ML18312A085
| ML18312A085 | |
| Person / Time | |
|---|---|
| Site: | Clinch River |
| Issue date: | 11/08/2018 |
| From: | Savwoir N Division of Construction Inspection and Operational Programs |
| To: | Allen Fetter NRC/NRO/DLSE |
| Fetter A | |
| References | |
| Download: ML18312A085 (9) | |
Text
1 Presentation to the ACRS Subcommittee Safety Review of the Clinch River Nuclear Site, Early Site Permit Application Quality Assurance Program
Description:
(SSAR Section 17.5)
Presented by Nicholas Savwoir, Reactor Operations Engineer NRO/DCIP/QVIB-1 November 14, 2018
2 Early Site Permit (ESP) Regulations Appendix B to Part 50, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants 10 CFR Part 52.17, Contents of applications; technical information Subsections (a)(1)(xi) and (xii)
3 Background
TVA (Tennessee Valley Authority) submitted Operating Nuclear Quality Assurance Plan (NQAP), Revision 32, with their ESP application TVA NQAP, Revision 32, commits to ANSI N45.2-1971 as endorsed by RG 1.28, Revision 3 Review involved multiple public meetings and clarification calls One request for additional information (RAI) with 8 questions; TVA responded by submitting NQAP, Revision 36
4 Key Review Areas
[1] Quality Assurance Program Description (QAPD)
Criterion I - Organization Criterion II-Quality Assurance (QA) Program
[2] Quality Assurance (QA)
Gap analysis evaluation Criterion XVII-QA Records Criterion VII-Control of Purchased Material, Equipment and Services Criterion XV-Nonconforming Material Parts of Components
[3] QA Implementation Inspection April 16-20th 2018 at TVA (Chattanooga, TN)
5 Key Review Area [1]
[1] QAPD Clinch River Nuclear Site, Criterion I and Criterion II NRC Staff RAI:
Small Modular Reactor (SMR) Organization for the Clinch River Nuclear (CRN) Site Independent Assessments at the CRN site Reference or commitment to 10 CFR Part 52 As a result of the staffs review; TVA revised the NQAP to Revision 36:
Added Appendix K (roles and responsibilities) and Appendix L (organization chart) in support of the SMR organization.
Added Independent Assessments at the CRN site.
Added 10 CFR Part 52 to NQAP.
6 Key Review Area [2]
[2] QA Gap Analysis and Criterion XVII NRC Staff RAI:
Gap Analysis evaluation between RG 1.28 Rev 3 & 4 (10 CFR 52.17(a)(1)(xii))
CRN QA record documents CRN electronic records controls As a result of the staffs review; TVA revised the NQAP to Revision 36:
TVA provided a gap analysis evaluation during inspection (ML18143B478)
Added Appendix M (Clinch River Commitments and Clarifications for the ESP QA Program) and committed to RG 1.28 Rev 4.
Identified the documents that are considered QA records per Criterion XVII Added electronic records controls per RIS 2000-18 and NIRMA (Nuclear Information & Records Management Association), TG-11,15,16, and 21
7 Key Review Area [2]
[2] QA Gap Analysis, Criterion VII and Criterion XV NRC Staff RAI:
An incorrect exemption for the use of Accreditation in lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services Did not address the notification of affected organizations for nonconforming materials, parts or components As a result of the staffs review; TVA revised the NQAP to Revision 36:
Revised ILAC (International Laboratory Accreditation) conditions per NEI 14-05A Guidelines for the use of Accreditation in lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services. Revision, 0.
Added Appendix M and the commitments to address the notification of affected organizations.
8 Key Review Area [3]
April 16-20th, 2018 Tennessee Valley Authority (TVA) office in Chattanooga, TN Inspection Procedure (IP) 35017, Quality Assurance Implementation Inspection Initial review of TVA revised NQAP, Revision 36 No findings of significance were identified QA Inspection Report publicly-available (ML18143B478)
[3] QA Implementation Inspection
9 Conclusion QAPD for the CRN Site ESP application meets the requirements of 10 CFR Part 50, Appendix B and 10 CFR Part 52.17(a)(1)(xi) and (xii).