RS-20-023, Additional Information Regarding Request for Approval of Change to Exelon Generation Company, LLC, Quality Assurance Topical Report

Additional Information Regarding Request for Approval of Change to Exelon Generation Company, LLC, Quality Assurance Topical Report

ML20055G249
Person / Time
Site:	Calvert Cliffs, Dresden, Peach Bottom, Nine Mile Point, Byron, Braidwood, Limerick, Ginna, Clinton, Quad Cities, FitzPatrick, LaSalle, 07201036, 07200072
Issue date:	02/24/2020
From:	Simpson P Exelon Generation Co
To:	Document Control Desk, Office of Nuclear Material Safety and Safeguards, Office of Nuclear Reactor Regulation
References
RS-20-023
Download: ML20055G249 (5)

Text

4300 Winfield Road Warrenville, IL 60555 630 657 2000 Office RS-20-023 10 CFR 50.54(a)(4)

February 24, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Braidwood Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-72 and NPF-77 NRC Docket Nos. STN 50-456, STN 50-457, and 72-73 Byron Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-37 and NPF-66 NRC Docket Nos. STN 50-454, STN 50-455, and 72-68 Calvert Cliffs Nuclear Power Plant, Units 1 and 2 Renewed Facility Operating License Nos. DPR-53 and DPR-69 NRC Docket Nos. STN 50-317, STN 50-318, and 72-8 Clinton Power Station, Unit 1 Facility Operating License No. NPF-62 NRC Docket No. 50-461 and 72-1046 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 James A. FitzPatrick Nuclear Power Plant Renewed Facility Operating License No. DPR-59 NRC Docket No. 50-333 and 72-12 R.E. Ginna Nuclear Power Plant Renewed Facility Operating License No. DPR-18 NRC Docket No. 50-244 and 72-67 LaSalle County Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-11 and NPF-18 NRC Docket Nos. 50-373, 50-374, and 72-70 Limerick Generating Station, Units 1 and 2 Renewed Facility Operating License Nos. NPF-39 and NPF-85 NRC Docket Nos. 50-352, 50-353, and 72-65 Nine Mile Point Nuclear Station, Units 1 and 2 Renewed Facility Operating License Nos. DPR-63 and NPF-69 NRC Docket Nos. 50-220, 50-410, and 72-1036

February 24, 2020 U.S. Nuclear Regulatory Commission Page 2 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

Subject:

Additional Information Regarding Request for Approval of Change to Exelon Generation Company, LLC, Quality Assurance Topical Report

Reference:

Letter from Patrick Simpson (Exelon Generation Company, LLC) to U.S NRC, "Request for Approval of Change to Exelon Generation Company, LLC, Quality Assurance Topical Report," dated December 5, 2019 By letter dated December 5, 2019 (Reference), Exelon Generation Company, LLC (EGC),

requested approval of a proposed change to the Quality Assurance Topical Report (QATR).

The proposed change modifies the internal audit frequency from 24 months to 36 months.

The NRC review identified a needed revision to the markup of QATR Appendix B item f provided as part of the original request. QATR Appendix B item f discusses using either a qualified offsite licensee fire protection engineer or an outside independent fire protection consultant for fire protection equipment and program implementation internal audits. The original markup should have deleted the last sentence, "an outside, independent fire protection consultant shall be used." The Attachment to this letter provides the revised markup for QATR Appendix B page 1 of 3. This Attachment replaces QATR Appendix B page 1 of 3 provided in the original request.

Should you have any questions concerning this request, please contact Mrs. Linda M. Palutsis at (630) 657-2821.

mQ Patrick R. Simpson Sr. Manager Licensing

Attachment:

Revised Mark-Up for QATR Appendix B page 1 of 3

February 24, 2020 U.S. Nuclear Regulatory Commission Page 3 cc: NRC Regional Administrator, Region I NRC Regional Administrator, Region III NRC Senior Resident Inspector - Braidwood Station NRC Senior Resident Inspector - Byron Station NRC Senior Resident Inspector - Calvert Cliffs Nuclear Power Plant NRC Senior Resident Inspector - Clinton Power Station NRC Senior Resident Inspector - Dresden Nuclear Power Station NRC Senior Resident Inspector - James A. FitzPatrick Nuclear Power Plant NRC Senior Resident Inspector - R.E. Ginna Nuclear Power Plant NRC Senior Resident Inspector - LaSalle County Station NRC Senior Resident Inspector - Limerick Generating Station NRC Senior Resident Inspector - Nine Mile Point Nuclear Station NRC Senior Resident Inspector - Peach Bottom Atomic Power Station NRC Senior Resident Inspector - Quad Cities Nuclear Power Station

ATTACHMENT Revised Mark-Up for QATR Appendix B page 1 of 3

Audit Frequency APPENDIX B Internal audits shall be conducted on a performance driven frequency, not to exceed 24 months or at the frequencies in calendar months as indicated below, in accordance with the Companys QAP. Audits shall include the following safety-related functions as applicable:

AUDIT FREQUENCY

a. The conformance of unit operation to provisions contained 24 36 Months within the technical specifications and applicable license conditions.

b. The adherence to procedures, training, and qualification of the 24 36 Months station staff.

c. The results of actions taken to correct deficiencies occurring in 24 36 Months facility equipment, structures, systems, components, or method of operation that affect nuclear safety (CAP).

d. The performance of activities required by the Quality Assurance 24 36 Months Program to meet the criteria of Appendix B of 10 CFR 50.

x Chemistry x Engineering - Design Control, x Engineering - Programs x Procurement / Materials Management x Maintenance x Nuclear Fuels x Operations x Quality Assurance Functions (internal and vendor audit \

assessment activities are evaluated by NIEP.)

e. The fire protection programmatic controls including the 24 36 Months implementing procedures (by qualified Nuclear Oversight personnel).

f. The fire protection equipment and program implementation, 24 36 Months including loss prevention, utilizing either a qualified offsite licensee fire protection engineer or an outside, independent fire protection consultant. An outside, independent fire protection consultant shall be used. at least every second year.

g. The Radiological Environmental Monitoring Program (REMP) 24 36 Months and its results.

h. The Offsite Dose Calculation Manual (ODCM) and 24 36 Months implementing procedures.

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