleet LAR internally reviewed and approved

• 2/27/18Pre-submittal meeting

• 3/1/18Submit Fleet LAR to NRC 4

LAR Overview

• Current Technical Specification Requirements for TS 5/6.3.1(Unit/Plant/Facility Staff Qualifications):ANS-3.1/N18.1-1971*Braidwood, Byron, Calvert Cliffs, Dresden, Ginna, LaSalle, Peach Bottom, Nine Mile Point Unit 1, Quad

Cities ANSI/ANS-3.1-1978*Clinton, Limerick, FitzPatrick, Nine Mile Point Unit 2, Three Mile Island Unit 1

• Proposed Technical Specification Requirements:"Each member of the unit [facility or plant] staff shall meet or exceed the minimum qualifications referenced for comparable positions as specified in the Exelon Quality

Assurance Topical Report" 5

LAR Overview*TS verbatim wording relocated to QATR*Minor exceptions for FitzPatrick

• Oyster Creek not included in Fleet Submittal

• Complies with the requirements of AL 95-06 (Relocation of Technical Specification Administrative Controls Related to

Quality Assurance)*These ANSI Standards are considered quality assurance controls*Consistent with TVA precedence for Browns Ferry and Sequoyah (ML16105A287) 6 6-Month Turnaround*The 6-month turnaround will position Exelon to more efficiently adopt and implement the ANSI-2014 standard upon issuance of

RG 1.8 Rev 4Prevents an additional year delay in Exelon achieving a common fleet standard and alignment for staff qualifications if no LAR is needed at the time RG 1.8 Rev 4 is issued*In 3/22/16 pre-submittal meeting NRC advised not to submit until NRC vetted the ANSI-2014 standard via the RG 1.8 Rev 4 process*In 3/22/16 meeting NRC had anticipated that the draft RG 1.8 Rev 4 would be noticed for public comments by end of May 2016*Draft RG 1.8 Rev 4 was noticed for public comments on 2/12/18

• Exelon has had a project in place for 3 years to adopt the ANSI-2014 standard 7

• TS wording relocated verbatim to QATR*FitzPatrick minor exceptions:Referenced "Entergy" QAP exceptionsTS 5.3.1 is already in most recent QATR revisionTS 5.2.2.f requires STAs at FitzPatrickto comply to the ANSI 1993 standard*Mark-ups throughout QATR Appendix C (Codes, Standards and Guides)*Proposed revisions are consistent with existing format for taking exceptions to RG compliance on a station by station

basis 8 QATR-Mark-ups RG 1.8 Rev 4 QATR revision*Exelon will implement the approved TS amendments within 60 days*No training standards are changed; only change management is to issue revised TS and revise the QATR

as proposed*After ANSI/ANS-3.1-2014 is endorsed via approved RG 1.8 Rev 4, Exelon will again revise the QATR via 10 CFR 50.54(a) evaluation process to adopt it*NRC exceptions to the ANSI/ANS-3.1-2014 that will be in the approved RG 1.8 Rev 4 will be carefully reviewed*It is expected that the subsequent 10 CFR 50.54(a) evaluation will not be a reduction in commitment 9