ML25092A055
| ML25092A055 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Watts Bar, Sequoyah, 99902056  |
| Issue date: | 04/01/2025 |
| From: | Kimberly Green Plant Licensing Branch II |
| To: | Hughes S Tennessee Valley Authority |
| Green K | |
| References | |
| EPID L-2024-LLQ-0000 | |
| Download: ML25092A055 (3) | |
Text
From:
Kimberly Green To:
Hughes, Shawna Marie
Subject:
Second Round Request for Additional Information - TVA Request for Approval of Revision 44 to TVA Fleet Quality Assurance Program Description (EPID L-2024-LLQ-0000)
Date:
Tuesday, April 1, 2025 1:27:00 PM Attachments:
FINAL RAI for TVA Fleet QAPD Revision - Round 2.docx
Dear Shawna Hughes:
By letter dated February 26, 2025 (Agencywide Documents Access and Management System Accession No. ML25057A473), Tennessee Valley Authority (TVA) submitted Topical Report (TR) NQA-PLN89-A, Revision 44, Quality Assurance Program Description for TVA Nuclear Quality Assurance Plan, to the U.S. Nuclear Regulatory Commission (NRC) for review and approval. Revision 44 to the TVA Fleet Quality Assurance Program Description (QAPD) reflects recent changes to the TVA organization and requests approval to 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 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. A draft request for additional information (RAI) was previously sent to you via email on March 31, 2025. You indicated that a clarification call was not needed. After transmission of the draft RAI, I recognized that the formatting and text of the quotation from Criterion I of Appendix B to 10 CFR Part 50 in the Introduction was not correct, and that I had not italicized Code of Federal Regulations. I have corrected the format to indent the quotation 0.5 inches for both the left and right margins, corrected the quotation by removing the acronyms and spelling them out (i.e.,
QAP and SSC), and italicized Code of Federal Regulations. No other changes were made to the requests.
A response to the attached RAI is due by May 1, 2025. The NRC staff considers that timely responses to RAIs help ensure sufficient time is available for staff review and contribute toward the NRCs goal of efficient and effective use of staff resources. If circumstances result in the need to revise the requested response date, please me at (301)415-1627 or via email atKimberly.Green@nrc.gov.
Sincerely, Kimberly J. 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 February 26, 2025 (Agencywide Documents Access and Management System Accession No. ML25057A473), TVA submitted the Quality Assurance Program Description (QAPD) for the fleet Nuclear Quality Assurance Plan, TVA-NQA-PLN89-A, Revision 44. This revision includes changes to reflect TVA organization changes that became effective on January 28, 2025.
Criterion I, Organization, of 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, requires, in part:
The applicant shall be responsible for the establishment and execution of the quality assurance programThe authority and duties of person and organizations performing activities affecting the safety-related functions of structures, systems, and components shall be clearly established and delineated in writingThe 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 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.
Issue In Part II, Section 1, subsection 1.5.C, TVA describes the role and responsibilities of the General Manager, Quality Assurance. The QAPD states, in part (emphasis added by underlined text):
The General Manager, Quality Assurance (QA) is responsible for the performance of the quality assurance oversight organization for the nuclear operating fleet, vendor support, CRN ESP, and the TVA New Nuclear Program.
The General Manager, QA has an independent reporting relationship with the CNO on quality issues.
2 However, in subsection 1.3, it states (emphasis added by underlined text):
The Executive Vice President/Chief Operating Officer (COO) is responsible for TVAs transmission and power supply, power operations, generation projects and fleet services. The COO is also responsible for the TVA New Nuclear Program and Projects through the Senior Vice President, New Nuclear Projects.
A.
Senior Vice President, New Nuclear Projects The Senior Vice President, New Nuclear Projects is responsible for new nuclear site projects and program technical and administrative activities.
The Senior Vice President, New Nuclear Projects is also responsible to ensure quality requirements are met for activities performed by the site project and program and their contractors. The management position responsible for the New Nuclear Program reports to the Senior Vice President, New Nuclear Projects.
In addition, subsection 1.5.B, TVA states that the Senior Vice President, Engineering and Operations Support, is also responsible for governance, oversight, and support of TVA New Nuclear Program and Projects activities.
It is not clear to the NRC staff whether the General Manager, QA has oversight of New Nuclear Projects since this position only states it has oversight of TVA New Nuclear Program and CRN ESP. In addition, given that the General Manager, QA reports to the CNO on quality issues and the CRN ESP are the responsibility of the COO, it is not clear to the NRC staff that the General Manager, QA has sufficient authority to provide oversight of CRN ESP and New Nuclear Programs as required by Criterion I of Appendix B to 10 CFR Part 50.
Request The NRC staff requests that TVA:
(1) identify in the TVA Fleet QAPD the position that has oversight of TVA New Nuclear Projects (other the CRN ESP).
(2) clarify how the General Manager, QA reports to a management level such that the General Manager, QA has the required authority and organizational freedom to perform oversight functions of the CRN ESP and New Nuclear Programs.