ML20024A446
| ML20024A446 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 06/14/1983 |
| From: | Bradley E PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Schwencer A Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8306170309 | |
| Download: ML20024A446 (16) | |
Text
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PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101
- s..
(tDw ARD G. B AU ER. JR.
No esNa mLcouNsso CUGENE J. BR ADLEY assoceaTu esNanas covNsak DON ALD SLANKEN RUDOLPH A. CHILLEMI E. C. KI R K H ALL T. H. M AMER CORNELL t
June 14 1983y
'^"'^"'""^*"
I assssTaNT eENER AL CoWNsEL EDW ARD J. CULLEN. J R.
THOM AS H. MILLER. J R.
IR EME A. McKEN N A assistant CoWNsEL s
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Mr.
A.
Schwencer, Chief Docket Nos. 50-352 1
Licensing Branch No. 2 50-153' Difv is io n of L'icensing s
- U.
S.
Nuclear Regulatory Commission s
y Washington, D.C.
20555
Subject:
Limerick Generating Station,-Units 1 & 2 x
s-Request for Additional Information from NRC Quality Assurance Branch (QAB)
References:
(1)
- Letter, E.
J.
Bradley to A.
Schwencer, g.
dated May 19, 1983 (2)
- Telecon, J.
- Gilray, D.
- Caphton, G.
s
' N a p u t.a,
M. Conner (NRC) and D.
- Honan,
~~
W.
- Anderson, V.
Lucia (PECO) on May J. 27,,
1983 (3)
- Letter, S.
L.
Daltroff to A.
Schwencer,,
datee June 7,
1983.
't t
File:
GOVT l-l (FSAR) s
Dear Mr. Schwencer:
s s
The reference'(2).telecSn was held to discuss'the information transmitted by the reference (1) letter.
During t' c course a
of_that telecon,.'QAB requested certain additional information 1
to enable it to' complete its review of Chapter 17 of the Limerick FSAR.*
The r e f e r e'n c e (3) letter transmitted information responsive to o'e of these QAB requests.
This letter transmits the balance n
of the information requested by QAB, in the f o rm' o f d r a f t FSAR page changes.
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I C306170309 830614 l l PDR ADOCK 05000352, (
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j The information contained in these draft FSAR page changes will be incorporated into the FSAR, exactly as it appears in the enclosures, in the revision scheduled for July, 1983.
.s,
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s Very truly yours, T
s Euge e J.
a ley l
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HDH/gra/33
. Enclosures N
' Copy to:
See Attached Service List s_
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cc: Judge Lawrence Brenner (w/o enclosure)
Judge Richard F. Cole (w/o enclosure)
Judge Peter A. Morris (w/o enclosure)
Troy B. Conner, Jr., Esq.
(w/o enclosure)
Ann P. Hodgdon (w/o enclosure)
Mr. Frank R. Romano (w/o enclosure)
Mr. Robert L. Anthony (w/o enclosure)
Mr. Marvin I. Lewis (w/o enclosure)
Judith A. Dorsey, Esq.
(w/o enclosure)
Charles W. Elliott, Esq.
(w/o enclosure)
Jacqueline I. Ruttenberg (w/o enclosure)
Thomas Y. Au, Esq.
(w/o enclosure)
Mr. Thomas Gerusky (w/o enclosure)
Director, Pennsylvania Emergency Management Agency (w/o enclosure)
Mr. Steven P. Hershey (w/o enclosure)
Donald S. Bronstein, Esq.
(w/o enclosure)
Mr. Joseph H. White, III (w/o enclosure)
David Wersan, Esq.
(w/o enclosure)
Robert J. Sugarman, Esq.
(w/o enclosure)
Martha W. Bush, Esq.
(w/o enclosure)
Atomic Safety and Licensing Appeal Board (w/o enclosure)
Atomic Safety and Licensing Board Panel (w/o enclosure)
Docket and Service Section (w/o enclosure) l i
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the various aspects of the Quality Assurance Plan to determine compliance with the elements of, and effectiveness of the OA Plan.
17.2A.18.4 Audits and surveillances shall be performed in accordance with written procedures to confirm that the OA Program is implemented in accordance with documented instructions, procedures and drawings. -
The results of the auditing program shall be documented by the Superintendent, OA Division and distributed to appropriate levels of management having responsibility in the area audited and Department management 17.2A.18.5 Audits shall be regularly scheduled on the basis of the status and importance of the activities.
The following. activities of the Quality Assurance program shall be audited at least every two Training, Health Physics and Chemistry, Fuel Handling, years:
Shift Operations, Surveillance Testing, Maintenance -
Instruments, In-service Inspection, Maintenance - Electrical and The Mechanical, Stores and Purchasing, Modifications, and Plans.
Plans activity encompasses the LGS Emergency Plans, Physical Security Plan, and Radiological Environmental Monitoring Program.
7-Regularly scheduled audits may be supplemented by unannounced or unscheduled audits or surveillances as determined by the Superintendent, OA Division.
17.2A.18.6 Audits and surveillances shall be performed by personnel from the Quality Assurance Division, who are independent of any direct responsibilities for the performance of activities which they l
will audit.
The OA Division may request assistance of personnel from other disciplines who are independent of areas being audited.
The Superintendent, OA Division shall establish the auditing program personnel qualifications and the requirements for the use of technical specialists to accomplish the auditing of the Personnel shall be selected for quality assurance program.
quality assurance auditing assignments base.d on experience or training which establish that their qualifications are commensurate with the complexity or special nature of the activities to be audited.
In selecting personnel for auditing i
assignments, consideration shall be given to special abilities, Srn,eano 7swwrAL NuRf6 -o123 3 Srst: spec.4 news 4A 4FN 81strJest.
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ONA DCNRS, Rev. 17, 02/83 17.2A-3 oelineded by [ Sechtm 62.2.6 f
-fhuse e vol,*l.s In add. Won, dor'nrec{ by f/16 QA Otvision.
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Appendix 17.2A.II ELECTRIC PRODUCTION DEPARTMENT APPLICATION OF INDUSTRY STANDARDS AND NRC REGULATORY GUIDES Philadelphia Electric Company Electric Production Department Quality Assurance Program will follow the guidance contained in NRC Regulatory Guides and the requirements of Industry Standards as described below.
When a Regulatory Guide endorses an Industry Standard, compliance with the recommendations of a guide indicates compliance with the requirements of the standard, and those guidelines modified by the guide.
Documents referenced in an ANSI Standard are excluded unless they are addressed separately, a.
Reculatory Guide 1.30, August 1972, " Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment" Endorses ANSI N45.2.4 - 1972.
PECO shall comply with Regulatory Guide 1.30, August 1972, f__.
and ANSI N45.2.4 - 1972 for those activities occurring during the operational phase that are comparable in nature.398 der Gei'8P 'Md %
extent, as determined by the G6en en. Superintendent c sf"Abdcu A
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activities occurring during the initial design and construction phase, except for the following alternates:
1.
ANSI N45.2.4, Section 1.1, Scope - PECO's alternate to classification of Class I and.IE electric power, instrumentation, and control equipment is to apply the requirements of this standard to PECO "Q-listed" items.
(Those instruments, equipment and systems-that prevent or mitigate the consequences of postulated accidents that could cause undue risk to the health and safety of the public.)
2.
ANSI N45.2.4, Section 3, Preconstruction Verification -
Subsection (3) requires the checking of records of protective measures maintained during storage for conformance to storage requirements.
ANSI N45.2.2 -
1978Property "ANSI code" (as page type) with input value "ANSI N45.2.2 -</br></br>1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Section 6.4, Control of Items in Storace requires inspections and examination during the storage period.
The responsibility Githin PECO for these inspections rests with the Stores Division.
Compliance with these requirements for checking of records is assured through the auditing program conducted by Quality Assurance Division Personnel along with the monitoring of Stores Division Activities by Stores Division Supervision.
17.2A.II-1
LGS FSAR criteria for use of items which have been identified as nonconforming.
11.
ANSI N18.7 - 1976/ANS
$Section5.2.6, Equipment Control (a.) Temporary modification (5th paragraph) - The need
- for independent verification of Temporary Modifications will be determined on an individual basis considering the complexity and impact of the modification.
(b.) (7th paragraph) requires " operating personnel" to place equipment in operation.
Equipment may be placed into operational status by personnel not on the operating staff, such as instrument technicians.
12.
ANSI N18.7 - 1976/ANS 3.2, Section 5.2.7, Maintenance and Modifications - The requirement concerning original design bases and requirements, material specifications, and inspection requirements is modified to permit approved alternate requirements which are subject to the design review process.
13.
ANSI N18.7 - 1976/ANS 3.2, Section 5.2.7.1, Maintenance Procrams (a.) Emergency maintenance to 0-Listed equipment (work which must proceed immediately to correct a degraded condition) may be performed concurrent with procedure preparation and' documentation of steps actually taken.
Such maintenance may be performed with the authorization of designated personnel and subsequent procedure approval by the l
PORC.
(b.) The cause of repetitive malfunctions should be determined; however, it is not practical, and may not be possible, to determine the cause of every malfunction.
i l
14.
ANSI N18.7'- 1976/ANS 3.2, Section 5.2.10, Housekeeping and Cleanliness Control (a.) Control measures to' prevent contamination with l
foreign materials will be specified in Administrative Procedures and will include, as appropriate, access control.
17.2A.II-4 l
b
LGS FSAR (b.) Second paragraph, first & second sentences are taken to mean:
"Where needed to prevent contamination.
ev//o r _-the-15.
ANSI N18.7 - 1976/ANS 3.2, Section 5.2.11, Corrective
- ^ g_
Action - The Plant Operations Review Committee.ee JnNf6" I ###"
erintenderet determines which items are Sof#y 88f "EG) $f:
Si...wm Sov G ro v f:' (JS "significant".
16.
ANS'I N18.7 - 1976/ANS 3.2,Section 5.2.12, Plants Records Management - Retention periods will satisfy statutory requirements for the record.
The significance of the event covered by the record and the contribution of the record to the ability to reconstruct significant events will be considered in establishing retention periods.
17.
ANSI N18.7 - 1976/ANS 3.2, Section 5.2.13, Procurement and Material Control - Item (1) - Administrative Procedures shall specify the means for control of procurement of commercially "off the shelf" items.
The
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Administrative Procedures shall describe the receipt inspection, storage, and handling prior to installation and operation, g ns er A\\
18.
ANSI N18.7 - 1976/ANS 3.2, Section 5.2.13.1, Procurement Document Control, (second sentence) - OA program requirements or alternate approved methods will be used to assure quality.
Examples of alternates for suppliers without GA programs includes material analysis, sample l
testing, in-process inspection and monitoring, and design review by PECO.
19.
ANSI N18.7 - 1976/ANS 3.2, Section 5.2.15, Review, Approval and Control of Procedures '- The frequency of review of plant procedures is discussed in FSAR Section 13.5.
20.
ANSI N18.7-1976/ANS 3.2, Section 5.2.17, Insaections -
The results of inspections are not always suaject to a further evaluation.
For example, evaluation beyond that given by inspection - level personnel is not normally required for go/no-go and pass / fail type inspections.
21.
ANSI N18.7 - 1976/ANS 3.2, Section 5.3, Preparation of Instructions and Procedures, (last sentence) - The
- f13
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l clarification regarding emergency maintenance in item above, applies.
22.
ANSI N18.7 - 1976/ANS 3.2, Section 5.3.10, Test and Inspection Procedures, (first paragraph) - The 17.2A.II-5 Rev. 17, 02/83 l
l e
iMa
- I r larification regarding test result evaluations in item l
, above, applies.
23.
ANSI N18.7 1976/ANS 3.2, Section 5.3.10, Test and Inspection Procedures, (second paragraph, last sentence)
- These procedural aspe, cts will be included when appropriate.
For example, "as-found condition" is not applicable to all test and inspection procedures.
c.
Reculatory Guide 1.37, March 1973, " Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water-Cooled Nuclear Power Plants."
Endorses ANSI N45.2.1 - 1973.
Decontamination and cleanup of radioactively contaminated systems and components are not included in the scope'of this response.
PECO shall comply with Regulatory Guide 1.37 - March 1973 and ANSI N45.2.1 - 1973 for those activities occurring during the operational phase that are comparable in nature and extent,
-- j as determined by the SeeMon-Superintenden Mer it.; 7Ec&
v rrg-.i;; tie..
eepensibl; f r the ecti"it"- to related
" N*le cw 0*"emH,n ong activities occurring during the initial design and b"""W'"I-M construction phase except for the following alternate:
1.
ANSI N45.2.1, Section 3.2, Water Quality Reauirements -
PH measurements are not required for conductivity values of 5 1 micromho/cm.
PECO utilizes PH limits of 5.2 to 8.6 at 250 C, uncorrected for CO2 and may apply conductivity measurements in place of total dissolved solids.
2.
ANSI N45.2.1, Section 3.1.2, Clahs B - The flushing velocity may be as specified in other approved documents associated with the maintenance or modification, as well as procurement documents, d.
Reculatory Guide 1.38, Revision 2, May 1977, " Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Water-Cooled Nuclear Power Plants."
Endorses ANSI N45.2.2 - 1972.
See discussion under ANSI /ASME N45.2.2 - 1978.
Rev. 17, 02/83 17.2A.II-6
^
Regulatory Guide 1.39, Revision 2, September 1977,
" Housekeeping Requirements for Water-Cooled Nuclear Power Plants."
Endorses ANSI N45.2.3 - 1973.
PECO shall comply with Regulatory Guide 1.39, September 1977 and ANSI N45.2.3 - 1973 for those activities occurring during the operational phase that are comparable in nature and
' N 'd # 4 '
extent, as determined by the:Ot; tion Superintenden er the PECO eivo..;;;tir r::pe..; 1 6 bc the--ecticity, to related N"
activities occurring during the design and construction phase LpeMwid chA except for the following alternates:
1.
ANSI N45.2.3, Section 2.1, Plannina - Zone II requirements for clean gloves, shoe covers, and head coverings will be determined by health physics personnel under the radiation protection program and specific requirements listed on the Radiation Work Permit for entry in Zone II areas.
4 2.
ANSI N45.2.3, Section 2.1, Plannina - Material accountability for Zones II and III shall be controlled i
by procedural requirements, periodic inspections and
- ((-
surveillance of areas for acceptable housekeeping practices.
Implementing procedures for activities such as maintenance and modifications req'uire housekeeping
~
and cleanliness inspections of areas and equipment to eliminate foreign materials that may have a detrimental effect.
Post Maintenance or modification inspections for housekeeping and cleanliness shall be conducted and documented in accordance with administrative controls.
3.
ANSI N45.2.3, Section 2.1 Plannin'a - Personnel accountability for Zone III will.tHe controlled as determined by the admin.istrative controls for locked doors and radiation work permit requirements in lieu of specific access registers.
l f.
Regulatory Guide 1.58, Revision 1, " Qualification of Nuclear l
Power Plant Inspection, Examination, and Testing Personnel."
Endorses ANSI N45.2.6 - 1978.
' Philadelphia Electric Company will comply with Regulatory Guide 1.58, Rev. 1 and ANSI N45.2.6-1978 except for the following l
clarification and alternates:
l' 1.
Regulatory Guide 1.58, Revision 1, section C.1, and ANSI N45.2.6-1978, subsection 1.2, states that the standard applies to " personnel who perform inspections, s
examinations,'and tests." Philadelphia Electric Company 17.2A.II-7 Rev. 17, 02/83
[
personnel, who inspect equipment as part of egndninr plant maintenance, in other than a quality control function, and plant staff personnel (as defined in the Limerick Technical Specifications) who approve test procedures and tests results and direct or supervise the conduct of individual tests, will be qualified in I
accordance with ANSI M10.t't07t in lieu of ANSI N45.2.6-1978.
b ' h -1978 2.
Regu'latory Guide 1.58, Revision 1, section C.4 and ANSI N45.2.6-1978, subsection 1.5, discuss the applicability of documents referenced in the standard.
In lieu of the latest revision of Regulatory Guides and ANSI Standards, PECo commitments are contained in Section 17.2.
3.
ANSI N45.2.6-1978, subsection 3.5, presents experience recommendations for candidates.
Experience in e
maintenance, modification, and operating activities is considered related experience because such experience provides training in the safety aspects of the facility.
g.
Reculatory Guide 1.64, Revision 2, June 1976, " Quality Assurance Requirement for the Design of Nuclear Power Plants."
Endorses ANSI N45.2.11 - 1974.
PECO shall comply with Regulatory Guide 1.64, June 1976, and ANSI N45.,2.11 - 1974 for those Electric Production Department activities occurring during the operational phase that are comparable in naturn and extent, as determined by the stetten SuperintendentY:: th; 7 CO ::; ni;;tien~'r;~;p;nsible f;; the F 'ti"ity, to related activities occurring-during the initial f design phase with the following clarification and alternates:
Clarification -
4 - Noclear GenerH,~.n ad sye-;Medes+-oA Rev. 17, 02/83 17.2A.II-8 A
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1.
Plant Design changes are categorized into Major and Einor Modifications.
Design controls for Major Kodifications which are delegated to the Engineering and Research Department are described in Section 17.2B.
Major Modifications.are defined in LGS Administrative Procedures.
2.
Minor Modifications are accomplished under the controls of plant oaministrative procedures in accordance with the LGS EP Ouality Assurance Plan.
Alternate -
Regulatory Guide 1.64, Section C.2 - Due to the nature of Minor Modifications and the size and expertise of LGS staff, when design verification is required, it may be performed by the designer's immediate supervisor if the supervisor is the only technically qualified individual.
Additionally, minor modifications are reviewed by the PORC.
h.
Reculatory Guide 1.74, Revision 0, February 1974, " Quality Assurance Terms and Definitions.
" ~ ~ '
Endorses ANSI N45.2.10 - 1973.
PECO shall comply with Regulatory Guide 1.74, Revision 0, February 1974 and ANSI N45.2.10 - 1973 except for the following alternate:
The word " examination" also means an exercise to examine progress or status of knowledge or qualification.
i.
Reculatory Guide 1.88, Revision 2,* October 1976, " Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records."
Endorses ANSI N45.2.9 - 1974.
l l
See discussion under ANSI /ASME N45.2.9 - 1979.
i j.
Reaulatory Guide 1.94, Revision 1, April 1976, " Quality Assurance Requirements for Installation, Inspection, and Testing of Structural Concrete and Structure Steel During the Construction Phase of Nuclear Power Plants."
l Endorses ANSI N45.2.5 - f974.
l PECO shall comply with Regulatory Guide 1.94, April 1976 and ANSI N45.2.5 - 1974 for those activities occurring during the operational phase that are comparable in nature and extent, asdeterminedbythe9teHerSuperintendengerthePECO
-Nucism r Genertyhors 17.2A.II-9 Q!!Gl SUfe rintendent-9 A
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LGS FSAR asgani::ti:n :: penc-i-b!c fec t.e ectivity, to related activities occurring during the initial design and construction phase.
l k.
Regulatory Guide 1.116, Revision
, May 1977, " Quality Assurance Requirements for Installation, Inspection, and Testing,of Mechanical Equipment and Systems."
Endorses ANSI N45.2.8 - 1975.
PECO shall comply with Regulatory Guide 1.116, May 1977, and ANSI N45.2.8 - 1975 for those activities occurring during the operational phase that are comparable in nature and extent,peneru+1oe a as determined by the Sea 44en SuperintendentVr the M^Of vote e Or-anizatirn re:poncibic for the ecti;ity, to related
$MP"' "fenobof- 0A activities occurring during the initial design and construction phase, except for the following alternates:
1.
ANSI N45.2.8, Section 2.2, Procedures and Instructions -
FSAR Section 13.5 addresses compliance with ANSI N18.7 -
1976/ANS 3.2 and Regulatory Guide 1.33.
These requirements provide adequate controls for the Procedures and Instructions addressed in this Section.
2.
ANSI N45.2.8, Section 2.3, Results - PECO's commitment to ANSI 18.7 - 1976/ANS 3.2 provides adequate guidance for the documentation and review of the results of inspections and tests.
3.
ANSI N45.2.8, Section 3.4, Physical Condition - PECO's response to ANSI N45.2.1, N45.2.2, and N45.2.13 provide adequate guidance and control for the requirement that mechanical items are in accordance with specified requirements and that the quality has been maintained.
1.
Regulatory Guide 1.123, Revision 1, July 1977, " Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants."
Endorses ANSI N45.2.13 - 1976.
PECO shall comply with Regulatory Guide 1.123, July 1977, and ANSI N45.2.13 - 1976 for those activities occurring during the operational phase that are comparable in nature and g o,(co r m,
extent, as determined by the Stet 4en Superintendent f 6.6 6 enerMo'1
.^spenrible*f : the ;ctiviti, to related and nern -. -
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activities occurring during the initial design and Si,gerirdov6d construc' tion phase.
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Regulatory Guide 1.146, August 1980, " Qualification of j
Quality Assurance Program Audit Personnel for Nuclear Power Plants" Endorses ANSI /ASME N45.2.23-1978.
Philadelphia Electric Company will comply with Regulatory Guide 1.146, August 1980 and AN,I/ASME N45.2.23-1978 except S
for the following alternates:
1.
Regulatory Guide 1.146, August 1980, section C.1 and ANSI /ASME N45.2.23-1978, subsection 1.5, discuss the applicability of documents referenced in the standard.
In lieu of the latest revision of Regulatory Guides and ANSI Standards, PECo commitments are contained in Section 17.2.
2.
ANSI /ASME N45.2.23-1978, subsection 2.3, states requirements for qualification of auditors.
In lieu of the stated requirements, PECo will qualify personnel in accordance with requirements presented below.
These alternate requirements will provide PECo with sufficient flexibility to qualify competent personnel with initial technical experience in a more effective manner.
The proration of credits between initial experience requirements and additional experience gained as an assistant to a Lead Auditor ensures that highly qualified personnel will be available as audit personnel in a more timely fashion.
Substitute the following for Paragraph 2.3.1 of ANSI /ASME N45.2.23-1978.
2.3.1 Education and Experience.
The prospective Lead Auditor shall have varifiable evidence that a minimum of ten (10) credits under the following scoring system have been accumulated.
2.3.1.1 Education (4 credits maximum).
Associate degrees from an accredited institution score one (1) credit or if the degree is an engineering, physical sciences, mathematics, or quality assurance, score two (2) credits or, a bachelor degree from an accredited institution score two (2) credits or if the degree is in engineering, physical sciences, mathematics, or quality assurance, score three (3)* credits; in addition score one (1) credit for a master degree in engineering, physical sciences, business management, or quality assurance from an accredited institution.
17.2A.II-11 Rev. 17, 02/83
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2.3.1.1 a)
Initial Experience Prior to Assignment (6 credits maximum).
Technical experience in engineering, manufacturing, construction, operation, maintenance, or quality assurance related to the aforementioned activities, score one (1) credit for each full year with a maximum of five (5) credits for this aspect of experience.
If two (2) or more years of this experience have been in the nuclear field, score one (1) additional credit.
2.3.1.2 b)
Additional Experience (after assignment) (4 credits maximum).
Experience in quality assurance, score one (1) credit for each full year (2 credits maximum) cr, Experience in auditing, score two (2) credits for each full year (3 credits maximum) or, Experience in nuclear quality assurance, score one (1) credit for each full year (3 credits maximum) or, Experience in nuclear quality assurance auditing, score one (1) credit per every six months (4 credits maximum),
2.3.1.3 Other Credentials of Professional Competence (2 credits maximum).
Certification of competency in engineering, science, or quality assurance specialities issued and approved by a State Agency, or National Professional or Technical Society, score two (2) credits.
2.3.1.4 Rights of Managemen't (2 credits maximum).
The Lead Auditor's employer may grant up to one (1) credit for other performance factors applicable to auditing which may not be explicitly called out in this standard such as leadership, sound judgment, maturity, analytical ability, tenacity, and past performance, plus one (1) credit for satisfactory completion of Lead Auditor training program.
gh ANEI/ASME N45.2.12 - 1977 "Requir h dLiiny vf-QualiTP%ssugance Progra c' ear Power Plants."
htheclarificationdiscussed-initemWgMEN45.2.12 y with
. r^"nirements of ANSI /A PECO shall
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atory Guide 1.33 and with the following alterimt:4.
Rev. 17, 02/83 17.2A.II-12 1
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SME N4 5. 2.12, Section 4. 2.4, Audi t.Not-Filuat ion and Section re-Audit _CanferentW~L Pre-audit notification is given to p plnagement in an informal manner due to dailypart and communications between-StHi4.Ltv Assurance
,IJiatrion personnel and plant personnel.
w o.
ANSI /ASME N45.2.2 - 1978 " Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants."
PECO shall comply with the requirements of ANSI /ASME N45.2.2
- 1978 except for the following alternates:
1.
ANSI /ASME N45.2.2, Section 2.7, Classification of Items
- Philadelphia Electric Co. does not classify items into the four (4) levels described in this standard.
However, the specific guidance and recommendations which are appropriate to each class are applied to those items packaged, shipped, received, stored, and handled through the use of procedures, original specifications, instructions and drawings as applicable.
2.
ANSI /ASME N45.2.2, Section 3, Packaging and Section 4, Shipping - Philadelphia Electric Co. utilizes the packaging and shipping requirements delineated in the s-original equipment specifications as part of our procurement requirements to suppliers or manufacturers.
Those requirements and recommendations of Sections 3 and 4 are included in the original specifications as appropriate for the item being procured.
Receipt inspection activities are in accordance with Section 5 of this standard and are sufficient to identify packaging and shipping nonconformities.
3.
ANSI /ASME N45.2.2, Section 6, Storace - Philadelphia Electric Co.
does not classify items into four (4) levels for storage purposes as delineated in Section 6.1.2.
Stored items are placed in limited access controlled areas, and are segregated with respect to the 0-list classification of the item (s).
The specific guidance and recommendations which are appropriate to each class are applied to those items stored through the use of procedures, specifications and manufacturers recoinmendations and instructions.
4.
ANSI /ASME N45.2.2, Section 6.4.2 (7), ' Care of Items -
The rotating of certain electrical motors in storage, which must be energized to release a electrical brake, will be stored and maintained in accordance with i
manufacturers recommendations.
Other motors, which can be rotated without energizing, will be maintained in 17.2A.II-13 Rev. 17, 02/83
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Components installed in Light-Water-Cooled Nuclear Power Plants.
The Engineering and Research Department follows the guidance of Regulatory Guide 1.143, July 1978, exclusive of other documents referenced therein.
> Inseyt 82.
Regulatory Guide 1.146, August 1980, " Qualification of j(/.
Ouality Assurance Program Audit Personnel for Nuclear Power Plants" Endorses ANSI /ASME N45.2.23-1978.
V Philadelphia Electric Company will comply with Regulatory Guide 1.146, August 1980 and ANSI /ASME N45.2.23-1978 except for the following alternates:
Regulatory Guide 1.46, August'1980, section C.1, and 1.
ANSI /ASME N45.2.23-1978, subsection 1.5, discuss the applicability of documents referenced in the standard.
In lieu of the latest revision of Regulatory Guides and ANSI Standards, PECo commitments are contained in Section 17.2.
2.
ANSI /ASME N45.2.23-1978, subsection 2.3, states In lieu of requirements for qualification of auditors.
(
the stated requirements, PECo will qualify personnel in
(
accordance with the requirements presented below.
These alternate requirements will provide PECo with sufficient flexibility to qualify competent personnel with initial The technical experience in a more effective manner.
proration of credits between initial experience requirements and additional experience gained as an assistant to a Lead Auditor ensures that highly qualified personnel will be available as audit personnel in a more timely fashion.
Substitute the following for Paragraph 2.3.1 of ANSI /ASME N45.2.23-1978.
2.3.1 Education and Experience.
The prospective Lead Auditor shall have varifiable evidence that a minimum of ten (10) credits under the following scoring system have been accumulated.
2.3.1.1 Education (4 credits maximum).
Associate degrees from an accredited institution score one (1) credit or if the degree is in engineering, physical sciences, mathematics,*or quality assurance, score two (2) credits or, a bachelor degree from an accredited institution N-score two (2) credits or if the degree is in 17.2B.II-5 Rev. 17, 02/83 l
b
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engineering, physical sciences, mathematics, or quality assurance, score three (3) credits; in addition score one (1) credit for a master degree in engineering, physical sciences, bu'siness management, or quality assurance from an accredited institution.
2.3.1.2 a)
Initial Experience Prior to Assignment (6 credits maximum).
Technical experience in engineering, manufacturing, construction, operation, caintenance, or quality assurance related to the aforementioned activities, score one (1) credit for each full year with a maximum of five (5) credits for this aspect of experience.
If two (2) or more years of this experience have been in the nuclear field, score one (1) additional credit.
2.3.1.2 b)
Additional Experience (after assignment) (4 credits maximum).
Experience in quality assurance, score one (1) credit for each full year (2 credits maximum) or, Experience in auditing, score two (2) credits for I
each full year (3 credits maximum) or, Experience in nuclear quality assurance, score one (1) credit for each full year (3 credits maximum) or, Experience in nuclear quality assurance auditing, score one (1) credit per every six months (4 credits maximum).
2.3.1.3 Other Credentials of Professional Competence (2 credits maximum).. Certification of competency in engineering, science, or quality assurance specialities issued and approved by a State Agency, or i
National Professional or Technical Society, score two i
(2) credits.
2.3.1.4 Rights of Management (2 credits maximum).
The Lead Auditor's employer may grant up to one (1) credit for other performance factors applicable to auditing which may not be explicitly called out in this standard such as leadership, sound judgment, maturity, analytical ability, tenacity, and pcst performance, plus one (1) cL* edit for satisf actory completion of Lead Auditor training program.
ANSI N45.2.12-1977, Requirements for auditing of Quality i'
q.
Assurance Programs for Nuclear Power Plants.
Rev. 17, 02/f' 17.2B.II-6 i
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LGS FSAR The Engineering and Research Department follows the guidance of ANSI N45.2.12-1977 exclusive of other documents reference I
therein.
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