ML20249C254
| ML20249C254 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/24/1998 |
| From: | NRC (Affiliation Not Assigned) |
| To: | |
| Shared Package | |
| ML20249C246 | List: |
| References | |
| NUDOCS 9806260266 | |
| Download: ML20249C254 (7) | |
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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO PROPOSED REVISION 19 TO THE NORTHEAST UTILITIES QUALITY ASSURANCE PROGRAM TOPICAL REPORT NORTHEAST NUCLEAR ENERGY COMPANY MILLSTONE NUCLEAR POWER STATION. UNITS 1. 2. AND 3 l
DOCKET NOS. 50-245. 50-336. AND 50-423
1.0 INTRODUCTION
On June 10,1996, Northeast Nuclear Energy Company (NNECO) transmitted proposed Revision 19 to the Northeast Utilities Quality Assurance Program (NUQAP) Topical Report for NRC review and approval in accordance with 10 CFR 50.54(a)(3). As a result of requests for additionalinformation by the NRC staff, significant organization changes, and the decision to permanently shut down the Haddam Neck Plant, NNECO amended its original submittal by correspondence dated February 20,1997 (Reference 4), June 3,1997 (Reference 5), August 7, 1997 (Reference 6), November 25,1997 (Reference 8), January 29,1998 (Reference 9), April 6, 1998 (Reference 11), and June 9,1998 (Reference 12). The proposed Revision 19 to the NUQAP sabmitted on June 3,1997, superseded the original (Reference 1) in its entirety. ,
2.0 BACKGROUND
l in its proposed Revision 19 to the NUQAP, dated June 3,1997, NNECO identified six new exceptions (three of which were previously approved by the NRC by Technical Specification amendments) to previous quality assurance (QA) program description commitments, i.e, reductions in commitment pursuant to Section 50.54(a)(3), and several changes in the following categories:
1 Deletion of all reference to Connecticut Yankee (Haddam Neck Plant) and its operating company, Connecticut Yankee Atomic Power Company, Identification of the Millstone Power Station Orgar.ization responsible for quality activities i
Deletion of information/ reference to construction and pre-operational phases throughout !
the NUQAP, and i I
= Editorial consistency. j l
l 9906260266 90062425 PDR ADOCK O P Emclosure !
l 2.1 Summarv of Prooosed NUQAP Chances Not Involvino QA Procram Exceptions to NRC-Endorsed American National Standards Institute (ANSI) Standards or Reaulatorv Guides BGal l
- 1. Applicable program responsibilities previously assigned to Northeast Utilities Service Company / Nuclear Plant Operating Companies are now assigned to NNECO and reference is made to the " Millstone Power Station,"
- Millstone Station," or
- Station" as necessary for program description in the operations phase.,
- 2. The NU Nuclear Organization for Millstone Power Station indicating the new organization names and titles are identified. For example, " Quality and Assessment Services" has t een changed to the " Nuclear Oversight,"" Director - Quality and Assessment Services" to "Vice President - Nuclear Oversight"; " Procurement Quality Services" to " Nuclear Materials and Document Management"; and the " Executive Vice President - Nuclear" to " President and Chief Executive Officer- NU Nuclear Group."
- 3. The role of the Yankee Atomic Electric Company as contracted to Nuclear Materials and I
Document Management for the offsite auditing, surveillance, and inspection of vendors is identified.
- 4. The responsibilities of Nuclear Materials and Document Management and Nuclear Oversight for verifying onsite and offsite vendor activities is clarified and the performance of audits, surveillance, and inspections is described as being performed "as appropriate" to indicate that the appropriate type and number of independent verification mechanisms are used to verify compliance with requirements and to make it consistent within the NUQAP.
- 5. The term " Quality Activities" was redefined and substituted for recurring words (e.g.,
design, construction, testing, operation, refueling, maintenance, and modification) since these activities are included in this new definition.
2.2 Summarv of Procosed NUQAP Chances involvino QA Procram Exceotions to NRC-Endorsed ANSI Standards or RGs
- 1. ANSI N18.1-1971. paragraph 4.2.2, states, in part, "The Operations Manager shall hold a Senior Reactor Operators license." NU has developed an attemative to this requirement, which has been accepted by the NRC by Amendment 132 for the Millstone Power Station, Unit No. 3, license, which allows that:
If the Operations Manager does not hold a Senior Reactor Operator license for Millstone Unit No. 3, then the Operations Manager shall have held a Senior Reactor Operator license at a pressurized water reactor, and the Assistant Operations Manager shall hold a Senior Reactor Operator license for Millstone Unit No. 3.
- 2. ANSI N18.1 1971. paragraph 4.2.2, states, in part, "The Operations Manager shall hold a Senior Reactor Operators license." NU has developed an attemative to this requirement, which has been accepted by the NRC by Amendment 190 for the Millstone Power Station Unit No. 2 license, which allows that:
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. l 3-If the Operations Manager does not hold a Senior Reactor Operator license for Millstone Unit No. 2, then the Operations Manager shall have held a Senior l Reactor Operator license at a pressurized water reactor, and an individual j serving in the capacity of the Assistant Operations Manager shall hold a Senior Reactor Operator license for Millstone Unit No. 2.
- 3. ANSI N18.1-1971. paragraph 4.2.2, states, in part, "The Operations Manager shall hold a Senior Reactor Operator's license." NU has developed on altemative to this requirement, which has been accepted by the NRC by Amendment 83 for the Millstone Power Station, Unit No.1, license, which allows that:
If the Operations Manager does not hold a Senior Reactor Operator license for Millstone Unit No.1, then the Operations Manager shall have held a Senior Reactor Operator license at a boiling water reactor, and the Assistant Operations Manager shall hold a Senior Reactor Operator license for Millstone Unit No.1.
- 4. ANSI N45.2.13-1976 - NNECO is taking exception to the provisions in the ANSI standard for performing an acceptance review for purchased engineering and consulting services under 10 CFR Part 50, Appendix B. In order to maintain independence of the vendors, NNECO will not perform an acceptance review of the work the vendors perform for the Independent Corrective Action Verification Program (ICAVP) requirement of the NRC's August 14,1996, Confirmatory Order.
- 5. ANSI N45.2.3-1973 - Provisions for five Housekeeping Zones NNECO has identified the ANSI Housekeeping Zone I as not being applicable to the Millstone units during their operations phase, in addition, as an attemative to the ANSI Zones 11- V, NNECO has established a program for the Millstone units with a minimum of two housekeeping zones with foreign material exclusion procedures defining controls and countermeasures to meet ANSI Zones 11, Ill, IV, and V requirements.
- 6. Exception to NNECO's commitment to RG 1.70, Revision 3, November 1978. - RG 1.70, Revision 3, states that the preliminary safety analysis report (PSAR) should include a listing of QA program procedures or instructions that implement the QA program for each major activity and identify which criteria of Appendix B to 10 CFR Part 50 that are implemented by each procedure, in the past, the NUQAP Topical Report had contained this listing as Appendix C," List of Typical Quality Assurance Related Procedures." Appendix C of the proposed Revision 19 no longer contains such a list. Indices currently maintained in accordance with QA program requirements identify the procedures that implement the QA program for Millstone Power Station and which, by title and originating organization, indicate the applicable 10 CFR Part 50, Appendix B criterion being implemented. This provides an attemative to maintaining a redundant list as an appendix in the NUQAP Topical Report.
3.0 EVALUATION Since QA program exceptions 1.3.1,1.3.2, and 1.3.3, above, have already received NRC approval as part of license amendments, this evaluation addresses exceptions 1.3.4 though 1.3.6 only. These program exceptions constitute reductions in the licensee's QA program description commitments pursuant to Section 50.54(a)(3).
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4 3.1 NUQ/,P Exception to Paragraph 10.3.5 of ANSI N45.2.13-1976 ANSI N45.2.13-1976, " Quality Assurance Requirements for Control of Procurement of items and Services for Nuclear Power Plants," paragraph 10.3.5., states, in part, in certain cases involving procurement of services only, such as third party inspection; engineering and consulting services, and installation, repair, overhaul or maintenance work; the Purchaser may accept the service by any or all of the following methods:
(a) Technical verification of the data produced
- (b) Surveillance and/or audit of the activity .
(c) Review of the objective evidence for conformance to the procurement document requirements such as certifications, stress reports, etc.
In order to maintain the independence requirement of the NRC's August 14,1996, Order (Reference 3), NNECO will not perform an acceptance review of the work produced by the l vendors contracted to conduct the ICAVP. This work will be performed in accordance with the L vendor's own NNECO approved,10 CFR Part 50, Appendix B, Quality Assurance Program.
In an August 14,1996, Confirmatory Order to NNECO, the NRC directed the licensee "to obtain the services of an organization, independent of the Licensee [ emphasis added] and its design contractors, to conduct a multi-disciplinary review of Millstone Units 1,2 , and 3. The review is to provide independent verification that, for selected systems, the Licensee's CMP [ Configuration Management Program) has identified and resolved existing problems, documented and utilized licensing and design bases, and established programs, processes and procedures for effective configuration management in the future."
NNECO relies upon its commitment to the provisions in ANSI N45.2.13-1976 to satisfy the requirements of Criteria IV, " Procurement Document Control," of Appendix B to 10 CFR Part 50,
" Quality Assurance Criteria For Nuclear Power Plants and Fuel Reprocessing Plants."
The staff agrees that the licensee's exception to paragraph 10.3.5 of ANSI N45.2.13-1976, is a reasonable interpretation of the independence provision in the NRC Confirmatory Order.
Therefore, the staff concludes that NNECO's exception to the provisions in paragraph 10.3.5 of ANSI N45.2.13-1976 constitutes a temporary, acceptable alternative to such provisions and applicable only to the vendors carrying out the ICAVP pursuant to the NRC Confirmatory Order.
3.2 NUQAP Excention to ANSI N45.2 3-1973. Subsection 2.1 ANSI N45.2.3-1973," Housekeeping During the Construction Phase of Nuclear Power Plants,"
Subsection 2.1, requires the establishment of five housekeeping zones.
In its June 3,1997, letter NNECO' proposed an altemative to this requirement that establishes for j the Millstone units, as a minimum, a two-zone program to which ANSI Zones I through V i requirements shall be applied as indicated below:
- ANSI Zone 1 requirements are not applicable to Millstone Station nuclear power plant operations and are therefore not applied; Millstone Station nuclear power plant foreign material exclusion (FME) procedures include provisions for implementing controls and countermeasures j l
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that meet or exceed the ANSI Zone 11, Ill, IV, and V requirements with the exception that work planning and the job supervisor shall determine when the ANSI Zones 11 and lil logging requirements for material and personnel accountability and clothing (i.e., gloves, shoe and head covering) are applied
. based upon retrievability and finalinspection of the work performed.
Additionally, by letter dated January 29,1998, NNECO proposed to revise its previous exception to ANSI N45.2.3-1973, Subsection 2.1, in recognition that " construction type" activities could occur during the operations phase of a nuclear power plant. Accordingly, NNECO proposed a new altamative to the ANSI provisions that establishes for the Millstone units, as a minimum, a two zone program to which ANSI Zones I through V requirements shall be applied as indicated below:
Millstone Station nuclear power plant foreign material exclusion (FME) procedures include provisions for implementing controls and countermeasures that meet or exceed the ANSI Zone I,11, lil, IV, and V requirements with the exception that work planning and the job supervisor shall determine when the ANSI Zones I, ll and lli logging requirements for material and personnel accountability and clothing (i.e.,
gloves, shoe and head covering) are applied based upon retrievability and final inspection of the work performed.
However, by letter dated June 9,1998, NNECO withdrew its proposed exception to ANSI N45.2.3-1973, Subsectica 2.1. Therefore, Revision 19 to the NUQAP will continue to meet the provisions of ANSI N45.2.3-1973 with no exceptions. ThWs accepteble.
3.3 NUQAP Fwamation to Sedion 17.1.2.4 of Reau!storv Guida 1.70. Revision 3 (November
.1.EZE)
Regulatory Guide 1.70 Revision 3, November 1978, Section 17.1.2.4 states, in part: "The PSAR should include a listing of QA program procedures or instructions that will be used to implement the QA program for each major activity such as design, procurement, construction, etc. The procedure list should identify which criteria of Appendix B to 10 CFR 50 are implemented by each procedure." -
NU has developed an attemative to this requirement where procedure indices are maintained that identify the procedures that implement the Quality Assurance Program for Millstone Power Station and which by title and originating organization, indicate the Appendix B to 10 CFR Part 50 criterion being implemented. This provides an attemative to maintaining a redundant list as an appendix in the NUQAP Topical Report.
Section 17.1, " Quality Assurance During The Design and Construction," of NUREG-75/087, "USNRC Standard Review Plan,"(SRP), dated November 24,1975, states, on page 17.1-7, paragraph 9, that the [ applicant's] Quality Assurav naram description is acceptable, in part, if
"(a] listing of the QA procedures plus a matrix of tia w procedures cross referenced to each criterion of Appendix B to 10 CFR Part 50 demonstrates that Appendix B provisions are fully implemented by documented procedures." Section 17.1 of the SRP provides the staff's acceptance criteria on this subject for nuclear power plants in the design and construction phase.
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I In Revision 1 to Section 17.1 of the SRP, provisions related to this area of QA program acceptance were modified as follows: " Existing or proposed QA procedures are identified ref octing that each criterion of 10 CFR 50 Appendix B will be met by documented procedure."
(Page 17.1-9, Paragraph 2B4). Subsequently, in Revision 2 of the SRP (July 1982), these provisions were modified to read: " Existing or proposed QA procedures are identified reflecting that Regulatory Guides listed in subsection VI, General Design Criterion 1 of Appendix A to 10 CFR 50,10 CFR Past. 50, $50.55a, and each criterion of 10 CFR Part 50, Appendix B will be met by documented procedures. In addition, activities conducted under 10 CFR Part 50,650.55(e) shall conform to the requirements of the QA program." j l'
Section 17.2, " Quality Assurance During the Operations Phase," Revision 2 (July 1981),
endorses Section 17.1 of the SRP with respect to QA program acceptance in this area. Since the inclusion of a listing of QA program procedures, or instructions that will be used to implement the QA program, is not a pre-requisite for QA program acceptance in Section 17.2 of the SRP, NNECO's proposal is an acceptable altemative to Section 17.1.2.4 of RG 1.70.
4.0 CONCLUSION
While NNECO's proposed QA program exceptions described above constitute reductions in I commitments in the QA program description previously approved by the NRC, such exceptions j contiriue to satisfy the provisions in the applicable ANSI standard and/or Regulatory Guides in i accordance with Section 17.2 of the SRP. Therefore, proposed Revision 19 to NNECO's NUQAP Topical Report, dated June 3,1997, and as amended through June 9,1998, continues to comply with the quality assurance criteria of Appendix B to 10 CFR Part 50 and is acceptable. 1 However, NNECO's exception to the provisions in paragraph 10.3.5 of ANSI N45.2.13-1976 {
constitutes a temporary, acceptable attemative to such provisions and applicable only to the vendors carrying out the ICAVP pursuant to the NRC Confirmatory Order.
5.0 BEEERENCES
- 1. T.C. Feigenbaum letter to the NRC, *Haddam Neck Plan, Millstone Nuclear Power Station, (
Units 1,2, and 3; Annual Reporting of Changes to the Quality Assurance Program; Proposed Revision 19 to the Northeast Utilities Quality Assurance Program Topical Report,"
dated June 10,1996
- 2. USNRC Letter to the Northeast Nuclear Energy Company, "10 CFR 50.54 Quality Assurance Program Change," dated August 7,1996
- 3. USNRC Letter to NNECO," Confirmatory Order Establishing Independent Corrective Action Verification Program (Effective immediately)- Millstone Nuclear Power Station, Units 1,2, and 3," dated August 14,1996
- 4. D.M. Goebel and T.C. Feigenbaum letter to the NRC, *Haddam Neck Plant Quality '
Assurance Program," dated February 20,1997
- 5. B.D. Kenyon letter to the USNRC, " Millstone Nuclear Power Station Units 1,2, and 3 - 1 Annual Reporting of Changes to the Quality Assurance Program, Proposed Revision 19 to j the Northeast Utilities Quality Assurance Program Topical Report - Millstone Nuclear Power j Station," dated June 3,1997
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- 6. B.D. Kenyon letter to the USNRC,
- Millstone Nuclear Power Station Units 1,2, and 3 -
l Annual Reporting of Changes to the Quality Assurance Program, Correction to Proposed Revision 19 to the Northeast Utilities Quality Assurance Proaram Tooical Reoort - Millstone bluclear Power Station." dated August 7,1997
- 7. USNRC Letter to NNECO, " Millstone Nuclear Power Station, Units 1,2, and 3 - Request for Additional Information Regarding Proposed Revision 19 to the Northeast Utilities Quality Assurance Program Topical Report," dated October 3,1997 l 8. B.D. Kenyon letter to the USNRC, " Millstone Nuclear Power Station, Units 1,2, and 3 -
l AdditionalInformation Regarding Proposed Revision 19 to the Northeast Utilities Quality Assurance Prooram Toolcal Reoort." dated November 25,1997
- 9. B.D. Kenyon letter to USNRC,
- Millstone Nuclear Power Station Units 1,2, and 3 - Change to Proposed Revision 19 to the Northeast Utilities Quality Assurance Prooram (NUQAP)
Toolcal Reoort." dated January 29,1998
- 10. USNRC Letter to NNECO, " Request for Additional Information Regarding Revision 19 to the Northeast Utilities Quality Assurance Program, Millstone Nuclear Power Station, Units 1,2, and 3 (TAC Nos. M95739, M95740, and M95741)," dated March 13,1998
- 11. B.D. Kenyon letter to USNRC,
- Millstone Nuclear Power Station Units 1,2, and 3 -
AdditionalInformation Regarding Proposed Revision 19 to the Northeast Utilities Quality Assurance Proaram Toolcal Reoort." dated April 6,1998
- 12. B.D. Kenyon letter to USNRC, " Millstone Nuclear Power Station Units 1,2, and 3 -
AdditionalInformation Regarding Proposed Revision 19 to the Northeast Utilities Quality Assurance Prooram Toolcal Reoort." dated June 9,1998 Principal Contributor: J Peralta Dated: June 24, 1998
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