ML14358A039

Northern States Power Company, Minnesota (NSPM) - Monticello Nuclear Generating Plant, Prairie Island Nuclear Generating Plant, Prairie Island ISFSI - Review of Changes to the NSPM Quality Assurance Topical Report

ML14358A039
Person / Time
Site:	Monticello, Prairie Island
Issue date:	02/20/2015
From:	David Pelton Plant Licensing Branch III
To:	Davison K, Gardner P Northern States Power Co, Xcel Energy
Beltz T, NRR/DORL/LPL3-1, 415-3049
References
TAC MF5120, TAC MF5121, TAC MF5122
Download: ML14358A039 (7)

Text

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 February 20, 2015 Peter A. Gardner Mr. Kevin K. Davison Site Vice President Site Vice President Monticello Nuclear Generating Plant Prairie Island Nuclear Generating Plant Northern States Power Company - Northern States Power Company -

Minnesota Minnesota 2807 West County Road 75 1717 Wakonade Drive East Monticello, MN 55362-9637 Welch, MN 55089

SUBJECT:

MONTICELLO NUCLEAR GENERATING PLANT AND PRAIRIE ISLAND NUCLEAR GENERATING PLANT, UNITS 1AND2- REVIEW OF CHANGES TO THE NORTHERN STATES POWER COMPANY QUALITY ASSURANCE TOPICAL REPORT (TAC NOS. MF5120, MF5121, AND MF5122)

Dear Mr. Gardner and Mr. Davison:

The U.S. Nuclear Regulatory Commission (NRC) has completed its review of changes to the Northern States Power Company (NSPM) Quality Assurance Topical Report (QATR) in response to your application dated October 31, 2014, as supplemented by letters dated November 12, and December 11, 2014, and January 20, 2015. The NSPM QATR is associated with Renewed Facility Operating License Nos. DPR-22, DPR-42, and DPR-60 for the Monticello Nuclear Generating Plant and Prairie Island Nuclear Generating Plant, Units 1 and 2, respectively, and Materials License No. SNM-2506 for the Prairie Island Independent Spent Fuel Storage Installation.

Specifically, the proposed changes include a revision to the conduct of Independent Assessments. This change divides the Independent Assessment function of the Nuclear Oversight organization into two distinct functions: Independent Audits and Independent Assessments, in which the commitment to NQA-1-1994 is applied to the Independent Audit function only. In addition, NSPM requested a 24-month audit interval and use of a 90-day grace period for the completion of independent audits. The changes, which are considered to be reductions in commitment, were submitted for NRC review and approval in accordance with the provisions of Title 1O of the Code of Federal Regulations (1 O CFR), section 50.54(a)(4).

The NRC staff has completed its review of your request and determined that the QA program description adequately describes how the requirements of Appendix B to 10 CFR Part 50 will continue to be implemented. The staff finds that the proposed changes to the NSPM QATR continue to meet the 10 CFR Part 50 requirements for the QA program and is acceptable.

P. Gardner, et al. If you have any questions, please contact Terry Beltz at (301) 415-3049.

vi L. Pelton, Chie Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-263, 50-282, 50-306, and 72-010

Enclosure:

Safety Evaluation cc w/encl: Distribution via Listserv

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION QUALITY ASSURANCE TOPICAL REPORT CHANGE NORTHERN STATES POWER COMPANY - MINNESOTA MONTICELLO NUCLEAR GENERATING PLANT PRAIRIE ISLAND NUCLEAR GENERATING PLANT. UNITS 1 AND 2 PRAIRIE ISLAND INDEPENDENT SPENT FUEL STORAGE INSTALLATION DOCKET NOS. 50-263. 50-282. 50-306 AND 72-010

1.0 INTRODUCTION

By letter dated October 31, 2014 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML14304A353}, as supplemented by letters dated November 12, and December 11, 2014, and January 20, 2015 (ADAMS Accession Nos. ML14316A593, ML14345A638, and ML15020A711, respectively), Northern States Power Company Minnesota (NSPM, the licensee), doing business as Xcel Energy, Inc., submitted a change to revise the NSPM Quality Assurance Topical Report (QATR) associated with the Monticello Nuclear Generating Plant; the Prairie Island Nuclear Generating Plant, Units 1 and 2; and the Prairie Island Independent Spent Fuel Storage Installation. The change was submitted for U.S.

Nuclear Regulatory Commission (NRC) review and approval in accordance with the provisions of Title 1O of the Code of Federal Regulations (10 CFR), section 50.54(a)(4). In its letter dated December 11, 2014, NSPM provided a response to NRC staff requests for additional information, including Revision 8b of the NSPM QATR. In its letter dated January 20, 2015, NSPM revised the definition of "nominally" to eliminate any confusion as to audit scheduling periodicity, including Revision Be of the NSPM QATR.

The QATR provides a top-level overview of the manner in which quality is to be achieved and presents NSPM's overall philosophy regarding quality assurance associated with the Monticello Nuclear Generating Plant; the Prairie Island Nuclear Generating Plant, Units 1 and 2; and the Prairie Island Independent Spent Fuel Storage Installation. The QATR is based on the applicable portions of 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."

Enclosure

2.0 REGULATORY EVALUATION

The Commission's regulatory requirements related to Quality Assurance (QA) programs are set forth in 10 CFR Part 50, Appendix B, "Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants;" 10 CFR § 50.34, "Content of applications; technical information;"

and 10 CFR 50.54, "Conditions of licenses."

Appendix B to 10 CFR Part 50, hereafter referred to as Appendix B, establishes the QA requirements for the design, manufacture, construction, and operation of structures, systems, and components (SSCs) that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public for the facility. The pertinent requirements of Appendix B apply to all activities affecting the safety-related functions of those SSCs and include designing, purchasing, fabricating, handling, shipping, storing, cleaning, erecting, installing, inspecting, testing, operating, maintaining, repairing, refueling, and modifying.

The regulations in 10 CFR § 50.34(b)(6)(ii) require, in part, that every applicant for an operating license include information that describes the managerial and administrative controls to be used to assure safe operation. Appendix B sets forth the requirements for such controls for nuclear power plants. The information shall include a discussion of how the applicable requirements of Appendix B will be satisfied.

The regulations in 10 CFR § 50.54{a){3) state, in part, that licensees may make a change to a previously accepted QA program description included or referenced in the Safety Analysis Report without prior NRC approval, provided the change does not reduce the commitments in the program description as accepted by the NRC. The regulations in 10 CFR 50.54{a)(4) state, in part, that changes to the QA program description that do reduce the commitments must be submitted to the NRC for review and approval. The licensee must wait 60 days following submittal or receive NRC approval prior to implementation.

3.0 EVALUATION In its letter dated October 31, 2014, in accordance with the provisions of 10 CFR 50.54(a)(4),

NSPM submitted a request for NRC review and approval of QATR changes considered as reductions in commitment. Enclosure 1 of the October 31, 2014, letter included Revision Ba to the QATR.

In evaluating the adequacy of the NSPM QATR, the NRC staff used the guidance contained in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Section 17.3, "Quality Assurance Program Description," dated August 1990 (ADAMS Accession No. ML052350376), and hereafter referred to as Section 17.3. Section 17.3 provides acceptance criteria for quality assurance program descriptions. The staff notes that the NSPM QATR is organized in a format consistent with NUREG-0800, Section 17.3.

The changes in QATR Revision Ba and Revision 8b include the following:

a. Changes to create a distinction between audits and independent assessments.

This change divides the Independent Assessment function of the Nuclear Oversight (NOS) organization into two distinct functions: Independent Audits and Independent Assessments. In the proposed change, the commitment to NQA-1-1994 is applied only to the new audit program, such that commitment to Basic Requirement (BR) 18 and Supplement 18S-1 is retained for the audit program and not applied to the independent assessment function. The NRC staff finds the change acceptable, since it meets the applicable requirements in Criterion XVIII of Appendix B to 10 CFR Part 50 for internal independent audits. The independent audit function will verify compliance with all aspects of the QA program and determine the QA program effectiveness.

b. Changes related to the audit schedule interval.

Regulatory Position 2.a.(2) of Regulatory Guide 1.28, Revision 4, "Quality Assurance Program Criteria (Design and Construction)" (ADAMS Accession No. ML100160003),

states that "applicable elements of an organization's QA program should be audited at least once each year or at least once during the life of the activity, whichever is shorter."

NSPM requested to perform audits using a 24-month interval, unless otherwise established by NRC rules, and summarized the audit frequencies and bases in the QATR, Table 1. .

NRC Administrative Letter (AL) 95-06, "Relocation of Technical Specification Administrative Controls Related to Quality Assurance" (ADAMS Accession No. ML100160003) includes guidance for the implementation of a performance-based schedule, provided that the audit interval does not exceed two years. The two year interval must be justified by performance reviews and the interval for the audit area must not be governed by other regulations. The NRC staff determined that NSPM meets the guidance provided in AL 95-06 and, therefore, the change is acceptable.

c. Changes in response to NRC staff requests for additional information (RAI).

The NRC staff issued RAls to NSPM in an e-mail dated December 2, 2014 (ADAMS Accession No. ML14337A787). As a result of the staff's RAI, NSPM made additional changes to its QATR as provided in its December 11, 2014, response letter (ADAMS Accession No. ML14345A640) and enclosure (ADAMS Accession No. ML14345A639).

The staff's RAI requested clarification on the licensee's basis for including a 25 percent grace period on completion of independent audits, contrary to the 90 day general grace period applied to provisions required to be performed on a periodic basis specified in Regulatory Guide 1.28, Revision 4, Section C.2.b(5). In its response, NSPM noted that the 25 percent grace period was selected in accordance with the definition of "nominal" provided in 10 CFR 26.5, but determined that a shorter grace period of 90 days is more appropriate for quality assurance audits.

The change to QATR Revision 8c (provided as an enclosure to the licensee's supplement dated January 20, 2015) addressed the following:

In Section C.3, "Independent Audit," and Table 1, "Programs or Activities Subject to Regulatory-related Independent Audit Frequencies," of Revision 8b to the NSPM QATR, the term "nominally" was defined as follows:

• Nominally means that the audit may be completed within a period of 90 days longer than the period stated. Thus the next scheduled due date for a biennial audit could be no later than 27 months from the previous completion of the audit. The subsequent audit returns to the original schedule.

The NRC staff determined that a grace period of 90 days for the completion of independent audits was acceptable in accordance with regulatory guidance. However, to provide additional clarification, the NRC finds that the grace period specified by the licensee does not allow the "clock" for a particular audit schedule to be reset forward. Therefore, the staff recommended that the above statement be changed to the following:

• Nominally means that the audit may be completed within a period of 90 days longer than the period stated. Thus the next scheduled due date for a biennial audit could be no later than 27 months from the original audit schedule.

The above change was incorporated in Revision 8c to the NSPM QATR. The change eliminates any confusion as to audit scheduling periodicity, as the "clock" reset would be based on an established audit schedule and not from completion of the previous audit.

4.0 CONCLUSION

The NRC staff used the acceptance criteria guidance of NUREG-0800, Section 17.3, as the basis for evaluating the acceptability of the NSPM QA program in conformance with the applicable portions of Appendix B to 10 CFR Part 50. The program description adequately describes how the requirements of Appendix B will be implemented. The NRC staff concludes that the proposed Revision Sc to the NSPM QATR follows the NRC guidance contained within, and conforms to the format of NUREG-0800, Section 17.3. The program description adequately describes how the requirements of Appendix B will be implemented. Therefore, the staff concludes that the proposed change to the NSPM QATR continues to meet the 10 CFR Part 50 requirements for the QA program and is, therefore, acceptable.

Principal Contributors: Andrea Keim Ashley Thomas Date: February 20, 2015

P. Gardner, et al. If you have any questions, please contact Terry Beltz at (301) 415-3049.

Sincerely, IRA/

David L. Pelton, Chief Plant Licensing Branch 111-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-263, 50-282, 50-306, and 72-010

Enclosure:

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