ML20010C659
| ML20010C659 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/27/1975 |
| From: | Jackie Jones CAROLINA POWER & LIGHT CO. |
| To: | Case E Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20010C645 | List: |
| References | |
| FOIA-81-121 NUDOCS 8108200283 | |
| Download: ML20010C659 (150) | |
Text
...
e
",' O. f * ] ]
8 s
~ % %... d
=
Caro'ina Power 4 Light Company February 27, 1975 111e: 1.c-3514 (6)
S.e ri 21: UG-75-300
?!r. I',dson G. Case, Acting Director Of fice of Nuclear Ieactor Regulation U. S. Juclear Regulatory Comission
~
j i
Unshington, D. C.
20545
Dear lir. Case:
~.,
f,RCNSUICP S. E. Pl. ANT tE TSil N DOCKEf NOS. 50-324 AND 50- 325 l
OUALITY ASSUR,\\NCE P110GRA11 l
In response to Ifr. U. R. Butler's letter of December 3, 1974, l
Carolina Power & Light Company's commitment to follow the applicable guid-I ance contained in WASH 1284 (10h6/73), " Guidance on Qaality Assurance Requirenents During the 'Operat Phase of Naclear Power Plants", UASl!
~
1309 (5/10/74), " Guidance on Quality Assurance Requirements During the l
Constructir;n Phase of Nuclear Power Plants", and UAS11 1283 (5/24/74),
" Guidance on Quality Assurance Requirements During Design and Prc :urement l
Phase of Nuclear Power Pli.nts" for the Brunsuick Stean Electric Plant (BSEP)
Operation and Maintenance QA Frogram is herbin st.bt.utted.
It is,CPEL~'P dntent? to iclieu the cpplienbin quideliacs Provided dir,the above referenced L'Aslb docur.enrn at.hshls.
However, wl.a c the stated' position in these MAS!b documents..could lead 4.c. cisunders.tranding, or alternate rtethods and/or selutions are implenented;for ocromulishaent of these; pcsitions) the a.ttachnent, tm sthis 3 ctstep desciit'es the sCr5! pcsitionsfor:4SEE.
The attached positions are based on previous QA commitments and the present structure of the approved BSEP Operation and 11aintenance QA Program which has been reviewed by NRC.
You s very truly,
~.
j L c-'-
i J. A. Jones Executive Vice President RBS:cg Engineering, Construction 6 Operation Attachment cc: }!c ss rs.
N. B. Bessac
&_1fcCoyfrn.
b
E. G. Ho110well bl. A. ItcDuffie l
(,
- p. W.110we W. B. Kincaid R. E. Jones E. E. Utley D. B. Waters
J'si.
8108200283 810618 PDR FOIA cymng3gg,~ grg;3g;;gygg.z.pg3ny_y BUSTANI81-121 PDR
-<.m s
v
'N
e U:?itt0 srA:ks M!!C10 /ill HliCUI. A TORY Pur.irilS';:ON W ASillM G FO f!. n.
C.
L'0 5:> 5 t l ',
hl!$
peciset ' os. 50-324 and 50-325 Licensce:
Carolina Pouer & Light Company I
Facility:
Bruusuick Stemi Electric Plant, Units 1 & 2 SU>E!ARY OF MEETING !! ELD L'ITli CPM. ON AUGUST 6, 1975 07 ' u,,e t: f, I " 7 '..
.- ; ic tv e c,,, cc,rc1. m Fet.or A L :,ht (CL't.L) nec ui b t he XC staff to di:. cuss the exceptions taken by CP&L regarding the quellt.y assurance guidelines contained in UAS!! documents cud 1309.
A list of at t endees is enclosed.
1283, 1284 The staff's revicu of the CP&L exceptions to the quality assurance guidelines in UASH documents 1283, 1284 and 1309, submitted by CP6L by letter dat ed February 27, 1975 staff's revieu, has been completed. As a result of the additional clarification.there were ten exceptions taken by CP&L that require enclosure to the ir.cr.oranduatEach of the ten exceptions contained in an to W. R. Butler frora R. H. Vollmer, dated June 19, 1975 were discussed and resolved at this meetJng.
amend their February CP&L will 27, 1975 letter to include at this iceting.
the changes agreed upon CP6L indicated that their company policy regarding Quality Assurance would be consistent regarding the exceptions to the guidelines of UAS!! doco.+ents 1283,1284 and 1309 f all their nuclear facilities.
I C- ('
Ray Powell, Project Mcnager Light Water Reactors Branch 1-2 Division of Reactor Licensing
Enclosure:
Attenrinrce List 1
[',
M
(
i s
=
~
4 ENCI.0SilRE IIEETING ATTEMDANCE (August 6,1975)
A r.tendees:
R. P, lack G. !!cCovern CPLL (Licensing)
T. Lentz CP&L (Q/A Manager)
CP&L (Q/A)
D. SkovholL*
NRC R. Voll::.or HitC II. Uc or.e d:h:
3 Pc n.. r./; u -
IMC R. Pc' cell NRC Apart Time 4
j l
4 4
{
f i
0
/
i m
i
I-
.,4-.
.i QA Conments on_CP6L Exceptions to NASH 1283, 1284, and_1309 1.
Item 3 of che " General" interpretations by Carolina Power and Light states that the guidance contained in ANSI N45.2.8 (draf t 3, revision 2) and ANSI N45.2.13 (draf t 2, revision 4) will be utilized "as appropriate." Yoer use of the phrase "as appropriate" does not provide us with a sufficient under-standing of the degree to which you will comply with and implement these standards. Uc request that you provide us with a more specific commitment to these ANSI standards, or provide a clear description of the phrase "as appropriate."
2.
Item 2 of the CP&L " Specific" interpretation or exceptions states that the BSEP QA program will be in accordance with
~
ANSI N45.2.6 (Regulatory Guide 1.58) with the following exceptions:,
a.
"N45. 2. 6, Sections 2. 2.4, 3.1, and 3. 2.2 - Only personnel performing NDE (PT, MT, UT, and RT) will be grouped in levels of capability and certified as such, b.
"N45.2.6, Section 3.2.1 - Potential employees are required to receive a complete examination to assure satisfactory physical condition, but annual physical examinations are not required.
"The near vision acuity of inspection, examination, and testing personnel will be checked annually by using the '
standard.Taeggers type chart or equivalent test type."
g With respect to the CP&L position on Sections 2.2.4, 3.1, and 3.2.2, the NRC staff will not insist that certification of inspection, examination, and testing personnel be made co
~
. the three specific levels of capability identified in the ANSI Standard, liowever CP&L should describe in equivalent detail their alternative to certifying inspection, examination, and testing personnel. This description should include:
a.
An identification of the levels of ' capability to which CP&L Inspection, examination, and testing personnel will be certified.
b.
A description of the education and experience requirements for each of the various levels of capability.
c.
A description of the specific required technical capabilities for each of the various icvels of capability.
Uc find that the CP&L controls for examination of inspection, examination and test personnel are acceptable with the following clarification regarding annual physical examinations: CP&L is required to determine what, if any, physical and medical requirements are required of their personnel to perform assigned tasks; and the affected personnel are annually exanfeed to verify they meet these requirements.
3.
In item 4.D CP&L states that " Chemical compounds that can contribute to intergranular cracking or stress-corrosion cracking at BSEP are not being used in cleaning of austenitic stainless steel and nickel-base alloys." The phrase "are not c
being used" only describes the situation at the time of submittal of the CP&L position. We request that you submit a more specific commitment which indicates future compliance with 4
(
this requirement of Regulatory Guide 1.37.
4
[
4.
CP&L item 4.F states that AST!1 A 268 will be used to detect possible intergranular precipitation of chromium carbides in corrosion resistant alloys.
This standard is a rar.orfal specification.
It appears that the CP&L reference should be ASTM A 262-68.
5.
CP&L takes exception (reference CP&L item 6. A.b) to the ANSI N45.2.2 statement which imposes Appendix A3 as a mandatory requirement.
CP&L's proposal to merely use this appendix for guidance is unacceptable.
It is the NRC staff position that CP&L must meet the requirements of Appendix A-3 or describe acceptable alternatives for the specific exceptions taken to Appendix A-3, 6.
In CP&L item 6.B to Regulatory Guide 1.38, CP&L states that for hoisting equipment it will only perform the required dynamic Ioad test over the full range "where practical." CP&L should slescribe the criteria used to determine when the dynamic load test is practical.
7.
For Regulatory Guide 1.64 (endorses N45.2.11), CP&L (item 7) states that "the degree to which all of the controls of N45.2.11 are applied depends on the magnitude of complexity and nucicar safety implications of the task at hand."
CP&L should describe the criteria used to determine when the controls of N45.2.11 are applicabic.
8.
In item 10, CP&L states that the record storap,e k'
vaults meet the requirements of a two-hour minimum rated facility (per NFPA 232) with the following exceptions:
[
h a
gh no p
6 566 Mh e Me m Wh+e d
w +4 mp hemm g D
Both the' temporary and' permanent storage vaults have a.
wall penetrations for hearing, ventilation, and lighting and the walls are not plastered with gypsum or portland cement.
(Contrary to NFPA 232 requirements).
b.
The door for the temporary storage 'vatit is a thrce-hour UL rated fire door rather than a two-hour vault type door required by NFPA 232.
In addition CP&L states that a lialon fire suppression system 9
and a fire alarm system are installed in both vaults.
The description o'f the record storage vault is insufficient to determine whether adequate protection is afforded from destruction due to fire. The following information is required:
A description of the wall penetrations including any special a.
controls or protections, such as heat, smoke, or flame actuated dampers.
b.
Whether an early warning system is installed in the vault and at what levels of temperature or smoke it is activated, c.
A description of the concentration of the Italon once the llalon fire suppresion system is activated; a
identification of what triggers the llalon system (smoke, heat, etc.); and an identification of the 1cvel of heat, smoke, etc., at which the Italon is activated.
d.
A description of any backup systems to the llalon system,.
such as a sprinkler system.
,.s h e '.
-0 c.
A description of the composition of the walls.ad the vallcovering material, and their degree of flammability.
em e me e
=
we _
e =
= * *
/
l i
.o,
. s 9.
CP&L item 12 states that CP&L will utilize Regulatory Guide 1.39 (ANSI N45.2.3), " Housekeeping Requirementt for Uater-Cooled Nucicar Power Plants,"
for maintenance or mod fication work only. *However Regulatory Guide 1.39 does not restrict itself to only maintenance or modification work.
Regulatory l
Cuide 1.39 describes an acceptable method for complying with Commission regulations with regard to housekeeping requirements l
"for quality affecting activities." Housekeeping is defined to encompass "all activities related to control of cicanness of facilities, cicanness of material and equipment,. fire prevention l
and fire protection including disposal of combustible materials I
and debris, control of access, and protection of materials."
It also states that these requirements are applicable during the operations phase as well as during construction.
Regulatory Guide 1.39 is clear.
It is the NRC staff's position that CP&L t
l l
comply with Regulatory Guide 1.39 or describe acceptable l
alternatives.
Since CP&L finds that the definitions of " zones" for cleanness requirements given in ANSI N45.2.3 are " impractical for implementation,"
CP&L should describe alternative definiH,ns.
i 1
10.
CP&L states that the guidance eu e
eG in ANSI N45.2.5 1974 will be utilized "as appropriate." CP6L should define what is meant by "as appropriate."
p.
4.
1
1 4
~
3 i
d I
CAROLINA PO'..'ER & LIGHf COMPANY POSITIONS ON Tl!E GUIPA::CE COSTAl"'.D I".,.DFl 12a. 1309, A"D 1283 FOR
--.... s-.,.lo-1, L....T
.t x t, lh,..t........ 2 o. 3 u... :
r a.s t..
i 1
i The following paragraphs contain both general and specific inter-l pretations of, or exceptions taken to, the guidance contained in WASH docu-ments 1284, 1309, and 1283.
i GENERAL l
i L
1.
The BSEP plant procedures and instructions, which are included in whole l
I or in part into the ESEP Operation and Maintenance QA Program, are de-signed to meet the applicable requirements delineated in those standards l
(and the regulatory guides uhich end;rse those standards) included in
~
However, each and every individual require-WASH 1284, 1309, and 1283.
ment is not spelled out verbatim. Th,is is specifically true where stand-l ards detail " common sense" or " good practice" requirements which are l
l understood nad practiced by experienced supervisory personnel apprcpriately I
trained and qualified for the task at hand.
4 1
2.
Essentially all the standards endorsed by those Regulatory Guides included in UASH 1284, 1309, and 1283 state that other docaments (usually other standards) are required to be included as a part of that particular stand-l ard and such documents are identified at the point of reference and de-scribed elsewhere in that standard.
In general, the regulatory position i
is, "that specific applicability of these listed documents has been or will be covered separately in other regulatory guides or in Cornission j
regulations where appropriate".
J4 CP6L:
i 1
The specific applicability and.cceptability additional documents I
referenced or included as a required part t'
tandard are or will be addressed separately.
3.:
Included'in all three of the above UASH documents are draft standards and regulatory guides which, it is assumed, are provided for interim guidance I
for quality assurance programs which conply with 10CFR30 Appendix B.
i Following are the CP6L positions for ESEP relative to those draf t docu-
- r. cat s included in WASH-128 3, WASH-1309, and WASH-1284 :
)
(}h) ANSI N45.2.12 (Draft 3, Rev. 4 - February _22,, 1974), " Requirements for Auditing of Quality Assurance Prograus for Nuclear Power Plants" 4
i.
k
_AN_S.I_ K4_5_._2.12 (con _t_i_n_u_e_d_)_
g l
CPEL:
e The CPEL Quality Assurance Audit Program conforms to, and QA j
audits are conducted in accordance with S45.2.12 (Draft 4, Rev. 1).
i 2 - September 1973)
" Supplementary B - ANSI N45.2.8 (Draft 3, Rev.
Inspection, and Quality Assurance Requirements for Installation, and Systers for the Constructica Testing of Mechanical Equipment Phase of Nuclear Power Plants" i
CP&L:
of the established Operation and Maintenance Within the context t
the applicable guidance contained in ANSI N45.2.8 QA Program, (Draf t 3, Rev. 2 - September 1973) vill be utilized as_approp_riate, in relation to nechanical naintenance or modification.
- -.. 7 C.- ANSI N45.2.13 (Draf t 2,.Rev. 4 - April 1974)
" Quality Assurance of items and Services for Requirements for Control of Procurement NL lear Pcwer Plants" CP5L:
2, Kev. 4-The applicable guidance contained in ANSI N45.2.13 (Draft i
in relation to procure-April 1974) ' uill be utilized is._ app 1p_pria_t c I
nent of items and services perft ted under the established require-I ments of the BSEP Operation and Maintenance QA Progran.
l 6
5 t
l
?
I.
I e i e
l
s Refulatory Position (continued) e A"SI N45.2.6-1973 are gene > illy acceptable and provide an adequate basis for cceplying with the pertinent quality assurcnce requircnents of Appen-dix B to 10CPR Part 50."
j i
CP6L:
j~
The qualification of ESEP inspection, examination, and testing personnel i
vill be in accordance uith ANSI N45.2.6-1973 with the following specific exceptions:
5 i
a.
N45.2.6 Sections 2.2.4, 3.1, and 3.2.2 - Only personnel perfonning NDE (PT, MT, UT, and RT) will be grouped in levels of capability and certified as such.
I
)
b.
K45.2.6 Section 3.2.1 - Potential employees are required to receive a complet'e examination to assure satisfactory physical i
condition, but annual physical excminations are not required.
l The near vision acuity of inspection, examination, and testing personnel will he checked annually by using the standard Jaeggers type chart or equivalent test type.
{
'/B.
J',egulatory Position C1 q
L'-
NRC:
"Although Subdivision 1.2 of ANSI M45.2.6-1973 states that the require-1 ments pronulgated apply during the construction phase of a nuc1 car power 4
plant, these requirements should also be considcred generally applicabic l
to inspection, examination, and testing activities du, ring fabrication i
prior to receipt of items at the construction site and during other phases of plant life, including preoperational and startup testing and the operational phase."
i e
CP&L:
l 1
CPAL personnel performing inspections, ' tests, and examinatiens during fabrication prior to receipt of itens at ESEP during the operating phase-of plant life vill be qualified in accordance with ANSI 545.2.6-1973 wit' the aforenentioned specific exceptions.
l 1
j
, s/ C.
Regulatory Position C2_
h%.
NRC:
Subdivision 1.5 of ANSI N45.2.6-1973 states, in part, "SNT-TC-1A, its l
Supplements and Appendices, are considered applicable for ttie qualification of personnel perforning nondestructive examination operations."
i i
i i
~,
1 ;
l Regulttory Position C2 (contir.ued)
CP&L:
2 I
All perscnnel performing NDE at ESEP will be qualified in accordance with SNT-TC-1A, its Supplements and Appendices.
g/ D.
Regulatory Position C3
,L$.
NRC:
" Item (7) of Subdivision 2.2.4 of ANSI N45.2.6-1973 requires that the The l
' basis used for certification' be documented in an appropriate form.
basis should include both the general educction and experience require-nents, as discussed in Subdivision 3.1, and the specific technical require-l ments, as discussed in Subdivision 3.2.
The specific technical abilities of the person being certified sh-uld be related to the specific assigned
- tasks, e.g.,
electrical inspection, concrete inspection, etc."
J CP6L:
+
The general education and expcrience of personnel perforning inspections, tests, and examinations at BSEP is documented.
(
1 3.#
Regulatory Guide 1.74 (February __1974)
" Quality Assurance Terms and Definitions"
,- et.
s Regulatory Position NRC:
s "The quality assurance terms and definitions contain'?d in ANSI N45.2.10-1973 are generally acceptable for use in describing and implementing quality assurance programs for the design, construction, and operation of nuclear power plant structures, systems, and components subject to the following:
I The definition of ' procurement documents' should be considered i
work l
to include such documents as contracts, letters of intent, orders, purchase orders, or proposals and their acceptances which i
i authorize the seller to perform services or supply equipment, raterial, or facilities on behalf of the purchaser."
i l
CP6L:
l are being The quality assurance terms and definitions of ANSI N45.2.10-1973 complied with for use in describing and implementing the LSEP Cperation and Maintenance Quality Assurance Program.
documents" in the future vill include such l
i The definition of "procurencnt documents as co'tiacts, letters of intent, work orders, purchase orders,.
l n
l
Reculatory Position (centinued) i the seller to perforp or proposals and their acceptances which author zenaterial, or facilities in behalf i
services er supply equipment,
- Quality Assurance Requirements for (March, 1973)
C oled Nuclear Regulatory Guide 1.37 Cleaning of Fluid Systems and Associated Compo 4.
Power Plants" I
Regulatory Position V A.
}.k -
NRC:
f naterials "The requirements and recommendations for en-site cleaning o l c1 caning and layup and components, cleanness control, and preoperationafluid systems t hat are inc of water-cooled nuclear power plant i
d Components ANSI N45.2.1-1973, " Cleaning of Fluid Systems an j
enerally l
acceptable and provide an adequate basis f or comp y nR Part 50."
quality assurance requirements of Appendix L to 10CF l
t
,j
'I CP&L:
l Program Those arcas of the Operation and Maintenance Quality Assurance ents, cicanness f
applicabic to on-site cleaning of materials and compon EP fluid-systems, control, and preoperation cicaning and layup of BS will be in accordance vith ANS1 K45.2.1-1973.
i 1
l Regulatory Position C2 J
B.
(.* -
t states that the requirc-
[
MRC:
"Although Subdivision 1.2 of ANSI K45.2.1-1973 1
h f a nuclear power ments promulgated apply during the construc t-;on p ase i ed in the standard are also appropriate to cleaning of flui
- plant, plant, and they l
components during the operation phase of a nuclear powerIn this regard, how j,
should be should be used when apnlicable. decontamination and cicanup of radioac[
particularly noted thatcontaminated systems and components are not ad d
ii j
ni
}
<> FC g N
o f
CP6L:
i h where applicable will be complied w t The requirements of ANSI N45.2.1-1973 d components during the opeF5Eicns ;
to cleaning of fluid systems and associate phase at USEP.
i 9
I I s o
M
,,_,.,,-,,--,-,-- - ---v n-.
..--n-
,-,,-----_y,.,
/C.
Py ulatory Po Qtion C3_
4
- s..
NRC:
the selection of the 545.2.1-1973 states that i
" Subdivision 3.2 of ANSI d by the organi-water quality for a specific application shall be ma e therwise speci-l zation responsibic for the cleaning operations un ess oThe water quality for final r'
le a t.t equivalent l
fled in the purchase document.
fluid systens and associated components should ce at a:cr."
ta the quality Of tha 0;er2:ir.; sys:c I
CP&L:
i t d The uater quality for the final flushes of fluid systems and assoc a eto the q components at HSEP is at l east equivalcut system vater.
D.-Rer,ulatory Positio.n C4 W-1 NRC:
i states, in part, that low sulfur, low l
"Section 5 of A"SI N45.2.1-1973 i
fluorine, and/or low chlorine cocpeunds nay be used on austenitic sta n-Icu sulfur and Icw lead compounds may be used en ibute to inter-1 css stecis and that l
nickel-base alloys. [Chenical compounds that could contr be used with granular cracking or stresc-corrosien cracking sheuld notExanples of such l
austenitic stain 1cus steel and nickel-base alloys.
fluorides, lead, zine,.
4 s
chemical compounds are those containing chlorides, ble or where copper, sulfur, or mercury where such cler.,ents are leacha d
der expected they could be released by breakdown of the ccmpoun s unThis' limitation is not I
(e.g., by radiation).
he environmental conditionsthe use of trichlorotrifluoroethane which nects t 4
I intended to prohibit 1
ing or requir'ements of Military Specification Mil-C-81302b fo i
f l
J are observed."
I Suodivision 7.3(4) cf ANFI N45.2.1-1973 f.
t t-
,L CP6L:
l Chenical compounds that can contribute to intergranular cracking or I
being_ilsed]in cleaning of F2SEF/are not stress-corrosion cracking at b
lloys. '--
c
.austenitic stainless steel and nickel-ase a
?
/E.
Ecgulatory Position C5 J
l p'.
NRC:
states, in part, that operations such as j
"Section 5 of A"SI N45.2.1-1973 h
ld be controlled.
grinding and. dding which generate particulate tratter s ou i
-7'-
,s
-__.m.-m--
y
.,4 mm
-y
,n
,_-,m_ _.
1 M ule ory Position CS (continued)
Adequate control of tools used in abrasive work operations such as i
- ided, grinding, sanding, chipping, or wire brushing should be prov could contribute to Specificc11y, tools which contain mat'crials thatintergranula because h raterials of previcus usage, may have become contaminated with
~
l Exanples 4."
j of such caterials are listed in Regulatory Position i
4 t
4
]
I 9
4 CP6L:
ld Those tools whose usage generates particulate matter are control e could con-the usage of tools that at BSEP.
Care is taken to prevent king.
tribute to intergranular cracking or stress-corrosion crac 1
F -- Regulatory Position C6 J
l NRC:
suggest s the use of ASTM A 262-6S
" Subdivision 1.4 of ASSI N45.2.1-1973 ion of chromium l
or ASTM A 393-63 for detection of in* ergranular precipitatASTM A 393-63 has bee carbides in corrosion-resistant alloys.
by AST11 and is no longer considered a valid test."
.f J
S CP&L:
p possible inter-When applicable at USEP, AST11 A 26S will be used to detect f
tenitic granular precipitation of' chromium carbides in corrosion-resistant aus
)
steels.
1912)
" Quality Assurance Requirenents for eTT J
V Q.
Regulatory Guide 1.30 (August, Inspection, and Testing of Instrumentation and E the Installation, Ug Equipment" ry, A.
Regulatory Position _
j NRC:
inspection, and testing of nucler..
"The requirements for the insta11ction, which are included in instrumentation and electric equipmentInspection, and Testing Req power plant A"S1 N45.2.4-1972, " Installation, During the Construction of Nuclear Instrumentation and Electrical Equipnent
- 71) are gen-Power Generating Stations" (also designated by IEEE Std. 336-19 l ing with the per-crally acceptabic and provide en adequate basis for comp y 10CFR Part 50."
tinent quality assurance requirenents of Appendix B to r
N 6
M 1
l l
ggulatory Position (continued) j CP6L:
The installation, inspection, and testing of nuclear power plant instrumen-tation and electrical equipment at'3SEP will be in accordance witly the
..cpplicahic requirements of ANSI N45.2.4,-1972 with the following exception--
ANSI K45.2.4, Section 7 states, in part, " Procedures shall be established for processing inspection and test data and their analysis and evaluation."
At BSEP data processing procedures per se have not been developed; instead, test data is recorded, processed, and analyzed in accordance with procedures and instructions in appropriate functional areas, e.g., maintenance, startup, etc.
y 6.
Regulatory Guide 1.38 (March,19731
" Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for k'ater-Cooled Muelcar Power Plants"
(.
--Regulatory Position A.
NRC:
i.
"The requirements and guidelines for packaging, shipping, receiving, storage, l
and handling of water-cooled nuclear power plant items that are included in ANSI N45.2.2-1972, " Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Pouer P1 cats During the Ccnstruction Phase," are generally acceptable and provide an adequate basis for ccmplying uith the pertinent l
,qaality assurance requirements of Appendix B to 10CFR Part 50."
1 t
i j
CP&L:
i l
Packaging, shipping, receiving, storage, and handling of BSEP items are in accordance with applicable requirenents of ANSI N45.2.2-1972 with the following specific exceptions:
I 6
a.
Subdivision 2.7 of ANSI K45.2.2-1972 states, in part, that, 3
"requircraents f or activities covered by this standard (pack-l aging, shipping, receiving, storage, and handling) are divided into four Icvels.
I l
At BSEP a classification system similar to ANSI N45.2.2-197?
I
'.jII has been developed and is fully implemented for the storage activity.
r
( The other activities--packaging, shipping, receiving, and handling--are adequately covered by documented procedures or
) procedures will be developed as required; houever, such pro-( cedures are neither tied to the classification system developed i at BSEP for storage, nor are they tied to the clasnification
' nystem developed in N45.2.2.
(_
~
i l
1 t
t a
t, I
Position (continued) in part, " Appendix
[
~
Regulatory I
- states, available ~iri
' b.-Subdivision 3.1 of ANSI N45.2.2-1972 ally not A-3 contai.s additional rec,uirements generThese requireme of
~
other documents.
d as guidance for l
this standard."
l BSEP Appendix A-3 of N45.2.2 shall be use w; 'tr At i
the packaging activity.
I, B.- -Regulatory Position C2 f
/
t lineates requirements forThis subdiv
{
NRC:
Subdivision 7.3.4 of ANSI N45.2.2-1972 defor special lifts.
load test over the l
re-rating hoisting equipmentre-rated equipvent be given a dynam cIcast equa i
i that i ting equipitent full range of the lift using a test weight atused in temporarily re-rating h in part, i
"The test weight isions of Su for special lifts in accordance with the provequal to 110% of th weight.
should be at least i
lifts at BSEP, is necessary for special for special i
CP&L:
ily re-rating hoisting equipmentf ANSI N Il re-rating of hoisting equipment i
the test weight used in temporar A d>mamic lead test lifts in cccordance with the provisions o1 cast equal to 110%
(
i g a weight at uill be at over the full range of the lift us n ical.
weight will be performed yhere pract 1
position C3 C.
Renula ory t
s its tapes containing not r. ore c.'
NRC:
tact with aus-
)
" Subdivision A.3.5.2 of ANS1 N45.2.2-1972 permof halogens k l alloy surfaces. desiccant bag r.sterials containi than 0.10% by weight tenitic stainless steel and nic epernits desiccants andd'with austen l
i4 "' '
- tapes, ANSI N45.2.2-1972not core than 0.25% halogens to be use i less steel and nickel alloy naterials,t b dd lThen used with austenitic sta n i ing cler it s that could con-desiccants, and the caterials for the desiccanf I
Exampics king or stress corrosion cracking.ntainin j
tribute to intergranular crac or where such elenents are Icachable of such chemical ccmpounds are those co i
zinc, copper, sulfur, or mercury wherekdown of the cor. poun they could he released by breadiation)."
4 mental conditions (e.g., by ra e
9.
mm
-re sm.-
v
+ - - - - - - - - -
.m
l 1
Renulatory Posit ion C3__(continued) l CP&L:
When used uith austenitic stainless steel and nickel alloy materials, j
tapes, desiccants, and the materials for the desiccantsbag will not be compounded from or treated with chemical compounds containing lead, zinc, copper, sulfur, or mercury or more than 0.1 percent (1000 ppm) halogens where such elements are 1cachable or where they could be released by breakdown of the compounds under expected environmental conditions.
i
?
V 7.--Regulatory Guide 1.64 (October, 1973)
" Quality Assurance Requirements
~
0'-
for the Desigi of Nuclear Power Plants" Regulatory Position i
NRC:
l "The requirements and reccmaendations for establishing and executing a quality assurance program during the design phase of nuclear power plants that are included in ANSI N45.2.11 (Draft 3, Rev. 1 - July, 1973) are generally acceptable to the AEC Regulatory Staff and provide an adequate basis for complying with the pertinent quality assurance require..:ents of 4
10CFR5P Appendix B."
j I
CPLL:
Those areas of the Operation ano Maintenance Quality Assurance Program for l
ESEP applicabic to design or modification of the plant are in accordance with the appropriate requirements of ANSI N45.2.11-1974.
The degree to which all of the controls of N45.2.11 arc applied depends en TIE' magnitude i
of complexity and nuclear safety implications of the task at hand.
r I
- g Regulatorv Gipide 1.8 (Safety Guide 8, March 10, 1971)
" Personnel Selection
.. and Training r,
.s y
}:,j7-Regulatory Position l
l '*
t NRC:
j "T1.e criteria for the selection and training of nuclear pouer plant personnel I
contained in ANSI N18.1, " Propose.d Standard for Selection and Training of Personnel for Nuclear Power Plant", dated June 22, 1970, are generally accept-able and provide an adequate basis for the selection and training of nuclear J
power plant personnel.
In some cases, plant design features or unusual operating conditions may indicate that additional or more specialized 4
i expertise is needed.
This determination will be made on an individual case basis.
~~
f 6
i i
=*
1 Regulatory Position (continued) i l
CP&L:
f The criteria for selection and training of personnel for operation o BSEE is addressed in the BSEP Technical Specifications.
1973)
" Quality Assurance Requirements for Regulatory Guide 1.f '. (June, Protective Coatings Applied to Water-Coo f-r-/
J o.Yr(-
A.
Regulatory Position NRC:
i lity "The requirements and guidelin zs included in ASSI N101.4-1972, "Qua l
for Assurance for Protective Coatings Applied to Nuclear Facilities,
I stainless steel, f
protective coatings app 1I9d to ferritic steels, aluminum, f es of water-zinc-coated (galvanized) steel, concrete, or casonry sur acd provide an adequate l
cooled nuclear power plants are generally acceptable anb l
f l
Appendix B to 10f.FR50."
j t
CP&L:
have been The applicable requirements and guidelines of ANSI K101.4-1972 speci incorporated into the appropriate "ac-built" l
In the future these specifications will I
SEP implemented during construction.
be implemented in accordance with the established requirements of t Operation and Maintenance QA Program.
4 Regulatory Pos_ition C4_
/
B, l
NRC:
the NRC Position C4 under this Regulatory Guide is essentially the same as I
i l
NRC Position C4 in Regulatory Guide 1.37 (March,1973).
I t
CP6L:
ide 1.37 l
See the CP&L position under Regulatory Position C4 of Regulatory Gu i
]'
(March, 1973).
1 i
T
)
2 l
l
- 8 I
e
,-r e-,
w w,
1,-
- qg-m,sS
+-
y we-y-w-ume m p-ep w-
i
}
10." Draft Standard ANSI 545.2.9 - Draf t 15, Rev. 0 - April, 1974 (Now Approved Standard ANSI N45.2.9-1974 endorsed by Regulatory Guide 1.88 -
l August, 1974)
"Collectien, Storage, and Maintenance of Nuclear Power.
Plant Quclity Asserence Records" 1
g/
Regulatory Position I'
KRC:
1 "The requirements and reco.nmend'ations for collection, storage, and main-I ten: nce of nuclear power plant quality assurance records that are included I
l in ANSI N45.2.9 are generally acceptable to the AEC Regulatory staff and provide an adequate basis for complying with the pertinent quality assurance l
j requirements of Appendix B to 10CFR Part 50."
4 i
6 1
l CP&L:
I E
storage, and naintenance of QA records at
.l The requirements for collection, j
ESEP vill be in accordance with ANS1 N45.2.9-1974 with the following specific
]
exceptions:
i
)
I 1.
N45.2.9 Section 5.6 states:
"Percanent and temporary record storage facilities shall be constructed or located as to protect contents from possibic destruction by causes such as fire, flooding, terradoes, 4
insects, rodents, and from possible deterioration by a conbinatino of extreme variations in temperature and humidity conditions." Both the j
temporary storage vault and the perranent storage vault at USEP have been specifically designed to protect contents from fire.
These structures have been constructed in accordance with local building codes apd are censidered f
to af ford adequate protection from destruction by other causes such as l
tornadoes.
Protection against possible ficoding conditicns will be pro-l vided by evacuation of vital quality assurance records.
Protection against destruction of records by insects or rodents will be provided through stand-l ard pes't control ceasures.
t
}
2.
ANSI N45.2.9 Section 5.6 indicates that records should be afforded j
the equivalent of a National Fire Protection Association (NFPA) Class A i~
l four-hour minimum rated facility.
i 4
Neither the temporary storage vault nor the percanent storage vault qualify as a four-hour minimum rated f acility.
3
+
The temporary storage _vpult meets the requirements for a two-hour 4
4 facility with the following exceptions:
1 8
The door is a three-hour UL rated fire door rather than a two-t 3
a.
f hour vault door.
(NFPA 232 requires the use of vault-type doors only.)
i j
i i
! l i
n
,m___
,_.._.._,,,,,_,,,.._c_
1 I
t' Regulatory Position (continued) b.
There are wall penetrations for heating, ventilation, and lir,hting.
(UFPA 232 d.es dot allow any vall penet rations.)
Contrary to the requirement of NFPA 232, the walls are not c.
plastered on either side with gypsum or portland cement plaster.
The permanent storage vault neets the requirements for a two-hour d ', #. facility with the following exceptions:
s^
c c
s
.< l ' ,%"",0~
There are wall penetrations for heating, ventilation, and a.
i li ghting.
1 7}
6 b.
The walls are not plastered on either side with gypsum or portland cement plaster.
A llalon fire suppression system and a fire alarm system are installed in both the temporary storage vault and the permanent storage vault.
11aving satisfied all other requirements for a two-hour rated facility and with the installation of the llalon system, these vaults are considered to provide adcquate protection cgainst fire.
g 1973)
" Pre-g.
Ref;u_ latoLy Guide 1.XX (Sow Regulatory Guide 3.68 - November.
operational and Initial Startup Test Programs for Uater-Cooled Power Reactors" i
l Regulator,v Position I) i, NRC:
"Each applicant shall prepare and conduct preoperational and initial startup test programs including the provisions and applicable tests described in this section and Appendix A of this guide, as well as other preoperaticnal and initial startup tests that have been identified in the fincl safety analysis t
l report."
t i
I CP6L:
i
- ~
The CP6L position for ESEP regarding Regulatory Guide 1.68 is included in A
the BSEP FSAR, Section 13.8.3 and in the letter sent by Mr. E. E. Uticy to Mr. E. G. Case dated February 14, 1975.
.s..g s.
\\.M i
.s.
\\..,-
\\
j l
0 db' ti
._, Q u' ~,,
, r.1,cl15 0
.~.
l I
t e.
1 a
i y~
i 12.-- Recui n t ory Cuide 1.39 (March. 19731 "Housekenping Requirements for 1.'ater-Cooled Nuclear Power Plants" Regulatory Position NRC:
I.
"The requirements and guidelines for the control of work activities, conditions, and environnents at water-cooled nuclear power plant sites which are included in ANSI Standard N45.2.3-1973, " Housekeeping During the Construction Phase of Nuclear Power Plant s", ara generally acceptable and provide an adequate basis for ctv Iving vith the pertinent quality
{
assurance requirenents of Appendix S eo '.0CFR Part 50."
e i
CP&L:
The applicabic requiremen'ts of N45.2.3-1973 are followed at BSEP within the context of the established Operation and Maintenance QA Program with
/. 2 L. the following specific exception -the zone designations of Section 2.1 of l*
" ~
N45.2.3 and the requirement s associated eith each zone are considered ippractical for implementation, as stated, at ESEP during the operations phase.
Instead, procedures or instructions for housekeeping activities, which include the applicable requirements outlined in Section 2.1 of N45.2.3 and which take into account radiation control considerations, security considerations and cleanliness requirements are developed on i
a case basis for maintenance or modification work to be performed.
u 13. - ANSI N45.2.5 - Draf t 3. Rev. 1 - January 1974_ (Now approved as ANS1 N45.2.5-1974)
" Suppler.entary Qaality Assurance Requirements for 8
Installation, Inspection, and Testing of Structural Concrete and
,,'r,;.
Structural Steel During the Construction Phase of Nuclear Power Plants" i
CP6L:
vill be utilized as The applicable guidance contained in N45.2.5 - 1974 future structural work is to be perferned which' in the event apgr,op r.i a t e
{.
falls under the established requirements of the BSEP Operation and Main-
,,.i-tenance QA Program.with the following exccption--concrete batch tests M.
g a central described in Subsection 4.8 of N45.2.5 will be performed at
.(N i ies.
a '"
,. location as close as practicable to the actual construction activ t f% (
['
2L
.x
( N ' ',
7 b~
i
%1 '
1
.I i t e
i
-_- -..-_ - - _. _ __. -.--..-. -...~._
- ~
- D
- 9 '-
l i
Page 1 of 3 i
TABLE 17.0-1 j
CONFORMANCE OF DUKE POWER PROGRAMS TO QUALITY ASSURANCE STANDARDS, REQUIREMENTS AND GUIDES Standard, Requirement or Guide Conformance Status Remarks C
1 "p
Regulatory Guide 1.8 - Personnel Selection Conforms RG 1.8 incorporates ANSI N18.1 Duke program b
and Training conforms to ANS! N18.1-1971 rather than the draft 1970 version j
Regulatory Guide 1.28 - Quality Assurance Conforms '
RG 1.28 incorporates ANSI N45.2-1971 O-Requirements for Design and Construction E
Regulatory Guide 1.30 - Quality Requirements Conforms RG 130 incorporates ANSI N45.2.4-1972 for 9
for the Insta.lation, inspection and Testing both construction and operation p
3 of Instrumenta lon and Electric Equipment O
1, j
Regulatory Guide 1.33 Rev (1) - Quality Assur-Conforms RG 1.33 Rev (1) incorporates ANSI N18.7-1976
/
4 ance Program Requ rements (Operations) and ANSI N45.2-1971 Regulatory Guide 1 37 - Quality Assurance Conforms RG 1 37 incorporates ANSI N45.2.1-1973 for Requirements for Cleaning of Fluid Systems both construction and operation x
i and Associated Components of Water-Cooled i
Nuclear Power Plants i
Regulatory Guide 1.38 Rev (2) - Quality Assur-Conforms RG 1 38 Rev (2) incorporates ANSI N45.2.2-l4 l
ance Requirements for Packaging, Shipping.
1972 for both construction and operation g Q g Cin Receiving, Storage and Handling of items for N
Vater-Cooled Nuclear Power Plants
,, k Q p t{q r,
Regulatory Guide 1.39 Rev (1) - Housekeeping Conforms RG 139 Rev (1) incorporates ANSI N45.2 3-l4 g;
7:
h
}
Requirements for Vater-Cooled Nuclear Power 1973 for both construction and operation.
N j
Plants Duke will use Nuclear Mutual Limited gS A i
l standards in lieu of NFPA National Fire Codes where conflicts exist between tne I
two.
f 4
8
\\
Amendment 1
..__.___.__.___-...______.___.__.m m_.__ _ _. _ _ _ _ _
C p
g
.O G
O i
e.
3 l
- i.
Page 2 of 3 I
TABLE 17.0-1 l
Standard, Recuire. ment or Guide Conformance Status Remarks j
Regulatory Guide 1.58 - Qualification of Alternative RG 1.58 incorporates ANSI N45.2.6-1973 for both Nuclear Power Plant inspection, Exam-construction and operation. Duke operational /
ination and Testing personnel functional testing personnel will meet the requirements of ANSI N18.1-1971 rather than ANSI N45.2.6 Regulatory Guide 1.64 Rev (2) - Quality Adopted RG 1.64 Rev (2) incorporates ANSI N45.2.11-1974.
j Assurance Requirements for Design of Nuclear with The use of the originator's immediate supervisor 3
Power Plants Clarification for design verification shall be restricted to special situations where the immediate super-4 visor is the only individual competent to per-6 form the verification. Advance justification for such use shall be documented and signed by a
the supervisor's management, with copy submitted to the quality Assurance Department.
Regulatory Guide 1.70 Rev (1)
. Standard Conforms This topical report conforms to the Chapter 17 Format and Content of Safety Analysis Reports Section of RG 1.70 Regulatory Guide 1.74 - Quality Assurance
. Conforms RG 1.74 incorporates ANSI N45.2.10-1973. Some' l
definitions used by Duke are worded differently Terms and Definitions i
than those in this standard; however, the general meanings are the same Regulatory Guide 1.83 Rev (2) - Collection, Conforms RG 1.88 Rev (2) incorporates ANSI N45.2.9-1974 4
i Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records I
Regulatory Guide 1.94 Rev (1) - Quality Assur-Rev (1)
RG 1.94 Rev (1) incorporates ANSI N45.2.5-1974 j
l ance Requirements for Installation, inspection, Conforms and Testing of Structural Concrete and Struct-I ural Steel During tSe Construction Phase of Nuclear Power Plants RG 1.116 Rev (0-R) incorporates ANSI N45.2.8-1975l 4 f
f Regulatory Guide 1.116 Rev (0-R) - Quality Conforms Assurance Requirements for installation, inspec-tions, ar.d Testing of Mechanical Equipment and Systems i
Regulatory Guide 1.123 Rev (1) - Quality Assur-Conforms RG 1.123 Rev (1) incorporates ANSI N45 2.13-1976 i
ance Requirements for Control of Procurement i
of item and Services for Nuclear Power Plants I
4 I
Amendment 4 4
_.y A
c6-d 0
(
. i.
\\
~
i
),
t t
6 l
Page 3 of 3 TABLE 17.0-1 Standard, Recuirement or Guide Conformance Status Remarks 6
ANS: N45.2.12 - Requirements for Auditing of Conforms Quality Assurance Programs for Nuclear Power 4
Plants (Draf t 3. Revision 4, 2/74)
+
10CFR50, Appendix B - Quality Assurance Conforms Criteria for Nuclear Power Plants 10CFR50.55a - Licensing of Production and Conforms 4
Utilization Facilities (ASME Boiler and Pressure Vessel Code,Section XI, 1971 -
Rules for Inservice inspection of Nuclear Reactor Coolant Systems) i 10CFR50 - operators Licenses Conforms iOCFR55, Appeedix A - Requalification Conforms i
Programs for Licensed Operators of 1
l Prodtetion and Utilization Facilities.
(
,i 10CFR50.55(e) - Conditions of Construction Conforms i
i Permits i
i.
4 j
t e
I 1
i f
Amendment 4 j
l 3
4 t
f.
!t. Lo r. c 1 I In v lb.d t
TOPICAL QUALITY ASSURANCE REPORT APPENDIX C R ev.
4 r v. u.a t'
)
BASELINE DOCUMENT M ATRIX Date March 31,1981 noa,oa co*sa 6 ocar coupaw j?
Page 3
of 17 i!'
]*
Florida Power & Light Company position regarding conflicting guidance and exceptions:
.J
]
lt j.
ANSI N45.2.6-1973, Paragraphs 1.1, 3.1, 3.2.2(a) and 4 (Table-1) identify requirements which 4-1 apply to personnel who perform inspections, tests or nondestructive examinations or who a '
participate in the approval of procedures, the handling of data or test results, or the control of
.i "
reports and records, b-1:.
FPL proposes an alternative to capability requirements for those who participate in: (1) the
]
approval of procedures, (2) the handling of data or test results and (3) the control of reports and i
i records.
FPL accomplishes this by having personnel determined to be qualified and cotopetent by management through consideration of education, training, and experience.
4 W
4 l
The Florida Power & Light Company position on the scope of ANSI N45.2.6-1973 is that personnel participating in testing who take data or make observations, where special training is j
not required to perform this function, need not be qualified in accordance with ANSI N45.2.6 1i but need only be trained to the extent necessary to perform the assigned function.
i.
t For operational tests performed by operating personnel, FPL considers that training and
(
]
qualification to the requirements of ANfI N18.1-1971 are equivalent to ANSI N45.2.6 and that s
F qualification to ANSI N45.2.6 is unnecessary and redundan t.
Operational tests will be i
supervised by qualified testing personnel.
I i
Regulatory Guide 1.70.6, Paragraph 17.1.12 states that the "PSAR should describe the measures which assure that the error of calibration standards is less than the error of production I
measuring and test equipment ' For projects with limited work authorizations for construction L
and for plants with operating licenses prior to May,1976, FPL has chosen an " equal to or better" requirement for calibration standards as stated in TQR 12.0.
)
i 4.
' TOPICAL QUALITY ASSURANCE REPORT APPENDIX C g,16 W u g('g R ev.
4 pm P
~6 Date
__h_f ar.ch 31,E8_1_
stoa o acw a s tic r ceI,.u B ASELINE DOCUMENT M ATRIX Page 4
of
}7 ANSI N45.2.9-1974 ANSI N45.2.9-1974, Section 3.2.5 requires Quality Assurance records be classified as lifetime or non permanent and further defines lifetime and non permanent in Section 2.2 of the Standard.
FPL provides the following definitions as an alternative to the above.
Lifetime Records: Records which are required by the NRC facili+y operating license, the NRC construction parmit, applicable parts of 10CFR, the FSAR, or oti er NRC commitments to be retained for the life of the plant.
Non permanent Records: Records which are required by the NRC facility operating license, the NRC construction permit, applicable parts of 10CFR, the FSAR, or 3ther NRC commitments to be retained for periods of time less than the life of the plant.
ANSI N45.2.9-1974, Paragraph 5.6 requires that records he "classi fied for fire protection purposes as National Fire Protection Association Class I and, as such, should be afforded the equivalent protection of a NFF A Class A, four hour minimum rated facility." FPL will meet the requirements of the NFPA Code, utilizing those portions which indicate that insulated protection eqiiipment with a rating below Class A may be used if certain building and occupancy conditions are met.
(
l ANSI N45.2.10 - 1973 A NSI N4 5.2.10 - 1973 iden tifies terms and their de finit ions important to the uniform understanding of the intent of required quality assurance practices for the construction of I
nuclear power plants. Regulatory Guide 1,74 (2-74) endorses these terms and definitions and extends them through the operational phase and includes a clari fica tion of procurement documents.
I FPL has developed a glossary of terms and their definitions as part of the Quality Assurance Manual which is being used throughout its nuclear construction and operating plant activities.
~
~
TOPICAL QUALITY ASSURANCE REPORT APPENDIX _C g s.% 4 R ev.
4
-?
rw %g s....
Date _%geb_31,1981 BASELINE DOCUMENT M ATRIX
~-
8 LCRiO A PO*te & LICHf COVP ANY Page 5
of 17 The following de finitions are currently listed in our glossary and are alternatives or clarifications to those listed in the ANSI Standard and Regulatory Guide:
Asse mbly A combination of subasse mblics or components or both, fitted together to 9 rm a workable unit.
Audit A docum ented activity perf or m ed in accordance with writ ten procedures or checklists to verify, by examination and evaluation of objective evidence, that applicable elements of the quality assurance progra m have been developed, documented and effectively implemented in accordance with specified requirements. An audit does not include surveillance or inspection for the purpose of process control or product acceptance.
Guidelines Particular provisions which are considered good practice but which are not mandatory in programs intended to comply with Standards.
The term "should" denotes a guideline; the term "shall" denotes a requirem ent; and the word " m ay" denotes p er m ission, neither a requirement nor a recommendation.
Inspec tor (Owner's or Installer's)
A qualified inspector employed by the Owner or Installer, whose duties include the verification of quality related activities on inst allations.
Inspec tion Examination, obse rv ation, or measure ment to determine the conformance of ma terials,
- supplies, components,
- parts, appur ten anc es, systems, processes, or structures to predetermined require m en t s.
TOPICAL QUALITY ASSURANCE REPOfkT APPENDIX C
]
I 2
I"N Q %,... h 2
a -
r BASELINE DOCUMENT M A'i4UX Date March 31,1981, uoaio* co* a s ucar coue m Page 6
of 17 Procurem ent Documents Contractually binding docum en ts, including such documents as contracts, letters of intent, work orders, purchase orders or proposals and their acceptances which authorize the seller to perform services or supply equipm ent, ma terial, or facilities on behalf of the purchaser.
Qualification (Personnel)
The characteristics or abilities gained through training or experience or both as m easured against established requirem ents such as standards or tests that qualify an individual to perform a required function.
Quality Assurance All those planned and systematic actions necessary to provide adequate confidence that a structure, sy stem or component will perform satisfactorily in service. Quality Assurance includes quality con trol.
Quality Control Those quality assurance actions related to the physical characteristics or material, structure, component or system, which provide a means to control the quality of the material, structure, component or systern to predetermined requirements.
Storage That period following the release of an item for shipment until turnover for start-up preoperational testing. This would include in-place storage.
Syste m An integral part of a nuclear power plant comprised of electrical, electronic, or mechanical components (or combinations thereof) that may be operated as a separate entity to perform a specific function.
4
!^
' TOPICAL QUALITY ASSURANCE REPORT APPENDIX C 9
R ev.
4 l
j
[
.R
"'R j
Date March 31,19R BASELINE DOCUMENT M ATRIX 8tCA10A Powim & LeCMT COMPAM
]
Page 7
of 17 t
i Testing Performance of those steps necessary to determine that systems or components function in accordance with predetermined i
specifications.
4
" Requirements" Clarification for Glossary REOUIR EM ENT:
A mandatory action, denoted by the word shall. (See " Guidelines")
Requirements are generally based on statutes or regulations, but may be internally generated within the company. "Shall" is therefore used for both exte rnal, legally enforceable actions and internal requirements not enforceabla under current NRC practices.
ANSI N45.12, Draf t 3, Rev. 4 ANSI N45.2.12, Paragraph 3.4.2, requires that " applicable elements of the Quality Assurance Program shall be audited at least annually or at least once within the life of the activity, whichever is shorter."
ANSI N18.7-1972, Paragraph 4.4 (endorsed by Regulatory Guide 1.33) states in part; " Audits of selected aspects of plant operation shall be performed with a frequency commensurate with their safety significance, and in such a manner as to assure that an audit of safety related activities is completed within a period of two years."
FPL has chosen a two year cycle for auditing elements of the internal and on-site QA Prograrn during the operation phase of plant life following initial fuel loading. FPL's position is that the two year cycle: (1) allows more in-depth and meaningful audits in each regularly scheduled area, (2). permits more audits of ongoing activities, and (3) in conjunction with the planning and scheduling requirements of TQR 18.0 provides for a comprehensive audit program. The audit f req sency requirements of ANSI N45.2.12 will be followed during other plants' phases.
In the case of suppliers, an annual evaluation of quality performance history shall be perforrned to determine reaudit requirements. Reaudit requirements for suppliers shall be based on the quality performance, and the complexity and criticality of the equipment or service being
TOPICAL QUALITY ASSURANCE REPORT APPENDIX C _
R ev.
4 __ _
PA E(m e
....?
Date _paych 3,1,1931, B ASELINE DOCUMENT M ATRIX e caica co*o a uc.o cou,w, Page
_3 of _}7
]
W procured.
A facility evaluation (audit) will be performed at least every three years and conducted in accordance with Quality Proc edures and Ouality Instructions for supplier evaluation.
ANSI N45.2.12, Paragraph 4.3.1 states: " A brief pre-audit conference shall be conducted at the audit site with cogniz$ tnt organization management. The purpose of the conference shall be to confirm the audit scope, present the audit plan, introduce auditors, meet counterparts, discuss audit sequence and plans for the post-audit conference, and establish channels of co m munica tion." FPL will not require the pre-audit conference for audits of limited scope and of specific site activities conducted by the Construction and Operations Groups.
This conference is omitted because the day-to-day contact of the auditors and plant management, the awareness on the part of plant management that these audits are conducted without pre-audit con fe renc es, and the limited scope of the audits meet the intent of a pre-audit conference.
ANSI N45.2.13-1976 ANSI N45.2.13-1976 Section 1.3 provides a definition of " procurement docu m en t" which is different from the definition contained in ANSI N45.2.10-1973 and Regula tory Guide 1.74. The Florida Power & Light (FPL) Quality Assurance Program uses the definition of " procurement document" contained in ANSI N45.2.10-1973 as modified by Regulatory Guide 1.74.
ANSI N45.2.13-1976 Section 3.3.a requires that procurement documents be reviewed prior to release for bid and contract award. The FPL Quality Assurance Program requires procurement document reviews prior to bid and contract award for all safety related purchases with the exception of these accomplished by " Confirming Purchase Order".
A " Confirming Purchase Order" is an order which is initially placed verbally with the supplier and then later confirmed with a written Purchase Orde r.
A " Confirming Purchase Order" is only used when time restrainsts would prohibit the normal review and approval cycle. The following controls are provided in the FPL Quality Assurance Manual to assure that the intent of ANSI N45.2.13 is satisfied for " Confirming Purchase Orders".
.. _ ~.. _
f isPPENDIX C TOPICAL QUALITY ASSURANCE REPORT.
~
- M6 b
fM Date March 31,1981 N
BASELINE DOCUMENT M ATRIX 8402:0& POWER & LIGHT COMPANY 2
Page 9
of 17 li i
i j
(1)
Quality Assurance must be contacted prior to contacting the supplier to place the order r
j unless it is an emergency purchase af ter normal working hours in which case Quality
)
Assurance is contacted the next working day.
1 j
1 (2)
Prior to verbally placing the order, it must be verified that the intended supplier is on the f
FPL Quality Assurance Approved Supplier List.
i i
i
{
' (3)
The verbally placed order must be promptly followed-up (confirmed) with a written
,i l
procurement document which is subject to all reviews and approvals required for safety related purchases.
t ANSI N45.2.13-1976 Section 1.1 states that the extent to which the individual requirements of 4
this standard will apply will depend upon the nature and scope of the work to be performed and I
the required quality of the items or services purchased. For commercial grade items, FPL has 1.
determined that certain of the individual requirements of ANSI N45.2.13 need not apply.
Commercial grade items are those (1) not subject to design or s ecification requirements that j
are unique to facilities or activities licensed by the NRC, and (2) used in applications other than facilities or activities licensed by the NRC, and (3) to be ordered from the manuf acturer/ supplier on the basis of specifications set forth in the manufacturer's published I
product description.
These commercial items are subject to varying degrees of control as Indicated in the FPL Quality Assurance Manual.
-j As a minimum, an evaluation is performed by qualified personnel to assure that the commercial i
item satisfies the necessary technical and quality requirements and the item is checked upon f
receipt to assure that the item received was the one ordered, damage was not sustained during i
j shipment, and documentation, if required, was received.
1 Section 8.2 of ANSI N45.2.13 identifies those nonconformances which shall be submitted to the j
Purchaser.
i i
j Florida Power & Light's (FPL) position regarding the nonconformances to be re-"rted is as follows:
1 TOPICAL QUALITY ASSURANCE REPORT APPENDIX C s
R ev.
4
. nr - --
g Date March 31,1981 N
BASELINE DOCUMENT M ATRIX i
l nea.o rowin 6 ocar car.~v Page 10 of 17 1
1 1
Suppliers (including A/E's and Contractors) shall submit all nonconformances which consist of one or more of the following:
i 1)
Technical or material requirements are violated.
2)
Requirement in supplier documents which have been approved by the Purchaser is violated.
3)
Nonconformances which would affect the quality of the item in regard to function of safety related features. In cases where the supplier cannot make this determination, i
they shall be submitted to the Purchaser for evaluation.
1 l
l nis policy assurcs that all nonconformances affecting safety related functions will be reviewed
)
and approved by FPL.
In all cases, the supplier's documentation on nonconformances is available for FPL's review.
]
ANSI N45.2.4-1972, Paragraph 2.5.2 requires that equipment be " suitably marked to indicate i
date of next required calibration". In lieu of rnarking equipment, FPL has chosen to control
)
calibration of installed instrumentation and control equipment by maintaining records for each piece of equipment by instrument tag number (or equivalent) to show that established schedules and procedures for calibration have been followed.
J
+
ANSI N4 5.2.11-1974 ANSI N45.2.11-1974, Paragraph 11.4 requires that " audits shall include an evaluation of design f
quality assurance policies, practices, procedures and instructions...." FPL's design quality assurance (and all other QA elements) policies, procedures and instructions are included in FPL's 4
Quality Assurance Program documentation. The Quality Assurance Department evaluates all of this documentation in reviews performed during its development and revision. Accordingly, FPL J
i j
does not require subsequent (and redundant) evaluations of these Quality Assurance Program policies, procedures and instructions during audits. FPL audits will include evaluations of the l
adequacy of the practices which are the implementation of these policies, procedures and instructions.
A
APPENDIX C TOPICAL QUALITY ASSURANCE REPORT 4%
R ev.
4 mg r
a If fb Date _ parch 31,1981 BASEUNE DOCUMENT M ATRIX 8tCa Ca 80wta L LiGMT CCMPANY Page 1I of 17 ANSI N45.7. 2-1972 ANSI N45.2.2-197 2 Sec tions 3.0, 4.0, and the Appendix address all the requirements applicable to the packaging and shipping of material. FPL in general does not package or ship material governed by this standard. Suppliers of material are required by purchase order to provide adequate packaging and shipping protection. Isolated cases of material packaging or shipping are treated on a case-by-case basis and receive protection comparable to that required by the manuf acturer of that material. Loading, rigging and handling precautions identified in Section 4.3 are applied to material unloaded by FPL from a transport vehicle.
ANSI N45.2.2-1972 Section 5.2 requires that specific attributes of material and components received by FPL be inspected. For plants with operating licenses FPL verifies conformance to procurement docurnents during receipt inspections. Any of these attributes identified in these procurement documents are verified during this inspection.
ANSI N45.2.2-1972 Section 2.7 requires that items governed by this standard be classified into one of four levels by the buyer or the contracter. For plants with operating licenses, FPL intends to consider what care is appropriate for each item individually rather than generically classifying the material into protection leve's and providing care required of that level. The following shall be considered when determining the handling, storage, and shipping require m en ts:
1.
The vendor's recommended handlir.g, shipping, and storage standards.
2.
Environ m ental requirem ents which may include such requirem ents as inert gas atmosphere, humidity limits, temperature limits, chemical requirements, acceleration (g force) requirem ents.
3.
Special tools or equipment which are provided and controlled as necessary to ensure safe and adequare handling. These tools or equipment shall be inspected and tested at specified times to verify that they are adequately maintained.
4.
Packaging, covering or coatings required D meet environmental requirements such as barrier and wrap material, desiccants, pipe caps, plugs, contact preservatives, etc.
y TOPICAL QUALITY ASSURANCE REPORT APPENDIX C f!MS
,u g 2 Rf. y n ev.
4
>^
"W i
m
~.[J{,
Q:
fu
^ -
M^tCh 31819E 13 ASELINE DOCUM ENT M ATRIX stoa.o.,o m a s t,:,,,
Page
_1Lof _1 5.
Container, crating, skids of sufficient strength to support the item (including stacking).
6.
Cushioning, blocking, bracing, and anchoring to pr, vent movement during shipment or handling.
7.
Special handling or storage procedures for unique situations.
8.
Marking and identification if item and its packaging.
9.
Anticipated " shelf life" of the item.
FPL considers this to be a more effective approach since the quantity of spare and replacement m a t erial, parts and components governed by this standard will be afforded protection commensurate with the recommendations of Section 2.7 of this standard.
ANSI N4 5.2.2-197 2 paragraph 6.4.1 requires the periodic verification of such items as identification and markings,'r rotective covers, coating and preservatives, desiccants, (and inert gas blankets, etc. In lieu of addressing these specific items, FPL (at plants under constructich) considers all the necessary prevention maintenance require m en ts for equipment and/or components on a case by case basis.
ANSI N45.2.2-197 2 Section 5.2, paragraph 5.2.1, requires certain preliminary inspections to be done " prior to unloading" or material which is received. We believe that the sequence specified in the standard is to facilitate commercial claims, and should these preliminary inspections occur "af ter unloading" that control of materials quality would not be degraded. Accordingly, required shipping damage inspections may be performed af ter unloading.
ANSI N45.2.2-1972, paragraph 7.4 requf *es that an inspection program be established for handling; equipment and rigging, including methods for identifying acceptable and nonconformi'g items. In lieu of having a program of periodic, documented inspections of rigging and handling equipment, FPL's practice is to have the iadividual user determine the equipment's acceptability prior to each use.
This prior to use inspection is exactly the same as that required during periotic insputions, and uses criteria identified in ANSI N45.2.2-1972, paragraph 7.4.
This practice also precludes the need for a system to indicate th-acceptability of rigging and
TOPICAL QUALITY ASSURANCE REPORT APPENDIX C Date _Ma rch,31,1981 B ASELINE DOCU MENT M ATRIX etca.o owia a tic, coveau Page 13 of 17 handling equipment. Implementation of this prior to use inspection will be assured through periodic surveillances and audits performed by Cuality Assurance and Quality Control. Cranes are inspected on a periodic basis and will be subjected to this prior to use inspection.
Certain mechanical components of the PSL-2 nuclear unit have been dasigned for a service environment of the site area because portions of the plant are exposed to the temperature, humidity, and ocean salt spray during operations. Extreme air temperature variations, snow or slush are not encounte. ed during operations or in the out-of,loors storage environment. As an 1
alte.nadve to th a rigic requirements of storage Icvels B and C in paragraph 6.1 of ANSI M4 5.2.2-197 2, FPL proposes to store these particular mechanical components outdoors, but within controlled areas, with sufficient periodic surveilla. ices and inspectiens to minimize the possibility of damage or lowering of quality due to corrosion, contamination, deterioration, or physical damage. In cases where special environmental conditions are present (i.e. hurricanes, paint sprays, concrete pours, etc.) precautions or additional steps will be taken to further protect 'he items.
Regulatory Guide 1.33 (Dated 11/3/71)
Appendix A of Tlegulatory Guide 1.33 lists " typical safety related activities which should be covered by
."ri t t en procedures".
Regula tory Guide 1.33 is invoked by the Technical Specifications at FPL Nuclear Plants.
In order to avoid duplicatio-f requirements invoked in our licensing documents, the FPL Quality Assurance Program does not list those required operating procedures specified in Appendix A.
L 8
~
APPENDN C
- TOPICAL QUALITY ASSURANCE REPORT d!/,9
$",1 I im[',k-n ev.
4
'[fr ma a
-I caie March 31,1981__
[f"'
haw B ASELINE DOCUMENT M ATRIX ncaioa coat a 6 oc d c0*'
p,ge 14 of 17 Regulatorv Guide 1.8, Rev.1, ANSI N18.1-1971 ANSI N18.1 describes the training and education requirements for plant staff positions and is endorsed by Reg. Guide 1.8 with an exception. That exception is the requirements for the Supervisor - Radiation Protection. ANSI N18.1 is invoked by Technical Specifications (Appendix A of the Facility Operating License) at FPL nuclear plants. Reg. Guide 1.8 is also invoked by Technical Specifications at our St. Lucie plant and a license amendment has been approved for our Turkey Point plant to specify the Health Physics Superviu qualifications addressed in Reg.
Guide 1.8.
To avoid duplication of requirements, FPL will address Plant Staff Qualifications in only the Technical Specifications.
ANSI N18.7 -197 2 A NSI N 18.7-197 2, Sec tions 4.2.2.1, 5.3 and 5.5 requires that personnel performing the independent review and audit be specified in number and technical discipline. Tnis standard is invoked by the Technical Specifications (Appendix A of the Facility Operating Licenses) vhich have been approved for the FPL nuclear plants at St. Lucie and Turkey Point. Specifically this function is performed by the Company Nuclear Review Board (CNRB) identified in Section 6.5.2 of the Technical Specifications.
l To avoid duplication of requirements, FPL will address the personnel and functions of this i
independent review and audit only in the Technical Specifications.
ANSI N45.7.1-197 3 ANSI N45.2.1-197 3 para >;ra phs 7.2.2, 7.2.3, and 7.3 address specific cleaning methods (Alkaline, Chelate, Acid) and make recommendations associated with several types of cleaning methods.
FPL's OA manual does not specifically delineate these paragraphs. However, the procedure developed per paragraph 2.2 of ANSI N45.2.1 will ensure that any specific cleaning method chosen will be properly considered and controlled.
l
TOPICAL QUALITY ASSURANCE REPORT APPENDIX C p
-r - 4 qp[
dev.
4 e
Y Date March 31,1981 BASEllNE DOCUMENT M ATRIX stonion no*ia a ocar cowaw Page 15 of 17 l
l ANSI N45.2.1-1973 paragraph 5 states in part that, " Fit'ed and tackwelded joints (which will not l
be immediately scaled by welding) shall be wrapped wit'; polyethylene or other non-halogenated
{
plastic filtn until the welds can be complcted". The FPL QA Manual shall require that the weld 1
j be covered to prevent entry of moisture and contaminants but will not specify the material to j
be employed. Materials employed to cover openings shall meet the requirements of Regulatory j
Guide 1.37, position 4.
]
ANSI N45.2.1-1973 paragraph 7.1 states in part, " provisions shall be made to collect leakage and I
protect insulation from being wetted".
FPL Quality Assurance Program includes the above f
r 5
i require ments. However, FPL's program allows the wetting of metallic type insulations which are not adversely affected by wetting.
I.
i For FPL's operating nuclear plants, alternative methods are followed to achieve equivalent objectives for the below listed sections of ANSI N45.2.3-1973:
The zone designations of Section 2.1 of N45.2.3 and the requirements associated with each j
zone are not consistent with the FPL IIousekeeping requirements at our operating nuclear units. In lieu of the zone designation, cleanliness is maintained at a level consistent with the work being performed, so as to prevent the entry of foreign material into safety j
related systems. Documented cleanliness inspections are performed immediately prior to
]
system closure. Control of personnel, tools, equipment, and supplies is established with j
approved procedures when the safety function of a system, component, or item may he l
jeopardi::ed and also while the reactor system is opened for inspection, maintenance, or l
repair.
ANSI N45.2.4-1972 paragraph 2.3 addresses installation specifications and requires the inclusion i
I j
of inspection and test objectives. FPL maintains that test values and inspection scope are inherently contained in the applicable procedures.
I i
i APPENDIX C
~ TOPICAL QUAll7V ASSURANCE REPORT of R ev 4
N "WQ} C i' X-
^
W'
-W d... ?
A rd Date
}iay,ch 31,1981 aca o co ia s uc, cob,a,,
BASELINE DOCUMENT M ATRIX Page 16 of 17 ANSI N4 5.2.4-1972 paragraph 6.1.2 requires that the inspection of installed equipment verify that " good and proper workmanship" has prevailed. FPL maintains that acceptable parameter compliance with codes and standards along with company preference is the verification of " good and proper workmanship".
ANSI N4 5.2.S-1975 ANSI N45.2.8-1975 paragraph 4.6 addresses care of items to the extent that temporary use of equipment or facilities to which the standard applies that are to become part of the completed project may he desirable.
The following clarification applies to the above statement. For FPL plants in the construction phase (to the point of plant operation license) temporary use of equipment and facilities may be used according to need and/or situation. In this case, authorization for usage shall be provided along with all the documents, conditions, safeguards and evaluations to verify permanent plant equipment adequacy.
In the operations phase all equipment, including temporary equipment, is subject to identical contro!s to preclude adverse effects on safety and suitability for use.
ANSI N45.2.8-1975 paragraph 2.3 requires that Measuring and Test Equipment (M&TE) used for inspection be identified on the Inspection Report. FPL may, as an option, employ a M&TE issue log which provides traceability between M&TE and the applicable inspections.
Planning Clarification ANSI N45.2.4-1972 paragraph 2.1; ANSI N45.2.6-1973, paragraph 2.1; ANSI N4 5.2.13-1976, paragraph 7.2; ANSI N18.7-1972, paragraph 5.1.6.3; ANSI N45.2.S-1975, paragraph 2.1 and paragraph 2.2 include plans and/or planned as required.
The terms plan and/or planning are included in FPL's activities as indicated in the following clarification:
1 TOPICAL QUALITY ASSURANCE REPORT APPENDDC C R ev.
4 BASELINE DOCUMENT M ATRIX Date March 31,1981 Page
_17 of _ 17 Planning is considered to be a management process or analytical tool used as an aid to help develop identification and/or development of program require men ts, implementation activities, assignments and staffing, inspections, surveillances and audits, controls and other activities to assure completeness of the requirements. Planning, as such, is not always documented nor addressed as an end item and is considered to be an integral
" process" within the developed item.
Plans which are considered to be end type or output type documents have the term " plan" in the title, such as ISI Master Plan, Audit Plan, Start-up Plan, and others, which as such will reflect directly the requirement of these standards in the appropriate documents.
Plans which are not considered to be end type or output type documents do not have the word plan in the title. However, certain procedures, instructions, flow charts, schedules and checklists may be considered to be plans reflecting planned actions which especially require step-Ly-step accomplishments. In these cases, :he term plan may not appear in i
the title but considered to be a plan only in the indirect sense and identified as a j
procedure or other document. FPL considers the above practice to be in compliance with the " plan" requirements of these standards.
Regulatory Guide 1.68 (11/73)
Regulatory Guide 1.68 (11/73) entitled "Preoperational and Initial Start-up Test Programs for Water Cooled Power Reactors" is addressed in Section 14.2.1 of the St. Lucie Unit 2 FSA which states in part, "The start-up test program is developed using the recommendation of Regulatory Guide 1.68".
To avoid duplication of requirements, FPL will address Regulatory Guide 1,68 in the FSAR.
l JJ
m
( e c.
l.
L.
s.
!!NP-2
),,..
i YSAR l l, 6 - I--
l S
APPE!? DIX A c
t-Fcr ulatc-Guide 1.28 - Quality /.ssprance Progrco Recuirenents Construction t
ID72)
Conforr.inin The Georgia Power Company Quality Assurance Program compljes with this Guide.
l The QI. Program is described in Section 17, of the FSAR and is implemented through the requircuents of the QA manual' and detailed work procedures.
l l
\\
l I
1 1
/
t s.
I e
P.
H v
A.1.28-1
in:P-2
=
FSAR 9
2 APPEl: DIX A s
R l
_fau atory Guide 1.30 - Quality Assurance Requirements for the Installation, l
Ins.pection and Testing of. Ins _trucentat_icn_c.nd. El_entr.ic Equir.=ent. (6/1117.2) g I
C n.f_e_rngnee j
4 HI?P-2 conforcs to this Guide as discussed in Chapter 8 c bsectfen 8.3.1.3.
u m
.g l
.e, 4
- j.,i l-Ii a
a b) 1 I
J 4
4 1
)
1 L
l I
?
I I
t I
i I
A.1.30-1 L
HNP-2 FSAR Regulatory Guide 1.33 - Quality Assurance Progra: Reauiretants (Operation)
Confortance (11/3/72)
Con f o rrance 21 35 GPC has chosen to use ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Pcwer Plants," instead of ANSI 31 N18.7-1972.
With one exception, the QA Program complies with this regulatory 18 3
guide as addressed in FSAR Section 17.2.
I Exception is taken to Paragraph 5.2.16 "1basuring and Test Equipment" of ANSI N18.7-1976 requires " equipment be suitably carked to indicate calibration status."
Installed process instrua3nts at Plant Hatch are identified by uniqu 38 instruzent numbers.
These instrument n mbers are traceable to calibration schedules and calibration records.
The,a instruments are not tagged or
\\
labeled with the date due to next calibration.
9 Arend. 38 10/77 f
Amend. 35 7/77
\\-
Arend. 31 1/77 Arend. 21 4/76 A.l.33-1
Y V
Regulatory Guide 1.37 - Quality Assurcnce Renuiretents fo-Clenninc of Fluid
{ys t ens r.nd Accocia ted Co:.ponents of 1.'a t er-Cooled ;;uclear Po.:er Plan t s (3/16/73l Conformance ne quality assurance requirements of this Guibh and of its basic reference,
/J SI !;45. 2.1-19 73, are being folicwed; thus, In;P-2 is in conformance with this Guide.
\\m l(
O 9
- +
e t
\\
A.l.37-1
liNP-2 FSAR APPEN. DIX A Reculatorv Guide 1.38 - Ouality Assurance Recuircrents for Packacingl Shipping, Receiving, Storage and Handling of Itecs for Water-Cooled Nuclear Power Plants (3/16/73) t.. '..
Conformance
-k~
During plant construction the intent of the basic reference for this l3;
'. 'c Guide, N. 4 5. 2. 2-19 72, is being followed; thus, iciP-2 is in conformance ii..
with the intent of this guide.
Folleving receipt of the operating licente,15P-2 will cc.cply with
~
E' this guide and ANSI N45.2.2-1972.
t t
Amend. 31 1/77 A.1. 3 8 Amend. 21 4/76 L
lisp-2 j
~
PSAR i
i j
APPL.!; DIX A q
RcJ2]latory Guide _1.38 - Opality Assurance Requirements for Packaning,
_SltPping uReceivingt_Sto. rare and_Iland.linn of Items for k'ater-Cooled _
i
!!uclear Power Plants (3/16/73)
Confom anc3 The intent of the basic referenc.' for this Guide, N.45.2.2-1972, is being followed; thus IC?P-2 is in conformance with the i_ntent of this Guide.
8 It t
\\
s f.
I 4
y 4
4 S
d M
J
)
9}
A.1,38-1
HNP-2 FSAR APPENDIX A Regulatory Guide 1.39 - Housekeeping Requirecents for k'ater-cooled Nuclear Power Plants (2/16/73)
Con fo rmanc e HNP-2 utilizes this guide as the basis for housekeeping at the RSP-2 construction site.
The QA field repre'sentatives audit to the requirenents 21 in this guide.
21 During tajor modifications or additions af ter receipt of the or.erating 31 license, this regulatory guide will be usW housekeeping requirements.
\\
.~
Arend. 31 1/77 A.1. 39-1 Arend. 21 4/76
J%
IINP-2 FSAR APPENDIX A Perulatory Guide 1.54 - Quality Assurance Requirements for Protective.
Coatings' Applied to k'ater-Cooled Nu~ clear Power Plants
?
(6/73)
Conformance The quality assurance requirements for protective coatings used in the pri-c.ary containment, as discussed in Subsection 3.8.2.7, meet the requirements of this guide except that ANSI N45.2-1971 listed in Regulatory Position c.1 22 was not used in conjunction with ANSI N101.4-1972.
l I
During cajor modifications or additions following receipt of the operating If cense, this regulatory guide vill be used for protective coatings applied inside the primary containment.
31 t
t I
k
~
l Amend. 31 1/77 Amend. 22 5/76 s.s. _
A.I.54-1 i
t
. ),.
10;P-2 FSAR APPENDIX A Regulatory Guide 1.58 - Qualifications of Nuclear Power Plant Inspection, Exa=ination, and Testing Personnel (8/73)
Conformance i
38 Incpection, exacination, and testing personnel used on liNP-2 for 21 safety-related systets and equip =ent following receipt of the cperating license will teet the requirements of ANSI N45.2.6-1973.
l31l38
\\
Acend. 38 10/77
(
A=end. 31 1/77 Amend. 21 4/76 A.1.58-1
l itNP-2 FSAR
\\
APPD; DIX A j
ri pulat ory Cuitle 1.64 - Qualf tv Anr urance Prorrari nequiretents for l
the Design of I:uclear Power-Plants (10/73)
)
{*
Confornance i
'n.e Georgia Power Corpany conplies with this Guide.
The QA Program for
}
design is inplemented through the require =nts of the QA !!anual of Cecrgia J
Tower Coepr.ny and the QA l'anual and detailed procedures of the architect-j engineer.
I 1
,i i
3
?
f i
A e
S gb A.l.64-1
HNP-2 FSAR APPENDIX A
~
Regulatory Guide 1.74 - Quality Ass'urance Terns and Definitions (2/74)
Conformance The quality assurance terns and definitions used in the Georgia Power Company, Southern Services, Inc., General Electric Co=pany, and Bechtel Power Corporation quality assurance programs are generally in agreceent with ANSI N45.2.10-1973 and therefore satisfy the intent of this guide.
~$
The quality assurance program for plant operations following receipt 3
of the operating li g li comply with this guide.
\\
l 1
1 A.1.74-1 A=end. 21 4/76
i j
11?;l - 2 FSAR I
APPFJ: DIX A P$Eulatory Cuf de 1.88 - Collecth Storage _, and ?!aintenance of trucicar hwer Plant Quality I.ssurance Pecords (8/74)_
i Conformance l
imp-2 conforts to the requirements of thi.e Guide.
1 a
\\
\\
.i O
e
\\]o
.?
A.l.88-1
{
EF
- 1. l w c i s, e
_\\ l s C.
\\.
3
(
i V (*
\\,.,
i QUAL.1TY ASSURANCE PROGR/J! REQUIR12!ENTS (DESIGN AND CON 1.28 (Revision 0; 6/.72) /
l The Virgil C. Cuenner Nuc1 car Station conplies with the reconcaendations T
of this guide as described in Section 17.1 and as discussed beloO.
l L-..__ d the cotamitments concern safety related equipment; It should be noted that the commitment to ANSI M45.2-1971, Section 2 " Quality Assurance Program,"
~
covers "The Importance of Palfunction or Failure of the Itern to Plant l
Saf ety," but the Virgil C. Summer Nuclear Station takes exception to the incorporation of reliability requirements within this scope and the cormitment does not extend to "The Importance of Italfunction or Failure of the Item to Plant Reliability." _
l l
\\,.
/
1 I
1 1
l
+
e f'd 3A-34 e+m,e
+e, e
u w
- W*
9
1.30 QUALITY ASSURANCE REQUIRDfENTS FOR Tile INSTALLATION, INSPECTION AND TESTING OF INSTRUMENTS AND ELECTRICAL EQUIPMENT (Revision Ib 8/72) i Virgil C. Summer Nuclear Station complies with the recommendations of Regulatory Guide 1.30.
Quality assurance programs are described in Chapter 17.
1 For clarification of the Westinghouse scope in regard to Regulatory I
Cuide 1.30, the following is provided.
For those Westinghcuse activities performed after September 1, 1972, l
Westinghouse follows the guidance of Regulatory Guide 1.30.
For those
(
Westinghouse activities perforced prior to September 1,1972, the WestinghouseOualityAssuranceProceduresemployedint!)kdesignofthe Virgil C. Sucmer Nuc1 car Station may vary in detail from the position of
(
Regulatory Guide 1.30, but ccet its provisions.
19 l
i l
l l
l
/
l 3A-36 AME!EENT 19 JUNE, 1980
1.33 OUALITY ASSURANCE PROGRAM REOUIREMENTS (OPERATION)
(Revision 1; l/77)
The Virg'il C. Summer Nuclear Station complies with the recommendations of Regulatory Guide 1.33 as discussed in Section 17.2 and Section 6.0 of the l
19 Technical Specifications.
i
\\
~
r t
9 s.
3A-43 AMENDMENT 19 JUNE, 1980
~-.
{',
y
' i 1.37 QUALITY ASSURANCE REQUIREMENTS FOR CLEANING OF FLUID SYSTD!S_
j AND ASSOCIATED COMPONENTS OF WATER-COOLED NUCLEAR POWER PLANTS t
~(Revision 0; 3/73)/
j 1
The Virgil C. Summer Nucicar Station complies with the recon:mendations f
Procurement orders apply cicaning require-
{
ments during fabrication and packaging of safety-related components so j
that equipment is delivered to the site in a properly cicaned condition.
Site procedures for the construction and operation phases meet the 4
requirements of M1SI-N45.2.1-1973 and this guide except for qualification of testing personnel (see position on Regulatory Guide 1.58).
i 1
/
i i
i l
}
J J
l l
l 4
/
l l
i j
i i
f J*
i
]
d i
\\
(
.i l
3A-47 MT.NDEiT 5 APRIL, 1978 7
eP l
._ = -. _, _, _ _.. _. -..,. _,. - _.. -.. _.., _ _ _ _ _,,,,., -....,,. _ _ _ - - _
1,38 OUALITY ASSURANCE PEOUIRDdENTS FOR PACEAGING, SHIPPING, RECEIVING, STORAGE AND llANDLING OF ITEMS FOR WATER-COOLED NUCLEAR POWER PLANTS (Revir.fon 0: 3/73)
The Virgil C. Summer Nuclear Station complies with the recommendations of Regulatory Guide 1.38 as ~ described herein. Packaging and shipping
/
procedures were develop,ed pr. lor to the issuance date of the guide.
While n
details may vary, the / recommendations of the guide are met in l
19
(
that good business practices are delineated in these procedurcs.
Measures are applied, as appropriate, to apply packaging requirements to procure-ment orders, to review supplier packaging procedures, to apply proper cleaning methods, to apply proper marking and identification, to provide protection to equipment from physical or weather damage, to apply special handling precautions'and to define storage recommendations.
Site storage, handling and receiving procedures during the constructid and operation q
phase meet the recoramendations of the guide.
I Tapes and desiccant used in conjunction with austenitic stainless steel and nickel alloy surfaces at the site meet the recormendations of the guide.
/
~
(
3A-48 AMENDMENT 19 JUNE, 1980
k s e
(.
HOUSErlEPI!;C REOUIRDE',75 FOP, k'ATER-COOLED :.TCLEAR POWER PLETS 1.39 (Revision 2, 9/77)_
The Virgil C. Surrer !!uclear Station cocplies with the recopendations of Regulatory Calde 1.39.
Site housekeeping procedures are in agree:::ent with /d:s1 1:45.2.3-1973.
7, r
I s-3A-49 AvINDuE17 5 s.
A?RIL, 1978
_. _.. _.. ~. _. _,....
.m.
,*g
(
\\
-1.58 QUALIFICATION OF NUCLEAR POWER PLANT INSPECTION, EXAMINATIDN AND TESTING PERSONNEL (Revision 0; 8/73)
For the period prior to issuance of an operating license, the Virgil C.
, Summer Nucicar Station QA program has and is" continuing to use an alter-
]I nate approach to Regulatory Guide 1.58.
This program is described below:
I i-Designated SCE&C or CAI personnel review the inspection, examination and
((
]
testing procedures of vendors and contractors who supply nucicar safety-1 I J
related services for the Virgil C. Summer Nuclear' Station.
SCE6C or CAI also reviews applicable vendor and contractor procedures which establish i
the qualification of inspection, examination and testing personnel.
I These procedures are reviewed prior to their application to SCE&G mate-rial or equipment and proposed documentation of personnel qualificat3on l
19 to the extent required by the nature and scope of the w rk is verified prior to acceptance of the material or equipment when pe' formed by the l
vendor or contractor.
SCE&G and CAI personnel responsible for reviewing
~
procedures, performing surveillance for procedure impicmentation and verifying inspection, examination and testing records are knowledgeable
)
and qualified in their particular area of inspection, examination or 1
testing.
i 1
~
l SCE&C or CAI does not impose a three-level qualification of inspection, examination and testing personnel on vendors and contractors, except in
/
i those cases where non-destructive examination (NDE) is required.
Within the scope of the NDE services specifications, qualifications of 37-i personnel performing non-destructive examination are in accordance with k,,
SNT-TC-1A.
1 j
The quality assurance
- programs which have been reviewed and approved by SCE&G or CAI have provisions for the indoctrination and training of i [
personnel a required by 10 CFR 50, Appendix B, Criterion II.
Vendors
\\
j and contractors were surveyed by SCE&G or CAI ahd were required to have j
indoctrination, training and certification programs designed to meet the a
needs of the inspection, examination or test r,equired.
These programs
's 3A-88 AMENDN5NT19 JUNE, 1980 9
N/
vary in scope and complexity commensurate with the nature of the work performed by these suppliers and the importance of the item or service involved.
Vendors and contractors that have done or 'Are now doing work on or for f--
the project's safety-related items and services comply with many elements of N 45.2.6.
~
The SCE6C/QC Program that has been used and is continuing to be used during
,s the construction phase was established in accordance with 10 CFR 50 11 Appendix B.
The elements of the QC program are similar to those imposed on vendors and contractors.
Subsequent to issuance of an operating license, the Virgil C. Summer Nuclear Station QA program will utilize ANSI 18.1-1971 for onsite operations organization personnel requiring qualifica lon to this standard as defined in Chapter 13.
For personnel whose qualifications are not required to meet those specified in ANSI 18.1 and who are performing inspection, examination and testing activities during the operational phase of the plant shall be qualified to ANSI N 45.2.6-1973 except the experience cited for 19 1cvels I, II and III shall be interpreted to mean actual experience in carrying out the types of inspectius, examination and testing activities being performed; and except for major modifications which will revert to the QA program defined in Section 17.1.
t
~
J 4
i
?
t 1
1 3A-89 AMENDMENT 19 JUNE, 1980 4
1 1
q' i
c
,o
'1.64 QUALITY ASSURANCE REOUIREMENTS FOR Tile DESIGN OF NUCLEAR POWER PLANTS (Revision 2; 6/76)_
l i
The design of the Virgil C. Summer Nuc1 car Station began p;ior to the
{
issuance of Regulatory Guide 1.64 or its re5renced document NISI N45.2.11-1974.
SCE6G did impose, however, the requirecents of Criterion
!j, 3, " Design Control," of '3 0 CFR 50 Appendix B, on organizations having design control responsibility for this project.
From the outset of the project, organizations having design responsibility have been closely audited for implementation of a meaningful and effective design control programs which meet Criterion 3 of 10 CFR 50 Appendix B.
Any deficient conditions in the audited design control programs were identified and I
i timely corrective action taken to resolve these deficiencies on the
{
design effort for the Virgil C. Summer' Nuclear Station.
)
)
U[onissuanceofAliSIN45.2.11,therequirementsofthe tandard were 1
j reviewed by SCE6G and compared to the implemented design control program for this project. The guidelines set forth in Regulatory Guide 1.64, l3 i
, andl ts subsequent revisions'in~1975 and 1976 are effective and
/meaningfulguidelinesfortheestablishmentofadesigncontrolprogram l
I for nuclear power plants, and SCE&G complies with the recommendations of l
13-this guide.
i j
f i
i i
I w
i
?
/
!t /'l
- l il
,l i
a i
I 3A-96 AMENDMENT 13 APRIL, 1979
QUALITY ASSURANCE TERMS AND DEFItiITIONS (Revision 0; 2/74)!
1.74 SCE&G has developed a glo.;sary of tertis which are listed in the SCE6G Quality Assurance Plan, the company's quality assurance program for impicmentation of the requirements for 10 CFR 50 Appendix B.
Terms re-quiring further definition have been so defined in specifications and other project documents as needed.
It is the position of SCE6G that the terms and definitions which it has I used in the impicmentation of the quality assurance program of this project are in agreement with the definitions contained in ANSI N.45.2.10-1973,"- and the definition of " Procurement Document" as noted Iin Section C of Regulatory Guide 1.74.
l
\\
t I
l l
l l
9 9
9 i
e 3A-111 9
4
..w
=m-9
1.88 COLLECTION, STORACE AND MAINTENANCE OF NUCLEAR POWER PLANT l5 QUALITY ASSURANCE RECORDS (Revision 2 ; 10/76)
The Virgil C. Summer Nuclear Station quality assurance records program complies with the recommendations of this, Regula tory Guide with the
{
following exceptions and clarifications:
ANSI-N45.2.9-74 Section Exceptions and Clarifications
( ~
17 5.6 The permanent records room is constructed and located to protect contents from nossible destruction by causes such as fire, flooding, insects, rodents and from possible deterioration by a combination of 11 extreme variations in temperature and humidity con-ditions.
5.6 The permanent records room is designed to meet a 4 17
('
hour fire rating except for the fire dampers and elec-13 trical penetrations, which are rated for 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
3.2.7 App. A Applicable c W god standards will either be main-i tained M N glaris. site or will be readily accessible j
f rom o *+.m
,, cc a.
3 I
e 3.2.7 App. A Only records identified as lifetime records are required to
]
be maintained.
!f
~
In addition, as discussed with the NRC Staff:
1.
The permanent records room is' equipped with an early warning fire l '17 i detection and automatic fire suppression system, with electronic supervision at a constantly attended location.
9 y
c
's s.
(.,
- t/
3A-130 AMENDMENT 21
{,
OCTOBER, 1980
?,
g 1
~
y 2.
Records are stored in metal cabinets. No records are stored 17
~
on the floor.
Adequate access and aisle ways are maintained.
i 3.
L'ork not directly associated with records storage or retrieval is
[
prohibited within the _pemanent records room.
Examples of such l
17 prohibited activities include but are not limited to:
records reproduction, film developing, and fabrication of mir.rofiche cards.
2 1
f 4.
Smoking, eating and drinking are prohibited.throughout the permanent _
17 l
records room.
5.
Ventilation, temperature, and humidity control equipment is protec-ted inside with standard fire dampers where they penetrate fire 17 barriers boua.ing the storage facility.
d
\\
a 4
)
/
Y 1
(
4, f
r
( *.
3A-130a AMENDMENT 17 FEBRUARY, 1980 '
1.94 QUALITY ASSUR NCE REQUIRE!!ENTS FOR INSTALLATION, INSPECTION AND TESTING OT STRUCTURAL CONCRETE A'iD STRUCTURAL STEEL DURING Tile CONSTRUDTION PHASE OF NUCLEAR POWER PLANTS (Revision 1: 4/76)!
The Virgil C. Summer Nuclear Station complies with the recommendations of Regulatory Guide 1.94 and ANSI N45.2.5-1974 except for the following.
1.
Cadweld Testing Iten 4.9.4 (Tensile Test Frequency) and Item 6.2.2 (Evaluation of Mechanical Splice Test Results).
The testing program is based upo;(
'that set forth in Section III Division 2 of the ASME Boiler and Pressure Vessel Code.
2.
Concrete Table B " Required In-Process Tests" for compressive \\ strength since the test frequency of concrete indicates 28-day strength tests and
\\
on 28 or 90 day strength tests is used.
3.
Admixture
/
Table B " Require 1 In-Process Tests" for Admixtures. Test by Infrared spectrophotometry analysis is not used.
f i
e O
9 e
3A-136 q
g
...em-.=-e-=
-=
L
^
~
n 1.116 QlhLITY ASSURANCE REOUIRDEhTS FOR INSTALIATION, INSPECTION, AND TESTING OF MECHA'iICAL EOUIPMENT AND SYSTEMS (Revisica 0-R; 6/76)/
The Virgil C. Summer Nucicar Station complies with the reco=mendations of the regulatory guide as discussed in Chr.pter 17.
(
\\
/
s
[k
~
c' 3A-158a AMENDMEST 5 i
APRIL, 1978
.=
.4.
- - +.
p
_~
~
j-(
b
n l.123 QUALITY ASSURANCE FIQUIREMENTS FOR CONTROL OF PROCUPR!EhT OF ITEMS AND SERVICES FOR NUCLEAR PO',,*ER PLANTS (Pavision 1; 7/77)!
'Ihe Virgil C Su:: er Nucicar Station co: plies with the reco :nendations of the regulatory guide as discussed in Chapter 17.
(
d
(
(
~
\\
~-
AMF FEE [
JP L, 1978 e
e
- m. e gee p-*-w me 8'
en-
-+eum e
r += *
- -e
-e
- we
-w a w ege*.m.e Em=-
e w-ew*%
-e O
4 -.,,.
i l.144 Auditing of Quality Assurance Programs for Nuclear i
Power Plants (Revision 0; 1/79) g f
Virgil C. Summer Nuclear Station complies with the recommendations of Regulatory Guide 1.144 except as stated herein.
.(
Applicability (Paragraph 1.2)
SCE&C imposes on its suppliers by way of procurement documents, the QA
(
system audit requirements necessary for the item or service being supplied.
Requirements for the audit elements of executing procedures, j
checklists, auditor qualifications, documented reporting of results, follow-up, and corrective action verification and evaluation are imposed.
i j
Follow-up (Paragraph 4.5.2) j 2
SCE6G will utilize other qualified team leaders at the irection of management to follow up audits.
This is an option to the existing 1
l requirement that the team leader performing the audit or management of
?
the auditing organization perform the follow-up.
1 4
l i
/
4 j
f_
i
)
i I.
(
d s
1
- 8 N_.
i 3A-165
{
AMENDMENT 20 AUGUST, 1980 3
- - - ~ -
.,,,,, _..,., - -., -,,. ~ - -.... _,,,.,, -,,., -.
.,..n.,
4,ew-..-,
v.-,,_,m-
e 13 - 3F7'-
SVRLN VIEGIMIA ELECTEE p TbtoElz G t
ATTACHMENT V REGULATORY GUIDE 1.58 QUALIFICATI0ff 0F NUCLEAR POWER PLANT ltJSPECTl0t1 EXAMlfJATl0f1 AtJD TESTitJG PERS0tJf1EL Personnel performing nondestructive examinations at Surry Power Station are requi red to comply wi th StiT-TC-1 A, " Recommended Practice for !!ondestructive Testing Personnel Qualification and Certification."
This applies to Vepco personnel as well as any contractors.
The Vepco Supervisor - liechanical Equipment is certified as Sl4T-TC-lA-Level III.
Referring to Figure A, Revision 1 the following job positions t
require qualifications as noted.
Job Title Af1SI-1445 2.6 LEVEL tis:rdrin We q Power Station Quality Gent +44 Engineer 11 System Quality Assurance Staff 1,11 Supervisor - Quality Assurance - Oper. & Maint.
lll Director - Quality Assurance 111 9
i l
l I
O L i~ - W 3 e
i l.
ATTACliMENT VI REGULATORY GUIDE 1.30 l
QUAllTY ASSURANCE REQUIREMENTS FOR TliE INSTALLATION, liiSPECT10tl, A!1D TESTING OF INSTRUME!JTATION AND ELECTRICAL ECU;PMEtJT The applicable portions of ANSI-1145 2.4-1972 as related to operating power stations have been adopted.
The Periodic Test Program, Station Administrative Procedures and Technical Speci fications provide l
speci fic instructions for implementation.
These procedures are subject to audit by both station and Vepco system quality assurance personnel for compliance.
l l
L_
g 7 (- y Y i
i ATTACHiiEi1T VII REGULATORY GUIDE 1.37 QUALITY ASSURANCE REQUIREtiEllTS FOR CLEAlllilG 0F FLUID SYSTEliS AND ASSOCIATED C014PONEllTS OF WATER COOLED !!UCLEAR' POWER PLANTS Procedures used at Surry during modifications and repairs are inter.ded to be in accordance with the applicable portions of At;S I-1445. 2.1 - 1973 These procedures include the prohibition of the i
use of low melting point alloys and restrict the level of halogens in cleaning solutions.
Water quality requirements are determined by station personnel and comply with regulatory position C.3 1
I i
t i
_,r
() 2 $~ b'$
ATTACHMENT Vill REGULATORY GUIDE 1.38 QUALITY ASSURANCE REQUIREMENTS FOR PACKAGING, SHIPPING, RECEIVING, STORAGE AND HANDLING OF ITEMS FOR WATER-COOLED NUCLEAR POWER PLANTS The station storeroom personnel are responsible for assuring that all material and equipment received at the station is checked for shipping damage, cleanliness, protection, identification, quantity count, documentation of receipt and any other specifics required as per purchase order and/or speci ficat ions, informed by Power Station qualityg,pjogergompersonnelareinstructed.and
^- rt:- cngineer of the i tems that a re considered to be Level 1 (Safety Related).
Attorance.
Qua l i ty ee+'. rn i personnel are responsible for assuring all material and equipment received at the station is in accordance with the applicable specification, purchase order or drawing.
~
as s o ro.n ce.
Quality <eo4+e4 personnel audit the storage of the material to assure quality is maintained from receipt of the material until it is used.
Such a check will consist of:
1.
Shipping damage 2.
Cleanlinc.ss 1
3 Prote_tive covers and seals 4.
Correct and sufficient preservatives 5
Correct and sufficient packing 6.
Correct material 7
I den t i fi ca t ion All material will be segregated as much as possible by classifi-i cation or type of material.
kWJ tevy,4 Material rejected by the Quali ty Geet4et Department (QC Hold) will be segregated from the material ac,cepted to prevent inadvertent use.
Storage and protection of material and equipment is defined by levels.
1.
Special Conditions -
i.e.,
air conditioning, humidity control, nitrogen or other gas blankets, etc.
O z.f-WL e-I j
2.
Heated Structures i
j 3
Unheated Structures t
l 4.
Open Structures - covered or scaled above ground The guidelines expressed as ANSI N45.2.2-1972 are followed where t
appropriate.
l; i
1.
i i
l 1
1 1
a 1
f l.
l 1
I i
3 i
h l
1 1
l 3
. _ _ _. _ - _ _ -.... _., _..... _. _ _,. _ _.. _ _. - _ _.,, _ - - _ _ _ _. _ _, _ _... _. ~ _ - _. _ _ _ -, _
L25-b/
ATiACHMENT IX REGULATt'RY GUIDE 1.39 HOUSEKEEPilG REQUIREMENTS FOR WATER COOLED r1UCLEAR POWER PLANTS General housekeeping requirements for the power station during operation follow a policy dictated by sound engineering and accident pre-vention practices.
The guidelines expressed in ANSI-N45.2-3-1973 are used during modification and repairs.
Housekeeping policy for inner containment components, systems and structures is dictated by Health Physics Department to climinate ex-cessive solid waste and accidents.
This is accomplished by limiting items that are taken into the containment and accountability to ensure excess materici taken in is removed.
Vepco general housekeeping procedures are established in the Accident Prevention Manual:
1.
Cembustible materials, such as oil soaked and paint covered rags, waste, packing and other rubbish, shall not be allcwed to accumulate.
2.
S tai rways, ais les, exis t s, walkways and s torage areas shall be kept f ree of debris and other obstructions.
3 Materials and supplies shall be stored in an orderly manner to prevent thei r falling, rolling or spreading and to prevent tripping and stumbling hazards.
4.
Floors and platforms shall be kept reasorably free of oil, grease, water and other slippery material.
qsserance.
T he powe r s ta t i on qua l i ty te+t-rei staff in accordance with Section XVill of the Quality Assurance Manual will audit the housekeeping, in ge.eral, of the facility.
Specific inspections for cleanliness of components after main-tenance to avoid component contamination by loose parts, grease, oil, etc.,
is the responsibility of the person performing the work.
ATTACHMEtlT X REGULATORY GUIDE i.64 QUALITY ASSURAtJCE REQUIREMEtJTS FOR THE DESIGtJ OF flVCLEAP, POWER PLAtJTS Procedures utcJ by Vepco for design changes and modifications comply with the guidelines expressed in ANSI 1145.2.11.
A good example of the application of these principles is the current High Energy Line Modi-fication being carried out at Surry Power Station.
e l
h 4
I j
i I.
I
D L 5
- S 'l ATTACHMENT XI EXTRACTS FROM ANSI N45.2.8 The extracts from ANSI-N45 2.8 as listed in the " Orange Book" are l a general use during modifications and repairs at Surry.
Statior. Procedures require that maintenance activities on Level 1 (Safety Related) systems and comps ats Le carried out u:ing These procedurc provide for " hold points" by written instructiongyE,I62f'O gineer.
the station quality <
4 4
J 4
f
0 L$
9Y
,A"C COMMENT 2.'
Section.i.l.0 " Organization" mentions an organizational chart, Figure A.
liowever, Figure A is missing.
Please enclose a copy.
VEPC0 RESPONSE Organizational chart, Figure A has been revised and is incl as part a
of the reply to AEC Comment 1.
AEC COMtENT
%.2 Furth2r describe the duties of onsite and offsite Quality Assurance personnel to permit a clear understanding of the speci fic
- spon-sibilities and authorities of these persons in the areas of (a) independ.nt acceptance inspection; (b) preparation, review, and concurrence or approval of drawings, speci fications, purchasc orders, procedures, nanuals, and changes thereto.
Describe the Vepco criteria for determining whether or not independent ~ physical inspection and formal audit is performed on all minor or major maintenance, or on both.
AEC COMMENT 2.6 Describe the policy, nature, scope and responsibility relative to performance of physical inspections, physical inspection measure-ments, and independent acceptance inspections.
VEPCO RESPONSE A.
Responsibilities and authorities in following ercas:
1 1.
Independent acceptance inspection:
QA Staff (offsite)
Conducts audits of the acceptance inspection functions as prior conditions warrart.
Authority to recommend changes / solutions to quality related problems.
Q Staff (onsite)
Conducts acceptance inspection at specified " hold points".
Authori ty to reject nonconforming items.
Performs audits of inspections performed by traintenance parsonnel.
l l
() 2L fi Il 1 2.
Preparation, review and concurrence or approval of.
- d. wings, specifications, purchase orders, procedure manuals and changes thereto.
QA staff (offsite)
Responsible for the preparation, review and changes to the Vepco system quality assurance manual.
Audits the ef fort of the Station Quality Assurance Engineer in i
l his area of responsibility.
Authority to recommend changes to the station quality assurance manual and provide technical direction to aid in the solutions to problems in the quality control ef-fort of the Power Station Quality Assurance Engineer and staff.
QA Staf f (onsite)
The review and concurrence with drawings, specifications purchase orders, procedures and manuals in use at the station is the function of the Station Nuclear Safety and Operating Committee.
The Power Station Quality Assurance Engineer is responsible for preparation of-the power station quality assurance manual and changes thereto This manual likewise receives approval by the Station NSO Committee.
The quality assurance staff audits the documents frequently to ensure revisions are made promptly and the obsolete material is destroyed.
Autht rity to initiate and promote changes to specifications, drawings, purchase orders, or manuals and prohibit their use if found obsolete until correct documents can be utulized.
B.
Independent Physical inspection and Audit it is current Vepco policy that physical inspections are carried out by the supervisor, or another f rom his group, responsible for the work.
Much of the work is inspected by several levels of station supervisors and in some cases by individuals from departments not directly responsible for per-formance of the work.
For example, the Periodic Test Program implementation is verified by more than one supervisory level as well as the station engineering group.
The Power Station Quality Assurance Engineer (PSQAE) inspections are limited to specific " hold points" designated on the written procedures.
The PSQAE during his routine audits of station activities is able to evaluate the effectiveness of this system.
In addition to the station inspection and audit activity, a formal audit program is now being implemented by the Vepco System Quality Assurance group.
Specific areas of station activities are audited twice weekly using preplanned audit check lists and formal reports are issued which describe audit findings.
6 L S'- 9 l-Verco has not classi fied formally maintenance activi ties into minor and major categories.
The main thrust of both the stat,lon and Vepco System quality assurance activities is directed to Level 1 or Safety Related systems and components.
AEC COMMENT i
23 Provide a full and complete description of the authority, organiza-tionaV f reedom, and independence of pe csonnel performing Quali ty Assurance functions, to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.
Indicate from whom technical Quality Assurance direction is received and from whom administrative control (salary review, hire / fire, position assignment)
VEPC0 RESPONSE _
A description of the authority of personnel performing quality assurance functions is given in the response to AEC Comment 1.
The organizational freedom is illustrated by the functional chart, Figure A, Revision 1.
ADMINISTRATIVE TECHNICAL QA DIRECTION (Salary review, hire / fire etc)__
Manager-Lic.
Senior Vice President-Senior Vice President-Po,+er and QA Power D i rec to r-QA Manager-Licensing & QA Manager-Licensing and QA Supervisor-Director-QA Direrter-QA QA-06M QA Staff Supervisor-QA-OcM Supervisor-QA-0EM Pover Station QA Sta f f, Supervisor-Station Manager Q' Engineer Production Services h
Power Station Power Station Q-PowerStationQf b
Qi Staff Engineer Engineer AEC C0f tENT 2.4 Describe the control it.voked to prevent use of obsolete drawings, obsolete manuals, and other obsolete instructions and policies.
In addition, identi fy those positions or persons who regularly receive copies of the audit reports relative to audits of the activities performed by onsite and home office quality personnel.
02 $ - N $
VEPCO RESP 0f15E Power Station Administrative Procedures, ADM-12, 13, 44 and 45 deal with the control df documents at the station.
The implementation of these procedures is verified by the QA audit p rog ram.
j
\\
Standardized distribution of audit reports is as follows:
1 System Audits (offsite)
Supervisor-QA-0&M l
Station Supervisor (Manager)
Department / Area Supervisor i
j Supe rvi sor-fluclea r Cpera t ions i
System QA File Station Audits (onsite)
Cognizant Supervisor 3
Station Manager (Chairman fluclear Safety and Operating Committee)
QC File Supervisor-QA-0SM A summary of audit activity is sent to the Manager-Licensing & Quality Assurance on a monthly basis.
i I
k
_C.. :s
's r
.s e
AEC COMMENT 2.5 Although the staf f recognizes that Vepco's formal training and i ndoctri nat ion program i s current ly under development, provide a program outline to permit an evaluation of scope and progress.
t VEPC0 RESPONSE t
An indoctrination and training period is implerunted for training of QA and QC Staf f personnel performing quali ty related functions.
Heavy emphasis j
is placed on "on the job" training and close supervision.
l Indoctrination is ini tiated and supervised by both of f-site and on-site QA management and consists of establishing a familiarity with applicable specifications, regulatory codes, organization (accenti.' ting freedom to perform quali ty assurance functions), compliance of quali ty assurance manual and power station qualityTNM5anual and audit scheduling and implemen-tation.
I The training period shall consist of utilization of available schools or seminars and supervised training while performing quality related functions.
The longevity of this program is directly deperident upon the prior training
]
or experience of the personnel and will be determined by the Director-Quality l
Assurance to assure proficiency is achieved and maintained.
The program has been implemented since the inception of the quality assuinnce staff.
Refinements will be made as the staffing requirements are met and on an individual basis for incoming personnel.
AEC COMMENT 2.7 Clari fy what is peant bv "moni toring audi ts" performed by the Power Station Quali ty C5N$@$3'Ingineer (PSQ[I).
Are these formal doc What activities are to be formally audited by the PSQ[ymented
- and audits?
by the Supervisor-Quality Assurance and Maintenance (SQA-QM)?
Delineste the scope and frequency apportioned to each of these.
Indicate whether there is a formal pre planned and scheduled system of audits and of i
I inspection.
t
}
VEPCO RESPONSE
" Monitoring audits" is a term wh ch has been revi*,ed to indicate formal j
audi ts performed by the Quali ty J3.TAfingineer.
The results of these audits are documented.
The formal audits may include station procurement, station. operations and maintenance, quali ty related activi ties during i
normal station operations or shutdowns and follow up audits of assigned corret* i ve action.
i 1
_m._
_, _.. _ _, - _. _., ~., __,
..._,_._,e.,,_,_-_w
62i h.$
j The Vepco Systen Quality Assurance group may audit the same areas as the Quality d1IR3EffN$igineer as well as the quality assurance ef fort at the System or Sta, tion levels.
The quality assurance staf f schedules and per-form audits.
~
The formal preplanned and scheduled audit plans by the on-site and off-site quality assurance personnel are described in the respective quality ase urance manuals.
Th'.ir scope and frequency is determined by the quality status of the area being audited.
Presently, the Vepco System quality assurance staff is conducting audits of i
various areas of Station operation at the rate of two per week by a schedule l
The station Quality ;LSVf2P" Engineer maint- *ns a schedule j
developed monthly.
of routine audits in the following areas:
Ope ra t i on, Electrical, Mechanical i
and I ns t rument Mai ntenance, Periodic T.esting, Health Physics, Procurement, Design Changes, Security, and Reactor Surveillance.
Each area is audited at j
least once within a quarter.
9 i
3 i
d i
i i
i i
REGULATORY GUIDE 1.8:
Personnel Selection and Training (Revision 1-R, May 1977)
RESPdNSE' The position of Regulatory Guide 1.8 is accepted (refer to sections 13.1 and 13.2).
s.
REGULATORY GUIDE 1.26:
Quality Group Classification and Standards for Water, Steam and Radioactive-Waste-Containing Components of Nuclear Power Plants (Revision 1, September 1974)
RESPONSE
Quality group classifications and code requirements for each quality group correspond to those indicated in Regulatory Guide 1.26 with the following exceptions:
A.
Positions C.1 and C.2 of the Regulatory Guide For Quality Group B and C instrument lines for, safety-related instruments, the instrument piping, tubing and fittings downstream of the instrument 1.8-14
/T,,..
'; : ' c.
k
~ d
- (*
root valves will be -the 'same Quality Group classifi-cation as the root valve.
The instrument valves
. will be Qua'ity Group D'.
l
' osition C.1 for the Quality Group B refueling
)
B.
P f
water tank and position C.2 for the Quality Group C condensate storage tank.
These tanks are of concrete construction with a stainless steel liner for maintenance of water quality and are not constructed to the ASME Boiler and Pressure Vessel Code,Section III, C.
Positions C.l.d, C.l.e, C.2.c and Footnote 4 of the j
]
Regulatory Guide j
The words "or remote manual" are considered to be j
inserted between the words " automatic",and " closure."
j-This option is included to avoid an unnecessary l
complication (leading to decreased plant reliability)
)
in lines which would not normally be provided with automatic closing valves.
i-D.
Position C.l.d of the Regulatory Guide i
j Specific exceptions taken to placing main steam and J
j feedwater lines in Quality Group B are as follows:
l The branch line size limitation of application of l
Seismic Category I requirements, indicated in
)
Regulatory Guide 1.29, is also applied to quality
.]*
group classification.
Therefore branch lines i
2-inch nominal pipe size and under, excluding con-tainment penetrations, are placed in Quality Group D.
i E.
Position C.2.a of the Regulatory Guide i
The requirement that systems providing cooling for the 4
i spent fuel pool be placed in Quality Group C is i
i 1.8-15 i
i
--.n.,
n.-
~.,,, -
. ~. ~ -. - - - - -. - - - -
r PVNGS FSAR CONFORMANCE TO NRC REGULATORY GUIDES interpreted to apply only to the minimum systems required during an emer,gency condition and not necessarily to those systems normally providing such cooling.
F.
Position C.2.b of the Regulatory Guide The seal water injection lines to the reactor coolant pumps are constructed to ASME Section III Class 2 requirements although the cooling water lines to the shell side of the seal water heat exchanger are constructed to Quality Group D requirements as are the cooling water lines for the reactor coolant pump motors.
This piping is Quality Group D because the cooling water is not required for safe shutdown of the reactor as the reactor coolant pumps can coast down without the benefit of this cooling water.
Equipment classification and code requirem~ents are presented in section 3.2.
\\,
g.)
I
- w 4
4
- ~
h
REGULATORY GUIDE'l.29:
Seismic Design Classification (Revision 1, August 1973)
)
RESPONSE
a j
- For construction phase activi' ties, the position of Regulatory l4 Guide 1.29'is accepted with the following exceptions:
A.
Position C.l.d of the Regulatory Guide Systems required for cooling the spent fuel storage f
pool are required to be designed for the SSE.
This is l-interpreted to apply only to the minimum systems j
required in an emergency condition and not necesssarily to those systems normally providing such cooling.
4 B.
Position C.l.f and Footnote 1 of the Regulatory Guide j
The words "or remote manual" are considered to be 1
inserted between the words " automatic" and " closure."
~
Th'is option is included to avoid an unnecessary complication (leading to decreased plant reliability)
{
in lines which would not normally be provided with i
automatic closing valves.
1 Position C.l.h of the Regulatory Guide
{
C.
1.
Refer to CESSAR Section 5.4.1.3.
{
Seismic classification oZ s ructures, systems, and components is presented in section 3.2.
Also see CESSAR Section 1.8.
i
~
I i
May 1981 1.8-17 Amendment 4 i
.5-
~+-------~--*,e--.<.-m---&-ms y
___- _. _,.19,y y
m--
a y,
p
--u_,-
g
,m v7,
-ww--.-
,q1-.,5w--
3--9--y~w
PVNGS FSAR CONFORMANCE TO NRC REGULATORY GUIDES REGULATORY GUIDE 1.29:
Seismic Design Classification (Revision 3, Sep,tember 1978)
RESPONSE
For operations phase activities that are comparable to activi-ties occurring during the construction phase, the following interpretations apply to the position of Regulatory Guide 1.29:
A.
Position C.l.d of the Regulatory Guide i
l Systems required for cooling the spent fuel storage l
pool are required to be designed for the SSE.
This is 4
interpreted to apply only to the minimum systems j
required in an emergency condition and not necessarily j
to those systems normally providing such cooling.
l l
B.
Position C.l.f and Footnote 1 of the Regulatory Guide i
The words "or remote manual" are considered to be j
inserted between the words " automatic" and " closure."
( ~
i l
This option is included to avoid an unnecessary i
complication (leading to decreased plant reliability) l in lines which would not normally be provided with l
automatic closing valves.
l C.
Position C.l.h of the Regulatory Guide i
Refer to CESSAR Section 5.4.1.3.
REGULATORY GUIDE 1.30:
Quality Assurance Requirements for the i
Installation, Inspection, and Testing J
j of Instrumentation and Electric k
Equipment (Revision 0, August 11, 1972) 1 I
j CONFORMANCE TO NRC d
REGULATORY GUIDES i
i
RESPONSE
j The requirements of the referenced Standard ( ANSI N45.2.4-1972)
I will be applied to the Bechtel quality program for construction of safety-related items as interpreted in the Regulatory Position as modified and interpreted below.
j A.
Section 2.1 Planning.
The required planning is j
frequently performed on a generic basis for application to many installations on one or more projects.
This results in standard procedures or plans for installation and inspection and testing which meet the requirements.
of the Standard.
Individual plans for each item or 4
system are not normally prepared unless the work 4
operations are unique; however, standard procedures or
)
plans are reviewed for applicability in each case.
j Installation plans or procedures are also limited in scope to those actions or activities which are essential 2
to maintain or achieve required quality.
B.
Section 3 Preconstruction Verification.
The require-ments of this section are applied to items which are a
received and stored prior to installation.
They are combined with receiving inspection activities in j
accordance with ANSI N45.2.2 requirements for items which are installed immediately after receiving
)
inspection.
1 i
For operations phase activities that are comparable to activities
,4 occurring during the construction phase, the following inter-1 pretations apply to the position of Regulatory Guide 1.30:
A.
Section 5.2:
4 The various tests are performed "as appropriate" as I
determined by PVNGS Engineering and Technical Services based upon the significance of the change or modification.
-, _ _ _ _ ~ _ _ _ _. _
_.. _ _ _. _ _ _~
r-2 i
CONFORMANCE TO NRC REGULATORY GUIDES Delta-ferrite content of procedure qualification welds is I.
j' determined by chemical analysis i*n accordance with ASME j
Code,Section III, Division 1, 1974 Edition, Paragraph NB-2433 1
j instead of by magnetic measurement devices called for in i
Paragraph C.l'.
Since austenitic stainless steel welding materials are, con-trolled to deposit 8 to 25% delta-ferrite based on chemistry, except for 309 and 309L welding materials, which are controlled
}
to deposit 5 to 15% delta-ferrite based on chemistry, magnetic
)
measurement of production welds required by Paragraph C.1 is j
not necessary to assure satisfactory delta-ferrite content.
REGLLATORY GUIDE 1.32:
Use of IEEE STD 308-1971, Criteria for i
Class IE Electrical Systems for Nuclear j
Power Generating Stations (Revision 0, j
August 11, 1972) i
RESPONSE
I j
The position of Regulatory Guide 1.32 is accepted (refer to j
section 8.3.1).
In addition, for a discussion of compliance I
with IEEE STD 308-1974, refer to section 8.3.
j I.
(^
l I
PVNGS FSAR CONFORMANCE TO NRC REGULATORY GUIDES B.
Section 6.2.2:
The requirement that systems tests' be made to verify that all parts of a system properly coordinate with each other is interpreted as not requiring that an entire systcm be re-tested after modification of only a portion of that system.
The testing require-ments of the Technical Specifications are met for inoperable equipment.
REGULATORY GUIDE 1.33:
Quality Assurance Program Requirements (Operation) (Revision 2, February 1978)
RESPONSE
The position of Regulatory Guide 1.33 is accepted with the following exception to Position C.2:
4 The APS commitment refers to Regulatory Guides, and revisions thereof, specifically identified in this FSAR.
Amendment 4 1.8-20 May 1981
The followAng c:<ception is 1.aken 1,o Section 3.4.2 of the referenced dtandard ANSI N18.7:-
q
The APS commitment cn the gaalification of personnel wh5 arb performing preoperational and startup test func-tions is found in section 14.2.2.9.
In addition, the following interpretations of the referenced standard ANSI N18.7 are made:
A.
Section 5.2.2:
The requirements of this section are accepted with the 4
following interpretations:
Temporary changes to procedures r.ay be made provided the change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator License on the unit affected.
Procedural steps for which actions should be committed 4
to memory are the immediate actions of the emergency procedures.
B.
Section 5.2.13.1:
The requirement that changes made to procurement documents be subject to the same degree of control as was used in the preparation of the original documents is applied consistent with the requirements of ANSI N45.2.ll, Paragraph 7.2.
Minor changes to documents, such as inconsequential editorial corrections or changes to commercial terms and conditions, may not require that the revised document receive the same review and approval as the original documents.
C.
Section 5.2.17:
The requirements of this section are accepted with the 4
following interpretation:
The reouirement that deviations, their cause, and any j
carrective action completed or planned shall be May 1981 1.8-21
- caendment 4
PVNGS FSAR CONFORMANCE TO NRC REGULATORY GUIDES
(
docuinented shall apply to significant deviations.
Other identified deviations will be documented and 4
corrected.
This interpretation is consistent with Appendix B to 10CFR50, Criterion XVI, Corrective Action.
The iniplementation of the positions of this Regulatory Guide are described in chapters 13, 16, and 17.
E e
E
EEGUI3 TORY GUIDE 1.37:
Quality Assurance R!quirements for Cleaning of Fluid Systems an,d Associated Components of Water-Cooled Nuclear Power Plants (Revision 0, March 16, 1973)
RESPCNSE The requirements of the referenced Standard ( ANSI N45.2.1-1973) as modified in the Regulatory Position are applied to cleaning activities specified or applied by Bechtel to safety-related items as modified and interpreted below.
A.
Set-, tion 2.1 Planning.
The required planning is I
frequently performed on a generic basis for application to many installationc on one or more projects.
This results in standard procedures or plans for installa-tion and inspection and testing which meet the require-ments of the Standard.
Individual plans for each item or system are not normally prepared unless the' work operations are unique, however, standard procedures 6r plans are reviewed for applicability in each case.
Installation plans or procedures are also limited in scope to those actions or activities which are essen-tial to maintain or achieve required quality.
This is consistent with Section II Paragraphs 2 and 3 of ANSI N45.2-1971 which provide for examination, measure-ment, or testing to assure quality or indirect control by monitoring of processing methods.
However, final cleaning or flushing activities are performed ia
~
accor.iance with procedures specific to the system.
i Also see CESSAR Section 1.8.
For operations phase activities that are comparable to activi-ties occurring during the constrrction phase, the referenced standard (ANSI N45.2.1-1973) as modified by Regulatory Guide 1.37 is accepted as modified below.
A.
Section 2.1 Planning.
The required planning is frequently performed on a generic basis for appli-cation to many systems and component installations.
4 This rese;ts in standard procedures for cleaning, inspection, and testing which meet the requirements of the Standard.
Individual plans for each item or system are not normally prepared unless the work
achieve required quality.,
This is consistent with Section 5.2.17 paragraph 5 of ANSI N18.7-1976 which pr'ovides for examination, measurement, or t'esting to 4
a'ssure quality or indirect control by monitoring of processing methods.
REGULATORY GUIDE 1.38:
Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Ilandling of Items for Water-Cooled Nuclear Power Plants (Revision 0, March 16, 1973)
RESPONSE
The requirements of the referenced Standard ( ANSI N45.2.2-1972) as modified and interpreted in the Regulatory Position are applied to the Bechtel quality program for construction of safety-related items, except as modified and interpreted below:
A.
Section 2.7 Classification of Items.
The four level classification system may not be used explicitly.
Ilowever, the specific requirements for each classifica-tion as specified in the Standard are applied to the items suggested in each classification and for similar items.
B.
Section 3.9:
Identification of items, after the o"tside of the container has been removed, is accomplished in accor-dance with ANSI N18.7, Section 5.2.13.3.
C.
Section 6.2 Storage Areas.
Paragraph 6.2.1 requires control and limited access to storage areas.
In lieu of and to amplify this paragraph the following is applied.
May 1981 1.8-24A Amendment 4 14
..Acau to aietuge t.reau wr J.cici
.3, a t.;.a w is controlled by the individual (s) resptnsible for material storage."
Level D items are stored in a site
, area which has access control consistent with zone IV of ANSI N45.2.3-1973.
While the areas may be posted to limit access, other positive controls (other than that for the overall site area) or guards may not be provided.
D.
Sections 3.9, 5.6, and Appendix A Section 3.9 Marking.
These ANSI N45.2.2 sections contrcl direct marking of austenitic stainless steel and nickel based alloys.
Marking is in compliance with the requirements of these sections except that markings may be directly applied using inks controlled so as not to contain more than 200 ppm of chlorides.
REGULATORY GUIDE 1.38:
Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Water-Cooled Nuclear Power Plants (Revision 2, May 1977)
RESPONSE
For operations phase activities that are comparable to activities occurring during the construction phase, the position of 4
Regulatory Guide 1.38 is accepted with the following exceptions to the referenced standard ( ANSI 45.2.2-1972):
A.
Section 2.7 Classification of Items.
The four level classification system may not be used explicitly.
However, the specific requirements for each classifica-tion as specified in the Standard are applied to the items suggested in each classification and for similar items.
41 Am<adment 4 1.8-24B May 1981
PVNGS FSAR CONFORMANCE TO NRC REGULATORY GUIDES B.
Section 3.9:
Identification of items, after the outside of the container has been removed, is accomplished in accor-dance with ANSI N18.7, Section 5.2.13.3.
C.
Section 6.2 Storage Areas.
Paragraph 6.2.1 requires control and limited access to storage areas.
-In lieu of and to amplify this paragraph the following is applied.
" Access to storage areas for level A, B and C is controlled by the individual (s) responsible for material 4
storage."
Level D items are stored in a site area which has access control consistent with zone IV of ANSI N45.2.3-1973.
While the areas may be posted to limit access, other positive controls (other than that for the overall site area) or guards mly not be provided.
D.
Sections 3.9, 5.6, and Appendix A Section 3.9 Marking.
These ANSI N45.2.2 sections control direct marking of austenitic stainless steel and nickel based alloys.
Marking is in compliance with the requirements of these sections except that markings may be directly applied using inks controlled so as not to contain more than 200 ppm of clilorides.
REGULATORY GUIDE 1.39:
Housekeeping Requirements for Water-Cooled Nuclear Power Plants j
(Revision 2, September 1977)
i l
)
PVNGS FSAR CONFORMANCE TO NRC REGULATORY GUIDES
RESPONSE
The requirements of the referenced Standard ( ANSI N45.2.3-1973) are applied to the Bechtel quality program for construction of safety-related items except as modified and interpreted below:
A.
Section 2.1 Planning.
The required planning is frequently performed on a generic basis for application to many installations on one or more projects.
This results in standard procedures or plans for installa-tion and inspection and testing which meet the require-ments of the Standard.
Individual plans for each item or system are no't normally prepared unless the work operations are unique; however, standard procedures or plans are reviewed for applicability in each case.
Installation plans or procedures are also limited in scope to those actions or activities which are essen-tial to maintain or achieve required qu'al'ity.
(
B.
Alternative equivalent zone designations and require-ments may he utilized to cover those situations not included in the subject Standard.
For example, situations in which shoe covers and/or coveralls are required but material accountability is not.
For operations phase activities that are comparable to activities occurring during the construction phase, the position of Regulatory Guide 1.39 is accepted with the following exception:
4 Alternative equivalent zone designations and requirements may be utilized to cover those situations not included in the subject Standard.
For example, situations in which shoe covers and/or coveralls are required but material account-ability is not.
2.
iguality Acuurance Requirements (a)
- Summary,
.(1)
Compliance with Regulatory Guide 1.54 for R and S areas is not required and therefore will not be imposed for these areas.
l 1
(2)
ANSI N 101.2 provides the testing and evalua-tion criteria established for coatings which shall be used.
The coating used shall be certified by the coating manufacturer to withstand the spray solution proposed by the project.
(3)
Compliance with Regulatory Guide 1.54 for each and every item to be located within the containment is considered impractical and in some cases unattainable.
Therefore, Regulatory Guide 1.54 will or will not be 5,
imposed in accordance with the following criteria:
(b)
Regulatory Guide 1.54 will be imposed for it. ems located within the containment b6ilding as follows:
(1)
For shop priming of liner plate; structural steel and fabricated shapes.
(2)
For shop priming of fabricated pipes, tanks, llVAC ducts and equipment.
(3)
Field touch-up of any Q class coated items, when the touch up area is in excess of 30 square inches.
(4)
For field finish painting of structural steel and equipment where called for in drawings and speci fications.
(S)
For surfacing of concrete where indicated in
(
drawings and specifications.
EEGULATORY GUIDE 1.58:
Qualification of Nuclear Power Plant Inspection, Examination and. Testing Personnel (Revision 1, September 1980)
RESPONSE
For operations phase activities the position of Regulatory Guide 1.58 is accepted with the following exception to posi.
I tion C.1:
)
The qualification of personnel who approve preoperational and startup test procedures and test results, and those l
who dir.ct or supervise the conduct of individual preoper-j ational and startup tests is discussed in section 14.2.2.9.
The qualification of other personnel discussed in posi-I tion Cl follows the guidelines of Regulatory Guide 1.8 as discussed in sections 13.1 and 13.2.
~
j 4
In addition, the following exceptions are taken to the refer-
=
4 i
enced standard ANSI N45.2.6-1978 are made-
\\
1 4
)
A.
The first sentence of paragraph 3.4 states that a i
Level III qualified person shall have all the capa-bilities of a Level II cualified person for the inspection, examination or test category or class in question.
APS will qualify level III persons without the actual hands on experience and capability to per-form specific inspections, examinations or tests required of a Level I or II qualified person, and utilize these persons for administrative and super-
['
~
visory functions including certifying persons at the t
1 same or lower level.
1 l
B.
Paragraph 3.3 states that a Level II qualified person i
shall have demonstrated experience in certifying lower level qualified persons.
APS does not use Level II qualified persons to certify lower level qualified persons, and does not require Level II qualified per-i i
sons to demonstrate this capability.
i i
U
REGULATORY GUIDE 1.64:
Quality Assurance Requirements for the Design of Huclear Power Plants (Revision O, October 1973)
I
RESPONSE
The Regulatory Guide endorses a superseded draft issue of the ANSI Standard N45.2.ll.
For C-E's program refer to CESSAR Section 17.0.
The Bechtel program complies with ANSI N45.2.11-1974 as interpreted herein.
A.
Section 3.1.
This section implies that all necessary design input (as listed in section 3.2) should be a'vailable prior to the start of a design activity.
In practice, certain design activities are initiated 4
before the firm input requirements are available.
(For example, foundation designs prepared based on preliminary information or equipment sizes and mounting and embedded conduit run based on preliminary estimates of circuit requirements).
The design phase QA program is structured to assure that all necessary design input is available before completion of final design of the work affected by the input and that final design input is available for use in verification of the final design.
B.
Section 4.1 Design Process General.
Paragraph 3 implies traceability back from final design to the source of design input.
In practice, a literal inter-pretation of this is r.ot always possible.
For example, final design drawings do not identify the related cal-culations.
This paragraph is interpreted to mean that-it shall be possible to relate the criteria used and analyses performed to the final design documents and that record files will permit location of analyses supporting specific design output documents.
..uut..uuny culoE 1.L4:
(uality Aucurunce Requ.tici..ents 1or ule Design.6f Nuclear Power Plants (Revisibn 2, June 1976)
RESPONSE
For operations phase activities that are comparable to activities occurring during the construction phase, ti2e position of Regulatory Guide 1.64 is accepted with the following exception to position C.2 of the Regulatory Guide:
Supervisory personnel may perform design verification under exceptional circumstances as documented and approved by the next level of supervision.
APS interprets ANSI N45.2.ll-1974 sections 3.1 and 4.1 as follows:
A.
Section 3.1.
This section implies that all necessary 4
design input (as listed in section 3.2) 'should be available prior to the start of a design activity.
In practice, certain design activities are initiated before the firm input requirements are available.
.(For example, foundation designs prepared based on preliminary information or equipment sizes and mount-ing and embedded conduit run based on preliminary estimates of circuit requirements).
The design phase QA program is structured to assure that all necessary design input is available before completion of final design of the work affected by the input and that final design input is available for use in verifica-tion of the final design.
B.
Section 4.1 Design Process General.
Paragraph 3 implies traceability back from final design to the source of design input.
In practice, a literal inter-pretation of this is not always possible.
For exam-plc, final design drawings do not identify the related calculations.
This paragraph is interpreted to mean REGULATORY GUIDES that it shall be possible,to relate the criteria used and hnalyses performed to the final design documents and that record files will permit location of analyses supporting speci fic design output documents.
PVNGS FSAR CONFORMANCE TO NRC REGULATORY GUIDES i
REGULATORY GUIDE 1.68:
Preoperational and Initial Startup Test Programs for Water-Cooled Power Reactors (Rcvision 0, November 1973)
RESPONSE
The positions and guidelines of Regulatory Guide 1.68 are accepted, except that Power Ascension Tests will be conducted using power plateaus of 20%, 50%, 80%, and 100% in' stead of 25%, 50%, 75%, and 100%, as recommended in Paragraph D.4 of Appendix A to Regulatory Guide 1.68.
Implementation of Regu-latory Guide 1.68 is discussed in section 14.2 and CESSAR Section 1.8.
REGULATORY GUIDE 1.68.2:
Initial Startup Test Program to Demonstrate Remote Shutdown Capa-bility For Water-Cooled Nuclear
(
Power Plants (Revision 1, July 1978)
RESPONSE
The position of Regulatory Guide 1.68.2 is accepted, except as follows:
Paragraph C indtcates licensee should develop and conduct a test program for each unit.
As the PVNGS units will be identical, testing on all units is unrealistic with the objectives of the test which are:
A.
Veri fication that the plant can be shut down from outside the control room.
B.
Verification that the plant can be maintained in hot shutdown.
PVNGS FSAR CONFORMANCE TO HRC REGULATORY GUIDES k
C.
Verification of cooldown capability.
Remote shutdown testing on the first unit will demonstrate the above objectives.
Control between the control room and remote shutdown panel is in parallel and transfer switches are not utilized.
Component and preoperational testing of following units and plant systems to be used in the remote shutdown panel will verify that they will function in the same manner as would be experienced on the first unit tested see section 14.2).
REGULATORY GUIDE 1.69:
Concrete Radiation Shields fot Niiclear Powel Plants (Revision O, December 1973)
RESPONSE
The position of Regulatory Guide 1.69 is accepted (refer to section 12.3).
REGULATORY GUIDE 1.70:
Standard Format and Content of Safety
(.
Analysis Reports for Nuclear Power Plants - LWR Edition (Revision 3, November 1978)
RESPONSE
The position of Regulatory Guide 1.70 is accepted in that the required content is provided.
The recommended format also is followed except when deviations are necessary to be consistent with CESSAR.
Quality Assurance Terms and Definitions REGULATORY GUl1}E_1.74:
(Revision 0, February 1974)
RESPONSE
~
_ accepted (refer to J
REGULATORY GUIDE 1.88:
Collection, Storage and Maintenance of Nuclear Power Plant Qua,lity Assur-ance Records (Revision 2, October 1976) l4
RESPONSE
The position of Regulatory Guide 1.88 is accepted.
4 REGULATORY GUIDE 1.116 : Quality Assurance Requirements for Installation, Inspection,- and Testing of Mechanical Eauipment and Systems i
(Revision 0-R, May 1977)
RESPONSE
For operations phase activities the position of Regulatory Guide 1.116 is accepted with the following clarifications:
Posit ion C.2 of Regulatory Guide 1.116 4
For the purposes of this Regulatory Guide and the American National Standard N45.2.8 which it endorses, " applicable operations phase activities that are comparable to activities occurring during the construction phase" shall be interpreted to mean those activities of such a scale and type that the following conditions are met:
1.
The work is to be performed by an outside contractor or owner's service organization not part of the plant organization.
May 1981 1.8-65 Amendment 4 G
2.
The system or area of the plant affected by the work is' released to the contractor or service organization during the activity, and, except for radiological protection purposes and other specified centrols, effectively ceases to be part of an operating nuclear power plant.
3.
The contractor or service organization has been directed in advance of the work that conformance to Reg. Guide 1.116 and ANSI N45.2.8 will be required, consistent with the PVNGS FSAR position on these standards.
If the above conditions are not met, and the activity is per-formed by the plant organization, the plant administrative procedures, which satisfy the same basic criteria as this guide and standard, shall apply.
Interpretations of ANSI N45.2.8 4
k A.
Section 2.3:
Test reports attached to or referenced in data sheets may meet the evaluation requirements of the last paragraph; B.
Sections 2.2 and 2.3; 5.2 and 5.4:
For application of the provisions of these sections to preoperational and startup testing, the APS position on the applicable revision of Reg. Guide 1.68, " Pre-operational and Initial Startup Test Programs for Water-Cooled Power Reactors," shall take precedence where there is a conflict or difference.
C.
Item 2.9e(6):
This item shall be interpreted to mean that any work perf;cmed without an approved design change shall not be considered complete and acceptable for its intended use
(
until the change is approved, and that the intent of
._u.~u m
7 design change approval shall be required prior to placing the affected item in service.
sa D.
Section 5:
For the purposes of functional tests addressed by this standard, APS defines completed systems as any system, or portion or component thereof, on which construction 4
is sufficiently complete to allow the required testing, and on which further or adjacent construction will not render the results of such testing invalid or indeterminate.
E.
Item 5.1.g:
Traceability as used in this item is considered to be the same as discussed in section 5.2.13.3 of ANSI N18.7.
REGULATORY GUIDE 1.123: Quality Assurance Requirements for Control of Procuren.ent of Items and Services for Nuclear Power Plants (Revision 1, July 1977) 4
RESPONSE
For operations phase activities, the position of Regulatory Guide 1.123 is accepted.
REGULATORY GUIDE 1.144: Auditing of Quality Assurance Programs for Nuclear Power Plants (Revision 1, September 1980)
RESPONSE
The requirements of the referenced standard ( ANSI N45.2.12-1977) as modified and interpreted in the position of Regulatory Guide 1.144 are applied to the APS quality assurance program for operations phase activities, with the following exceptions:
4 A.
Section 4.2.1:
A written individual audit plan may not be prepared for each audit.
However, all informa-tien required for the written plan will be included in audit schedules, notification letters, checklists,
(
reports, procedures or other audit records.
B.
Section 4.3.1:
A formal Pre-Audit Conference' may not be required for some routine internal audits' where informal pre-audit communication is determined to be
l(0b f
I 3
'/
MousT W LiGHTioci & Po'ER.
l I
17.2.2 Quality Assurance Program 17.2.2.1 Regulatory Commitment.
The llIJ.P QA Program is a total 2
administrative control and quality assurance progrc.m developed to protect the health and safety of the public and to meet applicable regulatory Q421.2 requirements, The quality assurance program for aperations conforms to the l
following Regulatory Guides and standards, with clar: fications and exceptions as noted:
I O
RC 1.8, Revision 1-R:
Selection and training of QA Department personnel will conform to the requirements of this Regulatory Guide.
0 RG 1.28, Revision 0: The quality assurance program for operat ions will conform to the requirements of this Regulatory Guide.
16 O
RG 1.30, Revision 0:
The quality assurance program for operations will conform to the requirements of this Regulatory Guide.
11 9
RG 1.33, Revision 2: The quality assurance program for operations 9 Q421.48 will conform to the requirements of this Regulatory Guide.
j G
RG 1.37, Revision 0: The quality assurance program for operations will conform to the requirements of this Regulatory Guide.
16
+
9 RG 1.38, Revision 2: The quality assurance program for operations will conform to the requirements of this Regulatory Guide.
2 Q421.2
]
G RG 1.39, Revision 2:
The quality assurance program for operations will conform to the requirements of this Regulatory Guide.
G kG 1.58, Revision 1:
The quality assurance program for operations will conform to the requirements of this Regulatory Guide with the exception of regulatory position C.l.
Personnel who (1) approve preoperational, startup, and operational test procedures and test 16 results and (2) direct or supervise the conduct of individual preoperational, startup, and operational tests will be qualified under j
the guidelines of ANSI N.45.2.6-1978, rather than RC 1.8.
I G
RG 1.64, Revision 2: The quality assurance program for operations will conform to the requirements of this Regulatory Guide.
j G
RG 1.74, Revision 0:
The quality assurance program for operations will conform to the requirements of this Regulatory Guide.
G RG 1.88, Revision 2:
The quality assurance program for operations will conform to the requirements of this Regulatory Guide.
17.2-10 Amendment 16, 4/10/81
RG 1.94, Revision 1: The quality assurance program for operations 2
will conform to the requirements of this Regulatory Guide with the following clarification:
Q421.2 1)
The testing frequency of sleeves with filler metal (cadwelds) 7 will comply with Sections 3.8.1.6.3 and 3.8.3.6.3.
4 2)
ANSI N.45.2.5-1974, Section 4.8, states " Pumped concrete must be sampled from the pump line discharge".
In lieu of this statement, in process strength samples of pumped concrete are taken at the delivery point.
Correlation tests of air content, slump, and temperature are perf ormed to verif y these plastic properties of the concrete at the placement point in accordance with the following frequency requirements:
a)
A minimum of 2 correlation tests are performed for each pumped placement exceeding 200 cu. yds.
16 b)
Otherwise, a minimum of 2 correlation tests per week are perfvtmed when any individual pumped placenent during a week requires delivery of more than one truckload of concrete.
c)
During a week when a pumped placement exceeding 200 cu. yds.
is made, the correlation tests performed on that placement will satisfy the weekly requirement for performing two correlation tests as specified in Item B above.
When any of the specified limits and tolerances on loss of air content, slump, or temperature are exceeded at the placement point, correlation tests between the delivery point and placement point will be accomplished for each 100 cu. yds. of concrete placed as long as limits and tolecances are exceeded.
If two consecutive tests are out of tolerance, corrective action will be implemented to assure that subsequent loads awaiting discharge into the pump are within tolerances for the placement. This will be accomplished by adjusting the plastic property requirements of the concrete at the pump intake.
" Correlation Tests", " Delivery Point", and " Placement Point" are as defined in ANSI N.45.2.5-1978, Section 1.4 Samples and frequency for cadweld testing is in accordance with ACI-359/ASME Section III, Division 2, issued for trial use and comment in 1973, including addenda 1 through 6, (see Sections 3.8.1.6.3 and 3.8.3.6.3 of the STP Final Safety Analysis Report).
If a work activity and contract is for a two-month period or less, an audit is not necessary when a facility preaward audit,
has been conducted.
O RG 1.116, Revision 0-R:
The quality assurance program for operations 2
will conform to the requirements of t
's Regulatory Guide.
ggy 17.2-11 Arendment 16, 4/10/81
J n
RG 1.123, Revision 1: The quality assurance program for operations 2
will conform to the requirements of this Regulatory Guide.
Q421.2 0
RG 1.146, Revision 0: The quality assurance program for operations will conform to the requirements of this Regulatory Guide.
16 9
ANSI N45.2.12, Draf t 3, Revision 4: The quality assurance program for operations will conform to the requiremen's of this standard.
2
o this rear,on no failure of man-made structures is considered credible.
~
ro refer to discussion in Section 9.2.5.
4 Reculato Guide 1.28 Quality Assura:
Program Requirements (Design and astruction)
(Safety Guide 28, 7/72)
Discussion The quality assurance program (< c ' n and construction) for CPSES complies with the requirements t
guide, except as stated in Appendix 1A(fi).
Requlatory Guide 1.2,
Seismic Desic Classification (Revision 2, 2/76)
Ng Discuse on he seismic Category I classifications of CPSES ' structures, systems nd components confonns to this regulatory guide.
Also refer to Appendix 1A(ti).
Regulatory Guide 1.30-i
. Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment (Safety Guide 30,
~
8/11/72) e s
I A(B)-12 f
- s. <
Tt,a, u t I.in.
6..... J..s ).
,I
- 0.,. wy O. n,,,A.
Il. A
CPSES/fSAR Discussion This guide is applicable. to ^e installation, inspection, and testing of instrumentation and electric equipment 'at CPSES.
The quality assurance methods for operations phase actfyities will comply with the applicable guidance :ontained in this guide for those activities covered by this guide which are similar to construction activities.
The application of the requirements of N!SI H45.2.4 - 1972, as endorsed by this guide, will be in accordance with the guidance provided in ANSI N18.7 - 1976.
l Also refer to Appendix 1A(N).
Regulatory Guide 1.31 Control of ferrite Content in Stainless Steel Weld Metal (Revision 2, 7)
Discussi-Compliance wit i his guide is currently under review.
discussion of compliance will be rovided later.
Also refer to Appendix 1 A N.
Requlatory Guide 1.32 Criteria for Safety-Related E. ctric Powe Systems for Nuclear Power
' Plants (Revision 2, 2/77)
Discussion s
The CPSES dp>ign complies with the requirements of this gui (or details
[eSection8.3.
1A(B)-13 5
6
(
C
CpSE5/FSAR Also r r to s on 3.8 Regulatory Guide 1.58 f~.. -
Qualification of Nuclear Power Plant Inspection, Examinatien, and Testing Personnel Discussion With r'eference to the subject Regulatory Guide as it applies to
~
e activities during the Construction phase:
1.
For inspection activities within the scope of the ASME Code, inspectors are qualified in compliance with the requirements of Regulatory Guide 1.58, Re sion 1.
2.
For inspection activities outside the scope of the ASME Code, inspection personnel are qualified in general compliance with the requirecents of Regulatory Guide 1.58, Revision 1 except r_,follows:
a.
Sonc inspection personnel qualifications are documented on a IUGC0 foita and not on the Constructor's form.
b.
Some of the qualification forms are signed by a TUGC
]
representative and not by a Constructor l
represen,tative.
18 i
3 Qualification records arc collected, stored and controlled in compliance with ANSI N45.2.9 Draft 11, Revision 0 dated January 17,15I3asincluifed'inthe"GrayBook".
qg AMENDMENT 18 9
APRIL 21, 1981 1A(B)-24 5
\\
CPSES/FSAR
(
'scussion Manual i *tiation controls for B0P systems meet the recor.ndations of l
this Regula y Guide in accordance with'the comments Section 7.3.2.2.7.
Sys m level manual actuation of BCP uponents ('such as the auxiliary feedwater umps, containment spray p'..ips, component cooling 11 water pumps, etc.) is complished through e system level actuation devices described in Secti 7.3.2.2.7, or manual initiation of safety injection, spray actuation, o tea ine isolation, as appropriate to the component.
N Also refer to Appendix 1 { {).
Regulatory Guide '.63 Electri: P netration Assemblies in Containment Structure for Light ' ter-Cooied Nuclear Pouer Plants
[
iscussion 8
Q040.39 The CPSES Electric Penetration Assemblics comply with the intent of Q400 Revision 2 (7/78) of this regulatory guide.
For details see Section 8.3.
Regulatory Guide 1.64, Quality Assurance Requirements for the Design of Nuclear Power Plants DiscussiIn_
q 8
The quality assurance program for design and construction at CPSES Q421.19 incorporates the intended objectives of ANSI N45.2.11 (Draf t 2, Revision 2
- 5/73).
For operations phase activities related to major design modification, the quality assurance methods utilized will comply with 1
applicable guidance contained in Revision 2 (6/76) of this regulatory
~-
AMENDMENT 11 JULY 31, 1980 m
i CPSES/FSAR guide.
The application of the requirements of ANSI N45.2.11 - 1974, as endorsed by this regulatory guide, will be in accordance with the guidance provided by ANSI N18.7 - 1976. -
~
Q42.1 Also refer to Appendix 1A(N) and Section 17.2.
Regulatory Guide 1.65 Materials and Inspec 1 r Reactor Vessel Cl u
tuds 8
.j 4
A 2
k JULY 31, 1980 g
1 A(ii)-26a a
9
5, CPSES/f5AR
[
O cussion The termina n of the operating license and subsequent ecommissioning of the Comanche Po k Steam Electric Station will d ress the
~
regulations in efrect that time.
I-Regulatory Guide 1.87 Guidance for Construcy n of Class 1 Compon s in Elevated-Temperature
, Reactors (Supplem to ASME Section III Code Cas 1592, 1593, 1594, 1595, and 1 -
c F acussion This regulatory guide is not applicable to the CPSES.
Regulatcry guide 1.88 Collection, Storage, and Maintenance of fiuclear Power Plant Quality Assurance Records Discussion The quality assurance program for design and r.onstruction at CPSES incorporates the intended objectives of AtiSI ti45.2.9 (Draft 11, j
Revision 0,1/73).
During the operations phase, the quality assurance
{
8 methods and administrative controls utilized for controlling and l
Q421.19 4
storing QA records, as described in Section 17.2, will comply with the j
., applicable guidance provided in AriSI fi45.2.9 - 1974, as endorsed by d
Re,v)sion 2 (10f/6) o( this regulatory guide.
Application of the 3
requirements of Revi,sion 2 (10/76) of this regulatory guide will be in j
accordance with the guidance provided in AriSI ti18.7 - 1976.
j
~
A t
AMEriDMEriT 8
\\
tiOVEMBER 30, 1979 1A(B)-36 r
CPSES/fSAR
', Discussion The quality assurance program for design and construction at CPSES incorporates the intended objectives of AflSI.ti45.2.9 (Draft 11, Revision 0, 1/73).
During the operations ph'ase, the quality assurance raethods and administrative controls utilized for controlling and storing QA records, as described in Section 17.2, will reflect the
. applicable guidance provided in AflSI ti45.2.9 - 1974, as endorsed by this guide.
Application of the requirements of this guide will be in accordance with the guidance provided in AfiSI fl18.7 - 1976 Regulatory Guide 1.83 Qualification of Class IE Equipment for fluclear Power Plants (11/74)
Discu fon The CPSES C ss IE equipment design complies with the quali cation program guideli s as delineated in this guide.
for,det s see Section 8.3.
Also refer to Appendix 1A N.
R_egulatory Guide 1.90 e
Inservice Inspection of Prestress ConcgeContainmentStructures with Grouted Tendons (11/74)
Discussion
~
I 1
N This regulatory 9 fde is not applicable to the CPSES.
s A
\\
lA(B)-35
'\\
}
\\
3
CPSES/fSAR Regulatory Guide 1.92 Com ining Modal Responses and Spatial Components in Seismic Resp se Analysis Discussion ined in the seismic Modal responses and spat (al components are cor response analysis of the CPSES in conforma e with Revision 1 (2/76) of this regulatory guide.
C Also refer to Appendix 1A(N) a 3.78.
Regulatog Guide 1.93 Availability of ectric Power Sources Discussic_
i e CPSES design complies with 'the requirements cf this regulatory guide dated December 1974.
Also refer to Section 8.3.
Reculatory Guide 1.94 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the
-. Construction Phase of Nuclear Power Plants
=.
i Discussien This regulatory guide is not applicable to CPSES design and 8
Qe21.19 construction activities.
The quality assurance methods utilized during
)
.f NOVEMBER 30, 1979 3
i
CPSES/FSAR Reoulatory Guide 1.94 Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of fluclear Power Plants (Revision 1, 4/76)
Discussion This guide is not applicable to CPSES design and. construction activities.
The quality assurance methods utilided during the operations phase to control najor structural modifications will comply with a'pplicable guidance contained in this guid'e for activities which are similar to construction activities.
The application of the requirements of AftSI fi45.2.5 - 1974, as endorsed by this guide, will be in accordance with the gaidance provided in AriSI fi18.7 - 1976.
Regulatory Guide 1.95 Protection of !!uclear Power Plant Control Room Opera. tors Against an Accidental Chlorine Release (Revision 1,1/77)
Di scussion_
The CPSES design com ies with the intent of thi~5 R-ulatory Guide as described in Sections 6.
and 9.4.
Reculatory Guide 1.96 1
DA'signofMiinSteam. Isolation e Lea, e Control Systems for Boiling Water Reactor flucl a Power Plants (R ision1,6/76)
Discussion n
This regul ory guide is not applicable to the CPSES.
'r 1A(B)-37
{
s
)
i(,c1MC ' irs (,ND E!ICTRic o
Request for Additional Information Diablo Canyon Units 1 & 2 260-1 260.0 QUAL.ITY ASSURANCE BRANCH 260.1 The first paragraph of Section 17.2.2 indicates that PG&E will modify its QA program to be responsive to new guidelines published by the Nuclear Regulatory Commission and new industrial standards if and when they are accepted by the Commission.
In accordance with this commitment, delete reference to the
" WASH" documents on page 17.2-1 and provide PG&E's position on meeting the following NRC guidelines which have been published since the WASH dccuments:
Regulatory Guide 1.8, February 1979, " Personnel Selection and Training" a.
(endorses ANSI /ANS 3.1).
b.
Re~gulatory Guide 1.26, February 1976, " Quality Group Classifications and Standards for Water, Steam, and Radioactive Waste Containing Compo-nents of Nuclear Power Plants."
Regulatory Guide 1.29, September 1978, " Seismic Design Classification."
c.
d.
Regulatory Guide 1.30, August 1972, " Quality Assurance Requirements for the Installation, Inspection and Testing of Instrurentation and Electric Equipment" (endorses N45.2.4).
Reculatory Guide 1.33, February 1978, " Quality Assurance Prcgram Require-e.
ments (Operation)" (endorses ANSI N18.7-1976/ANS 3.2).
f.
Regulatory Guide 1.37, March 1973, "Quclity Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants" (enourses-N45.2.1).
g.
Regulatory Guide 1.38, May 1977, " Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of iter.:s for Water-Cooled Nuclear Power Plants" (endorses N45.2.c).
h.
Regulatory Guide ! 39, September 1977, " Housekeeping Requirements for Wa ter-Cooled Nuclear Power Plants" (endorses N45.2.3).
i.
Regulatory Guide 1.58, August 1973, " Qualification of Nuclear Power Plant inspection, Examination, ar.u Testing Personnel" (endorses N45.2.6).
j.
Regulatory Guide 1.64, June 1976, " Quality Assurance Requirements for the Design of Nuclear Power Plants" (endorses N45.2.ll).
k.
Regulatory Guide 1.74, February 1974, " Quality Assurance Terms and Defi-nitions" (endorses N45.2.10).
1.
Regulatory Guide 1.88, October 1976, " Collection, Storage, and Maira :ance of Nuclear Power Plant Quality Assurance Records" (endorses N45.2.9).
. m.
Regulatory Guide 1.94, April 1976, " Quality Assurance Requirements for Ins ta lla tion, Inspection, and Testing of Structural Concrete and Struc-tural Steel During the Construction Phase of Nuclear Power Plants" (endorses N45.2.5).
Regulatory Guide 1.116, May 1977, " Quality Assurance Requirements for n.
i Installation, Inspection, and Testing of Mechanical Equipment and Systems" (endorses N45.2.8).
o.
Regulatory Guide 1.123, July 1977, " Quality Assurance Requirements for Control of Procurement of Itcms and Services for Nuclear Power Plants" (endor",es N45.2.13).
p.
Regulatory Guide 1.144, January 1979, " Auditing of Quality Assurance Pro-grams for Nuclear Power Plants," (endorses N45.2.12).
q.
Regulatory Guide 1.146, August 1980, " Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants" (endorses N45.2.23).
r.
Branch Technical Ps.
- tion (BTP) 'SR 9.5-1 (attached to SRP-Section 9.5 /l).
260.2 Provide the composition of the Onsite Safety Review Group and discuss its functioning.
For example, does it review procedures before or after issuance?
Does each group member have " veto power" over procedures or does the majority rule?
If majority rules, how are dissenting apinions handled?
Discuss why this group is shown on Figure 17.2-1 as being at the general office and not at the plant site.
260.3 Clarify the last sentence of the full paragraph on page 17.2-8 which states:
If a stop work recommendation by a quality assurance engineer does not come under the provisions of the authority of the Manager, Quality-Assurance, or -
in the absence of the Manager, Quality Assurance, the Vice Prasident-Nuclear Power Generation will make the decision as to the action to be taken.
260.4 Figure 17.1-1 indicates that the responsibility for quality control is not assigned to the Manager of Quality
- lurance.
Describe the responsibilities of the following organizations as tney impact on the QA program for Diablo Canyon during the operations phase. Also indicate the number of supervisory and technical personnel in each.
a.
Quality Control under the Manager of Materials.
b.
Chief Engineering Quality Control under the Engineering Vice President.
c.
Insp,ectors under the Resident Engineers.
d.
Lead Quality Control Engineer (and staff) under the Senior Site Represen-ta tive.
e.
Quality Control under the Chief, Engineering Research.
r
Pesm::se to NFC Intter of Octob2r 7,1980
{$s'Eu; idditional Infor ration on FSAR j
260.1 W2 fully emply with all cf the Regulatory Guides listed with specific clarifications ar.d exceptions on the follcwing:
1 Ec<3ulatory Guide 1.8, February 1979, endorses ANSI /N;S 3.1 - 1979.
a.
03r Diablo Canyon draft Tech. Specs, refer to NJSI N18.1 - 1971.
Na can ecuply kith the trore stringent requiramnts of ANSI /N;S 3.1 - 1979 after three years of carmrcial operation.
b.
Design and construction of Diablo Canyon Power Plant started in 1965 and trost of the work cannot emply with the specific requircnents of Regulatory Guide 1.26, February 1976. The intent of the Fagulatory Guide has been follcwM as shwn by cccraring the Regulatory Guide with Tables 3.2-2 and 3.2-3 in the FSAR.
It is our position that the Safe Shutdwn Earthquake (SSE) for c.
the plant, as defined in 10CFR100, Appendix A, and referred to in Regulatory Guide 1.29, Septs bar 1978, is the Ecuble D2sion Farthpake (DDE). The ASLB las decidtd that the Hosgri event is SSE.
- i. Na will cc.1 ply with this Pegulatory Guide and-ANSI N45.2.6 - 1973 as applicable to nondestructive testing and Oaality Control insprtion personnel. Oar plant Oaality Control Insp3ctors, Iv>.suver, will not have the three levelc of qualifications described in th3 ANSI St:ndard. As sycified in the NF2 Interpretation of P33ulatory Guide 1.58, issued April 1,1977, personnel perfoming inspection, examination, and testing functions associated with norval operations of the plant, such as surveillance testing, 4
ruintenance, and cartain technical reviews norrally assigned to j
the plant staff, will b2 qualificd to ANSI N18.1 - 1971.
1Property "ANSI code" (as page type) with input value "ANSI N18.1 - 1971.</br></br>1" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Na will ccnply with this Regulatory Guide except for the 4-hou-fire rating requiraient for the records storage facility which will be used to store records that cannot b2 microfibrd, e.g.,
I radiographs and recorder traces. The on-site records storage facility will ricet the 2-lvsur fire rating outlined in Section 5.6 of ANSI N45.2.9 - 1979, issued July 15, 1979.
Our ccupliance with BTP ASP 9.5-1 has been the subject of a r.
thorough revicw by the NBC Staff. The results of this reGw are doctrmnted in Supple: Tents 8 and 9 to the Staff's Diablo j
Canyon Safety Evaluation Report. The Staff concludes in j
Supplcmnt 9 that "All mtters relating to the fire protection prcgram have nw bmn resolved."
l 1
d 260.2_
The co:po.;ition and function of tha Onsite Safety Review Group is discusrad in Chapter 13 of.the Final Safety Analysis Peport.
In response to your steific questions:
It is the intent of the Onsite Safety Peview Group to revica new proccdures and clunges to existing procedures b2 fore issuance; h.7ever, tliis is not a requiran>nt. This policy is inple:rentcd to assure that "the independent group shall not b2 responsible for sign-off functions such that it bmms involved in the operating organization."
On any safety-related decision, a unanirous vote of the group is required.
If a vote on any issue is not unaninous, both najority and minority reports will b2 prepared and presentcd in the group's report to the F3 nager,I;uclear Projects.
Figure 17.2-1 is in error and lus been corrected. A copy of the revised Figure 17.2-1 is shown on page 6.
The Onsite Safety Raview Group will h2 physically located on-site. The chaln un of the Onsite Safety Faview Group reports off-site to the Panager, Nuclear j
Projects.
i 260.3 The ste:>-wrk authority assig:vd to the Panager, Qaality Assurance, l
is describal in Section I of the Quality Assurance Manual for Operating Nuclear Poer Plants. Tnis Section states, "... Should twre b2 a breach of any Inrt of the quality assurance prcrgram or tha technical or regulatory requircnents wherein public health or safety could be involved, the Maager, Quality Assurance, has the responsibility aM aut%Iity to stop the wrk.
If stopping the work wald involve c:unging pomr level or separating a generating unit frcm the IGandE systan, concurrence of the Vice President, Nuclear Peer Generation, is rcquired.
In the absence of the Manager, Onlity Assurance, the Vice President, Nuclear Pomr Generation, will rake the decision as to the action to be taken..
260.4a The Faterials Quality Control Cocrdinator reports directly to the Manager, Materials D2partmant. He develops aM maintains the Miterials D2partrent Quality Control Pro 3 ram and provides training in quality control to Paterials D'partnnnt p2rsonnel.
He audits their Ordity Control Program, reports on its effectiveness, and recanamndt appropriate corrective actions to the Panager, Vaterials D :partwnt. He is the prinury and principal liaison with the Quality Asst.rance Departm2nt as v211 as other CaTpany depart:n'nts in ratters relating to M1terials quality control. Th're is one sup2rviso" i
260.4b The Chief, Engineerin'y Quality Control (EOC), assu"es that the j
Ig Departm2nt parrotTns the follcwing functions:
J 1
1.
D2Velops and niintains the Digineering D2part:a2nt Quality j
Control Program.
Provides training in quality cont-ol to Engineoring D2partmnt Vrsonnel. Au3its the B2C Program and reports on its effectiveness. There are three supervisors and five technical personnel.
i 1
s.
^
I l
2.
Perfona or witnesses ahop tests and inspects cquirnent and natarial during :ranufacture or ambly. Evaluates the mpability of prospcctive suppliers to perform work l
to Carpany standards. There are five supervisors and l
twenty tcchnical personnel.
260.4c_ Th2 Senior ' Site Representive reports to the Construction Super-intendent and sup2rvises on-site activities, assures that itens and activities emply with quality and design require:ents, and inglerents the Ceneral Construction Quality Assurance Program.
Inplun?ntation is through Resident Engineers, Field Engineers, Inspectors, and Forcren.
NOTE: General Constniction will act as a contractor to Nuclear Plant Operations at Diablo Canyon during the operations phase. The numb'r of supervisory and technical personnel will be te" ally dependent upon the scope and type of kork to be per b naad. Tne Plant Manager will luve the responsibility for administering any contracts during the operations phase. Quality Control activities during construction activities in the operations phase will be perforned by Nuclear Plant Cperations.
260.4d Tne Icad Quality Control Engineer reports to the Senior Site Fepresentative and performs required in-process and final inspections of wrk perforned by PGarxiE physical forces, audits activities of contractors and PGandE personnel, processes and naintains doctnentation rcqaircl DESCRIPTION l Lpa
~E i
II. ANSI N18.7-1976, Quality Assurance for the Operational Phase of Nuclear Power Plants.
A. Regulatory Guide 1.33, Rev.1, January 1977 "o alternate positions.
B. ANSI N18.7 Paragraph S.2.17 specifies that inspection of operating activities may be conducted by second-line supervisory perscnnel or by other qualified personnel not assigned first-line supervisory responsibility for conduct 9et of the work. WPPSS allows plant operations shif t supervisors (first-line supervisors) to perform inspec'tions of survej,jl'nce tests provided that an af ter the fact review of surveillance documentation is performed by the 0,nerations Supervisor (a second-line supe'evisor) or by other personnel not assigned first-line responsibility fdr the conduct of the work.
1' c 9 44 sqdsq t
t 6n 1.:6,h; Q g, RuancA cytds < a E..
wd M'
\\ Spc- (ceuu'e w g UN5 E 9tc[dk:c {c919 f-t
,q h A
%. Asa ymu (
4 racc 3 or 19 we+s m M..
/'
~
- (
3
"'V-C^#E T
WASliLNG 5 0;; PUBLIC POWER SUPPLY SYSTE'.:
.' TO 3
04/28/78 P
OPERATIONAL
'.["*/
AP9HOVED g"A_)
QU.\\LITY ASSUR.iNCE PROGRA.\\1 D."'
- RIPTION SdMWL-III. A!:SI f145.2-1971, Quality Assurance Program Requirements for !!uclear E er Pl31ts.
A.
Regulatory Guide 1.23, June 1972-flo alternate positions.
B.
ANSI l145.2 Alternate positions - See the ','PPSS position statements on ANSI 1118.7 and the t!?5.2 daughter series.
i l
i 1
l l
e I
w%s mi PACC 4 CF h
r.
W W AS!!!.NGTO.'i PUBLIC PO"iEP. SUPPLY SYSTE:.:
PC
~
% ;'~
OPER ATION A L 3
04/28/78 (2 k -
- i. ULT 6vea l
I L f.a QU Al.1TY ASSUR.\\NCE PitOGRAM DESCitlPTION l; 7, N, Q, g (_.-
d y,Y/i IV. At!SI t!45.2.1-1973, Cleaning of Fluid Systems and A ciated Components Puring Construction Phase of Nuclear Power Plants.
A. Regulatory Guide 1.37, March 16,1973 - tio al ternate position.
B. AriSI t!45.2.1
- l. Section 2.3:
The Supply System takes exception to the requirement that the evaluation of the data be included on the data sheets since this is the function of the. test report and since it also precludes the structuring of data sheets for the exclusive use of recording data.
esco 5 or 19 L
v
?
^"
QF WASHLNGTON PUEIJC POWER SCFPLY SYSTE!.*
hI OPERATIONAL 3
04/28/78 q?')
-ovw L-QUAUTY ASSURANCE PPOGRAM DE5CRIPTION V.
AflSI 145.2.2-1972,_ Packaging, Shipping, Receiving, Storage and Handling of items for fluclear Pcwer Plants.
A.
Regul,ttery Guide 1.38, May 1977-l10 alternate positions S.
AflSI l145.2.2 1.
Paragraph 3.2.1, Item 1:
Temperature and humidity controls concerning levels of packaging are not considered to be required for nuclear pcwer plant fuel assemblies unless otherwise recommended by the fuel supplier.
2.
Paragraph 3.5.2:
WPPSS may elect to utilize tapes for identification indef-initely.
Use will be subject to the provisions of the WPPSS Position Statement on At4SI t145.2.2 APPA, paragraph A3.5.2.1 (a concerning chemical composition of tapes, and the section of this paragraph which addresses weld proximity.
Therefve, the phrase "may remain until system testing" will not appi.,
3.
Paragraph 3.7.1:
WPPSS may use cleated, sheathed boxes for loads up to 1,000 pounds rather than the 500 pound limit imecsed here.
This type box has been tested by :he Wr:P-2 ::SSS vendor, and been i
founo safe.
Other national standards allcw the 1,000 pound i
designation, see Federal Specificaticn PPP-8-501.
4.
Paragraph 6.1.2, Item 1:
Temperature and humidity controls concerning levels of storage are not considered to be recuired for nuclear pcwer plant fuel assemolies unless otherwise recorrended by the fuel supplier.
5.
Appendix A, Paragraph A3.5.2.1.(a:
WP. CSS will abide by '.he chemical ccmposition guidelines estab-lished by the regulation guide, with regard to control of tapes, dessicants and dessicant bags.
race 6 or 19
,,,,,y
W WAS:-IINGTO.N* PUBLIC POWEP. SUPPLY SYSTE:.'
3 04/28/78
([J OPEltATIONA L 4,, n o v a
.t.p.
QUA!.lTY AdSUllANCE Pl!OGit AM DESCl:11' TION Q
'7 %g f,h2 4
A---
VI. ANSI N45.2.3-1973, Houser;eeping Dur'og th? Construction Phase of Nuclear Power Plants.
)
A. Regulatory Guide 1.39, Rev.1, October 1976 - No alternate positions.
B. ANSI N45.2.3 Paragraph 2.1:
WPPSS does not intent to create cleanness zones at'the plant site in accordance with the cleanness zone designations listed in this standard.
WPPSS recognizes the need for good housekeeping practices and cleanness and, therefore, will comply to the various levels of control necessary' to meet the intent of this standard.
Controls will be accomplished with approved procedures e.g., Administrative, Operational, Maintenance, Safety and Health Physics, which will be at least as strigent as requirements noted in table of paragraph 2.1.
gg.
e4cc 7 or 19 o,+, ni
a -
c^rc Mh WASHINGT,0N PUBLIC POWEP. SUP?LY SYSTE'.:
VJ 3
04/28/78 OPERATIONAL
~"" ""
qw QUAI.ITY A55CE ANCE PROGR.O! DESCRWrION
/ ?'i k / _
L V I I. dilS I fl45. 5. 4-19_7_2 Installation, Inspection and Testing Requirements 2
ror instrumentation and Electrical Equipment Durinc the Construction of fluclear Pcwer Generating Stations.
A.
Regulatory Guide 1.30, August 11,1972-tic al ternate posi tions.
3.
AtJSI fi45.2.4-ilo alternate positions.
i l
1 J Q*
WPall R3 PACC OF
4'V-
- ^7E P*ij0.O WASHINGT,0N PUBUC POWEP. SU??LY SYSTC.
/
3 04' 28/78 2 -
OPERATIONAL Q' o 3h/
w uoveo t.y QUALITY A55i?RANCE PROGR.UI DESCRIPTION g
1 VIII. ANSI iM5.2.5-1974, Supplementary Quality Assurance Recuirements for Instaflation, Insoection and Testing of Structural Concrete and Structural Steel During the Con <truction Phase of ?uclear Pcwer Plants.
A.
Regulatory Guide 1.94-No alternate positions.
B.
AliSI tt:5.2.5-t:0 alterna:e positicns.
W Dd 5 m g PAGE g CF L
M LV.
OATL l-
%m..
WASHINGTON PUBLIC POWEit SU? PLY SYSTE.:
m 3
IU#
MM8 g 9-]
. OPEltATION Al, amvta C-()U A!.lTY A55 Cit ANCE PitOCit.01 DESC!tlPTION IX.
ANSI Nc5.2.6-1973, Qualificaticns of Inspection, Exarination and Testing Personnei for the Construction Phase of Nuclear Power Plants.
A. Regulatory Guide 1.53, August 1973 - No alterr. ate positions.
B. ANSI N45.2.6
- 1. Paragraph 1.1:
The applicability of the standard (as modified herein) will be limited to W9PSS personnel performing inspection, examir.ation and test activities as part of the quality verification pr9 cess bU'c":
..ho are not already qualified to ASNI 18.1 requirements...
Personnel approving inspection, examination and test procedures are included in the applicability. Persor.nel involved in handl.ng of data or centrol of reports and records are excluded cggc3 from applicability of the standard since these are acministrative rather then i.nspection, examination and test activities.
The extent of applicability to UPPSS suppliers will depend upon the nature and extent of material or services furnished, and is further described in this position.
- 2. Paragraph 2.2:
For Non-NDE Personnel the individuals perform 4og inspection, examination and +esting functio,ns associated with normal operations of the plant, such as surveillance testing, routine maintenance and certain technical reviaws normally assigned to the onsite, cperation organization are qualified to ANSI N18.1 -
1971Property "ANSI code" (as page type) with input value "ANSI N18.1 -</br></br>1971" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Personnel whose qualificat'ons are not required to meet those specified in ANSI N18.1 and who are performir.g inspection, 63\\b3 examination and testing activities during the operational. Phase of the plant are to be qualified to ANSI N;5.2.6-19~.'3 except that formal certification as described in this caragraph is not planned. Inspection and test personnel will be selected to predet rained qualification require. tents for the specified task based on their educations, experience and trainir.,. Experience shall be intrepreted to mean actual experience in carrying out the types of inspection, examinaticn and testing activity beir,g performed. These persons will be subject to evaluation and review at least every two years to ensure their continued proficiency. A list of persons considered so qualified will be maintained current in the department :nat they pertain to, along with their qualifications, and the types of inspections and tests they are qualified for.
W P4il Al Page 10 of 19 t
k WASHINGT.O. PUBLIC POWEP. SUPPLY SYSTEM 3
04/28/78 OPElt AT10N A1, 6%s) o.ovco
.C
,J QUAL,lTY ASSUllANCE PitOG!tA.\\1 DESCillP!'!ON A simil'ar approach will be used to evaluate qualifications of fion-flDE personnel of WPPSS suppliers.
- 3. Paragraph 2.2.4:
WPPSS does'not propose to issue formal certification to individuals with the details mentioned in this paragraph. However, the information will be available in documented form attesting that the individual is capable of performing the task.
Qualification characteristics shall also be documented.
WPPSS will use a similar approach in evaluating its suppliers compliance with this paragraph.
Certifications of t;DE Personnel will be maintained per SNT-TC-1A.
- 4. Paragraph 3.0:
Qualification requirements, including levels of capabili^ty, will be met for WPPSS and supplier fide personnel per position taken on Para. 2.2.
For tion-flDE personnel, the position taken on para. 2.2 will be used. Assignment of inspectors to specific tasks will take into account education, experience and technical knowledge.
THe inspectors will not be assigned Levels I, II and III as stated in the standard. However, the selection of personnel for particular tasks will be such as to match the c habilities to the types of '. asks, and maintain the intent of the three levels. The judgement to determine that a person's qualifications and capabilities meet the intent of a certain level of inspection function is made by the normal management process, using established acministrative and personnel procedures. Documentation for such justification is included in personnel files (See Attachment I).
A similar approace will be used to evaluate qualifications of rion-NDE persennel of WPPSS suppliers.
- 5. Paragraph 3.1:
See 3.0 above.
- 6. Paragraph 3.2.2:
A. Inspection and Testina Functions See 3.0.
- 7. Paragraph 4.0:
See 2.2 and 3.0.
encc 11 or 19 o,m ni
(
Wi W.tSiilNGTON PUBLIC POL *EP. SUTFLY SYSTC*
P-1C 3
04/28/78
-a -c OPERATIONAL q' ;,b-QU.\\LITY.\\SSURANCE PROGRA.\\1 DESCRIPTION
...aovco yg 7
6.
Paragraph 3.2.2:
a.
Inscection and Testing Functions See 3.0.
7.
Paragrapn 4.0:
See 2.2 and 3.0.
l eacc l2 or19 j
- ~is as l
L
ATTACP. MENT I TYPICAL CONTENT OF PERSONNEL Q'JAL.IFICATION FILE
(
l.
Education and Training o
Suc. mary of formal education. decrees, etc. obtained (year) o Part-time courses attended, periods, degrees or diplomas obtained o
Seminars.or training sessions attended, periods, certificates issued, if any o
Membership of professional bodies o
Any recognitions or awards received in fields related to the nature of work 2.
Experience a.
This section is a summary of work experience before joining WPPSS.
It is not a resume'.
Chronological employment history is not require:. Typically, it will be one paragraph summarizing totiT~ experience, stressing areas most relevant to the nature of job.
b.
Record of positions held in WPPSS, and the period of time in each, complete with'a position description in each case.
3.
Assignment of Inspection and Test Functions o
Initial assignment of inspection and test responsibility as o
Implement inspection and test procedures o
Evaluate inspection and test results o
Approve inspection and test results o
In each case state precisely the tyce of inspections and tests o
Reassignments o
Re-evaluation at least every two years 4.
Physical o
Eye test results (J-1) o Color vision test results o
Other physical examination results All above shall be current within one year.
.u
\\
1 5.
Termina tion i
, rmination or inspection and test assigr. ment, date o
ie j
j o'
Termination of employment, date 4
1 1
4
?
I I
0 i
1 5
e 6
e E
i 1,
i i
i 5
i i
f i
h i
s i
{
l.
l
'we'
. wm m--+
. w w-w-wm,-ww -
.. wver.
Yd WASHLNGTON Pl*BLIC POWEP. Sl;? PLY SYSTE:.
04/28/78
~
(Cha)'
CPEllATIONAL j
D' a m oets
()UAl.lTY A55UltANCE PltOCitAM DESClllPTION X. AtiSI f145. 2.8-197 5, Supplementary Quality Assurance Requirements for IEtaffation, inspection and Testing cf i<echanical Equipment and Systems for the Construction Phase of !!uclear Power Plants.
A. Regulatory Guide 1.116, Rev. 0-R, June 1976 - fio alternate positions.
B. A!!SI fl45.2.8 Section 2.3, Last Para:
The Supply System takes exception to the requirement that the evaluation of the data be included on the data sheet since this is the function of the test report and since it als.c precludes the structuring of data sheets for the exclusive purpose of recording data.
t racc 13 or 19
,,m m i
1
^Y WA5!!!NGTON PUBLIC POWEi1 SUPPLY SYSTE:.:
P'M 3
04/28/78
^
OPEllATIONA L i
t}J QUAI.lTY ASSUltANCE PitOGitA.\\1 DESCll!!' TION
.7 x!. Af4SI f445.2.9 - 1974 Requirements for Collection, Storage and Maintenance of Quality Assurance Records for fluclear Power Plants.
A. Regulatory Guide 1.88, Rev. 2, October,1976 - fio alternate positions
- 8. AflSI fl45.2.c - Sections 4 and 5:
Pre-established records checklists are not considered to be mandatory for all quality records (e.g. logs, surveillance tests, minutes of plant operating committees). Procedures governing receipt and storage of quality records shall specify when records checklists are required.
Where p.ocedures sp;cify that quality assurance records shall be generated 'during the accomplishment of an activity, that procedure may be considered to serve the purpose of a checklist.
Procedures shall specify how the requirements of these sections apply to the use of temporary working files (e.g. keeping plant logs in a temporary wor!.ing file for a specified period prior to transfer to permanent.sto. age files). These procedures shall assure that adequate control is provided.
t 1
eacc 14 or19 wem m
W' W
WASI:LN'GTON PUBLIC POWEP. SUPPLY SYSTE P V=G 3
04/28/78 g iS.;,
OPEll ATION AI, a
ar, ovio CJ QUAL!TY ASSUltANCE PitOGllA.\\1 DESCl!!PTION g
XII. AtlSI fl4'5. 2.10-1973, Quality Assurance Terms and Definitions.
A. Regulatory Guide 1.74, february 1974 - fio ternate positions.
B. AilSI N45.2.10 The following definitions will be used in lieu of the definitions given in the standards.
- 1. Procurement Documents - Requisitions, purchase orders or contracts with attachments necessary to specify/ verify requirements.
- 2. Specifimtion - A statement of a set of requirements to ha satisfied by a product, a material, a service or process indicating, whenever appropriate, the procedure by means of which it may be determined whether the requirements c
given are satisfied.
e ace 15or 19 orm a.
m
- i" d
WAS!!!NGTON PUBLIC POWEn SL1 PLY SYSTE:*.
.pn 3
04/28/78 OPEllATIONAL J
QUAL.!TY ASSUllASCE PROGilA31 DESCitlPTION
,,7 XIII. AflSI f145.2.ll-1974, Quality Assurance Requirements for The Design fluclear Power Plants.
A. Regulatory Guide 1.64, Rev. 2, June l'976.
Paragraph C.2:
i WPPSS takes excep'. ion to that part of paragraph C.2 that states that individuals performing design verification should not have irrmediate supervisory responsibility for the individual performing i
ti.e design. WPPSS may, by meeting the conditions listed below, make use of the originator's supervisor for desig. verification:
- a. The supervisor is the most technically qualified individual available. The justification is individually documented and approved by the supervizor's management in advance of releasing l
the approved design f or work.
- b. Quality Assurance audits cover frequency and effectiveness of use of supervisors as design verifiers to guard against abuse.
B. AfiSI !!45.2.11 - flo alternate positions.
wen as
- cc16or 19
i e
I 4h W.\\SillNGTON PUBLIC PONIEi'. SUPPLY SYSTC.*
^
-Cd
~3 04/28/78 s[s'gr),-
l g.
OPEllATION A L 4, ~ o v e. o
[
. 'lJ QUAL.!'iT ASSUltANCE Pl!OGitA.\\1 DESCillPTION 7
XIV. AftSI fl45.2.12-(Draf t 3, Revision 4) February 22, 1974 ty\\h8 Requirements for Auditing of Quality Assurance Programs for fluclear Power Plants.
A. There is no Regulatory Guide.
B. Ai;SI ::45.2.12 Paragraph 3.4.2 Program elements shall be audited at the frequencies identified in the WPPSS-position on AtiSI 1118.7 l
.i i
l 1
i raccl7cr 19 wem ai
irk
'Ev.
047c WAS!UNGTON PUBLIC POWEP SUPPLY SYSTE*.:
,g:;g 3
04/28/78 OPERATIONAL Q}.?h
^"I LgJ QUALITY ASSURANCE PROGRA.\\1 DESCRIPTION Y$$$.d.-
XV. AriSI it45.2.13-1976. Quality Assurance Recuirements for Control or7rocurement of ftems and Services for fluclear Pcwer Plants.
A.
Regulatory Guide 1.123, Draft, October 1976-ilo alternate positions.
B.
AflSI ft45.2.13-tio alternate positions.
l l
l PACd,$ Of lh W Nis 41
^
Y'8 WASHINGTON PUBUC POWER SUPPLY SYS[E:.:
' r?[C 3
04/2?/78 OPERATIONAL Cy# './
ure s so
~ g.)
QUAI,lTY ASSURANCE PROGRA>l DESCRIPTION 7
XVI. Al4SI fl101.4-197?, Quality Assurance for Protective Coatings Applied
'to ltiic~ lear Fac ifities.
c A.
Regulatory Guide 1.54, June 19/3 - tio alternate positions.
B.
AtiSI fl101.4 1.
WPPSS will envoke the requirements of this standard when procuring outside services for protective coatings.
If WPPSS applies protective coatings or effects repairs to existing protective coatings the applicable requirements such as inspections, Quality Assurance
$2l44 Program, materials, application, surface preparation etc. will be followed to the extent applicable for the owner performing the work rather than a contractor.
4 swPall Rg PACE}9 OF 19
V'8 WASHINGTON PUBLIC POWER. SUPPLY SYSTEM
^'"
3 4/23/78 hp OPERATIONAL am.ovoo g
QUALITY ASSURANCE PROGRAM DESCRIPTION I
17.0 Oy LITY ASSURANCE RECORDS 17.1 PURPOSE 17.1.1 This section establishes measures to assure that sufficient quality-related documentation is generated, identified, indexed and safely stored to provide a written documentary record of quality-related items and activities.
17.1.2 Documents to be made a part of the Quality Assurance Records shall include, but not be limited to the following:
operating logs, results of reviews required by the Operational QA Program to be performed, inspection reports, test reports, r.udit reports, procurement documents, material analyses, personnel, procedure and equipment qualifications, procedures, drawings, specifications, correspondence and related records pertinent to quality, as defined in the procedures for record management.
17.2 GEyEPAL 17.2.1 Managers of Cepartments and Plant Superintendents shall be responsible for. preparation, review, approval and the implementation of specific procedures and instructions for control of records under their cognizance (including those generated by them and those turned over to them by external organizations) and for incorporating the corpleted records into the OA records retention system.
17.2.2 Procedures for the offsite CA records retention system shall be developed by Engineering Services Operation to provide methods for the collection, indexing, including appropriate cross-referencing to insure prcmpt and accurate retrieval, storage, filing, maintenance and disposition of quality assurance records transmitted to them for retention.
17.2.3 Requircsents and responsibilities for record generation, retention, transmittal, and maintenance shall be established and documented consistent with the requirements in ANSI 45.2.9 and applicable pro-curement documents.
17.2.4 Quality Assurance documentation associated with procured materials, parts and components received or controlled by a WPPSS off-site organization will be controlled, reviewed and stored in accordance with the off-site organization': ;;ucedures until the item is released to the plant site, at which time the relatd documentation will be transmitted to t'e site for control in accordance with applicable plant procedures.
e vars as Pact I cr 7
s, r'75*LC 3
WAS!f1NGTON PUBLIC POWEP. SUPPLY SYSTE:.:
l4/28l78 OPEltATIONAL Cg,i.,.
APA6*OvCO ga QUALITY ASSURANCE PROGRA.\\1 DESCRil' TION 17.2.5 Procedures shall specify construction features and location requirements for record ',torage facilities which assure that GA records are protected from ;cssible destructico by causes such as fire, flonding, thef t and from possible deterioration by a combination of extreme variations in temperature and humidity.
e 9
4 4
2 or 2 WNIS R1 PAGC u
J
4;p WAsiUNGTON PUBLIC POW En SUPPLY SYSTEI.*
l" "
^"
4/28/78 OPERATIONAL
&p>&
seruovto L.
QUALITY ASSURANCE PROGRAM DESCRIPTION i_'
/N
,L--
18.0 AUDITS 18.1 PURPOSE This section provides measures to assure that sufficient audits are performed in a planned and systematic manner to verify complia ce with, and the effectiveness of all aspects of the WPPSS Operational Qt ality Assurance Program.
18.2 GENERAL.
18.2.1 The Manager, Quality Assurance is responsible for development and imple-mentation of a syr, tem of planned and periodic audits of WPDSS and its suppliers to verify compliance with applicable aspects of che Operational
~
Quality Assurance Program.
These audits will be conducted on a schedule which requires that each area of activity be evaluated against each element of the Quality Assurance Program within a specified time occiod.
18.2.2 The assigned Quality Assurance group in residence at the plant site shall conduct audits of in-plant activities.
The Quality Assurance Department A -
Audit Group, which is not resident at the plant, shall conduct audits of the plant site assigned Quality Assurance group, of WPPSS organiza-tions at the home office whose activities affect the operating plant, and of off-site suppliers.
18.2.3 Plant functions that are performed on a routine, scheduled basis, such as preventive maintenance, calibration, etc., are audited frequently enough to verify compliance. Audits are normally scheduled as reouired for special evolutions, such as major modifications.
In addition, unscheduled audits may be conducted in any area from time to time on any aspect of 10CFR50, Appendix B or this Operational Quality Assurance Program.
18.2.4 Audit team members are certified / qualified in accordance with Quality Assurance procedures.
18.2.5 The audit team is structured in a manner to preclude an auditor from having direct responsibility for the area which he is auditing.
18.2.6 Audits are conducted using pre-established written procedures / plans /
checklists in accordance with audit procedures.
Audits include (as appropriate) but are not limited to evaluation of work areas, activities, processes and goods; the review of documents and records; and quality-related practices, procedures, and instructions to 4
determine the effectiveness of implementaticn of the Operational Quality Assurance Program and compliance with 10CFR50, Appendix S.
P ACE l QF 2 WPJil Al
r-1 i
j
=
"E**
^'*
.T.C WASHINGTON PUBUC POWEi1 SCPPLY SYSTE!.
F TC 3
4/28/78 g7.A. -j3.,.
OPERATIONAL A P ='* A O V E D s,,g QUALITY.\\SSURANCE PROGRAM DESCRIPTION y
18.2.7 Audit findings are documented in audit reports transmitted from Quality Assurance to the responsible nanager(s) or outside organization (s) who are to review the audit report and to ensure that corrective action is accomplished in a timely manner.
Timely follow-up action is provided (including re-audits) as required to ensure corrective action has been ta ken.
Documentation associated with corrective action and follow-up action is traceable to the original audit report.
18.2.8 Audit findings shall be analyzed and the reports which indicate quality trends and the effectiveness of the OA program shall be reported to management for review and assessment. ~
e m
.s wem m rwc 2 or 2
" 'V -
^
W WASillNGTON PUBLIC POWEP. SUPPLY SYSTE:.:
i 3
4/28/78 OPERATIONAL djh a m oveo LF*
QUALITY ASSURANCE PROGRAM DESCRIPTION g
. ) W %_L-1 APPENDIX A Terms and Definitions (Also see ANSI h45.2.10)
ANSI N45.2 Series - Industry standards for quality assurance for nuclear power plants.
Approval,- An act of formally endorsing or adding positive authorization, or both.
ASME Code,Section III - A :ection of the ASME Code entitled " Nuclear Power
~'lant Components" wnich constitutes the ASME requirements for the construction P
of nuclear power plant components and appurtenances as defined in Article NA-1110 of Section III.
Utilization of this section of the code has been adopted by the State of Washington as a legal requirement.
Audit - An activity to determine through investigation the adequacy of, and adnerence to, established procedures, instructions, specifications, codes, and standards or other applicable contractual and licensing requirements, and the effectiveness of implementation.
~
Contractor - Any organization under contract for furnishing items or services.
It-inciticTs the terms Vendor, Supplier, Subcontractor, Fabricator and sub-tier levels of these where appropriate.
Deficiency (Desiation)_ - A nonconformance or departure of a characteristic from specified requirements.
Design - Technical and management processes which lead to and include the issuance of design output documents such as drawings, specifications, and other documents defining technical requirements of systems, structures, and components.
Design Changes - Changes in drawings and specifications which defiae the design ot" Category I systems, structures, and components of in-service nuclear power plants.
Disposition _ - A statement of actions required to resolve a nonconformance.
Documentation / Records - Written or pictorial information describing, seTinino, specifying, reporting or certifying activities, requirements, pro-cedures or results.
~.s eacc i or 4 wem. m
,i
"'V-
^'E T~1 WASHINGTON PUBUC POWEn SrPPLY SYSTEM 0,' %. M F
OPE!1ATION Al.
3 4/28/78 J@ar~ino'. O
.M LW QUALITY ASSUltA.NCE PROGilA\\1 DESClllPTION 7 -
4 In-Service Inspection - The inspection performed generally 4 ring a reactor refueling outage or plant shutdcwn which assures that the nuclear equipment, vessels, and materials are of sufficient integrity to provide protection of public health and safety.
Inspection - A phase of quality control which by means of examination, observation or measurement deter:aines the confccmance of materials, supplies, components, parts, appurtenances, systems, processes or structures to pre-determined quality requirements.
Instructions - Documents that specify. how ar) activity is to be performed.
They may include methods to be employed, material, equipment, or parts to be used, and a sequence of operations.
Maintenance - Collectively, the activities associated with servicing, replacing, and rebuilding plant structures, systcms and components to ensure continued compliance with design document requirements of the plant during operations.
Measuring and Test Equipment - Those instruments, gauges, tools, and measuring devices used during inspection and testing to determine that measuring and test parameters comply with appropriate re,yirements contained in specifica-tions and drawings.
Modification - A planned change in plant design or operation and accomplished in accordance with the requirements and limitation of applicable codes, stan-dards, specifications, licenses and predetermined safety restrictions.
NCR (Nonconformance Report) - Tne form used to document nonconformances of material, appurtenances, componen s, parts, systems and activities for WPPSS Nuclear Power Plants.
NRC Criteria _ - Criteria pertaining to Quality Assurance Programs from 10CFR50, Appendix B.
Nonconformance - A deficiency in characteristic, documentation, or procedure Eich renders the quality of an item unacceptable or indeterminate.
Examples of nonconformante include:
physical defects, test failures, incorrect or in-adequate documentation, or deviation from prescribed processing, inspection or test procedures.
Procedure - A document that specifies or describes how an activity is to be performed.
It may include methods to be employed, equipment or materials to be used and sequence of operations.
Procurement Documents - Requisitions, purchase orders and contracts with attacnments necessary to specify/ verify requirements.
uce 2 or 3 m s ni
a,
^'E Vf8 W AS!!INGTON PUBLIC POWER SLTPLY SYSTE:4 p'd 3
4/28/73 OPERXI ION A1.
- -Q[
==
eo uga QU ALITY ASSURANCE PROGRAM DESCRIPTION j
- w Ouality Class ! - Any nuclear system structure subassembly, ccaponent or s
cesign characteristics that prevent or mitigate the consequences of postu-lated accidents that could cause undue risk to the health and safety of the public. All engineered safeguards fall within this category. All Quality Class I items meet the applicable provisions of 10CFR50 Appendix 8 (Refer to the SAR and each plant's master equipment list).
Quality Class II - Any system, structure, subassembly, component, or desian cnaracteristic which, as a result of be a.g defeci.ive, could causo a safety hazard to plant personnel, an extended reduction in unit outpd, an un-scheduled unit trip, or equipment damage.
Quality assurance requirements for these items are assigned in the appropriate purchase specifications.
Cuality Class G_ - Any non-nuclear system, structure, subassembly, component or design characteristic to which Quality Assurance requirements are assigned in accordance with the consequences of failure, operating costs or procure-ment costs.
Re.iect - A disposition that provides that a nonconforming item ic unsuitable for its intended purpose or uneconomically feasible to be reworked or repaired.
Repair - The process of restoring a nonconforming characteristic to a condition sucn tnat the capability of an item to function reliably and safely is unimpaired, even though that item still may not conform to the original requirement.
Review (Document) - A de' liberate, critical examination for content adequacy of cocuments to meaningfully review reouirements which may(be accomplished before, during or after the activity controlled by the document s).
Review ( ActivitieQ - A deliberate, critical evaluation corAucted to assure '. hat an activity will oe, is being, or has been accomplished in.:mpliance with pre-determined requirements or goals.
The evaluation may be corducted before, during or after accomplishment.
Rework _- The process by which a ncnconforming item is cada to conform to a prior soecified requirement by completion, remachining, reassembling or other correc-tive means.
Services - Activities performed by a supplier such as design, fabrication, inspection, nondestructive examiriation, repair or installation.
_Soecification_ - A statement of a set of requit;ements to be satisfied by a product, a material, a service or process indicating, whenever appropriate, the procedure by means of which it may be determined whether the requirements given are satisfied.
3 or 4 mam racc
$^
WAS!bSGTON PCI3LIC PObn St'PPLY SYSTC.~
3 l 4/28/78
(.w/
OPERATIONAL
' (~ D r
-m QU.\\l.lTY ASSURANCE FROGP AM DESCRIP110N 1
Sucplier - Consultants performing quality-related services, and those contractors, l
subcontractors, and vendors providing safety-related structures, systems, components.
and services.
l Surveillance _ - A review, observation, or inspection for the purpose of verifying that an action has been accomplished as specified.
Surveillance Tests - A routine test performed at an operating plant on a struc-ture, system, subsystem, or component that determines whether or not tl.e design rcquirements are being met.
Technical Soecifications - Document containing the operational limits, parametars and tests which must be tollowed by an NRC licensed facility.
The Technical Spe;ifications apply to both facility operation and effluent control from the nuclear reactor.
Testing - The determination or verification of the capability o'f an item to meet specified requirements by subjecting the item to a set of physical, chemi-cal, environmental or operating canditions.
Use-As-Is - A disposition which may be imoosed for a nonconformance when it can be estaoTished that the discrepancy will result in no adverse conditicas and that the item under consideration will continue to meet all engineering func-tional requirements including safety, performance, maintainability, and fit.
Weld Repair - Spwialized rework wherein the process consists of removing material from a rejected weld, preparing the surfaces for new welding and rewelding to specifications.
l L
=l l
i
'l I
4 or 4 Pact w u g,u 5
-.