ML051570349
| ML051570349 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 06/17/2005 |
| From: | Martin R NRC/NRR/DLPM/LPD2 |
| To: | Gasser J Southern Nuclear Operating Co |
| Martin R, NRR/DLPM, 415-1493 | |
| References | |
| TAC MC5666, TAC MC5667, TAC MC5668, TAC MC5669, TAC MC5670, TAC MC5671 | |
| Download: ML051570349 (9) | |
Text
June 17, 2005 Mr. Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201-1295
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2, AND VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 - SAFETY EVALUATION RE: PROPOSED CHANGE TO THE QUALITY ASSURANCE PROGRAM (TAC NOS. MC5666, MC5667, MC5668, MC5669, MC5670, AND MC5671)
Dear Mr. Gasser:
By letters dated December 23, 2004, and April 28, 2005, Southern Nuclear Operating Company (SNC) requested a revision to the Quality Assurance Program for the Joseph M. Farley Nuclear Plant, Edwin I. Hatch Nuclear Plant, and Vogtle Electric Generating Plant. The submittal proposed to make changes to the independent review program and the audit program.
The Nuclear Regulatory Commission (NRC) staff has completed its review of the changes to the quality assurance programs, described in SNCs submittals. The NRC staff concludes that the programs conform to the acceptance criteria of NUREG-0800, Sections 13.4 and 17.2, and that they continue to satisfy the quality assurance requirements of Appendix B to 10 CFR Part 50. The proposed changes are, therefore, acceptable.
Please contact me at (301) 415-1493, if you have any other questions on these issues.
Sincerely,
/RA/
Robert E. Martin, Senior Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-348, 50-364, 50-321, 50-366 50-424, and 50-425
Enclosure:
Safety Evaluation cc w/encl: See next page
ML051570349 NRR-043 OFFICE PDII-1/PM PDII-1/LA PDII-1/SC NAME RMartin CHawes EMarinos DATE 06/ 17 /05 06/ 17 /05 06/ 17 /05
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION PROPOSED CHANGE TO THE QUALITY ASSURANCE PROGRAM COMMON SAFETY REVIEW BOARD CONDUCT OF OPERATIONS SOUTHERN NUCLEAR OPERATING COMPANY, INC.
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2 EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-348, 50-364, 50-321, 50-366, 50-424, AND 50-425
1.0 INTRODUCTION
By letter dated December 23, 2004, (Reference 1), Southern Nuclear Operating Company, Inc.
(SNC) submitted a revision to the quality assurance (QA) programs described in Chapter 17.2 of the Updated Final Safety Analysis Reports (UFSARs) for Joseph M. Farley (Reference 2),
Edwin I. Hatch Unit 2 (Reference 3), and Vogtle Electric Generating Plant (Reference 4). The submittal is supplemented by SNC letter dated April 28, 2005 (Reference 5), which responds to a request for additional information from the Nuclear Regulatory Commission (NRC) staff.
SNC has reorganized its Safety Review Board (SRB) into a single body for the independent offsite review of plant safety for all SNC nuclear power facilities. Associated with this reorganization, SNC proposes to revise the QA programs for the referenced facilities to reflect a common standard conduct of operations for the SRB. The SRB code of operation is described in Chapter 17.2 of the Farley and Vogtle UFSARs and in Chapter 13.4 of the Hatch UFSAR.
SNC has characterized four changes to the QA programs and independent review process as reductions in commitment that, pursuant to the provisions of Title 10 of the Code of Federal Regulations (10 CFR) Section 50.54, Conditions of licenses, paragraph 50.54(a)(4), are subject to review and approval by the NRC staff prior to their implementation.
2.0 REGULATORY EVALUATION
The NRC staffs review and evaluation of licensee programs for conducting reviews of operating phase activities are conducted in accordance with NUREG-0800, Standard Review Plan, Section 13.4, Operational Review. Provisions for independent review are described in Section 4.3 of ANSI N18.7, Administrative Controls and Quality Assurance Requirements for the Operational Phase of Nuclear Plants.
The Hatch and Vogtle operational QA programs follow the guidance of ANSI N18.7-1976, as endorsed by Regulatory Guide (RG) 1.33, Revision 2. The Farley QA program also follows the guidance of ANSI N18.7-1976 in implementing the independent review program, as stated in the list of regulatory commitments that are included as Enclosure 4 of SNCs submittal.
The NRC staffs review and evaluation of licensee operational QA programs are conducted in accordance with NUREG-0800, Section 17.2, Quality Assurance During the Operational Phase.
3.0 TECHNICAL EVALUATION
SNC proposes to make four changes, characterized as reductions in commitments, to the QA programs for the Farley, Hatch, and Vogtle nuclear power plants.
Adoption of a standard conduct of operations for the Safety Review Board, Adoption of a standard program of QA audits, Revision of maximum audit intervals, and Adoption of standard criteria for maximum extending audit intervals.
3.1 Standard Conduct of Operations for the Safety Review Board (Change 1)
SNC identifies one change, characterized as a reduction in commitment, in standardizing the SRB conduct of operations. The change is described as follows:
The requirement for the SRB to review reports and meeting minutes of the Plant Review Board (PRB) has been replaced with a commitment to review PRB performance.
Evaluation Subjects requiring independent review by the independent review body are described in Section 4.3.4 of ANS N18.7-1976. Review of the reports and minutes of the onsite operating organization (Plant Review Board) is not an explicit requirement of Section 4.3.4. A performance-based review of the activities of the PRB is an acceptable alternative to review of documentation.
3.2 Standard Program of QA Audits (Change 2)
The QA program descriptions for the SNC plants include audits under SRB cognizance plus a number of more specific topics which are different for each plant. SNC proposes to adopt a standard list description of QA audit topics. SNC states that adoption of a standard description of audit topics would not reduce the scope or effectiveness of the audit program.
Evaluation Section 4.5 of ANSI N18.7-1976 specifies that a comprehensive system of planned and documented audits shall be carried out to verify compliance with all aspects of the administrative controls and QA program.
A list of audit topics conducted under the Farley QA program is contained in Table 17.2.2 of the current Farley UFSAR. A list of audit topics conducted under the Hatch QA program is contained in Section 13.4.B.6 of the current Hatch UFSAR. A list of audits conducted under the Vogtle QA program is contained in Section 17.2.18.1 of the current Vogtle UFSAR. The Hatch and Vogtle lists contain at least the audit topics in the Farley UFSAR plus a number of more specific audit topics. The additional topics address specific audits required by the operational QA program to meet the criteria of 10 CFR Part 50, Appendix B, or the requirements of regulations other than Part 50.
To establish a standard set of QA audit topics, SNC proposes to maintain the list of Farley audits, while subsuming the description of additional audits conducted to verify compliance with all aspects of the administrative controls and QA program under the general category of audits of the performance of all activities required by the operations quality assurance program to meet the criteria of 10 CFR Part 50, Appendix B, which is item four on the Farley list of required audits.
SNCs letter of April 28, 2005, provides additional information for each of the audits deleted from the QA program description. Audits performed in compliance with 10 CFR Part 50, Appendix B, will continue to be performed, but not specifically listed. Four audit topics identified in Enclosure 3 of the letter are required by other regulations: 1) fitness for duty, which is covered by the regulation at 10 CFR Part 26; 2) special nuclear materials covered by the regulation at 10 CFR 74.31; 3) industrial safety, which is covered by the regulation at 20 CFR Part 1910; and 4) radioactive material packages, which is covered by the regulation at 10 CFR 71.137.
The list of audit topics contained in the Farley QA program description is consistent with the guidance of ANS N18.7-1976, Section 4.5, Audit Program. For the purpose of standardizing the list of audit topics, the additional detail provided by the Hatch and Vogtle lists may be dropped. The proposed list of audit topics is similar to the list of audits identified in Section 5.5.2, Review and Audits of the Standard Technical Specifications (NUREG-1431, Rev 0). The licensee will continue to conduct the audits required to meet the criteria of 10 CFR Part 50, Appendix B. The four audit topics identified above as outside the scope of Appendix B may be dropped since they are addressed by other regulations. The revised list of audits will be located in UFSAR Section 17.2.18.1 for all three SNC plants. The changes identified under Change 2 of SNCs submittal are acceptable.
3.3 Revision of Maximum Audit Intervals (Change 3)
SNC proposes to adopt a maximum 24-month audit interval, except where noted.
Evaluation Section 4.5 of ANS N18.7-1976 specifies that audits of selected aspects of operational phase activities shall be performed with a frequency commensurate with their safety significance and in such a manner as to assure that an audit of all safety-related functions is completed within a period of 24 months. Regulatory position four of RG 1.33 imposes more restrictive audit frequencies in the areas of correction of deficiencies, conformance of facility operations to technical specifications and license conditions, and training and qualifications of facility staff.
When the review and audit requirements for SNCs plants were relocated from the technical specifications to the QA program under the Improved Technical Specification Program, the relocations were performed in accordance with NRC Administrative Letter (AL) 95/06. AL 95-06 states that audit frequencies may be revised by implementation of a performance-based schedule (schedule adjusted according to objective evaluation of plant functional area performance), provided that the maximum audit interval does not exceed the 24-month interval specified in ANSI N18.7. Exceptions to the allowable use of performance-based audit frequencies are those audit intervals defined by regulations, such as regulations governing the emergency and security plans.
SNC implements a performance-based audit scheduling process that supports a maximum audit interval of 24 months for those audits identified by AL 95-06. SNCs performance-based audit programs are discussed in proposed revisions to Section 17.2.18.1 of the Hatch, Vogtle and Farley UFSARs.
A similar change in maximum audit intervals, based on performance-based audit scheduling, has been previously approved by the NRC staff (Reference 6). The proposed implementation of a maximum 24-month interval for the specified audits is consistent with the guidance of AL 95-06 and is, therefore, acceptable.
3.4 Standard Criteria for Extending Audit Intervals (Change 4)
The licensee has proposed the following standard criteria for extending audit intervals.
A.
Audits shall be performed at the intervals designated herein for each audit area. Schedules shall be based on the month in which the audit starts.
B.
A maximum extension not to exceed 25 percent of the audit interval shall be allowed. That is to say that, for audits on a 24-month frequency, the maximum time between specific audits shall not exceed 30 months.
Likewise, audits on an annual (12 month) frequency shall not be extended beyond 15 months.
C.
When an audit interval extension greater than one month is used, the next audit for that particular audit area will be scheduled from the original anniversary month rather than from the month of the extended audit.
D.
Item B shall also apply to supplier audits and evaluations except that a total combined time interval for any three consecutive inspection or audit intervals should not exceed 3.25 times the specified inspection or audit interval.
Evaluation Two of SNCs facilities have existing provisions for extending audit intervals by 25 percent though the wording differs slightly from the standard criteria above. The proposed criteria would standardize provisions for all facilities, clarify the current criteria that are subject to interpretation, and provide the flexibility to more effectively manage the audit schedule without reducing the effectiveness of the audit program. Similar audit extension provisions have been previously approved by the NRC staff (Reference 7). The audit interval extension provision conforms to the requirements of Appendix B to 10 CFR Part 50 and is consistent with the NRC staff guidance for reviewing audit programs, as delineated in Section 17.2 of NUREG-0800.
The proposed change is, therefore, acceptable.
4.0 CONCLUSION
Based on review of the changes to the QA programs, described in SNCs submittals, the NRC staff concludes that the programs conform to the acceptance criteria of NUREG-0800, Sections 13.4 and 17.2, and continue to satisfy the QA requirements of Appendix B to 10 CFR Part 50. The proposed changes are, therefore, acceptable.
5.0 REFERENCES
1.
Letter from Southern Nuclear Operating Company, Inc., to the U.S. NRC, Common Safety Review Board Conduct of Operation, December 23, 2004.
2.
UFSAR, Farley Nuclear Plant, Chapter 17.2, Operations Quality Assurance Program, Revision 18.
3.
UFSAR, Hatch Nuclear Plant, Chapter 17.2, Quality Assurance During the Operations Phase, Revision 22.
4.
UFSAR, Vogtle Nuclear Plant, Chapter 17.2, Operations Quality Assurance Program, Revision 12.
5.
Letter from Southern Nuclear Operating Company, Inc., to the U.S. NRC, Response to Request for Additional Information Regarding Proposed Change to the Quality Assurance Program, April 28, 2005.
6.
U.S. NRC letter to Boston Edison Company, Issuance of Amendment No. 168 to Facility Operating License No. DPR-35, Pilgrim Nuclear Power Station, November 12, 1996.
7.
U.S. NRC letter to Rochester Gas and Electric, Approval of Proposed Revision to the RG&E Corporations R.E. Ginna Nuclear Power Plant Quality Assurance Program for Station Operation, July 22, 1998.
Joseph M. Farley Nuclear Plant Edwin I. Hatch Nuclear Plant Vogtle Electric Generating Plant cc:
Mr. Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201 Mr. Raymond D. Baker Manager - Licensing Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201 Mr. J. R. Johnson General Manager Southern Nuclear Operating Company, Inc.
P.O. Box 470 Ashford, AL 36312 Mr. H. L. Summer, Jr.
Vice President - Nuclear Hatch Project Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. L. M. Stinson Vice President - Farley Project Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. M. Stanford Blanton Balch and Bingham Law Firm P.O. Box 306 1710 Sixth Avenue North Birmingham, AL 35201 Mr. B. D. McKinney, Licensing Manager Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Page 1 of 2 William D. Oldfield SAER Supervisor Southern Nuclear Operating Company, Inc.
P.O. Box 470 Ashford, AL 36312 Resident Inspector Hatch Project 11030 Hatch Parkway North Baxley, GA 31513 Resident Inspector Farley Nuclear Plant U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, AL 36319 Laurence Bergen Oglethorpe Power Corporation 2100 E. Exchange Place P.O. Box 1349 Tucker, GA 30085-1349 Mr. Harold Reheis, Director Department of Natural Resources 205 Butler St, SE, Suite 1252 Atlanta, GA 30334 Chairman Appling County Commissioners County Commissioners Baxley, GA 31513 Office of the County Commissioners Burke County Commission Waynesboro, GA 30830 State Health Officer Alabama Department of Public Health 434 Monroe St.
Montgomery, AL 36130-1701
Joseph M. Farley Nuclear Plant Edwin I. Hatch Nuclear Plant Vogtle Electric Generating Plant cc:
Chairman Houston County Commission P.O. Box 6406 Dothan, AL 36302 Mr. Arthur H. Dombay, Esq.
Troutman Sanders Nations Bank Plaza 600 Peachtree St, NE Suite 5200 Atlanta, GA 30308 Resident Inspector Vogtle Plant 8805 River Road Waynesboro, GA 30830 Mr. Steven M. Jackson Senior Engineer -Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, GA 30303-4684 Mr. G. R. Frederick, General Manager Edwin I. Hatch Nuclear Plant Southern Nuclear Operating Company, Inc.
U.S. Highway 1 North P.O. Box 2010 Baxley, GA 31515 Page 2 of 2 Mr. Reece McAllister Executive Secretary Georgia Public Service Commission 244 Washington St., SW Atlanta, GA 30334 Mr. D. E. Grissette, Vice President Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201 Mr. K. Rosanski, Resident Manager Oglethorpe Power Corporation Edwin I. Hatch Nuclear Plant P.O. Box 2010 Baxley, GA 31515 Mr. N.J. Stringfellow, Manager-Licensing Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. Skip Kitchens, General Manager Vogtle Electric General Plant Southern Nuclear Operating Company, Inc.
P.O. Box 1600 Waynesboro, GA 30830 Attorney General Law Department 132 Judicial Building Atlanta, GA 30334