ML20297A238

Fleet DQAP RAIs - Enclosure

ML20297A238
Person / Time
Site:	Oyster Creek, Pilgrim
Issue date:	10/22/2020
From:	Cruz-Perez Z, Amy Snyder Reactor Decommissioning Branch
To:	Sterdis A Holtec Decommissioning International
Zahira Cruz
Shared Package
ML20297A236	List: ML20297A237 ML20297A238
References
Download: ML20297A238 (4)

Text

REQUEST FOR ADDITIONAL INFORMATION RELATED TO REQUEST FOR APPROVAL OF HDI FLEET DECOMMISSIONING QUALITY ASSURANCE PROGRAM, REVISION 0 OYSTER CREEK NUCLEAR GENERATING STATION PILGRIM NUCLEAR POWER STATION HOLTEC DECOMMISSIONING INTERNATIONAL, LLC DOCKET NOS. 50-219, 50-293, 72-15, 72-1044 By letter dated August 27, 2020 (Agencywide Documents Access and Management System Accession No. ML20240A342), Holtec Decommissioning International (HDI) submitted an application seeking U.S. Nuclear Regulatory Commission (NRC) review and approval of Revision 0 of the Decommissioning Quality Assurance Program (DQAP) for the HDI fleet, in accordance with the provisions of Title 10 of the Code of Federal Regulations (10 CFR) paragraph 50.54(a)(4). The proposed Fleet DQAP provides for the transition of the individual site-specific DQAPs currently in use at Oyster Creek Nuclear Generating Station (Oyster Creek) and Pilgrim Nuclear Power Station (PNPS) to a fleet-based DQAP.

The NRC staff has reviewed HDI's submittal and determined that additional information is required to NRC staff to make an independent assessment regarding its technical review.

Question 1:

Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, Criterion I, in part, states that The persons and organizations performing quality assurance functions shall have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions. The persons and organizations performing quality assurance functions shall report to a management level so that the required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided. of the submittal included a list of changes that detail the changes between the proposed Fleet DQAP (Enclosure 1), Oyster Creek DQAP (Enclosure 3) and PNPS DQAP (Enclosure 4). In Section 1.1 of this table, the licensee states that The Fleet DQAP Station Management Section does not include the PNPS site Quality Assurance Manager position and responsibilities. In the Fleet DQAP, the management position responsible for Nuclear Oversight is part of the corporate organization. It further states that "Not including in the Fleet DQAP, the Quality Assurance Manager position and associated responsibilities from the Station Management Section of the PNPS DQAP, is a reduction in commitment since there is no longer a requirement for a Quality Assurance Manager permanently stationed at the PNPS site. This change is a reduction in commitment and requires NRC approval prior to implementation in accordance with 10 CFR 50.54(a)(4). This change does not reduce the overall effectiveness of

the DQAP. Site Quality assurance personnel will report to a Manager at the Corporate level with a reporting chain up through the Chief Nuclear Officer.

Section 1.3.1 of the PNPS DQAP states that The Pilgrim Nuclear Power Station (PNPS) site Quality Assurance Manager is responsible for site execution of the PNPS quality assurance program. This position has overall authority and responsibility for establishing, controlling and verifying the implementation and adequacy of the quality assurance program as described in this DQAP under the direction of the HDI Vice President of Quality Assurance. This position has the authority and responsibility to escalate matters directly to the highest-level nuclear executive of HDI if necessary.

It is unclear to the staff that how the elimination of a site Quality Assurance Manager will not reduce the overall effectiveness of the DQAP. Therefore, the licensee is requested to provide additional information for the following:

a) Without a site QA Manager, who would be the point of contact between the site QA personnel and Corporate? Whom, in the Corporate level, will site QA personnel report to?

b) Who would resume the overall responsibilities that a site QA Manager would have, such as establishing, controlling, and verifying the implementation and adequacy of the QA program to ensure that the QA program is still in compliance with the requirement delineated in Appendix B to 10 CFR Part 50?

c) Who, on site, would have authority and responsibility to escalate matters directly to the highest level nuclear executive of HDI if necessary?

d) In addition, Section 1.2.3 of the proposed Fleet DQAP details the functional responsibilities of the HDI Vice President Quality Assurance and Nuclear Oversight.

Similar language is found in Section 1.2.1 of the Oyster Creek DQAP for a management position responsible for Nuclear Oversight. However, two of the responsibilities, 1) assuring quality activities are performed in accordance with implementing procedures, and 2) Employee Concern Program, are not included in the proposed Fleet DQAP.

Therefore, the licensee is requested to provide information on who would be responsible for 1) assuring quality activities are performed in accordance with implementing procedures, and 2) Employee Concerns Program.

Question 2:

Appendix B to 10 CFR Part 50, Criterion I, in part, states that The persons and organizations performing quality assurance functions shall have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions. The persons and organizations performing quality assurance functions shall report to a management level so that the required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided. Because of the many variables involved, such as the number of personnel, the type of activity being performed, and the location or locations where activities are performed, the organizational structure for executing the quality assurance program may take various forms, provided that the persons and organizations assigned the quality assurance functions have the required authority and organizational freedom.

Section 2.5.1 of both the Oyster Creek DQAP and PNPS DQAP state that The management position responsible for Nuclear Oversight (or the HDI VP Quality and Nuclear Oversight) is responsible for ensuring that the applicable portions of the DQAP are properly documented, approved and implemented before an activity within the scope of the DQAP is executed.

Disputes arising between departments or organizations on any QA matter that cannot be resolved at a lower level of management will be referred to the CNO [Chief Nuclear Officer].

Similar language is found in Section 2.5.1 of the proposed Fleet DQAP. However, the proposed Fleet DQAP does not provide details how disputes arising between departments or organizations on any QA matters will be resolved.

It is unclear to the staff that should disputes arise on any QA matter between departments or organizations, how would these disputes be resolved and who will have the authority to decide on these disputes. Therefore, the licensee is requested to provide additional information on how QA matters will be resolved when disputes arise between departments or organizations, and who will have the final authority when disputes arise.

Question 3:

Appendix B to 10 CFR Part 50, Criterion I, in part, states that the applicant may delegate to others, such as contractors, agents, or consultants, the work of establishing and executing the quality assurance program, or any part thereof, but shall retain responsibility for the quality assurance program.

Section 5.3 of the Oyster Creek DQAP and PNPS DQAP both state that Controls are established which ensure that instructions, procedures, and drawings are current and accurately reflect plant design and regulatory requirements. Documents comprising of instructions, procedures, specifications, and drawings prepared by outside contractors for the performance of site activities are reviewed and approved by the responsible manager or designated representative. Section 5.3 of the proposed Fleet DQAP has similar language; however, it does not have any specific instructions for documents prepared by outside contractors and how these documents are reviewed and approved, and who is responsible for the accuracy of these documents.

Section 1.2.1 of the Fleet DQAP delineates that the HDI Chief Operating Officer (COO) has the overall responsibility for the safety, operation, and decommissioning of the nuclear sites. This position is responsible for providing management direction, oversight and support to the site organizations and for setting and implementing policies, objectives, expectations, and priorities to ensure activities are performed in accordance with the DQAP and other requirements.

It is unclear to the staff how documents prepared by outside contractors are reviewed and approved. Therefore, the licensee is requested to provide additional information regarding documents such as instructions, procedures, specifications, and drawings prepared by outside contractors, how these documents are reviewed and approved, and who has the overall responsibility for the accuracy of these documents.

Question 4:

Appendix B to 10 CFR Part 50, Criterion VII, in part, states 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. Documentary evidence that material and equipment conform to the procurement requirements shall be available at the nuclear power plant or fuel reprocessing plant site prior to installation or use of such material and equipment. This documentary evidence shall be retained at the nuclear power plant or fuel reprocessing plant site and shall be sufficient to identify the specific requirements, such as codes, standards, or specifications, met by the purchased material and equipment.

Section 7.2 of both the Oyster Creek DQAP and PNPS DQAP state that Verification that a vendor can meet the specified technical and quality requirements shall be documented. HDI maintains an Approved Vendor List (AVL) for those vendors qualified to perform safety significant work that are audited on a triennial basis. Documented vendor performance monitoring is performed in accordance with approved procedures as an acceptable alternate to the performance of the annual evaluation of vendors. The evaluated list of such vendors is described in controlling procedures for the appropriate safety significant classification except for procurement from other licensees that have an NRC approved quality program. Vendors of commercial grade calibration and testing services may be qualified based on their accreditation by a nationally-recognized accrediting body, as an alternative to qualification by vendor audit, commercial grade survey, or in-process surveillance as described below.

Section 7.2 of the proposed Fleet DQAP states that Verification that a vendor can meet the specified technical and quality requirements shall be documented. HDI maintains an Approved Vendor List (AVL) for those vendors qualified to perform safety significant work. The qualification requirements for vendors on the AVL are described in controlling procedures.

Vendor qualification processes use a graded approach based on the qualification level of the vendor.

It is unclear to the staff what is this graded approach for vendor qualification processes as stated in the proposed Fleet DQAP. Therefore, the licensee is requested to provide additional information and describe what is this graded approach for vendor qualification process.

Specifically, what measures, including documentary evidence, are in place to assure that purchased material, equipment, and services, conform to the procurement documents.