ML041610059
| ML041610059 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Palisades, Kewaunee, Point Beach, Prairie Island, Duane Arnold  |
| Issue date: | 06/20/2004 |
| From: | David Beaulieu NRC/NRR/DLPM/LPD3 |
| To: | Weinkam E Nuclear Management Co |
| Beaulieu, David, NRR/DLPM, 415-3243 | |
| References | |
| TAC MB7157, TAC MC1309, TAC MC1310, TAC MC1311, TAC MC1312, TAC MC1313, TAC MC1314, TAC MC1315, TAC MC1316 | |
| Download: ML041610059 (13) | |
Text
June 20, 2004 Mr. Edward J. Weinkam Director, Regulatory Services Nuclear Management Company, LLC 700 First Street Hudson, WI 54016
SUBJECT:
DUANE ARNOLD ENERGY CENTER, KEWAUNEE NUCLEAR POWER PLANT, MONTICELLO NUCLEAR GENERATING PLANT, PALISADES NUCLEAR PLANT, POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2, PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 REQUEST FOR ADDITIONAL INFORMATION RE: REQUEST FOR APPROVAL OF NUCLEAR MANAGEMENT COMPANY QUALITY ASSURANCE TOPICAL REPORT (TAC NOS. MB7157, MC1309, MC1310, MC1311, MC1312, MC1313, MC1314, MC1315, AND MC1316)
Dear Mr. Weinkam:
The Nuclear Management Company, LLCs (NMCs) letter of October 31, 2003, requested U.S. Nuclear Regulatory Commission (NRC) approval of the NMC Quality Assurance Topical Report. The NRC staff is reviewing your request and finds that additional information is needed as shown in the enclosed request for additional information (RAI). The enclosed RAI questions relate to Enclosure 6 of your submittal entitled, Reduction in Commitment Regarding Offsite Review Committees.
The NRC staff discussed the enclosed RAI with you and your staff on June 3, 2004, and you agreed to respond within 30 days of receipt of the RAI. Please contact me at (301) 415-3243 if you have questions.
Sincerely,
/RA/
David P. Beaulieu, Project Manager, Section 1 Project Directorate III Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-331, 50-305, 50-263, 50-255, 50-266, 50-301, 50-282, and 50-306
Enclosure:
Request for Additional Information cc w/encl: See next page
ML041610059 OFFICE PDIII-1/PM PDIII-1/LA IPSB-A/SC PDIII-1/SC NAME DBeaulieu THarris DThatcher JNakoski for LRaghavan DATE 06/18/04 06/09/04 06/09/04 06/20 /04
Duane Arnold Energy Center cc:
Mr. John Paul Cowan Executive Vice President &
Chief Nuclear Officer Nuclear Management Company, LLC 700 First Street Hudson, MI 54016 John Bjorseth Plant Manager Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 Steven R. Catron Manager, Regulatory Affairs Duane Arnold Energy Center 3277 DAEC Road Palo, IA 52324 U.S. Nuclear Regulatory Commission Resident Inspectors Office Rural Route #1 Palo, IA 52324 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 Jonathan Rogoff Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Bruce Lacy Nuclear Asset Manager Alliant Energy/Interstate Power and Light Company 3277 DAEC Road Palo, IA 52324 Daniel McGhee Utilities Division Iowa Department of Commerce Lucas Office Buildings, 5th floor Des Moines, IA 50319 Chairman, Linn County Board of Supervisors 930 1st Street SW Cedar Rapids, IA 52404 Craig G. Anderson Senior Vice President, Group Operations 700 First Street Hudson, WI 54016 Mark A. Peifer Site Vice President Duane Arnold Energy Center Nuclear Management Company, LLC 3277 DAEC Road Palo, IA 52324-0351
Kewaunee Nuclear Power Plant cc:
John Paul Cowan Executive Vice President &
Chief Nuclear Officer Nuclear Management Company, LLC 700 First Street Hudson, MI 54016 Plant Manager Kewaunee Nuclear Power Plant N490 Highway 42 Kewaunee, WI 54216-9511 Manager, Regulatory Affairs Kewaunee Nuclear Power Plant N490 Highway 42 Kewaunee, WI 54216-9511 David Molzahn Nuclear Asset Manager Wisconsin Public Service Corporation 600 N. Adams Street Green Bay, WI 54307-9002 Resident Inspectors Office U.S. Nuclear Regulatory Commission N490 Hwy 42 Kewaunee, WI 54216-9511 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 Jonathan Rogoff Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Larry L. Weyers Chairman, President and CEO Wisconsin Public Service Corporation 600 North Adams Street Green Bay, WI 54307-9002 David Zellner Chairman - Town of Carlton N2164 County B Kewaunee, WI 54216 Mr. Jeffery Kitsembel Electric Division Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854 Mr. Thomas Coutu Site Vice President Kewaunee Nuclear Power Plant Nuclear Management Company, LLC N490 Highway 42 Kewaunee, WI 54216-9511
Monticello Nuclear Generating Plant cc:
Jonathan Rogoff, Esquire Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 U.S. Nuclear Regulatory Commission Resident Inspectors Office 2807 W. County Road 75 Monticello, MN 55362 Manager, Regulatory Affairs Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637 Robert Nelson, President Minnesota Environmental Control Citizens Association (MECCA) 1051 South McKnight Road St. Paul, MN 55119 Commissioner Minnesota Pollution Control Agency 520 Lafayette Road St. Paul, MN 55155-4194 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 Commissioner Minnesota Department of Health 717 Delaware Street, S. E.
Minneapolis, MN 55440 Douglas M. Gruber, Auditor/Treasurer Wright County Government Center 10 NW Second Street Buffalo, MN 55313 Commissioner Minnesota Department of Commerce 121 Seventh Place East Suite 200 St. Paul, MN 55101-2145 Manager - Environmental Protection Division Minnesota Attorney Generals Office 445 Minnesota St., Suite 900 St. Paul, MN 55101-2127 John Paul Cowan Executive Vice President & Chief Nuclear Officer Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Nuclear Asset Manager Xcel Energy, Inc.
414 Nicollet Mall, R.S. 8 Minneapolis, MN 55401 Mr. Thomas J. Palmisano Site Vice President Monticello Nuclear Generating Plant Nuclear Management Company, LLC 2807 West County Road 75 Monticello, MN 55362-9637
Palisades Plant cc:
Robert A. Fenech, Senior Vice President Nuclear, Fossil, and Hydro Operations Consumers Energy Company 1945 Parnall Rd.
Jackson, MI 49201 Arunas T. Udrys, Esquire Consumers Energy Company 1 Energy Plaza Jackson, MI 49201 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 Supervisor Covert Township P.O. Box 35 Covert, MI 49043 Office of the Governor P.O. Box 30013 Lansing, MI 48909 U.S. Nuclear Regulatory Commission Resident Inspectors Office Palisades Plant 27782 Blue Star Memorial Highway Covert, MI 49043 Michigan Department of Environmental Quality Waste and Hazardous Materials Division Hazardous Waste and Radiological Protection Section Nuclear Facilities Unit Constitution Hall, Lower-Level North 525 West Allegan Street P.O. Box 30241 Lansing, MI 48909-7741 Michigan Department of Attorney General Special Litigation Division 525 West Ottawa St.
Sixth Floor, G. Mennen Williams Building Lansing, MI 48913 Manager, Regulatory Affairs Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043 Director of Nuclear Assets Consumers Energy Company Palisades Nuclear Plant 27780 Blue Star Memorial Highway Covert, MI 49043 John Paul Cowan Executive Vice President & Chief Nuclear Officer Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Jonathan Rogoff, Esquire Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Douglas E. Cooper Senior Vice President - Group Operations Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043 Daniel J. Malone Site Vice President Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043
Point Beach Nuclear Plant, Units 1 and 2 cc:
Jonathan Rogoff, Esquire Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Mr. Richard R. Grigg President and Chief Operating Officer Wisconsin Electric Power Company 231 West Michigan Street Milwaukee, WI 53201 Regulatory Affairs Manager Point Beach Nuclear Plant Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, WI 54241 Mr. Ken Duveneck Town Chairman Town of Two Creeks 13017 State Highway 42 Mishicot, WI 54228 Chairman Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 2443 Warrenville Road Suite 210 Lisle, IL 60532-4352 Resident Inspectors Office U.S. Nuclear Regulatory Commission 6612 Nuclear Road Two Rivers, WI 54241 Mr. Jeffery Kitsembel Electric Division Public Service Commission of Wisconsin P.O. Box 7854 Madison, WI 53707-7854 Nuclear Asset Manager Wisconsin Electric Power Company 231 West Michigan Street Milwaukee, WI 53201 John Paul Cowan Executive Vice President & Chief Nuclear Officer Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Douglas E. Cooper Senior Vice President - Group Operations Palisades Nuclear Plant Nuclear Management Company, LLC 27780 Blue Star Memorial Highway Covert, MI 49043 Site Director of Operations Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, WI 54241 Gary D. Van Middlesworth Site Vice-President Point Beach Nuclear Plant Nuclear Management Company, LLC 6610 Nuclear Road Two Rivers, WI 54241
Prairie Island Nuclear Generating Plant, Units 1 and 2 cc:
Jonathan Rogoff, Esquire Vice President, Counsel & Secretary Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Manager, Regulatory Affairs Prairie Island Nuclear Generating Plant Nuclear Management Company, LLC 1717 Wakonade Drive East Welch, MN 55089 Manager - Environmental Protection Division Minnesota Attorney Generals Office 445 Minnesota St., Suite 900 St. Paul, MN 55101-2127 U.S. Nuclear Regulatory Commission Resident Inspector's Office 1719 Wakonade Drive East Welch, MN 55089-9642 Regional Administrator, Region III U.S. Nuclear Regulatory Commission 2443 Warrenville Road, Suite 210 Lisle, IL 60532-4352 Administrator Goodhue County Courthouse P.O. Box 408 Red Wing, MN 55066-0408 Commissioner Minnesota Department of Commerce 121 Seventh Place East Suite 200 St. Paul, MN 55101-2145 Tribal Council Prairie Island Indian Community ATTN: Environmental Department 5636 Sturgeon Lake Road Welch, MN 55089 Nuclear Asset Manager Xcel Energy, Inc.
414 Nicollet Mall, R.S. 8 Minneapolis, MN 55401 John Paul Cowan Executive Vice President & Chief Nuclear Officer Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Craig G. Anderson Senior Vice President, Group Operations Nuclear Management Company, LLC 700 First Street Hudson, WI 54016 Mr. Joseph M. Solymossy Site Vice President Prairie Island Nuclear Generating Plant Nuclear Management Company, LLC 1717 Wakonade Drive East Welch, MN 55089
ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION REQUEST FOR APPROVAL OF NUCLEAR MANAGEMENT COMPANY QUALITY ASSURANCE TOPICAL REPORT NUCLEAR MANAGEMENT COMPANY, LLC DUANE ARNOLD ENERGY CENTER KEWAUNEE NUCLEAR POWER PLANT MONTICELLO NUCLEAR GENERATING PLANT PALISADES NUCLEAR PLANT POINT BEACH NUCLEAR PLANT, UNITS 1 AND 2 PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-331, 50-305, 50-263, 50-255, 50-266, 50-301, 50-282, AND 50-306 The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the Nuclear Management Companys (NMCs) request for NRC approval of its Quality Assurance Topical Report and has determined that the following additional information is needed in order to complete the review: of the NMC submittal proposes to eliminate the Offsite Review Committee, which implements the independent review program described in Section 4.3 of American National Standards Institute (ANSI) standard N18.7-1976 (alternately ANS-3.2), "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," endorsed by NRC's Regulatory Guide 1.33, "Quality Assurance Program Requirements." Qualification requirements for personnel implementing the independent review process are established by ANSI standard ANS 3.1, "Selection and Training of Nuclear Power Plant Personnel," endorsed by NRC's Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants."
NMCs implementation of the independent review function, as described by the current quality assurance programs for NMCs nuclear stations, is consistent with the organizational construction for standing committees, as described in Section 4.3.2 of ANS-3.2. ANS-3.2 establishes provisions for independent reviews, including functional responsibilities, organizational provisions for conducting review activities, technical qualifications of personnel conducting the reviews, and documentation and reporting of activities. Persons or organizations responsible for implementing the independent review function shall be sufficiently independent from cost and scheduling considerations when opposed to safety considerations, shall have direct access to responsible management at a level where appropriate actions can be accomplished, and shall report regularly on the effectiveness of the program to offsite management.
The staff requests the following additional specific information regarding the independent review function if the Offsite Review Committee were eliminated:
- 1.
Scope of review For each subject identified in Section 4.3.4 of ANS-3.2, (a) identify the organizational element(s) that would be responsible for the independent review of the subject and specific procedural or other administrative processes that will be used in implementing these reviews, or (b) provide justification why review of the subject is unnecessary.
2.
Authority/Independence/Organizational Freedom For the organizational element(s) identified above, (a) describe the organizational structure that ensures that personnel conducting independent reviews have sufficient authority, independence, and organizational freedom to identify safety problems, to initiate, recommend or provide solutions and to verify implementation of solutions, or (b) provide justification why this is unnecessary.
3.
Oversight of Audit Program With respect to the periodic review of the audit program described in Section 4.5 of ANS 3.2, (a) describe how this periodic, independent review would be performed, or (b) provide justification why this is unnecessary.
4.
Oversight of Corrective Action Process Section 5.2.11 of ANS-3.2 states that, In the case of significant conditions adverse to safety, the measures shall assure that the cause of the condition is determined and corrective actions taken shall be documented and reported to appropriate levels of management and for independent review.
(a)
Describe how independent review of the adequacy of corrective actions is accomplished if the independent review function described in Section 5.2.11 of ANS-3.2 were eliminated, or (b) provide justification why this is unnecessary.
5.
Results of Independent Reviews (a)
Describe how deficiencies, adverse trends, and recommendations resulting from independent reviews are reported, corrected, and verified, or (b) provide justification why this is unnecessary.
6.
Qualifications for Independent Review Personnel For personnel performing independent reviews, (a) define the qualifications requirement for personnel performing independent reviews, including competence to review the areas identified in ANS-3.2, Section 4.3.1. The requirements should be equivalent to those currently required for independent review personnel, or (b) provide justification why this is unnecessary.
7.
Records (a)
Define the provisions for preparation and retention of records of reviews, including identification of document reviews, recommendations and proposed actions resulting from these reviews, and the method for promptly disseminating this information to management having responsibility for the areas reviewed, or (b) provide justification why this is unnecessary.
8.
Regulatory Basis The independent review program is an administrative control, as defined under Title10 of the Code of Federal Regulations (10 CFR), Section 50.36(c)(5). The source of the requirement is the regulation at 10 CFR 50.40(b), as it relates to the licensee being technically qualified to engage in license activities. The staff reviews changes to the independence review program in accordance with Chapter 13.4, Operational Review, of the Standard Review Plan (NUREG-0800). of the submittal contains a section titled Basis for Concluding Continued Compliance with Appendix B. The independent review program is not an Appendix B requirement. The technical specification was relocated to the quality assurance program under a burden reduction initiative in accordance with the Commissions Final Policy Statement on Technical Specification Improvements for Nuclear Power Reactors (59 FR 39132). The 10 CFR 50.54(a) change control process requires regulatory review and approval of changes to the independent review program, but independent review is not an Appendix B requirement.
The submittal should be revised to delete the reference to Appendix B compliance and to address the regulations applicable to the independent review program.
9.
Independent Review of the submittal refers to the plant operations review committee as performing the independent review function. Please clarify whether the committee meets the definition of independent review, as defined in Section 2.2 and further described in the third paragraph of Section 3.2 of ANSI N18.7-1976.