ML081990367

Handouts from Duke Energy & NRC Meeting - NQA-1 Based QA Program Conversion

ML081990367
Person / Time
Site:	Oconee, Mcguire, Catawba, McGuire
Issue date:	07/15/2008
From:	Duke Energy Corp
To:	Office of Nuclear Reactor Regulation
References
Download: ML081990367 (29)

Text

luke vinergy NQA-1 Based QA Program Conversion Duke Energy &NRC Meeting July 15, 2008 1

kDuke Em'aD'k Agenda VEnergy

" Introductions

" Meeting Purpose

" Conversion Reasons

" Conversion Methodology

" Submittal Package

" Schedule

" Closing Remarks 2

Duke Energy Conversion Team WHIM

ý 1 -

11-1, 1. -

ý

" Jim Fisicaro

" Bob Gill - Li

- NRC Interface censing Manager m Jerry Standridge - QA SPOC m Kevin Rhyne-Team Lead m 40 Contributors - QA Criteria SMEs, m Management Review Team 3

Duke SEnergy Meeting Pu rpose 0 Commu nicate Duke's plan to convert the operating plant fleet to an ASME NQA-1 -1994 based QA program

• Share QA program conversion

• Obtain NRC feedback prior on completion and submittal methodology QAPD package 4

F Duke

" Energ Conversion Reasons SCEn e rf y

" Adopt a more current standard, incorporating years of industry operating experience

" Use a single, comprehensive, and actively maintained standard

" Benefit from a simpler, easier to understand standard

" Synchronize with the currently approved standard for new plant construction and operation

" Obtain consistency with the QAPD for new plant licensing (e.g. Lee Nuclear)

" Conform with the utility conversion trend 5

Duke Conversion Energy Methodology

" Meet 1 OCFR50, Appendix B requirements for a QA Program Description -(QAPD)

" Use NQA-I standard and NEI 06-14A template as proposed QAPD basis to establish. an equivalent QA program-

• Address differences -between current QATR-and proposed QAPD documents 6

Duke Conversion Energy Methodology (Continued)

" NEI 06-14A QAPD revisions 4 & 5 used as a template.for the operating fleet program

" Duke specifics replaced bracketed template text with additional information inserted as needed to fully describe the program

" Comparison matrix developed to show where current QATR commitments are addressed within proposed QAPD 7

PDuke OEnergy Conversion Methodology (Continued)

Quality Assurance Program Description Comparison Matrix Column 1 Column 2 Column 3 Column 4 Column 5 Current QATR Proposed QAPD and NQA-1 Differences R/NIl Basis for Acceptability Sections/Paragraphs Sections/Paragraphs (Note 3)

(Note 4)

(Note 5)

(Note 1)

(Note 2) 17.3.2.12 Inspection Section 10 - Inspection The paragraph title was N

changed to a section title.

In order to assure safe and Part II, Section 10 N/A N

N/A reliable operation, a program of inspections for QA Condition 1 Supplement 10S-1 structures, systems, and components is established at each nuclear station.

Inspection procedures for those activities affecting QA Condition 1 structures, systems and components are established by Nuclear Generation personnel.

8

SDuke Conversion SEnergy Methodology (Continued)

Comparison Matrix Format and Information Description Notes 1 - 5 describe information found in columns 1-5, respectively.

Column 1 - Provides verbatim text from the current QA Topical Report that is displayed in a paragraph-by-paragraph format (headings, list items too).

Column 2 - References locations where equivalent requirement statements are found within the proposed QAPD, NQA-1, or other specifically committed standards and regulatory documents.

Column 3 - Describes significant differences between the requirement statements found in the current and proposed QAPDs, clarifying statements, and references to notes.

Column 4 - Notes one of three requirement statement evaluation result designations: R =

Reduction in Commitment, N = No reduction in Commitment, and I = Increase in Commitment.

Column 5 - Provides clarifying or justifying statements for commitment changes (e.g., reductions, exceptions, alternatives).

9

'Duke Conversion SEnergy Methodology (Continued)

Comparison Matrix Format and Information Description The following evaluation notes are typically referenced within Column 3 to minimize redundant wording entry.

Note 6 - Descriptive requirement wording within the proposed QAPD, NQA-1 standard, or a regulatory document establishes equivalent requirements even though there may be a reduction in the level of methodology detail from the current QATR.

Note 7 - A requirement or commitment within the current QATR is redundant to one found in a regulation or other licensing document, therefore, the requirement is not repeated in the proposed QAPD.

Note 8 - A statement within the current QATR that prbvides only descriptive or clarifying information about the QA program is not considered a commitment to a regulatory requirement and is not repeated in the proposed QAPD.

10

Conversion E erg~y Methodology QAPD Differences Evaluation Process (Continued) 1.

2.

3.

4.

5.

Benchmark other utility submittals Initial evaluation by Team Lead Validation by Subject Matter Experts QA SPOC 1 OCFR50.54 review Management review 11

P Duke

- Energy Conversion Methodology (Continued)

QAPD Differences Evaluation Criteria

1. No Reduction in Commitment:

a.

Statements found within the proposed QAPD, NQA-1 standard, or other regulatory document establishes equivalent requirements and commitments.

b.

Detailed statements on how requirements are met may not be carried over into the proposed QAPD, provided the related requirements are addressed.

c.

A commitment to a requirement within the current QATR is redundant to one already made to a regulation within another licensing document.

d.

A statement that provides only descriptive or clarifying information about the QA program may not be carried over.

e.

Document format changes.

12

RDuke Conversion IlEnergy Methodology (Continued)

QAPD Differences Evaluation Criteria (continued)

2. Increase in Commitment:

• Commitment statements made within the proposed QAPD are beyond those found in the current QATR.

3. Reduction in Commitment:

E Commitment statements made within the current QATR are deliberately not included within the proposed QAPD.

13

Duke Energy Preliminary Evaluation Results N = No Reduction in Commitment (100% of preliminary paragraph comparison results fall into this category.)

I = Increase in Commitment (0% of preliminary paragraph comparison results fall into this category.)

R = Reduction in Commitment (0% of preliminary paragraph comparison results fall into this category.)

14

P Duke SEnergy No Reduction In Commitment Example 1 Quality Assurance Program Description Comparison Matrix Current QATR Proposed QAPD and NQA-1 Differences R/NIl Basis for Acceptability SectionslParagraphs Sections/Paragraphs (Note 3)

(Note 4)

(Note 5)

(Note 1)

(Note 2) 17.3.2.8 Test Control Section 11 - Test Control The paragraph title was N

changed to a section title.

a) Requirements and QAPD Part II, Section 11 None N

N/A acceptance limits contained in applicable design and vendor NQA-1 Supplement 11S-1 documents.

Supplement 11S-1 excerpt provided for this example:

"Test requirements and acceptance criteria shall be provided or approved by the organization responsible for the design of the item to be tested.

... Test requirements and "

acceptance criteria shall be based upon specified requirements contained in applicable design and other pertinent technical documents."

15

PDuke

- Energy No Reduction In Commitment Th Example 2 Quality Assurance Program Description Comparison Matrix Current QATR Proposed QAPD and NQA-1 Differences R/N/I Basis for Acceptability Sections/Paragraphs Sections/Paragraphs (Note 3)

(Note 4)

(Note 5)

(Note 1)

(Note 2) 17.3.2.2 Design Control Section 3 - Design Control The paragraph title was N

changed to a section title.

Abbreviated QAPD excerpt QAPD Part II, Section 1 Note 6 N

N/A provided for this example:

NQA-1 Basic Requirement 1 Requirements for establishing "Final approval prior to QAPD Part II, Section 2 QA program responsibilities, implementation of each station control, and procedural engineering change shall be by prescription and performance of the Nuclear Station Manager or QAPD Part II, Section 3 activities affecting quality are the Manager of Engineering; or NQA-1 Basic Requirement 3 found within the proposed for the Nuclear Station Manager QAPD and NQA-1 standard.

by the Operations QAPD Part II, Section 5 Superintendent, the NQA-1 Basic Requirement 5 However, no statements are Maintenance Superintendent, included within the proposed the Work Control QAPD that specify detailed Superintendent, or the On-Duty administrative statements on Emergency Coordinator as how final approval of previously designated by the engho ring changes are made.

Nuclear Station Manager."

Such details are provided within QA program implementation directives and procedures.

16

PDuke

- Energy No Reduction In Commitment Example 3 Quality Assurance Program Description Comparison Matrix Current QATR Proposed QAPD and NQA-1 Differences R/NIl Basis for Acceptability Sections/Paragraphs Sections/Paragraphs (Note 3)

(Note 4)

(Note 5)

(Note 1)

(Note 2) 17.3.2.12 Inspection Section 10 -Inspection The paragraph title was N

changed to a section title.

For inspections of concrete QAPD Part II, Section 10 Note 7 N

N/A containments, personnel NQA-1 Basic Requirement 10 fulfilling the role of Responsible No detailed statements are Engineer, shall be a Registered included within the proposed Professional Engineer QAPD that specify Responsible experienced in evaluating the Engineer qualifications and inservice condition of structural responsibilities.

concrete and knowledgeable of the design and construction codes and other criteria used in The Responsible Engineer the design and construction of qualifications and the concrete containment responsibilities are described in structure. The Responsible the ASME Boiler and Pressure Engineer may also perform Vessel Code, Section X1, inspections as discussed in this Subsection IWL, Requirements section.

for Class CC Concrete Components of Light-water Cooled Plants, paragraph IWL-2320, Responsible Engineer.

Section Xl of the ASME Code is endorsed by the NRC via reference within 10CFR50.55a(b)(2).

17

Puke 1nergy No Reduction In Commitment Example 4 Quality Assurance Program Description Comparison Matrix Current QATR Proposed QAPD and NQA-1 Differences R/NIl Basis for Acceptability Sections/Paragraphs Sections/Paragraphs (Note 3)

(Note 4)

(Note 5)

(Note 1)

(Note 2)

The Group Executive, Nuclear QAPD Part II, Section 2 Note 6 N

N/A Generation and Chief Nuclear Officer, appoints a Nuclear No statements are included Safety Review Board (NSRB) to within the proposed QAPD that serve as a nuclear safety review specify the appointment or use and audit backup to the normal of a Nuclear Safety Review operating organization.

Board (NSRB).

Rather, Duke commits to Option 1 - Independent Review Body (IRB) as described in Part II, Section 2 of the NEI 06-14A QAPD template. Standard f

Review Plan 17.5 references approval of this option via SE (Accession No. ML050210276).

Approval of the NEI template was via SE (Project No. 689, TAC No. MD3406, dated April 25, 2007).

18

P Duke f Proposed Submittal S0 Energy Package Submittal Pursuant to 10CFR50.54

• Duke QAPD Conversion Submittal Letter

• Enclosure 1 Marked Template Change Copy of Proposed QAPD

" Enclosure 2 - Final Unmarked Copy of Proposed QAPD

" Enclosure 3.- Old Versus New QAPD Comparison Matrix

" Enclosure 4-Summary of Comparison Results

" Enclosure 5 - Summary of Proposed QAPD Alternatives/Exceptions 19

Puke

.nergy Proposed Schedule

" Duke Submittal - October 2008

" NRC Approval - Spring 2009?

• Implementation - 6 to 9 Months After Approval 20

Puke nvin ergy Summary Closing Remarks 21

July 1, 2008 M. Wong PARTICIPANTS:

Participants from the NRC include members of the Office of Nuclear Reactor Regulation (NRR) g\\ ~~&)

NRR DUKE D. Thatcher UJ. Fisicaro P. Prescott

/R. Gill

-Q--(

/K. Rhyne Y-t&J L. Olshan Docket Nos. 50-269, 50-270, 50-287, 50-369, 50-370, 50-413, and 50-414

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Enclosure:

Agenda cc w/encl: See next page Distribution:

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I OFFICIAL RECORD COPY

UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D.C. 20555-0001 July 1, 2008 MEMORANDUM TO:

FROM:

SUBJECT:

Melanie C. Wong, Branch Chief Plant Licensing Branch I1-I Divisiojapf Operating Reactor Licensing clear Reactor Regulation e'onrd N.Olshan, Project Manager Plant Licensing Branch I1-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FORTHCOMING MEETING WITH DUKE ENERGY CAROLINAS, LLC, REGARDING OCONEE NUCLEAR STATION, UNITS 1,2, AND 3, MCGUIRE NUCLEAR STATION, UNITS 1 AND 2, AND CATAWBA NUCLEAR STATION, UNITS 1 AND 2 Tuesday, July 15, 2008 11:00 a.m. - 1:00 p.m.

U.S. Nuclear Regulatory Commission (NRC)

One White Flint North 11555 Rockville Pike, Room 0-1 F22 Rockville, Maryland To discuss Duke's transition to American Society for Mechanical Engineers NQA [Nuclear Quality Assurance]-1 -1994 This is a Category 1 Meeting. The public is invited to observe this meeting and will have one or more opportunities to communicate with the NRC after the business portion, but before the meeting is adjourned.

DATE & TIME:

LOCATION:

PURPOSE:

CATEGORY 1:

• MEETING CONTACTS:

Leonard N. Olshan, NRR 301-415-1419, Ino@nrc.qov John F. Stang, NRR 301-415-1345 ifs2@nrc.qov

• Commission's Policy Statement on "Enhancing Public Participation in NRC Meetings" (67 FR 36920), May 28, 2002

M. Wong PARTICIPANTS:

Participants from the NRC include members of the Office of Nuclear Reactor Regulation, (NRR)

NRR D. Thatcher P. Prescott C. Roquecruz L. Olshan J. Stang DUKE J. Fisicaro H. Gill K. Rhyne B. Travis Docket Nos. 50-269, 50-270, 50-287, 50-369, 50-370, 50-413, and 50-414

Enclosure:

Agenda cc w/encl: See next page

FORTHCOMING MEETING ON JULY 15, 2008, TO DISCUSS DUKE ENERGY CAROLINAS, LLC (DUKE) TRANSITION TO ASME NQA-1 -1994 JULY 15, 2008 AGENDA 11:00 a.m. - 11:10 a.m.

11:10 a.m. - 11:55 a.m.

11:55 a.m. - 12:50 p.m.

12:50 p.m. - 1:00 p.m.

Introductions and purpose of meeting Discussion of transition from Duke's current quality assurance program (QA) program to American Society of Mechanical Engineers NQA [Nuclear QA]-1-1994 Discuss comparison of NQA-1 -1994 to Nuclear Energy Institute QA Topical Report Closing remarks 1:00 p.m.

Adjourn

Oconee Nuclear Station, Units 1, 2, and 3 cc:

Mr. Bruce H. Hamilton Vice President, Oconee Site Duke Power Company LLC 7800 Rochester Highway Seneca, SC 29672 Ms. Lisa F. Vaughn Associate General Counsel and Managing Attorney Duke Energy Carolinas, LLC 526 South Church Street - EC07H Charlotte, North Carolina 28202 Manager, LIS NUS Corporation 2650 McCormick Dr., 3rd Floor Clearwater, FL 34619-1035 Senior Resident Inspector U.S. Nuclear Regulatory Commission 7812B Rochester Highway Seneca, SC 29672 Mr. Henry Porter, Director Division of Radioactive Waste Management Bureau of Land and Waste Management Dept. of Health and Env. Control 2600 Bull St.

Columbia, SC 29201-1708 f

Mr. Michael A. Schoppman Framatome ANP

• 1911 North Ft. Myer Dr.

Suite 705 Rosslyn, VA 22209 Mr. B. G. Davenport Regulatory Compliance Manager Oconee Nuclear Site Duke Energy Corporation ON03RC 7800 Rochester Highway Seneca, SC 29672 Mr. Leonard G' Green Assistant Attorney General NC Department of Justice P.O. Box 629 Raleigh, NC 27602 Mr. R. L. Gill, Jr.

Manager - Nuclear Regulatory Issues and Industry Affairs Duke Power Company LLC 526 S. Church St.

Mail Stop EC05P Charlotte, NC 28202 Division of Radiation Protection NC Dept of Environment, Health, &

Natural Resources 3825 Barrett Dr.

Raleigh, NC 27609-7721 Mr. Peter R. Harden, IV VP-Customer Relations and Sales Westinghouse Electric Company 6000 Fairview Road 12th Floor Charlotte, NC 28210 Mr. Henry Barron Group Vice President, Nuclear Generation and Chief Nuclear Officer P.O. Box 1006-EC07H Charlotte,. NC 28201-1006 Mr. Charles Brinkman Director, Washington Operations Westinghouse Electric Company 12300 Twinbrook Parkway, Suite 330 Rockville, MD 20852 Ms. Kathryn B. Nolan Senior Counsel Duke Energy Carolinas, LLC 526 South Church Street - EC07H Charlotte, NC 28202

McGuire Nuclear Station, Units 1 & 2 cc:

Vice President McGuire Nuclear Station Duke Power Company, LLC 12700 Hagers Ferry Road Huntersville, NC 28078 Associate General Counsel and Managing Attorney Duke Energy Carolinas, LLC 526 South Church Street - EC07H Charlotte, North Carolina 28202 County Manager of Mecklenburg County 720 E. Fourth St.

Charlotte, NC 28202 Regulatory Compliance Manager Duke Energy Corporation McGuire Nuclear Site 12700 Hagers Ferry Road Huntersville, NC 28078 Senior Resident Inspector U.S. Nuclear Regulatory Commission 12700 Hagers Ferry Road Huntersville, NC 28078 Mecklenburg County Department of Environmental Protection 700 N. Tryon St Charlotte, NC 28202 Manager Nuclear Regulatory Issues &

Industry Affairs Duke Energy Corporation 526 S. Church St.

Mail Stop EC05P Charlotte, NC 28202 Division of Radiation Protection NC Dept of Environment, Health & Natural Resources 3825 Barrett Dr.

Raleigh, NC 27609-7721 Owners Group (NCEMC)

Duke. Energy Corporation 4800 Concord Road York, SC 29745 Group Vice President, Nuclear Generation

& Chief Nuclear Officer P.O. Box 1006-EC07H Charlotte, NC 28201-1006 Senior Counsel Duke Energy Carolinas, LLC 526 South Church Street - EC07H Charlotte, NC 28202 Vice President Customer Relations and Sales Westinghouse. Electric Company 6000' Fairview Road, 12th Floor Charlotte, NC 28210 NCEM REP Program Manager 4713 Mail Service Center Raleigh, NC 27699-4713 Assistant Attorney General NC Department.of Justice P.O. Box 629 Raleigh, NC 27602

Leonard Olshan From:

Paul Prescott Sent:

Friday, June 27, 2008 10:28 AM To:

Leonard Qishan

Subject:

RE:

NQA - Nuclear Quality Assurance QATR - Quality Assurance Topical Report From: Leonard Olshan Sent: Friday, June 27, 2008 10:27 AM To: Paul Prescott

Subject:

RE:

Whoops, there is one question. What do "NQA" and "QATR" stand for? (I'll guess that NQA is nuclear quality assurance.)

From: Paul Prescott Sent: Friday, June 27, 2008 10:18 AM To: Leonard Olshan Cc: Carla Roquecruz; Dale Thatcher

Subject:

Hi Lenny, Just talked to Jim Fisicaro again. He had nothing planned for an agenda, so how's this: "The meeting is to discuss Duke's transition from their current quality assurance program to ASME NQA-1-1994 and format of this program to the NEI QATR template that was developed for new reactors." NRC will do introduction. Duke will provide discussion. We will close with any questions.

Just let me know if you need anything else.

Paul Prescott Senior Operations Engineer NRR/DE/EQVB (301)415-3026 MS: 0-9E3 1

Leonard Olshan From:

Paul Prescott Sent:

Friday, June 27, 2008 10:18 AM To:

Leonard Qishan Cc:

Carla Roquecruz; Dale Thatcher Hi Lenny, Just talked to Jim Fisicaro again. He had nothing planned for an agenda, so how's this: "The meeting is to discuss Duke's transition from their current quality assurance program to ASME NQA-1-1994 and format of this program to the NEI QATR template that was developed for new reactors." NRC will do introduction. Duke will provide discussion. We will close with any questions.

Just let me know if you need anything else.

Paul Prescott Senior Operations Engineer NRR/DE/EQVB (301)415-3026 MS: 0-9E3

• 1