NG-20-0050, Response to Request for Additional Information - NextEra Energy Duane Arnold, LLC Quality Assurance Topical Report (FPL-3)
| ML20178A519 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 06/26/2020 |
| From: | Dean Curtland NextEra Energy Duane Arnold |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NG-20-0050 | |
| Download: ML20178A519 (8) | |
Text
June 26, 2020 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555 Duane Arnold Energy Center Docket No. 50-331 NEXTera ENERGY.
DUANE ARNOLD NG-20-0050 10 CFR 50.54(a)
Response to Request for Additional Information - NextEra Energy Duane Arnold, LLC Quality Assurance Topical Report (FPL-3)
References:
- 1. NextEra Energy Duane Arnold, LLC letter NG-20-0006, "Request for Approval of NextEra Energy Duane Arnold, LLC's Quality Assurance Topical Report (FPL-3)
Revision O," February 13, 2020 (ML20049A860)
- 2. NRC E-Mail: "Request for Additional Information - Duane Arnold Energy Center Quality Assurance Topical Report (FPL-3) - EPID L-2020-LLQ-0002," from Mahesh Chawla, NRC, May 28, 2020 To support the transition of the Duane Arnold Energy Center (DAEC) to a decommissioning facility, NextEra Energy Duane Arnold, LLC (NextEra) submitted a request for approval of Quality Assurance Topical Report FPL-3 (Reference 1 ). In Reference 2, the NRC staff requested additional information to support its review of the Quality Assurance Topical Report FPL-3. The Enclosure to this letter provides NextEra's response to the request for additional information (RAI).
If you have any questions or require additional information, please contact J. Michael Davis, Licensing Manager, at 319-851-7032.
~µJ Dean Curtland Site Director, Duane Arnold Energy Center NextEra Energy Duane Arnold, LLC Enclosure NextEra Energy Duane Arnold, LLC 3277 DAEC Road, Palo, IA 52324
Document Control Desk NG-20-0050 Page 2 of 2 cc:
Regional Administrator, USNRC, Region Ill, Project Manager, USNRC, Duane Arnold Energy Center Resident Inspector, USNRC, Duane Arnold Energy Center A. Leek (State of Iowa)
Enclosure Response to Request for Additional Information REQUEST FOR ADDITIONAL INFORMATION NG-20-0050 Enclosure Page 1 of 2 On February 13, 2020 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML20049A860), NextEra Energy Duane Arnold, LLC (NEDA, the licensee) submitted a request for approval of Quality Assurance Topical Report FPL-3. To support the transition of Duane Arnold Energy Center (DAEC) to a decommissioning facility, NEDA has developed a site-specific DAEC Quality Assurance Topical Report (QATR) FPL-3 using the QATR FPL-1 as the basis. QATR FPL-1 will no longer be effective at DAEC following approval and implementation of QA TR FPL-3. The U.S. Nuclear Regulatory Commission (NRC) staff is reviewing the application and has determined that the following additional information is required in order to complete the review of the subject QATR.
RAI 1
Regulatory Basis Criterion XVII "Quality Assurance Records," of Appendix 8 to 10 CFR Part 50, states in part, that "records shall also include closely-related data such as qualifications of personnel..." Standard Review Plan (NUREG-0800), Section 17.3 (SRP 17.3), "Quality Assurance Program Description" Section 11.A.5 states, "Personnel training and qualification records are to be maintained."
Please clarify how the Quality Assurance Topical Report (QATR) FPL-3, specifically in paragraph A.5, maintains personnel training and qualification records or provide justification on why it is not needed.
NextEra Energy Duane Arnold, LLC Response to RAl-1 The effort to reflect the NRG approved Certified Fuel Handling program (reference NRG Accession No. ML19204A287) in FPL-3 paragraph A.5 resulted in the inadvertent omission of a statement regarding record maintenance. Paragraph A.5 will be amended with the following statement:
"Personnel training and qualification records are maintained in accordance with procedures."
This statement reflects that NEDA maintains training and qualification records of Certified Fuel Handlers and for personnel whose qualifications are described in the DAEC Technical Specifications.
RAl-2 Regulatory Basis NG-20-0050 Enclosure Page 2 of 2 NUREG-0800 SRP 17.3 Section 11.A.7 states in part, "the applicant is to comply with the regulatory positions in the appropriate revisions of the regulatory guides listed in Section VI.A of this chapter." NUREG-0800 SRP 17.3 Section VI.A "References" lists Regulatory Guide 1.28, "Quality Assurance Program Requirements (Design and Construction)," using NQA-1 and NQA-2.
Please clarify why Regulatory Guide 1.28 is not listed in Paragraph A.7 but Duane Arnold Energy Center (DAEC) commits to Regulatory Guide 1.28 in the QATR FPL-3 Section 8.4 and 8.15.
NextEra Energy Duane Arnold, LLC Response to RAl-2 NEDA has determined that removal of the commitment to Regulatory Guide 1.28 was in error. Section A.7, "Regulatory Commitments," A.7.3 will be amended to contain the following:
Regulatory Guide 1.28, Revision 3, August 1985, "Quality Assurance Program Requirements (Design and Construction)" (ASME NQA-1, 1983a) - NextEra Energy Duane Arnold complies with position C.2 for record retention times, and position C.3.2 for external audits, with the exception that for position C.3.2.2, the information described therein will be reviewed as it becomes available through its ongoing receipt inspection, operating experience, and supplier evaluation programs, in lieu of performing a specific evaluation on an annual basis. The results of the reviews are promptly considered for effect on a supplier's continued qualification and adjustments made as necessary (including corrective actions, adjustments of supplier audit plans, and input to third party auditing entities, as warranted). Additionally, results are reviewed periodically to determine if, as a whole, they constitute a significant condition adverse to quality requiring additional action. In lieu of compliance with Regulatory Position C.3.1, independent assessment frequencies as described in Section C of this QATR are established. In lieu of NQA-1 1983a, NQA-1 1994 is used. See the specific exceptions to 2S-1 and 2A-1 contained in Section A.5 of this QATR.
Appendix to Enclosure of NG-20-0050 Revised Affected QATR FPL-3 Pages 2 pages follow
NextEra Energy Quality Assurance Topical Report (FPL-3)
A.3 Responsibility (Continued)
The responsibility to take action to minimize personnel injury or damage to the facility and to protect the health and safety of the public in the event of an emergency not covered by approved procedures.
In establishing QAP responsibilities, NextEra Energy commits the DAEC to compliance with NQA-1, 1994, Basic Requirement 1 and Supplement 1 S-1.
A.4 Authority When responsibility is delegated for planning, establishing, or implementing any part of the overall QAP, sufficient authority to accomplish the assigned responsibilities is delegated. Regardless of delegation, NextEra Energy retains overall responsibility.
Responsibility and authority to stop unsatisfactory work, as delineated in Section A.2, includes authority to control further processing, delivery, installation, operation or use of nonconforming items. This assures that cost and schedule considerations do not override safety considerations.
In establishing QAP authorities, NextEra Energy commits the DAEC to compliance with NQA-1, 1994, Basic Requirement 1 and Supplement 1 S-1.
A.5 Personnel Training and Qualification Personnel assigned to implement elements of the QAP must be capable of performing their assigned tasks. To this end, indoctrination and training programs are maintained for personnel performing, verifying or managing activities within the scope of the QAP to assure that suitable proficiency is achieved and maintained.
Site and support staff minimum qualification requirements are as delineated in plant Technical Specifications. Other qualification requirements may be established but will not reduce those required by plant Technical Specifications. Sufficient managerial depth is provided to cover absences of incumbents.
When required by code, regulation, or standard, specific qualification and selection of personnel is conducted in accordance with those requirements as established in the applicable procedures. Indoctrination may include the administrative and technical objectives, requirements of the applicable codes and standards, and the QAP elements to be employed.
The Certified Fuel Handler training program ensures that the qualifications of fuel handlers are commensurate with the tasks to be performed and the conditions requiring response. The requirements of 1 O CFR 50.120, "Training and Qualification of Nuclear Power Plant Personnel" requires training programs to be derived using a systems approach to training (SAT) as defined in 1 O CFR 55.4. Although the requirements of 10 CFR 50.120 apply to holders of an operating license issued under Part 50, and the DAEC license no longer authorizes operation, the Certified Fuel Handler training program will, nonetheless, align with those requirements. Records of personnel training and qualification are maintained in accordance with procedures.
In establishing qualification and training programs, NextEra Energy commits the DAEC to compliance with NQA-1, Basic Requirement 2, Supplements 2S-1, 2S-2, 2S-3 and 2S-4, and Non-mandatory Appendix 2A-1 with the following clarifications and exceptions:
Revision O 12 of 50 TBD
NextEra Energy Quality Assurance Topical Report (FPL-3)
A.7 Regulatory Commitments (Continued)
A.7.2 When applicable, for Class 1, 2, and 3 items covered by Section Ill of the ASME Boiler and Pressure Vessel Code, the code Quality Assurance requirements are supplemented by the guidance of applicable regulatory guides (see Section A.7.3).
A.7.3 NextEra Energy also is committed to carrying out the prov1s1ons of certain nuclear quality assurance industry standards, other than ASME NQA-1. The extent of the commitment to each of the Regulatory Positions of related NRC Regulatory Guides and Generic Letters is specifically described below. Commitment to a particular Regulatory Guide does not constitute commitment to Regulatory Guides or other standards that may be referenced therein, unless otherwise noted.
Regulatory Guide 1.8, "Qualification and Training of Personnel for Nuclear Power Plants"
- commitments regarding qualification and training of personnel are described in Section A.5 of this QATR, which states that staff qualification requirements are as delineated in plant Technical Specifications.
Safety/Regulatory Guide 1.26, Revision (site specific) "Quality Group Classifications and Standards for Water-, Steam-, and Radioactive Waste-Containing Components of Nuclear Power Plants" - Commitment to Safety/Regulatory Guide 1.26 is site specific, as required by the approved UFSAR/License at each site. Sites may use this guidance to assist in establishing the lists of equipment to which this OAP applies, or for other purposes.
Regulatory Guide 1.28, Revision 3, August 1985, "Quality Assurance Program Requirements (Design and Construction)" (ASME NQA-1, 1983a) - NextEra Energy Duane Arnold complies with position C.2 for record retention times, and position C.3.2 for external audits, with the exception that for position C.3.2.2, the information described therein will be reviewed as it becomes available through its ongoing receipt inspection, operating experience, and supplier evaluation programs, in lieu of performing a specific evaluation on an annual basis. The results of the reviews are promptly considered for effect on a supplier's continued qualification and adjustments made as necessary (including corrective actions, adjustments of supplier audit plans, and input to third party auditing entities, as warranted).
Additionally, results are reviewed periodically to determine if, as a whole, they constitute a significant condition adverse to quality requiring additional action. In lieu of compliance with Regulatory Position C.3.1, independent assessment frequencies as described in Section C of this QATR are established. In lieu of NQA-1 1983a, NQA-1 1994 is used. See the specific exceptions to 2S-1 and 2A-1 contained in Section A.5 of this QATR.
Safety/Regulatory Guide 1.29, "Seismic Design Classification" -
Some plants were designed, constructed and licensed based on criteria available prior to this Regulatory Guide being issued. The specific design criteria and seismic designations are reflected in the UFSAR, and in other docketed analysis.
Regulatory Guide 1.30, August 1972, "Quality Assurance Requirements for the Installation, Inspection and Testing of Instrumentation and Electric Equipment," (ANSI N45.2.4-1972/IEEE 336-1971) - NQA-1 1994, Subpart 2.4/IEEE 336-1985 is substituted Revision O 15 of 50 TBD
BLIND CARBON COPY LIST FOR NG-20-0050 June 26, 2020 D. Curtland W. Maher CIPCO CTS Project Corn Belt IRMS GOS Associates, Inc.
John Karrick
Subject:
M. Davis Response to Request for Additional Information - NextEra Energy Duane Arnold, LLC's Quality Assurance Topical Report (FPL-3)