ML24345A226
| ML24345A226 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Watts Bar, Sequoyah, 99902056  |
| Issue date: | 11/21/2024 |
| From: | Kimberly Green Plant Licensing Branch II |
| To: | Hughes S Tennessee Valley Authority |
| Green K | |
| References | |
| EPID L-2024-LLQ-0000 | |
| Download: ML24345A226 (1) | |
Text
From:
Kimberly Green To:
Hughes, Shawna Marie
Subject:
Draft Request for Additional Information - TVA Request for Approval of Revision 43 to TVA Fleet Quality Assurance Program Description (EPID L-2024-LLQ-0000)
Date:
Thursday, November 21, 2024 3:02:00 PM Attachments:
Draft RAI for TVA Fleet QAPD Revision 21-24.docx
Dear Shawna Hughes:
By letter dated April 1, 2024 (Agencywide Documents Access and Management System Accession No. ML24093A047), Tennessee Valley Authority (TVA) submitted Topical Report (TR) NQA-PLN89-A, Revision 43, Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan, to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. Revision 43 to the TVA Fleet Quality Assurance Program Description (QAPD) would convert the TVA Fleet QAPD from American National Standards Institute (ANSI)
N45.2-1971, Quality Assurance Program Requirements for Nuclear Power Plants, and ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants, to American Society of Mechanical Engineering (ASME)
Nuclear Quality Assurance (NQA)-1-2015, Quality Assurance Requirements for Nuclear Facility Applications.
The NRC staff is reviewing your submittal and has identified areas where additional information is needed to complete its review. Attached, please find a draft request for additional information (RAI).
The draft RAI is being sent to ensure that the request is understandable and the regulatory basis for the request is clear. This email and the attachment do not convey or represent an NRC staff position regarding TVA's request.
Please let me know if TVA needs a call to clarify the NRC staffs requests
Sincerely, Kimberly Green, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
1 REQUEST FOR ADDITIONAL INFORMATION TENNESSEE VALLEY AUTHORITY BROWNS FERRY NUCLEAR PLANT, UNITS 1, 2, AND 3; SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2; WATTS BAR NUCLEAR PLANT, UNITS 1 AND 2; CLINCH RIVER NUCLEAR SITE DOCKET NOS. 50-259, 50-260, 50-296, 50-327, 50-328, 50-390, 50-391, 99902056 Introduction By letter dated April 1, 2024 (Agencywide Document Access and Management System Accession No. ML24093A047), the Tennessee Valley Authority (TVA) submitted Topical Report (TR) NQA-PLN89-A, Revision 43, Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan, (hereafter referred to as TVA Fleet QAPD) to the U.S. Nuclear Regulatory Commission (NRC). In this letter TVA requested the NRC staffs review and approval of the TVA Fleet QAPD included in Enclosure 1 of the letter pursuant to the requirements in Title 10 of the Code of Federal Regulations (10 CFR) 50.54(a), Conditions of licenses. By letter dated September 24, 2024 (ML24268A322), TVA submitted a supplement to its April 1, 2024, request. TVA stated that the supplement provides an update to the TVA Fleet QAPD in its entirety. Revision 43 to the TVA Fleet QAPD would convert the TVA Fleet QAPD from American National Standards Institute (ANSI) N45.2-1971, Quality Assurance Program Requirements for Nuclear Power Plants, and ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants, to American Society of Mechanical Engineering (ASME) Nuclear Quality Assurance (NQA)-1-2015, Quality Assurance Requirements for Nuclear Facility Applications.
The NRC staff reviewed the information presented in the TVA Fleet QAPD, Revision 43, as submitted in Enclosure 1 of TVAs letter dated in September 24, 2024 against the quality assurance (QA) requirements in Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, in accordance with the review guidance in NUREG-0800, Standard Review Plan (SRP), Section 17.5, Quality Assurance Program Description - Design Certification, Early Site Permit and New License Applicants, Revision 1. Based on this review, the NRC staff requests the following additional information, as documented below, to complete its review.
Underlining is used throughout this RAI document to add emphasis.
RAI 1
The regulation at 10 CFR 50.34(a)(7) requires an application for a construction permit (CP) to include a description of the quality assurance program (QAP) to be applied to the design, fabrication, construction, and testing of structures, systems, and components of the facility. The
2 description of the QAP for a nuclear power plant or a fuel reprocessing plant shall include a discussion of how the applicable requirements of Appendix B to 10 CFR Part 50 will be satisfied.
In the September 24, 2024, letter, TVA stated, in part, that:
Prior to CRN [Clinch River Nuclear] CPA [Construction Permit Application]
approval, work performed for New Nuclear and CRN CPA development is governed by the Fleet QAPD, currently under Revision 42, and will continue under the proposed Revision 43, until the CPA is approved. The New Nuclear QAPD will be incorporated by reference in the CRN CPA submittal.
Implementation of the New Nuclear QAPD will occur after Fleet QAPD Revision 43 implementation and prior to CPA approval.
The Executive Summary of the TVA Fleet QAPD, states, in part, that:
[this] document provides a description of the TVA nuclear quality assurance program (QAP) for the operation of licensed nuclear plants at Browns Ferry Nuclear, Sequoyah Nuclear (SQN), and Watts Bar Nuclear (WBN).
This Fleet QAPD applies to the CRN Small Modular Reactor (SMR) Project while under an approved early site permit (ESP) as well as the TVA New Nuclear Program Organization which addresses infrastructure and programmatic matters with siting, licensing, and planning for new nuclear projects, until such time as the
[QAPD] for New Nuclear (NNQAP, Reference NNP-TR-001-NP-A) is implemented and the CPA for CRN Project is approved by the NRC. After this milestone, New Nuclear Projects and Program work for siting, site-selection, design, licensing, planning, construction, and operation of new TVA nuclear plants (including the CRN SMR Project after issuance of the Construction Permit) are addressed under the TVA [New Nuclear QAPD].
The TVA Fleet QAPD does not clearly identify the timelines and conditions for when TVA New Nuclear Projects and Program will be governed by the TVA Fleet QAPD. Specifically, it is not clear whether both conditions (i.e., implementation of the TVA New Nuclear QAPD and CPA approval by the NRC) must be satisfied for TVA New Nuclear Projects and Program to be governed by the TVA New Nuclear QAPD.
Given that these timelines and conditions are clearly described in the September 24, 2024, letter from TVA, explain why TVA did not incorporate the language from the September 24, 2024, letter into the TVA Fleet QAPD.
RAI 2
Criterion I, Organization, of Appendix B to 10 CFR Part 50 requires, in part:
The applicant shall be responsible for the establishment and execution of the Quality Assurance Program (QAP)The authority and duties of person and organizations performing activities affecting the safety-related functions of SSCs shall be clearly established and delineated in writing. The persons and organizations performing QA 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 organizations performing quality assurance functions shall report to a management level so that the required authority and organizational freedom,
3 including sufficient independence from cost and schedule when opposed to safety considerations, are provided.
Part II, Section 1, Organization, of the TVA Fleet QAPD describes the TVA Nuclear organizational structure, functional responsibilities, levels of authority and interfaces for establishing, executing, and verifying QAPD implementation.
Part II, Section 1.3 of the TVA Fleet QAPD states that the Chief Operating Officer is responsible for TVAs transmission and power supply, power operations, resource management and operations services, and generation projects and fleet services.
Part II, Section 1.4 of the TVA Fleet QAPD states that the Chief Nuclear Officer (CNO) is responsible for the safe, reliable, and efficient operation of the TVA nuclear plants. The CNO has overall responsibility for the establishment, implementation, and administration of the TVA Fleet QAPD and the evaluation of its effectiveness. This responsibility is implemented through the General Manager, QA. The CNO also supports the TVA New Nuclear Program activities through the Senior Vice President, Engineering and Operations Support. Part II, Section 1.4 of the TVA Fleet QAPD also specifies that roles and responsibilities for licensing activities related to the New Nuclear Program and TVA New Nuclear project sites are governed by TVA New Nuclear procedures and guidelines. Part II, Section 1.4, Item B.5 of the TVA Fleet QAPD states that the Vice President, New Nuclear Program interfaces with the Vice President Site Project for project-related advanced nuclear technology development nuclear technology development, Licensing, Supply Chain, and Safety during the design phase, and for corporate support during construction and operations in fulfillment of their responsibilities.
Part I, Section 2, of the TVA Fleet QAPD, Revision 43 states that the TVA Fleet QAPD governs the quality related activities which addresses infrastructure and programmatic matters with siting, licensing, and planning for TVAs New Nuclear Projects and New Nuclear Program until such time as the TVA New Nuclear QAPD is implemented and the CRN SMR CPA is approved by the NRC.
Given that the CRN SMR project is governed by the TVA Fleet QAPD, Revision 43 prior to the NRCs approval of the CRN CPA:
- a. Specify which management position governs the quality related activities associated with the design phase in support of the CRN SMR CPA prior to the transition from the TVA Fleet QAPD to the TVA New Nuclear QAPD.
- b. Clarify how the Vice President, Site Projects, which is described in the TVA New Nuclear QAPD and referenced in the TVA Fleet QAPD, fits into the current TVA Nuclear organization since this position is not described in the TVA Fleet QAPD and nor is it depicted in Figure 2.1, TVA Fleet QAPD Organization Chart.
- c. Clarify whether implementing procedures for New Nuclear Programs and New Nuclear Projects will be implemented under the TVA Fleet QAPD prior to the implementation of the TVA New Nuclear QAPD.
RAI 3
Criterion I of Appendix B to 10 CFR Part 50 requires, in part, that the applicant shall be responsible for the establishment and execution of the QAP. 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.
4
- a. Part II, Section 1.6 of the TVA Fleet QAPD states, that [a] Nuclear Steam Supply System (NSSS) Supplier provides engineering services for plant design and licensing of specific plant types on TVA Nuclear sites. These engineering services for nuclear generation include site-specific plant types on TVA Nuclear sites. These engineering services for nuclear generation include site specific engineering and design necessary to support ongoing plant maintenance and modifications. Part II, Section 1.7 of the TVA Fleet QAPD, states that, Architect/Engineering (AE) Suppliers provide engineering services to support ongoing plant maintenance and modifications. These engineering services include engineering and design activities, including planning and support for maintenance and modification of nuclear generation. However, the TVA Fleet QAPD does not specify which manager has responsibility for oversight of the NSSS and A/E suppliers nor does it address who will provide the services for the CRN CPA. Specify the management position within the TVA Fleet organization that is responsible for establishing and managing oversight and execution activities of NSSS and A/E suppliers.
- b. Clarify whether NSSS and A/E suppliers will provide engineering and design services for new nuclear generation (e.g., site-specific engineering and design necessary to support development of the CRN SMR CPA and preconstruction activities at the CRN).
RAI 4
Criterion I, Organization, of Appendix B to 10 CFR Part 50 requires, in part:
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.
Part II, Section 2.8, QA Organizational Independence, of the TVA Fleet QAPD states, in part:
The QA function has sufficient independence from other TVA Nuclear priorities to bring forward issues affecting safety and quality and makes judgements regarding quality in all areas regarding TVA Nuclear design activities as appropriate. QA may make recommendations to management regarding improving the quality of work processes. If QA disagrees with any actions taken by the organization and is unable to obtain resolution. QA informs QA management and bring the matter to the attention of the CNO, who will determine the final disposition.
Explain why the requirements for independence and priorities of the QA function described in Part II, Section 2.8 of the TVA Fleet QAPD are only applicable to TVA Nuclear design activities and not to other quality-related activities.
RAI 5
The regulation at 10 CFR 50.55(f)(4)(I) requires a holder of an ESP to submit changes to the accepted QAPD and receive NRC approval prior to implementation of changes that reduce commitments.
5 Part II, Section 2.5, Item A of the TVA Fleet QAPD states that administrative control of the QAPD will be in accordance with 10 CFR 50.54(a).
The TVA Fleet QAPD does not identify whether the changes to the TVA Fleet QAPD is also governed by 10 CFR 50.55(f)(4)(i).
Explain if changes to the TVA Fleet QAPD will also be performed in accordance with 10 CFR 50.55(f)(4)(i). If not, explain what regulation will govern changes to the TVA Fleet QAPD as it relates to the CRN SMR ESP.
RAI 6
Criterion II, Quality Assurance Program, of Appendix to 10 CFR Part 50 states, in part, that The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
Part II, Section 2.11 of the TVA Fleet QAPD states that in establishing the qualification and training programs, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.2.3, as endorsed by Regulatory Guide 1.33, Quality Assurance Program Requirements, Revision 3 with the following clarification: Instead of ANSI/ASME NQA-1-2008 and NQA-1a-2009 Addenda, TVA commits to NQA-1-2015, Requirement 2 and the applicable regulatory position stated in RG 1.28, Revision 5 with clarifications and exceptions. Similar statements regarding commitments to ANSI/ANS 3.2-2012, as endorsed by RG 1.33, Revision 3 are made in:
Part II, Section 3.9 of the TVA Fleet QAPD for establishing TVAs program for design control and verification Part II, Section 4.2 of the TVA Fleet QAPD for establishing controls for procurement Part II, Section 5.4 of the TVA Fleet QAPD for establishing procedural controls Part II, Section 6.4 of the TVA Fleet QAPD for establishing provisions for document control Part II, Section 7.3 of the TVA Fleet QAPD for establishing controls for purchased items and services Part II, Section 8.2 of the TVA Fleet QAPD for establishing provisions for identification and control of items Part II, Section 10.5 of the TVA Fleet QAPD for establishing inspection requirements Part II, Section 11.4 of the TVA Fleet QAPD for establishing provisions for testing Part II, Section 12.4 of the TVA Fleet QAPD for establishing provisions for control of measuring and test equipment Part II, Section 13.3, Item A of the TVA Fleet QAPD for establishing provisions for handling, storage, and shipping Part II, Section 15.3 of the TVA Fleet QAPD for the establishing measures for nonconforming materials, parts, or components Part II, Section 16.3 of the TVA Fleet QAPD for the establishing provisions for corrective action In addition, Part II, Section 17.4, Item B of the TVA Fleet QAPD states that establishing the provision for plant records management for CRN ESP, TVA Nuclear commits to compliance with ANSI/ANS 3.2-2012, Section 3.17, as endorsed by and subject to the conditions specified in RG 1.28, Revision 5, including Regulatory Position C.3.a(1) and C.3.a(2). RG 1.28, Revision 5 does not endorse ANSI/ANS 3.2-2012.
Further, Part II, Section 18.5, NQA-1 Commitment / Exceptions, of the TVA Fleet QAPD only discusses commitments to NRC regulatory guidance and endorsed standards for establishing
6 the independent audit program for operating units. The TVA Fleet QAPD does not specify the NRC regulatory guides and endorsed standards that will be used to establish the independent audit program for the CRN SMR ESP and CPA.
RG 1.33, Revision 3 describes methods that the NRC staff considers acceptable to meet the regulations in 10 CFR 50.34(b)(6)(ii), Contents of applications: technical information and 10 CFR 50.79(a)(27), Contents of applications; technical information in final safety analysis report, for establishment of QA controls for the implementation of managerial and administrative controls to assure safe operation. RG 1.28, Revision 5, Quality Assurance Program Criteria (Design and Construction, in which the NRC endorsed NQA-1-2015, Part I and Part II requirements with exceptions and clarification, describes an acceptable method for the implementation of a QA program during the design and construction phases of nuclear power plants.
Since RG 1.28, Revision 5 is the NRC guidance document that endorses NQA-1-2015, it is not clear to the NRC staff why TVA does not commit to RG 1.28, Revision 5 in the TVA Fleet QAPD given that TVA stated that the TVA Fleet QAPD, Revision 43 converts the current operating fleet from ANSI N45.2-1971 and ANSI N18.7-1976 to ASME NQA-1-2015.
- a. Explain why TVA did not commit to RG 1.28, Revision 5, within the TVA Fleet QAPD both for operating plants and the CRN SMR project.
- b. Given that RG 1.28, Revision 5 does not endorse ANSI/ANS 3.2-2012, address the inconsistency stated in Part II, Section 17.4, Item B of the TVA Fleet QAPD.
- c. Specify the NRC regulatory guidance/endorsed standards that TVA will commit to complying with for establishing the audit program for the CRN SMR project during the time this project is governed by the TVA Fleet QAPD, Revision 43.
RAI 7
Criterion III, Design Control, of Appendix B to 10 CFR Part 50 requires, in part:
Measures shall be established to assure that applicable regulatory requirements and the design basis, as defined in § 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions. These measures shall include provisions to assure that appropriate quality standards are specified and included in design documents and that deviations from such standards are controlled. Measures shall also be established for the selection and review for suitability of application of materials, parts, equipment, and processes that are essential to the safety-related functions of the structures, systems and components.
Part II, Section 3.4 of the TVA Fleet QAPD, Item A states that Use of existing data will be performed in accordance with NQA-1-2015, Part IV, Subpart 4.2.3, Guidance on Qualification of Existing Data. These provisions assure that design inputs (such as design bases and the performance, regulatory, quality, and quality verification requirements) are correctly translated into design outputs (such as analyses, specifications, drawings, procedures, and instructions) so that the final design output contains or references appropriate acceptance criteria that can be related to the design input in sufficient detail to permit verification by inspection and test, as required. Item C states that [t]he design control program includes interface controls necessary to control development, verification, approval, release, status, distribution, and revision of design inputs and outputs.
7 It is not clear to the staff whether the statement in Item A regarding these provisions is intended to apply to Item C with respect to interface controls. Clarify the applicability of these provisions to the interface controls in Item C.
RAI 8
Criterion IV, Procurement Document Control, of Appendix B to 10 CFR Part 50, requires:
Measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the documents for procurement of material, equipment, and services, whether purchased by the applicant or by its contractors or subcontractors. To the extent necessary, procurement documents shall require contractors or subcontractors to provide a quality assurance program consistent with the pertinent provisions of this appendix.
Part II, Section 4 of the TVA Fleet QAPD states that TVA Nuclear has established the necessary measures and governing procedures to assure that purchased items, computer programs, and service are subject to appropriate quality and technical requirements.
Section 4.1, Item B of the TVA Fleet QAPD states:
Procurement document changes are subject to the same degree of control as utilized in the preparation of original documents. These controls include provisions such that:
- 1. Original technical or quality assurance requirements cannot be determined, an engineering evaluation is conducted and documented by qualitied staff to establish appropriate requirements and controls to assure that interfaces and interchangeability, safety, fit, and function, as applicable, are not adversely affected or contrary to applicable regulatory requirements.
- 2. Applicable technical, regulatory, administrative, quality and reporting requirements (such as specifications, codes, standards, tests, inspections, special processes, and 10 CFR Part 21) are invoked for procurement of items and services.
The TVA Fleet QAPD did not identify controls that will be applied for preparation of original procurement documents to ensure that applicable technical, regulatory, administrative, quality and reporting requirements are included in these procurement documents.
Describe the controls that will be applied for the preparation of original procurement documents in the TVA Fleet QAPD.
RAI 9
Criterion XVIII, Audits, of Appendix B to 10 CFR Part 50, states, in part, that [a]
comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program and to determine the effectiveness of the program.
Part II, Section 18.2, Item B of the TVA Fleet QAPD states, in part, that [i]nternal audits of operational phase unit functional areas are scheduled based on the month in which the audit starts. All applicable QA program elements for each functional area are audited with a nominal periodicity of 36 months. Items D and D.1 within this section state, that [a]n annual evaluation
8 is performed to determine the need for additional audits. Evaluations are performed prior to the 12 and 24 month date following the last audit.
Clarify whether an evaluation will be performed to determine the need for additional audits prior to the 36 month date following the last audit if an internal audit extension of 25 percent is applied to audits on a triennial periodicity.
RAI 10
Part I, Section 2 of the TVA Fleet QAPD states, in part, that [t]he QAPD applies to operations phase activities including those in support of Operating Licenses, and activities affecting the quality and performance of safety-related structures, systems, and components Part IV of the TVA Fleet QAPD identifies NRC regulatory guides and standards that TVA Nuclear commits to meeting with clarifications. These include:
RG 1.28, Quality Assurance Program Criteria (Design and Construction), Revision 5 RG 1.33, Quality Assurance Program Requirements (Operations), Revision 3 RG 1.64, Quality Assurance Requirements for the Design of Nuclear Power Plants, Revision 2, for which the TVA Fleet QAPD states that TVA Nuclear will maintain existing commitments to for existing TVA Nuclear plants.
RG 1.94, Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase, Revision 1, for which the TVA Fleet QAPD states that TVA Nuclear will maintain existing commitments to for existing TVA Nuclear plants.
RG 1.116, Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems, Revision 0-R, for which the TVA Fleet QAPD states that TVA Nuclear will maintain existing commitments to for existing TVA Nuclear plants.
ASME NQA-1-2015, Quality Assurance Requirements for Nuclear Facility Applications ANSI/ANS 3.2-2012, Managerial, Administrative, and Quality Assurance Controls for the Operational Phase of Nuclear Power Plants ANSI N45.2.5-1974, Supplementary Quality Assurance Requirements for Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel for the Construction Phase of Nuclear Power Plants, for which the TVA Fleet QAPD states that TVA Nuclear commits to for existing TVA Nuclear plants subject to the guidance included in RG 1.94, Revision 1 ANSI N45.2.8-1975, Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction Phase of Nuclear Power Plants, for which the TVA Fleet QAPD states that TVA Nuclear commits to for existing TVA Nuclear plants subject to the guidance included in RG 1.116, Revision 0-R.
ANSI N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants, for which the TVA Fleet QAPD states that TVA Nuclear commits to for existing TVA Nuclear plants subject to the guidance included in RG 1.64, Revision 2.
It is not clear to the NRC staff why TVA is committing to RG 1.64, Revision 2, RG 1.94, Revision 1, and RG 1.116, Revision 0 for the operations phase activities of operating licenses given that these RGs (1) are only applicable during the design and construction phase of a plant; and (2) have been withdrawn and superseded by RG 1.28. Explain TVA would commit to RG 1.64, Revision 2, RG 1.94, Revision 1, and RG 1.116, Revision 0, in addition to committing to RG 1.28, Revision 5 and RG 1.33, Revision 3 for existing TVA nuclear plants.