ML19269E943
| ML19269E943 | |
| Person / Time | |
|---|---|
| Site: | New Haven |
| Issue date: | 05/18/1979 |
| From: | Parr O Office of Nuclear Reactor Regulation |
| To: | Kintigh A NEW YORK STATE ELECTRIC & GAS CORP. |
| References | |
| NUDOCS 7906290851 | |
| Download: ML19269E943 (18) | |
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Docket Nos. STN 50-596 MAY 181979 and STN 50-597 Mr. Allen E. Kintigh Vice President - Generation New York State Electric & Gas Corporation 4500 Vestal Parkway East Binghamton, New York 12902
Dear Mr. Kintigh:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION CONCERNING NEW HAVEN 1 & 2 As a result of our review of the New Haven 1 & 2 Preliminary Safety Analysis Report, we find that we need additional information to continue our evaluation.
The specific information requested in the Enclosure concerns the areas of structural engineering, meteorology, and quality assurance.
Our review schedule is based on the assumption that the additional information requested will be available for our review by July 13, 1979.
If you cannot meet this date, please inform us within seven days after receipt of this letter so that we may consider the need to revise our review schedule.
Please contact us you desire any discussion or clarification of the Enclosure.
Since rely,
a rDhief an Light Water Reactors Branch No. 3 Division of Project Management
Enclosure:
As Stated cc w/ enclosure:
See next page 2168 010
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,ooezeoscht
Mr. Allen E. Kin',igh % 18 B79 cc: Roderick Schutt, Esq.
Oswego County Farm Eureau Huber, Magill, Lawrence & Farrell c/o Ms. Nancy 1, 14 ber 99 Park Avenue RD #3 New York, New York 10016 Mexico, New York 133 14 Andrew W. Wofford, Vice President Paul Voninski, Ph.D.
Lern Island Lighting Company Vice President 175 ')1d Country Road Mexico Acaden:y and Hick sville, New York 11801 Central School Mexico, New York 13114 Edward M. Barrett, Esq.
General Counsel Mr. Peter C. G. Brown Long Island Lighting Company Chairman of the Scard 250 Old Country Road Mi d-Hud son f.uclear Cpponents, Inc.
Mi neola, NE., York 11501 P. O. Box 666 Ne w Pa l t z, flew Yo rk 12561 E. J. Walsh, Jr., Esq.
General Attorney Robert J. Ka fin, Esqui re Long Island Lighting Ccmpany Mi l l er, Manni x, Lemery 3 Ka fin,
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250 Old Country Road P. O. Box 765 Mineola, New York 11501 11 Chester Street Glens Falls, New York 12801 Ms. Anne F. Cu rt i n
- 9. 0. 1 William Kepping, Supervisor Box 82A40 Town of Gardiner Valatie, New York 12184 Gardiner, New York 12525 Stanley B. Klimberg, Esquire Cr. Stephen J. Egemeier Acting Counsel Chairman New York State Energy Office Environmental "anagement Council 2 Rockefeller Plaza 300 Flatbush Avenue Albany, New York 12223 Kirjgston, New York 12401 Ecology Action c/o Ms. Helen Daly W. River Rd. RD e5 Oswego, New York 13126 Safe Energy for f4w Haven c/o Ms. Linda Clark Box # 122 RD #1 Mexico, New York 13114 2168 01!
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ir 130.0 STRUCTURAL ENGINEERING BRANCH
-130.4 New Haven PSAR Section 3.3 1 states that "the east ban < of the (1.4.1) diverted stream... serves to keep the probable maximum flood water level in the stream diversion around the site".
Since Section 3.4.2 of the PSAR has been omitted, it is not clear that this stream bank has been designed for loads due to the static and dynamic effects of the flood. Discuss how the stream bank design incorporates the static and dynamic effects of the flood
.r-r such as delineated in the U.S. Army Costal Engineering 9esearch P"""
Center Technical Report No. 4, " Shore Protection Planning and Design", 1966 issue. Also, indicate the degree of ccmpacticn and provide a sketch of the cross secticn of the bank indicating the slope and any soecial materials usec.
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6 130.5 The justificaiton given for use of ductility factors greater (3.5.3) than 10 is not adequate. Provide a more detailed discuss of the it.
technical justification. Note that references dated 1961 have,in most cases, been factored into the current staff position limiting
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ductilities to less than or equal to 10.
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_ 2-130.6 The design of the ultimate heat sink is not within the
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scope of SWESSAR-Pl..Therefore, in addi tion to the._
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information provided in Section 9.2.5 of the New Haven PSAR, supply the following design information:
(1) Provide a discussion of the analysis procedure employed, the design criteria (including load combinations), and structural sketches of the cooling tower and pumphouse cross-sections, and (2) List the material strer.gths, fy and fc', and the cement admixtures.
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, HYDROLOGY-METEOROLOGY BRANCH - METEOROLOGY $rCTION 372.16 Provide a copy of the Golde reference Protection of Structures (2. 3.1 )
against Lightning," 1978.
372.17 The tornado swath areas in Table 2.3-151 do not agree with the (2. 3.1 )
path lengths and path widths which they are computed from. Provide the corrected swath areas for Table 2.3-151.
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421.0 Quality Assurance Branch - Quality Assurance Section 421.5 Section 17.1.2 should reference Res !sion C instead of (17.1.2)
Revision B of SWSQAP-1-74A.
421.6 Provide a commitment that the development, control, and (17.1.1.2) use of computer code programs will be conducted in accordance with the QA program, and describe how the QA program will be applied.
421.7 List the expendable and consumable items covered by the QA (17.1.1. 2 )
program. Describe the measures which will be taken tc assure the quality of these items that ara required for the proper performance of safety-related structures, systems, and components.
(Examples of such items are weld rods, tendon grouting and grease, hydraulic snubber oil, diesel generator oil and fuel, and boric acid.) Also include in your description the measures which will be taken to:
(1) identify those individuals authorized to approve changes to the list, and (2) control the distribution of changes to the list.
421.8 Describe NYSE&G's QA program for fire protection.
The quality (17.1.1. 2 )
assurance program for fire protection should be under the management control of the quality assurance organization.
This control consists of (1) formulating or verifying a fire protection quality assurance program that incorporates suitable requirements and is acceptable to management responsible for fire protection, and (2) verifying the effectiveness of the quality assurance program for fire protection through review, surveillance, and audit.
Clarify that the quality assurance program for fire protection is under the management control of the Manager, QA, or provide an alternative position for che staff's evaluation. 21-8 provides supplemental guidance on qualtiy assurance for fire protection. Modify your PSAR so that it is responsive to this supplemental guidance or provide an alternative for the staff's evaluation. Note that if the fire protection quality assurance program criteria are met as part of the quality assurance program under 10 CFR Part 50 Appendix B (PSAR Chapter 17), it is not necessary to submit a detailed description for NRC review.
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. 421.9 Ccscribe those provisions established to assure that procen.
(17.1.l.25) required a impicment th? QA program a re cons is ten ; wi n QA program cc:aailments and corporate policies and are pic," ly 6
documented, controlled, and made undatory through a Nlicy statement or equivalent document signed by the responsible of ficial.
421.10 Provide a commitment that the procedural controls of NYSE&G's (17.1.1.25) principal contractors will provide for NYS~&C's review and documented agreement of acceptance of a QA program prior to the initiation of activities affected by the program.
421.11 Provide a conmitment that procrammatic chances to the
( 17'. l.1. 2 )
"NYSE&G quality assurance program description (SAR Sections
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17.1.1 end i 7.2) will be submi tteo to the NRC for review r.--
prior to implementation and that organizational changes will be submittcd no later than 30 days af ter announce:.unt.
(No te: editorial changes or personnel reassignmnts of a non-substantive nature do not require NRC notification.)
421.12 Uoda'.e Table 17.1-1 to ad fress Regulatory Guide 1.23, Rev.1, (Table 17.1-1) dated 3/73.
421.13 Section 17.1.1.1.1 of the PSAR is not complete.
Provide a P="r (17.1.1.1.1) description of how management (above or outside the QA organization) regularly assesses the scope, status, adeaucy, and compliance of the QA program to 10 CFR 50 Appendix 3.
These measures should include:
(1) Frequent contact with program status through reports, meetings, and/or audits, and (2) Pe formance of an annual assessment which is preplanned and documented. Any corrective action should be identified and tracked.
jy; W-421.14 Section 17.1.1.2.6 is not complete.
Describe the provisions h?/
(17.1, which assure that approved procedures and trained personnel are G
17.1.1.2.6) available to implement the applicable portion of the QA program
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prior to the initiation of the activity.
421.15 Provide a commitment that records of formal indoctrination l~
(17.1.1. 2. 6 )
and training will be maintained and will show the objective and content of each session, attendees, and date of attendance.
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. r' 4P.1.16 Provide a commitment that the scope of the design control
( 17.1.1. 3 )
program implemented by each of NYSE&G's major contractors will include: (1) field design engineering, (2) SAR accident analysis, (3) associated computer programs, (4) compatibility of materials, (5) accessibility for inservice inspection, i-maintenance, and repairs, and (6) cuality standards.
421.17 Describe NYSELG's ro'e in assuring that errors and deficiencies (17.1.1. 3) in approved design docurrents, including design mei. hods (such as computer codes), :. hat could adversely aficct s tructures, systems, and components important to safety are docca.cnted and that action is taken to assure that all errors and deficiencies are corrected.
421.18 Describe NYSF&G's role in assuring that deviations from (17.1.1. 3) specified qnlit: standards are identified and that procedures are established to ensure their control.
421.19 Describe how NYSE&G assures that internal and external design
( 17.1.1. 3 )
interface centrols, procedures, and lines of communication among participa ting design organizations and across technical
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disciplines are established and described for the review, approval, release, distribution, and revision of documents involving design interfaces.
421.20 Describe N"SE&G's role in assuring uhat guidelines or criteria
( 17.1.1. 3 )
are establish d 2nd described for detarmining the method of design verification (design review, al ternate calculations, or test).
421.21 Cescribe the roles of NYSEo, S&W, and CE with respect to
( 17.1.1. 3) the following design verification positions:
(1) Procedures must be established, described, and irplemented for design verification activities which assure the a,
following:
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(a) The verifier is qualified and is not directly respon-D..
sible for the design (i.e., neither the periurmer or his imrediate supervisor).
In exceptienal circumstances, the designer's immediate supervisor can perform the verification provided:
(i) The supervisor is the only technically qualified individual; (ii) The need is individually docurcntea and a mroved in advance by the supervisor's managment; and (iii) QA audits cover frequency and effec tiveness of use of supervisors as design verifiers to guard against abuse.
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~".7 testing of a prototype or lead production unit, is completed prior to release for procurcuent, manu-facturing, construction or to anc ther organization p
' i for use in other design activities.
In those cases
[i where this timing cannot be met, the design verifi-cation may be deferred, providing that the justifica-g tion for this action is docou,ented and the unverified
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portion of the design cui.put docucant and all design output documents, based on t.ie unverified data, are 9 'g"-
appropria tely identified and centrolled.
Cons truc tion site ac tivities associated with a design or design t
change should not proceed without verification past
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the point where the installation..culd become irre-versible (i.e., require extensive demolition and rework).
In all cases, the design verification should b-e be complete prior to fuel lead.
(c) Procedural control is established for design docuwnts
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that reflect the commitments of the PSAR; this con-trol differentiates between docu; rents that racaive formal design verification by interdisciplinary or j
multiorganizational teams and those unich can be reviewed by a single individual (a signature and c
date is acceptable documentaticn for scesonnel F
certification).
Dasign docua.cnts subject to prace-dural control include, but are not limited to:
., _ J specifications, calculations, coquter pregems, system descriptions, SAR when used as a design
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document, and drawings (including flow diagrms, piping and instru: rent diagrams, centrol logic dia-4 grams, electrical sin 9 e line diagrams, structural l
systems for major facilities, site arrangements, and equipment locations). Specialized reviews should be used when uniqueness or special design considera-tions warrant.
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'(d) The responsibilities of the verifier, de areas and ry Ed features to be verified, the pertinent censidcraticns c%4 to be verified, and the extent of docurentation are W-identified in procedures.
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(2)
The following provisions must be included if the verification
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,c method is only by test:
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-(a) Procedures provide criteria that specify.. hen verification should be by test; Ye 91
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Prototype, cc:apon 2nt, or fea ture tes ting is perfor.c.ed as early as possible prior te installation of olant equipoent, or prior to the point ' hen the~in3 tall: Lion would become irreversible.
(c)
Verification by test is performed ':nder c:nditions that simulate the most adverse design conditions as determined by analysis.
(3) Procedures must be established to assure that verified computer codes are certified for use and that their use is specified.
,7 421.22 Describe NYSE&G's role in assuring that design and specification (17.1.1. 3 )
changes, including fields changcs, are subject to the sne design controls that were applicable to the original design.
421.23 The penultimate sentence in Section 17.1.1.3.4 states:
"'N re (17.1.1. 3. 4 )
standard designs are applied and no change to standard design documents is required for NYSE3G i and 2, design verification is not mandatory."
This is unacceptable.
Eliminate this sentence or revise it such that it indicates that NYSE&G does not necessarily verify standard designs since these designs have already underqone design verificaticn in acccedance 6-with Regulatory Guide 1.64, Revision 2.
421.24 Provide a commitment that procedures will be established to assure that (17.1.1. 5 )
instructions, procedures, and drawings incluJe qu:ntiLativo (such as dimensions, tolerances, and operating limits) :nd qualitative (such as workmanship samples) acceptance criteria
.~or determining that important activities have been satisfac-torily accomplished.
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421.25 Provide a commitment that the scope of the document control K-(17.1.1. 6.1 )
program will provide for:
FC (1) Calculations, drawings, speci ficatiens, and analyses b
(including documents related to computer codes),
(2) As-built drawings i (3) Topical reports; and
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(4) Nonconformance reports.
421.26 Provide a commitment that procedures will be established to (17.1.1.6.1) assure that obsolete or superseded documents are removed and replaced by app'icable revisions in work areas in a timely manner.
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421.27 Provide a commitment that inspection procedures, instructions, (17.1.1.10.1) and checklists will provide for the following: --
(1) Identification of required procedures, drawings, specifications and revisions.
(2) Recording the identification of the inspector or data recorder and the results of the inspection operation.
(3) Specifying necesury measuring and test equipment, including accuracy requirements.
421.28 Sections 17.1.1.10.1 and 17.1.1.11.1 are incomplete.
(17.1.1.10)
Provide a more detailed description of NYSE&G's role in evaluating inspection and test results and their acceptability.
421.29 Describe how NYSE&G determines the validity of certificates
( 17.1.1. 7.1 )
of conformance.
(17.1.1.15) 421.30 Provide a commitment that inspection and test records will (17.1.1.17.1) contain the following information:
(1) A description of the type of observation; (2) The date and results of the inspection or test; (3) Information related to conditions adverse to quality; (4) Inspectcr or data recorder identification; (5) Evidence as to the acceptability of the results; and (6) Action taken to resolve any discrepancies noted.
421.31 Provide a commitment that NYSE&G will prepare an audit plan (1
1.1.18.1) which identifies audits to be performed, their frequencies, and schedules.
Audits will be regularly scheduled, based upon the status and safety imcortance of the activities being performed, and initiated early enough to assure effective QA during design, procurement, manufacturing, construction, installation, inspection, and testing.
421.32 Provide a corrc1itment that provisions will be established which (17.1.1.18.1) require audits to be performed in all areas where the requirements of Appendix B to 10 CFR Part 50 are applicable.
Areas which are often neglected but should be included are activities associated with:
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(1)
The determination of si te features '..hich af fect ;)lant safety te.g., core sarpling, si te and foundation preparation, and raethodology ;
(2)
The preparation, review, approval, and control of early procurements ;
(3)
Indoctrination and training programs; (4)
Interface control among the applicant and the principal
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contractors; (5) Corrective action, calibration, and noncenfor..:ance control systems; and (6) PSAR commitments.
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,UALITY ASSURANCE ATTACHMENT 421_d Q
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The quality assurance (QA) program should assure that the r2cuire ents for design, procuremeat, installation, testing, and administrative controls for the fire protection progetm for safety rela >d areas approved by NRC are satisfied.
The Quality Assurance pr:visicas for fire protection should apply to activities performed af ter the ef fective date of the adcation of said previsiens.
The GA progrte, should be under the r.anagement control of the QA organization.
This control consists of
('l) formulating and/or.erifying that the fire protectica CA program incorscrates suitable recuirements and is acceptatie to the arage7.ent res;cosible for fire protection and (2) verifying the ef fectiv? ness of the QA program for fire protection thr ugh review, su veillince, 3rd audits.
Performance of other QA program functions for.neeting the fire s
protection pregram requirements may be perferced by pers:nnel cutsid cf the QA organization.
The CA program for fire protectica s5culd be. part of the everall plant CA pr: gram.
These QA criteria ipply to these iters within the scope of the fire protectica pr: grim, such as fire protection systems, emergency; lighting, communication and emergency breathing acparatus as well as the fire protection requirements of a;plicable safety related equipment.
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9 Applicants,' licensees can meet the fire protect.ico cuality usurince (CA) program criteria of Appendix A to BiP 9.5-1 or Recula tdry Gaide 1.120 by either:
1) implementing these fire protection QA criteria as part of their QA
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program under 10 CFR Part 50 Appendix 3, where such a croitment is made, it is not necessary to submit a detailed description of the fire protection CA program or its implementaticn for.'RC revies; or q
- 2) providing for NRC review a description of the fire pr:tection QA
$by program and the measures for implementing the procram.
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guidance is provided belcw on acceptable measures f ar. cpicm:n ting i(
each of the fire protectien~Q.1 program criteria of Appendix A to i
BT? 9.5-1 or Regula tory Guide 1.120.
ff 1.0 Cesign Control and Procurem2nt Document Control "aasures shculd i
be established to assure tha t the applicable guidelines of the Regulatory Guide 1.120 cr approved NRC alternatives are.ncluded in design and procurement documents and tha t deviaticos therefrca are
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cen trol led.
These it.easures should assure tha t:
v' Design and procurement document changes, including field ch nges a.
and design deviations are subject to the same level of c:ntrols, reviews, and approvals that were applicable to the original document.
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2 b.
Quality standards are specified in, the design documents such as appropriate fire protection codes and standards, and deviations and changes from these quality standards are controlled.
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New designs and plant modifications, including fire protection systems, are reviewed by qualified personnel to assure inclusion of appropriate fire protection requirements.
These reviews should include items such as:
(1) Design reviews to verify adequacy of wiring isolation and cable separation criterir.
(2)
Design reviews to verify appropriate requirements for room
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isolation (sealing penetrations, floors, and other fire ba rrie rs ).
d.
A review and concurrence of the adequacy of fi 2 pro tec ti on requirements and quality requirements stated in procurement docu'nents are performed and documented by qualified personnel.
This review should datermine that fire protection retuirements and quality reouirements are correctly stated, inspectable anc controllable; there are adequate acceptance and rejection P
critwia; and the procurement document has been. prepared, re-P viewec, and approved in accordance with QA program requirements.
2.0 Ins tructions, Procedures, and Drawing - Inspections, tes ts, acmin-istrative controls, fire drills, and training that govern the fire protection program should be prescribed by documented instructions, procecures or drawings and should be accomplisned in accordance wi ta these documents.
The following provisions should be included, a.
Indoctrination and training programs for fire prevention and fire fighting are implemented in accordance with documented
.N2 procedures.
k b.
Activities such as design, installation, inspection, test, k
maintenance, and modification of fire protection systems are prescribed and accomplished in accordance with cocumented in-p structions, procedures, and drawings.
c.
Instructions and procedures for design installa, tion, inspec-
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tion, test, maintenance, modification and administrative controls E--
are reviewed to assure that proper inclusion of fire protection b
requirements, sucn as precautions, control of ignition sources and combustibles, provisions for backup fire protection of tne c.
activity requires disabling a fire protection system, and re-striction on material substitution unless specifically pemitted by design and confimed by design review.
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The installa tion or applica tien c f pene tra ticn c..n's and fire retardant coatings is perforrad by trained pers nnel usin9 approved procedures.
3.0 Cont, ci of Purchas:d "a terial, equipment, ind Servicn; - "usures s hall be es tablished to assure tha t purchased ratarial, :quipment and services conform to the procurement dacuments.
Thase2asures should include:
Provisions, as appropriate, for source evaluat ;n and selection, a.
objective evidence of quality furnished by tne contractor, inspections at suppliers, or recsiving inspecticns.
x b.
Scurce or receiving inspection, as a mini,um, for these items whose quality cannot be verified af ter installatten.
4.0 Inspection - A pr:gr:m for indecendent inscection of activities af fecting fir? protection should be established anc executed by, or for, the Organization performing the activity to verify c:nformance io documented install ation drawings and test procedurcs far accomplishing activities.
This pregram s.5:uld include:
a.
Inspecticas of (1) installation, maint: 2nce 3rd racificatica of fire protection systams; 2nd (2) em?rgancy lignting and : rtunica-f""'
tion equipment t: assure c;nformance to design and installation E~
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requirements.
b.
Inspection of penotration seals anc~ fire etardant c,i.ing installations to werify the activit" is satisf actaril.v c:coletec.
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Inspecticns of cable routing to verify conformance with design r equ i re:.e n t s.
d.
Inspections to verify that as;ropriate requirenents for reca isol aticn (sealing penetrations, flecrs, anc ather fire barriers)
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are acc:mplished during c:nstruction.
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Measures to assure that inspectica personnel Ire ir1' pendent from the individuals per?:rming the activity teing inspec_ed 2.n d are kn:wledgeable in the design and instaliation require ents for fire protection.
f.
Inspecti:n p r cedures, ins tructica.s, and check lists which pr: vide
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for the ic l: wing:
i (1)
Identification of charactaristics and activitics to be s
inspected h-(2)
Identification of the individuals or groups i esacosible f:r
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performing the inspectica cperation P
(3) Acceptance and rejection cr)teria M'
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4 (4) A description of the method of inspection (5)
Recording evidence of ccmpleting v e r i fy i n g a r.in u-facturing, inspection or test ope-. ion c
(6) Recording inspector or data recorder and the results of the inspection operation 9
Periodic inspecti:ns of fire drctection systems, emer;ency breathing and auxiliary aquipment, entrgency lighting, and c:77.nication equi;-
cent to assare tha ecceptable condition of these items.
h.
Periccic inspection of caterials subject to degradition such as fire stops, seals, and fire retardant coatings to assure these ite,ms '. ave not deteriorated or been damagea.
5.0 Test and Test Control - A test pecgram sh:uld be established and implacented to ensure that testing is performec and verified by inspectir.: and Tudit to demonstrate c:nformance with design and system readines s r!cuirarents.
The tests sncule be ;erformed in resu ts shculd be i
accordance with written tast procedures; test preparly evaluated and acted on.
The test program should incluce the,folicwing:
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a.
Installation Testing - Fclicwing construction, r.;;i fi c a-i c o, re; air L
cr replacement, suf ficient testing is ;erf: rend to demarstrate *. hat fire ;rotection systems, emergency lighting and c:. mnication ecui;-
ment will perf:rm satisfactcrily in service and tnat design criteria are cet.
Written test pr:cecures for installati:n tests inc,::cate the requirements anc acceptance limits containec in a;;1icabia design documents.
b.
Periodic tasting - The schedules and methcds for scricdic tastirg are develcpec and dccumentad.
rire protection equi; cant, emergancy 4
lighting, and c:enunication ecui; ment are testad ;criccically tc 5[CE *
- as:ure tnat the equipment will cre erly function and c ntinue to meet the design criteria.
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Fr:gr:ms are established for CA/QC to verify testing of fire
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protection systems and to verify that tcst perscnnel are ef fectively
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trained.
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Test results are d:cumented, evaluated, Inc their ac:a:tacility j.'
det2rmined by a qualified res;cnsible individual or group.
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6.0 Inscection, Test, and C;2 rating Status "e asures shculd be esta:l t shed to provide for the identification of items that have satisfactorily L-passed required tests and inspections.
These measures should include k
provisions for:
a.
Identification by me ans of tags, labels, or simil ar ter;crary markings to indicate c::sletion of required ins;ections an I
7 tests, and c;erating status.
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,c 7.0 Ncnc:nforning It::s - M2asures should be established to c:ntral _itaus
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that do not conform to specifiec requirements to prevent inacrectant
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use of installation.
These measures should include provisions to assure that; a.
N nc:nforming, inc:erative, or c11 functioning fire protection systems, n.,ergency lighting, 2nd cc.;cunicati:n equi; ent are caprcpriately tagged r labelled.
b' The identification, documentation, segregation, re'.
- w dis-position, and notification to the af fecta: cr;ani:ation of nonconforming matarials, parts, c =penants, or servicas are proc 2durally controlled.
c.
Documentation identifies the ncnc:nforming item, describes the nonconformance and the disposition of the n:rc:nf:r,ing item and includes signature approval of the disposition.
d.
Pecvisiens are established identifying these incividuals or d
groups dalegated the rasponsibility and authority for the
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dis 00sition and appr: val of nonc:nferr.ing items.
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W 8.0 Corrective Action - Measures shall be esta:lisned to ansure that c;n--
ditions adverse to fire protection such as failures, malfuncticns, deficiencies, deviations, cefactive c:mpenents, unc:ntrolled c;mbus-tible natarial and nonc:of:rmances are prerptly icantified, caportad and corrected.
These measures should assure:
a.
Procedures are established for evaluaticn of c:ncitions adverse to fire protection (sucn as nonconfor ance, failures, mai-p==-
functions, deficiencies, deviations, and defective :a terial and equipment) to determine the necassary corrective action, b;,
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M b.
In the case of significant or repetitive c:rcitions adverse
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to fire protectico, inclucing fire incidants, the c:use Of
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the canditions is determined and analyzed, cad art =pt corrective
.t actions are taken :: preclude recurrence.
The causa of the
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condition and the corrective action taken are ;r:=ptly reported Ff to cognizant levels of management for revicw and assessment.
N Y-9.0 Rac rds - Rec:rds should be prepared and maintained t: furnish 7;'
evidence that the criteria enumerated above are teing 7.et f or L~
activities affectirg the fire protection progr:m.
The folicwing
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provisions should be included:
t
L a.
Rec:rds are identifiable and retrievable and sh:uld d::; castrate b.
ccnformance to fir protection requirements.
The records shculd r
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6 include results of inspections, tasts, reviews, and iddits;, n-conformance and corrective action reports; construction, ainter.ince and modifica' ion records; and certified manufacturers' data.
b.
Record retention requirements are established.
10.0 Audits - Audits should be conducted and documented to serify c; ;liance with the fire protectica pr: gram, including dasign ind procu.: ar.t documents, instructions, procedures,.Ind drawings, and inspection and g-test activities.
The follcwing provisions should be included:
Audits are periodically performed te verify cc.r:lianca with the a.
administrative c:ntrols and impleccatation of quality assurance criteria including design and procurement, instructions, procccuras and drawings and inspection end test activities.
These audits are perferned by CA personnel in ac::rdance ita pr: established -ritter.
procedures or check lists anc Conducted by trained ;erscanel not
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having direct respcasibilities in the areas beine aucited.
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b.
Audit results are documented and then reviewed with management P="-
having res;0nsibility in the area audited.
Folle uc actico is taken by res;cnsible management to correct the c.
deficiencies revealed by the audit.
d.
Audits are annually performed to provide an ever211 assessment of c;nformance to fire protection requirce.ents.
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