ML062890059
| ML062890059 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs, Nine Mile Point, Ginna  |
| Issue date: | 10/09/2006 |
| From: | Montgomery B Constellation Energy Group, Constellation Generation Group |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| TAC MC9180, TAC MC9181, TAC MC9182, TAC MC9183, TAC MC9184 | |
| Download: ML062890059 (3) | |
Text
Constellation Generation Group 1997 Annapolis Exchange Parkway Suite 310 Annapolis, MD 21401 410-897-5189 0Constellation Energy, Generation Group October 9, 2006 U.S. Nuclear Regulatory Commission 11555 Rockville Pike Rockville, MD 20852 ATTENTION:
Document Control Desk
SUBJECT:
Calvert Cliffs Nuclear Power Plant Unit Nos. I & 2; Docket Nos. 50-317 & 50-318 Nine Mile Point Nuclear Station Unit Nos. I & 2; Docket Nos. 50-220 & 50-410 R.E. Ginna Nuclear Power Plant Docket No. 50-244 Response to Request for Additional Information Regarding Common Quality Assurance Program (TAC Nos. MC9180, MC9181, MC9182, MC9183, and MC9184)
REFERENCES:
(a)
Letter from J.M. Heffley (CGG) to Document Control Desk (NRC),
Request for Approval of a Common Quality Assurance Program for Constellation Generation Group, LLC, dated December 5, 2005 (b)
Letter from P.D. Milano (NRC) to J.M. Heffley (CGG), Calvert Cliffs Nuclear Power Plant, Unit Nos. 1 and 2, Nine Mile Point Nuclear Station, Unit Nos. 1 and 2, and R.E. Ginna Nuclear Power Plant - Request for Additional Information Regarding Common Quality Assurance Program (TAC Nos. MC9180, MC9181, MC9182, MC9183, and MC9184), dated May 15, 2006 (c)
Letter from J.M. Heffley (CGG) to Document Control Desk (NRC),
Response to Request for Additional Information Regarding Common Quality Assurance Program (TAC Nos. MC9180, MC9181, MC9182, MC9183, and MC9184, dated September 1, 2006 (d)
Telephone conference between P.D. Milano, et al (NRC) and B.S. Montgomery, et al (CGG) on September 21, 2006.
Reference (a) submitted a common Quality Assurance Topical Report (QATR), pursuant to Title 10 of the Code of Federal Regulations 50.54(a), for Calvert Cliffs Nuclear Power Plant, Units I and 2 (Calvert Cliffs), Nine Mile Point Nuclear Station, Units 1 and 2 (Nine Mile Point), and R.E. Ginna Nuclear Power9oDo!
Document Control Desk October 9, 2006 Page 2 Plant (Ginna). The program described in the QATR would be applied to licensed activities under 10 CFR Parts 50, 71, and 72.
Reference (b) requested additional information to assist the Nuclear Regulatory Commission (NRC) in their review of Reference (a). Reference (c) submitted the information requested in Reference (b).
In a telephone conference between NRC and Constellation Energy staff, (Reference d), NRC staff requested additional information on the bases for Exceptions 9 and 11. The bases for Exceptions 9 and 11 for Calvert Cliffs, Nine Mile Point and Ginna are provided below.
Exception 9 - Exception to ANSI N45.2.4-1972, Section 6.2.1 regarding calibration stickers.
This exception is based on changes to plant quality assurance programs that were evaluated to not be reductions in commitment.
The bases for the evaluations that they do not constitute a change in commitment was not communicated to the NRC since licensees are allowed by 10 CFR 50.54(a)(3) to make a change to a previously accepted quality assurance program description without prior NRC approval, provided the change does not reduce the commitments in the program description as accepted by the NRC. The NRC asked, in Reference (d), that we provide the bases to be used in their review of this exception. The following paragraphs provide that information.
At Calvert Cliffs, the use of a data base instead of calibration stickers placed on plant instrumentation was introduced in Revision 41 to the Quality Assurance Policy dated July 8, 1994 and was evaluated to not be a reduction in commitment. The basis for this evaluation was that, in the past, the date of calibration noted on the instrument was important because the calibration history of preventive maintenance was not kept on computer as computer tracking systems and trending programs did not exist. Now that computers can be used to track equipment, the date of calibration on a sticker is not necessary because the date of calibration and the identity of the person who performed the calibration are retrievable by the equipment identification code. Tracking and scheduling calibrations of instruments by computer allows use of a real predictive and preventive maintenance calibration program.
Calibration frequencies can be adjusted based on calibration history, vendor's recommendations, and instrument use.
At Nine Mile Point, the use of a data base for calibration information was part of Revision I to the Quality Assurance Topical Report, which was approved by the NRC in a letter dated December 31, 1985.
The basis was that, in some instances, size or locations of installed plant instrumentation precludes attaching calibration labels directly on the instrument.
The inclusion of this exception into the Fleet QATR extends the exception to Ginna and is acceptable because it will be implemented with the same controls and process as currently in place at Calvert Cliffs and Nine Mile Point.
Exception 11 - Exception to Regulatory Position C.4 of Regulatory Guide 1.33, Revision 2 regarding performing biennial audits in lieu of the six and twelve month audit frequencies specified for some activities.
For this exception, the NRC requested that we identify all the correspondence involved in the submittal of the changes that form a basis for the exception. The following paragraphs provide that information.
At Calvert Cliffs, this change to the Quality Assurance Policy was submitted along with a license amendment request on March 15, 1995. The license amendment request transferred audit requirements to the Quality Assurance Policy. This request was modified by Calvert Cliffs on May 1, 1996 to align the Technical Specification change with the Improved Standard Technical Specifications and to align the
Document Control Desk October 9, 2006 Page 3 Quality Assurance Policy with NRC Administrative Letter 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance."
The basis was that the more frequent audit intervals do not allow management the flexibility to devote auditing resources consistent with the strength of performance and safety significance of an activity. As a result, experience has shown that some audits are performed more frequently than deemed appropriate for the function. The Quality Assurance Policy change was approved by NRC Region I on September 25, 1996.
At Nine Mile Point, this change was submitted in Revision 19 to the Quality Assurance Topical Report, which is Appendix B to the Unit I Updated Final Safety Analysis Report, on October 24, 2005. The basis was that Nine Mile Point had a mature quality assurance program, an experienced and skilled staff, procedures that yield predictable results, and a stable work force. The change would also align Nine Mile Point with the other Constellation Generation Group nuclear plants to facilitate scheduling and implementation of coordinated fleet audits. The change was consistent with a Quality Assurance Program change submitted by New York Power Authority for James A. Fitzpatrick Nuclear Power Plant on December 9, 1998 and approved by the NRC on March 25, 1999.
At Ginna, the change was submitted on December 21, 1994 as Revision 21 to the Quality Assurance Program. This submittal was resubmitted in a letter dated March 10, 1995. The basis for this change was to allow the audit frequency to be adjusted based on safety significance and the assessed area's performance. The change was approved by NRC Region I on March 22, 1995.
Should you have any questions regarding the information in this submittal, please contact Mr. B.S. Montgomery at (410) 897-5189 or Bruce.S.Montgomery@constellation.com.
Very truly yours, Man er - Fleet Quality and Performance Assessment BSM/EMT/jmp cc:
P. D. Milano, NRC T. G. Colbum, NRC S. J. Collins, NRC R. 1. McLean, Maryland DNR Resident Inspector, NRC (Ginna)
J. P. Spath, NYSERD Resident Inspector, NRC (Calvert Cliffs)
P. Eddy, NYS Dept. of Public Services Resident Inspector, NRC (NMPNS)