ML23345A166

Tennessee Valley Authority - Pre-submittal Meeting for Conversion of Nuclear Quality Assurance Plan from ANSI N45.2-1971 to ASME NQA-1-2015 (EPID L-2023-LRM-0103) - Slides

ML23345A166
Person / Time
Site:	Sequoyah
Issue date:	12/13/2023
From:	Tennessee Valley Authority
To:	Kimberly Green NRC/NRR/DORL/LPL2-2
Wentzel M
References
EPID L-2023-LRM-0103
Download: ML23345A166 (14)

Text

Tennessee Valley Authority December 13, 2023 Pre-submittal Meeting for Conversion of Nuclear Quality Assurance Plan from ANSI N45.2-1971 to ASME NQA-1-2015

Agenda Opening Remarks

Background

Key Updates in New TVA Nuclear Quality Plan Key Alternative Commitments in New Quality Plan Developmental Resources Submittal Content Changes to Quality Assurance Program Description (QAPD)

Changes to Technical Specifications (TS)

Justification for TS Change Submittal Schedule Milestones Closing Remarks l 2

Opening Remarks The Tennessee Valley Authority (TVA) operating fleet currently operates under a Quality Plan based on the ANSI N45.2-1971 standard. This includes seven operating reactors at three nuclear sites, three Independent Spent Fuel Storage Installations, and the Clinch River Nuclear (CRN) site under an Early Site Permit.

The proposed Quality Plan is based on:

American Society of Mechanical Engineers (ASME) NQA-1-2015, Quality Assurance Requirements for Nuclear Facility Applications as endorsed by Regulatory Guide (RG) 1.28, Revision 5, Quality Assurance Program Criteria (Design and Construction),

ANSI/ANS 3.2-2012, Managerial, Administrative, and Quality Assurance Controls for the Operational Phase of Nuclear Power Plants as endorsed by RG 1.33, Revision 3, Quality Assurance Program Requirements (Operation).

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Background===

Vision: Transition the TVA operating fleet to a Quality Plan based on the NQA-1-2015 standard, to support future state of the operating fleet and New Nuclear.

Revise the operating fleet QA Plan to the NQA-1-2015 standard to align with the previously submitted TVA New Nuclear QAPD. Quality Plans based on a common standard support the sharing of TVA programs, processes and resources.

QA Plan Transition Approach Adopt the most recent quality-related NRC Regulatory Guides and minimize exceptions / alternatives (exception - RG 1.28, Revision 6)

Submit a Quality Assurance Program Description (QAPD) for the operating fleet based on NQA-1-2015 and ANSI/ANS 3.2-2012 Submit a New Nuclear QA Plan (Complete, pending Safety Evaluation (SE) issuance) l 4

Key Updates in New TVA Nuclear Quality Plan The new QAPD conforms to NQA-1-2015 as endorsed by RG 1.28, Revision 5 and ANSI/ANS 3.2-2012 as endorsed by RG 1.33 Revision 3.

New QAPD records standard conforms to NIRMA TG 2011 Series.

Replaced the offsite independent review committee with an independent review body (combining the onsite review committee, QA, and line management) consistent with ANSI/ANS 3.2-2012 and Duke Energy letter to NRC dated May 22, 2017 (ML17143A355).

Unnecessary details, examples, and redundant information have been removed to align with the language in NQA-1-2015.

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Key Alternative Commitments l 6 Maintain commitments to historical design and construction standards in effect when plants were built.

Maintain commitment to alternative administrative processes versus ANSI/ANS 3.2-2012 requirement for two-year procedure review.

Maintain a 36-month periodicity for internal audits of 10 CFR 50 Appendix B activities (not applicable to regulatory-based audits).

Where ANSI/ANS 3.2-2012 references NQA-1-2008 and NQA-1-2009 addenda for requirements, TVA Nuclear will follow NQA-1-2015.

Developmental Resources l 7 Palo Verde Nuclear Generating Station submittal and SE for transition to NQA-1, 2008 with 2009 Addendum (ML16194A323)

NEI 11-04, Nuclear Generation Quality Assurance Program Description NUREG-0800, Section 17.5, Quality Assurance Program Description - Design Certification, Early Site Permit and New License Applicants NRC Requests for Additional Information (RAI) for New Nuclear QAPD submittal.

Submittal Content l 8

Changes to QAPD

Related Changes to TS

Changes to QAPD l 9

Proposed TVA QAPD

Comparison of Existing to Proposed Quality Plan Regulatory Guide Commitments

Comparison of Existing to Proposed Quality Plan Requirements

Changes to TS l 10

Associated TS Change for all three sites:

BFN TS Change

SQN TS Change

WBN TS Change

Justification for TS Change l 11 The proposed TS change will allow flexibility for TVA to adopt future revisions of RG 1.33 without having to submit a license amendment request and instead be controlled by the NRC-approved TVA NQAP.

The proposed TS change is consistent with the intent of NRC Administrative Letter 95-06.

The proposed TS change is also consistent with BFN License Amendments Nos. 298, 322, and 282, and SQN License Amendment Nos. 338 and 331 (ML17034A360).

Submittal Schedule Milestones l 12 Submittal to NRC targeted for January 31, 2024.

NRC approval requested within 1 year of the date of the submittal.

Transition to the new Fleet QA Plan will be within 6 months of NRC approval of the QAPD and proposed TS change will be implemented within 60 days of NRC approval.

Closing Remarks l 13