ML051300539
| ML051300539 | |
| Person / Time | |
|---|---|
| Site: | Millstone, Surry, North Anna  |
| Issue date: | 05/05/2005 |
| From: | Dominion Nuclear Connecticut, Virginia Electric & Power Co (VEPCO) |
| To: | Document Control Desk, NRC/FSME |
| References | |
| 05-251 | |
| Download: ML051300539 (11) | |
Text
Serial No.05-251 Response to Request for Additional Information ATTACHMENT 1 RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION NUCLEAR FACILITY QUALITY ASSURANCE PROGRAM DESCRIPTION DOMINION NUCLEAR CONNECTICUT, INC.
VIRGINIA ELECTRIC AND POWER COMPANY
Serial No.05-251 Response to Request for Additional Information Quality Assurance Program Description Attachment 1 Page 1 of 10 RESPONSE TO REQUESTS FOR ADDITIONAL INFORMATION THE NUCLEAR FACILITY QUALITY ASSURANCE PROGRAM DESCRIPTION In a letter dated August 24, 2004, Dominion Nuclear Connecticut, Inc. (DNC) and Virginia Electric and Power Company (Dominion) submitted a revision to the respective stations Quality Assurance Program for NRC review and approval.
In a facsimile dated February 24, 2005, the NRC forwarded a request for additional information (RAI) related to the DNC and Dominion submittal. DNC and Dominion provide their response below.
The revisions to DOM-QA-1 and Discussion of Changes document are included with the response to the Draft RAI dated February 24, 2005. Changes to the QA Topical Report have been included in DOM-QA-1, Rev. 0a (Enclosure 2), and are indicated by strikethrough for deleted text and underline for inserted text with a vertical line in the right margin to indicate a change was made. A similar change has been made to Enclosure 4, Discussion of Changes, however, Tables 2 and 3 have been added without change markings to provide for better clarity of the text.
NRC Question 1 Provide a matrix that describes the migration of each unit/facility current quality assurance commitments to the proposed commitments for each unit/facility. The matrix should state whether each commitment is a non-reduction, reduction, or an increase in commitment. Provide justification for all reductions in commitments. Also provide references to any safety evaluation precedents used to change existing commitments. Demonstrate that these precedents are applicable to the licensees facilities.
Dominion Response of this submittal contains the information requested. A specific matrix of each commitment by former QA program description is provided as Table 2 for Millstone Power Station and Table 3 for North Anna and Surry Power Stations. to NFQAPD provides the proposed NFQAPD for the licensees facilities.
Serial No.05-251 Response to Request for Additional Information Quality Assurance Program Description Attachment 1 Page 2 of 10 NRC Question 1 Section 11.2, test procedures, states the prerequisites are normally completed prior to commencement of the test. How do you ensure the item is ready for testing if the prerequisites are not completed? What is the basis for this statement?
Dominion Response Based on ANSI N18.7-1976, subsection 5.3.2(4), there may be prerequisites that only apply to a specific part of a test (procedure) and therefore would only need to be satisfied at the point when those steps will be implemented. The statement in the QAPD has been clarified to address the question.
NRC Question 2 Section 13.3 provides the quality standards commitment and provides alternatives for Subpart 2.2 and subpart 2.15. What are the bases for these proposed alternatives?
Dominion Response These are alternatives carried over from the existing NRC-approved North Anna and Surry QA program. The alternatives were first proposed in Virginia Electric and Power Company Quality Assurance Program VEP-1, Revision 4 and approved by the NRC as documented in letter to E. A. Baum, dated October 6, 1982. The basis for the subpart 2.15 alternative is addressed in the Discussion of Changes under the NQA-1, Subpart 2.15, and Tables 2 and 3.
NRC Question 3 Section 17.2, records of activities, states that the records and their retention times are based on Regulatory Position C.2, Table 1, of NRC Regulatory Guide 1.28. The applicable revision number, i.e., Rev. 3, should be used to be consistent with the remainder of the NFQAPD.
Dominion Response This editorial change has been made. The specific information regarding the Regulatory Guide revision was provided in subsection 17.4 listing the commitments for this section.
Serial No.05-251 Response to Request for Additional Information Quality Assurance Program Description Attachment 1 Page 3 of 10 to NFQAPD provides a discussion of changes to the current Quality Assurance (QA) program for Millstone, North Anna and Surry.
NRC Question 1 In attachment 2, an evaluation of alternatives to committed standards is provided.
Specifically, pages 5 and 6 discuss commitments to ANS-3.1 (draft 12/79) and alternatives to ANS-3.1-1993. Since the proposed NFQAPD is adopting NQA-1-1994 and ANS-3.1-1994, in part, it is not clear why the licensee has chosen to maintain its commitment to ANS-3.1 (draft 12/79). Although approved as part of the licensing basis for North Anna and Surry, the draft 12/79 ANS-3.1 standard was not endorsed by the NRC staff. Provide a discussion as to why you are maintaining your commitment to ANS-3.1 (draft 12/79) for North Anna and Surry and why ANS-3.1 (draft 12/79) is applicable to Millstone (as it appears to be in this section).
Dominion Response The current facility technical specifications commit North Anna and Surry Power Stations to this draft standard and the draft Reg. Guide. This was discussed when Dominion presented the overview of Dominions project to have a consolidated QA program to the NRC. Dominions intent was to relocate the commitments from the Technical Specifications to the QA program, as much as practical, in the same form. As allowed in the guidance of Administrative Letter 95-05, a controlled change to a later edition standard, common for all the Dominion sites, could be made in the future in accordance with the provisions of 10 CFR 50.54(a). The change to a common standard would require that Dominion adopt a more recent standard, previously approved by the NRC through a Regulatory Guide or SER. Alternatively, Dominion would submit the change to the NRC for review and approval. Since Dominion understood this would be a two-part change process, the procedures and programs have not been updated to implement the requirements of the common standard across the fleet. Since the request to relocate the information from the Technical Specifications to the QA Program is being denied, Dominion will be required to make a concurrent change to the Technical Specifications and QA Program in order to adopt a common standard at a future date.
It was not the intent of this change to make these commitments applicable to any other Dominion stations. Millstone is currently committed to ANSI N18.1-1971 by technical specifications. It is Dominions intent for this standard to remain for the facility until the subsequent change to a common later edition standard for all sites is processed. Dominion has clarified the application of these commitments
Serial No.05-251 Response to Request for Additional Information Quality Assurance Program Description Attachment 1 Page 4 of 10 both in the NFQAPD, Appendix C and the discussion in Attachment 2 of the original submittal. Also, as a clarification, Dominion is committing to ANS-3.1-1993 in part, as endorsed by NRC Regulatory Guide 1.8, Revision 3, rather than ANS-3.1-1994.
NRC Question 2 In attachment 2, page 8 describes an alternative to NQA-1-1994 Appendix 2A-1 regarding the use of Level I, II, and III for qualification of inspectors. As proposed, the alternative does not provide an adequate description of the education and experience requirements for those individuals performing quality control verification. Provide further description of what is meant by the qualification program will ensure that only personnel that meet the education and experience requirements, and have demonstrated appropriate capabilities in the inspection and test activities they are assigned will be certified and used to perform those inspections (page 13 of proposed NFQAPD). How does the proposed alternative meet the requirements of 10 CFR 50 Appendix B, Section II (Quality Assurance Program)?
Dominion Response The alternative has been revised to state the qualification requirements for personnel who are not certified using the levels of qualification designated in Appendix 2A-1. These changes have been reflected in DOM-QA-1, subsection 2.5.5 (Enclosure 2) and 6.2 of Appendix C. The revised alternative is as follows:
In lieu of being certified as Level I, II, or III in accordance with NQA-1-1994, personnel performing operations phase independent quality verification inspections, examinations, measurements, or tests of material, products, or activities will be required to possess qualifications equal to or better than those required for performing the task being verified. The verification shall be within the skills of these personnel and/or is addressed by procedures. These individuals will not be responsible for the planning of quality verification inspections and tests (i.e., establishing hold points and acceptance criteria in procedures, or determining who will be responsible for performing the inspections), evaluating inspection training programs, or certifying inspection personnel.
This alternative meets the requirements of 10 CFR 50, Appendix B, Criterion II, by requiring training and qualification of personnel that assures suitable proficiency in the skills necessary to perform quality verification inspections and tests is achieved and maintained. The individuals qualified in accordance with this alternative participate in an accredited SAT-based training program that meets 10 CFR 50.120.
Serial No.05-251 Response to Request for Additional Information Quality Assurance Program Description Attachment 1 Page 5 of 10 This alternative is similar to the qualification requirements documented in the basis for the Nuclear Management Company Quality Assurance Topical Report (NMC QATR) Exception A.5 for NQA-1-1994, Supplement 2S-1 in Enclosure 3 of the NMC letter dated March 31, 2003 (ML033070161). The NMC QATR provides the minimum qualifications of the inspector conducting inspections, examinations or tests that are in the same organization as that which performed the work. The approval for this alternative was originally addressed in a letter from NRC Region III to Consumers Power Company, Docket Nos. 50-155 and 50-255, dated February 27, 1992. The basis for the Dominion change is equal to that indicated in the NMC alternative in that (1) the same level of qualification is required, (2) the personnel will be required to have the necessary skills and/or have the verification requirements specified in procedures, and (3) where the work involves the breaching of a pressure boundary, additional assurance of the quality of work can be obtained through a functional test (addressed in DOM-QA-1, subsection 10.2). The inspection planning process, performed by personnel qualified in accordance with Dominions commitment to NQA-1-1994, Supplement 2S-1 and Appendix 2A-1, takes the above three factors into account by establishing who will be responsible for performing the inspection. If the above three factors can not be met, the inspection responsibility would be assigned to personnel qualified in accordance with the commitment to NQA-1-1994.
To further clarify this alternative, the information regarding the use of a qualified engineer for certain inspection activities is being stated as a separate alternative in DOM-QA-1, subsection 2.5.5 and in item 6.2 of Appendix C.
NRC Question 3 In attachment 2, page 8 describes an alternative to NQA-1-1994 Appendix 2A-1.
The alternative to the education requirement of a high school graduation is proposed to be satisfactory demonstration of reading, writing, and mathematical skills through completion of an NANT accredited training development program or an approved inspector training program for nuclear facility personnel. Provide the justification for this proposed alternative. Specifically, how is the proposed alternative equivalent to the education and experience qualifications described in section 3.1 of NQA-1-1994 Appendix 2A-1 for Level I inspectors and test personnel?
Dominion Response After further evaluation of the quality verification inspection/test programs, Dominion has determined that this alternative is no longer needed and will delete it from its QA program.
Serial No.05-251 Response to Request for Additional Information Quality Assurance Program Description Attachment 1 Page 6 of 10 to NFQAPD contains the ANSI N45.2 requirements that are addressed by NQA-1-1994 standards and/or the new QA topical report.
NRC Question 1 ANSI N45.2.12 section 4.3.2.7 states that specific attention should be given to corrective action on program deficiencies identified during previous audits. In the comments section of page 21 of 22 (Audits), it states that this requirement is not addressed in NQA-1 and that corrective action is an element evaluated in each audit as stated in the NFQAPD, Appendix C. Neither the NFQAPD nor Appendix C of the NFQAPD address this requirement. Provide an explanation as to how this requirement is met in the proposed NFQAPD.
Dominion Response The reference to Appendix C in the table is in error. The correct reference is to Section 18 of the QAPD. In particular, subsection 18.3 addresses auditing and follow-up of corrective actions for programmatic deficiencies. to NFQAPD contains the ANSI N18.7 requirements that are addressed by NQA-1-1994 standards and/or the new QA topical report.
NRC Question 1 ANSI N18.7 section 2.2 Glossary of Terms contains the following terms:
operational phase, surveillance testing, and system. Attachment 4 states that these definitions are contained in the NFQAPD, Appendix D. However, Appendix D does not contain these definitions.
Dominion Response This appears to be a clerical error. Dominions master copy of Appendix D, kept as a separate document, contained those definitions. However, the copy that was appended to the submittal document does not contain all the definitions.
DOM-QA-1, Appendix D, (in Enclosure 2) has been modified to include the missing definitions.
Serial No.05-251 Response to Request for Additional Information Quality Assurance Program Description Attachment 1 Page 7 of 10 NRC Question 2 ANSI N18.7 Section 5.2.2 Procedure Adherence discusses temporary changes which do not change the intent of the approved procedure. Attachment 4 states that this information is located in NFQAPD Section 6. However, Section 6 does not discuss temporary changes to approved procedures. Specify where this information is located.
Dominion Response The paragraph that contained the referenced information was inadvertently deleted during the last revision of this section. Section 6.4 of DOM-QA-1 (Enclosure 2) has been modified to correct the error.
NRC Question 3 ANSI N18.7 section 5.2.9 discusses plant security and visitor control. Attachment 4 states that administrative controls are established through the security measures required by regulation (10 CFR 73) and NRC orders. These regulatory requirements have superceded the requirements of ANSI N18.7. However, NFQAPD section 5.4 item (3) is a restatement of ANSI N18.7 section 5.2.9. If the requirements of ANSI N18.7 are superceded, why are they listed in NFQAPD section 5.4.
Dominion Response Through this QA program submittal, Dominion is no longer committing specifically to ANSI N18.7-1976, however Dominion is still committed to have and control, procedures of the type that are described in Appendix A of Regulatory Guide 1.33, Revision 2, which includes administrative procedures for Security and Visitor Control. ANSI N18.7-1976 did provide some general discussions of procedures for security and these have been incorporated within the NFQAPD because they do not conflict with any regulatory requirements. This ensures appropriate control of the procedures in accordance with Regulatory Guide 1.33, Revision 2. However, the commitment stated within ANSI N18.7-1976 to follow the guidance and provisions of ANSI N18.17-1973 is not being carried forward since that information has been superceded by the regulations.
Serial No.05-251 Response to Request for Additional Information Quality Assurance Program Description Attachment 1 Page 8 of 10 North Anna and Surry NRC Question 1 Section 17.2.1.2D.3.c describes the function of the Manager Nuclear Engineering. Where is this function located in the proposed NFQAPD?
Dominion Response That position responsibility is described under the broader management responsibility contained in 1.2.4.1, Nuclear Engineering, of the NFQAPD. This was necessary because there are some differences in the specific organizational structure within the Nuclear Engineering organizations for each site. However, the responsibilities are retained within the Nuclear Engineering organization and are described within the Engineering administrative procedures for the respective groups.
Millstone NRC Question 1 Section 1.3.9 of the current Millstone QA Program states that Unit No. 2 Nuclear Operations is responsible for operations regarding the Millstone Power Station, Unit No. 1 Spent Fuel Pool Island and auxiliary systems. Section 1.2.3.a of the proposed NFQAPD states that the staff for operating units may be responsible for activities related to a decommissioned units spent fuel pool and auxiliary systems, The proposed NFQAPD is no longer specific as to who is responsible for Millstone Power Station, Unit No. 1 and it could be assumed that operators at other operating facilities may have that responsibility. In addition, no basis for the change for the change was provided. Provided the basis for the change and justification for the applicability to the North Anna and Surry facilities.
Dominion Response It was not the intent to allow other operating facilities to be responsible for Millstone Unit 1. Therefore, DOM-QA-1, Subsection 1.2.3.a (Enclosure 2), has been modified to appropriately address the specific responsibilities of Millstone Unit 2 staff for Millstone Unit 1 spent fuel pool and auxiliary systems.
NRC Question 2 Section 1.3.13 of the current Millstone QA program list the radiological protection responsibilities which includes maintaining records and reports on radioactive contamination levels. This responsibility is not listed in section 1.2.3.2.b of the
Serial No.05-251 Response to Request for Additional Information Quality Assurance Program Description Attachment 1 Page 9 of 10 proposed NFQAPD. Since 1.2.3.2.b is the same wording as section 1.3.13, explain why this responsibility is no longer listed.
Dominion Response There are a number of other required records and reports that the Radiation Protection (RP) organization is responsible for that were not previously listed in the QA program. However, regulations and other commitments, such as insurance requirements, establish what records and reports must be generated.
The proposed QA program states in 1.2.3.2.b that the RP organization is responsible for maintaining required records in accordance with federal and state codes. Though not to the same level of detail, the responsibilities are the same and would include records of contamination levels that are determined through the responsibilities stated earlier in the sentence.
NRC Question 3 Section 2.1 of the current Millstone QA Program states that the QAP applies to other quality programs including Anticipated Transient Without Scram (ATWS)
Quality Assurance that is applicable to Millstone Power Station, Unit No. 2 only. And to Electrical Equipment Qualification (EEQ), as defined by company commitments. Basic Requirement 2 of NQA-1-1994 states that the program shall identify the activities and the items to which it applies. However, section 2.2 of the proposed NFQAPD does not list the above programs as being applicable.
Specify the current commitments with regards to ATWS Quality Assurance and EEQ.
Dominion Response EEQ and ATWS quality assurance for the power stations are covered by the proposed QA program through the facility listing of SSCs (currently referred to as MEPL at Millstone and Q-List or EDS at North Anna and Surry). These lists take into account the quality requirements based on the importance to safety of the item. Section 2.4 of the proposed QA program discusses these programs. They are further described in the applicable facilitys FSAR/UFSAR.
The programs controlling the SSC listing include addressing 10 CFR 50.49 requirements. In addition, NQA-1-1994, Subpart 2.4 (ANSI/IEEE Std. 336-1985),
Installation, Inspection, and Testing Requirements for Power, Instrumentation, and Control Equipment at Nuclear Facilities, considers the need to address electrical equipment qualification for the environment to which it is subjected. To clarify, the quality assurance measures applied meet the guidance of Regulatory Guide 1.97. A reference to that guide is included in the commitments of Appendix C to DOM-QA-1 (Enclosure 2).
Serial No.05-251 Response to Request for Additional Information Quality Assurance Program Description Attachment 1 Page 10 of 10 The ATWS items, although not required to meet the 10 CFR 50, Appendix B quality assurance program, are addressed through the existing procedures and practices (e.g., design control, procedures, procurement control, independent verifications (by line personnel), and special process controls) that the facilities already have in place. To clarify, the quality assurance measures applied meet the guidance of Generic Letter 85-06. A reference to that generic letter is included in the commitments of Appendix C (Enclosure 2).