ML17298B380
| ML17298B380 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 10/18/1984 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Knighton G Office of Nuclear Reactor Regulation |
| References | |
| ANPP-30890-TFQ, NUDOCS 8410230263 | |
| Download: ML17298B380 (20) | |
Text
REGULATOR INFORMATION DISTRIBUTION b STEM (RIDS)
ACCESSION NBR; 841 FACIL:STN"50"528 STN"50 529 STN 50-530 AUTH,NAME VAN BRUNTiE,ED REC IP, NAME KNIGHTONiG ~
0230?63 DOC DATE: 84/1,0/18 NOTARIZED:
YES DOCKET Palo Verde Nuclear Stationi Unit ii Arizona Public 05000528 Palo Verde Nuclear Stationi Unit 2i Arizona Publi 05000529 Palo Verde Nuclear Stationi Unit 3i Arizona Publi 05000530 AUTt]OR AFFILIATION Arizona Public Service Co.
RECIPIENT AFFILIATION Licensing Branch 3
SUBJECT:
Forwards revs to FSAR Section 1 '
re clarification to Reg Guides 1.38 L 1.123.Reg Guide 1.38 changes,clar,ify that ANSI Std N45 ~ ?.'.?3 used for qualifications of personnel auditing 8 monitoring offsite inspiexam or testings DISTRIBUTION CODE:
8001D COPIES RECEIVED:LTR ENCL SIZE:
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TITLE: Licensing Submi t ta1:
PSAR/FSAR Amdts 8 Related Corr espondence NOTES:Standardized plant.
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05000528 05000529 05000530 RECIPIENT ID CODE/NAME NRR/DL/ADL NRR LB3 LA INTERNAL; ADM/LFMB IE FILE IE/DEPER/IRB 35 NRR ROEiM ~ L NRR/DE/CEB 11 NRR/DE/EQB 13 NRR/DE/MEB 18 NRR/DE/SAB 24 NRR/DHFS/HFEB40 NRR/DHFS/PSRB NRR/DSI/AEB 26 NRR/DSI/CPB 10 NRR/DSI/ICSB 16 NRR/DSI/PSB 19 NRR/D5 I/RS0 23 RGN5 EXTERNAL: ACRS 41 DMB/DSS (AMDTS)
LPDR 03 NSIC 05 COPIES LTTR ENCL 1
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1 RECIPIENT ID CODE/NAME NRR LB3 BC lIC ITRA, E 01 ELD/HDS3 IE/DEPER/EPB 36 IE/DQAS IP/QAB? 1 NRR/DE/AEAB NRR/DE/EHEB NRR/DE/GB 28 NRR/DE/MTEB 17 NRR/DE/SGEB 25 NRR/DHFS/LQB 32 NRR/DL/SSPB NRR/DSI/ASB NRR/DSI/CSB 09 NRR/DS I/METB 12 N
AB 22 REG FILF 04 R
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FEMA REP DIV 39 NRC PDR 02 NTIS COPIES LTTR ENCL 0
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TOTAl NUMBER OF COPIES REQUIRED:
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Arizona Public Service Company Director of Nuclear Reactor Regulation Attention:
Mr. George Knighton, Chief Licensing Branch No.
3 Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C.
20555 October 18, 1984 ANPP-30890 TFQ/JYM
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2 and 3
Docket Nos. STN-50-528/529/530 Clarifications to R.
G. 1.38 and 1.123 File: 84-056-026 G.1.01.10
Dear Mr. Knighton:
Attached are changes to Section 1.8 of the FSAR concerning clarifications to Regulatory Guides 1.38 and 1.123.
PVNGS uses the guidance of Regulatory Guide 1.146 "qualification of equality Assurance Program Audit Personnel for Nuclear Power Plants" which endorses ANSI N45.2.23.
The changes to Regulatory Guide 1.38 were made to clarify that ANSI N45.2.23 is used in lieu of ANSI N45.2.6 for the qualifications of personnel who audit and monitor off-site inspection, examination or testing.
The changes to Regulatory Guide 1.123 were made to clarify ANSI N45.2.23 is used in lieu of ANSI N45.2.6 for the qualification of personnel performing program verification.
If you have any questions on this matter, please contact me.
Very truly yours, 8410230263 841018 PDR ADOCK 05Q00528' PDR EEVBJr/JYM/bg Attachment CC:
E. A. Licitra w/a A. C. Gehr w/a J. Spraul w/a R. Zimmerman w/a F. E.
Van Brunt, Jr'PS Vice President Nuclear Production ANPP Project Director oat
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ANPP-30890 STATE OF ARIZONA
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) st COUNTY OF MARICOPA)
I, Edwin E.
Van Brunt, Jr.,
represent that I am Vice President, Nuclear Production of Arizona Public Service
- Company, that the foregoing document has been signed by me on behalf of Arizona Public Service Company with full authority to do so, that I have read such document and know its
- contents, and that to the best of my knowledge and belief, the statements made therein are true.
Edwin E. Van Brunt, Jr.
Sworn to hefore me'this
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dey of 5
n 1~4 My Commission Expires:
Ny
, 1984.
Notary Public
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PVNGS FSAR CONFOBJCQICE TO NRC REGULA,ATORY GUIDES achieve required quality.
This is consistent with Section 5.2.17 paragraph 5 of ANSI N18.7-1976 which provides for examination, measurement, or testing to assure quality or indirect control by monitoring of processing methods.
REGUZATORY GUIDE 1.38:
Quality Assurance Requirements for Packaging,
- Shipping, Receiving,
- Storage, and Handling of Items for Mater-Cooled Nuclear Po~er Plants (Revision 0, March 16, 1973)
RESPONSE
The requirements of.the referenced Standard (ANSI N45.2.2-1972)
'as modified and interpreted in the Regulatory Position are applied to the Bechtel quality program for construction of safety-related
- items, except as modified and interpret:ed below:
4.$
Section 2.7 Classification of Items.
The four level classification system may not be used explicitly.
- However, the specific requirements for each classifica-tion as specified in the Standard are applied to the items suggested in each classification and for similar items."
3Pc; Section '3. 9:
Identification of items, after the outside of the container ha been
- removed, is. accomplished in accor-dance with ANSI NZ8.7, Section 5,2.13 P..
Sect.ion 6.2 Storage Areas.
Paragraph 6.2.1 requires control and limited access to storage areas.
In lieu of and to amplify this paragraph the following is applied:
March 1982
INSERT I A.
Section 2.4 Personnel Qualification.
Off-site inspection, examination or testing shall be audited and monitored by personnel who are qualified in accordance with N45.2.23.
When the off-site inspection, examination or testing involves acceptance of the component the personnel will be qualified with N45.2.6.
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~ r PVNGS FSAR CONFOK~CE TO NRC REGULATORY GUIDES "Access to storage areas for level A, B and C is controlled by the.individual(s) responsible for material storage."
Level D items are stored in a site
'rea which has access control consistent with zone IV of ANSI N45.2.3-1973.
While the areas may be posted
~
to limit access, other positive controls (other than that. for the overall site area) or guards may not be provided.
Sections 3.9, 5.6, and Appendix A Section 3.9 Marking.
These ANSI N45.2.2 sections control direct marking of 1austenitic stainless steel and nickel based alloys.
Marking is in compliance with the requirements of these sections except that markings may be directly applied using inks controlled so as not to contain more than 200.ppm of inorganic halogens.
.P DELETED REGULATORY GUIDE 1. 38:
Quality Assurance Requirements for Packaging,
- Shipping, Receiving, Storage and Handling of Items for Water-Cooled J
Nuclear Power Plants (Revision 2, May 1977)
RESPONSE
For operations phase activities that are comparable to activities occurring during the construction
- phase, the position of Amendment 9
- 1. 8-24B 4"
August 1982
. PVNGS FSAR CONFORMANCE TO NRC REGULATORY GUIDES Regulatory Guide 1s38 is accepted with the following exceptions to the referenced standard (ANSI 45.2.2-1972):
8M Section 2.7 'Classification of Items.
The four level classification system may not be used explicitly.
However, the specific requirements for each classifica-tion as specified in the Standard are applied to the items suggested in each classification and for similar items.
Q~ Section 2.7 Classification of Items.
New (unirradiated) fuel elements, fission chamber detectors and sealed sources containing special nuclear material are classified as level B for the purposes of this standard.
February 1984 1.8-24C Amendment 12
+
Insert II A.
Section 2.4 Personnel Qualification. Off-site inspection, examination or testing shall be audited and monitored by personnel who are qualified in accordance with N.45.2.23.
When the off-site inspection, examination or testing involves acceptance of the component the personnel will be qualified with N45.2.6.
ll t'
PVNGS F SAR CONFORMANCE TO NRC REGULATORY GUIDES Section 3.9:
Identification of items, after the outside of the container has been removed, is accomplished in accor-dance with ANSI N18.7, Section 5.2.13.3.
Section 6.2 Storage Areas.
Paragraph 6.2.1 requires control and limited access to storage areas.
In lieu of and to amplify this paragraph the following is applied.
"Access to storage areas for level A, B and C is controlled by the individual(s) responsible for material storage."
Level D items are stored in a site area which has access control consistent with rone IV of ANSI N45.2.3-1973.
While the areas may be posted to limit access, other positive controls (other than that for the overall site area) or guards may not be provided.
FZL Sections 3.9, 5.6, and Appendix A Section 3.9 Marking.
These ANSI N45.2.2 sections control direct. marking of austenitic stainless steel and nickel based alloys.
Marking is in compliance with the requirements of these sections except that markings may be directly applied using inks controlled so as not to contain more than 200 ppm of inorganic halogens.
DELETED REGULATORY GUIDE l.39:, Housekeeping Requirements for Water-Cooled Nuclear Power Plants (Revision 2, September 1977)
February 1984 1.8-25 Amendment 12
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RESPONSE
PVNGS CESAR CONFORl1ANCE TO NRC REGULATORY GUI KS The position of Regulatory Guide 1.121 is accepted.
REGULATORY GUIDE 1.123: Quality Assurance Reauirements for 4
Control of Procurement of Items and Services for Nuclear Power Plants (Revision 1, July 1977)
RESPONSE
REGULATORY 'GUIDE 1.124: Service Limits and Loading Combination" for Class 1 Linear-Type Component Supports (Revision 1, January 1978)
RESPONSE
The position of Regulatory Guide 1.124 is accepted for the BOP Bechtel scope.
Also refer to CESSAR Appendix A.
REGULATORY GUIDE 1.127: Inspection of Mater-Control Structures Associated with Nuclear Power Plants (Revision 1, March 1978)
RESPONSE
The position of Regulatory Guide 1.127 does not apply to PIGS.
REGULATORY GUIDE 1.130:
Design Limits and Loading Combinations for Class 1 Plate-and-Shell Type Component Supports (Revision 0, July 1977}
K-..endmer.t 4
1.8-
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INSERT III For operations phase activities, the position of Regulatory Guide 1.123 is accepted with the following modification to ANSI N45.2.13-1976:
Section 7.5, Personnel, Qualifications.
Personnel responsible for performing verification activities shall be qualified in accordance with ANSI N45.2.23,for program verification and ANSI N45.2.6 for material inspection.