ML20114E397
| ML20114E397 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 04/23/2020 |
| From: | NRC |
| To: | NRC/NRR/DNRL |
| References | |
| Download: ML20114E397 (4) | |
Text
From: Tabatabai, Omid Sent: Thursday, April 23, 2020 3:37 PM To: Bill McCollum (bill@wrmccollum.com)
Cc: BellefontePEm Resource
Subject:
NRC Staff's Slide/Talking Points Used During April 16, 2020 Public Teleconference Meeting With Nuclear Development, LLC Attachments: ND-Public Meeting-4-16-2020-4-clean.pptx
Dear Mr. McCollum,
As requested, please find attached the one slide that the NRC staff from Quality Assurance and Vendor Branch used during the April 16, 2020 public teleconference meeting, along with their talking points.
Sincerely, Omid Tabatabai, Sr. Project Manager New Reactor Licensing Branch Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission (301) 415-6616 Public Meeting With ND Title 10 of the Code of Federal Regulations (10 CFR) Part 50.34(h)(3): The SRP was issued to establish criteria that the NRC staff intends to use in evaluating whether an applicant/licensee meets the Commission's regulations.
SRP Section A. Organization -
- Specifically, Nuclear Development (ND)s NQAP does not address the Engineer Procurement Contractor (EPC) roles and responsibilities, the EPCs involvement with the ND organizational descriptions and ORG chart, organizational elements which function under the cognizance of the QA program, describe the Nuclear Power Group (NPG), or Nuclear Procedure System (NPS).
- The corresponding SRP sections are:
o A.2 is the identified and described major delegation of work o A.4 is the major portions of the applicant's program are delegated o A.5 is the principle contractor o A.6 is the organizational descriptions SRP Section B. QA Program -
- Specifically, NDs NQAP section 3.3.3 does not specify the frequency assessments of effectiveness on quality services. ND removed the controls on the management position responsible to arrange for the assessment by an independent organization on an annual basis.
- The corresponding SRP section is:
o B.1 is the review of the QA program to assess the effectiveness and the adequacy of the scope and implementation.
SRP Section C. Design Control -
- Specifically, NNDs NQAP section 7.2.6 does not clarify the responsible design organization required to identify and document the particular design verification method(s) used. (C.11)
- Specifically, NDs NQAP section 7.2.4 does not clarify Engineer Procurement Contractor (EPC) design control in accordance with SRP Section C Design Control, interface control of design information transmitted across interfaces is documented and controlled. (C.14)
- Specifically, NDs NQAP section 7.2.7 does not clarify measures are provided that will ensure design changes, including field changes, are subject to the same design controls that were applied to the original design and are reviewed and approved by the organization that performed the original design unless the originating organization designates another responsible organization. (C.17)
- The corresponding SRP sections are:
o C.11 is the design verification o C.14 is design interfaces o C.17 is design changes D. SRP Section V. QA Program Commitments" -
- Specifically, in accordance with the SRP, certain quality assurance program commitments are required, including regulatory guides, generic letters, and standards.
- The corresponding SRP sections are:
o V.1 is Regulatory Guides and Generic Letters o V.2 is Standards E. Commission Policy Statement on Deferred Plants (52 Federal Register 38077)
- Specifically, NDs NQAP Appendix G, references a corrective action program however the staff needs clarification on the current status of structures systems and components (SSCs) maintenance, preservation, and documentation (MPD) and how ND will be addressed any issues entered in the CAP affecting SSCs.
- The Commission Policy Statement on Deferred Plants, states, In the context of this policy statement, it is expected that a utility, planning to maintain its reactivation option or transfer of ownership to others, will identify any SSC which are important to safety and establish appropriate MPD for these SSC(s).
The NRC staff has determined ND NQAP does not meet the construction permit regulatory requirements and request ND supplement their RAI response prior to license transfer.
Hearing Identifier: Bellefonte_CP_NDLLC_Public Email Number: 10 Mail Envelope Properties (MN2PR09MB5244D2D665F87257F532C83EDFD30)
Subject:
NRC Staff's Slide/Talking Points Used During April 16, 2020 Public Teleconference Meeting With Nuclear Development, LLC Sent Date: 4/23/2020 3:36:45 PM Received Date: 4/23/2020 3:36:50 PM From: Tabatabai, Omid Created By: Omid.Tabatabai-Yazdi@nrc.gov Recipients:
"BellefontePEm Resource" <BellefontePEm.Resource@nrc.gov>
Tracking Status: None "Bill McCollum (bill@wrmccollum.com)" <bill@wrmccollum.com>
Tracking Status: None Post Office: MN2PR09MB5244.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 4208 4/23/2020 3:36:50 PM ND-Public Meeting-4-16-2020-4-clean.pptx 305515 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
NRC PUBLIC MEETING - APRIL 16, 2020 Nuclear Development (ND): Bellefonte- Nuclear Quality Assurance Program (NQAP)
- Title 10 of the Code of Federal Regulations (10 CFR) Part 50.34(h)(3)
- States, in part that, The Standard Review Plan (SRP) was issued to establish criteria that the NRC staff intends to use in evaluating whether an applicant/licensee meets the Commission's regulations.
- Organization (SRP: A.2, A.4, A.5, A.6)
- QA Program (SRP: B.1)
- Design Control (SRP: C.11,C.14, C.17)
- QA Program Commitments (SRP: V.1, V.2)
- Commission Policy Statement (52 Federal Register 38077)
Nicholas Savwoir and Carla Roque-Cruz Quality Assurance and Vendor Inspection Branch, Office of Nuclear Reactor Regulation