ML25034A235
| ML25034A235 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 02/10/2025 |
| From: | Southern Nuclear Company |
| To: | Division of Operating Reactor Licensing |
| Lamb J, NRR/DORL/LPL2-1 | |
| References | |
| EPID L-2025-LRM-0003 | |
| Download: ML25034A235 (1) | |
Text
SNC Pre-Submittal Meeting Fleet Quality Assurance Topical Report Revision to Incorporate Vogtle 3&4 February 10, 2025
Agenda Introductions & Meeting Purpose
Background
Proposed Changes Reason for the Proposed Changes Regulatory Basis Submittal Contents Schedule Discussion / Feedback
Revised SNC QATR INTRODUCTIONS Southern Nuclear Operating Company (SNC)
Nuclear Regulatory Commission (NRC)
MEETING PURPOSE SNC is proposing changes to its Quality Assurance Program (QAP). Some of the changes represent reductions in commitment and must be submitted to the NRC in accordance with § 50.54(a)(4). The purpose of the meeting is to discuss the primary changes to the QAP as well as SNCs plan for submitting information to the NRC.
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Revised SNC QATR BACKGROUND SNC participated in a previous public meeting on this topic (ML23361A086):
Meeting Notice - ML23345A125 Pre-submittal Meeting Slides - ML23361A081 Meeting summary - ML24019A193 4
Revised SNC QATR DESCRIPTION OF THE PROPOSED CHANGES The primary intent of the proposed change is to transition the Vogtle Electric Generating Plant (VEGP) 3&4 QAP from the Nuclear Development Quality Assurance Manual (NDQAM) to the fleet Quality Assurance Topical Report (QATR).
The proposed QATR will become applicable for VEGP 3&4 and the associated docket numbers will be added to the cover page.
Some of the revisions represent reductions in commitment for one or more of the SNC plants.
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Revise SNC QATR DESCRIPTION OF THE PROPOSED CHANGES Example changes that represent a RIC at Farley, Hatch, and/or Vogtle 1&2:
The Plant Review Board (PRB) meeting schedule is changing from once per calendar month to on a periodic basis.
The quorum requirements of the Plant Review Board (PRB) are removed from the QATR in the proposed change.
Removal of Appendix C (Surveillances) 6
Revised SNC QATR DESCRIPTION OF THE PROPOSED CHANGES Example changes that represent a RIC at Vogtle 3&4:
Remove the review of the internal audit program, conducted every 24 months, from the independent review function.
Fire Protection program audit frequency 7
Revised SNC QATR DESCRIPTION OF THE PROPOSED CHANGES Example changes that represent a RIC for QATR and NDQAM:
Removal of Nonconformance dispositions are reviewed for adequacy, analysis of quality trends, and reports provided to the vice president - site.
Removal of 'Review of proposed changes to the ISFSI Technical Specifications or license.
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Revised SNC QATR REASON FOR THE PROPOSED CHANGES Farley, Hatch, and VEGP 1&2 currently use a common QAP (the QATR); the proposed change will integrate VEGP 3&4s QAP commitments (from the NDQAM into the fleets QATR).
Aligns all SNC plants to a common QAP and allows maintaining one plan versus two.
Updates the fleet QAP (QATR) to incorporate improvements in formatting and content.
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Revised SNC QATR SUBMITTAL CONTENTS
- Cover letter
- Enclosure
- Description of the Change
- Reason for the Proposed Change
- Basis for Concluding that the Revised Program Continues to Satisfy the Criteria of 10 CFR 50 Appendix B and the Previously Accepted Quality Assurance Program
- Conclusion
- References
- Attachment - RIC Table (see example on next slide)
- Attachment - Marked-up changes (affected pages with RICs annotated)
- Attachment - Clean-typed copy of the proposed QATR
- Note that additional documents can be made available during an audit (current version of the NDQAM, additional mark-ups, etc.)
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Revised SNC QATR RIC TABLE & MARKUP Example & subject to change 11 The submittal will present information that provides a direct line-of-sight between the RIC and the affected portions of the QATR.
The table provides a description of the change that represents a RIC, a description of current requirements in the QAP, and the justification for the change as reflected in the proposed QATR.
- NRC Pre-submittal Meeting - February 10, 2025
- Submit Reductions in Commitment to NRC - March 2025
- Based upon the extent of changes, SNC would support an NRC audit following the submittal
- Requesting NRC approval in accordance with 10 CFR 50.54(a)
DISCUSSION & FEEDBACK 12