View source for CP-201101107, Response to Request for Additional Information Related to Request for a Change to the Quality Assurance Plan Involving a Reduction in Commitment

{{Adams
| number = ML11229A808
| issue date = 08/10/2011
| title = Response to Request for Additional Information Related to Request for a Change to the Quality Assurance Plan Involving a Reduction in Commitment
| author name = Flores R, Lucas M
| author affiliation = Luminant Power, Luminant Generation Co, LLC
| addressee name = 
| addressee affiliation = NRC/Document Control Desk, NRC/NRR
| docket = 05000445, 05000446
| license number = 
| contact person = 
| case reference number = CP-201101107, TXX-11099
| document type = Letter type:CP
| page count = 4
| project = 
| stage = Response to RAI
}}

=Text=
{{#Wiki_filter:Rafael Flores                      Luminant Power Senior Vice President              P 0 Box 1002
                                                           & Chief Nuclear Officer            6322 North FM 56 rafael.flores@luminant.com         Glen Rose, TX 76043 Luminant                                                                                      T 254 897 5550 C 817 559 0403 F 254 897 6652 CP-201101107                                                                       Ref: 10CFR50.54(a)
TXIX-11099 August 10, 2011 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555

==SUBJECT:==
COMANCHE PEAK NUCLEAR POWER PLANT (CPNPP)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO A REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE REQUEST FOR A CHANGE TO THE QUALITY ASSURANCE PLAN INVOLVING A REDUCTION IN COMMITMENT

==REFERENCES:==
: 1. Letter logged TXX-11014, dated May 3, 2011, from Rafael Flores of Luminant Power to the NRC requesting a change to the Quality Assurance Plan.
: 2. Request for Additional Information from Balwant Singal, NRR, via e-mail dated July 11, 2011.

==Dear Sir or Madam:==

In reference 1 above, Luminant Generation Company LLC (Luminant Power) requested a change to the Quality Assurance (QA) Program, as provided in FSAR Chapter 17.
The proposed QA Program change revises FSAR section 17.2.15, "Nonconforming Material, Parts, or Components," and an associated commitment, to allow use of a conditional release to install a nonconforming item in the plant, and declare the affected component operable per Technical Specifications, provided that an evaluation of the nonconforming condition supports Technical Specification operability.
Reference 2 provided Luminant Power with a request for additional information from the Nuclear Regulatory Commission that is needed to review the QA Program change request. This letter provides the additional information requested in reference 2 in an attachment.
In accordance with 10CFR50.4(b)(7), a copy of this correspondence, with attachment, is being provided to the NRC Region IV Office and the CPNPP NRC Resident Inspectors.
This communication contains no new commitments.
Should have any questions regarding this submittal, please contact Tom Daskam at (254) 897-0348.
QOOL/

U.S. Nuclear Regulatory Commission TXX- 11099 Page 2 of 4 8/10/2011 I state under penalty of perjury that the foregoing is true and correct.
Executed on August 10, 2011.
Sincerely, Luminant Generation Company, LLC Rafael Flores By:
Mitch Lucas Site Vice President Attachment - RESPONSE TO A REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE REQUEST FOR A CHANGE TO THE QUALITY ASSURANCE PLAN INVOLVING A REDUCTION IN COMMITMENT c-          E. E. Collins, Region IV Balwant Singal, NRR Resident Inspectors, CPNPP

U.S. Nuclear Regulatory Commission TXX- 11099 Page 3 of 4 8i10/2011 ATTACHMENT to TXX-11099 RESPONSE TO A REQUEST FOR ADDITIONAL INFORMATION RELATED TO THE REQUEST FOR A CHANGE TO THE QUALITY ASSURANCE PLAN INVOLVING A REDUCTION IN COMMITMENT

U.S. NucLear ReguLatory Commission TXX- 11099 Page 4 of 4 811012011 NRC Request for Additional Information:
Appendix B to Title of Code of Federal regulations (10 CFR), Part 50, Criterion 15, states in part, "measures shall be established to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation." Clarify how installing, testing and allowing for a nonconformity item to be declared operable based on Technical Specification operability satisfies the requirements of Appendix B to 10 CFR Part 50.
CPNPP Response:
The proposed change to the FSAR, section 17.2.15, "Nonconforming Materials, Parts, or Components,"
affects only subsection 5 on conditional releases, and does not alter the other 17.2.15 subsections, which address various measures for controlling nonconforming items, including: identification, tagging, segregation, documentation, re-inspection, testing, operability review, and disposition of the nonconformance, among others. The current FSAR, section 17.2.15, subsection 5, addresses conditional releases of nonconforming items, and this section contains some of the program controls to prevent inadvertent use or installation of nonconforming items. The proposed change to FSAR, section 17.2.15, subsection 5, as discussed further below, continues to provide adequate controls to prevent inadvertent use or installation of nonconforming items. CPNPP FSAR section 17.2.15 currently satisfies 10CFR50, Appendix B, Criterion 15, and the proposed FSAR section 17.2.15, if approved, will continue to satisfy this 10CFR50 requirement.
The proposed change to FSAR, section 17.2.15, subsection 5, would revise the current conditional release provision and allow for a conditional release of a nonconforming item from the warehouse for installation, testing, and operation, and allow taking Technical Specification credit for use of the nonconforming item, provided that: 1) resolution of the nonconforming condition is tracked in the Corrective Action Program, and 2) an Operability evaluation that meets the NRC Part 9900 Technical Guidance for assessing degraded or nonconforming conditions for potential impact on Operability is completed prior to taking Technical Specification credit for the nonconforming item. This change in the conditional release program allows Technical Specification credit to be taken for use of a nonconforming item, where the nonconformance does not adversely impact those characteristics required for SSC Operability.
With the additional requirement to complete a satisfactory Operability evaluation prior to taking Technical Specification credit for the nonconforming item, the proposed FSAR program for conditional release of nonconforming items is comparable to the current FSAR program requirements. The change will also provide additional plant operational flexibility, and may prevent unnecessary plant mode changes and shutdowns.}}