ML070460215
| ML070460215 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 02/22/2007 |
| From: | Martin R NRC/NRR/ADRO/DORL/LPLII-1 |
| To: | Gasser J Southern Nuclear Operating Co |
| Martin R, NRR/DORL, 415-1493 | |
| References | |
| TAC MD2486, TAC MD2487, TAC MD2488, TAC MD2489, TAC MD2490, TAC MD2491 | |
| Download: ML070460215 (11) | |
Text
February 22, 2007 Mr. Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
Post Office Box 1295 Birmingham, Alabama 35201-1295
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2, VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION (RAI)
RE: SOUTHERN NUCLEAR OPERATING COMPANY, INCs COMMON QUALITY ASSURANCE TOPICAL REPORT (TAC NOS. MD2486, MD2487, MD2488, MD2489, MD2490 AND MD2491)
Dear Mr. Gasser:
By letter dated June 29, 2006, Southern Nuclear Operating Company, Inc., requested review and approval of the proposed combined Quality Assurance Topical Report (QATR) affecting the Joseph M. Farley Nuclear Plant, Units 1 and 2, Edwin I. Hatch Nuclear Plant, Unit Nos. 1 and 2, and Vogtle Electric Generating Plant, Units 1 and 2, quality assurance program descriptions.
The U.S. Nuclear Regulatory Commission staff has reviewed the submittal and determined that additional information is required to adequately evaluate the acceptability of the proposed changes. A listing of the requested additional information is found in the enclosure.
J. Gasser We discussed these items with your staff on February 15, 2007. Please contact me at (301) 415-1493, if you have any other questions on these issues.
Sincerely,
/RA/
Robert E. Martin, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348, 50-364, 50-321, 50-366, 50-424 and 50-425
Enclosure:
Request for Additional Information cc w/encl: See next page
J. Gasser February 22, 2007 We discussed these items with your staff on February 15, 2007. Please contact me at (301) 415-1493, if you have any other questions on these issues.
Sincerely,
/RA/
Robert E. Martin, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348, 50-364, 50-321, 50-366, 50-424 and 50-425
Enclosure:
Request for Additional Information cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsNrrPMRMartin (hard copy)
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Edwin I. Hatch Nuclear Plant, Units 1 & 2 cc:
Mr. Dennis R. Madison Vice President - Hatch Edwin I. Hatch Nuclear 11028 Hatch Parkway North Baxley, GA 31513 Laurence Bergen Oglethorpe Power Corporation 2100 E. Exchange Place P.O. Box 1349 Tucker, GA 30085-1349 Mr. R. D. Baker Manager - Licensing Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Resident Inspector Plant Hatch 11030 Hatch Parkway N.
Baxley, GA 31531 Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE., Suite 1252 Atlanta, GA 30334 Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, GA 30328-4684 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission 244 Washington St., SW Atlanta, GA 30334 Arthur H. Domby, Esq.
Troutman Sanders Nations Bank Plaza 600 Peachtree St, NE, Suite 5200 Atlanta, GA 30308-2216 Chairman Appling County Commissioners County Courthouse Baxley, GA 31513 Mr. Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. Dennis R. Madison, General Manager Edwin I. Hatch Nuclear Plant Southern Nuclear Operating Company, Inc.
U.S. Highway 1 North P.O. Box 2010 Baxley, GA 31515 Mr. K. Rosanski Resident Manager Oglethorpe Power Corporation Edwin I. Hatch Nuclear Plant P.O. Box 2010 Baxley, GA 31515
Joseph M. Farley Nuclear Plant, Units 1 & 2 cc:
Mr. J. Randy Johnson Vice President - Farley Joseph M. Farley Nuclear Plant 7388 North State Highway 95 Columbia, AL 36319 Mr. B. D. McKinney, Licensing Manager 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. J. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201 State Health Officer Alabama Department of Public Health 434 Monroe St.
Montgomery, AL 36130-1701 Chairman Houston County Commission P.O. Box 6406 Dothan, AL 36302 Resident Inspector U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, AL 36319 William D. Oldfield SAER Supervisor Southern Nuclear Operating Company, Inc.
P.O. Box 470 Ashford, AL 36312
Vogtle Electric Generating Plant, Units 1 & 2 cc:
Mr. Tom E. Tynan Vice President - Vogtle Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830 Mr. N. J. Stringfellow Manager, Licensing Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, GA 30328-4684 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission 244 Washington St., SW Atlanta, GA 30334 Mr. Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE, Suite 1252 Atlanta, GA 30334 Attorney General Law Department 132 Judicial Building Atlanta, GA 30334 Mr. Laurence Bergen Oglethorpe Power Corporation 2100 East Exchange Place P.O. Box 1349 Tucker, GA 30085-1349 Arthur H. Domby, Esquire Troutman Sanders Nations Bank Plaza 600 Peachtree Street, NE Suite 5200 Atlanta, GA 30308-2216 Resident Inspector Vogtle Plant 8805 River Road Waynesboro, GA 30830 Office of the County Commissioner Burke County Commission Waynesboro, GA 30830
Enclosure REQUEST FOR ADDITIONAL INFORMATION REGARDING THE SOUTHERN NUCLEAR OPERATING COMPANY, INC.s (SNOCs)
COMMON QUALITY ASSURANCE PROGRAM The Nuclear Regulatory Commission (NRC) staff reviewed Southern Nuclear Operating Company, Incs (SNCs), Quality Assurance Topical Report (QATR) and developed the following list of requests for additional information (RAIs) in order to determine whether the licensee satisfies the requirements of Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Appendix B. The discussion below is organized by the enclosures to the QATR submittal, as indicated in each heading.
RAIs from Enclosure 1 of SNCs QATR PART I INTRODUCTION 1.
Part 1, Section 1.4 of the QATR commits to compliance with NQA-1-1994, Quality Assurance Requirements for Nuclear Facility Applications. SNC utilizes the terms and definitions provided in NQA-1-1994 with the exception of the term "verification."
Appendix D to the QATR provides additional definitions of terms used in the QATR that are not contained in the NQA-1-1994 definitions, in that the QATR proposes to use the terms "independent verification" and "concurrent verification" instead of the term "verification." Provide the bases for the proposed definitions of "independent verification" and "concurrent verification," and why they are acceptable.
PART II QA PROGRAM DESCRIPTION (QAPD) DETAILS Section 1 Organization 2.
The Three Mile Island (TMI)-related requirement contained in 10 CFR 50.34(f)(3)(iii)(F) requires ensuring that the size of the QA organization is commensurate with its duties and responsibilities. Clarify how the QATR provides for ensuring that the QA organization is sized commensurate with its duties and responsibilities.
Section 2 Quality Assurance Program 3.
The QATR proposes an alternative to Supplement 2S-1 that would allow a qualified engineer to plan an inspection, evaluate the capabilities of an inspector, or evaluate the training program for inspectors. Provide a bases for why the use of an engineer to perform these functions is acceptable.
4.
Section 2.4 of the QATR establishes a commitment to NQA-1-1994, Basic Requirement 2, and its supplements with clarifications and exceptions to these requirements. As an exception the QATR proposes that nondestructive examination (NDE) personnel will follow the applicable standard cited in the version(s) of the American Society of Mechanical Engineers (ASME), Pressure and Vessel Code (Code),Section XI. Provide a bases for why the Supplement 2S-2 alternative regarding the qualification of NDE personnel does not include Section III of the ASME Code.
Section 3 Design Control 5.
The TMI-related requirement contained in 10 CFR 50.34(f)(3)(iii)(C) requires that QA personnel are included in the documented review and concurrence of quality-related procedures associated with design, construction, and installation.
Clarify how the QATR implements measures to control the documented review and concurrence of quality-related procedures.
Section 4 Procurement Document Control 6.
Section 4.2 of the QATR establishes a commitment to NQA-1-1994, Basic Requirement 4, and Supplement 4S-1, and includes clarifications and exceptions to these requirements. As an exception, the QATR proposes that "the quality assurance review of procurement documents is satisfied through review of the applicable procurement specifications, including the technical and quality procurement requirements, prior to bid or award of contract." This exception does not specify if procurement documents as well as changes to procurement documents will be part of the proposed QA review. Clarify how the proposed QA review of procurement documents includes reviews of procurement document changes.
Section 6 Document Control 7.
ANSI Standard N18.7-1976, "Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," (ANSI N18.7) specifies that there should be coordination and control of interface documents. The QATR no longer commits to the requirements of ANSI N18.7. Clarify how the QATR addresses the coordination and control of interface documents.
Section 7 Control Of Purchased Material, Equipment, and Services 8.
Section 7.2 of the QATR proposes to use an alternate method for procurement of commercial-grade calibration services for safety-related applications in lieu of performing a supplier audit, commercial-grade survey, or in-process surveillance for calibration laboratory accredited by the National Voluntary Laboratory Accreditation Program (NVLAP) or American Accreditation of Laboratory Associates (A2LA), as recognized by NVLAP through a Mutual Recognition Arrangement (MRA).
a.
An MRA is a generic term referring to a conformity assessment process.
For assessment of calibration laboratories, the NRC has found the International Laboratory Accreditation (ILAC) MRA to be an acceptable alternative. The alternative previously approved by the NRC does not include MRAs administered under other programs. Clarify which MRA the QATR proposes to use.
b.
The NRC has approved this alternative only to be used with domestic accredited calibration service suppliers. Clarify how the QATR will implement the procurement of commercial-grade calibration services consistent with the previously approved alternative.
Section 16 Corrective Action 9.
Section 3.2 of ANSI N18.7 specifies that the corrective action program shall include provisions for all personnel to identify conditions that are adverse to quality. The QATR no longer commits to the requirements of ANSI N18.7. Clarify how the QATR provides for all personnel to identify conditions that are adverse to quality.
Section 18 Audits
- 10. NRC's previously approved provision states that "a general grace period of 90 days may be applied to provisions that are required to be performed on a periodic basis unless otherwise noted. Annual evaluations and audits that must be performed on a triennial basis are examples where the 90-day general grace period could be applied. The grace period does not allow the "clock" for a particular activity to be reset forward. The "clock" for an activity is reset backwards by performing the activity early." Section 18.1 of the QATR provides provisions for the performance of audits. The QATR incorporates a grace period of 25 percent to be applied to provisions that are required to be performed on a periodic basis. Describe the bases and acceptability of the provision for the 25 percent grace period stated in the QATR.
- 11. Section 18.1 of the QATR provides measures and frequencies for audits and evaluations of suppliers. The QATR provides a 36-month interval for audits of supplier activities, and 12-month interval for evaluation of supplier activities. In addition, the QATR allows for a maximum extension not to exceed 25 percent of the audit or evaluation. The combined time interval for any three consecutive audit or evaluation intervals should not exceed 3.25 times the specified audit or evaluation interval.
a.
Clarify what is included in an evaluation of a supplier and if the evaluation will be documented.
b.
Provide bases for the allowed extension period provided in the QATR for audits and evaluations of suppliers.
- 12. Section 3.1 of ANSI N18.7 specifies that when any work carried out under the requirements of the QA program is delegated to others, the work is to be audited by the QA audit program. Clarify how the QATR will provide measures to address the audit of QA programs delegated to others.
- 13. NRC Regulatory Guide 1.33, "Quality Assurance Program Requirements," Revision 2, provides a frequency of 12 months for audits of facilities conformance with Technical Specifications and for audits of performance, training, and qualifications of the facility personnel. Provide the bases for the proposed extended audit frequencies provided in Section 18.1. of SNCs QATR: Description of Proposed Changes/Basis For Concluding The Revised Program Continues To Satisfy 10 CFR, Part 50, Appendix B
- 14. As stated in 10 CFR 50.54(a)(3)(ii), the use of a QA alternative, clarification or exception approved by an NRC safety evaluation, provided that the bases of the NRC approval are applicable to the licensee's facility, is not considered to be a reduction in commitment. The NRC staff needs to understand how the bases of the NRC approval are applicable to the licensee's individual facilities. A statement that the bases are met is not adequate. For each of the alternatives, clarifications and exceptions mentioned in Enclosure 2, Sections 4.2 and 4.3, provide the bases for each affected operating nuclear facility. These bases should include information for each of the alternatives, clarifications or exceptions on the current commitment for each facility and explain why it is acceptable.
Examples of how to address providing bases for the proposed alternative, clarification or exception may be found in Dominion's QA Consolidation submittal,, "Description of Changes," and the associated supplemental document dated August 24, 2004, and May 05, 2005, respectively, and Constellation's Common QATR, Attachment 4, and the associated supplemental documents dated December 5, 2005, and September 1, 2006, respectively.
- 15. Paragraphs 4.2.7(b) and 4.2.8 of Enclosure 2 provide an alternate method for items requiring labeling or tagging. Provide an explanation of why the same alternative is taken for two different applications, and why it is acceptable.
RAIs From Enclosure 3 of SNCs QATR: Existing QA Programs Versus QATR Comparison Matrix
- 16. In Enclosure 3 of the QATR, SNC proposes moving the Vogtle QA program section 17.2.17.1, "Record Retention," to the Final Safety Analysis Report (FSAR), Chapter 13, "Conduct of Operation." Section 17 of the proposed QATR has a commitment to Regulatory Guide 1.28 under Record Retention, which includes guidance on the retention period for the different types of documents. The staff finds that would be appropriate, that the details be included in the implementing procedures instead of FSAR Chapter 13. Explain the basis for moving this information to Chapter 13 of the FSAR and why taking this information out of the FSAR could result in a change to the license design bases.
RAIs From Enclosure 5 of SNCs QATR: ANSI N18.7-1976 Conformance Matrix
- 17. Regulatory Guide 1.33 specifies a minimum audit frequency of 6-months for audits of corrective actions affecting safety-related equipment, 12-months for audits of facilities conformance with Technical Specifications, and 12-months for audits of performance, training, and qualifications of the facility personnel. In order for the staff to determine the acceptability of the proposed audit program, describe the bases for scheduling audits with the proposed performance-based program, as outlined in Section 4.3 of Enclosure 5 and how it comports with the audit program outlined in Section 18.1 of Enclosure 1.
- 18. Section 5.2.15 of ANSI N18.7, "Review, Approval and Control of Procedures,"
specifies the following:
In order to ensure that the procedures in current use provide the best possible instructions for performance of the work involved, systematic review and feedback of information based on use is required.
The proposed QATR submittal, as stated in the comparison to ANSI N18.7 in Enclosure 5, does not appear to address procedure feedback.
Plant procedures shall be reviewed by an individual knowledgeable in the area affected by the procedure no less than every 2 years to determine if changes are necessary or desirable. The proposed QATR submittal, as outlined in the comparison to ANSI N18.7 in Enclosure 5, does not appear to address the 2-year procedure review.
Provide additional information describing how these requirements of ANSI N18.7 are met by the proposed QATR.