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Request for Additional Information Change to Quality Assurance Program Description for Palo Verde Nuclear Generating Station, Units 1, 2, and 3 (CAC Nos. MF6537, MF6538, and MF6539)
	ML16006A366
Person / Time
Site:	Palo Verde
Issue date:	01/06/2016
From:	Watford M M; Plant Licensing Branch IV
To:	Dilorenzo M, Elkinton D, Stephenson C, Weber T; Arizona Public Service Co
References
	MF6537, MF6538, MF6539
	Download: ML16006A366 (5)
	v • d • e

1 NRR-PMDAPEm Resource From: Watford, Margaret Sent: Wednesday, January 06, 2016 11:01 AM To:Carl Stephenson; Del Elkinton; Mike Dilorenzo; Tom Weber Cc: Klos, John

Subject:

Request for Additional Information on PV NGS, Change to Quality Assurance Program Description (MF6537, MF6538, MF6539)

Attachments:

Final RAIs for PVNGS QAPD Change (MF6537-9).pdfTom, By letter dated July 28, 2015 (Agencywide Document Access and Management System (ADAMS) Accession No. ML15212A718), Arizona Public Service Company (APS or the licensee) submitted a change to the Quality Assurance Program Description (QAPD) for Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and

3. The proposed change would revise the PVNGS QAPD to adopt a standardized QAPD based upon the guidance of Nuclear Energy Institute (NEI)11-04A, "Nuclear Generation Quality Assurance Program Description" (ADAMS Accession No. ML12258A358). The NEI 11-04A Quality Assurance Program template was reviewed and endorsed by the U.S. Nuclear Regulatory Commission (NRC) by letter dated May 9, 2013 (ADAMS Accession No. ML13023A051). APS submitted the letter based on a determination that the proposed change could be considered a reduction in the program's commitments pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(a).

Based on the review of the change, the NRC staff has determined that additional information is required regarding the proposed PVNGS QAPD. Please see the formal request for additional information (RAI) in the attached document. A clarification call was held on December 21, 2015 to ensure APS understood the

RAIs. It was agreed that APS will provide response to the RAIs by February 5, 2016.

Thank you, Maggie Watford Project Manager, Plant Licensing Branch IV-I Division of Operating Reactor Licensing U.S. Nuclear Regulatory Commission

Phone: 301-415-1233 Email: Margaret.Watford@nrc.gov

Hearing Identifier: NRR_PMDA Email Number: 2575 Mail Envelope Properties (Margaret.Watford@nrc.gov20160106110100)

Subject:

Request for Additional Information on PVNGS, Change to Quality Assurance Program Description (MF6537, MF6538, MF6539) Sent Date: 1/6/2016 11:01:21 AM Received Date: 1/6/2016 11:01:00 AM From: Watford, Margaret Created By: Margaret.Watford@nrc.gov Recipients: "Klos, John" <John.Klos@nrc.gov> Tracking Status: None "Carl Stephenson" <carl.stephenson@aps.com> Tracking Status: None "Del Elkinton" <delbert.elkinton@aps.com>

Tracking Status: None "Mike Dilorenzo" <michael.dilorenzo@aps.com> Tracking Status: None "Tom Weber" <thomas.n.weber@aps.com> Tracking Status: None Post Office: Files Size Date & Time MESSAGE 1642 1/6/2016 11:01:00 AM Final RAIs for PVNGS QAPD Change (MF6537-9).pdf 162708

Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

REQUEST FOR ADDITIONAL INFORMATION REQUEST TO CHANGE QUALITY ASSURANCE PROGRAM DESCRIPTION PALO VERDE NUCLEAR GENERATING STATION, UNITS 1, 2, AND 3 ARIZONA PUBLIC SERVICE COMPANY DOCKET NOS. 50-528, 50-529, AND 50-530 TAC NOS. MF6537, MF6538, AND MF6539 By letter dated July 28, 2015 (Agencywide Document Access and Management System (ADAMS) Accession No. ML15212A718), Arizona Public Service Company (APS or the licensee) submitted a change to the Quality Assurance Program Description (QAPD) for Palo Verde Nuclear Generating Station (PVNGS), Units 1, 2, and 3. The proposed change would revise the PVNGS QAPD to adopt a standardized QAPD based upon the guidance of Nuclear Energy Institute (NEI)11-04A, "Nuclear Generation Quality Assurance Program Description

" (ADAMS Accession No. ML12258A358). The NEI 11-04A Quality Assurance Program template was reviewed and endorsed by the U.S. Nuclear Regulatory Commission (NRC) by letter dated May 9, 2013 (ADAMS Accession No. ML13023A051). APS submitted the letter based on a determination that the proposed change could be considered a reduction in the program's commitments pursuant to Title 10 of the Code of Federal Regulations (10 CFR), Section 50.54(a).

Based on the review of the change, the NRC staff has determined that additional information is required regarding the proposed PVNGS QAPD.

Question 1

In the submittal dated July 28, 2015, Attachment 2, "Proposed PVNGS Operations Quality Assurance Program Description Based Upon NEI 11-04A," Section 2.2.7 , "NQA-1 Commitment/Exceptions," states that Palo Verde is committed to compliance with American Society of Mechanical Engineers (ASME) NQA-1-2008, Requirement 2 with the following clarifications and exceptions:

As an alternative to Section 303.3 that prospective Lead Auditors have participated in a minimum of five (5) audits in the previous three (3) years, the following may be used for qualification of experienced individuals:

Prospective lead auditors shall demonstrate their ability to effectively implement the audit process and lead an audit team. They shall have participated in at least one audit within the year preceding the individual's effective date of qualification. Upon successful demonstration of the ability to effectively lead audits, licensee management may designate a prospective lead auditor as a lead auditor.

The proposed alternative was based on a previously approved NRC safety evaluation report dated March 27, 1998, for the San Onofre Nuclear Generating Station (ADAMS Legacy Accession No. 9803310346), which stated in part:

Prospective Lead Auditors shall demonstrate their ability to effectively implement the audit process and effectively lead an audit team. This process is described in written procedures which provide for evaluation and documentation of the results of this demonstration. In addition, the prospective Lead Auditor shall have participated in at least one Nuclear Oversight audit within the year preceding the individual's effective date of qualification. Upon successful demonstration of the ability to effectively implement the audit process and effectively lead audits, and having met the other provisions of Section 2.3 of ANSI/ASME N45.2.23-1978, the individual may be certified as being qualified to lead audits.

The proposed alternative in Palo Verde's QAPD does not require the prospective Lead Auditor to participate in at least one Nuclear Oversight audit. Provide clarification on how Palo Verde's Lead Auditor participates in at least one Nuclear Oversight audit within the year preceding the individual's effective date of qualification.

Question 2 In Attachment 2 of Palo Verde's proposed QAPD, Section 2.7, "Control of Purchased Material, Equipment, and Services," provides guidance on purchasing commercial grade calibration services from a calibration laboratory in accordance with the guidance contained in NEI 11-04A, Revision 0.

On August 28, 2014, NEI submitted Revision 1 of NEI 14-05, "Guidelines for the Use of Accreditation in Lieu of Commercial Grade Surveys for Procurement of Laboratory Calibration and Test Services," to the NRC staff for review and endorsement. The NRC staff reviewed and endorsed NEI 14-05 on February 9, 2015, in a safety evaluation report (ADAMS Accession No ML14322A535).

Clarify if Palo Verde intends to use the guidance in NEI 11-04A, or the recently approved guidance provided in the NRC's safety evaluation report for NEI 14-05, dated February 9, 2015.

Question 3 In Section 4.0, "Regulatory Commitments," of Palo Verde's proposed QAPD, the licensee commits to Regulatory Guide (RG) 1.8, Revision 1-R, "Personnel Selection and Training," dated September 1975 (ADAMS Accession No. ML12305A250) and includes a list of exceptions and clarifications, A through F.

The exception under Paragraph C does not align with any current staff or industry guidance. Clarify how the exception is acceptable and provide a basis of how the exception continues to satisfy Appendix B to 10 CFR Part 50.

Also, clarify where APS will use the equivalency of a bachelor's degree and which applicable regulatory guides that endorsed industry standards will be used as cited in paragraph C.

Question 4 In Section 4.0 of Palo Verde's proposed QAPD, the licensee commits to RG 1.26, Revision 1, "Quality Group Classifications and Standards for Water, Steam and Radioactive-Waste-Containing Components of Nuclear Power Plants

," dated September 1974. The equipment classification and code requirements are described in Updated Final Safety Analysis Report (UFSAR) 3.2. "Classification of Structures, Components, and Systems [SSCs]." Quality group classification and code requirements for each quality group correspond to those indicated in RG 1.28, Revision 1, "Quality Assurance Program Requirements (Design and Construction)," with exceptions.

RG 1.28, Revision 1 provides no classification and code requirements. Provide clarification on APS's use of RG 1.28, Revision 1 for equipment classification and code requirements.

Question 5 Palo Verde's proposed QAPD Section 5.5, "Plant Maintenance," was identified in Attachment 5, "Specific Deviations from the NEI 11

-04A Template and the Basis for the Deviations," of Palo Verde's submittal as being changed. Palo Verde's proposed QAPD does not reflect the proposed change as identified in Attachment 5.

Provide clarification on what Palo Verde's intentions are for the proposed QAPD regarding Section 5.5, "Plant Maintenance."