ML19329E901
| ML19329E901 | |
| Person / Time | |
|---|---|
| Site: | Midland |
| Issue date: | 11/03/1976 |
| From: | Bauman R CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.) |
| To: | Boyd R Office of Nuclear Reactor Regulation |
| References | |
| 2912, NUDOCS 8006180745 | |
| Download: ML19329E901 (22) | |
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THIS DOCUMENT'00NTAIN5 P00R QiMUTY PMES
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November 3,1976
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Director of Nuclear Reactor Regulation Q%
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U.S. Nuclear Regulatory Commission Washingtch, D.C.
20555 MIDIAND PROJZCT IUCI[
DOCKET NUMBERS 50-329 & 50-330 2g QA REGUIATORY GUIDE RESPONSES FILE: 0505.2 SERIAL: 2912 On March 29, 1976, we sent proposed " Quality Assurance Program" description to the Director of Nuclear Reactor Regulation with a request that it be reviewed.
On September 24, 1976, S. A. Varga provided the Staff Evaluation of this pro-gram description in a le~cter to S. H. Howell. This evaluation listed five items to be resolved and a request for infomation relative to Regulatory Guide 1 55 In response to the September 24, 1976 letter, the March 29, 1976 submittal has been revised and is attached to this letter. Following is information as to how the five items in the September 24, 1976 letter vere resolved:
(1) In response to the first question the reference to CPC-1 has been mod-ified to identify CPC-1A, Revision No. 4, as the appropriate reference.
(2) The request for quality assurance infomation relative to Regulatory Guides 154 and 194 has been responded to as follows:
(a) The infomation contained in Consumers Power letters of November 7, 1975 and Febmary 3,1976 to the Director of Nuclear Reactor Regu-lation have been combined to produce the position on Regulatory Guide 154 which appears in Section I-G of the attachment.
(b) The infomation contained in Consumers Power letters of October 15, 1975 and February 10, 1976 to the Director of Nuclear Reactor Reg-ulation have been combined to produce the position on Regulatory Guide 194 which appears in Section I-K of the attachment.
(3) With the exception of Babcock & Wilcox activities, the effectivity date for implementation of the program commitments is shown in Section II of the attachment. The effectivity date for the Babcock & Wilcox commit-ments vill be the date of publication of Revision 3 of their Topical Report fBAW-10096A which is currently undergoing review by the QA Branch of the Division of Nuclear Reactor Regulation. When this date has been e3 m j established it vill be inserted into Section II of the attachmerit and s
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2 copies will be forwarded to you.
(4) The exceptions to comitments are contained in Section III of the attachment.
(5) The reference to ANSI N45 2 3-1973 has been corrected in Section I-F of the attachment.
Relative to Regulatory Guide 155, the Project has changed its position described in our letter of December 1,1975 and will implement Section C.2.a of Regulatory Guide 155 for the balance of the project.
Subsequent to the March 29, 1976 submittal, it has been decided to commit to Revision 3 of the Babcock & Wilcox Quality Assurance Topical Report fBAW-loo 96A in lieu of the commitment to Revision 1 of that document. This change has elimi-nated the need for Section II, " Babcock & Wilcox Alternative," in the March 29, 1976 submitt-' which, in turn, resulted in the re-numbering of Sections III and IV of that subaittal.
Please review the attached proposed " Quality Assurance Program" description and provide an evaluation as to the acceptability of that description with.
the understanding that the effectivity date for implementation of the Bab-cock & Wilcox commitments will.be provided when it nas been detemined.
R. C. Bauman Project Engineer RCB/HWS/lc
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QUALITY ASSURANCE PROGRAM 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 Assurance Program Manual (Topical Report No. CPC-1A Revision k) 2.
For Bechtel (Architect-Engineer, Constructor) Activities; Bechtel Quality Assurance Program for N2 clear Power Plants (Topical)
' Report No. BQ-TOP-1, Revision lA) 3.
For Babcock and Wilcox (Nuclear Steam Supply System Supplier) Activities; B&W N.P.G.D. Quality Assurance Program for Nuclear Equipment (Topical Report No. BAW-10096A, Revision 3)
This compliance is subject to the following alternatives, interpretations, and exceptions:
I BECHTEL ALTERNATIVES AFD INTERPPJETATIONS_,
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 tnplementation of the Bechtel QA Topical Report (BP-TOP-1):
A.
Construction Work Procedures The Bechtel Quality Assurance Topical (Section 1.5.4, page 12, paragraph 1) requires that " Construction Managers are responsibl2 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 activitiec.
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Chief Construction Engineers are responsible for providing division standard work procedures to the projects". The Topical (Section 1.5.2, page 11, sub-paragraph 3) further requires that the Quality Assurance Manager be responsible for " Approving quality related procedures and manuals prepared by departments and projects within his division for conformance to quality assurance polietes".
-In lieu of this requirement the Bechtel Midland Quality Assurance Pro-gram requires that Construction personnel perform their quality program related functions using either division standard work procedures prepared by Construc-tion Engineering or project work procedures prepared by Project Field Engineer-ing 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 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..."
In lieu 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 sub-paragraph 13 of the Bechtel Quality Assurance Topical.
The Bechtel Midland Quality Assurance-Program also requires that this activity be audited by the Project Quality Assurance Engineer. -
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C.
Titles In the following cases, Midland Project organizations and personnel
.have titles differing from those in Bechtel Quality Assurance Topical Report but the responsibilities are the same.
Bechtel Quality Assurance Topical Report Midland Project Title Title Materials, Fabrication and Quality Materials and Quality Services Control Services Department Department Field Construction 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 D.
Supplemental Interpretations of Regulatorv Guide 1.37 (ANSI N45.2.1-1973)
Section 4 (Pre-Installation cleanliness) of ANSI N45.2.1 states " Items should not be delivered to the point of installation site sooner than neces-sary unless the installed location is considered a better storage area".
In lieu of this requirement items might, in some cases, be delivered to the in-stallation 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.
Suoplemental Alternates and Interpretation of Regulatorv Guide 1.38 (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 itens under levels A through D for the project. Categorization dif-fering from Section 2.7 will be considered acceptable provided that no degradation in commodity quality is assured..
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As in the case of electric motors, exterior pumps, and exterior valves, which are designed for outside service and could possibly be secred 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.
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 el_nents, airborne contamination, and physical damage as necessary and commensurate with the ultimate use of the item".
This determination is made by Field Engineering in accordance with Project prepared and Project Quality Assurance approved procedures.
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 Regulatorv Guide 1.39 (ANSI Nh5.2.3 - 1973) 1)
Section 2.1 Planning. The Project will use four cleanliness 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 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 standard will be covered by including these items into Zone B or upgrading Zone C for the particular items. Zone IV will be included in Zone C except the restrictions on tobacco or eating is not required.
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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. Protec-tive coverings will be utilized in work arens to 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.
Restriction List Zones A
B C
D Clothing changes Yes No No No Clean gloves, shoe :o7ers, Yes Yes No No head covering Filtered air Yes No No No Material preeleaning Yes No No No Material accountability Yes Yes No No Personnel accountability Yes Yes No No No use of tobacco or eating Yes Yes No No 2)
Para 2.2 Procedures and Instructions. This paragraph requires procedures i
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 is the national fire code followed at the t
site.
G.
Alternates and Interpretations of Regulatorv Guide 1.54 (ANSI N101.4-1972)
The following alternates and interpretations apply to the i=plementation of Regulatory Guide 1.5h and ANSI N101.h.
1)
The painting reenirements for the Midland project are specified in four project painting specifications, nost of which were developed prior to the issuance of Regulatory Guide 1.5h.
ANSI N101.h was used extensively in the development of these specifications and _
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,. 3 compliance to ANSI Nk5.2 is required by Consumers Power Company i
for equipment procured for the Midland project. Although not specifically required in all four specifications, ANSI N101.h I
and ANSI N101.2 are generally referenced and are used in the evaluation and approval of vendor painting procedures.
2)
In instances where non-LOCA qualified paint is used on swall components with a limited painted surface, such as valve operators, instrumentation, =all accessory ecmponents and equipment trim, the FSAR vill provide the total surface area painted with these non-LCCA qualified paints to substantiate their limited applicatien and therefore acceptable use. It is the applicant's position that upon completing the tabulation of the amount of non-LOCA qualified paint used inside the Midland containment, should this amount be belev 100 kilograms, the amount vould be acceptable.
In the calculation of this total weight, only components exposed to the LOCA environment vill be considered. If upon completion of the tabulation of the amount of non-LOCA qualified paint used inside containment, this amount exceeds 100 kilograms, it is'the applicant's position that the folleving vill be considered in eenjunction with system characteristics (sump screen size and spray no::le openings) to determine acceptability or necessity of any corrective actions:
The areas of paint exposed to the containment LOCA atmosphere a.
b.
The mode of paint failure (i.e., flaking or solubility) 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 (ANSI Nh5.2.6-1973)
The Regulatory Guide states that the provisions of ANSI Nk5.2.6-lot 3 are " generally applicable.....during fabrication prior to receipt of items L _
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The project will not impose ANSI N45.2.6 on suppliers during fabrication prior to receipt of items at the construction site. Instead.. the following activities are performed to ensure that off-site 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, avaminations and tests are qualified to perform these activities.
Such measures include procedures for qualification of personnel describing the minimum experience, training and proficiency testing required for quali-fication. The measures also include requirements for records documenting
. qualifications for each of the supplier's inspection,- examination, and testing personnel. Personnel qualification procedures will be reviewed by Bechtel prior to initiation of inspections, examinations, or tests.
Also, Bechtel performs surveillance inspection at suppliers 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 the quality requirements of Section III of the ASME Boiler and Pressure Vessel Code are performed by supplier personnel certified to SNT-TC-LA.
I.
Supplemental Alternate to Regulatorv Guide 1.64 (ANSI N45.2.ll-1974)
Paragraph C-2, of the Regulatory Guide places restr':tions 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 addi-
-tional 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.
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Alternate to Regulatory Guide 1.88 ( ANSI Nh5.2.9-197h)
Section 5.6 of ANSI Nk5.2.9 requires that the per=anent record storage facility have " structure, doors, frames, and hardware class A fire rated with a recommended four hour mini =um rating." In lieu of this the existing Jobsite record storage facility has a two hour fire rating.
K.
Alternates and Internretations of Regulatorv Guide 1.9h ( ANSI Nk5.2.5-197h)
The following alternates and interpretations apply to ANSI Nh5.2.5:
1)
Sections 1.h Definition of Sampling Point and h.8 In-Process Tests
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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 batch plant, 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 Nh5.2.5 Section k.8 states that " Samples for J.nprecess tests shall be taken at the sampling point in accordance with ASDI C 172."
AS'IM C 177, Section 2, Note 3, reads:
" Sampling should normally be performed as the concrete'is delivered frem the concrete mixer to the conveying vehicle used to transport the concrete to the forms." ASti C 172, Paragraph 3.2.1, Sampling frcm Stationary Mixers Except Paving Mixers, gives explicit instructions for stationary =ixer sampling. L
p Compressive strength test cylinders are cast from representative samples taken from the discharge of the batch plant stationary mixer in accordance with Paragraph 3, AS W C 172. Slump, air content, unit weight and temperature of the concrete vill be recorded when cylinders are being cast. For purposes of correla-tion, cylinders vill also be cast from a sample taken at the trans-port discharge of the same batch from which a sample was taken at the stationary mixer. After correlation has been established, 4
correlation cylinders are continued en 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 losded as evidenced by the mixer uniformity tests of ASTM C 94.
Concrete samples from the batch plant mixer allow for better control of preparing samples, as well as less disturbance of cylinders from preparation through 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 1
a correlation program is developed as recommended by ACI/30h 1
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The correlation program compares the test results for the same batch between the batch discharge and truck or pump discharge.
2)
Section h.5, Concrete Placement. Fegulatory Guide 1.9h (C-3) requires that. ACI-309-72 be used to deter =ine the adequacy of consolidation equipment. ACI 309-72 was incorporated into the construction specification in 1973, subject to the following alternates:
a) Alternate to Equipment Requirements The project concrete placement specification was written in 1970, and based on the then current ACI Committee 609 report.
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 cccurred. We therefore see no scund reason to justify the replacing of the project equip =ent to meet the recommendations of ACI 309-72, and discarding equip-ment that is currently performing in a satisfactory =anner.
b) Alternate to Lift Thickness Requirements ACI 309-72 Section T.1 states:
"The concrete should nor-m117 he deposited in layers 12 to 18 inches (30 to h5 c=) thick (depending on the length of the vibrator head and other factors)."
Other ACI specifications and recommendations for lift thickness are as follows:.
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- 1) 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 cone.ete vill be deposited en concrete which has hardened stTficiently to cause the formation of seams or planes of weakness within the section."
- 11) AcI 301-72 Chapter lh on " Massive Concrete," Section ik.k.3 i
states: "Ccn rete shall be placed in layers approxi=ately 18' inches thick."
iii) ACI 301-72 Section 8.3 references ACI 30h for detailed recommendations for depositing concrete. ACI 30h-73 Chapter 6, Section 6.1 staten,.
"It (concrete-ed.) should be placed in horizontal layers not exceeding 2 ft. (60 cm) in depth, avoiding inclined layers and cold joints."
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The project construction specifications require that concrete be placed,in horizontal layers "of not greater depth than 2h inches so that satisfactory consolidation can be achieved with vibrators."
- Field inspections of concrete placements and concrete core samples indicate satisfactory consolidation and placement of concrete has occurred. By combining the foregoing requirement:. and other related factors (concrete mix consistency, and results or field inspection), the use of lifts not exceedinst 2h inches is in accordance with ACI specifications.,
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3 3)
Table B Required In-Process Tests. This table requires that the compressive strength of grout be in-process tested daily during production to the requirements of AST4 C 109.
"he folloving
~ lternates to the testing of grout will be i=plemented:
a a) Batch Plant Mixed Grout 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 =1x vith the coarse aggregate removed, leaving the cement, pozzolan, sand and admixtures in the same ratio as before and enough vater to provide the desired consistency, but not exceeding the maxi =um vater /(cement +
pozzolan) ratio established for the concrete mix. Since this vill 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 =anufacturing grout is done as part of the concrete in process testing progra=, and this accomplishes satisfactory quality centrol of the greut.
b) Premixed Grout Factory packaged grout which requires addition of water and mixing in accordance with the manufacturer's instructions vill be tested in accordance with ASt< 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.
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Section'k.9 1, Qualification of Cadweld Operators. The standard can be interpreted to imply that qualifications of splicing crews is required for each positien and each bar size. The Bechtel position is that the qualificatiens for each position vill be for the largest bar to be used. This is also censistent with the May 15, 1973 staff memo and CPCo's Regulatory Guide 1.10 position.
- 5) ~Section 5.h, 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 i= pact vrench, and the turn-of-the-nut method), co.; cur with ANSI Nh5.2.5 requirements.
The third =ethod, the use of direct tension indicators, is a new method permitted by the Errata of October 22, 197h to the "AISC Specification for Structural Bolts Using ASTM A 325 er A h90 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 lead indicators, at least three load indicators from each bag or box shall be f
verified in a calibration device s'.milar to that required for vrench calibration. If nut face vashers are used between the indicators and the nuts, the indicators shall be tested with vashers at the rate of three vashers frcm each bag or box.
Each verification test shall show not less than the specified gap when bolt is tightened to the specified tension.
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i ii). Lead indicator vashers shall be installed in accordance vith the manufacturer's instructions. When a load i
indicator is required under the nut a 'special nut face vasher shall be fitted between the indicator and the nut.
l 111) Bolted joints made with lead 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 deter =ine the bolts are properly tightened.
1 iv) Direct tension-indicators used with bolts that have been tightened to the full extent specified in Section 5 of the AISC specification shall riot be reused.
b) The Midland project permits vaiving of the AISC requirements for i
inspection by torque or power vrench provided special inspection procedures are followed.
1 II.
EFFECTIVITY DATES The preceding con:mitments vill be implemented on the following dates for all safety related activities relative to the Midland Project:
l A.
For Consumers Power Activities; April 21, 1976 i
B.
For Eechtel Activities; April 1, 1977 i
C.
For Babcock and Wilcox Activities; Cat,Mt.nf (.:.d> CE 6 //4' L y Sam J A,&w GA Tc.fcal:
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The preceding dates do not apply to those instances where the Midland plant design, procurement, fabrication or ccustruction would have to be modified to conform to. meet the preceding ecm=itments. These instances are defined below.
III.
EXCEPTIONS BASED ON THE NEED FOR MODIFICATION OF TEE PLAl"f DESIGN, PROCUREMENT. FABRICATION OR CONSTRUC'HC7 The following exceptions relate to specift commitments which vill not be implemented because implementation vould reqv. ire unvarranted modifications of the Midland Project design, procurement, fabrication or construction:
A.
General Excettien to Censumers Power, Bechtel and Babcock and Wilcox Commitments No attempt vill be made to change procurement documents which have been issued prior to the effectivity date est:Colished fer the Consumers Power, Bechtel or Babcock and Wilcox commitments in order to comply with those commitments. The relevant commit-ments will be applied to procurement documents which are issued on or after the effectivity date.
B.
Scecifie Exceptions to Babcock and Wilcox Ccemitments
- 1) Section 2.2.1, paragraph 1 of the B&W Topical Report reads as follows:
"The degree of QA involvement with any specific equipment / component is determined by the safety classification system defined in the B&W Safety Classification Specification derived from Regulatory Guide 1.26 and TF E Standard 308-1973."
In addition to the preceding, the Project Position for Regulatory Guide 1.26 (as described in R. C. Bauman's
. )
T 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 2k, 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 Desien Document Recort Secticn Pararrath System Requirements Specification (S.R.S.)
2.2.2 2
3.2 1
3.2 12 4.0 1
h.0 2
System Descriptions (S.D.)
3.2 1
3.2 7
3.2 12 Balance of Plant Criteria (BOP) 3.2 12 Contract Infor=atien Sheets (CIS) h.0 1
In addition, B&W procedures which i=plement the Topical Report identify a Plant Parameter List (PFL) 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 preli=inary 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. i
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3 Ncne of the above documents have been (or vill be) prepared for the non-fuel components supplied for the Midland Project. For new projects, these documents are used as the basis documents for the preparation of Equipment Specifications and Balance of Plant Criteria. However, these docu=ents became a require-ment of the B&W Design Control system after Equipment Specifications were issued and pc,curement activities initiated for the Midland Project. In additics, Balance of Plant Criteria requirements have been satisfied by other means without recourse to these documents. Formal Balance of Plant Criteria documents will not be prepared since this criteria has been for*m ded to the Architect Engineer in the form of correspondence from B&W to Bechtel and B&W vill review Bechtel design documents which contain NSSS interfaces for the adequacy of those interfaces.
Therefore, since Equipment Specifications and Balance of Plant Criteria have been prepared vithout recourse to the SRS, SD, PFL, CIS and TDL documents, these docu=ents are not needed for the Midland Project.
- 3) Section l~ and Appendix A of the Topical Report co=mit 3&W to implement the requirements of ANSI Nh5.2.9-197k. Section h.3.1 of ANSI Nh5.2 9-197h requires for receipt control of CA Records that the system shall include:
"A Records Chechlist 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 CA records i -.
. 4 (i.e., calculations, specifications, procurement documents, etc) have been prepared and filed without recourse to a records checklist. However, they are listed on the Documents Historical Listing (DHL). The DEL is the output of an a'utomated system that identifies and reports the status of contract documents originated by B&W.
It also provides a convenient =eans 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 consist 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 vork authorisations approved by the B&W Project Manager for the Midland Project. As these documents are prepared, they vill be listed on the DHL.
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The Quality Requirenents Matrix (CF31) described in Section h of the Topical Repcrt vill continue to serve as the Records Checklist for vendor generated docu=ents. The QPM 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 3&W CA F.ngineer for the Midland Project is required by B&W administrative procedures to verify that the vender QA Records required by the QRM have been received and properly dispositiened.
In smmag, because the majority of B&W generated CA Records have been prepared and over 60% of the required vendor CA,
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12 7sr g3q NRC DISTRiflUTIO,N Fon PART 50 DOCKET MATERIAL FROM:
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TO:
Mr Boyd Consusmers Power Co 11-3-76 Jackson, Michigan ATE RECEIVED R C Bauman 11-5-76
& EyTER O NoToRt2 E D PROP INPUT FORM NUMBER oF COPIES RECEIVED JilomGINAL kUNC LASSIFIE D CCoPv one singed oESCRIPTioN ENCLoSU RE.
Ltr re their 3-29-76 submittal or Quality Responses to questions concerning the Assurance Program....trans the following:
Quality assurance Program for Midland (10 cys enci rec'd)
DO NOT ElRuu d PLANT NAME:
Midland 1 & 2 e :7 o.s.2 SAFETY FOR ACTION /INFORMATION ENVTRn 11-10-76 ehf
'A33IGI'EU AD:
ASCTONrn Ap.
BRANCH C1tIEF:
BRANCH CitTEF*
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