ML19329E800

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Revision to App 1B to Psar.Constitutes Amend 36 to CP & OL Application
ML19329E800
Person / Time
Site: Midland
Issue date: 12/16/1977
From:
CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:
Shared Package
ML19329E790 List:
References
NUDOCS 8006170953
Download: ML19329E800 (14)


Text

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'IDEP (Cont'd)

APPENDIX IB

l' APPENDIX 1C PAGE AMEND PAGE AMEND PAGE AMEND PAGE AMEND r

1C-1 0 1C-11 0 1C-21. 0 1C-29b 2 1C-2 0 1C-12 0 1C-22 0 1C-30 0 1C-3 25 1C-13 14 1C-23 0 1C-31 0 1C-4 0 1C-14 14 1C-24 14 1C-5 0 1C-15 0 1C-25 0 IC-6 0 1C-16 0 1C-26 0 1C-7 5 1C-17 0 1C-27 5 1C-8 9 1C-18 0 1C-28 0 1C-9 0 1C-19 0 1C-29 2 1C-10 5 1C-20 0 1C-29a 2 i

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, APPENDIX 1B r*% .

- QUALITY ASSURANCE PROGRAM 4

Subject to 'those effectivity ' dates shown in Section II below, the' Midland Project Quality. Assurance-Program will comply with the requirements of the following documents:

1. For Consumers Power Activities:

The Consumers Power Company Quality A.surance Program Manual (Topical Report No. CPC-1A' Revision 5)

2. - For Bechtel (Architect-Engineer, Constructor) Activities; Bechtel Quality Assurance Program for Nuclear Power Plants
(Topical) ' Report No. 'BQ-TOP-1, Revision lA)

.3. For Babcock and Wilcox .(Nuclear Steam Supply System Supplier)

,_ Activities; 4 .

. B&W N.P.G.D. Quality Assurance Program for Nuclear Equipment (Topical Report No. BAW-10096A, Revision 3) y This compliance is subject to the following alternatives, interpretations, and exceptions:

( I BECHTEL ALTERNATIVES AND INTERPRETATIONS

. Note: Unless specifically noted' otherwise all organizations, groups, and personnel discussed in thisSection I are Bechtel organizations,' groups, and personnel.

The following alternatives and interpretations apply to the implementa-tion of the Bechtel QA Topical Report (BP-TOP-1):

E A. Construction Work Procedures The Bechtel-Quality Assurance Topical (Section 1.5.4, page 12,

= paragraph 1) requires that " Construction Managers are-responsible for the management and technical direction of assigned projects, and for assuring that construction projects are provided with' appropriate personnel,' and are following prescribed division practices

.and procedures for conduct of construction activities. Chief Construction Engineers are responsible.for-providing division

! standard work procedures to the projects". The Topical (Section 1.5.2,

- page 11,_ subparagraph 3) further requires that the Quality Assurance Manager be' responsible.for " Approving quality related procedures and mancals prepared by departments and projects within his division for.conformance to quality assurance policies".

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In lieu of this requirement the Bechtel Midland Quality Assurance Program requires that Construction per?onnel perform their quality

.s program related functions using either division standard work procedures prepared by Construction Engineering or project work procedures prepared by Project Field Engineering personnel. The final decision on which to use rests with the Project Field Engineer.

All quality program related procedures used by Construction personnel are approved by Project Quality Assurance.

Project Field Engineering has already prepared and is in the process of preparing approximately 75% of the required construction work procedures. Many of these. work procedures were prepared prior to the existence and issue of procedures issued by the Division i

Chief Construction Engineer.

B. Review of Quality Control Instructions The Bechtel Quality Assurance Topical (Section 1.6.1, page 14, subparagraph 13) requires that Project Quality Assurance " Review,

, prior to use. . . . Quality Control Instructions. . ."

1 In liew of this requirement the Consumers Power Company Quality Assurance Topical Report requires that all Quality Control Instructions be reviewed and approved by Consumers Power Company . Quality Assurance prior to use. This review implements the commitments for review described in Section 1.6.1 subparagraph 13 of the Bechtel Quality Assurance Topical.

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k The Bechtel Midland Quality Assurance Program also requires that this activity be audited by the Project Quality Assurance Enginee r.-

, C. Titles

'In .the following cases, Midland Project organizations and personnel nave titles differing from those in Bechtel Quality ,

Assurance Topical Report but the responsibilities are the same. l Bechtel Quality l

Assurance Topical Report Midland Project Title Title Materials, Fabrication and Quality Materials and Quality Services Control Services. Department Department i

Field Constr'tetion-Manager Project Superintendent Project Construction Quality Control Project Field Quality Control Engineer Engineer Field Contracts Administrator Field Subcontracts Administrator

-Division Chief Engineer Cognizant Chief Engineer

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- D,' Supplemental Interpretations of Regulatory Guide 1.37-3/16/73 (ANSI N45.2.1-1973) f "i .

Section 4 (Pre-Installation cleanlinass) of ANSI N45.2.1 states " Items should not be delivered to the point of installation site sooner than necessary unless the installed location is considered a better storage area". In lieu of this requirement items might, in some cases, be delivered to the installation site sooner than necessary at the direction of the Project Field Engineer and will be protected in accordance with Section 5 of ANSI N45.2.1.

E. Supplemental Alternates and Interpretation of Regulatory Guide 1.38 -3/16/73 (ANSI N45.2.2-1972)

The following alternates and interpretation apply to ANSI N45.2.2:

1) Section 2.7 Classification of Items. The listings in paragraph 2.7.1 through 2.7.4 will be used as a guide in determining the categorizing of items under levels A through D for the project.

Categorization differing from Section 2.7 will be considered acceptable provided that no degradation in commodity quality is assured.

As in the case of electric motors, exterior pumps, and exterior valves, which are designed for outside service and could possibly be stored in areas other than those in which they are designated, i.e. outside service electric motors shown in Level B could possibly be placed in a Level C area.

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The same would apply to exterior pumps and valves shown in Level C which could possibly be placed in a Level D area. In all cases however, the classifications shown in ANSI N45.2.2 will be reviewed and considered by field engineering.

2) Section 2.7.4 Level D Classification. The last sentence 1st.

paragraph is interpreted to read "These items require protection against the elements, airborne contamination, and physical damage as necessary and commens' urate with the ultimate use of the item". This determination is made by Field Engineering in accordance with Project prepared and Project Quality Assurance approved proceaures.

3) Section 6.2.2 Cleanliness and Housekeeping Practices in Storage Areas. Detrimental soil is defined as material or items which could degrade the stored material.

F. ' Supplemental Alternates to Regulatory Guide 1.39-3/16/73 (ANSI N45.2.3-1973)

1) Section 2.1 Planning. The Project will use four cleanliness

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zones instead of the five zones listed in this paragraph.

These zones will provide the necessary cleanliness and will provide less confusion in the field. The requirements of

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. zones I and II in the standard will be included in Zones A and

.B of.the field procedure. The requirements of Zone III'of the

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. /~' -standard will be.covared by'-including these items into Zone B or upgrading Zone C for the.particular items. ' Zone IV will be in'cludedlin Zone C except the restrictions on tobacco or eating is not required. This zone can be upgraded to include these restrictions for particular items if necessary.

Zone V will.be incorporated into Zones C or D as required.

Note:

, ' Zone C provides no restriction except that the areas will be-maintained free of-detrimental scrap materials and will be

, swept regularly. Protective coverings will be utilized in work areas.co minimize grease and oil spillage on finished

surface. Zone D areas will be heavy construction areas without cleanliness restrictions and will be upgraded to Zone C when

.the heavy construction is completed.' i h ' Restriction List- Zones I.

( . A B C D Clothing changes Yes No No No 7'

Clean gloves, shoe covers, Yes Yes No No head covering '

Filtered air Yes No No No Material preeleaning.

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Yes to No No

(. Material accountability Yes Yes No No Personnel accountability Yes Yes No No No-use of tobacco or eating Yes Yes No No i

2) Para 2.2 Procedures and. Instructions. This paragraph requires i

procedures for safety and fire regulations. The project will use procedures which describe existing National State and

. Local codes and regulations ~to control. safety and fire. NFPA

' uis the national fire code followed at the site.

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- G. Alternates and Interpretations of Regulatory Guide 1.54-June 1973 (ANSI N101.4-1972)

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.The following alternates and interpretations apply to the implementation of Regulatory Guide 1.54 and ANSI N101.4.

, 1) . The' painting requirements. for the Midland project are specified

~1n four project painting specifications,-most of which were

~ =. developed _ prior.co the issuance of Regulatory Guide 1.54.

3 itiSI N101.4 was used extensively in the development of these specifications and compliance to ANSI N45.2 is required by Consumers Power. Company for equipment 1 procured for the Midland g

- proj ect. .Although not.specifically required 1n all four. ~

specifications, ANSI N101.4 and ANSI N101.2 are generally

referenced and are used'in the evaluation and approval of

~ vendor painting; procedures.

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2) In' instances where non-LOCA qualified' paint-is used on small '

4 components with a limited painted surface, such as valve  !

l f 3J , operators, instrumentation,-small accessory components and .

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-equipmentitrim, the FSAR will provide the total surface area painted with these non-LOCA qualified paints to substantiate their limited application and therefore acceptable use. -It is:

the applicant's position that upon completing the tabulation e of the amount of non-LOCA qualified paint used inside the

- Midland' containment, should this amount be below 100 kilograms, '

the. amount would be acceptable. 'In the calculation of this

, total weights only components exposed to the LOCA environment

- will be considered. .If upon completion of the tabulation of j the amount of non-LOCA qualified paint used _inside containment, this amount exceeds'100 k11ograms, it is the applicant's position'that the following will be considered in conjunction with system characteristics (sump screen size and spray nozzle

  • openings)-to determine acceptability or necessity of any corrective actions:

i - a. The areas of paint exposed to the containment LOCA atmosphere i

b. -The mode of paint failure (i.e., flaking or solubility) i
c. The potential of the paint reactants reaching the containment

' sump, considering possible surrounding traps such as insulation, etc H. Alternate to Regulatory Guide 1.58-August 1973 (ANSI N45.2.6-

1973)

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_The Regulatory Guide states that the provisions of ANSI N45.2.6-1973 are " generally applicable. . . . during fabrication prior to

!. receipt of items at the construction site". The -project will not impese. ANSI.N45.2.6 on suppliers during fabrication prior to receipt 1- of items at the construction site. Instead, the following activities are performed to ensure that offsite inspection, examination or

. testing is performed adequately. Bechtel procurement documents will require that the supplier's Quality Assurance program provide

. measures to assure that personnel performing safety-related inspections,

' examinations and tests are qualified to perform these activities.

JSuch measures ' include procedures for qualification of personnel describing the minimum experience, training and proficiency testing required for qualification. The measures also include-requirements for' records documenting qualifications for each of the supplier's-

-inspection,~' examination. and testing personnel. Personnel qualifica-tion procedures will be reviewed by Bechtel prior to initiation of inspections, examinations, or tests.'

--Also, Bechtel perfo'rms' surveillance inspection at supplier's facilities-by.using'_ inspectors qualified in accordance with ANSI

' N45.2.6. Quality' Assurance audits are. performed on' suppliers and additionally, nondestructive examinations. performed according to

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the quality requirements. of Section III of the ASME Boiler and Pressure Vessel _ Code are performe~d by supplier personnel certified to SNT-TC-1A.

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. I'. Supplemental Alternate to Regulatory Guide 1.64-Revision 1

( ANSI N45.2.11-1974)

Paragraph C-2, of the Regulatory Guide places restrictions on the use of the supervisor for design verification. As an alternate the following controls will be exercised. Design verification may be performed by the originator's supervisor if the supervisor is the only individual in the project team competent to perform the design verification. In such cases, an additional review will be performed by either the next higher level of supervision or by off-project personnel. These personnel are qualified in the area of

- design review and verification.

J. Alternate to Regulatory Guide 1.88-August 1974 (ANSI N45.2.9-1974)

Section 5.6 of ANSI N45.2.9 requires that the permanent record storage facility have " structure, doors, frames, and hardware class A fire rated with a recommended four hour minimum rating."

In' lieu of this the existing Jobsite record storage facility has a two hour fire rating.

K. Alternates and Interpretations of Regulatory Guide 1.94-April 1975 (ANSI N45.2.5-1974)

The following alternates and interpretations apply to ANSI N45.2.5:

( 1) Sections 1.4 Difinition of Sampling Point and 4.8 In-Process s Tests on Concrete and Reinforcing Steel. These sections seem to require the sampling of concrete at the truck discharge or the end of the pump line. For the Midland project, the concrete receives its final mix at the central batchplant, and is transported by agitator trucks to the final conveying system.

The sampling point for the compressive strength test cylinders is from the discharge of the central batch plant stationary mixer, based'on the following:

ANSI N45.2.5 Section 4.8 states that " Samples for inprocess tests shall be taken at the sampling point in accordance with ASTM C 172."

ASTM C 172, Section 2, Note 3, reads: " Sampling should normally be performed as the concrete is delivered from the concrete mixer to the cenveying vehicle used to transport the concrete to the forms." ASTM C 172, Paragraph 3.2.1, Sampling from Stationary Mixers Except Paving Mixers,'gives explicit instructions for stationary mixer sampling.

Compressive strength test cylinders are cast from representative samples taken'from the discharge of the batch plant stationary mixer in accordance with Paragraph 3, ASTM C 172. Slump, air content, unit weight and temperature of the concrete will be

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o s. correlation, cylinders will also be cast from a sample taken at the transport discharge of the same batch from which a sample was taken at the stationary mixer. After correlation has been established, correlation cylinders are continued on a periodic basis to verify the correlation.

The conveying vehicle is defined as an agitator truck. The drums are turned at agitating speeds and not at mixing speed, because the concrete is completely mixed before being loaded as evidenced by the mixer uniformity tests of ASTM C 94.

Concrete samples from the bat ch plant mixer allow for better control of preparing samples, as well as less disturbance of cylinders from preparation hrough initial curing.

The sampling point for final acceptance of air content, slump and temperature is at the truck discharge except for concrete conveyed by pump. Pumped concrete is sampled at the pump line discharge.

The production control for air content, slump and temperature can be at the batch plant discharge or truck discharge provided that a correlation program is developed as recommended by ACI/304 Paragraph 9.7. The correlation program compares the test results for the same batch between the batch discharge and truck or pump discharge.

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2) Section 4.3 Measuring, Mixing and Transporting Equipment requires measuring and mixing of concrete to be in accordance with National Ready Mix Concrete Association - (NRMr'.', Concrete Plant Standard and Truck Mixer-and Agitator standata.

The NRMCA Plant Standard Section 2.2 requires that the batching recorders, ". . . shall register both empty balance and total weight of each batched material."

The concrete batch plant at the Midland site will not provide a zero printout on our batch plant ticket. Since our control panel locks out until the scale reads zero, the system meets the intent of NRMCA even though the printer does not provide a

-numerical indicator.

i 3)- Section 4.5, Concrete Placement. Regulatory Guide 1.94 (C-3) requires that ACI-309-72 be used to determine the adequacy of consolidation equipment. ACI 309-72 was incorporated into the construction specification in 1973, subject to the following alternates: I

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, . ,. e a) Alternate to Equipment Requirements The project concrete placement specification was written in 1970, and based on the then current ACI Committee 609 rep ort. The equipment currently in use on the project was purchased in accordance with the ACI Committee 609 report, and has been maintained in conformance with it to date. Field inspection of concrete placements and concrete cores indicate satisfactory concrete consolidation has occurred. We therefore see no sound reason to justify the replacing of the project equipment to meet the recommenda-tions of ACI 309-72, and discarding equipment that is currently performing in a satisfactory manner.

b) Alternate to Lift Thickness Requirements ACI 309-72 Section 7.1 states: "The concrete should normally be deposited in layers 12 to 18 inches (30 to 45 cm) thick (depending on the length of the vibrator head and other factors)."

Other ACI specifications and recommendations for lift thickness are as folicws:

i) ACI 301-72 Chapter 8 on " Placing," Section 8.3.1 states: " Concrete shall be deposited continuously, or in layers of such thickness that no concrete will be deposited on concrete which has hardened sufficiently to cause the formation of seams or planes of weakness within the section."

11) ACI 301-72 Chapter 14 on " Massive Concrete," Section 14.4.3 states: " Concrete shall be placed in layers approxi-mately 18 inches thick."

iii) ACI 301-72 Section 8.3 references ACI 304 for detailed recommendations for depositing concrete. ACI 304-73 Chapter 6, Section 6.1 states: "It (concrete-ed.)

should be placed in horizontal layers not exceeding 2 ft. (60 cm) in depth, avoiding inclined layers and cold joints."

The project construction specifications require that concrete be placed in horizontal layers "of not greater depth than 24 incbes so that satisfactory consolidation can be achieved with brators." Field inspections of concrete placements and concrete. core samples indicate satisfactory consolidation and placement of concrete has occurred. By combining the foregoing requirements and other related factors (concrete mix consistency, and results of field inspection), the use of lifts not exceeding 24 inches is in accordance with ACI specifications.

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. ~4) Table 3 required In-Process Tests. This table requires that

' the compressive strength of grout be in-process tested daily during production to the requirenents of ASTM C 107. The following alternates to the testing of grout will be implemented:

a) Batch Plant Mixed Groot The specifications require that each class of concrete has a companion grout mixture for use on construction joints, buttering pump lines and such other applications as shown on the drawings. As appropriate to the concrete mix, the grout mix is specified to be the concrete mix without the addition of coarse aggregate, leaving the cement, pozzolan, sand (fine aggregate 3/8 inch or less) and admixtures in the same ratio as before and enough water to provide the desired consistency, but not exceeding the maximum water /(ce=ent + pozzolan) ratio established for the concrete mix. Since this will produce a grout at least as strong as its companion concrete (due to the high cement content per cubic yard), testing of all the materials used in manufacturing grout is done as part of the concrete in-process testing program, and this accomplishes satisfactory quality control of the grout.

b) Premixed Crout Factory packaged grout which requires addition of water

,- and mixing in accordance with the manufacturer's instructions will be tested in accordance with ASTM C 109 for each lot purchased as a quality control check on the factory's production. Since the project specifications require proper storage to prevent deterioration, there is no reason to require daily testing.

5) Section 4.9.1, Qualification of Cadweld Operators. The standard can be interpreted to imply that qualifications of splicing crews are required for each position and each bar size. The Bechtel position is that the qualifications for each position will be for the largest bar to be used. This is also consistent with the May 15, 1973 staff memo and CPCo's Regulatory Guide 1.10 position.
6) Section 5.4, High Strength Bolting a) The installation and inspection of high strength bolted joints are accomplished by one of three methods. Two of these methods, (i.e., automatic cutoff impact wrench, and ,

the turn-of-the-nut method), concur with ANSI N45.2.5 l

requirements. i

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The third method, the use of direct tension indicators,

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is a new method permitted by the Errata of October 22, 1974 to the "AISC Specification for Structural Bolts Using ASTM A 325 or A 490 Bolts."

The quality control procedures required for the use of direct tension indicators are as follows:

i) To verify the load indicating qualities of the load indicators, at least three load indicators from each bag or box shall be verified in a calibration device similar to that required for wrench calibration. If nut face washers are used between the indicators and the nuts, the indicators shall be tested with washers at the rate of three washers frem each bag or box.

Each verification test shall show not less than the specified gap when bolt is tightened to the specified tension.

ii) Load indicator washers shall be installed in accordance with the manufacturer's inerructions. When a load indicator is required under the nut a special nu:

face washer shall be fitted between the indicator and the nut.

iii) Bolted joints made with load indicators shall be inspected visually to ensure that all bolts have the load indicators properly installed and to the proper gap. At least 20% of the bolts in each connection but not less than two bolts shall be checked with a feeler gage to determine the bolts are properly tightened.

iv) Direct tension indicators used with bolts that have been tighted to the full extent specified in Section 5 of the AISC specification shall not be reused, b) The Midland project permits waiving of the AISC requirements for inspection by torque or power wrench provided special inspection procedures are followed.

L. Alternates to Implementation of WASH 1283 (Revision 1) and WASH 1309 Where the Bechtel QA Topical Report or the preceding information discusses versions of Regulatory Guides or ANSI standards which are different from those provided in WASH 1283 (Revision 1) " Guidance

'un Quality Assurance Requirements During the Design and Procurement Phase of Nuclear Power Plants" or WASH 1309 " Guidance on Quality Assurance Requirements During the Construction Phase of Nuclear 1

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. Power Plants," the versions discussed in the Bechtel QA Topical

. Report or in the preceding information will be implemented by

, +g Bechtel.

In addition, the following draf t ANSI standards will be implemented in lieu of the standards provided in WASH 1283 or 1309:

Draft Standard Version in WASH Document Version to be Implemented ANSI N45.2.12 Draft 3 Revision 4 Draft 4 Revision 1 ANSI N45.2.13 Draft 2 Revision 4 Draft 3 Revision 3 II. EFFECTIVITY DATES Subject to the exceptions contained in Section III below, the preceding commitments will be implemented on the following dates for all subsequent safety-related activities relative to the Midland Project:

A. For Consumers Power Activities; December 2,1976 B. For Bechtel Activitie.s; May 15, 1977 with the exception of commitments relative to Regulatory Guides 1.30, 1.37, 1.38, 1.39 and 1.94 where the effectivity date will be July 1, 1977.

C. For Rabcock and Wilcox Activities; August 7,1977.

III. EXCEPTIONS The following exceptions relate to specific commitments which will not be implemented because implementation would require unwarranted modifications of the Midland Project design, procurement, fabrication or construction:

A. General Exception to Consumers Power. Bechtel and Babcock &

Wilcox Commitments No attempt will be made to change procurement documents which have been issued prior to the effectivity date established for the Consumers Power, Bechtel or Babcock & Wilcox commitments in order to comply with those commitments. The relevant commitments will be applied to procurement documents which are issued on or af ter the effectivity date.

B. Specific Exceptions to ' Babcock & Wilcox Commitments 1)- Section 2.2.1, paragraph 1 of the B&W Topical Report reads as follows: "The degree of QA involvement with any

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, specific equipment / component is determined by the safety

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classification system defined in the B&W Safety Classifica-N .

tion Specification derived from Regulatory Guide 1.26 and IEEE Standard 308-1973." In addition to the preceding, the Project Position for Regulatory Guide 1.26 (as described in R. C. Bauman's October 10, 1975 letter to Mr. Roger Boyd and as supplemented by R. C. Bauman's February 5, 1976 letter to Mr. Roger Boyd and as evaluated in S. A. Varga's September 24, 1976 letter to S. H. Howell) is also a basis of the safety classification system.

2) The following design documents are discussed in the B&W Topical Report:

Topical Design Document Report Section Paragraph System Requirements Specification (S.R.S.) 2.2.2 2 3.2 1 3.2 12 4.0 1 4.0 2 System Descriptions (S.D.) 3.2 1 3.2 7 3.2 12 Balance of Plant Criteria (BOP) 3.2 12 Contract Information Sheets (CIS) 4.0 1 In addition, B&W procedures which implement the Topical Report identify a Plant Parameter List (PPL) and Technical Deviation List (TDL). The TDL is a tabulation of all the

. technical and performance differences between the B&W Standard Plant and the "As-Sold" contract plant. For new projects, the issuance of the TDL establishes the preliminary contract technical baseline and is the basis for preparation of the contract technical documents. The PPL is used for new contracts to identify major factors of plant design.

None of the above documents have been (or will be) prepared for the r.on-fuel components enpplied for the Midland Project. For new projects, stese documents are used as the basis documents for the preparation of Equipment Specifications and Balance of Plant Criteria. However, these documents became a requirement of the B&W Design Control system after Equipment Specifications were issued and procurement activities initiated for.the Midland Proj ect. In addition, Balance of Plant Criteria requirements have been satisfied by other means without recourse to these documents. Formal Balance of Plant Criteria documents

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n will not be prepared since this criteria has been forwarded e'%

. to the Architect Engineer in the form of correspondence from B&W to Bechtel and B&W will review Bechtel design documents which contain NSSS interfaces for the adequacy of those interfaces. Therefore, since Equipment Specifica-tions and Balance of Plant Criteria have been prepared without recourse to the SRS, SD, PFL, CIS and TDL documents, these documents are not needed for the Midland Project.

3) Section 17 and Appendix A of the Topical Report commit B&W to implement the requirements of ANSI N45.2.9-1974.

Section 4.3.1 of ANSI N45.2.9-1974 requires for receipt control of QA Records that the system shall include: "A Records Checklist designating the required QA Records."

A Records Checklist has not been (and will not be) prepared for the Midland Project. The majority of B&W generated QA records (i.e., calculations, specifications, procurement.

documents, etc) have been prepared and filed without recourse to a records checklist. Houaver, they are listed on the Documents Historical Listing (DHL). The DHL is the output of an autemated system that identifies and reports the status of contract documents originated by B&W. It also provides a convenient means of verifying that the necessary records have in fact been generated.

The remainder of QA records to be generated by B&W for the Midland Project consists primarily of documents to support FSAR activities, Core design and site support activities (i.e., Field Changes, Site Problem Reports, etc.). The need for the foregoing records is identified in work authorizations approved by the B&W Project Manager for the Midland Project. As these documents are prepared, they will be listed on the DHL.

The Quality RequirementJ Matrix (QRM) described in Section 4 of the Topical Report will continue to serve as the Records Checklist for vendor generated documents. The QRM identifies the QA Records required from vendors by the B&W procurement documents. As vendor documents'are received, they are listed on the DHL described above.

, The B&W QA Engineer for the Midland Project is required by B&W administrative procedures to verify that the vendor QA Records required by the QRM have been received and properly dispositioned.

In summary, because the majority of B&W generated QA Records have been prepared and over 60% of the required vendor QA Records have been received, a Records Checklist will not be prepared. The DHL and QRM provide an adequate means of verifying that the required QA Records have been generated.

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