ML081990367

Handouts from Duke Energy & NRC Meeting - NQA-1 Based QA Program Conversion

ML081990367
Person / Time
Site:	Oconee, Mcguire, Catawba, McGuire
Issue date:	07/15/2008
From:	Duke Energy Corp
To:	Office of Nuclear Reactor Regulation
References
Download: ML081990367 (29)

Text

luke vinergy NQA-1 Based QA Program Conversion Duke Energy & NRC Meeting July 15, 2008 1

kDuke Em'aD'k VEnergy Agenda

" Introductions

" Meeting Purpose

" Conversion Reasons

" Conversion Methodology

" Submittal Package

" Schedule

" Closing Remarks 2

Duke Conversion Team

- Energy 11-1, 1 . - ý .

WHIM ý

" Jim Fisicaro - NRC Interface

" Bob Gill - Licensing Manager mJerry Standridge - QA SPOC mKevin Rhyne- Team Lead m40 Contributors - QA Criteria SMEs, m Management Review Team 3

Duke Meeting Pu rpose SEnergy 0 Commu nicate Duke's plan to convert the operating plant fleet to an ASME NQA-1 -1994 based QA program

• Share QA program conversion methodology

• Obtain NRC feedback prior on QAPD package completion and submittal 4

F"Duke SCEn e Energ rf y Conversion Reasons

" Adopt a more current standard, incorporating years of industry operating experience

" Use a single, comprehensive, and actively maintained standard

" Benefit from a simpler, easier to understand standard

" Synchronize with the currently approved standard for new plant construction and operation

" Obtain consistency with the QAPD for new plant licensing (e.g. Lee Nuclear)

" Conform with the utility conversion trend 5

Duke Conversion Energy Methodology

" Meet 10CFR50, Appendix B requirements for a QA Program Description -(QAPD)

" Use NQA-I standard and NEI 06-14A template as proposed QAPD basis to establish. an equivalent QA program-

• Address differences -between current QATR-and proposed QAPD documents 6

Energy Duke Conversion Methodology (Continued)

" NEI 06-14A QAPD revisions 4 & 5 used as a template.for the operating fleet program

" Duke specifics replaced bracketed template text with additional information inserted as needed to fully describe the program

" Comparison matrix developed to show where current QATR commitments are addressed within proposed QAPD 7

PDuke Conversion OEnergy Methodology (Continued)

Quality Assurance Program Description Comparison Matrix Column 1 Column 2 Column 3 Column 4 Column 5 Current QATR Proposed QAPD and NQA-1 Differences R/NIl Basis for Acceptability Sections/Paragraphs Sections/Paragraphs (Note 3) (Note 4) (Note 5)

(Note 1) (Note 2) 17.3.2.12 Inspection Section 10 - Inspection The paragraph title was N changed to a section title.

In order to assure safe and Part II, Section 10 N/A N N/A reliable operation, a program of inspections for QA Condition 1 Supplement 10S-1 structures, systems, and components is established at each nuclear station.

Inspection procedures for those activities affecting QA Condition 1 structures, systems and components are established by Nuclear Generation personnel.

8

SDuke Conversion SEnergy Methodology (Continued)

Comparison Matrix Format and Information Description Notes 1 - 5 describe information found in columns 1-5, respectively.

Column 1 - Provides verbatim text from the current QA Topical Report that is displayed in a paragraph-by-paragraph format (headings, list items too).

Column 2 - References locations where equivalent requirement statements are found within the proposed QAPD, NQA-1, or other specifically committed standards and regulatory documents.

Column 3 - Describes significant differences between the requirement statements found in the current and proposed QAPDs, clarifying statements, and references to notes.

Column 4 - Notes one of three requirement statement evaluation result designations: R =

Reduction in Commitment, N = No reduction in Commitment, and I = Increase in Commitment.

Column 5 - Provides clarifying or justifying statements for commitment changes (e.g., reductions, exceptions, alternatives).

9

'Duke Conversion SEnergy Methodology (Continued)

Comparison Matrix Format and Information Description The following evaluation notes are typically referenced within Column 3 to minimize redundant wording entry.

" Note 6 - Descriptive requirement wording within the proposed QAPD, NQA-1 standard, or a regulatory document establishes equivalent requirements even though there may be a reduction in the level of methodology detail from the current QATR.

" Note 7 - A requirement or commitment within the current QATR is redundant to one found in a regulation or other licensing document, therefore, the requirement is not repeated in the proposed QAPD.

" Note 8 - A statement within the current QATR that prbvides only descriptive or clarifying information about the QA program is not considered a commitment to a regulatory requirement and is not repeated in the proposed QAPD.

10

Conversion erg~y E Methodology (Continued)

QAPD Differences Evaluation Process

1. Benchmark other utility submittals

2. Initial evaluation by Team Lead

3. Validation by Subject Matter Experts

4. QA SPOC 10CFR50.54 review

5. Management review 11

P Duke Conversion

- Energy Methodology (Continued)

QAPD Differences Evaluation Criteria

1. No Reduction in Commitment:

a. Statements found within the proposed QAPD, NQA-1 standard, or other regulatory document establishes equivalent requirements and commitments.

b. Detailed statements on how requirements are met may not be carried over into the proposed QAPD, provided the related requirements are addressed.

c. A commitment to a requirement within the current QATR is redundant to one already made to a regulation within another licensing document.

d. A statement that provides only descriptive or clarifying information about the QA program may not be carried over.

e. Document format changes.

12

RDuke Conversion IlEnergy Methodology (Continued)

QAPD Differences Evaluation Criteria (continued)

2. Increase in Commitment:

• Commitment statements made within the proposed QAPD are beyond those found in the current QATR.

3. Reduction in Commitment:

E Commitment statements made within the current QATR are deliberately not included within the proposed QAPD.

13

Duke Preliminary Energy Evaluation Results N = No Reduction in Commitment (100% of preliminary paragraph comparison results fall into this category.)

I= Increase in Commitment (0% of preliminary paragraph comparison results fall into this category.)

R = Reduction in Commitment (0% of preliminary paragraph comparison results fall into this category.)

14

P Duke No Reduction In Commitment Example 1 SEnergy Quality Assurance Program Description Comparison Matrix Current QATR Proposed QAPD and NQA-1 Differences R/NIl Basis for Acceptability SectionslParagraphs Sections/Paragraphs (Note 3) (Note 4) (Note 5)

(Note 1) (Note 2) 17.3.2.8 Test Control Section 11 - Test Control The paragraph title was N changed to a section title.

a) Requirements and QAPD Part II, Section 11 None N N/A acceptance limits contained in applicable design and vendor NQA-1 Supplement 11S-1 documents.

Supplement 11S-1 excerpt provided for this example:

"Test requirements and acceptance criteria shall be provided or approved by the organization responsible for the design of the item to be tested.

... Test requirements and "

acceptance criteria shall be based upon specified requirements contained in applicable design and other pertinent technical documents."

15

PDuke Th No Reduction In Commitment Example 2

- Energy Quality Assurance Program Description Comparison Matrix Current QATR Proposed QAPD and NQA-1 Differences R/N/I Basis for Acceptability Sections/Paragraphs Sections/Paragraphs (Note 3) (Note 4) (Note 5)

(Note 1) (Note 2) 17.3.2.2 Design Control Section 3 - Design Control The paragraph title was N changed to a section title.

Abbreviated QAPD excerpt QAPD Part II, Section 1 Note 6 N N/A provided for this example: NQA-1 Basic Requirement 1 Requirements for establishing "Final approval prior to QAPD Part II, Section 2 QA program responsibilities, implementation of each station control, and procedural engineering change shall be by prescription and performance of the Nuclear Station Manager or QAPD Part II, Section 3 activities affecting quality are the Manager of Engineering; or NQA-1 Basic Requirement 3 found within the proposed for the Nuclear Station Manager QAPD and NQA-1 standard.

by the Operations QAPD Part II, Section 5 Superintendent, the NQA-1 Basic Requirement 5 However, no statements are Maintenance Superintendent, included within the proposed the Work Control QAPD that specify detailed Superintendent, or the On-Duty administrative statements on Emergency Coordinator as how final approval of previously designated by the engho ring changes are made.

Nuclear Station Manager." Such details are provided within QA program implementation directives and procedures.

16

PDuke No Reduction In Commitment

- Energy Example 3 Quality Assurance Program Description Comparison Matrix Current QATR Proposed QAPD and NQA-1 Differences R/NIl Basis for Acceptability Sections/Paragraphs Sections/Paragraphs (Note 3) (Note 4) (Note 5)

(Note 1) (Note 2) 17.3.2.12 Inspection Section 10 -Inspection The paragraph title was N changed to a section title.

For inspections of concrete QAPD Part II, Section 10 Note 7 N N/A containments, personnel NQA-1 Basic Requirement 10 fulfilling the role of Responsible No detailed statements are Engineer, shall be a Registered included within the proposed Professional Engineer QAPD that specify Responsible experienced in evaluating the Engineer qualifications and inservice condition of structural responsibilities.

concrete and knowledgeable of the design and construction codes and other criteria used in The Responsible Engineer the design and construction of qualifications and the concrete containment responsibilities are described in structure. The Responsible the ASME Boiler and Pressure Engineer may also perform Vessel Code, Section X1, inspections as discussed in this Subsection IWL, Requirements section. for Class CC Concrete Components of Light-water Cooled Plants, paragraph IWL-2320, Responsible Engineer.

Section Xl of the ASME Code is endorsed by the NRC via reference within 10CFR50.55a(b)(2).

17

Puke No Reduction In Commitment Example 4 1nergy Quality Assurance Program Description Comparison Matrix Current QATR Proposed QAPD and NQA-1 Differences R/NIl Basis for Acceptability Sections/Paragraphs Sections/Paragraphs (Note 3) (Note 4) (Note 5)

(Note 1) (Note 2)

The Group Executive, Nuclear QAPD Part II, Section 2 Note 6 N N/A Generation and Chief Nuclear Officer, appoints a Nuclear No statements are included Safety Review Board (NSRB) to within the proposed QAPD that serve as a nuclear safety review specify the appointment or use and audit backup to the normal of a Nuclear Safety Review operating organization. Board (NSRB).

Rather, Duke commits to Option 1 - Independent Review Body (IRB) as described in Part II, Section 2 of the NEI 06-14A QAPD template. Standard f Review Plan 17.5 references approval of this option via SE (Accession No. ML050210276).

Approval of the NEI template was via SE (Project No. 689, TAC No. MD3406, dated April 25, 2007).

18

P Duke f Proposed Submittal S0 Energy Package Submittal Pursuant to 10CFR50.54

• Duke QAPD Conversion Submittal Letter

• Enclosure 1 Marked Template Change Copy of Proposed QAPD

" Enclosure 2 - Final Unmarked Copy of Proposed QAPD

" Enclosure 3.- Old Versus New QAPD Comparison Matrix

" Enclosure 4- Summary of Comparison Results

" Enclosure 5 - Summary of Proposed QAPD Alternatives/Exceptions 19

Puke Proposed Schedule

.nergy

" Duke Submittal - October 2008

" NRC Approval - Spring 2009?

• Implementation - 6 to 9 Months After Approval 20

Puke n Summary vin ergy Closing Remarks 21

July 1, 2008 M. Wong PARTICIPANTS: Participants from the NRC include members of the Office of Nuclear Reactor Regulation (NRR)

NRR DUKE (--l g\ ~~&)

-- D. Thatcher -, UJ. Fisicaro P. Prescott /R. Gill

-Q--( /K. Rhyne Y-t&J L. Olshan Docket Nos. 50-269, 50-270, 50-287, 50-369, 50-370, 50-413, and 50-414

Enclosure:

Agenda cc w/encl: See next page Distribution:

PUBLIC M. Cox, EDO Rgn II LPL2-1 R/F PMNS RidsNrrAdro D. Thatcher, NRR RidsNrrDorl (TMcGinty) P. Prescott, NRR RidsNrrPMJStang C. Roquecruz, NRR RidsNrrDorlLpl2-1 (MWong) KClark, OPA, Rgn II RidsNrrLAMO'Brien (hard copy) RidsOgcMailCenter RidsNrrPMLOIshan (hard copy) Receptionist (OWFN and TWFN)

RidsAcrsAcnw&mMailCenter RidsRgn2MailCenter (JMoorman)

RidsOpaMail C. Tucci, NRR Accession No. ML081830154 I

I OFFICE -IJhRR/LPL2-1/PIV/ N R/LPL2-1/LA N R R/LPE*C NAME , LOishan Y'-fO'Brien MWorb IKJ DATE 7kkon 1111 "F 4 I

OFFICIAL RECORD COPY

.. UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 1, 2008 MEMORANDUM TO: Melanie C. Wong, Branch Chief Plant Licensing Branch I1-I Divisiojapf Operating Reactor Licensing clear Reactor Regulation e'onrd N.Olshan, Project Manager FROM:

Plant Licensing Branch I1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

SUBJECT:

FORTHCOMING MEETING WITH DUKE ENERGY CAROLINAS, LLC, REGARDING OCONEE NUCLEAR STATION, UNITS 1,2, AND 3, MCGUIRE NUCLEAR STATION, UNITS 1 AND 2, AND CATAWBA NUCLEAR STATION, UNITS 1 AND 2 DATE & TIME: Tuesday, July 15, 2008 11:00 a.m. - 1:00 p.m.

LOCATION: U.S. Nuclear Regulatory Commission (NRC)

One White Flint North 11555 Rockville Pike, Room 0-1 F22 Rockville, Maryland PURPOSE: To discuss Duke's transition to American Society for Mechanical Engineers NQA [Nuclear Quality Assurance]-1 -1994 CATEGORY 1:

• This is a Category 1 Meeting. The public is invited to observe this meeting and will have one or more opportunities to communicate with the NRC after the business portion, but before the meeting is adjourned.

MEETING CONTACTS: Leonard N. Olshan, NRR John F. Stang, NRR 301-415-1419, 301-415-1345 ifs2@nrc.qov Ino@nrc.qov

• Commission's Policy Statement on "Enhancing Public Participation in NRC Meetings" (67 FR 36920), May 28, 2002

M. Wong PARTICIPANTS: Participants from the NRC include members of the Office of Nuclear Reactor Regulation, (NRR)

NRR DUKE D. Thatcher J. Fisicaro P. Prescott H. Gill C. Roquecruz K. Rhyne L. Olshan B. Travis J. Stang Docket Nos. 50-269, 50-270, 50-287, 50-369, 50-370, 50-413, and 50-414

Enclosure:

Agenda cc w/encl: See next page

FORTHCOMING MEETING ON JULY 15, 2008, TO DISCUSS DUKE ENERGY CAROLINAS, LLC (DUKE) TRANSITION TO ASME NQA-1 -1994 JULY 15, 2008 AGENDA 11:00 a.m. - 11:10 a.m. Introductions and purpose of meeting 11:10 a.m. - 11:55 a.m. Discussion of transition from Duke's current quality assurance program (QA) program to American Society of Mechanical Engineers NQA [Nuclear QA]-1-1994 11:55 a.m. - 12:50 p.m. Discuss comparison of NQA-1 -1994 to Nuclear Energy Institute QA Topical Report 12:50 p.m. - 1:00 p.m. Closing remarks 1:00 p.m. Adjourn

Oconee Nuclear Station, Units 1, 2, and 3 cc:

Mr. Bruce H. Hamilton Mr. Leonard G' Green Vice President, Oconee Site Assistant Attorney General Duke Power Company LLC NC Department of Justice 7800 Rochester Highway P.O. Box 629 Seneca, SC 29672 Raleigh, NC 27602 Ms. Lisa F. Vaughn Mr. R. L. Gill, Jr.

Associate General Counsel and Managing Manager - Nuclear Regulatory Attorney Issues and Industry Affairs Duke Energy Carolinas, LLC Duke Power Company LLC 526 South Church Street - EC07H 526 S. Church St.

Charlotte, North Carolina 28202 Mail Stop EC05P Charlotte, NC 28202 Manager, LIS NUS Corporation Division of Radiation Protection 2650 McCormick Dr., 3rd Floor NC Dept of Environment, Health, &

Clearwater, FL 34619-1035 Natural Resources 3825 Barrett Dr.

Senior Resident Inspector Raleigh, NC 27609-7721 U.S. Nuclear Regulatory Commission 7812B Rochester Highway Mr. Peter R. Harden, IV Seneca, SC 29672 VP-Customer Relations and Sales Westinghouse Electric Company Mr. Henry Porter, Director 6000 Fairview Road Division of Radioactive Waste Management 12th Floor Bureau of Land and Waste Management Charlotte, NC 28210 Dept. of Health and Env. Control 2600 Bull St. Mr. Henry Barron Columbia, SC 29201-1708 Group Vice President, Nuclear Generation f and Chief Nuclear Officer Mr. Michael A. Schoppman P.O. Box 1006-EC07H Framatome ANP Charlotte,. NC 28201-1006

• 1911 North Ft. Myer Dr.

Suite 705 Mr. Charles Brinkman Rosslyn, VA 22209 Director, Washington Operations Westinghouse Electric Company Mr. B. G. Davenport 12300 Twinbrook Parkway, Suite 330 Regulatory Compliance Manager Rockville, MD 20852 Oconee Nuclear Site Duke Energy Corporation Ms. Kathryn B. Nolan ON03RC Senior Counsel 7800 Rochester Highway Duke Energy Carolinas, LLC Seneca, SC 29672 526 South Church Street - EC07H Charlotte, NC 28202

McGuire Nuclear Station, Units 1 & 2 cc:

Vice President Manager McGuire Nuclear Station Nuclear Regulatory Issues &

Duke Power Company, LLC Industry Affairs 12700 Hagers Ferry Road Duke Energy Corporation Huntersville, NC 28078 526 S. Church St.

Mail Stop EC05P Associate General Counsel and Managing Charlotte, NC 28202 Attorney Duke Energy Carolinas, LLC Division of Radiation Protection 526 South Church Street - EC07H NC Dept of Environment, Health & Natural Charlotte, North Carolina 28202 Resources 3825 Barrett Dr.

County Manager of Mecklenburg County Raleigh, NC 27609-7721 720 E. Fourth St.

Charlotte, NC 28202 Owners Group (NCEMC)

Duke. Energy Corporation Regulatory Compliance Manager 4800 Concord Road Duke Energy Corporation York, SC 29745 McGuire Nuclear Site 12700 Hagers Ferry Road Group Vice President, Nuclear Generation Huntersville, NC 28078 &Chief Nuclear Officer P.O. Box 1006-EC07H Senior Resident Inspector Charlotte, NC 28201-1006 U.S. Nuclear Regulatory Commission 12700 Hagers Ferry Road Senior Counsel Huntersville, NC 28078 Duke Energy Carolinas, LLC 526 South Church Street - EC07H Mecklenburg County Charlotte, NC 28202 Department of Environmental Protection 700 N. Tryon St Charlotte, NC 28202 Vice President Customer Relations and Sales Westinghouse. Electric Company 6000' Fairview Road, 12th Floor Charlotte, NC 28210 NCEM REP Program Manager 4713 Mail Service Center Raleigh, NC 27699-4713 Assistant Attorney General NC Department.of Justice P.O. Box 629 Raleigh, NC 27602

Leonard Olshan From: Paul Prescott Sent: Friday, June 27, 2008 10:28 AM To: Leonard Qishan

Subject:

RE:

NQA - Nuclear Quality Assurance QATR - Quality Assurance Topical Report From: Leonard Olshan Sent: Friday, June 27, 2008 10:27 AM To: Paul Prescott

Subject:

RE:

Whoops, there is one question. What do "NQA" and "QATR" stand for? (I'll guess that NQA is nuclear quality assurance.)

From: Paul Prescott Sent: Friday, June 27, 2008 10:18 AM To: Leonard Olshan Cc: Carla Roquecruz; Dale Thatcher

Subject:

Hi Lenny, Just talked to Jim Fisicaro again. He had nothing planned for an agenda, so how's this: "The meeting is to discuss Duke's transition from their current quality assurance program to ASME NQA-1-1994 and format of this program to the NEI QATR template that was developed for new reactors." NRC will do introduction. Duke will provide discussion. We will close with any questions.

Just let me know if you need anything else.

Paul Prescott Senior Operations Engineer NRR/DE/EQVB (301)415-3026 MS: 0-9E3 1

Leonard Olshan From: Paul Prescott Sent: Friday, June 27, 2008 10:18 AM To: Leonard Qishan Cc: Carla Roquecruz; Dale Thatcher Hi Lenny, Just talked to Jim Fisicaro again. He had nothing planned for an agenda, so how's this: "The meeting is to discuss Duke's transition from their current quality assurance program to ASME NQA-1-1994 and format of this program to the NEI QATR template that was developed for new reactors." NRC will do introduction. Duke will provide discussion. We will close with any questions.

Just let me know if you need anything else.

Paul Prescott Senior Operations Engineer NRR/DE/EQVB (301)415-3026 MS: 0-9E3

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