ML17355A100

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CB&I Arey a MOX Services, Submittal of Amendment Number: MPQAP-2017-0001 of the MOX Project Quality Assurance Plan
ML17355A100
Person / Time
Site: 07003098
Issue date: 12/20/2017
From: Del Vecchio D
CB&I AREVA MOX Services
To:
Document Control Desk, Office of Nuclear Material Safety and Safeguards
References
DCS-NRC-000469, MPQAP-2017-0001
Download: ML17355A100 (27)
v • d • e


Text

~ A l AREVA L~

MOX SERV ICES, LLC Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Docket Number 0 70-03098 CB&I AREY A MOX Services Mixed Oxide Fuel Fabrication Facility DCS-NRC-000469 20 December 201 7 Submittal of Amendment Number: MPQAP-2017-0001 of the MOX Project Quality Assurance Plan CB&I AREVA MOX Services, LLC (MOX Services) hereby submits to the U.S. Nuclear Regulatory Commission (NRC) Amendment Number: MPQAP-2017-0001 of the MOX Project Quality Assurance Plan (MPQAP) (Enclosure 1) for review and approval. MPQAP-2017-0001 incorporates limited alternatives to portions ofNQA-1 Subpart 2.2 which provide MOX Services the option to perform evaluations to identify and implement the appropriate preventive maintenance requirements during construction. These alternative preventive maintenance requirements, in conjunction with component installation inspections, component IROFS functional testing and post system turnover maintenance and surveillance requirements provide reasonable assurance that IROFS components will be reliable and available upon demand to perform their credited IROFS function during operation. Similar alternatives to the NQA-1 preventive maintenance requirements have already been approved for use at several Part 50 reactor facilities. Additional supporting information is included in the justification within the Enclosure.

NRC review and approval of MPQAP-2017-0001 is requested by February 28, 2018 in order to support ongoing project activities.

If you have any questions, please feel free to contact me at (803) 442-6485 or Dealis Gwyn, Licensing and Nuclear Safety Manager at (803) 819-2780.

avid Del Vecchio President and Project Manager P.O. Box 7097, Aiken, SC 29804-7097/Savannah River Site, F-Area, Bldg. 706-5F, Aiken, SC 29808

DCS-NRC-000469 20 December 2017 Page 2 of 2

Enclosure:

MOX Project Quality Assurance Plan Amendment MPQAP-2017-0001 cc (w/encl):

David Tiktinsky, USNRC/HQ cc (w/o encl.):

Scott Cannon, NNSA/SRS Paul Carman, USNRC/RII Jason Eargle, USNRC/RII Michael Ernstes, USNRC/RII David Faubert, NNSA/SRS William Gloersen, USNRC/RII Mark Gober, MOX Services Dealis Gwyn, MOX Services Chip Hicks, MOX Services Dennis Ivey, MOX Services Charles Nickell, MOX Services Gilles Rousseau, MOX Services Kathryn Sutton, ML&B David Tiktinsky, USNRC/HQ Paul Whittingham, MOX Services Bryan Wilkes, MOX Services Lauren Wylie, MOX Services Doug Yates, MOX Services MOX Project Management Office Document Control Administrator (moxpmodca@srs.gov)

EDMS: Corresp\\\\Outgoing\\NRC\\2017 NRC

Enclosure MOX Project Quality Assurance Plan Amendment MPQAP-2017-0001

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Amendment No.: MPQAP-2017-0001 NRC Approval Required Approvals Director Project Assura Date: 2tJ /).!lo /?

Date:

2o)JEC IJ Current Wording:

Proposed Wording:

MPQAP Section 19.2.3 Preventive Maintenance MPQAP Section 19.2.3 Preventive Maintenance (third paragraph, last sentence)

(third paragraph, last sentence)

The rationale for deviations from industry standards The rationale for deviations from industry standards or vendor recommendations for PM shall be Sf-Vendor recommendations for PM shall be documented.

documented.

MPQAP ATIACHMENT A: COMMITMENT TO MPQAP ATIACHMENT A: COMMITMENT TO QUALITY ASSURANCE STANDARDS QUALITY ASSURANCE STANDARDS SUBPART 2.2 Quality Assurance Requirements for SUBPART 2.2 Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants Handling of Items for Nuclear Power Plants The MPQAP follows this Subpart during Construction The MPQAP follows this Subpart during Construction with the following alternatives:

with the following alternatives:

This Subpart is not applicable during Operations.

Page 1 of24 Amendment No. MPQAP-2017-0001

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 2 of 24 Amendment No. MPQAP-2017-0001 Section 4.5.2, Inspections at Point of Shipment and Section 4.5.3, Inspection at Port of Entry.

In the aftermath of the September 11, 2001 terrorist attacks, on board point of shipment and port of entry inspections are no longer allowed. To assure acceptable items are received, packaging inspections prior to shipment and at receipt of the item will be performed.

Section 4.5.2, Inspections at Point of Shipment and Section 4.5.3, Inspection at Port of Entry.

In the aftermath of the September 11, 2001 terrorist attacks, on board point of shipment and port of entry inspections are no longer allowed. To assure acceptable items are received, packaging inspections prior to shipment and/or at receipt of the item will be performed.

{Editorial note: New text to be inserted}

Section 6.4.2, Subparagraph (h): MOX Project will follow either vendor recommendations for preventive maintenance, an engineering evaluation, or engineering requirements documents delineating appropriate maintenance requirements, for items in storage. Engineering evaluations and engineering requirements documents will consider vendor recommendations.

Section 6.5 (last sentence): During a period of layup after release of an item from storage, vendor recommendations for preventive maintenance, or an engineering evaluation or an engineering

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 3 of 24 Amendment No. MPQAP-2017-0001 requirements document delineating appropriate maintenance requirements will be followed.

Engineering evaluations and engineering requirements documents will consider vendor recommendations.

SUBPART 2.18 Quality Assurance Requirements for Maintenance of Nuclear Facilities This Subpart does not apply during the construction phase.

SUBPART 2.18 Quality Assurance Requirements for Maintenance of Nuclear Facilities This Subpart does not apply during the construction phase.

{Editorial note: New text to be inserted}

Section 3.2.1(second sentence): During a period of layup after release of an item from storage, vendor recommendations for preventive maintenance, or an engineering evaluation or an engineering requirements document delineating appropriate maintenance requirements will be followed.

Engineering evaluations and engineering requirements documents will consider vendor recommendations.

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 4 of 24 Amendment No. MPQAP-2017-0001 Justification:

Summary of Changes The changes contained in amendment MPQAP-2017-001 are summarized below:

(1) In MPQAP Section 19.2.3, clarified that deviations from vendor recommendations for preventive maintenance (PM) will be documented.

(2) Delete the caveat concerning the applicability of the commitment to NQA-1 Subpart 2.2 during Operations, clarify when receipt inspections may be performed, and add alternative language for Sections 6.4.2(h) and 6.5.

a. Deleted caveat related to applicability during operations and changed and to and/or in the phrase prior to shipment and/or at receipt.
b. Added Section 6.4.2, Subparagraph (h): MOX Project will follow either vendor recommendations for preventive maintenance, an engineering evaluation, or engineering requirements documents delineating appropriate maintenance requirements, for items in storage. Engineering evaluations and engineering requirements documents will consider vendor recommendations.
c. Section 6.5 (last sentence): During a period of layup after release of an item from storage, vendor recommendations for preventive maintenance, or an engineering evaluation or an engineering requirements document delineating appropriate maintenance requirements will be followed. Engineering evaluations and engineering requirements documents will consider vendor recommendations.

(3) Subpart 2.18: added alternative language for Section 3.2.1 (second sentence).

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 5 of 24 Amendment No. MPQAP-2017-0001

a. Section 3.2.1 (second sentence): During a period of layup after release of an item from storage, vendor recommendations for preventive maintenance, or an engineering evaluation or an engineering requirements document delineating appropriate maintenance requirements will be followed. Engineering evaluations and engineering requirements documents will consider vendor recommendations.

Justification of the changes is provided in the following sections.

Item 1 - MPQAP 19.2.3 Clarification Clarification that deviations from vendor recommendations for preventive maintenance (PM) will be documented aligns MPQAP 19.2.3 with the proposed change to the commitment to the second sentence in NQA-1, Subpart 2.18, Section 3.2.1. Since change is made to be consistent with the source requirement (NQA-1, Subpart 2.18), this change is a clarification and does not result in any reduction of commitments.

Item 2(a) NQA-1 Subpart 2.2 Applicability and Receipt Inspection The caveat regarding applicability during operations was deleted for clarification. The deletion of the caveat does not result in the reduction of any commitments.

The and in the compliance statement for Subpart 2.2 is interpreted to mean, in general, inspections are performed both prior to shipment and at receipt, but not necessarily at both locations for all SSC. The addition of and/or provides more clarity to the location of the performance of the receipt inspections is optional but does not result in the reduction of any commitments.

Items 2(b) and (c) NQA-1 Subpart 2.2 Sections 6.4.2 and 6.5 Alternatives

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 6 of 24 Amendment No. MPQAP-2017-0001 The alternatives to NQA-1 Subpart 2.2 Section 6.4.2 and 6.5 provide MOX Services the flexibility to identify and implement the appropriate preventive maintenance requirements during the construction phase of the project considering engineering requirements documents, engineering evaluations and vendor recommendations.

While economic factors can be a consideration in developing these requirements, the established PM requirements, in conjunction with previously established management measures, will ensure that that IROFS reliability and availability is maintained. The evaluations may identify requirements to refurbish or replace some components prior to operations based on actual storage or installation life and selected PM requirements (i.e., if operations date exceeds time interval, it may be more efficient use of project resources to refurbish or replace an component when compared to PM costs of extended storage/installation). While PM requirements are an important factor in IROFS reliability and ability, they are only one aspect. Additional factors include:

Maintaining appropriate environmental conditions during storage Checks/inspections prior to component installation Checks/inspections prior to component testing Testing to demonstrate capability to perform IROFS safety function prior to system turnover to operations Periodic maintenance after installation after system turnover to operations Periodic surveillance testing to demonstrate IROFS safety function performance after system turnover to operations

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 7 of 24 Amendment No. MPQAP-2017-0001 These factors along with documented evaluations that establish the appropriate preventative maintenance requirements during construction provide reasonable assurance that IROFS components will be reliable and available upon demand to perform their credited IROFS function.

In addition, the MOX Services alternate approaches to NQA-1 Subpart 2.2 are consistent with established NRC precedence for reactors, which are also required to establish 10 CFR 50 Appendix B QA programs. Examples of similar approved alternative approaches are provided in Attachment 1. Cases where it could be clearly identified that the accepted alternative was applicable during the construction phase are identified. is not intended to be complete list nor is it intended to demonstrate all the facilities that used this option during construction (i.e., actual number of facilities that used the approved NQA-1 Subpart 2.2 may be larger than the table identifies). Attachment 1 demonstrates that the MOX Services alternate approach to a portion of NQA-1 Subpart 2.2 is similar to approaches previously accepted by the NRC. The common theme in that MOX Services reinforces with its amendment is a focus on commitments to perform documented engineering evaluations for preventive maintenance.

Preventive Maintenance Requirements Engineering requirements documents are the primary means of conveying preventive maintenance requirements. Engineering evaluations are performed, as required, based on the complexity and criticality of the structures, systems, and components in installed storage (storage) or extended layup (layup). Vendor recommendations for preventive maintenance, where applicable, are considered in the determination of engineering requirements for maintenance requirements.

During the construction phase, the project is determining layup and storage requirements to support IROFS reliability and availability while also considering the following:

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 8 of 24 Amendment No. MPQAP-2017-0001

a. Risk reduction (future limitation of cost due to repairs or replacement)
b. Property protection
c. Limiting conditions that cause equipment degradation As part of the process to transition to operations but prior to placing IROFS into service, MOX Services verifies that IROFS are capable of performing their credited safety function. This verification includes verification the IROFS have been installed in accordance with the design, IROFS will performed their safety function, preventive maintenance activities have been performed, and a preventive maintenance program has been established to support continued IROFS reliability. If there are IROFS components or parts of an IROFS, that have exceed their service life, the parts or components will be refurbished or replaced, as necessary, to support IROFS reliability and availability during operations.

Preventive maintenance programs address three aging categories Preventive maintenance programs have the goal of ensuring the reliability and readiness of the assemblies and components under their care when they called upon. Reliability is a term that applies to assemblies and components in service. Assemblies and components must be kept in a state that allows them to reliability perform when placed into service. Readiness is a term that applies to assemblies and components waiting to go into service. Readiness is the capability of assemblies and components to go from an inactive out-of-service state to an active in-service state. Categorizing preventive maintenance by aging mechanism is one way that preventive maintenance programs effective manage the care of complex assemblies and components to ensure their reliability and readiness.

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 9 of 24 Amendment No. MPQAP-2017-0001 Complex assemblies comprise a multitude of different components. Each assembly and each component within the assembly is subject to different aging mechanisms that determine whether the assembly falls under one of the following three aging categories:

a. Infinite lifetime (i.e., no apparent aging effects)
b. Finite lifetime with periodic renewal (i.e., preventive maintenance)
c. Finite lifetime with no effective renewal process (i.e., replacement is required)

Preventive maintenance programs use engineering evaluations to determine the appropriate preventive maintenance requirements for assemblies and components. Engineering evaluations are used to identify the applicable aging mechanisms and to categorize assemblies and components into bins. The engineering evaluations provide the means to effectively target preventive maintenance where such maintenance assures the continued reliability and readiness of the assemblies and components.

Some assemblies and components are best kept dry, clean, sealed up, and periodically monitored for signs of deterioration. The hands-off approach precludes inadvertent degradation of components that have an infinite life except through wear by excessive manipulation, e.g., O-ring seals on access covers.

Some assemblies and components require periodic preventive maintenance. These assemblies and components may contain pieces that have finite lifetimes and require periodic renewal, e.g., batteries, lubricants.

Some assemblies and components may just age and require replacement, e.g., electrolytic capacitors.

Preventive maintenance on components with finite lifetimes would be ineffectual.

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 10 of 24 Amendment No. MPQAP-2017-0001 Thus, the proposed change strengthens the effectiveness of the preventive maintenance to be performed by committing to documented engineering evaluations that evaluates and determines effective preventive maintenance requirements for the assemblies and components. The proposed change does not reduce the commitment to perform preventive maintenance. The commitment to documented engineering evaluations assures long term reliability of the assemblies and components by ensuring preventive maintenance is effectively targeted.

Common cause failures caused by not following vendor recommendations Complex assemblies and components may have specific vendor recommendations for preventive maintenance that may be considered excessive during layup and storage. If these preventive maintenance activities are not performed the potential to have reliability issues in the future may exist, but these reliability issues are not certain. Startup testing is performed to ensure systems, structures, and components perform as specified. If issues are found during startup testing the systems, structures, and components are repaired, retested, and if they pass, then placed into service. At no time are systems, structures, and components allowed to be placed into service without assurance that they will perform as expected. These issues are specific to each assembly and component and should not be considered common to all assemblies and components.

The converse situation is also not a certainty. Guarantees of performance could not be given to systems, structures, and components, even if all of the vendor recommended preventive maintenance activities were performed. Preventive maintenance activities by their nature may be a cause of inadvertent damage to the component or to adjacent or related assemblies and components not undergoing the preventive maintenance activity. In order to preclude future reliability conditions, things like access covers have to be removed and replaced without damage. Adjacent components have to be disassembled and reinstalled to allow access to the components being maintained and to restore the assembly to whole. Errors performed in the disassembly

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 11 of 24 Amendment No. MPQAP-2017-0001 and the reassembly are points in the process where the act of providing preventive maintenance could be detrimental and the lack of preventive maintenance beneficial. It is clear that balancing preventive maintenance requirements ensures long term reliability and readiness of the assemblies and components.

Layup and storage requirements differ from operating requirements Preventive maintenance requirements are determined by engineering as part of the determination of layup and storage requirements. Periodic inspections and lubrication of components requiring lubrication are performed in accordance with a desktop procedure for preventive maintenance of equipment oil/grease reservoirs, which is based on successful practices from the reference facility, for example. These practices, by necessity, consider but may not follow vendor recommendations because of the unique process and nuclear safety requirements imposed by the design. Lubricating materials may differ from specified materials during layup and storage as a result of the nature of the equipment in a dormant state and the cost of the material.

During layup and storage some lubricating materials are known to be deliquescent and/or become gummy and rust promoting when left in a static condition in the humid atmospheric conditions at the site. Adherence to vendor recommendations in these instances could cause more harm and are best avoided. This strategy relies on final inspections and tests that are performed as part of commissioning to verify performance of the structures, systems, and components prior to turnover to Operations and startup. Material will be refurbished and/or replaced as required at that time.

Inconsistencies in vendor recommendations for similar equipment Vendor recommendations for preventive maintenance intervals and preventive maintenance actions varies with each product and each vendor. Variations in requirements are found between products offered by a single vendor and across multiple vendors that offer similar products, such as, manually operated ball valves.

For example, ball valve Vendor A makes no recommendations for long term storage of their product, while ball

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 12 of 24 Amendment No. MPQAP-2017-0001 valve Vendor B recommends multiple full stroke actuations every x months. The safety function of these ball valves is to maintain the confinement barrier, i.e., not leak. None of the valves have a safety function associated with actuation. Engineering makes the decision regarding which requirement is appropriate for the valves. If maintaining the valves in the equivalent of their new in box state is deemed more appropriate for maintaining the safety function, then periodic actuation of some of the valves to maintain an operability function becomes less of a priority.

Safety Significance of preventive maintenance during Construction The project is in Construction. Construction means the availability of alternative maintenance mechanisms that would not be optional when equipment is contaminated. Construction also means utility systems that are designed to have certain performance envelopes during Operations may not have the same characteristics during Construction because of temporary construction needs. These performance criteria include electrical power supplies, which may be negatively affected by heavy construction users, e.g., noise introduced by welding machines. Structures, systems, and components are not energized, have not been turned over to operations, and no special nuclear material is in the plant. Unlike structures, systems, and components in an operating facility, structures, systems, and components in Construction are not capable of nor will they be required to replace operating engineered safety features to prevent or mitigate any event sequences. The capability of the structures, systems, and components to prevent or mitigate event sequences will be demonstrated during cold startup testing but prior to turnover to operations. At which time, items requiring replacement will be replaced as required to ensure the performance during operations, including the performance of safety functions. For the long term reliability and readiness of the assemblies and components the preventive maintenance program needs to take into account the project phase.

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 13 of 24 Amendment No. MPQAP-2017-0001 Summary While efficient use of project resources is a consideration in establishing preventive maintenance requirements, the MOX Services alternatives to portions of NQA-1 Subpart 2.2 continue to provide reasonable assurance that IROFS will be reliable and available during operations and is consistent with previously NRC approved alternatives for nuclear facilities during construction and operation. Preventive maintenance requirements are one factor supporting IROFS reliability and availability; additional factors include maintaining appropriate layup and storage environment, testing that demonstrates performance of IROFS safety functions prior to operations and preventive maintenance activities and surveillances demonstrating IROFS operability during operations.

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 14 of 24 Amendment No. MPQAP-2017-0001.

Approved Alternative Commitments to RG 1.38, ASME N45.2.2, and NQA-1 Subpart 2.2 Nuclear Power Plant Approved Alternatives to Subpart 2.2 TVA Bellefonte Unit 1* and Unit 2*

TVA Watts Bar Unit 1* and Unit 2*

(ML082320585, ML082700335, ML082700355, and ML082700354)

Appendix B NRC Regulatory Guide 1.38 alternatives:

7. Section 6.4.2(8) -TVA will follow vendor recommendations/ requirements for preventive maintenance, or provide an engineering evaluation or engineering requirements document delineating appropriate maintenance requirements, for items in storage. Engineering evaluations and engineering requirement documents will consider vendor recommendations/requirements.

Duke Energy Levy Unit 1* and Unit 2*

Duke Energy William States Lee Unit 1* and Unit 2*

Duke Energy Shearon Harris Unit 2* and Unit 3*

(ML17048A455)

Subpart 2.2, Section 2.2 establishes criteria for classifying items into protection levels. Instead of classifying items into protection levels during the operational phase, Duke Energy Corporation may establish controls for the packaging, shipping, handling, and storage of such items on a case-by-case basis with due regard for the item's complexity, use, and sensitivity to damage. Prior to installation or use, the items are inspected and serviced as necessary to

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 15 of 24 Amendment No. MPQAP-2017-0001 assure that no damage or deterioration exists which could affect their function.

Nebraska Public Power District Cooper Station (ML052300062)

13. ANSI N45.2.2 Section 6.4.2 Care of items in storage shall be exercised in accordance with the following: "Types of components that could require maintenance while in storage shall be identified and evaluated for specific maintenance requirements. Maintenance activities 6.4.2 (6) through 6.4.2 (8) listed in this requirement shall be considered during this evaluation and any deviations shall be justified and documented."
14. ANSI N45.2.2 Section 6.5 The last sentence of this section is not applicable to the operations phase.

Entergy Vermont Yankee Nuclear Power Station (ML16035A506)

13. ANSI N45.2.2 Section 6.4.2 Care of items in storage shall be exercised in accordance with the following: Types of components that could require maintenance while in storage shall be identified and evaluated for specific maintenance requirements. Maintenance activities

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 16 of 24 Amendment No. MPQAP-2017-0001 6.4.2 (6) through 6.4.2 (8) listed in this requirement shall be considered during this evaluation and any deviations shall be justified and documented.

14. ANSI N45.2.2 Section 6.5 The last sentence of this section is not applicable to the operations phase.

NextEra (Florida Power & Light)

St Lucie Unit 1 and Unit 2 Turkey Point Unit 3 and Unit 4 NextEra Seabrook Station NextEra Duane Arnold Energy Center NextEra Point Beach Unit 1 and Unit 2 (ML17181A175)

Subpart 2.2, Section 6.4.2 states that care of items in storage shall be exercised in accordance with the following: (h) Other maintenance requirements specified by the manufacturer's instructions shall be performed. Exception is taken to the wording of Section 6.4.2 (h) and an alternate requirement substituted that "Care of items in storage shall be exercised in accordance with the following: Types of components that could require maintenance while in storage shall be identified and evaluated for specific maintenance requirements. Maintenance activities in Section 6.4.2 (h), listed in this requirement shall be considered during this evaluation and any deviations shall be documented."

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 17 of 24 Amendment No. MPQAP-2017-0001 Dominion Kewaunee Power Station Dominion Millstone Power Station Dominion North Anna Power Station Unit 1 and Unit 2 Dominion Surry Power Station (ML14188B134)

Regarding maintenance of items in storage in accordance with subsection 6.4.2, "Care of Items":

the requirement of item (f) will not apply to rotating electrical equipment less than 50 HP, the requirement of item (g) will not apply to rotating equipment weighing less than 50 pounds, the requirements of (e), (f), and (g) may be exempted for specific items on a case-by-case basis provided that a documented engineering evaluation determines that such care is not required.

Duke Energy Brunswick Unit 1 and Unit 2 (ML16019A031)

4. Paragraph 6.4.2, Care of Items: The following alternates are provided for indicated subparts:
a. Space heaters in electrical equipment shall be energized unless a documented engineering evaluation determines that such space heaters are not required.
b. Rotating electrical equipment, commensurate to safety or reliability, shall be given insulation resistance tests on a schedule basis, unless a documented evaluation determines that such tests are not required.

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 18 of 24 Amendment No. MPQAP-2017-0001

c. Rotating equipment, commensurate to safety or reliability, shall be evaluated for shaft rotation requirements. The degree of turn shall be established so that the parts receive a coating of lubrication where applicable, and so that the shaft does not come to rest in a previous position. (90 deg. and 450 deg. rotations are examples.)
d. Other maintenance requirements specified by the manufacturers instructions shall be evaluated to determine applicability during storage of the item.

Duke Energy Shearon Harris Unit 1 (ML16019A031)

22. Paragraph 6.4.2, Care Of Items: The following alternates are provided for indicated subparts:

(5) "Space heaters in electrical equipment shall be energized unless a documented engineering evaluation determines that such space heaters are not required."

(6) "Large (greater than or equal to 50 hp) rotating electrical equipment shall be given insulation resistance tests on a scheduled basis unless a documented engineering evaluation determines that such tests are not required."

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 19 of 24 Amendment No. MPQAP-2017-0001 (7) "Prior to being placed in storage, rotating equipment weighing over approximately 50 pounds shall be evaluated by engineering personnel to determine if shaft rotation in storage is required; the results of the evaluation shall be documented. If rotation is required, it shall be performed at specified intervals, and documented. Parts will receive a coating of lubrication where applicable, so that the shaft does not come to rest in the same position occupied prior to rotation. For long shafts or heavy equipment subject to undesirable bowing, shaft orientation after rotation shall be specified and obtained."

(8) Other maintenance requirements specified by the manufacturer's instructions shall be evaluated by responsible plant personnel to determine applicability during storage of the item.

23. Paragraph 6.5, Removal Of Items From Storage:

HNP does not consider the last sentence of this paragraph to be applicable to the operations phase due to the relatively short period of time between installation and use. The first sentence of the

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 20 of 24 Amendment No. MPQAP-2017-0001 paragraph is replaced with: "HNP will develop, issue, and implement a procedure(s) which cover(s) the removal of items from storage. The procedure(s) will assure that the inspection status of all material issued is known, controlled, and appropriately dispositioned."

When items are released and waiting at a location prior to installation, responsible plant management in accordance with plant procedures will determine and document the extent of inspection and storage requirements.

Duke Energy H.B. Robinson Unit 2 (ML16019A031) e) Section 6.4.2 of ANSI N45.2.2 - 1972, titled Care, sub-items (5), (6), and (7) are clarified as follows:

1) Sub-item (5), space heaters in electrical equipment shall be energized, unless a documented engineering evaluation determines that such space heaters are not required.
2) Sub-item (6). large rotating electrical equipment (i.e. greater than or equal to 50 horsepower) shall be given insulation resistance tests on a scheduled basis,

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 21 of 24 Amendment No. MPQAP-2017-0001 unless a documented engineering evaluation determines such tests are not needed.

3) Sub-item (7). prior to being placed in storage, rotating equipment weighing over approximately 50 lbs. shall be evaluated and documented by engineering personnel to determine if shaft rotation during storage is required. If rotation is required the degree of turn shall be such that the parts receive lubrication where applicable and the shaft does not come to rest in a previous position. Required rotation shall be performed at the necessary intervals and documented.

AmerenUE Callaway Nuclear Plant (ML16321A394) 13.3 Applicable manufacturer instructions and recommendations, or procurement requirements shall be reviewed and invoked in governing procedures when determined appropriate based on an engineering review. Deviations which relax manufacturer's recommendations shall involve an engineering evaluation. This may be appropriate when unrealistic requirements are recommended

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 22 of 24 Amendment No. MPQAP-2017-0001 and such recommendations are not reasonably necessary to preclude equipment degradation.

With regard to Section 6.4.2 of ANSI N45.2.2 - 1972 titled Care of Items: The following alternates are provided for the indicated subparts:

(5) "Space heaters in electrical equipment shall be energized unless a documented engineering evaluation determines that such space heaters are not required."

(6) "Large (greater than or equal to 50 HP) rotating electrical equipment shall be given insulation resistance tests on a scheduled basis unless a documented engineering evaluation determines that such tests are not required."

(7) "Prior to being placed in storage, large (greater than or equal to 50 HP or when designed to be used with a prime mover of greater than or equal to 50 HP) horizontal rotating equipment shall be evaluated by engineering to determine if shaft rotation in storage is required: the results of the evaluation shall be documented. If rotation is required, it shall be

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 23 of 24 Amendment No. MPQAP-2017-0001 performed at specified intervals, be documented, and be conducted so that parts receive a coating of lubrication where applicable and so that the shaft does not come to rest in the same position occupied prior to rotation. For long shafts or heavy equipment subject to undesirable bowing, shaft orientation after rotation shall be specified and obtained."

(8) Maintenance requirements specified by the manufacturer's instructions are addressed in this OQAM, Section 13.3.

With regard to Section 6.5 of ANSI N45.2.2 - 1972 titled Removal of Items from Storage: Ameren Missouri does not consider the last sentence of this Section to be applicable to the Operating Phase due to the relatively short period of time between installation and use. The first sentence of the Section is replaced with:

Ameren Missouri shall develop, issue, and implement a procedure(s) which cover(s) the removal of items from storage. The procedure(s)

MOX Project Quality Assurance Plan (MPQAP)

AMENDMENT Docket No. 070-03098 Page 24 of 24 Amendment No. MPQAP-2017-0001 shall assure that the status of material issued is known, controlled, and appropriately dispositioned."

  • Applicable during Construction
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