ML20045E718
| ML20045E718 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 12/31/1993 |
| From: | NIAGARA MOHAWK POWER CORP. |
| To: | |
| Shared Package | |
| ML18040A217 | List: |
| References | |
| NUDOCS 9307020352 | |
| Download: ML20045E718 (100) | |
Text
{{#Wiki_filter:.. . .. f ENCLOSURE A TO NMPIL 0768 - i NINE MILE POINT - UNIT 1 SAFETY EVALUATION
SUMMARY
REPORT : i 1993 ;
)
i
'I
~l I
i i 1 Docket No. 50-220 License No. DPR-63 9307020352 930630 ' PDR- ADOCK 05000220 K PDR _____z_________ _e
1 I
.I Safoty Evaluation Summary Report Page 1 of 57 i O l Safety Evaluation No.: 83-044 l Implementation Document No.: Mod. N1-81-29 -
1 UFSAR Affected Pages: VI-63 (Figure VI-24) system: Emergency Ventilation " Title of Change: Modify BV 202-36 Pilot ! Solenoid Design , Description of Change: I This change replaced the solenoid pilot valves on air-operated blocking valve BV 202-36 with a different model, re-piped the air - input to the solenoid valves in a series configuration i (previously a parallel configuration), .and-installed-a keylock > switch in place of the original manual switch for the solenoid valves. Procedural controls will govern the.use of the switch. ; Normally, the blocking valve will be left open. This will prevent the failure of initiation of the emergency ventilation i system. Closure of the' blocking valve will be allowed only : during venting and purging of the drywell and suppression chamber
-l or for maintenance reasons under procedural control.
Safety Evaluation Summary: ) Automatic blocking valve BV 202-36 is at.the junction or -I interface of t.te emergency ventilation and normal ventilation
- systems. The valve provides'for purging the torus and drywell through the emergency ventilation system at the same time normal building ventilation is being used. The blocking valve prevents ,
contaminated air from being blown back into the reactor building. l during this condition. ! The new configuration of the air piping for the solenoids prevents single failure of-the emargency ventilation system.- The i added procedural controls governing use of the keylock switch and l maintaining-the valve normally open assures the availability of } the emergency ventilation system. .;
~
The modification will not affect the designed operation-of the [' emergency. ventilation system or the normal ventilation system. Venting'and purging of the drywellland suppression chamber will-not be affected except for the added procedural control. -; Based on the evaluation performed, it is concluded that this- I change does not involve an unreviewed safety question. : O l
?
b i
Safety Evaluation Summary Report 1 Page 2 of 57 O Safety Evaluation No.: 89-026, Rev. 1 Implementation Document No.: Mod. N1-86-020 UFSAR Affected Pages: VI-43, VI-43a, VI-43b, VI-47 (Table VI-3a), VI-48 (Table VI-3a), VI-48a (Table VI-3a), VI-49 (Table VI-3b), VI-50 (Table VI-3b), VI-50a (Table VI-3b) , VI-50b (Table VI-3b), VI-51 (Table VI-3c) System: 201.1 Title of Change: Air-Operated Containment Vent
& Purge Valves Description of Change:
The NRC required NMPC to reduce the air-operated containment vent and purge valve isolation system response time to 15 seconds or less to assure that safety-related purge / vent valves would be closed before the onset of any potential fuel failure following a loss-of-coolant accident (LOCA). NMPC interpreted this ' requirement as the need to limit disc travel (i.e., valve closure) time to 14 seconds or less under LOCA conditions. , To meet the valve closure time requirement, Modification No. N1-86-020 removed speed control valves from vent and purge valves IV 201-08, 201-10, 201-16, and 201-32. Removal of the speed control valves reduced the line resistance, thus allowing air to exhaust in a shorter time and hence close the isolation valves more quickly. . To further reduce butterfly valve closure time for valves IV 201-10 and 201-32, quick exhaust valves (QEVs) were added to their air lines between the solenoid valves and the air - operators. Quick exhaust valves are used in similar applications at Nine Mile Point Unit 1 and have performed their function satisfactorily. Safety Evaluation Summary: The analyses performed addressed the addition of QEVs to IV 201-10 and 201-32. The removal of the already wide open speed control valves from IV 201-08, 201-10, 201-16, and 201-32 was judged to have no impact on safety as they do not act as pressure or containment barriers / boundaries. Also, as the removal of the speed control valves resulted in one less component that
Safety Evaluntion Summary Report Page 3 of 57 O Safety Evaluation No.: 89-026, Rev. 1 (cont'd.) Safety Evaluation Summary: (cont'd.) potentially could fail, the probability of a malfunction of , equipment important to safety is reduced. Based on the analyses and evaluations performed, this ' modification (1) does not increase the probability of occurrence or consequences of an accident previously evaluated in the FSAR; (2) does not create the possibility of an accident of a different type than any evaluated.previously in the FSAR; and (3) does not reduce the margin of safety as defined in the basis contained in the Technical Specifications. Therefore, it is concluded that this modification does not involve an unreviewed safety question. i t O 1 4 O i
Snfcty Evaluation Summary Report Page 4 of 57 O Safety Evaluation No.: 89-029, Rev. 1&2 Implementation Document No.: Mod. N1-89-209 UFSAR Affected Pages: VI-58 (Figure VI-22); X-21 System: Head Spray Title of Change: Partial Removal of the Head Spray Piping Description of Change: As reported in letter NMPIL 0589, dated June 28, 1991, the reactor head spray cooling system was eliminated by permanently removing the spool piece in the discharge line to the reactor ' vessel head. The remaining system piping was blind flanged (including the portion that contains the containment isolation valves). 4 This revision of the Safety Evaluation addressed Appendix J leak test requirements for the subject containment penetration. , Isolation valves 34-01 and 34-02 are no longer subject to Appendix J Type C testing. The new blind flange is subject to Appendix J Type B testing for gasketed penetrations. Safety Evaluation Summary: 1 The head spray system was not required to operate under any shutdown, cooldown, accident, or transient conditions. This flow path was also not required to satisfy Appendix R cold shutdown inventory makeup requirements. Reactor isolation now occurs at the blind flange at the reactor vessel head. Containment isolation occurs at the blind flange inside the inboard check valve 34-02. Appendix J Type B and Type A testing of the blind flange assures that primary containment integrity is maintained. i Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. I 1
Safoty Evaluation i Summary Report : Page 5 of 57
]
Safety Evaluation No.: 89-030, Rev. 1 l Implementation Document No.: Mod. N1-89-215 l l UFSAR Affected Pages: N/A l 1 System: 125Vdc Battery Boards ; Title of Change: Installation-of Class 1E Fuses - at 125Vdc Battery Boards #11 -{ and #12 { Description of Change-This modification upgraded the equipment which feeds the loads , powered from the 125Vdc battery boards #11 and #12. Originally, j these loads were fed through circuit breakers. The modification replaced the breakers with fuses that are sized to clear a fault j for-the maximum available short circuit current. ; This safety evaluation was previously reported in' letter NMPIL ! 0512 dated June 29, 1990. Revision 1 of the safety evaluation l revised the fuse interrupting rating (from 200KA ac/40KA dc-to i 25KA dc) and the applicable National Electric Code year (from 1 1987 to 1990). _. Safety Evaluation Summary: 1 The revision to the Safety Evaluation does not affect the. original conclusions. The deletion of the breakers and the - addition of fuses will not increase the probability of occurrence ; of an accident previously analyzed in the UFSAR, nor will it ; decrease the margin of safety at Nine Mile Point Unit-1. f Replacement of the breakers with qualified fuses ensures that adequate short circuit interrupting capability is provided. Based on the evaluation performed, it is concluded that this 1 change does not involve an unreviewed safety question. j ; I i t O , , e 4
Safety Evaluntion Summary Report Page 6 of 57 9 Safety Evaluation No.: 90-003, Rev. 1 Implementation Document No.: Calc. A-10.1-AA-26, Rev. 1 UFSAR Affected Pages: N/A System: N/A , Title of Change: NMP1/NMP2 Helicopter Operations Description of change: NMPC helicopter services provide local transportation between the site and surrounding areas including Syracuse Hancock Airport. This safety evaluation reviews the acceptability of this type of operation in the context of aircraft hazards. Helicopter operations involve approximately 45 to 60 flights per year between the Syracuse Airport and the site. The flight path usually does not encroach on the air space above the site security fence. Safety Evaluation Summary: There are currently three helicopter landing areas, all within approximately 0.5 miles of the site:
- 1. In the parking area, approximately 1200 ft. southeast of the Unit 2 reactor building.
- 2. In the parking area adjacent to the training center.
- 3. In the lawn area adjacent to the training center.
A calculation performed for Unit 2, based on the NRC Standard Review Plan 3.5.1.6 methodology, concluded that the actual probability of a helicopter accident leading to radiological consequences in excess of 10CFR100 limits would be less than about 104 per reactor year. A similar calculation was not performed for Unit 1. However, if such a calculation were performed for Unit 1 structures, the results would yield probabilities of the same order of magnitude as calculated for Unit 2. Therefore, helicopter operations do not represent a credible hazard to Unit 1 and need not be considered in the plant design basis. Based on the analyses and evaluations performed, it is concluded that NMPC helicopter operations do not constitute an unreviewed safety question. O
Safety' Evaluation Summary Report Page 7 of 57 '
- (
Safety Evaluation No.: 90-006 Implementation Document No.: Mod. N1-89-255 i UFSAR Affected Pages: VI-49 (Table VI-3b) System: Drywell Inerting and Containment Atmospheric i tilution (201) . Title of Change: Modify closure Time for Vent and Purge ~ Motor-Operated Valves Description of Change: This change modified the motor operators on safety-related vent and purge isolation valves numbers 201-07, 201-17,.201-31 and > 201-09, to reduce the stroke time for valve closure from less , than 60 seconds to less than 30 seconds. Closing time reduction was accomplished by increasing motor power output and/or reducing the gear ratio to increase output rpm. () Safety Evaluation Summary: This reduction in stroke time addresses concerns-originally raised by the NRC per NRC Safety Evaluation, " Containment Purging / Venting During Normal Plant Operation," issued. March.19, ' 1984; NRC Safety Evaluation, " Radiological Consequences Analysis of LOCA During Containment Purging," issued December 8, 1983; and final resolution of the issue reached via NMPC letter to NRC
- dated May 29, 1986. Specifically, the reduction in stroke time will reduce the consequences of a radiological release.
Upgrade of these safety-related valves was accomplished utilizing qualified Limitorque parts installed in the same-configuration as originally existed. In addition, on valves 201-07 and 201-17, l where motor size has been increased, calculations have-concluded > that existing conductors and breakers are adequate to handle the anticipated increased power loads. l The NRC accepted the new surveillance criteria associated with this change in License Amendment No. 140, dated April 12, 1993. 3 O 4
I1 Safety Evoluction ! Summary Report l Page 8 of 57 ) Safety Evaluation No.: 91-011 i i Implementation Document No.: DCR N1-91-001LS036 UFSAR Affected Pages: Figure IX-1 System: 24-kV Electrical System Title of Change: Revise Figure IX-1 in NMP1 FSAR Description of Change: This change corrected a discrepancy involving the location of the termination between the auxiliary power station service transformer #10 cables and the 24-kV main generator output leads. Drawing C-19409-C Sheet 1B E21.1 originally showed the termination made at the main generator side of the links. The-correct termination should be shown on the main transformer side of the links. [ This safety evaluation is being reported at this time in support of the change to UFSAR Figure IX-1, which was incorporated in UFSAR Revision 10. Safety Evaluaticn Summary: This is a documentation-only change to properly reflect the as-built field configuration. The olant design basis, procedures, and analyses are not affected. The corrected termination location will not prevent cables feeding the station service transformer #10 from performing their intended function. The 24-kV electrical system is not safety related. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. O
Safety Evaluation Summary Report Page 9 of-57 Safety Evaluation No.:. 91-012, Rev. 1 Implementation Document No.: SC1-0G93-91 UFSAR Affected Pages: VI-50 (Table VI-3b) System: Postaccident Sampling (PAS) Title of Change: Impact of Leaving Isolation Valves 63-04 and 63-05 Normally Open Description of Change: Isolation valves 63-04 and 63-05 are located in the discharge return line to the torus for the PAS system. These valves also. provide a path for discharging fluid to the torus from relief-valve 122.1-03. This relief valve serves as an overpressure protection device for the low pressure portion.of the PAS system. This change revises the position of valves 63-04 and 63-05 from normally closed to normally open. Safety Evaluation Summary: ( Most of the PAS system is designed for the full reactor / pressure of 1200 psig. However, the portion of this system between valves BV 122-05 and BV 122-06 is designed for 250 psig, and piping between safety valve 122.1-03 and isolation valve 63-05 is designed for 150 psig. Keeping valves 63-04 and 63-05 open will ensure proper operation of relief valve 122.1-03 and will ensure that the design pressure'of this portion of the system is not increased as a result of leakage of valves isolating this portion of the system from the high reactor pressure.- Isolation valves 63-04 and 63-05 are open during normal plant operation when there is flow through the' PAS system, and hence keeping these va:ves open during normal operation will not impact nuclear safety in a way not previously evaluated. Also, the reactor protection system will ensure closing of these valves during-an accident condition. Leakage of reactor coolant through the blocking valves into the PAS system piping is not considered significant, though contamination may slightly increase. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. O
Scfoty_Evoluction - Summary Report Page 10 of 57 O Safety Evaluation No.: 91-013, Rev. 1 Implementation Document No.: DCR N1-90-001LS935 UFSAR Affected Pages: X-46 (Figure X-9) System: Instrument Air Title of Change: Reconciliation of As-Built and Design Documentation for the Removal of Instrument Air compressor /Intercooler (EPN 94-01, 02) Ball Valves Description of Change: This change deleted the ball valves that are shcwn on design drawings as being installed on the upstream aide of each intercooler provided with instrument air compressorr 94-01 and 94-02 (EPN3). These ball valves are indicated in the design documentation as being furnished and installed by the air compressor /intercooler vendor. However, during a recent plant walkdown, it was discovered that these subject ball valves were not installed. Safety Evaluation Summary: Deletion of the ball valves is a documentation-only change to reflect the as-built condition of the plant, and will not affect operation of the air compressor intercoolers. Review of the system operating and maintenance procedures indicates that these ball valves are not needed for system operation or maintenance. Alternate valves are installed and are used to provide positive equipment isolation for maintenance purposes. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question.
Safety Evaluation Summary Report Page 11 of 57 -q b Bafety Evaluation No.: 91-015, Rev. 1 ' Implementation Document No.: Mod. N1-88-091 UFSAR Affected Pages: N/A System: Motor-Generator (MG) Set Title of Change: Modification Acceptance Test for Static Battery Chargers l 161A and 171A (N1-STP-16) Description of Change: Special test procedure N1-STP-16 was generated to verify the operability of static battery chargers 161A and 171A, installed under Modification N1-88-091, as operational backups to the battery charging MG sets. The MG sets (one train at a time) were removed from service to allow the static battery chargers to maintain de load and charge each battery. This required entry into a 24-hour limiting condition of operation (LCO) for each train per Technical Specification Section 3.6.3. A wiring change in each MG set control panel was also required to allow (~ performance of the tests. ( Safety Evaluation Summary: The substitution of a static charger for a MG set during the test is functionally a one-for-one equipment substitution with equivalent electrical characteristics and greater reliability. The battery continues to be capable of supplying de load ; throughout the test, and operation of the battery system remains the same regardless of whether the static battery charger or MG set is in service. Any de transients that may occur during the test were evaluated and would not affect the MG set. If the static charger fails the' acceptance for any reason and the MG set cannot be returned to service, the plant will be shut down in accordance with the Technical Specification LCO. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed sa."ety question. i
I Snfety Evaluation Summary Report Page 12 of 57 O Safety Evaluation No.: 91-023 Implementation Document No.: Cales. SO-TORUS-M009, S0-TORUS-M010, S14-81, S14-81-F009; GE Report GENE-770-91-34 UFSAR Affected Pages: VII-2, VII-11, VII-13a, VII-16, VII-18; XV-159, XV-160, XV-164, XV-166, XV-167, XV-169, XV-169a, XV-169b, XV-169c, XV-169d, XV-169e, XV-169f, XV-169g, XV-169h, XV-1691, XV-169j, XV-169k, XV-169L (F XV-60a), XV-169m (F XV-60b); XVI-104, XVI-114 System: Containment Spray Title of Change: Heat Removal Capacity of the Containment Spray System Based on the Design Basis Reconstitution LOCA Suppression Chamber Temperature Response Analysis Description of Change: The origillal FSAR suppression chamber heatup analysis was performed between 1965 through 1968. Documentation of this analysis was not adequate to fully capture the original methods and assumptions. Therefore, the design basis reconstitution (DBR) analysis of the DBA LOCA suppression chamber heatup was performed using NRC-approved methods. The DBR suppression chamber heatup analysis resolved four items, identified as problems, in the areas of (1) heat exchanger fouling, (2) maximum lake water temperature, (3) spray system flow requirements, and (4) decay heat calculation. The DBR suppression chamber heatup analysis results were previously reported in letter NMPIL 0676, dated June 29, 1992, under Safety Evaluation 93-028, which specifically addressed the effects of increased lake water temperature. Safety Evaluation Summary: The DBR analysis evaluated the containment suppression chamber heatup assuming the containment spray system is operated in the
Safety l Evaluation Summary Report-Page 13 of 57 Safety Evaluation No.': 92-023 (cont'd.) Safety Evaluation Summary: (cont'd.) , drywell and wetwell spray mode and also operated in accordance i with the Emergency Operating Procedures (EOPs). ; Results of the DBR analysis for 82*F lake temperature yielded a peak calculated suppression chamber-temperature of 158.9'F if the 't following operability requirements are imposed:
- 1. . Minimum downcomer submergence of 3.5'ft. and a maximum l torus water temperature of 85'F. ;
- 2. The containment spray heat exchanger is initiated- '!
within 15 minutes post-LOCA. ;
- 3. Containment spray pump flow rate is 3600 gpm. l The DBR analysis results' conclude that all' der,ign criteria !
associated with maximum torus water temperature are satisfied at : the calculated peak temperature of 158.9'F. The analysis included the effects of the increased. peak torus temperature on the torus design, piping design conditions, Mark I ! loads, containment and core spray pumps NPSH and seal design, core cooling capability of core spray, and drywell and wetwell l maximum pressures. Based on the evaluation performed, it is concluded that the ! containment spray system continues to be operable. This change l does not involve an unreviewed safety question. ' l l 1 i
'i i
i
Safety Evaluation Summary Report Page 14 of 57 O Safety Evaluation No.: 91-025, Rev. O, 1, &3 Implementation Document No.: Calc. S14-81-F022, EOP ? UFSAR Affected Pages: N/A System: Core Spray Title of Change: Assuring Adequate NPSH to the Core Spray Pumps During Long-Term Post-LOCA Operation After the Core is Covered by Removing Core Spray Topping Pumps from Service Description of Change: This change revised the emergency operating procedures (EOPs) to permit the core spray topping pumps to be removed from service during long-term postaccident cooling. This maneuver will lower system flow and help to assure that the core spray pumps have adequate net positive suction head (NPSH) and operate below the shockless capacity of the pumps. Operating at the lower flow . rate will prevent possible accelerated erosion of the core spray pump impeller. Safety Evaluation Summary: The topping pumps will not be removed from service until the reactor vessel pressure has deteriorated (less than 30 psig) and the core is covered, and the only need for injection is to maintain level. The topping pump and its associated components will not be damaged in this mode of operation and the safety function of the core spray system will be satisfied. Removing the topping pump from servics does not disable it permanently. If an operator feels the need to restart the topping pump, it can be reinitiated. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. 1 0
, i
- i. l L 'Safoty Evaluation )
Summary Report j Page 15 of 57 . i I t" l kw safety Evaluation No.: 91-030
.i Implementation Document No.: DCR N1-91-800LG002' UFSAR Affected Pages: VII-26 System: Liquid Poison.
l Title of Change: Reconcile Licensing and Plant Documentation to Concur with- ' Design Documentation and-the As-Built Condition for the Liquid Poison System Pressure Relief Valves r Description of Change: , This change-establishes the setpoint-of the liquid poison system safety relief valves as 1500 psig 3% in accordance with the valve nameplate and ASME ' Section VIII Division' 1 Part UG-133 (f) - 1971 for tolerance. Also, the design discharge pressure of the: , liquid poison pumps is revised from 1500 psig-to 1670 psig. Safety Evaluation summary: 1
)
The setpoint of 1500 psig 3% is appropriate to safely perform 1' the function of these valves, which is to protect the pumps and: associated piping from damage due to overpressure.. The pumps are; designed to operate and deliver their' safety function flow for discharge pressures as high as 1670 psig. The associated piping has been qualified for pressures up'to 1750 psig. -The highest-possible system pressure'with the setpoint at 1500 psig- 3%Lis 1638 psig, taking into account setpoint error, elevation head, ! backpressure and 3% accumulation. Thus, the new setpoint will1 maintain pressures within [ ANSI (ASA)-B31.1-1955 limits. Based on the evaluation performed, it is concluded that this ' change does not involve an unreviewed safety question. i [ q r f
Sofoty Evaluation l Summary Report l Page 16 of 57 Safety Evaluation No.: 91-037, Rev. O, 1&2 l Implementation Document No.: Temp. Mod. 5347 UFSAR Affected Pages: N/A System: Radwaste Disposal Title of Change: Temporary Modification 5347: Installation of (MFTDS) Filters and Demineralizers Description of Change: In order to facilitate the replacement of the #12 concentrator circulating pump (EPN 45-217), the modular fluidized transfer demineralization system (MFTDS) was installed to maintain the operability of the #12 concentrator portion of the radwaste system. The MFTDS consisted of a series of four vessels (1 filter and 3 demineralizers) which diverted the effluent of waste concentrator
- 12 to the waste collector tank. This assembly was located in the Dow seamer and drum storage area, on the 261' elevation of the waste building.
Safety Evaluation Summary: The MFTDS was installed in accordance with established site procedures and meets the design requirements for the radwaste system. Process control instrumentation and periodic waste samples assure proper operation of the MFTDS. Personnel radiation exposures are maintained ALARA by the installation of shielding and by controlling access to the MFTDS equipment area. Rupture of a system hose during the filter /demineralizer process is bounded by a tank rupture as described in UFSAR Section XII-A.2.2. Any dispersed liquid from a hose leak can readily be recovered and processed through the floor drain system. Based on the evaluation performed, it is concluded that this temporary change does not involve an unreviewed safety question. O
i Safoty Evoluntion i Summary Report Page 17 of 57 iO NA Safety Evaluation No.: 91-040, Rev. 1 Implementation Document No.: Simple Design Change . SC1-0266-91 i UFSAR Affected Pages: VIII-38 (Figure VIII-14), , VIII-39 System: In-core Monitoring Title of change: APRMs 11-18 Scram / Rod Block Setpoint Description of Change: This change revised the flow-biased rod block and scram setpoints for average power range monitors (APRMs) R102A through D from , 107% and 118.5% to 106% and 116%, respectively. This setpoint revision was required since the calibration frequency of APRM flow units R103A through D was revised from once a month to once every 3 months per Technical Specification Amendment No. 130. Revising the calibration frequency for the flow units affects these setpoints since the APRMs receive their flow-biasing signals from the flow units. {e) x- , Safety Evaluation Summary: The new setpoints were calculated by calculation 9P-APRM-R102A-D. A margin was developed by considering instrument inaccuracy, calibration uncertainty and drift, and was then subtracted from the analytical limit to come up with the required setpoint. These setpoint revisions ensure safe operation and shutdown of the plant by causing the APRM flow-biased rod block and scram to occur below the Technical Specification limits of 110% and 120%, respectively. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. l l l l 1
Safety Evaluation Summary Report Page 18 of 57 Bafety Evaluation No.: 91-041 . Implementation Document No.: N/A UFSAR Affected Pages: N/A System: Reactor Manual Control Title of change: Dual Control Rod Selection Description of change: On December 16, 1989, an operator at the Oyster Creek Nuclear Station inadvertently selected two control rods during a rod withdrawal. This was attributed to mechanical problems within the reactor manual control s'jstem. The purpose of this evaluation was to determine whether the potential for dual rod selection represented an unreviewed safety question for Unit 1. Safety Evaluation Summary: The dual control rod withdrawal concern was evaluated for any impact on the continuous control rod withdrawal transient and the lh control rod drop transient. The evaluation concluded that the dual control rod selection scenario does not represent a safety concern because the probability of occurrence is small and the consequences are small since reactor scram on high neutron flux protects the reactor core. Additional administrative controls and operator training as a result of the Oyster Creek event have been implemented to ensure proper rod selection withdrawal. Based on the evaluation performed, it is concluded that continued operation of Unit 1 in its current configuration does not involve an unreviewed safety question. O
Safety Evaluation i Summary Report ' Page 19 of 57 N.] Safety Evaluation No.: 91-043, Rev. 1 &_2 Implementation Document No.: Major Order No. 0546 UFSAR Affected Pages: III-3 (Figure III-1) System: N/A Title of Change: New York Telephone Switch Building at Nine Mile Point Unit 2 , Description of Change: , The original telephone system on site was inadequate to meet the needs of site personnel. A new single switch replaced the two switches previously in use at Units 1 and 2. The new system is housed in a new building outside the protected area, west of the east flood control berm at Unit 2. Safety Evaluation Summary: The new single switch facilitates the entire site telephone system as well as meeting the future of data communication. The (~Ns_s} new building is not within the direct flow path of flood waters, and thus will have no adverse impact on the probable maximum precipitation (PHP) flood study. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question.
Snfaty Evaluntion Summary Report Page 20 of 57 O Safety Evaluation No.: 91-069 Implementation Document No.: N/A UFSAR Affected Pages: III-3 (Figure III-1) System: N/A Title of Change: Nine Mile Point Unit 2 Site Paving and Drainage Description of Change: This change regraded and paved the parking lot south of the "P" building (an area of approximately 16,000 square yards) . Drainage of the swale south of the parking area, running to the east and then to the north, was also improved by lining with geotexal fabric and cobblestone. The existing culvert under the east service road was abandoned. A 12'-0" paved turning lane was also added to Lake Road between the warehouse road and the east service road. Safety Evaluation Summary: The paved turning lane improves the flow of traffic into and out - of the plant. Paving the parking lot eliminates the possibility of personnel injury due to loose rocks and standing water conditions. A review of the flood study calculations determined that this change improves site drainage and has no adverse effect on the probable maximum precipitation flood elevation. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. I
-I Safoty Evaluation
, Summary Report a Page 21 of 57 j
' Safety Evaluation'No.: 92-001 -
Implementation Document No.: Mod. N1-90-010 ' UFSAR Affected Pages: N/A System: Fire Protection Title of Change: Fire Panel Overheating
- Description of Change:
This modification enhanced the mechanical ventilation of the local fire control panels (LFCPs) to prevent the overheating of , temperature-sensitive' equipment, thereby improving the- _j reliability of the panels. Additional exhaust fans'and intake -! filters were installed on each cubicle of each LFCP. These ' changes improved air flow through each cubicle, thereby improving the cooling of the LFCP internals. , i Safety Evaluation Summary: This change does not alter any safety function described in the-
.O UFSAR and does not adversely affect the Unit 1 fire _ protection program. This modification not only improves the reliability ~of-the LFCPs, but the plant-fire protection system as a whole._.The l
1 equipment added by this modification does not interconnect with any functions performed within the LFCPs. Therefore, any fault by this equipment will not_ impact the ability of the LFCPs to' ; perform their intended functions. Based on the evaluation performed, it is concluded that this , change does not involve an unreviewed safety question. I i
Safety Evaluation Summary Report Page 22 of 57 O , Safety Evaluation No.: 92-009 Implementation Document No.: Procedure N1-EMP-GEN-296 UFSAR Affected Pages: IX-2a System: 345-kV Distribution Title of Change: Establishment of and Restoration from 345-kV Backfeed through Station Transformers T1 or T2 Description of Change: This change established a procedure for backfeeding 345 kV to the Station when in the cold shutdown or refueling condition. After disconnecting the main generator links and closing in on the 345-kV breakers R915 or R925, and after taking the appropriate precautions, backfeed is accomplished by energizing main transformer T1 or T2 by way of 345-kV lines 8 or 9. This configuration will step down the system voltage from 345 kV to 24 kV and use station service transformer #10 to supply 4160 V to energize power boards #11 and #12. Safety Evaluation Summary: When Unit 1 is in the cold shutdown or refueling condition, the main turbine generator is out of service and station power is being supplied by the 115-kV reserve sources via transformers T101N and T101S. The establishment of 345-kV backfeed through transformer T1 or T2 increases the reliability of availability of offsite ac power to energize the 4160-V power boards 11 and 12. This configuration does not affect the station distribution system or nuclear safety. The 345-kV system will not be, at any time during this configuration, the only source of ac power available to supply the station. The 345-kV buses will not be paralleled to the 115-kV lines or the emergency diesel generators while the backfeed configuration is in place. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. O
Safety Evaluation Summary Report. : Page'23 of 57 , Safety Evaluation No.: 92-010, Rev. 3 Implementation Document No.: Simple Design Change SC1-0078-92
- UFSAR Affected Pages: VI-64, VI-68 ,
System: Reactor Protection (RPS) , i Title of Change: Removal of High Radiation i Sensor Relay Timers (2-11/202 and 2-12/202), Reactor Building Ventilation System Description of Change: ; This change removed time delay relays 2-11/202.and'2-12/202. These relays delayed closure of the reactor building normal-exhaust line isolation valves and delayed tripping.offthe normal exhaust fans upon detection of high radiation levels.within'the reactor building. The' purpose of the delay was_to ensure that: reactor building negative pressure was maintained during the transition from normal to emergency ventilation system operation.- ; Analysis has shown that the time delay is not required to achieve k- that purpose.. Safety Evaluation. Summary: ; Analysis has demonstrated that the time delay relays are not ! required to maintain the reactor building pressure negative ! during the transition from normal to emergency ventilation system operation. In addition, removal of the timer reduces the > likelihood of an overpressurization/underpressurization event. Maintaining the subject negative pressure will be accomplished by ' surveillance (N1-ST-Q20) of the ventilation c2:scea isolation - valve closure times. l Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. 1 i r
?
Safcty Evaluntion Summary Report Page 24 of 57 O Safety Evaluation No.: 92-011 , Implementation Document No.: N/A UFSAR Affected Pages: IX-4 System: 115-kV Offsite Power Supply Title of Change: Bennetts Bridge Hydro - ' Removal from Service in 1992 and 1993 Description of Change: Bennetts Bridge Hydro Station Units 3 and 4 are being removed from service from June 1, 1992, to February 1, 1993, for rehabilitation and upgrading. With their removal from service, dedicated emergency backup power to the Unit 1 high pressure coolant injection (HPCI) system through the 115-kV transmission system will not be available. Also, controllership of the hydroelectric operations at Bennetts Bridge has been transferred from the Central Regional Control . Center in Syracuse to the Northern Regional Control Center in Watertown. Safety Evaluation Summary: Since HPCI backup power was not assured during 115-kV system blackout conditions, credit was not taken for its use in the loss-of-coolant accident (LOCA) analyses. Thus, the results of the current LOCA analysis remain unchanged. Removal of these units at Bennetts Bridge will not cause a violation of the Technical Specifications (Section 3.1.8, High Pressure Coolant Injection, and Section 3.6.3, Emergency Power Sources). Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. i l l l 1 O
Safety Evaluation Summary Report Page 25 of 57 O N. Safety Evaluation No.: 92-021 Implementation Document No.: LDCN U-N0184 UFSAR Affected Pages: XV-5 System: Fuel, Turbine Bypass Portion of Main Steam Title of Change: Disposition of Turbine Bypass Capacity Shortfall, PR-2070 Description of Change: Safety Evaluation No. 90-048 (previously reported in letter NMP1L 0589 dated June 28, 1991) addressed a shortfall of turbine bypass valves capacity that was measured during plant restart testing. This change adds a clarification to UFSAR Chapter XV, which notes that this shortfall in bypass capacity will not cause the transients defined in UFSAR Chapter XV, which use the bypass system, to exceed any safety limits. These transients are bounded by the reload analysis which does not take credit for the bypass system. Safety Evaluation Summary: This change updated the UFSAR to note the impact of the turbine bypass capacity shortfall on Chapter XV transients, as previously analyzed in Safety Evaluation No. 90-048. Since the limiting transients analyzed for the reload analysis do not take credit. for the turbine bypass valves, the bypass capacity shortfall does not impact plant safety. Based on the evaluation prerformed, it is concluded that this change does not involve an unreviewed safety question. O
I { Safcty Evaluation Summary Report Page 26 of 57 Safety Evaluation No.: 92-025, Rev. 1 Implementation Document No.: Procedures N1-OP-5, N1-ISI-LK101 UFSAR Affected Pages: N/A System: Control Rod Drive (CRD) Title of Change: Manual Operation of CRD Flow Control Valve (FCV) When Temperatures are Equal to or Greater Than 212*F Description of Change: During reactor vessel hydrostatic testing, this change allows operation of the CRD system with the FCV set to manual at a flow rate of less than 50 gpm, with an operator dedicated (as required by procedure N1-ISI-LK101) to assume control should increased makeup be required. Also, during plant startup and operation, this change allows operation of the CRD system with the FCV set to manual at a flow rate of greater than or equal to 50 gpm, with an operator dedicated (as required by procedure N1-OP-05) to assume control to provide makeup as required. The change during plant startup and operation also allows placing the FCV in manual with a dedicated operator if reactor pressure results in erratic response while set in automatic. The dedicated operator insures that an adequate flow rate (greater than or equal to 50 gpm) is maintained. This change was necessary to maintain proper feed and bleed control during the reactor hydrostatic test, and to eliminate erratic CRD FCV response while under low reactor pressure conditions during startup. Safety Evaluation Summary: This change is acceptable since (1) the system continues to meet the Technical Specification surveillance requirements in that the pump meets its pump head curves and is capable of automatic initiation, (2) in the event of reactor coolant leakage and resulting pump discharge head decrease, pump flow will increase in accordance with the pump curve, and (3) the dedicated operator can assume manual control to compensate for any reactor coolant leakage. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. O
i Safoty Evaluction Summary Report Page 27 of 57 q (s- ' Safety Evaluation No.: 92-031 Implementation Document No.: N/A UFSAR Affected Pages: I-5; V-3 (Table V-1), V-21, V-22, V-23 (Figure V-5), V-23a, V-24 (Figure V-6) , V-25 (Figure V-7); XVI-1, XVI-51 System: N/A Title of Change: Incorporation of the Method of Revision 2 to Regulatory Guide 1.99, Radiation Embrittlement of Reactor Vessel Materials into the Plant Licensing Basis Description of Change: New reactor vessel pressure-temperature (P-T) limits have been developed to reflect the impact of Regulatory Guide (RG) 1.99, Revision 2, to ensure Station operations are conducted with reactor pressure vessel (RPV) above nil ductility transition temperature (NDTT) to preclude brittle failure of RPV materials. Os Generic Letter (GL) 88-11 requested all nuclear plants to analyze the impact of RG 1.99, and that all actions necessary be completed within two plant outages of the effective date of the revision. NMPC performed the appropriate analyses and updated the P-T limits curves. This change also resolved a mixup in reactor vessel surveillance specimens. Several capsules have > been reinserted in the reactor cavity, and the surveillance capsule withdrawal schedule has been revised. A license amendment request to incorporate these changes into the Technical Specifications was submitted to the NRC. Safety Evaluation Summary: The revised P-T operating limits are based on analysis using Revision 2 to RG 1.99, and thus satisfy GL 88-11. Implementation of the revised P-T operating limits ensures that Station operations are conducted with the reactor vessel materials above the NDTT. The revised P-T operating limits and surveillance program preclude brittle failure of the reactor vessel materials since safety margins specified in 10CFR50 Appendix G and the ASME Code Appendix G will be maintained. The revised P-T limits and surveillance program were approved by the NRC in their safety evaluation associated with the issuance of License Amendment No. 127.
Safety Evaluation Summary Report Page 28 of 57 O Bafety Evaluation No.: 92-032, Rev. 0 & 1 Implementation Document No.: Mod. N1-92-011 UFSAR Affected Pages: N/A System: Emergency Condenser Title of Change: Cut Weld Joining Valve 39-04 to Valve 39-02 and/or Cut Weld Joining Valve 39-03 to Valve 39-01 , Description of Change: This evaluation reviewed and evaluated the safety implications and impacts of cutting out the circumferential butt weld joining check valve 39-04 to gate valve 39-02 (and/or the butt weld joining check valve 39-03 to gate valve 39-01) with (1) the reactor in the cold shutdown condition, (2) irradiated fuel contained in the reactor vessel, and (3) single reactor pressure boundary isolation via a safety-related manual gate valve. This action was to facilitate shop repair of cracks in the check valve and eventual replacement of the gate valves. ; Safety Evaluation Summary: The emergency condenser system is not required to be operable when the plant is in the cold shutdown condition. The design of the manual gate valve is such that it can provide isolation of the reactor pressure boundary when performing maintenance on the upstream check valve. The valve, when closed, has demonstrated leak-tightness and will not degrade during the cutting operation. Existing cracks located in the gate valve body will not become larger as a result of the cutting operation. In the event that some minor leakage were to occur through the valve disc seat area, it would be well within the makeup capabilities of reactor water makeup systems and would not lead to core uncovery. Measures were taken to establish reactor conditions most favorable with respect to inventory, isolation, level indication, and decay heat removal, and to mitigate the consequences in the unlikely event that excessive leakage were to occur during the cutting operation. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. O
1 Snfoty Evaluntion , Summary Report j Page 29 of 57 ;
/s l k_-)
Safety Evaluation No.: 92-033 Implementation Document No.: Fuel Handling Procedure N1-FHP-27, Rev. 9 UFSAR Affected Pages: N/A System: Control Rod Drive Title of Change: Extended Core and Control' Rod Drive Maintenance Tech. Spec. Basis Change for Spiral Offload Description of Change: This change to Technical Specification Bases Section 3.5.3 revised the sequence of bypassing the refueling interlock for control rods located in an offloaded fuel cell. The original bases required bypassing the refueling interlock prior to withdrawal of the control rod located within an offloaded fuel cell. The revised sequence installs the refueling interlock jumper after the control rod for the selected cell is fully (' withdrawn, thus maintaining the one-rod-out automatic protection until all rod movement is complete. In addition, the original bases specified that independent verification of the refuel interlock bypass would be performed by a member of the reactor analysis staff. The revised bases now specify that an independent licensed operator or engineer will perform the independent verification. Safety Evaluation Summary: This Technical Specification basis change does not adversely affect nuclear safety, nor does it increase the potential for an inadvertent criticality excursion during refueling operations. , General Electric recommended that refuel interlocks be maintained until after the control rod located within an offloaded fuel cell was fully withdrawn. The interlock for the withdrawn control rod would then be bypassed and independently verified. Operation in this sequence provides automatic protection from multiple control rod withdrawal which could result in inadvertent criticality. The bases change in the independent verification is due to the fact that the Reactor Analysis Department no longer exists because of an organizational change. This independent verification is consistent with that required by Technical /N Specification 4.1.1 b. (3) (b) , " Control Rod System." U
Safety Evaluation Summary Report Page 30 of 57 O Safety Evaluation No.: 92-033 (cont'd.) Safety Evaluation Summary: (cont'd.) Based on the avaluation performed, it is concluded that this change does not involve an unreviewed safety question. O' O
Snfety Evaluntion Summary Report Page 31 of 57 , rh Safety Evaluation No.: 92-034 i Implementation Document No.: Procedure N1-OP-43 UFSAR Affected Pages: N/A System: Average Power Range Monitoring (APRM) and Intermediate Range Monitoring (IRM) Nuclear Instrumentation Systems Title of Change: Coincident APRM Downscale and IRM Upscale Scram in RUN Design Basis ) Description of Change: This change to operating procedure N1-OP-43 allows the withdrawal of the IRM detectors to the storage position when the mode switch is in RUN, and the associated APRM is greater than the downscale trip setpoinc as long as the associated IRM is maintained ' onscale. The procedure previously allowed the IRM to be maintained in an upscale trip to maintain the-APRM downscale operable. This practice resulted in partial IRM insertion at ; \-- power and premature IRM detector burnout. Safety Evaluation Summary: The design basis for the coincident IRM upscale and APRM downscale scram in the RUN mode is to assure proper overlap between the IRM and APRM systems. The Technical Specifications allow this scram to be bypassed in the RUN mode when the IRM and APRMs are onscale. Operating the IRMs such that the IRM is in the storage position in the RUN mode is consistent with the UFSAR description. Verifying the IRM is onscale (operable) and APRM operability, per Technical Specifications, is the only requirement to assure that the bypass conditions are applicable. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. O
Safety Evaluntion 1 Summary Report Page 32 of 57 : Safety Evaluation No.: 92-036, Rev. 0 & 1 Implementation Document No.: Mod. N1-92-011 UFSAR Affected Pages: N/A System: Emergency Condenser (Condensate Return) Title of Change: Replacement / Repair of Emergency Condenser Valves Description of Change: This change consisted of replacement of cracked manual gate valves 39-01 and 39-02 with new valves, and weld repair of check valve 39-04. This also involved replacement of a straight spool of 10" pipe in each loop to accommodate valve fit up, and minor configuration changes to the drain pipes attached to the valves. Safety Evaluation Summary: This change restores the emergency condenser system to its design basis, and hence nuclear safety and plant operability are not affected. This modification meets all code and regulatory h requirements for repair, replacement, test, and examination of the valves, piping, and welds. These repairs were performed with the reactor head removed and the reactor core offloaded. The recirculation loops #11 and #15 suction nozzles were plugged. Measures were taken to minimize the duration that the plugs were required, and to establish conditions most favorable with respect to reactor inventory, level indication, and makeup water availability. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. O
. .- . _~. . , - . . . - - . - .-.
1 Safety Evoluntion Summary Report j Page-33 of 57 l(() : Safety Evaluation No.: 92-037 I Implementation Document No.: Major Order No._1566 ! UFSAR Affected Pages: IV-35, IV-35a ! System: Control Rod
-f Title of Change: Control-Blade Replacement !
i' Description of Change: This evaluation addresses the use of General Electric Duralife-230.(D-230) control rods. The D-230 is an improved design'with f' an extended lifetime. Design features of the D-230 include: (1) the use of hafnium in place of boron carbide'in the upperlsix ! inches of the control rod blade and in the outerLedge of each wing; (2) use of high-purity stainless steel tube material; (3) a i redesigned velocity limiter; (4) a new upper handle design; (5) ! incorporation of the BWR/6 control blade coupling release handle design; and (6) noncobalt pins and rollers._. ll The D-230 blade is'very similar to the ALLCR'addressedLin Safety: f O Evaluation No.'85-029, except that the-D-230 blade has a larger volume of B/3 to increase control rod lifetime. safety Evaluation summary: The D-230 generic safety evaluation has been previously approved l by the NRC. The new control rod reactivity worth is the same as e the all-Bg3 control rods. The scram insertion times and control rod drop times are not significantly affected. l Based on the evaluation performed, it is concluded that these I changes'do not involve an unreviewed safety question. j k i e h i {
-}
i
Safety Evaluntion Summary Report Page 34 of 57 O Safety Evaluation No.: 92-038, Rev. 2& 3 Implementation Document No.: Procedures NEP-POL-300, GAP-POL-01 UFSAR Affected Pages: XII-30; Sections XIII.A, XIII.B, XIII.F, XIII.G; 10A-10, 10A-12, 10A-13 System: N/A Title of Change: Nine Mile Point Unit 1 Reorganization Description of Change: Section XIII of the UFSAR describes the organization responsible for operation of Nine Mile Point Unit 1. This change addresses revisions to the Nuclear Division organizational structure. Departments and positions were redefined and reorganized to enhance the flow of communication and productivity of the Nuclear Division. Affected areas of the division organization include Generation and Quality Assurance. Safety Evaluation Summary: The organizational changes provide the Nuclear organization with resources to be both efficient and effective while meeting NRC guidance. The changes did not reduce the effectiveness of supervision or the ability of groups or individuals to perform activities necessary to ensure safe operation or shutdown of the plant. Positions specific to Unit 1 meet ANSI /N18.1-1971 requirements as endorsed by Regulatory Guide 1.8. Positions with site-related responsibilities meet both ANSI /ANS-3.1-1978 and ANSI /N18.1-1971 as endorsed by Regulatory Guide 1.8. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. l 1
Safety Evaluation Summary Report ' Page 35 of 57
,- m Safety Evaluation No.: 92-039, Rev. 1 Implementation Document No.: Procedure N1-STP-23 UFSAR Affected Pages: N/A System: Core Spray, Containment Spray, Automatic Depressurization System (ADS)
Title of Test: Testing of Initiation Logic for Core / Containment Spray and ADS Circuitry as Powered from EDG 102 and 103 for Degraded Voltage Conditions Description of Change: Special test procedure N1-STP-23 was performed to acquire data for existing circuit relays for characteristics of pickup and dropout voltages and frequency response. With the plant in cold shutdown conditions and with one channel of both core and containment spray operational, the initiation logic of the other O , channel was isolated from its normal power supplies, tested, and subsequently returned to service. Testing involved connection of these circuits to a source of variable voltage and frequency. Voltages were increased and decreased to derive the desired information for pickup and dropout of relay coils. The circuits were then tested at variable frequencies to determine circuit response with respect to time. This test was performed to satisfy a commitment to the NRC following the Electrical Distribution System Functional Inspection (Inspection Report No. 50-220/91-80). Safety Evaluation Summary: The testing was performed with the plant in cold shutdown. One channel of both the core spray and containment spray systems remained operable. The evaluation determined that the testing would not initiate or adversely affect _other safety-related structures, systems or components since logic circuitry being tested was isolated. Appropriate precautions, limitations and test abort criteria were included in the procedure should unexpected conditions arise which could have the potential to put the plant in an unsafe condition. System operability tests were performed before the systems were returned to service. As an added precaution, spare timers and relays were made available (of the types being tested) as a prerequisite to testing.
Safety Evaluation Summary Report Page 36 of 57 O Safety EvaluatEon No.: 92-039, Rev. 1 (cont'd.) > Safety Evaluation Summary: (cont'd.) Based on the evaluation performed, it is concluded that this test does not involve an unreviewed safety question. O' O
I i l Safety Evaluntion ; Summary Report Page 37 of 57 l l Safety Evaluation No.: 92-040 l Implementation Document No.: Procedures NIP-ECA-01, NIP-SRE-01 i UFSAR Affected Pages: Section XIII.G System: N/A Title of Change: Operations Experience Assessment Description of Change: This procedural change fulfills the operating experience assessment (OEA) function by utilizing an alternative approach to that presently described in the UFSAR. The assessment function is no lorger fulfilled primarily by the OEA group. The procedurai changes require that the OEA function be accomplished by a responsible organization which is considered most cognizant over the operating information being evaluated. This assessment function is controlled by a Nuclear Division Interfacing Procedure, NIP-ECA-01, entitled " Deviation Event Report." The DER process, in conjunction with Nuclear Division Interfacing s Procedure NIP-SRE-01, entitled " Operating Experience Assessment," meets the requirements of TMI Issue I.C.5. In addition, the procedural changes eliminate the need for mandatory Station Operations Review Committee (SORC) participation every two months with the OEA group. The alternative approach allows the Plant Manager to request SORC involvement in the processing of DERs related to the OEA function ' on an as-needed basis. safety Evaluation Summary: The use of the DER process to fulfill the OEA function, as mandated by TMI Issue I.C.5, is acceptable based upon the following: ' l
- 1. The DER process is proceduralized; ;
- 2. OEA for any given applicable DER is performed by the most qualified NMPC group, since the selection criteria of the responsible organization for processing the DER.is procedurally required to be the most cognizant group for the subject matter of a given DER;
.i
Safety Evaluntion Summary Report Page 38 of 57 O Safety Evaluation No.: 92-040 (cont'd.) Bafety Evaluation Summary: (cont'd.)
- 3. The DER disposition process provides a mechanism by which necessary plant' actions, training, and retraining will be stipulated; and
- 4. SORC involvement, as mandated by either Plant Manager on an as-needed basis, ensures fulfillment of SORC's review function of advising the Plant Manager on matters related to nuclear safety.
Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. O 1 0
'!t Safety Evaluation :
Summary Report , Page 39 of 57. , Safety Evaluation No.: 92-045 f Implementation Document No.: N/A l UFSAR Affected Pages: N/A [ System: Radwaste Title of Change: Temporary Use of a CO2 Pellet Decontamination Facility _at : NMP1 l Description of Change: ' This change involves the installation and use of a CO 2 Pellet- -l cleaning facility for decontamination of tools and other hardware during NMP1 outages. The pellet cleaning facility will be , temporarily located on the west side of the Unit 1 turbine i building, and consists of a 14-ton liquid CO2 storage tank, ' compressed air delivery' system, CO Pelletizer, delivery gun, 2 cleaning enclosure, and support equipment enclosure. The system cleans radioactively-contaminated hardware of up to 4000 lbs. by , means of high-velocity delivery of CO2 Pellets. The solid CO O, expands to gas during the decontamination process and is removed along with the contaminants via the HVAC system. Air exhaust 2 from the cleaning facility is directed into the turbine building.- Safety Evaluation Summary: j The CO2 Pellet cleaning facility is expected to reduce both the time and exposure to workers in the handling of radioactive materials. The' controls and operation of the facility do not l create a new radioactive effluent pathway or create,an l unmonitored release of radioactivity. The decontamination ; enclosures are designed to ensure that a' negative pressure is maintained in both the walk-in and glove box enclosures. A HEPA. - filter system is-used to ensure _that both workers and the- . l environment are not subjected to unfiltered exfiltration from the l . facility. Control room habitability would not be affected by. rupture of the CO2 storage tank or loss of containment of the 3 facility. The facility itself will not create any building ~ wake- l effects that would affect atmospheric dispersion values used for_ : accident analyses. 1 Based on the evaluation performed, it is concluded that this -) temporary change does not involve an unreviewed safety question. . ) l i
Safety Evolustion Summary Report : Page 40 of 57 ) l Safety Evaluation No.: 92-046, Rev. 0&1 l Implementation Document No.: N/A UFSAR Affected Pages: III-3 (Figure III-1) System: N/A Title of Change: Nine Mile Point Compressed Bottled Gas Storage Facility Description of Change: This change consists of the construction of a new bottled gas storage facility. The new storage facility is a nonsafety-related structure and is located outside the protected area south of the Unit 2 Warehouse. The area of the new facility is about 2500 sq. ft, with interior ceiling height about 15 ft., and is designed to accommodate 550 bottles of various compressed gases. The facility consists of two areas; the east area is designated for storage of the flammable bottles, and the west area is designed for storage of the nonflammable bottles. Safety Evaluation Summary: The construction of the new storage facility does not disturb those attributes of the site, in the immediate vicinity of the plant, which safely divert the local probable maximum precipitation runoff overland to Lake Ontario. Also, since the new facility is low in elevation and outside the protected area, this location will not create any wind disturbances which may affect the atmospheric dispersion factor study. The effects of an accidental nitrogen gas release from the facility on control room habitability were evaluated. The potential for missiles as a result of fire or explosion was also considered. No adverse impacts were identified. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. 9-I
Safety Evaluation Summary Report Page 41 of 57 Bafety Evaluation No.: 92-050, Rev. 0 & 1 Implementation Document No.: N/A UFSAR Affected Pages: N/A System: Main Steam; Reactor Instr; Turbine Protect / Supervisory , Title of Change: Refuel Cycle Surveillance Frequency Extension Evaluation Description of Change: Certain NMP1 Technical Specification surveillances which are required to be performed on a " refuel cycle" timetable nominally became due in January 1993. The due dates of these surveillances were extended to allow plant operation during a period of low operating reserve based on New York Power Pool (NYPP) projections. This safety evaluation reviewed the affected surveillances and provided a basis for justifying extensions to Technical Specification specified surveillance periods. The current refuel outage latest start date was February 19, 1993, I for the purposes of this evaluation. Therefore, the extension 5 e) covered a period from January 1993 until after February 19, 1993, during the planned refuel outage. Safety Evaluation Summary: A review of historical equipment "as-found, as-left" historical data and associated statistical analysis confirms that the effects on setpoint drift due to the surveillance frequency extension would be insignificant. Also, none of the ASME Section XI test frequencies will be exceeded without NRC approval. A relief request was submitted to the NRC to delay certain surveillances specified in the IST program (reference NMPC letter ! NMP1L 0705 dated August 15, 1992). Therefore, the delay in the start of Unit i refuel surveillances until after February 19, 1993, will not cause plant operation outside of analyzed limits or accident conditions or cause the reduction of any margin of safety. j Based on the evaluation performed, it is concluded that this i change does not involve an unreviewed safety question. i I ($3) . l
Safety Evaluntion Summary Report Page 42 of 57 Safety Evaluation No.: 92-052 Implementation Document No.: Temporary Mod. 92-044 UFSAR Affected Pages: N/A System: N/A Title of Change: Reroute the Security Fence to support the Demolition of
" Area Complex" Building and the Construction of the Swing Building Description of Change:
This change constructed a temporary " bubble fence" and rerouted the security fence to exclude the Area complex site from the protected area of Nine Mile Point so activities associated with the construction of the swing building would be outside the security zone. The temporary " bubble fence" was constructed following security procedures and regulations. The fence was equipped with a security intrusion detection system, and a closed-circuit TV camera (CCTV) was installed in accordance with 10CFR73. Safety Evaluation Summary: This temporary modification does not result in a significant elevation change in the flooding levels within the berm area of Nine Mile Point Site. Rerouting the security fence and construction of the " bubble fence" do not disturb those attributes of the site in the immediate vicinity of plant which safely divert the local probable maximum precipitation (PMP) runoff overland to Lake Ontario. ' Based on the evaluation performed, it is concluded that this temporary change does not involve an unreviewed safety question. O : l l
Sofcty Evaluation Summary Report Page 43 of 57 g Safety Evaluation No.: 92-053, Rev. 0&1 Implementation Document No.: Simple Design Change SC1-0092-92 UFSAR Affected Pages: VI-22 System: Torus ; Title of Change: Torus Corrosion Coupons Description of Change: This change installed corrosion coupons in the torus to provide another method of determining torus shell corrosion rates in addition to the current UT methods. The coupon holder supports were attached to existing gussets on the ring girders, and were fabricated from lexan, to prevent or minimize galvanic corrosion. Safety Evaluation summary: The NRC directed NMPC to install corrosion coupons in the torus , during the 1993 refuel outage in their August 25, 1992, Safety O Evaluation Report. Although the coupons do not perform any safety function, the holders and supports are designed to withstand LOCA loads. Even if the coupons were dislodged during a LOCA, there would be no detrimental effect due to impact on the torus shell, and no detrimental effect to core and containment spray systems since the loose coupons would not have the capability, under LOCA conditions, to enter the horizontal suctions of those systems. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. 5 t
Sofety Evaluntion Summary Report Page 44 of 57 9 Safety Evaluation No.: 92-054 Implementation Document No.: Procedures N1-CSP-8M, S-SP-5 UFSAR Affected Pages: IX-24 System: Emergency Diesel Generator Fuel Oil Handling and Storage Title of Change: Emergency Diesel Generator Fuel Oil Sampling Description of Change: The First Supplement to the UFSAR (May 1968), in describing the emergency diesel generator (EDG) fuel oil storage and delivery system (page V-12), states that " Sample taps will be provided . between the tanks and filters," and also that samples will be taken at 6-month intervals initially, then annually thereafter. The current monitoring of EDG fuel oil quality is performed monthly. Samples are taken from the storage tank with a sample thief, accessed through the storage tank till port, obtaining a sample at a depth of 6 in, from the tank bettom. This evaluation addresses the equivalency for the sampling method O, currently utilized. Safety Evaluation Summary: Although provisions for sampling taps were provided for on the delivery system, alternate methods are used to monitor the fuel
- oil quality. The sampling procedure used ASTM D-270, as referenced by Regulatory Guide 1.137, as a basis for the procedure method. The most current sampling method is ASTM D-4057-88 (superseding ASTM D-270). It contains the guidance necessary to obtain the ASTM " outlet sample" from the storage tank at the same level as the suction line of the transfer pump.
This sample is equivalent to a transfer line sample used to monitor the EDG fuel oil quality. Failures of the sample thief chains that result in the sampler either remaining in the storage tank fill tube or falling to the bottom of the storage tank have been evaluated and will not prevent the EDGs from performing their function. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. , O
)
Safety Evaluation Summary Report l Page 45 of 57 ;; Safety Evaluation No.: 92-056 i Implementation Document No.: N/A , UFSAR Affected Pages: N/A l System: N/A Title of Change: Storage of Gell Fuel in the , South Half of the Fuel Pool Description of Change: .} This safety evaluation addressed the insertion and storage of 172' new Gell' fuel assemblies into.the boraflex poison' racks in the . south half of the NMP1 spent fuel pool. These assemblies were loaded in the core for Reload 12.- The new' fuel was inserted in ; the south half of the spent fuel pool prior to the reload. The. .i core was completely offloaded for the refueling as well as other- ,' maintenance activities. The south half of the spent fuel pool had sufficient open spots to accommodate the new-fuel as well as the offloaded core. Thus, the racks had a mixed array of exposed bundles and new Gell fuel. Safety Evaluation Summary:. The Gell fuel is designed to be handled and stored in the same I manner as the current fuel assemblies. The Gell reload fuel axial enrichment is less than the design'value for the racks, and- ; the weight of the Gell assembly is'slightly less than the current fuel assembly designs. A criticality analysis of the' spent fuel - pool verifies that the infinite neutron multiplication factor (K-inf) meets the acceptable rack reactivity limits. Due to the j 7 dynamic similarity of the Gell fuel design to previous fuel-designs, rx) significant differences in seismic response are predicted, and the seismic loads are considered to be within'the i design values for the racks. l Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. ; i i
Snfety Evalustion Summary Report Page 46 of 57 O Safety Evaluation No.: 92-057 Implementation Document No.: Simple Design Change SC1-209-91 UFSAR Affected Pages: N/A
- System: Containment Spray / Containment Spray Raw Water Title of Change: Provide Venting Capability to ,
the Containment Spray Heat Exchangers Description of Change: This change provides venting to the shell and tube sides of the containment spray heat exchangers by opening the vent line manually-closed blocking valves and leaving them permanently open except during surveillances and maintenance. Upon system initiation, the exchangers are filled along with the balance of the system piping. Without the vent lines open, the potential exists for noncondensible gases (air) to become trapped within the exchangers, effectively reducing the heat exchange surface ' area and adversely affecting system performance. Safety Evaluation Summary: Each containment spray heat exchanger has two vent lines on the tube side and two vent lines on the shell side. On each side, the two vents combine upstream of a Y-type strainer and a flow limiting orifice. The tube side vents are routed to the floor drain system; the shell side vents are routed to the torus. Leaving the vent lines normally open reinstates the original design configuration (i.e., prior to replacement of heat exchangers in 1986). Potential impacts evaluated included additional flow to the floor drain system, isolation of the common vent line to the torus, and interconnection of heat exchangers via the common shell side vent line. No adverse , impacts on plant safety were identified. l Based on the evaluation performed, it is concluded that this l change does not involve an unreviewed safety question. ; i 1 I i i
Snfety Evaluation Summary Report Page 47 of 57 Safety Evaluation No.: 92-059, Rev. 1 Implementation Document No.: Mod. N1-86-026 UFSAR Affected Pages: III-46 (Figure III-18) System: TSC Emergency Ventilation (System #212) Title of Change: Addition to TSC Ventilation Control Panel Description of Change: This modification installed indication lights for Technical Support Center (TSC) emergency ventilation fan FN-1 and dampers 212-42, 212-31 and 212-87, located in the charcoal filter room, as well as indication lights for normal / emergency power source. A digital timer was also wired to key switch KS-2. The timer runs only when the TSC ventilation system is in the emergency mode of operation. All indication is provided on the TSC ventilation control panel ATPC-1, located in the TSC. Safety Evaluation Summary: This modification provides indication at the TSC ventilation control panel to monitor status of ventilation equipment related to the TSC, without requiring occupants to exit the TSC. Allowing personnel to remain in the TSC during emergency < conditions decreases the possibility of personnel contamination and loss of valuable TSC personnel time. The new equipment / material introduced by this modification only i affects the TSC emergency ventilation system. It is isolated from other areas of NMP1 and NMP2 which could affect the safe shutdown of either plant. i Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. l O l 1
i i Safety Evaluation Summary Report : Page 48 of 57 i Safety Evaluation No.: 92-060 Implementation Document No.: LDCR 1-92-UFS-008 UFSAR Affected Pages: V-11 (Figure V-1) ; VI-44 (Table VI-1) , VI-45 (Table VI-1) , VI-4 6 (Table VI-2), VI-56, VI-58 (Figure VI-22); VII-47 (Figure VII-12); X-9 (Figure X-3) system: Various Title of Change: Miscellaneous UFSAR Discrepancies Description of Change: A review of the UFSAR against current controlled design basis documents uncovered multiple discrepancies, primarily due to a failure to properly update the UFSAR as design changes were made. In all cases analyzed in this safety evaluation, the UFSAR was incorrect and required revision. The reason for this safety evaluation was to assure that none of the proposed changes constitute an unreviewed safety question. Safety Evaluation Summary: Most of the identified UFSAR changes are due to design changes and have been previously evaluated in 10CFR50.59 safety evaluations. Other changes are due to inconsistencies within the UFSAR itself, e.g., one table includes a valve while the corresponding figure omits it. Several of the changes addressed are simply editorial in nature and have no technical significance. One change addressed the piping configuration for the recirculation pump coolers, which was inaccurately represented on-UFSAR Figure VI-22 (page VI-58). This UFSAR correction is made to accurately depict the as-built plant configuration, and has no impact on the functioning of the coolers, the reactor building closed loop cooling system, or the containment isolation valves for the subject penetration. Based on the evaluation performed, it is concluded that these UFSAR changes do not involve an unreviewed safety question. O
SafotyfEvaluntion Summary Report Page 49 of 57 O Safety Evaluation No.: 92-070 Implementation Document No.: N/A . UFSAR Affected Pages: X-62, 10A-13 System: N/A-
' Title of Change: Reduction Fire Brigade Staffing through Partial Combination'of the Unit Fire Brigades 1 Description of Change:
This change reduces the Unit Fire Brigade staffing to a minimum of a Fire Chief and two Fire Fighters. This results in a minimum site response. organization of five Brigade members. , Safety Evaluation Summary: Establishing a Unit staff size of~a Fire Chief and two Fire Fighters achieves the requirements of 10CFR50 Appendix'R and'BTP O CMEB 9.5-1, which requires that at least five Brigade members respond to a fire. Of these five responders, the Fire Chief afd. two members,must be familiar with the effects of fire and fire. suppression activities on plant systems. The. reduction in Unit-dedicated Fire Brigade staffing levels will not result in a lesser response to a fire (either in number of personnel' fighting the fire or in a significant increase in their response-time) or in a-loss of fire watch or' surveillance / maintenance activities. ; Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question and does. not decrease the effectiveness of the fire protection program. t i O
)
Safety Evaluation Summary Report Page 50 of 57
~
O Safety Evaluation No.: 93-003, Rev. 0& 1 Implementation Document No.: Temporary Mod. 93-0004 UFSAR Affected Pages: N/A System: Control Rod Drive Title of Change: Operation with Partially Open 301-133 Valve and Test Equipment Installed Description of Change: During the performance of a surveillance procedure for CRD/HCU 10-31, the withdraw high point vent (301-133) valve would not fully isolate, which prevented disconnecting the test equipment because of the resultant coolant leakage. The test equipment was left installed until the valve could be repaired and/or the line depressurized and the cap replaced. Safety Evaluation Summary: Operation with the high point vent valve not fully closed and the test equipment installed is acceptable. A failure of the test equipment is unlikely since the test equipment pressure and temperature ratings exceed those of the CRD system. If a failure did occur, the resulting inventory loss is well within the makeup capability of the CRD system. Analyses contained in NUREG-0803, which show the offsite doses would be below 10CFR100 limits and that the Reactor Building would be accessible for coolant activity values at the Standard Technical Specification limit, are bounding. Rod 10-31 is operable and can be fully withdrawn. Worst-case analysis indicates sufficient shutdown margin exists even if the rod gets stuck in the full out position. Based on the evaluation performed, it is concluded that this temporary change does not involve an unreviewed safety question. O
i Safety-Evaluation Summary Report , Page 51 of 57 Safety Evaluation No.: 93-009 Implementation Document No.: Procedures GAP-POL-01 Rev. 01, and NEP-POL-300 Rev. 01 3 UFSAR Affected Pages: Section XIII.A . i System: N/A , Title of Change: Restructuring of Nuclear : Support. organization Functions ! in Accordance with Revised Procedures GAP-POL-01 and i NEP-POL-300 Description of Change: t
.i Changes have been made to the corporate level management and technical support. structure of NMPC's Nuclear Division including:
Reorganizing the Licensing and Information Management-Branches of the Nuclear Support Organization back under the Nuclear. j Engineering Organization; reorganizing the Training and Emergency ' Preparedness Branches of the Nuclear Support Organization back j under.the Nuclear Generation Organization; reorganizing the ! O. Procurement Branch of Nuclear Support under the Nuclear Generation Organization; dissolving the Nuclear' Support i Organization and eliminating the position of Vice President Nuclear Support. 1 Safety Evaluation Summary: The new organizational structure provides E for the integrated management of activities that support the operation and maintenance of Nine Mile Point Unit 1 and Unit 2. The Vice President Nuclear Generation will have overall' responsibility for ') the support functions of Training, Emergency-Preparedness, and ; Procurement, in addition to_his present. responsibilities. The ; Vice President Nuclear Engineering will have overall' responsibility for the support functions of Licensing and , Information Management, in addition _to his present ' responsibilities. These changes provide clear corporate management control / direction of onsite and offsite support functions. These changes allow'for dissolving the Nuclear Support Organization and eliminating the position of Vice President Nuclear Support. Based on the analysis performed, the new organizational structure for the support-functions of Licensing, Information Management, Training, Emergency Preparedness, and Procurement does not constitute an unreviewed safety question.
. i
l Safety Evaluation l Summary Report Page 52 of 57 ; Safety Evaluation No.: 93-010 l l Implementation Document No.: Procedure N1-FHP-8A l UFSAR Affected Pages: X-57, X-58 i System: Spent Fuel Pool Title of Change: Fuel Preparation Machine Fuel Submergence Description of Change: This change modifies the minimum water depth over handled fuel from 8 ft. to 7 ft.-3 in. The change is in response to a discrepancy noted during revision to procedure N1-FHP-8A. Further, clarification is added to indicate that the depth refers to the depth of water over active fuel. Safety Evaluation Summary: This modification changes P.he depth of water over fuel handled in the pool. No changes to the depth or level of the pool, fuel handling procedures or methods, or existing accidents or analyses are proposed. This change will have no impact on the safe f operation or shutdown of the plant, nor will it affect the consequences or probability of any accidents or malfunctions of equipment. The only identified change will be an increase in the calculated refuel floor dose rates due to the 9-in. decrease in water depth over the fuel bundle being handled. However, the fuel preparation machine has been in operation previously in this configuration, and measured dose rates during fuel movements have been significantly lower than calculated values. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. O
Safety Evaluation Summary Report Page 53 of 57 p Safety Evaluation No.: 93-016 Implementation Document No.: Procedure NIP-TQS-01 UFSAR Affected Pages: Section XIII.B System: N/A Title of Change: Changes to NIP-TQS-01 to Describe Nine Mile Point Unit 1 and Nine Mile Point Unit II Staff Positions Comparable to ANSI N18.1-1971 and ANSI /ANS-3.1-1978 Description of Change: This change to procedure NIP-TQS-01 added a list that cross-references titles used for staff members at Unit 1 to comparable positions as they appear in ANSI N18.1-1971. Safety Evaluation Summary: This change more clearly delineates staff positions as they are [) \- titled by NMPC and their qualifications as required by ANSI N18.1-1971. The NMPC staff member titles are in some cases different than those listed in ANSI N18.1-1971, but the functional responsibilities are the same as are the qualifications of the staff members holding those positions. The organization provides clear lines of authority to the Plant Manager and clear management control. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. O
Safoty Evaluation Summary Report Page 54 of 57 O Bafety Evaluation No.: 93-031, Rev. O Implementation Document No.: Procedures NEP-POL-300, NIP-IRG-01 and NIP-ECA-04 UFSAR Affected Pages: Section XIII.A System: N/A Title of Change: Nuclear Licensing Organizational Structure and Responsibilities - Revised Procedures NEP-POL-300, NIP-IRG-01 and NIP-ECA-04 Description of Change: The organizational structure of the Nuclear Licensing Organization has changed such that the Manager Licensing reports directly to the Executive Vice President Nuclear. Prior to this change, the Manager Licensing reported directly to the Vice President Nuclear Engineering. In addition, the Manager Licensing has assumed the responsibilities for interfacing with INPO, and implementing the Quality First Program. These responsibilities were transferred from the Manager Executive Staff. The Manager Executive Staff position has been eliminated. Safety Evaluation Summary: The changes made to the organizational structure of the Nuclear Engineering and Nuclear Licensing Organizations continue to provide for the integrated management of activities that support the operation and maintenance of Nine Mile Point Unit 1 and Unit
- 2. These changes also continue to provide clear management control and effective lines of authority and communications ;
between the organizational units involved in the management, operation, and technical support of the operation of Nine Mile Point Unit 1 and Unit 2. ; Based on this evaluation, the organizational structure of the Nuclear Engineering and Nuclear Licensing Organizations continues ! to satisfy the acceptance criteria of SRP 13.1.1, and does not constitute an unreviewed safety question. j l l i i
Safety Evaluation , Summary Report Page 55 of 57 O Safety Evaluation No.: 93-034 - Implementation Document No.: Procedures GAP-POL-01, NEP-POL-300 UFSAR Affected Pages: Section XIII.A System: N/A t Title of Change: Restructuring of Nuclear Generation and Nuclear Engineering Organizations per- ; Revised Procedures GAP-POL-01 and NEP-POL-300 Description of Change: , This change revised the Nuclear Generation organization by expanding the existing Site Services organization to include , Nuclear Security, Technical Services (including Fire Protection, Central Maintenance, Environmental Protection, and Procedures), Procurement, and Construction Services. The Site Services organization is now titled Site Support and is under the () direction of the General Manager Site Support. The Nuclear Engineering organization was revised to remove the Construction Services functions from the responsibilities of ' Manager Engineering (Units 1 and 2) and remove the functional area of Procedure Processing and Publishing. Safety Evaluation Summary: The revised organizational structure provides for the integrated management of common activities to support the operation and maintenance of Nine Mile Point Unit 1 and Unit 2. This organizational change alters the reporting structure of existing positions but does not affect the performance of functions or responsibilities. The new reporting structure provides clear management control and effective lines of authority and communications between the organizational units involved in the management, operation, and technical support for the operation of the facility. This change meets the acceptance criteria described in Branch Technical Position CMEB 9.5.1, Standard Review Plan Chapter 13.1, and Technical Specification 6.2.1. Based on the evaluation performed, it is concluded that this change does not involve an unreviewed safety question. -
Safety Evaluation Summary report Page 56 of 57 O UFSAR TEXT, TABLE AND FIGURE CHANGES (BASED ON PREVIOUSLY REPORTED SAFETY EVALUATIONS) A number of text and figure revisions were made to the UFSAR to include additional changes that are based on previously reported safety evaluations. These changes are identified below. Safety Evaluation No.: 85-035 Previously Reported: NMPC Letter to NRC dated November 15, 1985 Containment spray isolation valve IV 80-35 was initially locked open as a result of the requirements of 10CFR50 Appendix R (reference NMPC letter to the NRC dated September 12, 1983). However, as described in NMPC letter to the NRC dated November 15, 1985, modifications performed during the 1984 refueling outage eliminated this requirement, and motive power has been returned to valve IV 80-35. UFSAR Appendix 10B, Table 1 (page 10B-38) has been updated to reflect this restoration of motive power to IV 80-35, as described in safety Evaluation 85-035. Safety Evaluation No.: 89-013, Rev. 5 Previously Reported: 6/28/91 (as Rev. 3,4) UFSAR Figure VII-3 (page VII-12) has been revised to depict the containment spray system blocking valves 80-40 and 80-45 as normally open, with their operators removed, as described in Safety Evaluation 89-013. This change was previously incorporated into the text of UFSAR Section VII-B.2.0, but the figure revision vas inadvertently overlooked. Safety Evaluation No.: 89-050, Rev. 2 Previously Reported: 6/29/92 , Figure III-14 (page III-26) has been revised to show the revised control room emergency ventilation fan design flow rate of 2875 cfm (110%), as described in Safety Evaluation 89-050, Rev. 2. O
?
Safety Evaluation i Summary Report i Page 57 of 57
'FSAR U TEXT, TABLE AND FIGURE CHANGES l (BASED ON PREVIOUSLY REPORTED. SAFETY EVALUATIONS)
(Cont'9.) ; Safety Evaluation No.: 90-057, Rev. 1 i Previously Reported: 6/28/91 ; i Safety Evaluation 90-057 Rev. 1 described upgrading of various ;
-plant barriers to fire rated as an enhancement to the Fire 'l Protection Program. The Fire Hazards Analysis drawing B-40146-C !
was further revised to indicate that the one-hour rating of the .i slab at elevation.298'-0" in the reactor building is. excluded
'}
above the instrument room at elevation 281'-0". ; Safety Evaluation No.: 91-028 Previously Reported: 6/29/92
- i UFSAR pages VII-15 and XVI-113 have been revised to be consistent :l with the design basis reconstitution suppression chamber heatup l analysis regarding containment spray system capability, as 1 described in Safety Evaluation 91-028. !
l I
-i
- i i
i l
?
I
t O-ENCLOSURE B. TO NMP1L 0768 IDENTIFICATION OF CHANGES, REASONS AND BASES FOR NMPC-QATR-1 (UFSAR APPENDIX B) i O . ENCLOSURE C TO NMP1L 0768 INCORPORATION OF THE FPQAP , INTO THE NMPC-QATR-1 (UFSAR APPENDIX B) l I I O ; I i
O O OL ENCLOSURE B TO NMPIL 0768
-i IDENTIFICATION OF CIIANGES, REASONS AND BASES FOR NMPC-QATR-1 (UFSAR AITENDIX B) b
_m- m_____._m._d--__m&__mmm__ ._,+,.ei+c4u--,.momm ,4
.-.w.r.-
2 .. v--+-,*--%.-e,. e, , , ,,,....w_g... ..,.~.m%,.%,.,_..,%%m._w. r. Mm g. -e.m%, -_.yu,,,,aw-.,.,-,.., . ., _ U , U, s m,..,,,_ , _ ,. , . ,_ ,,,.-g. ,_, ,_ 3
- - . _ = _ . . - . . - . ~
- , . . - -- . n .
O O O ENCLOSURE B - IDENTIFICATION OF CIIANGES, REASONS AND HASES FOR N5fPC-QATR-1 (UFSAR APPENDIX B) Page 1 of 28 - BASIS FOR CONCLUDING T11AT NEW Tile REVISED PROGRAhl UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B NMPC.QATR-1 10CFR50 APPENDIX B AND (N5f PC-QATR-1) REVISION 7 COM5flTMENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF Cll ANGE REASON l'OR CIIANGE APPROVED BY Tile NRC Page ALL Page ALL a. Revised section and page numbering consistent a. Editorial. a. N/A Section ALL Section ALL with conversion of the QATR into UFSAR Appendix B. Section cross-references were revised accordingly,
- b. Defined and consistently applied acronyms for b. Editorial. b. N/A commonly used terms throughout the document; e.g., Quality Assurance Topical Report (QATR), Quality Assurance (QA).
Niagara Mohawk Power Corporation (NMPC), etc.
- c. Corrected typographical errors and modified c. Editorial. c. N/A punctuation and grammar.
- d. Revised department title from " Quality d. To be consistent with the d. The organizat;an title change does Assurance" to " Nuclear Quality Assurance". current organization title, not alter the functions or The title of *Vice President Quality Assurance" responsibilities of the QA (now became "Vice President Nuclear Quality NQA) department.
Assum;ce". Page B-i N/A Revised Table of Contents to reflect new Appendix Editorial. N/A Table of Contents Table of Contents B format.- Page B-ii N/A Added List of Tables consistent with FSAR Editorial. N/A List of Tables N/A - format. Page B.0-1 Page i Section B.O changes: Section B.O reason: Section B.O basis: , Introduction Introduction a. Removed reference to NMPC's Quality a. To more accurately describe a. NMPC's policy regarding Quality Assurance Policy Added reference to the kwatien of NMPC's Assurance matters has not NMPC's Nuclear Division Policy policy regarding Quality changed. It continues to tw and Directives Manualin third paragraph. Assurance matters. embodied in the Nucicar Division Policy and Directives Manual.
- b. Added Fire Protection Program QA b. To incorporate fire protection b. The commitment to BTP APCSB requirements by reference to Branch Technical QA requirements into the 9.5-1. Appendix A, was previously Position (BTP) APCSB 9.5-1, Appendix A. overall QA Program contained in the separate Fire ,
description. Protection Quality Assurance Program (FPQAP), Introduction and Scope section. This administrative change does not alter the commitment to the BTP. a
, _ . , _-_.....<.m -_...._,.-,.-_-_m...-- ,. - .m. -
--m. ~,- . _. . - - --- _. - . ,m. . _ . . _- _ . , . . . . , . - - - -
O O O ENCLOSURE H -IDENTIFICATION OF CIIANGES, REASONS AND HASES FOR NMPC-QATR-1 (UFSAR APPENDIX 11) Page 2 of 28 , BASIS FOR CONCLUDING TIIAT NEW TIIE REVISED PROGRAM
! UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B NMPC-QATR-1 10CFR50 APPENI)lX B AND (NMPC-QATR-1) REVISION 7 COMMITMENTS PREVIOUSLY PAGF>SECTION PAGE/SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY TIIE NRC N/A Page ii Removed QA Policy from the QATR. To climinate a policy Catement NMPC's policy regarding Quality N/A QA Policy that was redundant to that Assurance matters has not changed.
contained within the Nuclear it continues to be embodied in the Division Policy and Directives Nuclear Division Policy and Manual. Directives Manual. I i ,,,-.w-,_ . . . , ., ,- -,,.,,...__w --w,,,.,,, .,, r-...w,-,4v. w ,,,--,.,,--.e,-- -. ww. 4,~., _-- , , - , - , ,r-,. , - - ,, ,. - , - . .. r, ~-w, . , - - . . ,- v. ,,.--r .,
O O O ENCLOSURE B - IDENTIFICATION OF CIIANGES, REASONS AND BASES FOR NMPC-QATR-1 (UFSAR APPENDIX B) Page 3 of 28 - BASIS FOR CONCLUDING TilAT NEW Tile REVISED PROGRAM UFSAR PREVIOUS CONTINUES TO SATISIT APPENDIX B NMPC-QATR-l 10CFR50 APPENDIX B AND (NMPC-QATR-1) REVISION 7 COMMITMENTS PREVIOUSIX PAGE/SECTION PAGFJSECTION IDENTIFICATION OF CllANGE REASON FOR CilANGE APPROVED BY TIIE NRC Page B.1-1 Page 1-1 Section B.1.1 changes: Section B.I.1 reason: Section B.1.1 basis: Section Section a. Changed "such as" to "c.g.." a. Editorial. a. N/A B.1.1 1.1 b. In second paragraph. inserted "and fire b. To incorporate fire protection b. Fire Protection QA requinments protection" following " safety-related' QA requirements into the were previously contained in the overall QA Program separate FPQAP. This description. administrative change does not alter any commitments regarding Fire Protection QA.
- c. Replaced the " Nuclear Support" organizational c. To reflect the current c. The functions and responsibilities unit with " Nuclear Licensing" organization structux. The of the Nuclear Licensing unit Nuclear Surport unit, which remain unchanged. The functions included Licensing, has been and responsibdities of other units dissolved. De Nuclear within Nuclear Support were Licensing unit now reports transferred to Nuclear Generation directly to the Executive Vice or Nuclear Engineering.
President Nuclear.
- d. Deleted " Nuclear Controller" from the d. The Nuclear Controller does d. This text change is consistent with statement regarding quality of work. not perform any activities to the QA Program Responsibility which the QA Program Matrix (UFSAR Appendix B, applies. Table B-1).
B.I.2.1 1.2.1 Section B.I.2.1 changes: Section B.I.2.1 reason: Section B.I.2.1 basis:
- a. Added " Upper Management Nuclear" between a. Editorial, to more clearly a. N/A
*NMPC* and " organization" describe the organization depicted on the refe enced figures.
- b. Changed figure reference from
- Figure 1-1" b. Editorial. He NMPC b. N/A (of the QATR) to " Unit 1 UFSAR Figure organization is already XIII-I and Unit 2 USAR Figure 13.1-la". described in other sections of the Unit Safety Analysis Reports,
- c. Added "for QA Program Elements
- following e. Editorial clarification. c. N/A
" Departmental responsibilitics'.
- d. Revised reference from " Figure 1-2* to " Table d. Editorial. The referenced d. N/A B-1* material continues to be the QA Program Responsibility ,
Matrix (Table B-1).
O O O ENCLOSURE B - IDENTIFICATION OF CIIANGES, REASONS AND IIASES FOR NMPC-QATR-l (UFSAR APPENDIX B) Page 4 of 28 BASIS FOR CONCLUDING TIIAT NEW Tile REVISED PROGRAM UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B NMPC-QATR-1 10CFR50 APPENDIX B AND . (NMPC-QATR-1) REVISION 7 COMMITMENTS PREVIOUSLY PAGFJSECTION PAGE/SECTION IDENTIFICATION OF CilANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Page B.1-2 Page 1-2 Section Section Section B.I.2.1.1 changes: Section B.I.2.1.1 reason: Section B.I.2.1.1 basis: B.I.2.1.1 1.2.2.1, a. Eliminated the " Manager Executive Staff' a. To reflect the current a. Responsibility for the Quality first 1.2.2.I. A. 1.2.2.L A.1 position. organization. Ngram (Q1P) has been transferred to Nuclear Licensing. Otherwise, as shown on the QA Program Responsibility Matrix (Table B-1), the Manager Exceutive Staff had neither primary nor support responsibilities for QA Ngram elements,
- b. Added a paragraph that references Unit I b. To avoid duplication between b. This is an editorial change only.
UFSAR Section Xill.A and Unit 2 USAR UFSAR Appendix B and Responsibilities and duties of key Section 13.1.1 for descriptions of other sections of the Unit nuclear division personnel are responsibilities for the Manager Licensing, Safety Analysis Reports. already described in the Unit Director Nuclear Communications and Public Safety Analysis Reports, and QA Affairs, and Controller Nuclear Division. The Program responsibilities continue new paragrsph also references Unit 1 UFSAR to be depicted on the QA Program Appendix 10A and Unit 2 USAR Appendix 9A Responsibility Matrix (Table B-1). for descriptions of organizational responsibilities regarding the Fire Protection i Program.
- c. Added reference to Table B-1 for QA Program e. Editorial clarification. c. N/A responsibilities of the Nuclear Generation organization unit.
l- d. Deleted description of Plant Managers, Unit i d. To avoid duplication between d. This is an editorial change only. and Unit 2, responsibilities, and added a UFSAR Appendix B and Responsibilities and duties of Plant ' paragraph referencing Unit i UFSAR Section other sections of the Unit Managers are already described in XIII.A and Unit 2 USAR Section 13.1.2. Safety Analysis Reports. the Unit Safety Analysis Reports, and QA Program responsibilities continue to be depicted on the QA - Program Responsibility Matrix (Table B-1).
. . _ _ - _ - , . - _ . , ._..-._..u._ m . - _ -- _ _ _ _ . . _ -.
O O O - ENCLOSURE B -IDENTIFICATION OF CIIANGES, REASONS AND BASES FOR NhlPC-QATR-l (UI5AR APPENDIX B) Page 5 of 28 BASIS FOR CONCLUDING TilAT NEW Tile REVISED PROGRAh! UFSAR PREVIOUS CONTINUES TO SATISIT APPENDIX B NSIPC-QATR-1 10CFR50 APPENDIX B AND (NMPC-QATR-1) REVISION 7 COM511TMENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CilANGE REASON FOR CilANGE APPROVED BY Tile NRC Page B.1-3 Page 1-3 Section Section Section B.I.2.1.1 changes (continued): Section B.1.2.1.1 reason: Section B.1.2.1.1 basis: B.I.2.1.1 (continued) 1.2.2.I.A.2 a. Removed description of responsibilities for the a. To avoid duplication between a. Responsibilities and duties of 1.2.2.I. A.3 Manager Site Services and the Manager UFSAR Appendix B and Nuclear Generation Branch 1.2.2.I.B Nuclear Security. Note that the Manager Site other sections of the Unit Managers are already described in 1.2.2.1.B.1 Services position has been eliminated, and the Safety Analysis Reports, and the Unit Safety Analysis Reports 1.2.2.L B.2 General Manager Site Support position has to reflect the current (see also the change d:scription for 1.2.2.I.B.3 been created. Also, the Traimng, organization. previous QATR Page 1-2). Overall Procurement, and Emergency Preparedness functions performed by the functions have been added to the Nuclear Nuclear Generation branch have Generation branch (previously part of Nuclear not been reduced. QA Program Support). responsibilities of the Nuclear Generation branch continue to be depicted on the QA Program Responsibility Matrix (Table B-1).
- b. Removed descriptions of responsibilities for the b. To avoid duplication between b. Responsibilities and duties of Manager Units 1 and 2 Engineering, Manager UFSAR Appendix B and Nuclear Engineering branch Technology Services, and General Supervisor other sections of the unit managers / supervisors are already Engineering Performance Services. Note that safety analysis reports, and to described in the Unit Safety the Manager Information Management position reflect the current Analysis Reports. Overall has been added to the Nuclear Engineering organization. functions performed by Nuclear branch (previously part of Nuclear Support). A Engineering have not been paragraph was added to reference Unit I reduced. QA Program UFSAR Section XIII.A and Unit 2 USAR responsibilities of the Nuclear Section 13.1.1 for descriptions of the Nuclear Engineering branch continue to be Engineering organization. depicted on the QA Program Responsibility Matrix (Table B-1).
l
- c. Revised reference for " Figure 1-2" to " Table c. Editorial. The referenced c. N/A B-1." item continues to be the QA Program Responsibility Matrix (Table B-1).
o ____ __. _
O O O ENCLOSURE B - IDENTIFICATION OF CIIANGES, REASONS AND 11ASES FOR NMPC-QATR-1 (UFSAR APPENI)lX B) Page 6 of 28 BASIS FOR CONCLUDING TilAT NEW TIIE REVISED PROGRAh! Ul5AR PREVIOUS CONTINUES TO SATISFY APPENI)lX B NMPC-QATR-1 10CFR50 APPENDIX B AND (NMPC-QATR-1) REVISION 7 COMMITMENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY Tile NRC Page B.1-3 Page 14 Section Section 'ection B.I.2.1.1 changes (continued): Section B.I.2.1.1 resson: Section B.I.2.1.1 basis: B. I .2.1.1 (continued) 1.2.2.I.D 4 v Removed description of responsibilities for the a. To avoid duplication between a. This is an editorial change only. 1.2.2.1.C Manager ISEG. UFSAR Appendtx B and Responsibilities of the Manager 1.2.2.I.C.1 other sections of the Unit ISEG ere already described in the 1.2.2.1.C.2 Safety Analysis Reports. Unit Safety Analysis Reports. 1.2.2.1.C.3 1.2.2.1.C.4 b. Removed description of the Nuclear Support b. To reflect the current b. The restructuring of support 1.2.2.1.C.5 organization, which has been climinated. The organization. functions is similar to the Manager Licensing and Director fluman or5tional strw4ure that Resource Development now report directly to existed when Unit 2 was licensed the Executive Vice President Nuclear. The .
- :)ctober 1986. The changes in Training and Emergency Preparedness I 49 responsibility do not functions were transferred to Nuclear j affe. .ne functions and duties of Generation, and the Information Management g e.fected groups. QA Program function was transferred to Nuclear i responsibilities have been Engineering. g appropriately reflected in the QA g Program Responsibility Matrix (Table B-1).
~m.. , , .._,, . .- __ _ _
. . . . - . ..._..._., ., - _ m . . . . - . .
O O O ENCLOSURE B - IDENTIFICATION OF CIIANGES, REASON 5 AND flASES FOR NMPC-QATR-1 (UISAR APPENDIX B) Page 7 of 28 BASIS FOR CONCLUDING TilAT NEW Tile REVISED PROGRAM UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX 11 NMPC-QATR-1 10CFR50 APPENDIX B AND (NMPC-QATR-1) REVISION 7 COMAllTMENTS PREVIOUSIN PAGE/SECTICN PAGE/SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY Tile NRC Page B.1-3 Page I-5 Section B.I.2.1.1 changes (continued): Section B.I.2.1.1 reason: Section B.I.2.1.1 basis: Section Section a. Remove description of responsibilities for the a. To reflect the current a. See item b for Previous QATR B.I.2.1.1 (continued) 1.2.2.1.C.6 Manager Procurement, who was part of the organization. Page 1-4. 1.2.2.I.D Nuclear Support organisation. The 1.2.2.1.D.1 Pmeurement function has been transferred to 1.2.2.l.D.2 Nuclear Generation. 1.2.2.1.D.3 b. Revised reference fmm " Figure 1-2 to " Table b. Editorial. b. N/A 1.2.2.1.D.4 B-I"
- c. Revised QA responsibility description from c. To be more specific c. This change more completely
" Performance of NDE such as ISI and regarding the type of activity. describes the types of examinations Erosion / Corrosion" to " Performing ISI and that may be performed.
Erosion / Corrosion Examinatier:s (Visual and Examination scope and techniques J NDE)." have not been changed.
- d. Changed " Managers Quality Assurance d. To reflect position title d, e A f. Streamlining of the NQA Operations Units I and 11" to " Managers change and reassignment of organization does not change the Quality Assurance Units 1 and 2." The duties and responsibilities functions or responsibilities of responsibilitics of these managers now include within the QA organization. NQA. Adequate resources Nuclear Engineering and Licensing activities, continue to be available to verify which were previously the responsibility of the the overall quality of design.
Manager Quality Assurance Engineering. operation, maintenance, and
- c. Eliminated " Manager Quality Assurance c. To reflect reassignment of modification activities at the Nine Engineering." The responsibilities of this duties and responsibilities Mile Point Nuclear Stations.
position wre divided between the Managers within the QA organization. QA and the new position of Manager Quality Assurance Support.
- f. Added " Manager Quality Assurance Support" f. To reflect position title and removed the descriptions of the Supervisor change and reassignment of Quahty Assurance Audits and the Supervisor duties and responsibilities Quality Assurance Services. Responsibilities of within the QA organimion, the Manager Quality Assurance Support include s!! activities previously described for the Supervisor QA Audits and the Supervisor Quality Services, and also include Fuels and Procurement activities that were praiously the responsibility of the Manager Quality Assurance Engineering.
1 - - ----m, , ~ , - , , - . . - , _ _ _ . - - , , , , . . . . .m, ,w, , , - - <- , ,r-. -r, , .e. - - .. , ,, -- -
O O O ENCLOSURE B - IDENTIFICAllON OF CllANGES, REASONS AND BASES FOR N5fPC-QATR-1 (UFSAR APPENDIX B) Page 8 of 28 BASIS FOR CONCLUDING TilAT ' NEW Tile REVISED PROGRAh! UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B NMPC-QATR-1 10CFR50 APPENDIX B AND (N5fPC-QATR-1) REVISION 7 COMAllTalENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY Tile NRC Page B.I.4 Page 16 Section B.I.2.1.1 changes (continued): Section B.I.2.1.1 reason: Section B.I.2.1.1 basis: Section Section a. Removed description of responsibilities for a. To avoid duplication between a. This is an editorial change only. B.I.2.1.1 (continued) 1.2.2.I . E " Controller Nuclear Division" UFSAR Appendix B and Responsibilities of the Controller 1.2.3. A other sections of the Unit Nuclear Division are already 1.2.3.B Safety Analysis Reports. described in Unit 1 UFSAR Section XIll.A and Unit 2 USAR Section 13.1.1. (See also the change description for Previous QATR Page 1-2.) B.I.2.1.2 Section B.I.2.1.2 changes: Section B.I.2.1.2 reason: Section B.1.2.1.2 basis:
- a. Removed descriptions regarding the V.P. a & b. Editorial. To a & b. These are editorial changes Electric Customer Service, General Manager consolidate organizational only. The functions and Central Region, Director System Electric descriptions in a single responsibilities of the corporate Operations, and Manager Meter and Laboratory location within the Unit support departments have not Facilities. Safety Analysis Reports, changed. Their descriptions have thereby avoidmg duplication. simply been relocated within the
- b. Added brief description of responsibilities of Unit Safety Analysis Reports. QA corporate support departments with Program responsibilities for these reference to Unit 1 UFSAR Section Xill.A.1 departments continue to be and Unit 2 USAR Section 13.1.1. depicted on the QA Program Responsibility Matrix (Table B-1).
- c. Revised reference from " Figure 1-2" to
- Table c. Editorial. The referenced c. N/A B-1." item continues to be the QA Program Responsibility Matrix (Table B-1).
N/A Page 1-7 Removed organization chart (added reference to To avoid duplication between This is an editorial change only. The Unit I and Unit 2 organization charts in Section UFSAR Appendix B and other NMPC organization is already shown B.I.2.1). sections of the Unit Safety on figures contained in Unit 1 Analysis Reports. UFSAR Section Xill.A and Unit 2 USAR Section 13.1. The Nuclear Quality Assurance department organization is described within the text of UFSAR Appendix B.
O O O i ENCLOSURE B - IDENTIFICATION OF CII ANGES, REASONS AND BASES FOR N51PC-QATR-1 (UFSAR APPENDIX B) Page 9 of 28 BASIS FOR CONCLUDING TilAT NEW TIIE REVISED PHOGRAh! UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIXB N51PC-QATR-1 10CFR50 APPENDIX B AND (N5tPC-QATR-1) REVISION 7 CO515tITalENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CII ANGE REASON FOR CIIANGE APPROVED BY TIIE NRC { . Table B-1 PaFe 1-8 Table B-1 changes: Table B-1 reason: Table B-1 basis: Figure 1-2 a. Changed " Figure 1-2" to " Table B-1", a. Editorial. These changes are a. N/A removed page number, and relocated table to consistent with the FSAR the end of Appendix B. style and format.
- b. Revised table header to identify industry b. Editorial. b. N/A standards; i.e., NQA-1 and ANS-3.2.
- c. Added a column to identify Fire Protection QA c. To incorporate Fire c. This is an administrative change requirements from BTP APCSB 9.5-1. Protection QA requirements only. These requirements were Appendix A, and merged Fire Ntection QA into the overall QA Program previously contained in Figure 1-1 responsibilities (from FPQAP Figure 1.1) into description. of the FPQAP. Overall Fire Table B-1. Protection QA Program responsibilities are not reduced.
- d. Added a column to identify Risk Management d. To incorporate Fire d. This is an administrative change (RM) QA Program responsibilities. Protection QA requirements only. The Risk Management into the overall QA Ngram responsibilities for Fire Ntection description. QA activities were previously contained in Figure 1-1 of the FPQAP and have not been altered.
- e. Removed the column for Nuclear Support e. To reflect the current e. QA Ngram responsibilities of (NSP). The Nuclear Support organization has organization. Nuclear Support have been been climinated. transferred to Nuclear Licensing, Nuclear Generation or Nuclear Engineering as appropriate. See also the change description for Previous QATR Page 1-3.
- f. Added a column to identify Nuclear Licensing f. To reflect the current f. This is an administrative change (NL) QA Program responsibilitics. organization. only. Nuclear Licensing's responsibilities were previously grouped under the Nuclear Support column, but are now shown separately.
- g. Removed the column for Nuclear Security g. To depict responsibilities at g. This is an administrative change (NS). a higher level rather than only. QA Ngram responsibilities listing lower-tier of Nuclear Security are now organizational units. included as pa:t of the Nuclear Generation column.
,. . . . _ _ _ _ . _ _ . . _ . _ _ . ,. _ _ . . - .~ --. .- _ .2 . _ . _ . _ . _,_
O O O ENCLOSURE B - IDENTIFICATION OF CIIANGES, REASONS AND HASES FOR NMPC-QATR-1 (UFSAR APPENDIX B) Page 10 of 28 BASIS FOR CONCLUDING TIIAT NEW TIIE REVISED PROGRAM UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B NMPC-QATR-l 10CFR50 APPENDIX B AND (NMPC-QATR-1) REVISION 7 COMMITMENTS PREVIOUSLY PAGFJSECTION PAGE/SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Table B-1 Page 1-8 Table B-1 changes (continued): Table B-1 reason: Table B-1 basis: (continued) Figure 1-2 h. Consolidated the columns for Meter & Test h. To depict responsibilities at h. This is an administrative change (continued) (MT) and Meter & Laboratory (ML) into a a higher level rather than only. The Electric Customer single Electric Customer Service Strategic listing lower-tier Service Strategic Business Unit Business Unit (EC) column. organizational units. (EC) column encompasses the previous MT and ML columns. QA Program responsibilities are not reduced.
- i. Transferred the Fire Protection QA Program i. To incorporate Fire Protection i. This is an administrative change responsibilities of the Meter and Laboratory QA requirements into the only. Fire Protection QA Program
! department from FPQAP Figure 1.1 to Table overall QA Program responsibilities are not reduced. B-l. under the "EC" column. This resuhed in description. l
- the addition of "S" entries in the EC column for Criteria lit, IV, VII, XIV, XV, and XVill.
l
- j. The definition of the "P" designation has been j. To clarify Primary and j. This change recognizes that an expanded by adding " including any Support Support responsibilities. organization with primary Responsibilities" and changed "S", "P" Alleviates the need to list responsibility for a QA Program identifications to reflect new definition. The both a "P" and an "S" in the element may also have an following matrix entries were changed matrix column for a single associated support responsibility.
accordingly for "P,S" to "P": program element. QA Program responsibilities are . not affected by this change. (1) Criterion II. Column NE (2) Criterion VII. Column NE (3) Criterion Xil, Column EC (previously Column MT)
I O O O-ENCLOSURE 11 - IDENTIFICATION OF CilANGES, REASONS AND DASES FOP N5tPC-QATR-l (UFSAR APPENDIX B) Page 11 of 28 BASIS FOR CONCLUDING TIIAT NEW Tile REVISED PROGRAh! UFSAR PREVIOUS CONTINUES TO SATISFT APPENDIX B N5tPC-QATR l 10CFR50 APPENDIX B AND (N5tPC-QATR-1) REVISION 7 C0515tlT3 TENTS PREVIOUSLY PAGE/SECTION PAGF>SECTION IDENTIFICATION OF CllANGE REASON FOR CllANGE APPROVED BY TIIE NRC Table B-1 Page 1-8 Table B.! changes (continued): Table B-1 reason: Table B-1 basis: (continued) Figure 1-2 k. In the Nuclear Generation (NG) column, k. To reDect current k. Overall QA Ngram (continued) changed *S* to "P" for Criterion II, changed organizational structure, responsibilities are not reduced.
"P" to "S" for Criterion XV, and changed "P" responsibilities, and These changes account for the to "S* for Cnterion XVill. single. point accountability. clunination of the NuclearSupport organization and the resulting addition of the Training, Procurement, and Emergency Preparedness functions to Nuclear Generation. The indicated responsibilities are consistent with NhlPC procedural requirements.
- 1. In the Nuclear Engineering (NE) column, I. To redect current 1. Overall QA Ngram added an "S" entry for Criterion XIV and organizational responsibilities. responsibilities are not reduced.
changed "P" to "S" for Criterion XVIII. The indicated responsibilities are consistent with NhlPC procedural requirements.
- m. In the Nuclear Quality Assurance (NQA) m. To reRect current m. Overall QA Program column, changed "R" to "S,R" for Criterion organizational responsibilities. responsibilities are not reduced.
VII, changed *R" to "S.R" for Criterion XV, The indicated responsibilities are and changed "S R" to "P R" for Criterion consistent with NhlPC procedural XVil. requirements.
- n. In the Electric Customer Service Strategic n. To redect current n. Overall QA Program Business Unit (EC) column, changed "S" to organizational responsibilities. responsibilities are not reduced.
"P" for Criterion XVII. ("S" was previously The indicated responsibilities are shown in the blT and blL columns.) consistent with NhlPC procedural requirements.
- - - - _ _ _ - _ _ _ _ - - _ _ _ _ _ _ _ _ - - _ _ __ - ___ _ .-- - _ _ _ _ .-. - - . _ . . - - - _ ~ . - - . . .-. . ..-_ - . - - - - - - - . .
O O. O ENCLOSURE II-IDENTIFICATION OF CllANGFS, REASONS AND BASES FOR NMPC-QATR-l (UFSAR APPENDIX B) Page 12 of 28 BASIS FOR CONCLUDING TIIAT NEW TIIE REVISED PROGRAM UFSAR PREVIOUS CONTINUES TO SATISIT APPENDIX B NMPC-QATR-1 10CFR50 APPENDIX B AND (NMPC-QATR-1) REVISION 7 COMMITMENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF Cil ANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Page B.2-1 Page 2-1 Section Section B.2.1 2.I Section B.2.1 changes: Section B.2.1 reason: Section B.2.1 basis:
- a. Added discussion of the Fire Protection QA a. To incorporate Fire a. This is an administrative change Program and references to tha Unit 1 UFSAR Protection QA requirements only. These requirements were Appendix 10A and Unit 2 USAR Appendix 9A. into the overall QA Program previously contained in FPQAP, description. Revision 3. Sections 1.1 and 2.0.
(See Enclosure C for FPQAP changes.)
- b. Added " fire protection" to activities performed b. To incorporate Fire b. This is an administrative change under the QA Program. Protection QA requirements only, %ese requirements were into the overall QA Program previously contained in FPQAP, description. Revision 3. Section 2.2. (See Enclosure C for FPQAP changes.)
B.2.2.1 2.2.1 Section B.2.2.1 - No changes. B.2.2.2 2.2.2 Section B.2.2.2 changes: Section B.2.2.2 reason: Section B.2.2.2 basis:
- a. Changed
- Appendix C Matrix
- to
- Table B-2." a. Editorial. a. N/A Page B.2-2 Page 2-1 Section Section B.2.2.2 (continued) 2.2.2 (continued) Section B.2.2.2 (continued) - No changes.
Page 2-2 Section B.2.2.3 2.2.3 Section B.2.2.3 changes: Section B.2.2.3 reason: Section B.2.2.3 basis:
- a. His section has been rewritten to reflect that a. To be consistent with current a. NMPC's policy regarding Quality the Nuclear Division Policy and Directives Nucicar Division Policies and Assurance maners has not Manual sets forth the overall program Directives. changed. That policy continues to requirements. be embodied in the Nuclear Division Policy and Directives.
B.2.2.4 2.2.4 Section B.2.2.4 - No changes. B.2.2.5 2.2.5 Section B.2.2.5 - No changes.
O O O ENCLOSURE B - IDENTIFICATION OF CllANGES, REASONS AND BASES FOR NhlPC-QATR-1 (UFSAR APPENDIX B) Page 13 of 28 BASIS FOR CONCLUDING TIIAT, NEW TIIE REVISED PROGRAAI UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B NhlPC-QATR-1 10CFR50 APPENDIX B AND (NhlPC-QATR-1) REVISION 7 COhlhllThlENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY Tile NRC Page B.2-3 Page 2-2 (continued) Section Section B.2.2.5 (continued) 2.2.5 (continued) Section B.2.2.5 (continued) - No changes. B.2.2.6 2.2.6 Section B.2.2.6 - No changes. Page 2-3 Section B.2.2.6 (continued) 2.2.6 (continued) Section B.2.2.6 (continued)- No changes. B.2.2.7 2.2.7 Section B.2.2.7 changes: Section B.2.2.7 reason: Section B.2.2.7 basis:
- a. Added " Fire Protection Program" between "are a. To incorporate Fire a. This is an administrative change applied to* and
- emergency plans." Protection QA requirements only. The requirements were into the overall QA Program previously contained in FPQAP, description. Revision 3, Section 2.0. (See Enclosure C for FPQAP changes.)
- b. Deleted " nuclear
- from between *the" and b. Editorial. b. N/A
" station" B.2.2.8 2.2.8 Section B.2.2.8 - No changes.
Page B.2-4 Page 2-3 (continued) Section Section B.2.2.8 (centinued) 2.2.8 (continued) Section B.2.2.8 (continued) - No changes. B.2.2.9 2.2.9 Section B.2.2.9 - No changes. B.2.2.10 2.2.10 Section B.2.2.10 changes: Section B.2.2.10 reason: Section B.2.2.10 basis:
- a. Changed " Appendix A and B of this Topical a. Editorial, s. N/A Page 2-4 Report" to " Tables B-3 and B-4.*
Section B.2.2.11 2.2.11 Section B.2.2.11 - No changes. b.2.2.12 2.2.12 Section B.2.2.12 - No changes. Page B.2-5 Page 2-4 (continued) Section Section B.2.2.12 (continued) 2.2.12 (continued) Section B.2.2.12 (continued) - No changes. B.2.2.13 2.2.13 Section B.2.2.13 - No changes. B.2.2.14 8 2.2.14 Section B.2.2.14 - No changes. Page 2-5 Sect on B.2.2.14 (continued) 2.2.14 (continued) Section B.2.2.14 (continued) - No changes. . ___ _ _ _._ _. _.. _ _ . _ _ _- _ _ . _ - . - , , _ , , . , _ - . . . . _ _ . . . _ . . . _ _ - ~ . - . . . . - . . -
O O 0 ENCLOSURE B - IDENTIFICATION OF CllANGES, REASONS AND BASES FOR NMPC-QATR-1 (UFSAR APPENDIX B) Page 14 of 28 BASIS FOR CONCLUDING TilAT NEW TIIE REVISED PROGRAM UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B NMPC-QATR-l 10CFR50 APPENDIX B AND (NMPC-QATR-1) REVISION 7 COMMITMENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CIIANGE REASON FOR CilANGE APPROVED BY TIIE NRC . Page B.2-6 Page 2-5 Section Section B.2.2.14 (continued) 2.2.14 (continued) Section B.2.2.14 (continued) - No changes. B.2.2.15 2.2.15 Section B.2.2.15 - No changes. B.2.2.16 2.2.16 Section B.2.2.16 changes: Section B.2.2.16 reason: Section B.2.2.16 basis:
- a. Added "and FSAR sections" atler " Technical a. Editorial, to indicate that the a. N/A Specifications." SRAB is also discussed in the Unit Safety Analysis Reports.
B.2.2.17 2.2.17 Section B.2.2.17 changes: Section B.2.2.17 reason: Section B.2.2.17 basis:
- a. Added " Generation" after "Vice President a. Editorial, to correct position a. N/A Nuclear." title.
- b. Added " sections" after "FSAR" b. Editorial. b. N/A
- c. Changed " Administrative Procedures (APs)" to c. To be consistent with current c. The GAPS have replaced the APs
" Generation Administrative Procedures Nuclear Division procedure and contain the same requirements (GAPS)". titles. regarding SORC responsibilities.
Page 2-6 Section B.2.2.18 2.2.18 Section B.2.2.18 - No changes. Page B.2-7 Page 2-6 Section Section B.2.2.18 (continued) 2.2.18 (continued) Section B.2.2.18 (continued)- No changes. Page B.3-1 Page 3-1 Section Section B.3.1 3.1 Section B.3.1 - No changes. l B.3.2.1 3.2.1 Section B.3.2.1 - No changes, j B.3.2.2 3.2.2 Section B.3.2.2 - No changes. ! B.3.2.3 3.2.3 Section B.3.2.3 - No changes. i B.3.2.4 3.2.4 Section B.3.2.4 - No changes. l B.3.2.5 3.2.5 Section B.3.2.5 - No changes. II l
O O O ENCLOSURE B - IDENTIFICATION OF CllANGES, REASONS AND BASFS FOR N5tPC-QATR-1 (UFSAR APPENDIX H) Page 15 of 28 BASIS FOR CONCLUDING TIIAT NEW TIIE REVISED PROGRAh! UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX 11 NSIPC-QATR-l 10CFR50 APPENDIX B AND (N5lPC-QATR-l) REVISION 7 C051AllThlENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CllANGE REASON FOR CilANGE APPROVED BY TiiE NRC . Page B.3-2 Page 3-1 (continued) Section Section B.3.2.6 3.2.6 Section BJ.2.6 - No changes. Page 3-2 1 Section B J.2.7 3.2.7 Section BJ.2.7 - No changes. B J.2.8 3.2.8 Section B.3.2.8 - No changes. B.3.2.9 3.2.9 Section BJ.2.9 changes: Section B.3.2.9 reason: Section BJ.2.9 basis:
- a. Deleted the word " single" preceding a. Editorial. a. N/A
- individual".
Page BJ-3 Page 3-2 (continued) Section Section BJ.2.10 3.2.10 Section BJ.2.10 - No changes. Page 3-3 Section B J.2.11 3.2.11 Section BJ.2.11 - No changes. B 3.2.12 3.2.12 Section BJ.2.12 - No changes. B J.2.13 3.2.13 Section BJ.2.13 - No changes. Page BJ 4 Page 3-3 (continued) Section Section BJ.2.13 (continued) 3.2.13 (continued) Section BJ.2.13 (continued) - No changes. B J.2.14 3.2.14 Section BJ.2.14 - No changes. BJ.2.15 Section BJ.2.15 changes: Section BJ.2.15 reason: Section BJ.2.15 basis:
- a. Added section describing design control for fire a. To incorporate Fire a. This is an administrative change l
protection systems, equipment, and Protection QA requirements only. These requirements were i components. into the overall QA Program previously contained in FPQAP, description. Revision 3, Section 3.0. (See Enclosure C for FPQAP changes.) L .. .. . . _ . . _ . _ . _ . . . _ . _ . . . . . . . . . .. . . . . . . . . .. . . .
O O O ENCLOSURE B - IDENTIFICATION OF CilANGES, REASONS AND BASES FOR NAllT-QATR-1 (UFSAR APPENUlX B) Page 16 of 28 BASIS FOR CONCLUDING TIIAT NEW TIIE REVISED PROGRAh! UFSAR PREVIOUS CONTINUES TO SATISFY
. APPENDIX B N5fPC-QATR-1 10CFR50 APPENDIX B AND (NSIPC-Q ATR-1) REVISION 7 CON 15tlThlENTS PREVIOUSLY PAGluSECTION PAGE/SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Page B.4-1 Page 4-1 Section Section B.4.1 4.1 Section B.4.1 - No changes B.4.2.1 4.2.1 Section B.4.2.1 - No changes.
B.4.2.2 4.2.2 Section B.4.2.2 - No changes. B.4.2.3 4.2.3 Section B.4.2.3 - No changes. B.4.2.4 4.2.4 Section B 4.2.4 - No changes. B.4.2.5 4.2.5 Section B.4.2 5 - No changes. Page B.4-2 Page 4-2 Section Section B.4.2.5 (continued) 4.2.5 (continued) Section B.4.2.5 - No changes. B.4.2.6 4.2.6 Section B.4.2.6 - No changes. B.4.2.7 4.2.7 Section B.4.2.7 - No changes. B.4.2.8 4.2.8 Section B.4.2.8 - No changes. B.4.2.9 Section B.4.2.9 changes: Section B.4.2.9 reasen: Section B.4.2.9 basis:
- a. Added section describing procurement a. To incorporate Fire a. This is an administrathc change document control requirements as applied to the Protection QA requirements only. Rese requirements were Fire Protection Program. into the overall QA Program previously contained in FPQAP, description. Revision 3. Section 4.0. (See Enclosure C for FPQAP changes.)
Page B.4-3 N/A Section B.4.2.9 (continued) Section B.4.2.9 changes (continued): Section B.4.2.9 reason: Section B.4.2.9 basis:
- a. See above. a. See above. a. See above.
O O O ENCLOSURE B - IDENTIFICATION OF CIIANGES, REASONS AND B ASES FOR NMPC-QATR 1 (UFSAR APPENDIX B) Page 17 of 28 BASIS FOR CONCLUDING TIIAT NEW Tile REVISED PROGRAM UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B NMPC-QATR-1 ~ 10CFR50 APPENDIX B AND (NMPC-QATR-1) REVISION 7 COMMITMENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Page B.5-1 Page 5-1 Section Section B.S.1 5.1 Section B.5.1 changes: Section B.5.1 reason: Section B.5.1 basis:
- a. Changed " App. A" to
- Table B-3* a. Editorial. a. N/A B.5.2.1 5.2.1 Section B.5.2.1 - No changes.
B.5.2.2 5.2.2 Section B.5.2.2 changes: Section B.S.2.2 reason: Section B.5.2.2 basis:
- a. Changed "such as" to "e.g.," (two places). a. Editorial. a. N/A B.5.2.3 5.2.3 Section B.5.2.3 - No changes.
B.5.2.4 5.2.4 Section B.5.2.4 - No changes. B.5.2.5 Section B 5.2.5 changes: Section B.5.2.5 reason: Section B.5.2.5 basis:
- a. Added section addressing instructions, a. To incorporate Fire a. This is an administrative change procedures, and drawings relating to the Fire Protection QA requirements only. These requirements were Protection Pmgram. into the overall QA Program previously contained in FPQAP.
description. Revision 3. Section 5.0. (See Enclosure C for FPQAP changes.) Page B.6-1 Page 6-1 Section Section B.6.1 6.1 Section B.6.1 - No changes. B.6.2.1 6.2.1 Section B.6.2.1 - No changes. B.6.2.2 6.2.2 Section B.6.2.2 - No changes. Page 6-2 Section B.6.2.3 6.2.3 Section B.6.2.3 - No changes. Page B.6-2 Page 6-2 Section Section B.6.2.3 (continued) 6.2.3 (continued) Section B.6.2.3 (continued)- No changes. B.6.2.4 6.2.4 Section B.6.2.4 - No changes. B.6.2.5 6.2.5 Section B.6.2.5 - No changes. B.6.2.6 6.2.6 Section B.6.2.6 - No changes. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . - ___ _. .- ._ ~ . _ . _ . _ .- ~ . . . - - _ . . - . . . . _ _ _ _ _ - . . .. _ . - , _ _. _, --
O O O ENCLOSURE II- IDENTIFICATION OF CilANGES, REASONS AND IIASES FOR NMPC-QATR-1 (UFSAR APPENDIX B) Page 18 of 28 BASIS FOR CONCLUDING TilAT NEW Tile REVISED PROGRAM UFSAR PREVIOUS CONTINUES TO SATISIT APPENDIX B NMPC-QATR-l 10CFR50 APPENDIX B AND (NMPC-QATR*l) REVISION 7 COMMITMENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CIIANGE REASON FOR CilANGE APPROVED BY Tile NRC Page B.7-1 Page 7-1 Section Section B.7.1 7.1 Section B.7.1 - No changes. B.7.2.1 7.2.1 Section B.7.2.1 - No changes.- B.7.2.2 7.2.2 Section B.7.2.2 - No changes. B.7.2.3 7.2.3 Section B.7.2.3 - No changes. Page B.7-2 Page 7-2 Section Section B.7.2.3 (continued) 7.2.3 (continued) Section B.7.2.3 changes (continued): Section B.7.2.3 reason: Section B.7.2.3 basis:
- a. In Item 2.c, deleted "Such that" preceding a. Editorial, a. N/A
" receiving *,
B.7.2.4 7.2.4 Section B.7.2.4 - No changes. B.7.2.5 7.2.5 Section B.7.2.5 - No changes. Page B 7-3 Page 7-2 (continued) Section Section B.7.2.6 7.2.6 Section B.7.2.6 - No changes. B.7.2.7 7.2.7 Section B.7.2.7 - No changes. Page 7-3 Section B.7.2.8 7.2.8 Section B.7.2.8 - No changes. B 7.2.9 7.2.9 Section B.7.2.9 - No changes. B.7.2.10 Section B.7.2.10 changes: Section B.7.2.10 reason: Section B.7.2.10 basis:
- a. Added section describing control of purchased a. To incorporate Fire a. This is an administrative change material, equipment, and services for fire Protection QA requirements only. These requirements were protection items. into the overall QA Program previously contained in FPQAP.
description. Revision 3. Section 6.0. (See Enclosure C for FPQAP changes.) Page B.7-4 N/A Section B.7.2.10 changes (continue 1: Section B.7.2.10 reason: Section B.7.2.10 basis: Section a. See above. a. See above. a. See above. B.7.2.10 (continued)
~. .- . ~ . - . , _ _ . .--
O O O ENCLOSURE B -IDENTIFICATION OF CIIANGES, REASONS AND BASES FOR N31PC-QATR-1 (l.iFSAR APPENDIX B) Page 19 of 28 NEW BASIS FOR CONCLUDING TIIAT UFSAR PREVIOUS TiiE REVISED PROGRAM APPEND X B N31PC4)ATR-1 CONTINUES TO SATISFY (N31PC-QATR-l) REVISION 7 10CFR50 APPENDIX B AND PAGE/SECTION PAGE/SECTION COMMITMENTS PREVIOUSLY IDENTIFICATION OF CIIANGE REASON FOR CliANGE APPROVED BY TIIE NRC Page B.8-1 Page 8-1 Section Section B.8.1 8.1 Section B.8.1 - No changes. B.8.2.1 8.2.1 Section B.8.2.1 - No changes. B.8.2.2 8.2.2 Section B.8.2.2 - No changes. B.8.2.3 8.2.3 Section B.8.2.3 - No changes. B.8.2.4 8.2.4 Section B.8.2.4 - No changes. Page B.91 Page 9-1 Section Section B.9.1 9.1 Section B.9.1 - No changes. B.9.2.1 9.2.1 Section B.9.2.1 - No changes. B.9.2.2 9.2.2 Section B.9.2.2 - No changes. B.9.2.3 9.2.3 ; Section B.9.2.3 - No changes. B.9.2.4 9.2.4 Section B.9.2.4 - No changes. B 9.2.5 9.2,5 Section B.9.2.5 - No changes. Page B.9-2 Page 9-2 Section Section B.9.2.5 (continued) 9.2.5 (continued) B.9.2.6 Section B.9.2.5 (continued) - No changes. 9.2.6 Section B.9.2.6 - No changes. B.9.2.7 9.2.7 Section B.9.2.7 - No changes. B.9.2.8 9.2.8 Section B.9.2.8 - No changes. B.9.2.9 9.2.9 Section B.9.2.9 - No changes. Page B.9-3 Page 9-2 Section Section B.9.2.9 (continued) 9.2.9 (continued) Section B.9.2.9 (continued) - No changes. Page B.10-1 Page 10-1 Section Section B.10.1 10.1 Section B.10.1 - No changes. B.10.2.1 10.2.1 Section B.10.2.1 - No changes. B.10 2.2 10.2.2 Section B.10.2.2 - No changes.
O O- O ENCLOSURE B -IDENTIFICATION OF CIIANGES REASONS AND BASES FOR N5tPC-QATR-1 (UFSAR APPENDIX 11) Page 20 of 28 - BASIS FOR CONCLUDING TilAT NEW TIIE REVISED PROGRASI UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B N5fPC-QATR-1 10CFR50 APPENDIX B AND (N5fPC-QATR-1) REVISION 7 COMMITMENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CIIANGE REASON FOR CilANGF, APPROVED BV Tile NRC Page B.10-2 Page 10-2 Section Section B.10.2.3 10.2.3 Section B.10.2.3 changes: Section B.10.2.3 reason: Section B.10.2.3 basis:
- a. Added "and inspection / surveillance of activities a. To incorporate Fire a. This is an administrative change affecting fire protection." Protection QA requirements enly. These requirements were into the overall QA Program previously contained in FPQAP, description. Revision 3, Section 7.4. (See Enclosure C for FPQAP changes.)
B.10.2.4 10.2.4 Section B.10.2.4 - No changes. B.10.2.5 10.2.5 Section B.10.2.5 - No changes. B.10.2.6 10.2.6 Section B.10.2.6 - No changes. B.10.2.7 10.2.7 Section B.10.2.7 - No changes. B.10.2.8 10.2.8 Section B.10.2.8 - No changes. Page 10--3 Section B.10.2.9 10.2.9 Section B.10.2.9 - No changes. Page B.10-3 Page 10 3 Section Section B.10.2.9 (continued) 10.2.9 (continued) Section B.10.2.9 (continued) - No changes. B.10.2.10 Section B.10.2.10 changes: Section B.10.2.10 reason: Section B.10.2.10 basis:
- a. Added section describing inspection and a. To incorporate Fire a. This is an administrative change surveillance of activities affecting fire Protection QA requirements only. These requirements were protection. into the overall QA Program previously contained in FPQAP, description. Revision 3. Section 7.0. (See Enclosure C for FPQAP changes.)
O O O ENCLOSURE B - IDENTIFICATION OF CllANGES, REASONS AND BASES FOR NMPC-QATR-1 (UFSAR APPENDIX B) Page 21 of 28 BASIS FOR CONCLUDING TilAT NEW TIIE REVISED PROGRAM UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B NMPC-QATR.I 10CFR50 APPENDIX B AND (NMPC-QATR-1) REVISION 7 COMMITMENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CilANGE REASON FOR CllANGE APPROVED BY Tile NRC Page B.ll-1 Page 11-1 Section Section B.ll.1 11.1 Section B.11.1 - No changes. B.11.2.1 11.2.1 Section B.ll.2.1 - No changes. B.11.2.2 11.2.2 Section B.11.2.2 - No changes. Page Il-2 Section B.11.2.3 11.2.3 Section B.11.2.3 - No changes. Page B.11-2 Page 112 Section Section B.11.2.3 (continued) 11.2.3 (continued) Section B.ll.2.3 (continued) - No changes. B.11.2.4 11.2.4 Section B.ll.2.4 - No changes. B.11.2.5 11.2.5 Section B.11.2.5 - No changes. B.11.2.6 Section B.11.2.6 changes: Section B.11.2.6 reason: Section B.11.2.6 basis:
- a. Added section describing tests and test control a.. To incorporate Fire a. This is an administrative change for fire protection items. Protection QA requirements only. These requirements were into the overall QA Pmgram previously cortained in FPQAP, description. Revision 3, Sections 8.1 and 8.2.
(See Enclosure C for FPQAP changes.) Page B.12-1 Page 12-1 Section Section B.12.1 12.1 Section B.12.1 - No changes. B.12.2.1 12.2.1 Section B.12.2.1 - No changes. B.12.2.2 12.2.2 Section B.12.2.2 - No changes. B.12.2.3 12.2.3 Section B.12.2.3 - No changes. B.12.2.4 12.2.4 Section B.12.2.4 - No changes. B.12.2.5 12.2.5 Section B.12.2.5 - No changes. B.12.2.6 12.2.6 Section B.12.2.6 - No changes. B.12.2.7 12.2.7 Section B.12.2.7 - No changes. I
O O O ENCLOSURE D -IDENTIFICATION OF CIIANGES, REASONS AND BASES FOR NSIPC-QATR-1 (UFSAR APPENDIX B) Page 22 of 28 BASIS FOR CONCLUDING TilAT NEW Tile REVISED PROGRAM . UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B NhlPC-QATR-1 10CFR50 APPENDIX B AND (N51PC-QATR-1) REVISION 7 C05thilT51ENTS PREVIOUSLY PAGE/SECTION PAGFJSECTION IDENTIFICATION OF CIIANGE REASON FOR CilANGE APPROVED BY Tile NRC Page B.12-2 Page 12-1 Section Section B.12.2.7 (continued) 12.2.7 (continued) Section B.12.2.7 (continued) - No changes. B.12.2. 8 12.2.8 Section B.12.2.8 - No changes. B.12.2.9 Section B.12.2.9 changes: Section B.12.2.9 reason: Section B.12.2.9 basis:
- a. Added section describing control of measuring a. To incorporate Fire a. This is an administrative change and test equipment as it applies to the Fire Protection QA requirements only. These requirements were Protection Program. into the overall QA Program previously contained in FPQAP, description. Revision 3. Section 10.0. (See Enclosure C for FPQAP changes.)
Page B.13-1 Page 13-1 Section Section B.13.1 13.1 Section B.13.1 - No changes. B.13.2.1 13.2.1 Section B.13.2.1 - No changes. B.13.2.2 13.2.2 Section B.13.2.2 - No changes. Page B.14-1 Page 14-1 Section Section B.14.1 14.1 Section B.14.1 - No changes. B.14.2.1 14.2.1 Section B.14.2.1 - No changes. B.14.2.2 14.2.2 Section B.14.2.2 - No changes. B.14.2.3 14.2.3 Section B.14.2.3 - No changes. B.14.2.4 14.2.4 Section B.14.2.4 - No changes. B.14.2.5 14.2.5 Section B.14.2.5 - No changes. B.14.2.6 14.2.6 Section B.14.2.6 - No changes. B.14.2.7 Section B.14.2.7 changes: Section B.14.2.7 reason: Section B.14.2.7 basis:
- a. Added section describing inspection, test, and a. To incorporate Fire a. This is an administrative change operating status for fire protection items. Protection QA requirements only. These requirements were into the overall QA Program previously contained in FPQAP, description. Revision 3. Section 9.0. (See Enclosure C for FPQAP changes.)
O O O ENCLOSURE B - IDENTIFICATION OF CIIANGES, REASONS AND BASES FOR NhlPC-QATR-I (UFSAR APPENDIX B) Page 23 of 28 BASIS FOR CONCLUDING TIIAT NEW TIIE REVISED PROGRASI UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B N51PC-QATR-1 10CFR50 APPENDIX B AND (NhlPC-QATR-1) REVISION 7 COhlAllT5fENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Page B.151 Page 15-1 Section Section B.15.1 15.1 Section B.15.1 - No changes. B.15.2.1 15.2.1 Section B.15.2.1 - No changes. B.15.2.2 15.2.2 Section B.15.2.2 - No changes. B.15.2.3 15.2.3 Section B.15.2.3 - No changes. B.15.2.4 15.2.4 Section B.15.2.4 - No changes. B.15.2.5 15.2.5 Section B.15.2.5 - No changes. B.15.2.6 15.2.6 Section B.15.2.6 - No enanges. B.15.2.7 15.2.7 Section B.15.2.7 changes: Section B.15.2.7 reason: Section B.15.2.7 basis: -
- a. Added "on an audit / surveillance basis" a. To clarify the method of a. The NQA Department following
- documentation". documentation review. reviews nonconformance documentation on an audit / surveillance basis.
This clarification does not change measures established to control nonconformances. B.15.2.8 15.2.8 Section B.15.2.8 - No changes. B.15.2.9 15.2.9 Section B.15.2.9 - No changes.
O O O ENCLOSURE B . IDENTIFICATION OF CilANGES, REASONS AND BASES FOR NMPC-QATR-1 (UFSAR APPENDIX B) Page 24 of 28 BASIS FOR CONCLUDING TilAT NEW TIIE REVISED PROGRAM UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B NMPC-QATR-1 10CFR50 APPENDIX B AND (NMPC-QATR-1) REVISION 7 COMMITMENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CIIANGE REASON FOR CllANGE APPROVED BY TIIE NRC Page B.15-2 Page 15-1 Section Section B.15.2.9 (continued) 15.2.9 (continued) Section B.15.2.9 (continued) - No changes. D.15.2.10 15.2.10 Section B.15.2.10 - No changes. Page 15-2 Section B.15.2.11 15.2.11 Section B.15.2.11 - No changes. B.15.2.12 15.2.12 Section B.15.2.12 - No changes. B.15.2.13 15.2.13 Section B.15.2.13 changes: Section B.15.2.13 reason: Section B.15.2.13 basis:
- a. Replaced " based on the results/ inspection of a. To be consistent with Section a. This revision is consistent with QA activities
- with " based on quality trends B.15.2.12. Section B.15.212, which states identified" that " quality trends" are identi6cd when evaluating documents that identify nonconformances.
B.15.2.14 15.2.14 Section B.15.2.14 - No changes. B.15.2.15 Section B.15.2.15 changes: Section B.15.2.15 reason: Section B.15.2.15 basis:
- a. Added section describing measures to control a. To incorporate Fire a. This is an administrative change nonconforming fire protection materials, parts, Protection QA requirements only. These requirements were or components. into the overall QA Program previously contained in FPQAP, description. Revision 3, Section i1.2. (See Enclosure C for FPQAP changes.)
Page B.16-1 Page 16-1 Section Section B.16.1 16.1 Section B.16.1 - No changes. B.16.2.1 16.2.1 Section B.16.2.1 - No changes. B.16.2.2 16.2.2 Section B.16.2.2 - No changes. B.16.2.3 16.2.3 Section B.16.2.3 - No changes. B.16.2.4 16.2.4 Section B.16.2.4 - No changes. B.16.2.5 Section B.16.2.5 changes: Section B.16.2.5 reason: Section B.16.2.5 basis:
- a. Added section describing corrective actions for a. To incorporate Fire a. This is an administrative change conditons adverse to fire protection. Protection QA requirements only. These requirements were into the overall QA Program previously contained in FPQAP, descripion. Revision 3, Sections 11.1 and 11.3. (See Enclosure C for FPQAP changes.)
O O O ENCLOSURE B - IDENTIFICATION OF CII ANGES, REASONS AND BASES FOR N5tPC-QATR-1 (UFSAR APPENDIX B) Page 25 of 28 BASIS FOR CONCLUDING TilAT NEW Tile REVISED PROGRAh! UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B NhlPC QATR-1 10CFR50 APPENDIX B AND (NNIPC-QATR-1) REVISION 7 CO515 TIT 5fENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CilANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Page B.17-1 Page 17-1 Section Section B.17.1 17.1 Section B.17.1 - No changes. B.17.2.1 17.2.1 Section B.17.2.1 - No changes. B.17.2.2 17.2.2 Section B.17.2.2 change : Sectk>n B.17.2.2 reason: Section B.17.2.2 basis:
- a. Added item 10, " Records for activities a. To incorporate Fire a. This is an administrative change affecting the Fire Protection Program" and Protection QA requirements only. These requirements were renumbered previous item 10 as item 11. into the overall QA Program previously contained in FPQAP, description.- Revision 3, Section 12.0. (See Enclosure C for FPQAP changes.)
B.17.2.3 17.2.3 Section B.17.2.3 - No changes. Page B.17-2 Page 17-1 (continued) Section Section B.17.2.3 (continued) 17.2.3 (continued) Section B.17.2.3 (continued) - No changes. B.17.2.4 17.2.4 Section B.17.2.4 - No changes. B.17.2.5 17.2.5 Section B.17.2.5 - No changes. Page 17-2 Section B.17.2.6 17.2.6 Section B.17.2.6 - No changes. B.17.2.7 17.2.7 Section B.17.2.7 - No changes. B.17.2.8 17.2.8 Section B.17.2.8 - No changes. -- . - - , , . _ _ - ,e-:,, n. . -e. - - - - , - - - - - . y we . .s,, y --e v - v,,.-, -:----= y ,i,--. ,-.,4.-w w . . m e + .- . ,.-r - -- y
O O O ENCLOSURE B - IDENTIFICATION OF CilANGES, REASONS AND BASES FOR NMPC-QATR-1 (UFSAR APPENDIX B) Page 26 of 28 BASIS FOR CONCLUDING TilAT NEW Tile REVISED PROGRAM UFSAR PREVIOUS CONTINUES TO SATISFY APPENDIX B NMPC-QATR-1 10CFR50 APPENDIX B AND (NMPC-QATR-l) REVISION 7 COMMITMENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CII ANGE REASON FOR CIIANGE APPROVED BY Tile NRC Page B.18-1 Page 18-1 Section Section B.18.1 18.1 Section B.18.1 - No changes. B.18.2.1 18.2.1 Section B.18.2.1 - No changes. B.18.2.2 18.2.2 Section B.IB.2.2 - No changes. B.18.2.3 18.2.3 Section B.18.2.3 - No changes. B.18.2.4 18.2.4 Section B.18.2.4 - No changes. B.18.2.5 18.2.5 Section B.18.2.5 - No changes. Page 18-2 Section B.18.2.6 18.2.6 Section B.18.2.6 - No changes. Page B.18-2 Page 18-2 Section Section B.18.2.6 (continued) 18.2.6 (continued) Section B.18.2.6 (continued) - No changes. B.18.2.7 18.2.7 Section B.18.2.7 - No changes. B.lB.2.8 18.2.8 Section B.18.2.8 - No changes. B.18.2.9 18.2.9 Section B.18.2.9 - No changes. B.18.2.10 18.2.10 Section B.18.2.10 - No changes. B.18.2.11 18.2.11 Section B.I8.2.11 - No changes. B.18.2.12 Section B.18.2.12 changes: Section B.18.2.12 reason: Section B.18.2.12 basis:
- a. Added section describing QA audits cenducted a. To incorporate Fire a. This is an administrative change for the Fire Protection Program. Protection QA requirements - only. These requirements were into the overall QA Program previously contained in FPQAP.
description. Revision 3, Section 13.0. (See Enclosure C for FPQAP changes.) Page B.lB-3 N/A Section B.18.2.12 (continued) Section B.18.2.12 changes (continued): Section B.18.2.12 reason: Section B.18.2.12 basis:
- a. See above. a. See above. a. See above.
O O O ENCLOSURE B - IDENTIFICATION OF CIIANGES, REASONS AND BASES FOR NMPC-QATR-1 (UFSAR APPENDIX B) Page 27 of 28 BASIS FOR CONCLUDING TilAT NEW Tile REVISED PROGRAM UFSAR PREVIOUS CONTINUES TO SATISIT APPENDIX B NMPC-QATR-1 10CFR50 APPENDIX B AND (NMPC-QATR-1) REVISION 7 COMMITMENTS PREVIOUSLY PAGE/SECTION PAGE/SECTION IDENTIFICATION OF CII ANGE REASON FOR CilANGE APPROVED BY Tile NRC Table B-3 Appendix A Table B-3 changes: Table B-3 reason: Table B-3 basis: Sheet 1 of 1 Page A-1 a. Changed titic from " Appendix A* to a. Editorial. a. N/A Page A-2 " Table B-3"
- b. Changed format. b. Editorial. b. N/A
- c. Within the footnote, changed " Appendix A" to c. Editorial. c. N/A "this Table" and " Appendix B" to " Table B4".
- d. Changed items in the Revision /Date column to d. Editorial. d. N/A show the revision number first, followed by the date (consistent with the column title).
- c. Added item i1, BTP APCSB 9.5-1, e. To incorporate Fire c. This is an administrative change Appendix A. Protection QA requirements only. The commitment to BTP into the overall QA Program APCSB 9.5.1, Appendix A, was description. previously contained in FPQAP, Revision 3, Section 2.1. The commitment to the BTP has not been altered.
Table B4 Appendix B Table B-4 changes: Table B4 reason: Table B4 basis: Sheet I of 8 Page B-1 a. Changed format. a. Editorial. a. N/A Sheet 2 of 8 Page B-2 b. Changed Title from " Appendix B, b. Editorial. b. N/A Sheet 3 of 8 Page B-3 Interpretations and Exceptions of Appendix A Sheet 4 of 8 Page B4 Documents", to " Table B4, Interpretations Sheet 5 of 8 Page B-5 and Exceptions of Table B-3 Documents." Sheet 6 of 8 Page B4 c. Changed references to Appendix A and c. Editorial. c. N/A Sheet 7 of 8 Page B-7 Appendix B to Table B-3 and B4, respectively. Sheet 8 of 8 Page B-8 d. In item 5.d. revised reference from " Question d. Editorial. Heavy Loads d. N/A Page B-9 and Answer section" to " Appendix 9C" Analysis was incorporated Pag- B-10 into Appendix 9C of the Unit Page B-11 2 USAR.
O O O ENCLOSURE D -IDEN11FICATION OF CIIANGES, REASONS AND DASES FOR NMPC-QATR-1 (UFSAR APPENDIX B) Page 28 cf 28 BASIS FOR CONCLUDING TIIAT NEW Tile REVISED PROGRAM UFSAR FREVIOUS CONTINUES TO SATI5FY APPENDIX B NMPC-QATR-1 10CFR50 APPENDIX B AND (NMPC-QATR-1) REVISION 7 COMMITMENTS PREVIOUSLY PAGE/SECTION PAGFJSECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Table B-2 Arpendix C Table B-2 changes: Table B-2 reason: Table B-2 basis: Sheet 1 of 1 Page C-1 a. Changed " Appendix C* to ' Table B-2", s. Editorial. a. N/A
- b. Changed format. b. Editorial. b. N/A
- c. Revised the list of QAPs and NIPS. c. To be consistent with current c. The revisions to the nfe:enced procedure numbers, procedun: numbers do not affect implementation of any requirements of the Quality Assurance Program.
i - - - , - . , - , - , - , - - e ,~, ,-~.-.,e -- , - . - - - , - , - - e ,, ,~- .n, - - ,--l--u--,'s-.-,m, > - , , , ---.-_u- - - - ._ , ,
'O O O-ENCLOSURE C TO NMP1L 0768 s
INCORPORATION OF TIIE FPQAP INTO TIIE NMPC-QATR-1 (UFSAR APPENDIX B) _. _.___ ___.____ _ _ . _ . . . _ . . _ _ . . _ _ . _ , _ _ . _ _ . . . . _ . _ . . . _ . . _ _ . . . . .._.._...-_.___._..___._._.___m
O O O ENCLOSURE C - INCORPORATION OF TIIE FINAP INTO Tile NMPC-QATR-1 (UFSAR APPENDIX B) Page 1 of 21 De following table pmvides the identification, reason, and basis for changes made to the NMPC-FPQAP since the submittal of Revisions 2 and 3. The table also provides a cross-reference beturen FPQAP Revision 2, Revision 3, and the new Unit I FSAR (Updated) Appendix B, as an aid to understanding the manner in which the program descriptions were combined. B ASIS FOR CONCLUDING TilAT NEW Tile REVISED PROGRAhl FPQAP FPQAP UFSAR CONTINUES TO SATISFY REY.2 REV.3 APP.B BTP 9.5-1 AND PAGE! PAGFJ PAGE/ COMMITMENTS FREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CilANGE REASON FOR CilANGE APPROVED BY TIIE NRC Page i Page 2 Page B-1 Eliminated NMPC-FPQAP Table of Contents. Editorial. The Fire Pretection N/A Quality Assurance Program has ; been combined with applicable sections of the NMPC-QATR-1 , (UFSAR Appendix B). Pageii Page 3 Page B.0-1 Eliminated Introduction and Scope Section of the To combine the FPQAP with the implementation of fire protection quality FDQAP by including Fire Protection Program overall Quality Assurance assurance requirements is not affected by Q tality Assurance requirements into the Program description. the combined program description, applicable sections of NMPC-QATR-1 (UFSAR Appendix B). Pageiii Psge 4 Page B.0-1 Removed QA Policy from the NMPC-FPQAP To climinate a policy statement NMPC's policy regarding Quality Qustity Section and NMPC-QATR-1. Added reference to that was redundant to that Assurance matters has not changed. It Assurance B.O Nuclear Division Policy and Directives Manual contained within the Nuclear continues to be embodied in the Nuclear Policy in UFSAR Appendix B, Section B.O. Division Policy and Directives Division Policy and Directives Wnual. Manual. Page iiii Page 5 thru 8 N/A Removed Summary of Changes from FPQAP. Editorial. He identification, N/A andv reason, and basis for each change are provided in this enclosure.
- -. .. -- , + -c - ,, , , ,,w- e,- - - - v,+ , , , , , - - , , m-. -,,,,wm w ,-,,ca- e -e < -ee- .-+ ,, . - , , < - -
- O O O ENCLOSURE C - INCORPORATION OF TIIE FlyAP INTO TIIE N31PC-QATR-1 (UFSAR APPENDIX B) Page 2 of 21 BASIS FOR CONCLUDING TilAT NEW Tile REVISED PROGRAM FPQAP FINAP UFSAR CONTINUES TO SATISFY REY.2 REY.3 APP.B BTP 9.5-1 AND PAGE/ PAGE/ PAGE/ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY Tile NRC Page1 Page 9 Page B.1-1 Change: Reason: Basis:
Section Section Section a. Revision 3 changed Section title fmm a. Editorial. To more correctly a. N/A 1.0 1.0 (Revised) B.O
- Organization" to " Overview". describe the purpose of the 1.1 1.1 (Revised) B.I.1 section.
Page B.2-1 Section b. Revision 3 added " Fire Extinguishment" and b. Editorial. Expanded b. N/A B.2.1 ' Smoke Removal" and replaced program definition to include
- housekeeping" with " Control of additionalinformation from Combustibles and Ignition Sources" Attachment 2 of FPQAP Revision 2.
- c. The Revision 3 changes and FPQAP Section e. Editorial. By combining the c. N/A 1.1 have been superseded by Sections B.I and FPQAP with the overall QA B.2. Section B.l.1 was revised to include Program description, the fire protection activities. Sections Revision 3 changes to B.I.2.1.1 and B.2.1 have been revised to Sections 1.0 and 1.1 no reference Unit I FSAR (Updated) Appendix longer apply. The combined 10A and Unit 2 USAR Appendix 9A for a QA Program description description of the Fire Protection Program. clim* mates redundant information by referencing other sections of the Unit Safety Analysis Reports.
4
-- % .-n. . , _ ,mn. - . . . , . , - w - + - - v--w -
1.--w w v. r .-+ .. , ,_s_, .. -v
O O O ENCLOSURE C - INCORPORATION OF TIIE FPQAP INTO TIIE NMPC-QATR-1 (UFSAR APPENDIX B) Page 3 of 21 BASIS FOR CONCLUDING TilAT NEW Tile REVISED PROGRA31 FINAP FPQAP UFSAR CONTINUES TO SATISFY REV.2 REY.3 APP.B BTP 9.5-1 AND PAGFJ PAGE/ PAGE/ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CllANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Page 1 Page 9 Page B.1-2 Change: Reason: Basis: Section Section Section a. Revision 3 revised section title from a. Editorial. a. N/A 1.2 1.2 B.I.2.1.1 *1mplementation* to " Organization".
- b. Revision 3 removed the description of b. Editorial. To reflect only b. N/A Executive Vice President-Nuclear the main administrative responsibilities, structure of NMPC's fire protecti(m program.
- c. The Revision 3 changes and FPQAP Section c. NMPC's current c. N/A 1.2 have been superseded by Section Organizational structure.
B.I.2.1.1. including the responsibilities of the Executive Vice President-Nuclear, is described in Section B. I .2.1.1. Page 1 Page 9 Page B.1-2 Change: Reason: . Basis: Section Section Section a. Revision 3 changed title from
- General a. To reflect current title. a. The title change is administrative and 1.2.A 1.2.1 B.I.2.1.1 Superintendent-Nuclear Generation" to "Vice provides the position with greater (Revised) President Nuclear Generation". authority.
- b. The Revision 3 changes and Section 1.2.1 b. FPQAP Section 1.2.1 has b. This change was previously addressed hsve been superseded by Section B.I.2.1.1. been combined with QATR in NMPC-QATR-1, Revision 6.
Section 1.2.2. The title change was previously identified in QATR. Revision 6 Section 1.2.2, which is now Section B.I.2.1.1.
O O O ENCLOSURE C - INCORPORATION OF TIIE FPQAP INTO TIIE N31PC-QATR-1 (UISAR APPENDIX B) Page 4 of 21 BASIS FOR CONCLUDING TilAT NEW TIIE REVISED PROGRA51 FPQAP FPQAP UFSAR CONTINUES TV SATISFY REY.2 REV.3 APP.B BTP 9.5-1 AND PAGE/ PAGFJ PAGFJ C05thitThlENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Page 1 Page 10 Page B.1-2 Change: Reason: Basis: Section Section a. Revision 3 changed the title of " Station a. To reneet title change and a. The title change is administrative in 1.2. A.1 1.2.1.1 Superintendents, Unit I and Unit 2" to
- Plant to reDect only the main nature and does not change the 1.2. A.2 (Revised) hianagers" and included the responsibilities of administrative structure of functions or responsibilities of the -
1.2. A.3 the Site Superintendent hiaintenance, NhlPC's Fire Protection position. The described responsibilities Page 2 Technical Superintendent, Superintendent Program. Fire protection reflect single ,* int accountability and Section Training, Site Fire Program Coordinator, implementation do not aher Fiw Protection QA 1.2.A.4 Supervisor Operations Support, and Unit responsibilities are delineated Program elements. 1.2. A.5 Supervisors Fire Protection under the Plant in implementing procedures. 1.2.A.6 hianagers to whom they report. Page 3 Section b. The Revision 3 change and FPQAP Section b. Editorial. Position title b. N/A 1.2. A .6 1.2.1.1 have been superseded by Section changes were previously 1.2. A.7 B. I .2.1.1. identified in QATR, Revision 6, Section 1.2.2, which is now Section B.1.2.1.1. Organizational responsibilities for the Fire Protection Program are describedin the Unit Safety Analysis Reports which are referenced in Section B.I.2.1.1. _______m-m_. - m ._ - ~ - - . _ . _ . . . _ _ , ,, .# e e- - - - - , . - . . , 4m. -, .y , , , , , , . , . .
O O O ENCLOSURE C - INCORPORATION OF TIIE FPQAP INTO TIIE NMPC4ATR-I (UFSAR APPENDIX B) Page 5 cf 21 BASIS FOR CONCLUDING TilAT NEW TIIE REVISED PROGRAM FPQAP FPQAP UFSAR CONTINUES TO SATISFY REY.2 REV.3 APP.B BTP 9.5-1 AND
- PAGE/ PAGE/ PAGE/ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY Tile NRC Page 4 Page 10 Page B.1-2 Change
- Reason: Basis:
Section 3ection Section a. Revision 3 changed the title of "Vice a. To reflect that Nuclear a. The change to the organizational 1.2.B 1.2.2 B.I.2.1.1 President Nuclear Engin-cring and Licensing" Licensing no longer reports structure does not affect functions or Page 5 to Vice President Nuclear Engineering". to the Vice President Nuclear duties related to Fire Protection QA Section revised responsioility descripion and Engineering, and to Program elements. The revised 1.2.B .1 climinated the description of responsit-ilities reflect only the main responsibility description only reflects 1.2.B.2 for the Fire Protection Engineer and Manager administrative structure of single-point accountability; it does not Nucicar Consulting Services. the Fire Protection Program. affect the functions or duties oi subordinate positions.
- b. The Revision 3 change and FPQAP Section b. Editorial. Position title b. N/A 1.2.2 have been superseded by Section changes were previously B. I .2.1.1 identified in QATR. Revision
- 6. Section 1.2.2, which is now Section B.I.2.1.1.
Organizational responsibilities for the Fire Protection Program are described in the Unit Safety Analysis Reports which are now referenced in Section B.I.2.1.1. Page 5 & 6 Page 10 Page B.1-2 Change: Reason: Basis: Section Section Section a. Revision 3 provided a more general a. Editorial. To provide a a. N/A 1.2.B.2.a 1.2.2.1 B.I.2.1.1 description of the Fire Protection Program more consolidated descriptr.r. Manager's responsibilities. of responsibilitics.
- b. The Revision 3 change and FPQAP Section b. Editorial. The b. N/A 1.2.2.1 have been superseded by Section responsibilities of the B.I.2.1.1. Fire Protection Program Manager are described in the Unit Safety Analysis Reports which are referenced in Section B.I.2.1.1.
__ . _ _ _ _ _ . . _ _ _ . . . _ _ - _ . . - . _ _ . __.c . _ _ _ _2. . . . _ . _ __ _ __ ~ __u _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
O O O ENCLOSURE C -INCORPORATION OF TIIE FPQAP INTO Tile NhlPC-QATR-1 (UFSAR APPENDIX B) Page 6 of 21 BASIS FOR CONCLUDING TrlAT NEW Tile REVISED PROGRAM FPQAP FPQAP UFSAR CONTINUES TO SATISFY REY.2 REY.3 APP.B BTP 9.5-1 AND PAGE/ PAGE/ PAGFJ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY Tile NRC Page 6 Page 10 Page B.1-3 Change: Reason: Basis: Section Section Section a. Revision 3 changed the title of "Vice a. To reflect current title. a. This change is administrative in nature. 1.2.C 1.2.3 B.l.2.1.1 President-Quality Assurance" to "Vice The responsibilities of the positian have Page 7 President Nuclear Quality Assurance". not changed. Section 1.2.C.1 b. Revision 3 revised the description of the Vice b. The Vice President's b. The revised responsibility description 1.2.C.2 President Nuclear Quality Assurance responsibilities we.c only reflects single-point accountability; 1.2.C.3 responsibilities and eliminated responsit, rephrased for clarity. it does not affret the functions or duties descriptions for subordinate positions. Subordinate responsibilities of subonlinate positions. were removed to reficct single-point accountability,
- c. The Revision 3 changes and FPQAP Section c. Editorial. Nuclear Quality c.. N/A 1.2.3 have been superseded by Section Assurance organizational B.I.2.1.1. responsibilities are descrild in Section B.I.2.1.1.
Organizational responsibtiities for the Fire Protection Program are described in the Unit Safety Analysis Reports which are referenced in Section B.I.2.1.1. N/A Page 10 Page B.1-3 Change: Reason: Basis: Section Section a. Revision 3 added Vice President Nuclear a. To describe a revised a. The ch.mge in reporting structure does 1.2.4 B.I.2.1.1 Support responsibilities. Nucle ** isivision not affect the functions and duties of the organizational structure. affected groups.
- b. The Revision 3 change and FPQAP Section b. To reflect the elimination of b. The change in reporting structure does 1.2.4 have been superseded by Section the Nuclear Support not affect the functions and duties of the B.I.2.1.1. organization. affected groups.
.. _ . - . ._ _ _ _ . . _ . . ~ _ _ __ _. . . . - . _ _.. . . _ . _ . . _ _ . . _
O O O ENCLOSURE C - INCORPORATION OF Tile ITQAP INTO Tile NMPC-QATR-1 (UFSAR APPENDIX B) Page 7 of 21 4 BASIS FOR CONCLUDING TIIAT NEW TIIE REVISED PROGRAM i FPQAP ITQAP UFSAR CONTINUES TO SATISFY REY.2 REV.3 APP.B BTP 9.5-1 AND PAGE/ PAGE/ PAGE/ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY TIIE NRC N/A Page 10 Page B.18-2 Change: Reason: Basis: Section Section a. Revision 3 added Section 1.2.5 to describe a. Editorial. To describe the a. N/A 1.2.5 B.18.2.3 Safety Review and Audit Board (SRAB) responsibilities of the SRAB B.18.2.12 responsibilities. as they relate to Fire Prutection QA Program elements.
- b. He Revision 3 change and Section 1.2.4 b. Editorial. SRAB b. N/A have been superseded by Sections B.18.2.3 responsibilities are described and B.18.2.12. in Section B.18.2.3 and identified in Section B.18.2.12.
Page 7 Page 10 Page B.1-4 Change: Reason: Basis: Section Section Section a. No change in Revision 3. a. N/A a. N/A 1.2.D 1.2.7 B.I.2.1.2
- b. FPQAP Section 1.2.7 has been superseded b. Editorial. To consolidate the b. N/A by Section D.I.2.1.2. His section was added description of nonnuclear to describe overall corporate support corporate support responsibilitics and provides a reference to responsibilities into a Unit 1 UFSAR Section Ill.A.1 and Unit 2 separate section USAR Section 13.1.1 for a further description.
, -=n , ,. .- , - , - , _- , , , , .my--w y -, y ,-,,- -
,, y, -
w% - we+r ,. v-,-.y - , , , -e-.- +-rm r, ,-, , - - wy , , . -.,,
O O O-ENCLOSURE C - INCORPORATION OF Tile FPQAP INTO TIIE NMPC-QATR-1 (UFSAR APPENDIX B) Page 8 of 21 BASIS FOR CONCLUDING TilAT NEW TIIE REVISED PROGRAM FPQAP FPQAP UFSAR CONTINUES TO SATISFY REV.2 REY.3 APP.B BTP 9.5-1 AND PAGF1 PAGE/ PAGE/ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CllANGE REASON FOR CllANGE APPROVED BY Tile NRC Page 8 Page N/A Page B.1-2 Change: Reason: Basis: Section Section Section a. Revision 3 re.n sved the " Manager System a. This position is a corporate a. All QA Program responsibilities 1.2.E 1.2 B.I.2.1.1 Purchasing
- postion and responsibilities position. Purchasing regarding procurement have been description. functions are now performed assumed by the Nuclear Division.
within the Nuclear Division.
- b. The Revision 3 change has been superseded b. Editorial. This change was b. N/A by Section B.I.2.1.1. previously identified in QATR, Revision 6. Section 1.2.2. Section B.I.2.1.1 has been revised to provide a reference to the Unit Safety -
Analysis Rerorts, which describe procurement responsibilities. Page 8 Page N/A Page B.1-2 Change: Reason: Basis: Section Section Section a. Revision 3 removed the Program Director- a. This position is a corporate a. All QA Program responsibilities 1.2.F 1.2 B.I.2.1.1 Nuclear Materials Management position and position. Materials regarding Materials Management have responsibilities description. Management functions were been assumed by the Nuclear Division. combined with Purchasing functions which are now performed within the Nuclear Division.
- b. The Revision 3 change has been superseded b. Editorial. This change was b. N/A by Section B.I.2.1.1. previously identified in QATR, Revision 6, Section 1.2.2. Section B.I.2.1.1 has been revised to provide a reference to the Unit Safety Analysis Reports, which describe Materials Management responsibilities.
I
O O O ENCLOSURE C - INCORPORATION OF TIIE FPQAP INTO TIIE NhlPC-QATR-1 (UFSAR APPENDIX B) Page 9 of 21 BASIS FOR CONCLUDING TIIAT NEW TIIE REVISED PROGRAM FPQAP FPQAP UFSAR CONTINUES TO SATISFY REY.2 REY.3 APP.B BTP 9.5-1 AND PAGFJ PAGFJ PAGE/ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Page 5 Page 10 Page B.1-4 Change: Reason: Basis: Section Section Section a. Revision 3 added the responsibilities of the a. Editorial. To be consistent a. N/A 1.2 G 1.2.6 B.I.2.1.2 Supervisor Standards Laboratory. with the responsibilities described in the QATR.
- b. The Revision 3 change and Section 1.2.6 b. Editorial. "Ihe b. N/A have been superseded by Section 1.2.1.2. responsibilities were previously described in the QATR. Section B.I.2.1.1 has been revised to provide a reference to the Unit Safety Analysis Reports which describes these responsibilities.
Page 8 Page N/A Page B.1-2 Change: Reason: Basis: Section Section Section a. Revision 3 removed Supervisors' a. To reflect only the main a. The revised responsibility description 1.2.11 1.2 B.I.2.1.1 responsibilities. administrative structure of reflects single-point accountability; it the fire protection program. does not affect the functions, duties, or responsibilities of supervisory positions.
- b. The Revision 3 change has been superseded b. Editorial. Section B.I.2.1.1 b. N/A by Section B.I.2.1.1. has been revised to pivvide a reference to the Unit Safety Analysis Reports which describe Fire Protection Program responsibilities.
- co- ... . . , .v-. . . - - , , . . - - m- , - - . . . ~.r . . -. -, , - , - . , . . - - .,s, .---.4 . - . .
O O O ENCLOSURE C - INCORPORATION OF TIIE FPQAP INTO TIIE NMPC-QATR-1 (UFSAR APPENDIX B) Page 10 of 21 4 BASIS FOR CONCLUDING TIIAT NEW TIIE REVISED PROGRAh! FPQAP FPQAP UFSAR CONTINUES TO SATISFY REY.2 REV.3 APP.B BTP 9.5-1 AND PAGE/ PAGFJ PAGE/ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CilANGE REASON FOR CilANGE APPROVED BY TIIE NRC Page 9 Page 11 Table B-1 Change: Reason: Basis: Figure 1.1 Figure 1.1 a. Revision 3 removed corporate Purchasing and a. To reflect the transfer of a. The Nuclear Division has assumed all Materials Management Departments, and Purchasing functions from QA Program responsibilities reganting revised FPQAP Section numbers, corporate headquarters to the Purchasing for the Fire Protection
+
Nuclear Division. Ngram.
- b. The Revision 3 changes a.. ' Figure 1.1 have b. Editorial. Figure 1.1 has b. Table B-1 depicts organizational been superseded by revised Table F i. been incorporated into Table responsibility for implementing the QA B-1. QATR Figure 1.1 was Program for fire protection. (See previously updated to reflect Enclosure B for Table B-1 changes.)
this change. Page 10 Page 12 Page B.2-1 Change: Reason: Basis: Section Section Section a. Revision 3 deleted *uses a graded approach a. Editorial. To clarify that the a. NMPC has applied, and continues to 2.1 2.1 B.2.1 to apply appropriate criteria from 10CFR50, QA Program for fire apply, the criteria from BTP 9.5-1 in Appendix B to Fire Protection systems or protection applies the QA Program for fire protection. activities" and added " applies the criteria the criteria from Branch from Branch Technical Position (BTP) 9.5-1. Technical Position (BTP) 9.5-1 to fire protection systems and activities.
- b. The Revision 3 change and the FPQAP b. To include the QA Program b. The QA Ngram elements for fire Section 2.1 have been superseded by description for fire protection protection are not altered by combining including Branch Technical Position (BTP) as part of the overall plant the FPQAP with the QATR.
9.51 in Section B.0, and referring to Unit 1 . QA Program description. l- UFSAR Appendix 10A and Unit 2 USAR Appendix 9A in Sections B.2.1. l l l l i i l l _ _- . . = _. _-. - - . _ . . . - - . - . . .- .- -- . -. ..
O O O ENCLOSURE C INCORPORATION OF TIIE FPQAP INTO Tile NMPC-QATR-1 (UFSAR APPENDIX B) Page !! of 21 4 BASIS FOR CONCLUDING TIIAT NEW Tile REVISED PROGRAM FPQAP FPQAP UFSAR CONTINUES TO SATISFY REV.2 REY.3 APP.B BTP 9.5-1 AND PAGE/ PAGE/ PAGE/ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Page 10 Page 12 Page B.2-1 Change: Reason: Basis: Section Section Section a. Revision 3 removed the word " instructions" a. Editorial. " Instructions" are a. N/A 2.2 2.2 B.2.1 between " procedures" and "and". included in the defmition of "other documents"
- b. The Revision 3 change and the FPQAP b. Editorial. The term b. N/A Section 2.2 have been superseded " instructions" has been by combining Section 2.2 into Section B.2.1. retained in Section B.2.1.
Page 10 Page 12 Table B-1 Change: Reason: Basis: Section Section 1.3 a. Revision 3 moved Section 23 to Section 1.3 a. Editorial. a. N/A 23 and updated document titles.
- b. The Revision 3 change and FPQAP Section b. Editorial. b. N/A. (See Enclosure B for Table B-1 23 have been superseded by incorporating changes.)
Figure 1.1 into Table B-1. Page 11 Page 12 Page BJ-4 Change: Reason: Basis: Section Section Section a. Section 3.1 has been renumbered B3.2.15. a. Editorial, a. N/A 3.1 3.1 B3.2.15 Page 11 Page 13 Page B3-4 Change: Reason: Basis: Section Section Section a. Revision 3 added " Applicable work a. Editorial. To clarify the use a. N/A 3.2 3.2 (Revised) B3.2.15 documents invoke design documents as of design documents as inputs necessary to ensure proper fabrication, to work documents. inspection and testing".
- b. The Revision 3 change and FPQAP Section b. Editorial. b. N/A 3.2 have been incorporated into Section B3.2.15.
Page 11 Page 13 Page B3-4 Change: Reason: Basis: Section Section Section . a. Section 33 was renumbered BJ.2.15. a. Editorial. a. N/A 33 33 B3.2.15
- - -- -- - . - . - . . . . . . . . . . - - .- .. . . . . -. .- .. - - . . - . - . - . . . - . - - . - - ~ _ . - - . .
; O O O ENCLOSURE C - INCORPORATION OF TIIE FPQAP INTO Tile NhlPC-QATR-1 (UFSAR APPENDIX B) Page 12 of 21 ; BASIS FOR CONCLUDING TilAT NEW Tile REVISED PROGRAM FPQAP FPQAP UFSAR CONTINUES TO SATISFY REV.2 REV.3 APP.B BTP 9.5-1 AND -
PAGFJ PAGFJ PAGFJ COhlMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CllANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Page !I Page 13 Page B.3-4 Change: Reason: Basis: I Section Section Section a. Section 3.4 was renumbered B.3.2.15. a. Editorial. a. N/A 3.4 3.4 B.3.2.15 Page 11 Page 13 Page B.3-4 Change: Reason: Basis: Section Section Section a. Revision 3 deleted "under the direction and a. Editorial. Implementing a. N/A 3.5 3.5 (Revised) B.3.2.15 guidance of a Fire Protection Engineer procedures dictate the review (qualified) and Quality Assurance Personael". requirements and the level of design input required,
- b. De Revision 3 change and FPQAP Section b. Editorial. b. N/A 3.5 have been incorporated into Section B.3.2.15.
Page 12 Page 13 Page B.4-2 Change: Reason: Basis: Section Section Section a. Revision 3 rewrote Section 4.0. Added a. Editorial. To clarify a. N/A 4.0 4.0 (Revised) B.4.2.8 *such as Underwriters
- Laboratories or procurement document i B.4.2.9 Factory Mutual, will be procured with the control.
Page B.4-3 required listing mark.* Also added Section " Technical changes to procurement documents B.4.2.9 are processed in a manner commensurate with that used for the original."
- b. The Revision 3 change and FPQAP Section b. Editorial. b. N/A 4.0 have been superseded by revised Sections B.4.2.8 and B.4.2.9.
Page 13 Page 13 Page B.5-1 Change: Reason: Basis: i Section Section Section a. Revision 3 deleted "by personnel designated a. Editorial. Specified in a. N/A 5.0 5.0 (Revised) B.5.2.5 by the relevant document". implementing procedures. l- b. He Revision 3 change and FPQAP Section b. Editorial. b. N/A 5.0 have been incorporated into Section B.5.2.5. I l l
,as.-- e eumeve-- w " M '=v**P4 -M^+MT9r'f*-Ww 4' !Yv*4==-erM W -e T 4 T-e 'tu W r .D-.- *eeg 6en y. g+'r---- e- c---- r' ^ '- - - - ~w +W-.- N wer- a .= **-
- mT---. w- ee
O- O O ENCLOSURE C - INCORPORATION OF TIIE FPQAP INTO Tile NMPC-QATR-1 (UWAR APPENDIX B) Page 13 of 21 BASIS FOR CONCLUDING TIIAT NEW TIIE REVISED PROGRAM FPQAP FPQAP UMAR CONTINUES TO SATISIT REY.2 REV.3 APP.B BTP 9.5-1 AND PAGE/ PAGE/ PAGF) COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BV TIIE NRC Page 14 Page 14 Page B.7-3 Change: Reason: Basis: Section Section Section a. Revision 3 provided a general rewrite of a. Editorial. a. N/A 6.1 6.0 (Revised) B.7.2.10 Section 6.0. 6.2 Page B.7-4 6.3 Section b. Revision 3 deleted the requirement for Fire b. This allows a broader base b. The established controls continue to B.7.2.10 Protection QualiSed Contractors List of suppliers, while ensure that purchased material. (FPQCL) and inserted language which served maintaining requirements for equipment, and services conform to the as the basis for the FPQCL. a listing mark (U.L. or procurement documents. F.M.) or another method of supplier qualification, or source surveillance,
- c. Revision 3 added
- General use items not c. To clarify the use of certain c. Noncritical subcomponents can be procured specifically for fire protection standard items in fire verified operable based on established applications may be used in fire protection protection systems. controls, applications. This includes items such as standard hardware items and gaskets."
- d. The Revision 3 changes and FPQAP Section d. Editorial. d. N/A 6.0 have been incorporated into Section B.7.2.10.
Page 15 Page 14 Pages B.7-3 Change: Reason: Basis: Section Section and B.7-4 a. Revision 3 incorporated Section 7.0 a. Editorial. Consolidation of a. N/A 7.0 6.0 (Revised) Section " Material Control" into Section 6.0
- Control section.
B.7.2.10 of Purchased Material, Equipment and Services."
- b. The Revision 3 change and FPQAP Section b. Editorial b. N/A 6.0 have been incorporated into Section B.7.2.10.
O O O ENCLOSURE C - INCORPORATION OF TIIE FPQAP INTO TIIE Nhil'C-QATR-1 (UFSAR APPENDIXPage B) 14 of 21 NEW BASIS FOR CONCLUDING TIIAT FPQAP FPQAP LTSAR TIIE REVISED PROGRAh! REV.2 REV.3 APP. Il CONTINUFS TO SATISFY PAGE/ PAGFJ PAGFJ BTP 9.5-I AND SECTION SECTION SECTION COMMITMENTS PREVIOUSLY IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Page 16 & Page 15 Page B.10-3 Change: 17 Reason: Basis: Section Section a. Revision 3 renumbered Section 8.0 to 7.0 Section a. Editorial. a. N/A 7.1 (Revised) B.10.2.10 " Inspection and Surveillance.* 8.1
- b. Revision 3 deleted generalinformation and b. Editerial. The general b. N/A gave more details for scope of inspections, information is contained in surveillances, and overcheck inspections. implementing procedures.
- c. The Revision 3 changes and FPQAP Section e. Editorial. c. N/A 7.1 have been incorporated into Section B.10.2.10.
Page 17 Page 15 Page B.10-2 Change: Section Reason: Basis: Section Section a. Revision 3 deleted "except as noted in a. Editorial. These exceptions a. N/A 8.2 7.2 (Revised) B.10.2.8 Paragraph 8.1 above, relating to Preventative are covered within specific hiaintenance and Operational implementing procedures for inspections / Tests." preventive maintenance.
- b. The Revision 3 change and FPQAP Section b. Editorial. The independence b. N/A
'7.2 have been superseded by Section of inspection personnel is B.10.2.8. described in Section B.10.2.8.
Page 17 Page 15 Page B.10-1 Change: Section Reason: Basis: Section Section a. Revision 3 moved Section 8.3 to Section 7.3 S.3 a. Editorial. a. N/A 7.3 (Revised) B.10.2.2 and revised section to include the term
" surveillance" where applicable,
- b. The Revision 3 changes and FPQAP Section b. Editorial. b. N/A 7.3 have been superseded by Section B.10.2.2.
O O- O ENCLOSURE C - INCORPORATION OF TIIE FPQAP INTO TIIE NMPC-QATR-1 (Ul3AR APPENDIX B) Page 15 of 21 BASIS FOR CONCLUDING TIIAT NEW TIIE REVISED PROGRAM FPQAP FPQAP UFSAR CONTINUES TO SATISFY REV.2 REY.3 APP.B BTP 9.5-1 AND PAGE/ PAGE/ PAGE/ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CIIANGE - REASON FOR CIIANGE Al' PROVED BY Tile NRC Page 17 Page 16 Page B.10-2 Change: Reason: Basis: Section Section Section a. Revision 3 deleted " Quality a. Editorial. Clarifies that a. N/A 8.4 7.4 (Revised) B.10.2.3 Assurance / Quality Control *, an! deleted " personnel" performing "overcheck inspections and NDE*, and added inspection and surveillance
" inspection and or surveillance activities" activities shall meet applicable qualifications.
t
- b. The Revision 3 change and FPQAP Section b. Editorial, b. N/A 7.4 have been incorporated in Section 10.2.3.
Page 18 Deleted Deleted Change: Reason: Basis: Figure 8.1 a. Revision 3 deleted Figure 8.1. a. Editorial. Inspection and a. N/A surveillance responsibilities are specified by implementing procedure.
- b. FPQAP Figure 8.1 was omitted from UFSAR b. Editorial. b. N/A Appendix B.
Page 19 Page 16 Page B.11-2 Change: Reason: Basis: Section Section Section a. Revision 3 renumbered Section 9.0 to 8.0 a. Editorial. a. N/A 9.1 8.1 (Revised) B.!1.2.6 " Test and Control *.
- b. Revirion 3 revised renumbered Section 8.1 b. Editorial. QA performs b. N/A by deleting "The program shall be verified audits and surveillance of all through review, audit or surveillance, based areas.
on an evaluation of pregum details."
- e. The Revision 3 change and FPQAP Section c. Editorial. c. N/A 8.1 have been incorporated into Section i 11.2.6.
, .,- - , * - -
- w*-- + -*.-a ++v-we-
- um-e a,--. -*-v -a.-u-oww .-e-, --.=n !!w- - + - - > -s-w- - . s-s s + .--r- t - - = = . ' = e- te -
---w- * .--~a - a --- - =. dens
O O O l- ENCLOSURE C - INCORPORATION OF TIIE FPQAP INTO TIIE NMPC-QATR-1 (UFSAR APPENDIX B) Page 16 of 21 i BASIS FOR CONCLUDING TIIAT NEW TIIE REVISED PROGRAh! FPQAP FPQAP UFSAR CONTINUES TO SATISFY REV.2 REY.3 APP.B BTP 9.5-1 AND PAGFJ PAGE/ PAGE/ COMAllTMEN'IS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CIIANGE REASON FOR C*IANGE APPROVED BY TIIE NRC i Page 19 Page 16 Page B.ll-2 Change: Reason: Basis: Section Section Section a. Revision 3 renumbered Section 9.2 to 8.2. a. Editorial. a. N/A 9.2 8.2 B.I1.2.6
- b. The Revision 3 change and FPQAP Section b. Editorial. b. N/A 8.2 have been incorporated into Section B .11.2.6.
Page 20 Page 16 Page B.12-2 Change: Reason: Basis: Section Section Section a. Revision 3 revised first sentence from a Editorial. a. N/A 10.0 10.0 (Revised) B.12.2.9 " Validity of measurements and test will be assured through the use of appropriate inspection." to read " Validity of inspection, surveillance and test results is assured through the use of appropriate measuring".
- b. The Revision 3 change and FPQAP Section b. Editorial. b. N/A 10.0 have been incorporated into Section B.12.2.9.
Page 21 Page 16 Page B.14-1 Change: Reason: Basis: Section Section Section a. Revision 3 renumbered Section i1.0 to 9.0 a. Editorial. Consolidation of a. N/A 11.0 9.0 (Revised) B.14.2.7 " Inspection, Test and Operating Status *. sections.
- b. Revision 3 changed " Measures shall" to b. Editorial. Better wording b. N/A '
- Measures are". for pmgram level document.
- c. The Revision 3 change and FPQAP Section c. Editorial. c. N/A 9.0 have been incorporated into Section B. I 4.2.7.
_ . _ . - . . . . _ . - _ _ _ . . ~ _ ~ _ . _ . . . _ ~ . _ . - . . _ . . . . _ _ . _ . _ - . . . . _ ._ _ . _ _ . . . _ . . - _ _- - _ , . __.
O O- O ENCLOSURE C - INCORPORATION OF TIIE FPCAP INTO TIIE NMPC-QATR-1 (UFSAR APPENDIX B) Page 17 of 21' BASIS FOR CONCLUDING TIIAT NEW TIIE REVISED PROGRAM FINAP FPQAP UFSAR CONTINUES TO SATISFY REV.2 REV.3 APP.B BTP 9.5-1 AND PAGE/ PAGE/ PAGFJ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY Tile NRC Page 22 Page 17 Page B.16-1 Change: Reason: Basis: Section Section Section a. Revision 3 renumbered Section 12.0 to 11.0 a. Editorial. a. N/A 12.1 11.1 (Revised) B.16.2.5 and changed heading to " Nonconforming Materials, Parts or Components / Corrective Action"
- b. Revision 3 Section 11.1 was revised to b. Editorial. b. N/A provide a new g:ncral description.
- c. Revision 3 Change "a" was superseded by e. Editorial, c. N/A Section B.15.0 and B.16.0. Revision 3 Change "b" and FPQAP Section 11.1 have been incorporated into Section B.16.2.5.
Page 22 Page 17 Page B.15-2 Change: Reason: Basis: Section Section Section a. Revision 3 renumbered Section 12.2 to 11.2 a. Editorial. a. N/A 12.2 11.2 (Revised) B.15.2.15 and combined former Sections 12.1 and 12.2. Page B.16-1 Section b. ' Revision 3 added "and to assure that b. Editorial. To incorporate b. N/A B.16.2.2 corrective actions are taken" to Section 11.2. Section 13.0 of Revision 2.
- c. Revision 3 Change "a" and Section 11.2 have e. Editorial. c. N/A been incorporated into Section B.15.2.15.
Revision 3 Change "b" has been superseded by Section B.16.0. i
O O O . ENCLOSURE C - INCORPORATION OF Tile FPQAP INTO TIIE NMPC-QATR-1 (UFSAR APPENDIX B) Page 18 of 21 BASIS FOR CONCLUDING TilAT NEW TIIE REVISED PROGRAM ETQAP ITQAP UFSAR CONTINUES TO SATISFY REY.2 REY.3 APP.B BTP 9.5-1 AND PAGE/ PAGFJ PAGE/ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CIIANGE REASON FOR CIIANGE APPROVED BY Tile NRC Page 22 Page 17 Page B.161 Change: Reason: Basis: Section Section Section a. Revision 3 renumbered Section 12.3 to 11.3 a. Editorial. To incorporate a. N/A 12.3 11.3 (Revised) B.16.2.5 and changed " Documentation shall identify Section 13.0 of Revision 2. the nonconforming item, describe the nonconformance and record the disposition" to " Documentation describes the condition adverse to fire protection, the nonconforming item, and records the corrective action taken."
- b. The Revision 3 change and FPQAP Section b. Editorial. b. N/A i1.3 have been incorporated into Section B.16.2.5.
Page 23 Page 17 Page B.16-1 Change: Reason: Basis: Section Section Section . a. Revision 3 incorporated Section 13.0 a. Editorial. a. N/A 13.0 11.0 (Revised) B.16.2.2 " Corrective Action" into Section 11.0
" Nonconforming Materials, Parts or Components / Corrective Action".
- b. . The Revision 3 change and FPQAP Section b. Editorial. b. N/A 11.0 have been superseded by Section B.16.2.5.
Page 24 Page 17 ' Page B.171 Change: Reason: Basis: Section Section Section ' a. Revision 3 renumbered Section 14.1 to 12.1, n. Editorial. a. N/A 14.1 12.1 (Revised) B.17.2.2 " Records".
- b. Revision 3 changed "shall* to "are". b.' Editorial. b. N/A
- e. The Revision 3 changes and FPQAP Section c. Editorial. 'c. N/A 12.1 have been superseded by Section B.17.2.2.
O O O ENCLOSURE C - INCORPORATION OF Tile FPQAP INTO Tile NMPC-QATR-1 (UFSAR APPENDIX B) Page 19 of 21 BASIS FOR CONCLUDING TilAT NEW TIIE REVISED PROGRAM FIMAP FPQAP UFSAR CONTINUES TO SATISFY , REV.2 REV.3 APP.B BTP 9.51 AND PAGE/ PAGE/ PAGE/ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CilANGE REASON FOR CilANGE APPROVED BY Tile NRC , Page 24 Page 17 Page B.17-1 Change: Reason: Basis: Section Section Section a. Revision 3 renumbered Section 14.2 to 12.2 a. Editorial, a. N/A 14.2 12.2 (Revised) B.17.2.2 " Records Control *. B.I7.2.3 ,
- b. Revision 3 replaced "nonconfonnance and b. Deviation / Event Reports b. Deviation / Event Reports are cortretive action reports
- with have replaced identifiabic and retrievable.
" Deviation / Event Reports
- nonconformance and corrective action reports.
The change reflects Deviation / Event Reports as controlled records.
- c. The Revision 3 changes and FPQAP Section c. Editorial. The c. N/A 12.2 have been superseded by Sections Deviation / Event Report B.17.2.2 and B.17.2.3. process was previously identified in the QATR.
Page 24 Page 17 Page B.17-2 Change: Reason: Basis: Section Section Section a. Revision 3 renumbered Section 14.3 to 12.3 a. Editorial. a. N/A 14.3 12.3 (Revised) B.17.2.3 " Record Retention".
- b. The Revision 3 change and FPQAP Section b. Editorial. b. N/A 12.3 have been superseded by Section B.17.2.3.
--- - _ - - - _ _ --- 7
. FIN)AP
-von WF TiiE FTQAP INTO TIIE NMPC Q, _ - - - - -
FPQAP NEW REV.2 PAGE/ REV.3 LTSAR - ATR-1 (UFSAR APPENDIX B) PAGE/ AFP, B Page 20 of 21 SECTION PAGFJ SECTION Page 25 SECTION Section Page I8 BASIS FOR CONCLUDING T ) 15.1 Section Page B.18-2 Change:IDENTIFICATION OF CIIANGE Tile REVISED PROGRAM 13.1 (Revised) Section CONTINUES TO SATISFT B.18.2.12 a. REASON FOR CllANGE BTP 9.5-1 AND Revision and revise 3 renumbered 0 to 13.0 Section Reason: 15 COMMITMENTS PREVIOUSLY i Pmgram".d title fmm " Audit
- to a."QA Audit Editorial. Basis:
APPROVED BY Tile NRC
- a. N/A b.andRevision changed w 3 renumbered on 15.1 to 13.1 Secti conducted" to "QA Audits areb.cording Editorial. from " Audits shall be onducted*. b. N/A
- c. Revision 3 Change "a* has b Page 25 by Section B.18. Revision 3 Cheen c. superseded ange "b" and Editorial.
Section Page 18 FPQAP Section e 13.1 hav be 15.2 Section Page B.18 2 into Section B.18.2.12. en incorporated
- c. N/A Section Change:
13.2 (Revised) a. B.18.2.12 Page B.18-3 Revision 3 renumbered 2 to 13.2 Section Reason: 15 Section B.18.2.12 included frequencies, three bullets 2 that showiand
- a. Editorial, deleted the first paragraph of 15 Basis:
- ng audit program
- a. N/A
- b. Revision 3 added " Fire Pr Audits are performed per the reotection Pmgram the applicable Technical Squirements of b. Editorial.
pecincations: Unit-1 6.5.3.8.g. 6.13.1 and 613
, b. N/A Unit-2 6.5.3.8.k,6.5.3.81 .,
. 2 andand 6 5 c.
3.8.m". Revision 3 incorporated footnote regarding NRC Generic Letter Section 13.2. 82-21 into renumbered c. Editorial.
- c. N/A
- d. The Revision 3 changes and F 13.2 have been incorporated intPQAP Section B.18.2.12. o Section d. Editorial.
- d. N/A d
I
O O 1 O \ ENCLOSURE C - INCORPORATION OF Tile FPQAP INTO TIIE NMPC-QATR-1 (UFSAR APPENDIX B) Page 21 of 21 FPQAP NEW FPQAP REY.2 UFSAR REV. 3 PAGFJ PAGFJ APP.B BASIS FOR CONCLUDING TilAT SECTION PAGFJ Tile REVISED PROGRAM j SECTION SECTION CONTINUES TO SATISIT Page 25 l IDENTIFICATION OF CIIANGE BTP 9.S-1 AND Page 18 Section Page B.18-3 Change: REASON FOR CilANGE COMMITMENTS PREVIOUSLY Section 15.3 Section a. APPROVED BY Tile NRC ( 13.3 (Revised) Reason: B.18.2.12 Revision 3 renumbered Section 15.3 to 13.3
- a. Editorial. Basis:
" Audit Results" and added "and the Safety a. N/A Review and Audit Board (SRAB)".
- b. The Revision 3 change and FPQAP Section 13.3 have been incorporated into Section b. Editorial.
B.18.2.12. b. N/A Page 26 Page 9 Page B 2-1 Attachment i Section Change: Section a.
1.1 Reason
B.2.1 Revision 3 revised Section 1.1 to further Basis: a. expand the Fire Protection Program Editorial Incorporated into
- a. N/A description and deleted Attachment 1, whichSection 1.1.
contained redundant information.
- b. The Revision 3 change and Section 1.1 have been superseded by Section B.2.1. Sectionb. Editorial. The scope of the b. N/A Fire Protection Program is B.2.1 was revised to include a reference to the Unit i UFSAR Appendix 10A and Unit 2 describedin Unit 1 UFSAR Page 27 USAR Appendix 9A. Appendix 10A and Unit 2 Deleted Deleted USAR Appendix 9A. Change:
Reason:
- a. Revision 3 deleted Attachment 2. a. Basis:
Revision 3, Section 6.0, was revised to delete the FPQCLa. The established controls continue to and incorporated the root casure that purchased material, requirements for the list. equipment, and services conform to the procuremerit documents.
- b. UFSAR FPQAP Attachment Appendix B. 2 was omittedb.from Editorial.
- b. N/A
1 1 O O ~ O. ENCLOSURE C - INCORPORATION OF Tile FPQAP INTO Tile NMPC4]ATR-1 (UFSAR APPENDIX B) Page 20 of 21 BASIS FOR CONCLUDING TilAT NEW TIIE REVISED PROGRAM FPQAP FPQAP UFSAR CONTINUES TO SATISFY REV.2 REV.3 APP.B BTP 9.5-1 AND PAGE/ PAGE/ PAGE/ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CllANGE REASON FOR CIIANGE APPROVED BY TIIE NRC Page 25 Page 18 Page B.18-2 Change: Reason: Basis: Section Section Section a. Revision 3 renumbered Section 15.0 to 13.0 a. Editorial. a. N/A ' 15.1 13.1 (Revised) B.18.2.12 and revised title from " Audit" to "QA Audit - Program" , i
- b. Revision 3 renumbered Section 15.1 to 13.1 b. Editorial. b. N/A and changed wonling from " Audits shall be conducted
- to "QA Audits are conducted".
- e. Revision 3 Change "a" has been superseded c. Editorial. c. N/A l y Section B.18. Revision 3 Change "b" and FPQA.P Section 13.1 have been incorporated I into Section B.18.2.12.
Page 25 Page 18 Page B.18-2 Change: Reason: Basis: Section Section Section a. Revision 3 renumbered Section 15.2 to 13.2 a. Editorial. a. N/A 15.2 13.2 (Revised) B.18.2.12 and deleted the first paragraph of 15.2 that Page B.18-3 included three bullets showing audit program Section frequencies, B.18.2.12
- b. Revision 3 added " Fire Protection Program b. Editorial. b. N/A Audits are performed per the requirements of the applicable Technical 5pecifications:
Unit.1 6.5.3.8.g. 6.13.1, and 6.13.2 and Unit-2 6.5.3.8.k, 6.5.3.8.1. and 6.5.3.8.m".
- c. Revision 3 incorporated footnote regarding e. Editorial. c. N/A NRC Generic Letter 82-21 into renumbered Section 13.2.
- d. The Revision 3 char- and FPQAP Section d. Editorial. d. N/A 13.2 have been incorporated into Section B.18.2.12.
. . . . . - - . ~ . _ - . - . , , . - - , . - . ,.-_ - .- - - . _ . - - -.- . - . - _ ~ . . . - . - , . - , . . _ . . _ _ _ . . . ._
O O O ENCLOSURE C - INCORPORATION OF Tile FPQAP INTO T!IE NMPC-QATR-1 (UFSAR APPENDIX B) Page 21 of 21 BASIS FOR CONCLUDING TilAT NEW TIIE REVISED PROGRAM FPQAP FPQAP UFSAR CONTINUES TO SATISFY REY.2 REV.3 APP.B BTP 9.5-1 AND ! PAGE/ PAGE/ PAGE/ COMMITMENTS PREVIOUSLY SECTION SECTION SECTION IDENTIFICATION OF CilANGE REASON FOR CilANGE APPROVED BY Tile NRC Page 25 Page 18 Page B.18-3 Change: Reason: Basis: Section Section Section a. Revision 3 renumbered Section 15.3 to 13.3 a. Editorial. a. N/A 15.3 13.3 (Revised) B.18.2.12
- Audit Results" and added "and the Safety Review and Audit Board (SRAB)"
- b. The Revision 3 change and FPQAP Section b. Editorial. b. N/A 13.3 have been incorporated into Section B. I 8.2.12.
Fage 26 Page 9 Page B.2-1 Change: Reason: Basis: Attachment 1 Section Section a. Revision 3 revised Section 1.1 to further a. Editorial. Incorporated into a. N/A 1.1 B.2.1 expand the Fire Protection Program Section 1.1. description and deleted Attachment 1, which contained redundant information.
- b. The Revision 3 change and Section 1.1 have b. Editorial. The scope of the b. N/A been superseded by Section B.2.1. Section Fire Protection Program is B.2.1 was revised to include a reference to described in Unit 1 UFSAR the Unit 1 UFSAR Appendix 10A and Unit 2 Appendix 10A and Unit 2 USAR Appendix 9A. USAR Appendix 9A.
Page 27 Deleted Deleted ' Change: Reason: Basis: Attachment 2 a. Revision 3 deleted Attachment 2. a. Revision 3, Section 6.0, was - a. The established controls continue to revised to delete the FPQCL ensure that purchased material, ; and incorporated the root equipment, and services conform to the requirements for the list. procurement documents.
- b. FPQAP Attachment 2 was omitted from b. Editorial. b. N/A UFSAR Appendix B.
_ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ . _ ~ _ . . _ . _ . . ._. _ _ _ - . ._ _ _ - . . - - _ - _- - ..}}