Levy, Units 1 & 2, Response to Request for Additional ... · Standard Review Plan Section 13.1.1,...

Progress EnergySerial: NPD-NRC-2009-088` 10CFR52.79June 3, 2009

U.S. Nuclear Regulatory CommissionAttention: Document Control DeskWashington, D.C. 20555'0001

LEVY NUCLEARPOWER PLANT, UNITS I AND 2DOCKET NOS. 52-029 AND 52-030RESPONSE TO REQUEST FOR ADDITIONAL INFORMATION LETTER NO. 024 RELATED TOMANAGEMENT AND TECHNICAL SUPPORT ORGANIZATION

Reference: Letter from Brian C. Anderson (NRC) to Garry Miller (PEF), dated April 9, 2009,"Request for Additional Information Letter No. 024 Related to SRP Section 13.1.1for the Levy County Nuclear Plant, Units 1 and 2 Combined License Application"

Ladies and Gentlemen:

Progress Energy Florida, Inc. (PEF) hereby submits our response to the Nuclear RegulatoryCommission's (NRC) request for additional information provided in the referenced letter.

A response to the NRC request is addressed in the enclosure. The enclosure also identifieschanges that will be made in a future revision of the Levy Nuclear Power Plant Units 1 and 2application.

The latest revision of Progress Energy's New Nuclear Plant Development Quality AssuranceProgram Description Topical Report includes recent organizational changes, and will be submittedunder separate cover.If you have any further questions, or need additional information, please contact Bob Kitchen at

(919) 546-6992, or me at (919) 546-6107.

I declare under penalty of perjury that the foregoing is true and correct.

Executed on June 3, 2009.

Sincerely,

General ManagerNuclear Plant Development

Enclosure

cc: U.S. NRC Region II, Regional AdministratorMr. Brian C. Anderson, U.S. NRC Project Manager

Progress Energy Carolinas, Inc.P.O. Box 1551Raleigh, NC 27602

United States Nuclear Regulatory CommissionNPD-NRC-2009-088

bc: Robert Kitchen, Manager-Nuclear Plant LicensingTillie Wilkins, NPD-LicensingShawn Hughes (Shaw Power Group)John O'Neill, Jr. (Pillsbury Winthrop Shaw Pittman, LLP)A. K. Singh (Sargent & Lundy, LLC)Lorin Young (CH2M HILL)John Archer (WorleyParsons)NPD Document Control Inbox (Records: Correspondence)File: NGG-NPD (Dawn Bisson)

Enclosure to Serial: NPD-NRC-2009-088Page 1 of 16

Levy Nuclear Power Plant Units I and 2Response to NRC Request for Additional Information Letter No. 024 Related toSRP Section 13.1.1 for the Combined License Application, dated April 9, 2009

NRC RAI #

13.01.01-1

13.01.01-2

13.01.01-3

13.01.01-4

13.01.01-5

13.01.01-6

13.01.01-7

13.01.01-8

13.01.01-9

13.01.01-10

Progress Energy RAI #

L-0175

L-0176

L-0177

L-0178

L-0179

L-0180

L-0181

L-0182

L-0183

L-0184

Progress Energy Response

Response enclosed - see following pages











NRC Letter No.: LEVY-RAI-LTR-024

NRC Letter Date: April 9, 2009

NRC Review of Final Safety Analysis Report

NRC RAI #: 13.01.01-1

Text of NRC RAI:

Standard Review Plan Section 13.1.1, "Management and Technical Support Organization,"section 1.1 .B.iii states that the applicant should provide a plan for the development of the plantmaintenance programs. FSAR section 13.1 does not appear to include a description of the planto develop the plant maintenance programs.

Please identify the location of this information in the Levy County COL application, or justify itsexclusion.

PGN RAI ID#: L-0175

PGN Response to NRC RAI:

Plant maintenance procedures are developed by maintenance, engineering, and work controldepartment personnel to provide programs that ensure proper operability and reliability of plantequipment. These programs are developed and made effective during the preoperation/startupphase with approved administrative procedures such that as equipment is placed in service itwill be monitored and maintained under approved maintenance programs. FSAR Chapter 13,Appendix 13AA will be clarified to reflect maintenance program development in a future FSARrevision.

Associated Levy COL Application Revisions:

The following change will be made in a future revision to the Levy Units 1 and 2 (LNP) FSAR:

Add the following paragraph after the last sentence of FSAR Subsection 13AA.1.1.1.1.8:

To ensure equipment operability and reliability, plant maintenance programs such as preventiveand corrective maintenance are developed and made effective during the pre-operation/startupphase with approved administrative procedures under the direction of the managers in chargeof maintenance, engineering and work control.

AttachmentslEnclosures:

None.





NRC RAI #: 13.01.01-2

Text of NRC RAI:

Standard Review Plan Section 13.1.1, "Management and Technical Support Organization,"section 1.1.B.iv states that the applicant should describe how design, construction, andpreoperation responsibilities are assigned by the applicant's headquarters staff andimplemented within the organizational units. FSAR section 13.1 does not appear to include adescription of how design, construction, and preoperation responsibilities are assigned by theapplicant's headquarters staff and implemented within the organizational units.


PGN RAI ID#: L-0176


Progress Energy organizational changes have impacted position title(s) in Figures 13AA-201and 13.1-203. The VP-Nuclear Projects and Construction title has been changed to VP-NuclearPlant Development reporting to the President /CEO Progress Energy Florida and responsiblefor new plant licensing, engineering and construction. A VP-Operational Readiness positionreporting to the President /CEO Progress Energy-Florida has also been developed and will beresponsible for the overall operational readiness for fuel load, startup testing and plantoperation. For consistency with the Levy COLA Revision 0, the title VP-Nuclear Projects &Construction is used in the response below. However, Chapter 13 will be revised to reflectthese title changes as part of the Levy COLA annual update.

Related to Standard Review Plan Section 13.1.1, "Management and Technical SupportOrganization," section 1.1.B.iv, Preoperational Responsibilities; Section 13.1.1.1 of the LNPFSAR provides a description for how design, construction, and operation functionalresponsibilities are delineated. Section 13.1.1.3 provides a description of how theresponsibilities are implemented within the organizational units. The last sentence of Section13.1.1.1 states "The management and technical support (vendor and interface) organization fordesign, construction, and preoperational activities is addressed in Appendix 13AA."

To provide clarification on the relationship of the interfaces between the applicant organizationand the vendor and Architect/Engineer organization, Chapter 13, Section 13.1.1.1 will berevised as indicated below.


The following change will be made in a future revision to the Levy Units 1 and 2 (LNP) FSAR:


Chapter 13, Section 13.1.1.1 Design, Construction, and Operating Responsibilities, secondparagraph.

Delete:

Key executive and corporate management positions, functions, and responsibilities arediscussed in Subsection 13.1.1.3.1. The corporate organization is shown in Figure13.1-203. The management and technical support organization for design, construction,and preoperational activities is addressed in Appendix 13AA.

Insert:

The corporate organization as shown in Figures 13.1-203 and 13AA-201 provide fordesign, construction, and preoperational activities and oversight of NSSS vendor andArchitect/Engineer management and technical support organizations for design,construction, and preoperational activities as discussed in Appendix 13AA.

Attachments/Enclosures:

None.





NRC RAI #: 13.01.01-3

Text of NRC RAI:

Standard Review Plan Section 13.1.1, "Management and Technical Support Organization,"section 1. 1.B.v states that the applicant should provide the working or performance levelorganizational unit with responsibility for the project for design, construction, and preoperation.FSAR section 13.1 does not appear to include the working or performance level organizationalunit with responsibility for the project for design, construction, and preoperation.


PGN RAI ID #: L-0177


Progress Energy organizational changes have impacted position title(s) in Figure 13AA-201referenced in this response. The VP-Nuclear Projects and Construction title has been changedto VP-Nuclear Plant Development reporting to the President /CEO Progress Energy Florida andresponsible for new plant licensing, engineering and construction. A VP-Operational Readinessposition reporting to the President /CEO Progress Energy-Florida has also been developed andwill be responsible for the overall operational readiness for fuel load, startup testing and plantoperation. Chapter 13 will be revised to reflect these title changes as part of the Levy COLAannual update.

Related to Standard Review Plan Section 13.1.1, "Management and Technical SupportOrganization," section 1.1..B.v, Preoperational Responsibilities; Section 13.1.1.3 of the LNPFSAR provides a description for how design, construction, and operation applicantresponsibilities are delineated. Appendix 13AA.1.1.1.2 "Preoperational Activities" provides adescription for how project design, construction, and preoperational activities are delineated.Figure 13AA-201 shows the working level organization unit with responsibility for design,construction, and preoperation activities and how it relates to the overall PGN organizationalstructure.


No COLA changes have been identified associated with this response.


None.





NRC RAI #: 13.01.01-4

Text of NRC RAI:

Standard Review Plan Section 13.1.1, "Management and Technical Support Organization,"section 1.1 .B.vi states that the applicant should provide the estimated number of personnel to beassigned to each unit with responsibility for the project for design, construction, andpreoperation. FSAR section 13.1 does not appear to include the estimated number ofpersonnel to be assigned to each unit with responsibility for the project for design, construction,and preoperation.




Progress Energy organizational changes have impacted position titles in Table 13.1-201referenced in this response. Chapter 13 will be revised to reflect these title changes as part ofthe Levy COLA annual update.

Related to Standard Review Plan Section 13.1.1, "Management and Technical SupportOrganization," section 1.1.B.vi, Preoperational Responsibilities; the Levy Nuclear Plant Units 1and 2, COL Application, FSAR Table 13.1-201 for preoperational activities provides a GenericPosition/Site-Specific Position Cross Reference relating ANS-3.1-1993 Function Positions toSite Specific Nuclear Plant Positions and an estimate of the number of personnel to beassigned to each unit with responsibility for project preoperational activities.

The content and level of detail in these sections of the LNP FSAR is consistent with theReference COLA and the FSAR submittal for Shearon Harris Units 2 and 3.




None.





NRC RAI #: 13.01.01-5

Text of NRC RAI:

Standard Review Plan Section 13.1.1, "Management and Technical Support Organization,"section I.1 .B.vii states that the applicant should provide the general educational and experiencerequirements for those personnel with design, construction, and preoperation responsibilities.FSAR section 13.1 does not appear to include the general educational and experiencerequirements for those personnel with design, construction, and preoperation responsibilities.




LNP FSAR Subsection 13.1.3.1, Qualifications of Technical Support Personnel, states thefollowing:

The qualifications of managers and supervisors of the technical support organizationmeet the qualification requirements in education and experience for those described inANSI/ANS-3.1-1993 (Reference 201) as endorsed and amended by Regulatory Guide1.8 except for cold license operators as described in NEI 06-13A.

Both of these references are readily available and therefore the requirements are not restatedin this section.

The content and level of detail in these sections of the LNP FSAR is consistent with theReference COLA and the FSAR submittal for Shearon Harris Units 2 and 3.




None.





NRC RAI #: 13.01.01-6

Text of NRC RAI:

Standard Review Plan Section 13.1.1, "Management and Technical Support Organization,"section 1.1.B.viii states that the applicant should discuss how the applicant's managementinterfaces with the NSSS and AE for the project for design, construction, and preoperation.FSAR section 13.1 does not appear to include a discussion of how the applicant's managementwill interface with the NSSS and AE for the project for design, construction, and preoperation.




Progress Energy organizational changes have impacted position title(s) in Figure 13AA-201referenced in this response. The VP-Nuclear Projects and Construction title has been changedto VP-Nuclear Plant Development reporting to the President /CEO Progress Energy Florida andresponsible for new plant licensing, engineering and construction. A VP-Operational Readinessposition reporting to the President /CEO Progress Energy-Florida has also been developed andwill be responsible for the overall operational readiness for fuel load, startup testing and plantoperation. Chapter 13 will be revised to reflect these title changes as part of the Levy COLAannual update.

LNP FSAR Section 13.1.1.1 discusses the applicant's management organization. The lastsentence states that the management and technical support organization for design,construction, and preoperational activities is addressed in Appendix 13AA; this includesoversight of the NSSS and AE (vendor) management organization.

FSAR Appendix 13AA provides discussion and a figure to describe how the applicant'smanagement organization interfaces with the NSSS and AE organizations, which together arereferred to as engineering, procurement, and construction (EPC) contractor.

Figure 13AA-201 shows the construction management organization. The constructionmanagement organization includes Progress Energy personnel and EPC personnel. Asindicated in Figure 13AA-201, the project director of the EPC contractor reports to the ProgressEnergy site executive. In addition to Figure 13AA-201, the following FSAR subsection providesinterface information:

* Design - FSAR Subsection 13AA.1.1.1.1.3 addresses interface requirementsassociated with design between the reactor technology vendor and plant staff.


" Construction - FSAR Subsection 13AA.1. 1.1.1.8 addresses accountability of theEPC contractor to the site executive in addition to monitoring of contractorperformance.

* Pre-operation - FSAR Subsection 13AA. 1.1.1.2.2 addresses the preoperational andstartup testing organization. Pre-operation and startup testing is performed by theplant test and operation (PT&O) organization and is managed by the functionalmanager in charge of startup testing as discussed in FSAR Subsection 14.2.2.1.4.Interface responsibilities described include:

o participation in the joint test working group (JTWG) which is a group made upof Progress Energy and EPC personnel to review and approve testing,

o coordinating turnover of systems from construction to PT&O, ando coordinating vendor participation in testing.

To further clarify the relationship of the interfaces between the applicant organization and theNSSS vendor and Architect/Engineer organization, Chapter 13, Section 13.1.1.1 will be revisedas indicated in response to RAI 13.01.01-2 contained in this letter.


See response to LNP RAI 13.01.01-2 contained in this letter.


None.





NRC RAI #: 13.01.01-7

Text of NRC RAI:

Standard Review Plan Section 13.1.1, "Management and Technical Support Organization,"section 1.1 .B.x states that the applicant should provide the process for the required review ofcontractor work by the applicant's staff for design, construction, and preoperation. FSARsection 13.1 does not appear to include the process for the required review of contractor workby the applicant's staff for design, construction, and preoperation.




Progress Energy organizational changes have impacted the following position title(s) andreporting responsibilities in this response: the VP-Nuclear Projects and Construction title hasbeen changed to VP-Nuclear Plant Development reporting to the President /CEO ProgressEnergy Florida and responsible for new plant licensing, engineering and construction.Additionally, a VP-Operational Readiness position reporting to the President /CEO ProgressEnergy-Florida has also been developed and will be responsible for the overall operationalreadiness for fuel load, startup testing and plant operation. For consistency with the Levy COLARevision 0, the VP-Nuclear Projects and Construction title is used in the response below.However, Chapter 13 will be revised to reflect these changes as part of the Levy COLA annualupdate.

Section 13.1.1.2 of the LNP FSAR states: Before beginning preoperational testing, the VicePresident - Nuclear Projects and Construction or designated project manager for LNP 1 and 2,the Plant General Manager for LNP 1 and 2 and the Vice President - Nuclear Engineering andServices establish the organization of managers, functional managers, supervisors, and staffsufficient to perform required functions for support of safe plant operation.

The early establishment of this organization supports the oversight and review described inAppendix 13AA.

Section 13AA.1.1.1.1.8 Management and Review of Construction Activities includes thefollowing:Overall management and responsibility for construction activities is assigned to the VP -Nuclear Projects and Construction. The Project Director of the engineering, procurement, andconstruction (EPC) contractor is accountable to the VP - Nuclear Projects and Construction forconstruction activities. See Organization Chart Figure 13AA-201. Monitoring and review ofconstruction activities by utility personnel is a continuous process at the plant site. Contractorperformance is monitored to provide objective data to utility management in order to identify


problems early and develop solutions. Monitoring and review of construction activities is dividedfunctionally across the various disciplines of the utility construction staff (e.g., electrical,mechanical, instrument and control) and tracked by schedule based on system and major plantcomponents/areas.

Section 13AA.1.1.1.2.2 Preoperational and Startup Testing states:Preoperational and startup testing is conducted by the plant test and operations (PT&O)organization. The PT&O organization, functions, and responsibilities are addressed in Section14.2. Sufficient numbers of personnel are assigned to perform preoperational and startuptesting to facilitate safe and efficient implementation of the testing program. Plant-specifictraining provides instruction on the administrative controls of the test program. To improveoperational experience, operations and technical staff are used as support in conducting thetest program and in reviewing test results.




None.





NRC RAI #: 13.01.01-8

Text of NRC RAI:

Standard Review Plan Section 13.1.1, "Management and Technical Support Organization,"section I.1.B.xi states that the applicant should provide those design, construction, andpreoperation positions that have functional responsibilities other than for the COL application,and the expected proportion of time assigned to the other activities. FSAR section 13.1 doesnot appear to include those design, construction, and preoperation positions that havefunctional responsibilities other than for the COL application, and the expected proportion oftime assigned to the other activities.




Progress Energy organizational changes have impacted the following position title(s) andreporting responsibilities in this response: the VP-Nuclear Projects and Construction title hasbeen changed to VP-Nuclear Plant Development reporting to the President /CEO ProgressEnergy Florida and responsible for new plant licensing, engineering and construction.Additionally, a VP-Operational Readiness position reporting to the President /CEO ProgressEnergy-Florida has also been developed and will be responsible for the overall operationalreadiness for fuel load, startup testing and plant operation. Chapter 13 will be revised to reflectthese changes as part of the Levy COLA annual update.

FSAR Figure 13AA-201 illustrates the construction management organization and includespositions identified that have functional responsibilities for design, construction, orpreoperational testing of Levy Units 1 and 2 (LNP). These managers, functional managers, andpersonnel that report to them will perform their duties specific to LNP. No collateralresponsibilities outside of the LNP project have been identified for these personnel.

Since these personnel have no other functional responsibilities, no additional FSAR discussionis required to satisfy this SRP requirement.




None.




'NRC Review of Final Safety Analysis Report

NRC RAI #: 13.01.01-9

Text of NRC RAI:

Standard Review Plan Section 13.1.1, "Management and Technical Support Organization,"section I.1.B.xii states that the applicant should provide the early plans for providing technicalsupport for the operation of the facility. FSAR section 13.1 does not appear to include the earlyplans for providing technical support for the operation of the facility.


PGN RAI ID#: L-0183


Progress Energy organizational changes have impacted the following position title(s) andreporting responsibilities in this response: the VP-Nuclear Projects and Construction title hasbeen changed to VP-Nuclear Plant Development reporting to the President /CEO ProgressEnergy Florida and responsible for new plant licensing, engineering and construction.Additionally, a VP-Operational Readiness position reporting to the President /CEO ProgressEnergy-Florida has also been developed and will be responsible for the overall operationalreadiness for fuel load, startup testing and plant operation. For consistency with the Levy COLARevision 0, the title VP-Nuclear Projects and Construction is used in the response below.However, Chapter 13 will be revised to reflect these changes as part of the Levy COLA annualupdate.

Plans for providing early technical support for the operation of the facility are included inChapter 13 of the Levy COL FSAR as follows:

" Section 13.1.1.2 "Provisions for Technical Support Functions" states the following:Before beginning preoperational testing, the Vice President - Nuclear Projects andConstruction or designated project manager for LNP 1 and 2, the Plant GeneralManager for LNP 1 and 2 and the Vice President - Nuclear Engineering and Servicesestablish the organization of managers, functional managers, supervisors, and staffsufficient to perform required functions for support of safe plant operation.

* Section 13.1.1.2 also states: In the event that station personnel are not qualified to dealwith a specific problem, the services of qualified individuals from other functions withinthe company or an outside consultant are engaged. For example, major contractors,such as the reactor technology vendor or turbine generator manufacturer, providetechnical support when equipment modifications or special maintenance problems areconsidered.


Section 13AA. 1.1.1.1.8 Management and Review of Construction Activities states:Overall management and responsibility for construction activities is assigned to the VP -Nuclear Projects and Construction. The Project Director of the engineering,procurement, and construction (EPC) contractor is accountable to the VP - NuclearProjects and Construction for construction activities. See Organization Chart Figure13AA-201. Monitoring and review of construction activities by utility personnel is acontinuous process at the plant site. Contractor performance is monitored to provideobjective data to utility management in order to identify problems early and developsolutions. Monitoring of construction activities verifies that the contractors are incompliance with contractual obligations for quality, schedule, and cost. Monitoring andreview of construction activities is divided functionally across the various disciplines ofthe utility construction staff (e.g., electrical, mechanical, instrument and control) andtracked by schedule based on system and major plant components/areas.

After each system is turned over to plant staff, the construction organization relinquishesresponsibility for that system. At that time they will be responsible for completion ofconstruction activities as directed by plant staff and available to provide support forpreoperational and start-up testing as necessary.

The content and level of detail contained in the LNP FSAR on this subject is consistent with theReference COLA and the FSAR submitted for Shearon Harris Units 2 and 3.




None.





NRC RAI #: 13.01.01-10

Text of NRC RAI:

Standard Review Plan Section 13.1.1, "Management and Technical Support Organization,"section 1.2.B states that the applicant should provide the relationship of the nuclear-orientedpart of the organization to the rest of the corporate organization. FSAR section 13.1 does notappear to include the relationship of the nuclear-oriented part of the organization to the rest ofthe corporate organization.




Progress Energy organizational changes have impacted the following position title(s) andreporting responsibilities in this response: the VP-Nuclear Projects and Construction title hasbeen changed to VP-Nuclear Plant Development reportingto the President /CEO ProgressEnergy Florida and responsible for new plant licensing, engineering and construction.Additionally, a VP-Operational Readiness position reporting to the President /CEO ProgressEnergy-Florida has also been developed and will be responsible for the overall operationalreadiness for fuel load, startup testing and plant operation. Responsibility for fuel load, startuptesting and plant operation will transition to the Chief Nuclear Officer at fuel load. Chapter 13will be revised to reflect these changes as part of the Levy COLA annual update.

To clarify how the nuclear-oriented part of the corporation (NGG) relates to the other majorcorporate departments of Power Operations, Administration & Corporate Relations, andFinance, organizational links will be added to Figure 13.1-203.


The following change will be made in a future revision to the LNP FSAR:

Revise Figure 13.1-203 to include functional organizational links showing how Nuclear PlantDevelopment (NPD) and Nuclear Generation Group (NGG) relate to the other major corporatedepartments as shown in the figure on the following page.


None.


Progress Energy IncPresident and CEO

Nuclear GenerationSenior VP & Chief

Nuclear Officer

- - - - - - -Via interface agreement- -I

Levy Nuclear Power PlantUnits 1 and 2

Part 2, Final Safety Analysis Report

Corporate and Engineering OrganizationFIGURE 13.1-203

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