ML18114A637

Discusses 770110 Rept QA Program,Operations Phase. Requests Exception from ANSI N45.2.4 & N45.2.8 Paragraphs Re Calibr Control & Equipment Test.Discusses Proposed Alternative

ML18114A637
Person / Time
Site:	Surry, North Anna
Issue date:	05/31/1979
From:	Baum E VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:	Haass W Office of Nuclear Reactor Regulation
References
417, NUDOCS 7906050323
Download: ML18114A637 (4)

Text

e VIRGINIA ELEOTRIO AND PoWER COMP.A.NY RIOHMOND,VIRGINJA 23261 May 31, 1979 Mr. W. P. Haass, Chief Serial No. 417 Quality Assurance Branch LQA/MDT:esh

• Division of Project Management Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555 RE: Docket Nos. 50-280, 50-281 50-338, 50-339 50-404, 50-405

Dear Mr. Haass:

Virginia Electric and Power Company 1 s letter Serial No. 411, dated January 10, 1977 submitted amendment three to our topical report entitled,*

11 Qua1 ity Assurance Program-Operations Phase 11 (VEP-1-lA) which was approved by Nuclear R_egulatory Commission letter dated February 22, 1977.

This letter is submitted to indicate exceptions to ANSI N45~2.,4 11 (nsta11ation, Inspection, and Testing Requirements of Instrumentation and Electrical Equipment During the Cons.truction (Operations) of Nuclear Power Generating Stations, and ANSI N45e2.8; "Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems: for the Construction (Operations) Phase.of Nuclear Power Plants,"

and to provide alternatives to the requirements therein.,

ANSI *N45.2~4..;1972, as referenced by Regulatory Guide*l.30, 8-11-72, to which. Vepco has committed, requires the folfowi_ng:

Paragraph 2.5.2, "Calibration Control," states in part

• 11 ** -~and equipment suitably marked to indicate date of next required calibration."

Paragraph 6.2.1, "Equipment Test;" states in part

• • ***~requiring calibration shal 1 be tagged or labeled on *completion indicating dat*e of calibration and identity of person that performed the calibration."

Additionally, ANSI N45.2.8, Draft 3,* Rev. 2,. Apri 11973, 11 Supplementary Quality Assurance Requirements for lnstal lation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction (Operation) Phase of Nuclear Power Plants, 11 to which Vepco has previously committed, requires the following:

Paragraph 2.8.2, Calibration Control," states in part

• ~ ** ~~~uipment suitably_marked so that calibration status can be determined

• 11 *

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• ' e e VIRGINIA ELECTRIC AND POWER COMPANY TO Mr. *W., P~ Haass 2 Vepco wishes to take exception to those portions of the paragraphs listed above and provide the following alternative:

The 11 Measuring*and Test Equipment Program" provides that items of mea*suring and test equipmen*t and reference standards shall be tagged or labeled indicating the date of calibration, ide~iity of person performini calibration and date of reca 1 i brat ion. These i terns a re* in a cal i bra-t ion program which requires recalibration on a specified frequency or in certain cases, prior to use.

The "Periodic Test Program" provides for instrumentation and electrical equipm.ent in the categories of (1) instru-ments installed as 1 isted in the T~chnical Specifications, (2) installed instrumentation used to verify Technical Specification parameters, and (3) installed safety-related instruments and electrical equipment that provide an active function during operation or during shutdown i.e., ,vice being designated safety related s~lely because the instrument is ~n int~gral part of a pressure retaining boundary, shall be in a calibration program. This program provides, by the use of equipment hist6ry data, statui, records, and perform-ance schedules, for the date that calibration is due and indicates the status of calibration. The identity of person(s) performing calibration is provided on the calibration documents.

These exceptions and alternatives provide the necessary controls to comply with 10 CFR 50, Appendix B, Criterion XII, "Control of Measuring and Test Equipment, 11 which requires these devices to be calibrated and adjusted at specified periods to maintain *accuracy within necessary limits, and Criterion XIV, "Inspec-tion, Test and Operating Status, 11 which states ** ~measures to be established which indicate by the use of markings such as stamps, tags,* Jabels, routing cards, or other suitable means the status of -inspections and test performed upon individual items of the nuclear power plant * .,."*

Commencing with the date of this letter, Vepco shall provide for the calibration of Measuring and Test Equipment as indicated in the alternatives pro-posed in this letter, ~nless otherwise notified.

Very truly yours, E. A. Baum, Executive Manager Licensini & Quality Assuiance cc: Mr. James P. 0 1 Rellly, Director Office of Inspection and Enforcement

~egion 11

. ,., e VIRGINIA ELECTRIC .A.ND PowBR COMP.ANY HIOHMOND, VIRGINIA 23261 May 31, 1979 Mr. W. P. Haass, Chief Serial No. 417 Quality Assurance Branch LQA/MDT:esh Division of Project Management Office of Nuclear Reactor Regulation U. S Nuclear Regulatory Commission 0

Washington, DC 20555 RE: Docket Nos. 50-280, 50-281 50-338, 50-339 50-404, 50-405

Dear Mro Haass:

Virginia Electric and Power Company 1 s letter Serial No. 411, dated January 10, 1977 submitted amendment three to our topical report entitled,*

11 Qual ity Assurance Program-Operations Phase 11 (VEP-1-lA) which was approved by Nuclear Regulatory Commission letter dated February 22, 1977.

This letter is submitted to indicate exceptions to ANSI N45.2.4 11 lnstallation, Inspection, and Testing Requirements of Instrumentation and Electrical Equipment During the Conitruction (Operations) of Nuclear Power Generating Stations, 11 and ANSI N45o2o8, 11 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems for the Construction (Operations) Phase of Nuclear Power Plants,"

and to provide alternatives to the requirements therein.

ANSI N45.2o4-1972, as referenced by Regulatory Guide 1.30, 8-11-72, to which. Vepco has committed, requires the folfowi_rig:

Paragraph 2.5.2, 11 Calibration Control," states in part 11

. . ~and equipment suitably marked to indicate date of next required cali'bration. 11 Paragraph 6.2.1, "Equipment Test;' states in part 11

• .'orequiring calibration shall be tagged or labeled on completion indicating date of calibration and identity of person that performed the cal ibration. 11 Additionally, ANSI N45.2.8, Draft 3, Rev. 2, April 1973, 11 Supplementary Quality Assurance Requirements for Installation, Inspection, and Testing of*

Mechanical Equipment and Systems for the Construction (Operation) Phase of Nuclear Power Plants;* to which Vepco has previously committed, requires the following:

Paragraph 2.8.2, 11 Calibration Control, 11 states in part 11 0 ** equipment suitably marked so that calibration status can be determined. 11

.. j. \

(_ ' .. e e VIRGINIA ELECTRIC AND POWER°COMPANY TO Mr. W.

• P. Haass 2 Vepco wishes to take exception to those portions of the paragraphs listed above and provide the following alternative:

The "Measuringand Test Equipment Program" provides that items of mea*suring and test equipmen*t and reference standards shall be tagged or labeled indicating the date of calibration, ide~iity of person performini calibration and date of recalibration. These items are in a calibra-tion program which requires recalibration on a specified frequency or in certain cases, prior to use~

The "Periodic Test Program" provides for instrumentation and electrical equipm~nt in the categories of (1) instru-ments installed as listed in the Technical Specifications, (2) installed instrumentation used to verify Technical Specification parameters, and (3) installed safety-related instruments and electrical equipment that provide an active function during operation or during shutdown i.e., ,vice being designated safety related s~lely because the instrument is ~n integral part of a pressure retaining boundary, shall be in a ialibration program. This program provides~ by the use of equipment history data, status, records, and perform-ance schedules, for the date that calibration is due and indicates the status of calibration. The identity of person(s) performing calibration is provided on the calibration documents.

These exceptions and alternatives provide the necessary controls to comply with 10 CFR 50, Appendix B, Criterion XI I, "Control of Measuring and Test Equipment," which requires these devices to be calibrated and adjusted at specified periods to maintain *accuracy within necessary limits, and Criterion XIV, Inspec-tion, Test and Operating Status," which states " ** ~measures to be established which indicate by the use of markings such as stamps, tags,*labels, routing cards, or other su1table means the status of inspections a~d test performed ~pan individual i terns of the nuclear power plant *** "

Commenci_ng with the date of this letter, Vepco shall provide for the calibration of Measuring and Test Equipment as indicated in the alternatives pro-posed in this letter, ~nless otherwise notified.

Very truly yours,

~-------=<..

E. A. Baum, Executive Manager Licensing & Quality Assuiance cc: Mr. James P. O'Reilly, Director Office of Inspection and Enforcement R_eg ion 11