ML24004A185
| ML24004A185 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 01/04/2024 |
| From: | Southern Nuclear Operating Co |
| To: | Division of Operating Reactor Licensing |
| References | |
| EPID L-2023-LRM-0106 | |
| Download: ML24004A185 (1) | |
Text
SNC Vogtle 3&4 Pre-Submittal Meeting Transition of the Vogtle 3&4 Quality Assurance Program (QAP) from the Nuclear Development Quality Assurance Manual (NDQAM) to the SNC Fleet Quality Assurance Topical Report (QATR)
January 8, 2024
Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR
- The purpose is to discuss the transition of the Vogtle 3&4 Quality Assurance Program from the Nuclear Development Quality Assurance Manual (NDQAM) to the fleet Quality Assurance Topical Report (QATR).
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR
- This meeting will cover the following topics for each license amendment request:
- Reason for Proposed Change
- Overview License Amendment Request
- Precedent (if applicable) 3
Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR
- Reason for Proposed Change Aligns all SNC plants to a common Quality Assurance Plan Description SNC operating plants (except V34) use a common Quality Assurance Plan Description -
[Quality Assurance Topical Report (QATR)]
V34 has separate Quality Assurance Plan Description - Nuclear Development Quality Assurance Manual (NDQAM)
Integrates V34 quality plan commitments from NDQAM with QATR Updates Fleet QA plan description (QATR) to incorporate improvements in formatting and content.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part I Changes Change Discussion Added reference to 10 CFR 52 and NUREG 0800 Section 17.5, V34 Commitment Additions Revision 0, as appropriate.
Added NDQAM statement, SNC may delegate to others, such Potential increase in Commitment (F, H, V1&2) as contractors, agents, or consultants, the work of V34 Commitment Addition establishing and executing the quality assurance program, or any part thereof, but shall retain responsibility for the quality assurance program.
Replaced Definitions of terms used in this QATR and not QATR Improvement Item. Definitions are contained in contained in NQA-1-1994 list of definitions are shown in referenced standards/regulatory document. This is coupled Appendix D to the QATR. with The definitions provided in with the deletion of Appendix D Definitions.
NQA-1-1994, Part I, Introduction, Section 4 or ANS-3.2/ANSI N18.7-1976 apply to select terms as used in this document.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Organization)
Change Discussion Replaced NDQAM statement Specific titles identifying Vogtle 3&4 impact only. Adopted QATR description for the fleet individuals responsible for implementation of QA program regarding the location titles responsible for implementation of elements are provided in the conduct of operations procedures QA program elements. No impact to any plant conduct of for the applicable departments. with existing QATR statement operations procedures.
Specific titles identifying individuals responsible for implementation of QA program elements are provided in the conduct of operations described in Chapter 13 of the applicable site FSAR.
Revised subsection to state that construction is complete all QATR Improvement Item.
sites and added clarification language from the NDQAM regarding major rework and modifications during the Operation Phase Added the NDQAM subsection general description language QATR Improvement Item.
the operational structure during the operational phase 6
Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Organization cont..)
Change Discussion Reduced levels of management listed this subsection. Fleet: QATR Improvement Item. Changes are made to the President and CEO, Chief Nuclear Officer/EVP, Sr. Vice President organization section of the QATR to limit the extent and detail
- Operations, Vice President - Operations Support, Vice of organization position description consistent with current President - Engineering, Vice President - Regulatory Affairs, industry practice. (ex. Palo Verde SER) The descriptions of these Vice President Human Resources and Senior manager positions list the direct reports performing a quality function.
responsible for supply chain. Site: Vice President - Site and Plant manager remain.
Removed levels of management listed this subsection to QATR Improvement Item. The current NDQAM description is positions that do not perform quality-related activities as used.
described in NQA-1-1994 or the organization structure above the position was sufficient to describe the QA function.
Added the NDQAM general description of Independent QATR Improvement Item. The current NDQAM description is Oversight to this subsection used.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Quality Assurance Program)
Change Discussion Added a new subsection titled Independent Review which The new Independent Review subsection implements the QAP aligns with the level of detail of the NDQAM and Option 1 of as described in Option 1 of NEI 06-14A but incorporating the NEI 06-14A. As a result, the QATR Appendix A Plant Review knowledge and experience from QATR.
Board (PRB) and Appendix B Independent Review is deleted.
The Plant Review Board (PRB) is designated as the Independent Review Body as stated in Option 1 of NEI 06-14A.
With regards to the PRB meeting schedule, the new section Potential Reduction in Commitment (F, H and V 1&2) states, Activities occurring during the operational phase shall The QATR currently states, The PRB shall meet at least once be independently reviewed on a periodic basis. per calendar month, or more frequently if convened by the PRB Chairperson. The periodicity will be controlled by implementing procedures.
With regards to oversight of PRB activities, the new section Potential Reduction in Commitment (F, H and V 1&2) states, The results of IRB reviews of matters involving the The QATR currently states, SNC periodically performs safe operation of the facility are periodically independently independent reviews of matters involving the safe operation reviewed. of its fleet of nuclear power plants, with a minimum of one such review being conducted for each generating site each year. ... The performance of the Plant Review Board is included in this review. The periodicity will be controlled by implementing procedures.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Quality Assurance Program cont..)
Change Discussion The NDQAM statement, Reviews the adequacy of the audit Potential Reduction in Commitment (V 3&4) program every 24 months will not be transferred to the QATR. Farley, Hatch and Vogtle 1&2 use the Nuclear Industry Evaluation Program (NIEP) to audit the QA programs for each utility every 36 months. Vogtle 3&4 will be subject to this process when integrated into the fleet QATR.
The minimum required education and experience of the PRB The plant and support staff, in which PRB membership are (i.e., Independent Review Committee) Chair and Members as drawn from, qualification requirements are as delineated in stated in the NDQAM will not be transferred to the QATR. each sites Technical Specifications.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Design Control)
Change Discussion Added subsections for Computer Application and Digital V34 Commitment Additions Equipment Software (Vogtle 3&4 Only) and Setpoint Control (Vogtle 3&4 Only)
Added Vogtle 3&4 specific commitment to NQA-1-1994 V34 Commitment Addition 10
Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Procurement Document Control)
Change Discussion 10 CFR 50.55(e) references removed from this section. 10 CFR 50.55(e) is related to construction activities; thus, it is historical.
The NDQAM statement, 10 CFR 21 requirements for posting, Duplicate information. The QATR contains the following evaluating and reporting will be followed and imposed on statement, Applicable technical, regulatory, administrative, suppliers when applicable. will not be transferred to the quality and reporting requirements (such as specifications, QATR. codes, standards, tests, inspections, special processes, and 10 CFR 21) are invoked for procurement of items and services.
Added NDQAM language regarding contracts bids or awards QATR Improvement Item. The statements capture various reviews. requirements found in Basic Requirement 4 and Basic Requirement 8 of NQA-1 which are currently applicable to the Fleet.
Relocated International Laboratory Accreditation Cooperation QATR Improvement item (ILAC) commitment items to Part II, Section 7 NQA-1-1994 Commitments 11
Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Instructions, Procedures, and Drawings)
Change Discussion Removed this statement from the Temporary Procedure The scope of PRB reviews is detailed new subsection titled Control subsection, and, if required, reviewed by the Plant Independent Review. Review of temporary procedures is not Review Board and approved by the appropriate plant mentioned in scope but require PRB for review if a 50.59 management within 14 days of implementation. Evaluation is required by implementing procedures.
Incorporated NDQAM language on Procedure Content. QATR Improvement Item.
Remove the following statement, Appendix E of this QATR Appendix E provides redundant information. The information in provides additional details regarding procedures developed Appendix E was provided as equivalent requirements for and implemented by SNC. meeting the regulatory positions of Reg. Guide 1.33, Rev. 2.
SNC commitment to Reg. Guide 1.33, Rev. 2 is described in QATR Part III, Regulatory Commitments.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Document Control)
Change Discussion The NDQAM Subsection 1.2, Types of Documents to be The NDQAM language was derived from bracketed and controlled will not be transferred to the QATR. italicized information in NEI 06-14A as examples of the documents to be controlled and is not all inclusive. The QATR does not list the types of documents to be controlled to this level of detail.
The NDQAM Subsection 2.0, Review and Approval of Potential Reduction in Commitment (V 3&4)
Documents will not be transferred to the QATR. Level of detail not in the QATR. Activity controlled at the procedure level.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Identification And Control Of Materials, Parts, and Components)
Change Discussion Added clarification language NDQAM statement, This includes QATR Improvement Item.
controls for consumable materials and items with limited shelf life to preclude the use of items whose shelf life has expired.
Added commitment, There are specific personnel Increase in commitment (F, H, V1&2) qualification and certification requirements for personnel performing safety-related non-destructive evaluation (NDE) activities for the nuclear industry that are not addressed by the ILAC accreditation process. Therefore, the ILAC accreditation process cannot be used as part of the commercial-grade dedication process of NDE services in lieu of performing procurement source evaluation and selection.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Control of Special Processes)
Change Discussion Only editorial changes.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Inspection)
Change Discussion The NDQAM Subsection 2.0, Inspection Program will not be Potential Reduction in Commitment (V 3&4) transferred to the QATR. Level of detail not in the QATR. Activity controlled at the procedure level.
Added NDQAM statement regarding Inspector Qualification, QATR Improvement Item.
SNC has established qualification programs for personnel performing quality inspections. The qualification program requirements are described in Part II, Section 2. These qualification programs are applied to individuals performing quality inspections regardless of the functional group where they are assigned.
Added NDQAM statement regarding NQA-1-1994 V34 Commitment Addition Commitment for Vogtle 3&4 only, For structures with design based on American Concrete Institute ACI-349, the testing and inspection requirements of ACI-349, as identified and supplemented in Updated Final Safety Analysis Report Section 3.8, may be applied in lieu of NQA-1-1994 Subpart 2.5, paragraph 7.13.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Test Control)
Change Discussion Added NDQAM statement, Tests are performed and results QATR Improvement Item.
documented in accordance with applicable technical and regulatory requirements including those described in the Technical Specifications and UFSAR. Test programs ensure appropriate retention of test data in accordance with the records requirements of this QATR. Personnel that perform or evaluate tests are qualified in accordance with the requirements established in Part II, Section 2.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Control Of Measuring and Test Equipment)
Change Discussion Added NDQAM statement, The suppliers of commercial- QATR Improvement Item.
grade calibration services shall be controlled as described in Part II, Section 7.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Handling, Storage, and Shipping)
Change Discussion Added NDQAM statement, The suppliers of commercial- QATR Improvement Item.
grade calibration services shall be controlled as described in Part II, Section 7.
The NDQAM statements regarding the special handling devices Potential Reduction in Commitment (V 3&4) will not be transferred to the QATR. Special handling devices are described in the UFSAR/FSAR for each site with regards to compliance to NUREG-0612, Control of Heavy Loads at Nuclear Power Plants.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Inspection, Test, and Operating Status)
Change Discussion Added NDQAM statement, Administrative procedures also QATR Improvement Item.
describe the measures taken to control altering the sequence of required tests, inspections, and other operations. Review and approval for these actions is subject to the same control as taken during the original review and approval of tests, inspections, and other operations.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Nonconforming Materials, Parts, or Components cont.)
Change Discussion Added NDQAM statement, Administrative procedures also QATR Improvement Item.
describe the measures taken to control altering the sequence of required tests, inspections, and other operations. Review and approval for these actions is subject to the same control as taken during the original review and approval of tests, inspections, and other operations.
The QATR statement, Conditional release of nonconforming Potential Reduction in Commitment (F, H, V 1&2) items for installation requires the approval of the vice president - site or his designee. to Conditional release of nonconforming items for installation requires the approval of the designated management.
The NDQAM statement, Nonconformance dispositions are Potential Reduction in Commitment (V 3&4) reviewed for adequacy, analysis of quality trends, and reports Analysis of trends of nonconformances is described in NUREG-provided to the designated management. will not be 0800-17.1, but it is not in NUREG-0800-17.5 and this change is transferred to the QATR. consistent with ANSI N18.7. NQA-1-1994 does not describe trending of dispositions of nonconformances. Appendix 16A-1, Nonmandatory Guidance on Corrective Action, Section 3.1 states, Conditions adverse to quality should be reviewed to determine the existence of trends. This is consistent with QATR Part II, Section 16 which requires trending of conditions adverse to quality and analysis of the trends. 21
Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Nonconforming Materials, Parts, or Components cont..)
Change Discussion The NDQAM Subsection 2.0, Reporting Program will not be Potential Reduction in Commitment (V 3&4) transferred to the QATR. This describes administrative controls that are controlled by the Corrective Action Program, the Part 21 Reporting Program and detailed in existing fleet and site procedures.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Corrective Action)
Change Discussion The following NDQAM statements will not be transferred to the Potential Reduction in Commitment (V 3&4)
QATR: Level of detail not in the QATR. Activity controlled at the
- SNC procedures require personnel to identify known procedure level.
conditions adverse to quality.
- In the case of a significant condition adverse to quality, the cause is determined and actions to preclude recurrence are taken.
The following NDQAM statements will not be transferred to the Duplicate information. Section 4 Procurement Document QATR: In the case of suppliers working on safety-related Control NQA 1 1994 Commitment, states In lieu of this activities, or other similar situations, SNC may delegate requirement, SNC may require suppliers to have a documented specific responsibilities for corrective actions but SNC supplier quality assurance program that is determined to meet maintains responsibility for the effectiveness of corrective the applicable requirements of 10 CFR 50, Appendix B, as action measures. appropriate to the circumstances of the procurement which will include a corrective action program.
The NDQAM Subsection 2.0, Interface with the Reporting Potential Reduction in Commitment (V 3&4)
Program will not be transferred to the QATR. This describes administrative controls that are controlled by the Corrective Action Program, the Part 21 Reporting Program and detailed in existing fleet and site procedures.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Quality Assurance Records)
Change Discussion Added NDQAM statement, Measures are established that QATR Improvement Item.
ensure that sufficient records of completed items and activities affecting quality are appropriately stored.
Under Consideration: Upgrading to the latest Nuclear Information and Records Management Association (NIRMA) standards.
[Ref. R.G. 1.28, Quality Assurance Program Criteria (Design and Construction) Rev. 6]
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial QATR Part II Changes (Audits)
Change Discussion Adopted the QATR Section Performance of Audit to align NDQAM Part II, Section 18, 3.0 Internal Audits, Paragraph 3.2 Vogtle 3&4 audit intervals with the Fleet states, Audits of Fleet organizations established prior to new construction will be conducted at the frequency indicated in the SNC QATR. Additionally, NEI 06-14A provides for extending frequencies of audits that is consistent with the SNC method.
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Non-Editorial Changes Part III (Regulatory Commitments)
Change Discussion Add Vogtle 3&4 specific commitment to Regulatory Guide 1.8 V34 Commitment Addition Add Vogtle 3&4 specific commitment to Regulatory Guide V34 Commitment Addition 1.26, revision 4 Remove Vogtle 3&4 commitment to Regulatory Guide 1.33, Potential Reduction in Commitment (V 3&4)
Revision 2 to be consistent with SNC Fleet QATR 26
Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR Additional Non-Editorial Changes Change Discussion Appendix A Plant Review Board Deleted Relocated to new QATR Independent Review Section (Adopted NDQAM Language)
Appendix B Independent Review Deleted Relocated to new QATR Independent Review Section (Adopted NDQAM Language)
Appendix C Quality Assurance Surveillances Deleted As stated in ASME NQA-1-1994, Part I, Section 4, Terms and Definitions, an audit should not be confused with surveillance or inspection activities performed for the sole purpose of process control or product acceptance. SNC procedure NOS-106, Nuclear Oversight Surveillances, version 7.0, would be incorporated by reference.
Appendix D Definitions Deleted Duplication. Definitions are provided in NQA-1-1994, Part I, Introduction, Section 4 or ANS-3.2/ANSI N18.7-1976.
Appendix E Procedures Deleted This appendix provides redundant information. The information in Appendix E was provided as equivalent requirements for meeting the regulatory positions of Reg. Guide 1.33, Rev. 2.
SNC commitment to Reg. Guide 1.33, Rev. 2 is described in QATR Part III, Regulatory Commitments.
Created new Part V Nonsafety-Related SSC Quality Control V34 Commitment Addition (Vogtle 3&4 Only) [NDQAM Part III]
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Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR
- Precedent 28
Schedule Transition the Vogtle 3&4 QAP from the NDQAM to the SNC Fleet QATR
- Schedule
- Submit LAR - 3rd Quarter 2024.
- Request Approval - 1 year from acceptance.
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Questions?