ML031910003

Regarding Nuclear Quality Assurance Program Amendment 32

ML031910003
Person / Time
Site:	Oconee, Mcguire, Catawba, McGuire
Issue date:	07/10/2003
From:	Martin R NRC/NRR/DLPM/LPD2
To:	Tuckman M Duke Energy Corp
Martin E. Robert/NRR/DLPM/415-1493
References
TAC MB7166, TAC MB7167, TAC MB7168, TAC MB7169, TAC MB7170, TAC MB7171, TAC MB7172
Download: ML031910003 (6)

Text

July 10, 2003 Mr. M. S. Tuckman Executive Vice President Duke Energy Corporation 526 South Church St Charlotte, NC 28201-1006

SUBJECT:

CATAWBA NUCLEAR STATION, UNITS 1 AND 2, MCGUIRE NUCLEAR STATION, UNITS 1 AND 2 AND OCONEE NUCLEAR STATION, UNITS 1, 2 AND 3 RE: NUCLEAR QUALITY ASSURANCE PROGRAM, AMENDMENT 32 (TAC NOS. MB7166, MB7167, MB7168, MB7169, MB7170, MB7171 AND MB7172)

Dear Mr. Tuckman:

By letter dated December 18, 2002, as supplemented by letter dated April 24, 2003, the Duke Energy Corporation submitted amendment number 32 to its Duke Energy Corporation Topical Report, Duke-1-A, on the Quality Assurance (QA) Program for the Oconee, McGuire, and Catawba Nuclear Stations. We have continued our review of the amendment to your QA Program and have identified a further need for additional information as discussed in the Enclosure. We discussed these issues with your staff on June 19, 2003. Please provide a response at the earliest practical time to enable our timely completion of the review.

Please contact me at (301) 415-1493, if you have any other questions on these issues.

Sincerely,

/RA/

Robert E. Martin, Senior Project Manager Project Directorate II, Section 1 Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-413, 50-414, 50-369, 50-370, 50-269, 50-270 and 50-287

Enclosure:

Request for Additional Information cc w/encl: See next page

ML031910003 OFFICE PDII-1/PM PDII-1/LA IEHB/SC PDII-1/SC NAME RMartin CHawes DThatcher* LOlshan for JNakoski DATE 07/9/03 07/8/03 06/30/03 07/9/03 REQUEST FOR ADDITIONAL INFORMATION REGARDING QUALITY ASSURANCE PLAN REVISION DUKE POWER COMPANY WILLIAM B. MCGUIRE NUCLEAR STATION, UNIT 2 DOCKET NOS. 50-369 AND 50-370 CATAWBA NUCLEAR STATION UNITS 1 AND 2 DOCKET NO. 50-413 AND 50-414 OCONEE NUCLEAR STATION UNITS 1, 2 AND 3 DOCKET NOS. 50-269, 50-270 AND 50-287 BACKGROUND On December 18, 2002, the Duke Power Company (Duke, licensee) requested that the Nuclear Regulatory Commission (NRC) staff review and approve Amendment 32 of its Nuclear Quality Assurance Program (referred to as Topical Report). This amendment to the Topical Report includes a reduction in commitment with respect to hold point inspections for routine maintenance activities. The proposed alternative would eliminate hold point inspections by substitution of an indirect monitoring process. The NRC staff requested additional information in a letter dated April 4, 2003, and Duke responded to that request in its letter dated April 24, 2003. This further request for additional information (RAI) is based on the NRC staffs review of Dukes letter dated April 24, 2003, and on discussions held with Duke on June 19, 2003.

The information provided to date does not adequately or clearly describe the scope of activities to which the proposed alternative would apply. In addition, the description of the monitoring process is neither specific nor robust enough to demonstrate that process monitoring will maintain a level of control comparable to hold point inspections. As discussed during the June 19, 2003, telephone conference, the NRC staff needs further clarification for the following three areas: (1) a clearer definition of the scope of activities to which process monitoring would be applied, (2) a description of the elements of the selection process, and (3) a description of the proposed monitoring process.

A. Topical Report Definitions of Maintenance:

Define the following terms for inclusion in the topical report: (1) maintenance, (2) routine maintenance, and (3) non-routine maintenance; these will be used to determine the activities that will require hold point inspections or activities requiring process monitoring. Include a more complete list of clarifying examples for routine and non-routine maintenance (e.g., routine maintenance might include torquing, restoration, oil change; non-routine maintenance might include work on valve actuators or diesel generator overhaul).

Consider the following working definitions provided by the NRC staff in developing your response:

Maintenance consists of those activities necessary to maintain or restore systems to within specified design limits.

Routine maintenance consists of repair, rework, replacement, adjustment, cleaning or other actions necessary to maintain an item to acceptable conditions and is performed by trained and qualified personnel in accordance with documented procedures and/or instructions.

Non-routine maintenance activities are intended to change specified design limits, such as modifications. Non-routine maintenance includes maintenance that may be routine, but is performed by personnel who may not have the requisite training and qualification to perform the activity without supervisory oversight, or a first time evolution performed in an operating plant environment. Non-routine maintenance includes American Society of Mechanical Engineer (ASME)Section XI Code activities, special processes, civil activities, and modifications.

B. Topical Report Description of Elements of the Selection Process Used to Determine Routine Maintenance Activities that will be Controlled Through Process Monitoring:

1. Clarify that determination of routine maintenance activities to be controlled through process monitoring is procedurally administered through the review of existing or new model work orders, that this is accomplished by qualified personnel, and that this determination is a one-time process for a given task.

2. The draft quality process monitoring procedure, QAM-3, included with the licensees response to the letter dated April 24, 2003, states that maintenance tasks coded with a Quality Control (QC) determination code QC P are activities associated with routine maintenance and that QC hold points for maintenance procedures are not applicable; however, the maintenance activity is a candidate for process monitoring. This statement suggests that inspections (both hold point and process monitoring) for activities coded QC P could be eliminated.

Clarify that QC determination code P means that hold point inspections are required unless the activity is selected for process monitoring. Provide specific clarification on how activities coded QC P that are not determined to be candidates for process monitoring are controlled.

3. The checklist for selecting activities for process monitoring needs to be more specific and robust. Provide additional checklist details such that: (1) the NRC staff can understand how the process is applied, and (2) knowledgeable persons using the checklist for the same activity or similar activities would arrive at the same conclusion as to selecting process monitoring to control a selected activity.

4. Define the qualifications of the personnel making the routine maintenance determinations (American Nuclear Society (ANS) standard 3.1 or equivalent).

Include specific commitments in the topical report for training required for personnel including planners, maintenance and QC personnel who would select activities to be controlled through process monitoring.

C. Topical Report Description of Process Monitoring Elements The definition of Quality Process Monitoring, provided in the draft procedure QAM-3, attached to the licensees response dated April 24, 2003, states that Quality Process Monitoring (Process Monitoring) is monitoring or direct observation to verify whether an item or activity conforms to specified requirements. Provide specific clarification on the determination process, the criteria used, how the determination is documented in the work package, and what actions are taken when an item or activity does not conform.

McGuire Nuclear Station Catawba Nuclear Station Oconee Nuclear Station cc:

Ms. Lisa F. Vaughn Mr. Richard M. Fry, Director Legal Department (ECIIX) Division of Radiation Protection Duke Energy Corporation North Carolina Department of 422 South Church Street Environment, Health, and Charlotte, North Carolina 28201-1006 Natural Resources 3825 Barrett Drive County Manager of Mecklenburg County Raleigh, North Carolina 27609-7721 720 East Fourth Street Charlotte, North Carolina 28202 Ms. Karen E. Long Assistant Attorney General Mr. Michael T. Cash North Carolina Department of Regulatory Compliance Manager Justice Duke Energy Corporation P. O. Box 629 McGuire Nuclear Site Raleigh, North Carolina 27602 12700 Hagers Ferry Road Huntersville, North Carolina 28078 Mr. C. Jeffrey Thomas Manager - Nuclear Regulatory Anne Cottingham, Esquire Licensing Winston and Strawn Duke Energy Corporation 1400 L Street, NW. 526 South Church Street Washington, DC 20005 Charlotte, North Carolina 28201-1006 Senior Resident Inspector NCEM REP Program Manager c/o U. S. Nuclear Regulatory 4713 Mail Service Center Commission Raleigh, NC 27699-4713 12700 Hagers Ferry Road Huntersville, North Carolina 28078 Mr. T. Richard Puryear Owners Group (NCEMC)

Mr. Peter R. Harden, IV Duke Energy Corporation VP-Customer Relations and Sales 4800 Concord Road Westinghouse Electric Company York, South Carolina 29745 6000 Fairview Road 12th Floor Charlotte, North Carolina 28210 Dr. John M. Barry Mecklenburg County Department of Environmental Protection 700 N. Tryon Street Charlotte, North Carolina 28202

McGuire Nuclear Station Catawba Nuclear Station Oconee Nuclear Station cc:

Mr. Gary Gilbert North Carolina Electric Membership Regulatory Compliance Manager Corporation Duke Energy Corporation P. O. Box 27306 4800 Concord Road Raleigh, North Carolina 27611 York, South Carolina 29745 Senior Resident Inspector North Carolina Municipal Power 4830 Concord Road Agency Number 1 York, South Carolina 29745 1427 Meadowwood Boulevard P. O. Box 29513 Mr. G. R. Peterson Raleigh, North Carolina 27626-0513 Site Vice President Catawba Nuclear Station County Manager of York County Duke Energy Corporation York County Courthouse 4800 Concord Road York, South Carolina 29745 York, South Carolina 29745 Piedmont Municipal Power Agency Mr. Dhiaa Jamil 121 Village Drive Vice President, McGuire Site Greer, South Carolina 29651 Duke Energy Corporation 12700 Hagers Ferry Road Saluda River Electric Huntersville, North Carolina 28078 P. O. Box 929 Laurens, South Carolina 29360 Manager, LIS NUS Corporation Mr. Michael A. Schoppman 2650 McCormick Drive, 3rd Floor Framatome ANP Clearwater, Florida 34619-1035 1911 North Ft. Myer Drive Suite 705 Senior Resident Inspector Rosslyn, VA 22209 U. S. Nuclear Regulatory Commission 7812B Rochester Highway Mr. L. E. Nicholson Seneca, South Carolina 29672 Compliance Manager Duke Energy Corporation Mr. Henry Porter, Director Oconee Nuclear Site Division of Radioactive Waste 7800 Rochester Highway Management Seneca, South Carolina 29672 Bureau of Land and Waste Management Department of Health and Environmental Control 2600 Bull Street Columbia, South Carolina 29201-1708