ML20059C642
| ML20059C642 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 12/22/1993 |
| From: | Hebert J Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20059C645 | List: |
| References | |
| JRH-93-271, MN-93-121, NUDOCS 9401050584 | |
| Download: ML20059C642 (8) | |
Text
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- i MaiheYankee O
REl. LAB 1E ELECT A.lCITY SMCM9)).
EDISON DRIVE + AUGUSTA, MAINE 04330 * (207) 622-4868 L
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December 22, 1993
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MN-93-121-
'JRH 271
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. UNITED' STATES NUCLEAR REGULATORY COMMISSION Attention:. Document Control Desk-Washington, DC.20555 (a)
License No. DPR-36 (Docket No. 50-309)
Reference:
Subject:
Maine Yankee Operational Quality. Assuran ce Program - Rev. 8
. Gentlemen:
Enclosed is< Revision 8 of the Maine Yankee Operational Quality Assurance Program for your information. Change number one (1) and two (2) of Section I are being submitted as a' reduction in commitment-to the Operational Quality-Assurance Program.(0QAP) document. A summary of_the substantive changes is also included. We plan to implement these. changes upon receipt of NRC'
- approval. or 60 days after submittal to the Commission, whichever occurs first.
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If you have any questions regarding the content of the program revision,
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Q please contact J. C. Frothingham, (207) 882-6321,' ext.'5820.
p Very truly yours,
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James R. Hebert, Manager
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Licensing & Engineering' Support Department SJB/ jag Enclosure
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Mr. Thomas T. Martin Mr. E. H. Trottier Mr. J. T. Yerokun Mr. Plackeel' K. Eapen i
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OPERAT10NAL QUALITY ASSURANCE PROGRAM
. SUNWIARY OF SUBSTAN11AL CHANGES FOR REV. 8 The following changes are being submitted in accordance with 10CFR50.54(a)(3).
SECTION 1.
Change number one (1) and two (2) are being submitted as a reduction in commitment to the Operational Quality Assurance Program (OQAP) document.
Therefore, included with these changes as required are the following:
All pages affected by the change are attached and indicated by brackets.
Identification of the changes.
The reason for the change.
The basis for conduding that the revised program incrarporating the changes i
continues to satisfy the criteria of 10CFR50, Appendix B and the Safety Analysis Report quality assurance program description commitments previously accepted by the NRC.
1.
IDENTIFICATION OF THE CHANGE:
Section lil, remove Step B.1.b, which currently requires the Quality Programs Department (QPD) to perform in-line reviews of Engineering Design Change Requests (EDCRs) and major changes to EDCRs (ECNs).
REA?ON FOR THE CHANGE:
i The Maine Yankee Quality Programs Department (QPD) currently performs in-j line reviews of all ECCRs and major changes to EDCRs to meet the requirements of Section lil, Step B.1.b of the OQAP.
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The OPD in-line EDCR revicx function is in addition to the following OQAP specified reviews and approvals:
o Independent engineering design verification performed by Yankee Nudear Services Division.
o The Licensing and Engineering Division is responsible for preparation, review and approval of design docurnents.
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Plant Manager /PORC review and approval.
o Vice President, Operations review and approval.
QPD performs the following additional quality verification activities associated with the design control process.
o QPD performs in-line reviews of safety dassified procurement docurnents associated with design changes, as specified in Section IV, Steps B.1.b and c of the OQAP.
o QPD performs in-line reviews of safety dassified modification implementation instructions, i.e., Design Change installation Instructions, in accordance with Section VI, Step B.1.c of the OOAP.
o QPD performs evaluations and audits of the design control system as j
specified in Section lil, Step B.1 of the OQAP.
Based on the number of existing EDCR in-line reviews and QPD involvement in several aspects of the design process, QPD in-line reviews of EDCRs and major changes to EDCRs is not deemed to be warranted. Siminating QPD's in-line review of EDCRs will enable QPD's resources to be utilized in other higher value activities.
BASIS FOR CONCLUDING THAT THE REVISED PROGRAM INCORPORATING THE CHANGE CONTINUES TO SATISFY THE CRITERIA OF APPENDIX B AND THE SAFETY ANALYSIS REPORT QUALIT/
ASSURANCE PROGRAM DESCRIPTION COMMITMENTS PREVIOUSLY ACCEPTED BY THE NRC:
The section of 10CFR50, Appendix B, Criterion 111 addressing the design change review function states: "The verifying or checking process shall be performed by individuals or groups other than those who performed the original design, but who may be from the same organization." The independent engineering design verification performed by Yankee Nudear Services Division as defined in Section Ill of the OQAP continues to satisfy the 10CFR50, Appendix B, Criterion ill design review requirements.
Of the ANSI standards and regulatory guides committed to in Section ll of the OQAP, only ANSI N45.2.11, Quality Assurance Requirernents For The Design Of Nudear Power Plants, addresses the design change review function. ANSI N45.2.11 states in-part " Design verification shall be performed by any competent individuals or groups other than those who performed the original design but who may be from the same organization." The independent engineering design verification performed by Yankee Nudear Services Division I
as defined in Section 111 of the OQAP continues to satisfy this requirement.
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2.
IDENTIFICATION OF THE CHANGE-Appendix B, step ll.R., remove, " Heat Tracing for Boric Acid injection." and i-l replace with," Heat Tracing for Post Accident Hydrogen Monitoring."
l REASON FOR THE CHANGE:
This change was requested by Maine Yankee Corporate Engineering, consistent with their responsibility for establishing and maintaining documentation which designates the safety dassification of plant systems.
Maine Yankee Technical Evaluation number 23A89 was completed by Engineering, which indudes the following information:
IEEE Standard 622,1987, section 4.3.1 states, "It is the recommendation of this document that electrical heat tracing systems not be dassified as Class 1E systems and that critical process control systems be powered from reliable station power sources."
For critical process piping, heat tracing systems, dassified Category 1 in Maine Yankee Specification (MYS) 3908, redundant power sources are utilized at Maine Yankee, and they are powered from emergency buses. These redundant trains (A and B) consist of a primary theimostat at a setpoint, secondary (backup) thermostats set at a lower setpoint, and individual heaters for each train. Alarm ind:'.ation is also provided. For freeze protection, dassified as category 2 in MYS 3908, a single power train is spacified.
I Although a single power supply is specified, at Maine Yankee we have assured that the single train which powers certain freeze protection lines are powered i
off an emergency bus to ensure its operating reliability.
J IEEE Standard 622,1987, section 4.3.1 states, " The recommendation for not dassifying electrical heat tracing systems as dass 1E is based on station -
j operating criteria in that electrical heat tracing systems, even as applied on reactor injection systems, do not perform any emergency functions either during or after a postulated loss of coolant accident (LOCA). Instead, electric heat tracing systems render such piping systems operable during normal station operation and thus are not needed during or after a postulated LOCA. For further discussions and technical explanations on normal and accident station L i
operations with respect to non Class 1E heat tracing systems, refer to Appendix B."(Appendix B of IEEE Std 622,1987) i "An exception to this recommendation is the dassification of electric heat tracing systems applied on post accident sampling systems. Such post accident sampling systems were mandated by the Nudear Regulatory
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after this standard was first published in 1979." (Explanation of these requirements may be found in Appendix C of IEEE Std 622,1987) i At Maine Yankee, the heat tradng for the Hydrogen Analyzer sample lines is in agreement with this 1E dassification.
BASIS FOR CONCLUDING THAT THE REVISED PROGRAM INCORPORATING THE CHANGE CONTINUES TO SATISFY THE CRITERIA OF APPENDIX B AND THE SAFETY ANALYSIS REPORT QUALITY ASSURANCE PROGRAM DESCRIPTlON COMMITMENTS PREVIOUSLY ACCEPTED BY THE NRC:
Review of 10CFR50 Appendix B, ANSI N45.2.4 and Standard Review Plan 17.1, section ll.3A revealed no specific requirements regarding dassification of heat tracing systems.
10CFR50 Appendix B does state, " Measures shall be established to assure that applicable regulatory requirements and design basis, as defined in 50.2 and as specified in license application, for those structures systems, and components to which this appendix applies are conectly translated into specifications, drawings, procedures, and instructions. These measures shall indude provisions to ensure that appropriate quality standards are specified and induded in design documents and that deviations from such standards are controlled."
j This change is adding a system which was not previously induded but is directed to be induded as a 1E system by IEEE Std 622,1987. At the same time Maine Yankee would like to remove reference to other heat tracing systems (Heat Tracing for Boric Acid injection) as 1E, recommended by IEEE Std 622,1987. As specified in 10CFR50 Appendix B, criteria 111., this change is an effort to, " ensure that appropriate quality standards are specified."
j Also, as specified in 10CFR50 Appendix B, criteria Ill.." deviations from such standards are controlled", this criteria continues to be satisfied in that this change must be approved via a Maine Yankee Technical Evaluation. Technical Evaluation 236-89 has been completed, which indudes much of the information presented with this change. In addition, in order for this change to be made to the Operational Quality Assurance Program, it must be revieved and approved by the NRC.
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l SECTION ll.
The changes identified in this section do not constitute a reduction in commitment.
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l-Induded with each of these changes are the following:
1 Identification of the change.
Reason for the change.
l All pages affected by the change.
i 1.
Identification of Chanae: In the sign-off page, added G.M. Leitch as Vice President, Operations.
Reason For Chanae:
The position was vacant when revision 7 to the program was submitted and has since been filled.
1 2.
Identification of Chanae: In the sign-off page, removed the sign-off for the Vice President, Public & Govemmental Affairs.
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Reason For Chanae:
This position has been vacated and subsequently
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removed from the organizational chart.
i 3.
Identification of Chanae: Section I.B. third paragraph, removed reference to the Vice President of Public and Govemment Affairs.
Reason For Chance:
This position has been vacated and subsequently
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removed from the organizational chart..
i 4.
Identification of Chanae: Section I., organizational chart, removed the Vice President of Public and Govemment Affairs. As a result, the General Counsel and Manager, Public Affairs report directly to the Pasident and Chief Executive Officer.
Reason For Chanae:
The position of Vice President of Public and Govemment Affairs has been vacated and subsequently removed from the organizational chart.
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identification of Chanae: Section I., organizational chart, The Manager Financial Services is now the Treasurer / Manager Financial Services.
Reason For Chanae:
Consolidation of positions.
6.
Identification of Chanae: Section ll.C.4)b), added "in accordance with 10CFR50.4 (b)(7) and 50.54(a)(3)".
Reason For Chanae:
To ensure that changes to the program which involve a reduction in commitment are prepared and submitted as required.
7.
Identification of Chanae: Section VI.B.1 changed Administration Department to Finance and Administration Division.
Reason For Chanae:
This change was incorporated, as an effort continued from revision 7 of this program, to elevate the level of responsibility from the departrnent to the division level throughout the program document.
l 8.
Identification of Chanae: Section VI.B.2., transferred responsibilities for steps 2 a, b, e and f to the Operations Division, new step VI.B.5, and renumbered as appropriate.
l Reason For Chanae:
The Operations Division has' assumed responsibility I
for those items from the Administration Department.
9.
Identification of Chance: Section XII.B.2., changed Maintenance Department to Operations Division.
Reason For Chanae:
This change was incorporated, as an effort continued from revision 7 of this program, to elevate the level of responsibility from the department to the division level throughout the program document.
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I 10.
Identification of Chanae: Appendix B, step V.19 was added to incorporate the Station Blackout Equipment.
Reason For Chanae:
Not previously induded in the program docurnent.
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