ML042300115
| ML042300115 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Palisades, Kewaunee, Point Beach, Prairie Island, Duane Arnold  |
| Issue date: | 08/18/2004 |
| 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: ML042300115 (12) | |
Text
August 18, 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:
By application to the U.S. Nuclear Regulatory Commission (NRC) dated October 31, 2003, as supplemented July 23, 2004, Nuclear Management Company, LLC (NMC) requested 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 Enclosures 1 through 5 of your submittal.
The NRC staff discussed the enclosed RAI with your staff and on August 4, 2004, 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
ML042300115 OFFICE PDIII-1/PM PDIII-1/LA PDIII-1/SC NAME DBeaulieu THarris LRaghavan DATE 08/17/2004 08/17/2004 08/17/2004
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. F. D. Kuester President & Chief Executive Officer WE Generation 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 801 Warrenville Road Lisle, IL 60532-4351 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 Dennis L. Koehl Site Vice-President Nuclear Management Company, LLC 6590 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 (NMC) request for approval of its Quality Assurance Topical Report, Rev 0a, submitted by letter dated October 31, 2003, as supplemented on July 23, 2004. The NRC is reviewing Enclosure 6 of the submittal as a separate task and as such, a request for additional information regarding Enclosure 6 was sent by letter dated June 20, 2004, to which NMC responded on July 23, 2004. We have completed our initial review of the remainder of the submittal and have determined that the following information is needed to continue our review.
1.
Assessment Section C of the proposed quality assurance (QA) topical describes NMCs assessment program. The QA topical defines the term independent assessment as being synonymous with the term audit, as used in the context of Criterion XVIII of Appendix B to 10 CFR Part 50.
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," specifies a maximum period of two years to complete an audit cycle covering all safety-related functions. NRC Regulatory Guide (RG) 1.33, "Quality Assurance Program Requirements," Revision 2, amplifies this guidance in specifying minimum audit frequencies of 6 months for audits of corrective actions affecting safety-related equipment, 12 months for audits of facility conformance with technical specifications (TS), and 12 months for audits of performance, training, and qualifications of the facility staff.
In order for the staff to determine the acceptability of the proposed assessment program, the following additional information is requested concerning the bases for this exception to ANSI N18.7-1976 and NRC RG 1.33, Rev. 2.
1.1 Under the proposed performance-based program, there is no minimum period for completing audits of safety-related functions. Describe in further detail, the systemic attributes of the process for scheduling audits. Identify the applicable procedures that define the independent assessment process and provide these procedures for staff review.
1.2 Describe the methodology that will be used as the bases for determining the schedule for independent assessments. Describe the quantitative performance metrics that will indicate whether performance of each topic identified in Table 1 of the QA topical is declining and needs to be assessed.
1.3 With regard to NRC RG 1.33, provide the bases for concluding that effective oversight of the activities addressed by regulatory position C.4 (i.e., corrective actions, TS conformance, personnel performance, training, and qualifications) will be maintained at a level commensurate with the safety significance of these activities, in lieu of specifying a minimum assessment frequency.
1.4 The submittal proposes to eliminate the independent review program, described in section 4.3 of N18.7. If this program were eliminated, as proposed in Enclosure 6 of the submittal, describe the oversight process that would ensure that the performance and effectiveness of the assessment and independent assessment programs are maintained.
2.
Qualification and Training of Personnel Section A.7.3 of the proposed QA topical identifies NMC commitments to nuclear quality standards other than ANSI/ASME NQA-1, "Quality Assurance Requirements for Nuclear Facility Applications." For qualification and training of personnel, NMC commits to follow the guidance of NRC RG 1.8, "Qualification and Training of Personnel for Nuclear Power Plants," Rev. 3, May 2000.
NRC RG 1.8, Revision 3 endorses ANS 3.1-1993, "Selection, Qualification, and Training of Personnel for Nuclear Power Plants," and establishes two regulatory positions with respect to this standard. In committing to NRC RG 1.8, Revision 3, the QA topical takes exception to both regulatory positions and states that NMC does not commit to follow ANS 3.1-1993. The exceptions are not specified in the QA topical, but reference is made to site TSs.
Current QA programs for NMC plants do not commit to follow Revision 3 of NRC RG 1.8.
Point Beach commits to NRC RG 1.8, Revision 0 (1971); Monticello and Prairie Island commit to NRC RG 1.8, Revision 1 (1975); Duane Arnold commits to NRC RG 1.8, Revision 1-R (1977); Palisades and Kewaunee commit to NRC RG 1.8 (1980 Draft).
It appears that commitments to NRC RG 1.8 are incorporated in both the plant TSs and the quality assurance program. Consequently, changes in commitments to NRC RG 1.8 would be subject to two regulatory change processes.
2.1 Confirm plant-specific commitments to NRC RG 1.8 and ANS 3.1 will remain unchanged as the result of the proposed QA program consolidation or, alternately, provide the bases for changing these commitments.
2.2 Provide clarification as to the intent of including a commitment to Revision 3 of NRC RG 1.8 in the QA topical, in addition to the commitments made in the TSs.
3.
Qualification of Nondestructive Examination Personnel Section A.5 of the proposed QA topical describes provisions for personnel training and qualification. Exception is taken to NQA-1 Supplementary Requirement 2S-2, which specifies the use of American Society of Nondestructive Testing Recommended Practice SNT-TC-1A for qualification of all personnel who perform examinations covered by that supplement. As stated, the exception allows use of American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code(s) or national standards in lieu of SNT-TC-1A.
Regulatory position C.3 of NRC RG 1.58, "Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel," Revision 1, which is followed by most NMC plants, specifies that SNT-TC-1A should be used in conjunction with (i.e., in addition to) the additional provisions of the ASME Code. This position would also apply to other national standards.
3.1 Address regulatory position C.3 of NRC RG 1.58 with respect to use of codes other than SNT-TC-1A for qualification of nondestructive examination personnel.
4.
Hoisting and Rigging NMC plants currently follow the guidance of ANSI N45.2.2, "Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants During the Construction Phase," Section 7 for handling safety-related items. Guidance is provided for the handling of items to minimize damage and to preserve the quality of the item and container. ANSI N45.2.2 incorporates, by reference, industry standards applicable to these guidelines, such as the ANSI B30 series related to hoisting and rigging.
By taking exception to NQA-1, Subpart 2.15, QA Requirements for Hoisting, Rigging, and Transporting of Items for Nuclear Power Plants," NMC effectively withdraws the current commitment to ANSI N45.2.2 for hoisting and rigging. Changes to these commitments would no longer be reviewed by the staff through the regulatory change control process of 10 CFR 50.54(a)(3).
4.1 Provide additional information describing the proposed exception to the guidance of N45.2.2 for material handling. Identify and describe NMC commitments to standards establishing quality assurance requirements for hoisting and rigging, the licensing documents containing these commitments, and the process for controlling changes to these commitments.
5.
Records NQA-1, Supplementary Requirement 17S-1 classifies records as lifetime (i.e., permanent) records and nonpermanent records. Section B.15 of the proposed QA topical states that NMC uses the list of lifetime records in NQA-1, Appendix 17A-1, supplemented by the recommended retention times established in NRC RG 1.28, Quality Assurance Program Requirements (Design and Construction), position C.2 (Table 1).
5.1 NRC RG 1.28 does not provide retention times for operation records. Provide retention times for records listed in Appendix 17A-1, but not in NRC RG 1.28.
5.2 NMC plants currently follow the guidance of N45.2.9, which provides guidance for retention times for both permanent and nonpermanent records. NQA-1 (Appendix 17A-1) only lists permanent records. Provide the bases for establishing retention times for nonpermanent operations records.
5.3 Clarify how 10 CFR 71 and 10 CFR 72 recordkeeping requirements will be satisfied.
Specifically, Section A.7.3 of the proposed QA topical states,"NMC complies with position C.2 [of Regulatory Guide 1.28, Revision 3] for record retention times."
Section B.15, second paragraph, states "NMC uses the list of records in Non-mandatory Appendix 17A-1, supplemented by the recommended retention times established in Regulatory Guide 1.28, position C.2 (Table 1), to establish the types of records that will be created and retained in support of plant operation."
Section B.15, third paragraph, states "In establishing provisions for records, NMC commits to compliance with NQA-1, 1994, Basic Requirement 17 and Supplement 17S-1." Position C.2 and Supplement 17S-1 do not appear to satisfy the requirements of 10 CFR 71.135 and 10 CFR 72.174. For example, 10 CFR 71.135 requires the licensee to retain records "for 3 years beyond the date when the licensee last engages in the activity for which the quality assurance program was developed," and 10 CFR 72.174 requires "records must include closely related data such as qualifications of personnel, procedures, and equipment" and "must be maintained...until the NRC terminates the license or CoC."