ML20149K436

NRR E-mail Capture - Formal RAIs for Columbia (COVID-19) QA Plan Change Surveillance, Request Response by Tuesday June 2, 2020

ML20149K436
Person / Time
Site:	Columbia
Issue date:	05/26/2020
From:	John Klos NRC/NRR/DORL/LPL4
To:	Ronnie Garcia Energy Northwest
References
Download: ML20149K436 (3)

Text

From: Klos, John Sent: Tuesday, May 26, 2020 1:38 PM To: Garcia, Richard M.

Cc: Klos, John

Subject:

Formal RAIs for Columbia [COVID-19] QA plan change surveillance, request response by Tuesday June 2, 2020 Importance: High

Rick, By letter dated May 18, 2020 (Agencywide Documents Access and Management System Accession No. ML ML20139A225) Energy Northwest requested approval to revise Columbia Generating Stations (Columbias) Operational Quality Assurance Program Description (OQAPD).

The technical review branch has determined the following questions are necessary to support a technical review. A response on the docket is requested by next Tuesday June 2, 2020.

Background:

Title 10 of the Code of Federal Regulations (10 CFR) 50.54(a)(4) requires licensees to submit changes to the quality assurance (QA) program description that represent a reduction in commitment. 10 CFR 50.54(a)(4)(ii) requires that the submittal of a change to the Safety Analysis Report QA program description must include all pages affected by that change and must be accompanied by a forwarding letter identifying the change, the reason for the change, and the basis for concluding that the revised program incorporating the change continues to satisfy the criteria of Appendix B to 10 CFR Part 50 and the Safety Analysis Report QA program description commitments previously accepted by the NRC.

Criterion VII, Control of Purchased Material, Equipment, and Services, states, in part that Measures shall be established to assure that purchased material, equipment, and services, whether purchased directly or through contractors and subcontractors, conform to the procurement documents. These measures shall include provisions, as appropriate, for source evaluation and selection, objective evidence of quality furnished by the contractor or subcontractor, inspection at the contractor or subcontractor source, and examination of products upon delivery.

Question 1 In the submittal Energy Northwest stated that the following process description is based on industry guidance found in the document Remote Source Verification During a Pandemic or Similar State of Emergency: Screening Criteria and Process Guidance, [Electrical Power Research Institute] EPRI, Palo Alto, CA: 2020. 3002019436. The Energy Northwest definitions differ from those used in the EPRI document in that source verification at Energy Northwest includes vendor surveillances, inspections and audits. Energy Northwest stated that its submittal will use the vendor surveillance in place of the EPRI term source verification to be consistent with our existing program terminology. The function described by the two terms will be the same.

Please clarify if and how Columbias alternate method of performing remote vendor surveillances will change the inspections and audits in its OQAPD?

Question 2 By letter dated May 18, 2020 Energy Northwest requested approval to revise Columbias (OQAPD). In the submittal the Columbia stated that the following process description is based on industry guidance found in the document, Remote Source Verification During a Pandemic or Similar State of Emergency: Screening Criteria and Process Guidance, EPRI 3002019436.

Columbias submittal, Attachment 1, Revised Pages of Columbias OQAPD does not reference EPRI 3002019436, Remote Source Verification During a Pandemic or Similar State of Emergency: Screening Criteria and Process Guidance and is not in included in the proposed change.

a. Provide clarification if the EPRI guidance will be included in Columbias OQAPD or implementing procedures?

b. Please provide clarification on where and how the screening questions in EPRI 3002019436, Section 4, Remote Source Verification Screening Process, will be implemented if the EPRI document is not referenced in Columbias OQAPD?

Question 3 Energy Northwests submittal, Attachment 1, Revised Pages of the Columbia Operational Quality Assurance Program Description, states in part that, Remote vendor surveillance is acceptable as a dedication process when a pandemic or similar state of emergency has been declared restricting access or travel to and/or from vendor locations affected by the declaration.

The remote vendor surveillance will be screened for eligibility, planned, and then performed using real time video and documented.

Please clarify if Columbia intends to use remote source verification in EPRI 3002019436 dedication activities only, or in addition to Appendix B, Criteria VII inspection at the contractor or subcontractor source requirements?

John Klos DORL Callaway, Columbia Project Manager U.S. NRC, Office of Nuclear Reactor Regulation, Division of Operating Reactor Licensing, O9D22 NRC/NRR/DORL/LPL4, MS O9E3 Washington, DC 20555-0001 301.415.5136, John.Klos@NRC.gov

Hearing Identifier: NRR_DRMA Email Number: 606 Mail Envelope Properties (BL0PR0901MB3217C7838F860DC2E2D47643E3B00)

Subject:

Formal RAIs for Columbia [COVID-19] QA plan change surveillance, request response by Tuesday June 2, 2020 Sent Date: 5/26/2020 1:38:21 PM Received Date: 5/26/2020 1:38:22 PM From: Klos, John Created By: John.Klos@nrc.gov Recipients:

"Klos, John" <John.Klos@nrc.gov>

Tracking Status: None "Garcia, Richard M." <rmgarcia@energy-northwest.com>

Tracking Status: None Post Office: BL0PR0901MB3217.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 4673 5/26/2020 1:38:22 PM Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: