ML20090M620
| ML20090M620 | |
| Person / Time | |
|---|---|
| Site: | Monticello, Prairie Island  |
| Issue date: | 06/13/1975 |
| From: | Mayer L NORTHERN STATES POWER CO. |
| To: | Ziemann D Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 9105070378 | |
| Download: ML20090M620 (4) | |
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REGULATORY ~, mKETFILE yy NOMTHERN STATES POWER C0MPANY
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s MONTICELIA NUCLEAR GENERATING PIANT Docket No. 50-263 License No. DPR-22
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PRAIRIE ISIAND NUCLEAR GENERATING PIANT Docket Nos. 282 & 306 License Nos. DPR-42 6 60 Response to NRC/DRL Request for an Operational QA Prostram Description Your letters dated March 26, 1975, concerning both the Monticello and Prairie Island Plants, asked that we submit within 90 days an updated description of our operational QA Program in the fom of a FSAR Amendment.
It also suggested that application of the guidance contained in WASH documents 1283,1284 and 1509 would enhance our Operational Quality Assurance Program.
The Monticello and Prairie Island Plants were issued operating licenses on August 25, 1970, and August 9,1973, respectively. The two plants operate under management and administrative controls which govern those operating, maintenance and modification activities that are safety related. The management and administrative controls are continuously upgraded and amplified on the basis of operating experience and recocinendations or suggestions contained in applicable regulatory guidance. We believe that our current program meets the requirements of ANSI N18.7-1972 and those portions of ANSI N45.2-1971 which are applicable to the operations phase of nuclear pcuer plants. Meeting these requirements satisfies the requirements of current Regulatory Guide 1.33.
Additional guidance for improvements in the Operational Quality Assurance Program wr.s obtained through NSP representation at the regional conferences conducted by the JRC on Operational Quality Assurance as described in WASH 1284. That document also states that ANSI N18.7 is currently being revised to incorporate those activities applicable to the operations phase of nuclear pcuer plants that are contained in ANSI N45.2.
(We understand that this has recently been completed but we have not yet obtained a copy of the approved standard.) WASH 1284 also states that the Regulatory Staff intends to recognize the revised N18.7 Standard by appropriately revising Regulatory Guide 1.33 when the ANSI N18.7 revision is issued. We believe that our current Operational Quality Assurance Program will confom to the require-ments and recocenendations to be contained in the ANSI N18.7 and Regulatory Guide 1.33 revisions.
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nom (ERN OTATEO POWER CC, PANY 1
Mr Dennis L Ziemann l
Page 2 June 13,1975 The Regulatory Staff Safety Evaluation Report for Prairie Island states on Page 18-2:
"We conclude that the applicant's Quality Assurance Program has provided r
an adequate icvel of quality for all safety-related systems and structu-as during construction and provides for a continuation of this quality into plan' oeration.
l Adherence to the program will be the subject of continuing inspection a te Commission's Directorate of Regulatory 'perations." The Monticello Qut 4 i j
Assurance Program is nearly identical to the Prairie Island program; th.: tore, we l
conclude that a Regulatory Staff review of the Monticello program would find it to be satisfactory.
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We believe that the current Operational Quality Assurance Programa at our nuclear facilities are comprehensive, effective, and free of any significant weaknesses.
For example, at the Monticello Plant we have successfully completed three refueling j
outages with no significant deficiencies being found in the management and admin-t istrative controls. We have also completed several major modification projects at W nticello with no significant weaknesses being found in our design and construction activities < L'epections by the NRC Inspection and Enforcement Branch have reviewed all aspects quality related activities.
They have made detailed inspections of i
the modification projects at the Monticello Plant and have inspected a number of major repairs that have been completed. We are not aware of any significant weak-nesses which have been disclosed by this extensive inspection program, although minor defici j cies have been brought to our attention and necessary changes have been made i
to our Operational Quality Assurance Programs.
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On the basis of the effectiveness of our Operational Quality Assurance Programs, we find it difficult to understand, at this stage of operations, why we have been requested to prepare a FCAR-type of document describing the Operational Quality Assurance Programs for the Monticello and Prairie Island Plants. This is par-r ticularly difficult to understand when there have been no significant deficiencies in our programs pointed out to us as a basis for either submitting the material requested or for upgrading our programs. Production of a FSAR-type of document describing the Design, Construction and Operational Quality Assurance Program is a prodigious task and appears to be material that is necessary to secure an operating i
license. We are unaware of any direct regulatory requirement for preparation of FSAR amendments beyond the date of operating license issuance and consider it to be f
almost a "back-fit" requirement.
Ihe preparation of such a document at this time, rather than enhancing our Operational Quality Assurance Program, would divert personnel from curtsutly assigned responsibilities and would detract from the attention being paid to safety related and quality assurance activities by the management and engineering staffs for our nuclear activities. We believe that any evaluation of our Operational Quality Assurance Program ht this point in time should be a results oriented type of review rather than by review of a FSAR-type document.
We respectfully requ st that your requirement for production of a FSAR amendment be reconsidered.. If there is a. requirement for submission of such a document, we i
ask that you consider the following factorst i
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Noi HERN OTATED POWER CL IPANY Mr Dennis L Ziemann Page 3 i
June 13,1975
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1.
The document to be prepared would better be described as a program description or a topical report, should not be required to meet the i
extrerne detail as contained in a FSAR-type of filing, and should not be filed as a TSAR amendment.
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2.
Sufficient time should be allwed for issuance,and our review, of 1
pending revisions to ANSI N18.7 and HRC Regulatory Guide 1.33.
3.
Allw adequate time for preparation and sulunittal of this document,
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such that the necessary manpwer can be secured, or assigned, con-sistent with other higher priority activities and so as to not unduly divert personnel from safety related activities. We would suggest six months follwing issuance of revised Regulatory Guide 1.33 as an appropriate period of time in which to prepare the document.
Very truly yours,
&r lf L 0 Mayer, PC Manager of Nuclear Support Services IDM/ak cc: D L Ziemann (60 copies)
J G Keppler C Charnoff l
Minnesota Pollution Control Agency Attn:
E A Pryrina I
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